IR 05000458/1989016

Insp Rept 50-458/89-16 on 890327-31.Violation Noted.Major Areas Inspected:Inservice Testing Program,Including Program Test Procedures & Test Results for Pumps & Valves & Followup of Svc Water Corrosion Problems

ML20246G222
Person / Time
Site:	River Bend
Issue date:	05/01/1989
From:	Barnes I, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246G210	List: IR 05000458/1989016 ML20246G208 ML20246G213
References
50-458-89-16, NUDOCS 8905150223
Download: ML20246G222 (9)

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APPENDIX B

.U.S. NUCLEAR' REGULATORY COMMI'SSION (. , REGION:I NRC Inspection' Report: 50-458/89-16 Operating License: NPF-47-

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Docket:. 50-458 Licensee: Gulf States Utilities Company (GSU)

P;0. Box 220 St. Francisville, LA 70775

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Facility.Name: River Bend Station (RBS)

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. Inspection.At: RBS, St.'Francisville, LA Inspection Conducted: March 27-31,1989

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Inspectors: Nw> 5-i-s9 psR.C. Stewart,ReactorInspector, Materials Date e and Quality Programs Section, Division of Reactor' Safety

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$.~m I. Barnes, Chief, Materials .and Quality-s:- 1 - & 9 Date Programs Section Division'of Reactor-Safety Approved: u 31 ,+, s- i - E' 9 I. Barnes, Chief, Materials. and Quality

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Date-Programs'Section, Division of Reactor Safety

l Inspection Summary j Inspection Conducte'd March 27-31,1989.(Report 50-458/89-16)  !

Areas Inspected:. Routine, unannounced' inspection of j inspection findings, the RBS inservice testing (IST) previously identified

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program test procedures- !

and test results for pumps; and valves,.and followup on service water corrosion y problem Results: In the area of licensee actions on previous inspection findings, one violation.was identified (paragraph 2) regarding the failure-to impose 10 CFR Part 21 requirements in a procurement of;0konite tape and cement with specified 1 environmental qualification requirement q l

J 8905150223 890502 PDR ADOCK 05000458 <

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, 1 In the-area of IST performance, the licensee's test procedures appeared to be well detailed in addressing ASME Section XI Code requirements. Leak rate testing of category valves and the disassembly / inspection of specified Type C check valves were conducted in accordance with approved procedures and appeared to meet the ASME Section XI Code requirements for these activities. However, several IST pump and valve tests scheduled during this inspection period were delayed because_of other plant outage priorities. Therefore, a meaningful assessment of test performance could not be mad Followup on service water corrosion problems identified that the licensee has implemented significant enhancements in water treatment practices and chemistry .,

controls during 1987 and 1988. Appropriate cleaning and life extension program I

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actions were observed to be underway with respect to service water heat exchangers. Inspection followup items were identified with respect to:.

(a) actions and criteria used with respect to assessment of ultrasonic examination results on service water piping welds, (b) review of ultrasonic examination results on fire protection system piping, (c) verification of actions taken in regard to service water isolation valves, and (d) review of long-term program actions in regard to systems and components impacted by corrosion product buildu No violations or deviations were identifie ,

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DETAILS L .1.- Person Contacted a '

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GSU t'

• J. C. Deddens. Senior Vice President

• T. F. Plunkett, Plant Manager

• M. F. Sankovich Manager, Engineering Department

• T. L. Crouse, Manager,-Quality Assurance (QA)

- *K. F. Suhrke, Manager, Project Management

• J. E. Booker, Manager,. River Bend Oversight 5

• L. A. England Director, Licensing

• W. H. Odell, Manager, Administration

• G. Mahan, Senior Welding Engineer

• J. R. Hamilton, Director, Design Engineering

• T. L. Weir, Director, Materials Management

• M. S. Feltner,' Engineer - Nuclear Licensing

• A. J. Kugler, Process' System Supervisor

• J. W.' Cook, Lead Environment Analyst - Licensing NRC I

• E. J. Ford, Senior' Resident Inspector

• W. B. Jones, Resident Inspector L

• Denotes attendance at exit interview conducted on March 31, 198 . Licensee Actions on Previous Inspection Findings (92701)  ! (Closed)OpenItem(458/8726-02): GSU's " Pump and Valve Inservice

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Testing Plan . River Bend Station - First 10 Year-Interval,"

Revision 3, NRC correspondence dated August 31, 1987, denied relief request for pump relief No. 2, and valve relief request Nos. 24, 35, and portions.of 3 j During this inspection, the NRC inspector reviewed the specific issues involved in the relief request denials noted above. The NRC inspector observed that a working meeting was held on December 15-16, 1987, with the licensee, NRC, and EG&G personnel attending, to discuss outstanding issues, including relief request Nos. 2, 24, 31, and 3 The results of these discussions have been incorporated in the licensee's current Revisien 5 to the IST Program Plan, dated March 22, 1988. This item is considered close (Closed)UnresolvedItem(458/8825-01): This item required further

' review of the GSU procurement practice for Okonite tape and cement l

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-4-l because of questions regarding classification of the materials as a basic component and compliance of the procurement practice with 10 CFR Part 2 TheNRCinspectorreviewedPurchaseOrder(P0)8-10-72689 dated July 15, 1988 (and three subsequent revisions to the P0 dated through'

January 23,1989) to the Okonite Company for the supply of nuclear

' jacketing' tape, nuclear hi-voltage splicing tape, and nuclear splicing cement. The P0 defined that the products were safety-related..that no QA program was applicable, and that the vendor was. required to certify both that the material was commercial grade and that the supplied material was-identical to that in Okonite Qualification Report NQRN-3. The provisions of 10 CFR Part 21 were

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not' imposed in the P0. The NRC inspector identified to licensee personnel that invoking environmental qualification requirements in the' P0 classified the items as a basic component (as defined by 10'CFR Part 21), and for which the regulation required that the provisions of 10 CFR Part 21 be imposed in the P0. Licensee personnel-informed the NRC inspector that the vendor would not accept 10 CFR Part 21 applicability as' a procurement requirement, the products had been certified to be commercial grade, and that the dedication process used for these materials was consistent with the NRC-conditionally endorsed EPRI NP-5622, " Guidelines for the Utilization of Commercial Grade Items in Nuclear Safety-Related  !

Applications (NCIG-07)."

It was ascertained from discussion with licensee personnel that the dedication process relied, in part, on a GSU source surveillance that was performed at two Okonite facilities during July 20-21, 198 This surveillance identified that no changes in technical requirements had taken place since the last GSU PO which invoked 10 CFR Part 50, Appendix B requirements. The surveillance report also indicated that: (1) The manufacturing standards and specifications had not been revised, (2) Okonite procurement practices required use of approved vendors and furnishing of certificates of conformance or certified test reports, and (3) varying levels of receipt testing of in oming products were performe The NRC inspector did not establish the reasons for the existing Okonite QA program not being invoked in the P0 if its use was to be a basis for a "like for like" dedication, other than the surveillance was actually performed after placement of the P0. It was also not ,

apparent whether the existing QA program in place at Okonite was essentially the same as when purchase orders invoking 10 CFR Part 50, Appendix B requirements had been accepted, or whether subsequent reductions in QA program controls had occurred. The NRC inspector considered that the procurement approach had technical merit for the particular circumstances, if appraisal of traceability of materials to batches subjected to environmental qualification type testing had been performed prior to procurement and appropriate procurement t

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-5- f requirements invoked. The procurement in question invoked, however, unique nuclear specification requirements without imposing 10 CFR Part 21, which is an apparent violation of Section 21.31 of 10 CFR Part 21 (458/8916-01). Followup of IST (73756)

During this inspection, the NRC inspector conducted a followup review of l the licensee's implementation of the IST program procedures for safety-related pumps and valves. The results of prior NRC review of the River Bend IST program are documented in NRC Inspection Report 50-458/89-06. The objectives of this inspection were to assess the adequacy of the functional testing performed with respect to this licensee's commitments and requirements of Section XI of the ASME Cod Pump Testing - No test was conducted by the licensee during this inspection period, Valve Stroke Time Testing - No valve stroke timing was witnessed by the NRC inspector during this inspection perio Category C Check Valve Disassembly / Inspection - Section XI of the ASME requires check valves to be exercised to the positions in which they perform their safety functions. However, for some check valves, the licensee cannot practically establish or verify sufficient flo to full-stroke exercise the valves open. The NRC staff position is that valve disassembly and inspection can be used as a positive means ,

of determining that a valve's disk will full-stroke exercise open or

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of verifying closure capability, as permitted by IWV-3522 Section XI ASME Cod .

During this inspection period (plant outage), numerous safety-related check valves, identified in the RB IST program, were scheduled to be disassembled / inspected; however, because of the licensee's work schedule slippage, the NRC inspector witnessed only one check valve disassembly / inspectio On March 29, 1989, the NRC inspector witnessed the disassembly and ;

inspection of Check Valve 1E12*VF084A, conducted under maintenance Work Order 123303. During the work activity, the NRC inspector reviewed RB Procedure CMP-9173, " Check Valve Rework," Revision 3, dated January 20, 1988. CMP-9173 provides the general instructions for the removal, disassembly, inspection, rework, reassembly, and installation of check valves. In addition, the NRC inspector reviewed Work Order 123303 and observed the stcp-by-stop process prescribed in the work order, including the QC inspection process i sign-off where applicabl No violations or deviations were identified.

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.ii d., ValveLeakRateTesting-CertainISTCategoryAvalves-(valvesfor which seat leakage _1s limited to a specific maximum amount in the closed position) are tested at each refueling outage in accordance with 10 CFR 50, Appendix J as identified in the RB IST program plan, relief request No. 31. During this inspection, the NRC inspector-reviewed the test procedures ~and leak test results for the following:

STP-602-3825,'" Fuel- Pool Cooling Valve Leak Rate Test,"

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Revision 1, dated December 28, 1988. (Eight containment  !

isolationvalves)

No violations,or deviations were identifie . Followup'on Service Water (SW) System Corrosion Problems (9E701) Background

..During this inspection, a followup was made regarding SW system corrosion problems that had been encountered at RBS. As'a result of review with licensee personnel .it was ascertained that-the following'

e types of conditions had been identified, j (1) Pinhole leaks .had been discovered in the SW outlet line from HVK Chiller B and a SW supply line to:the EHC skids, both of.which

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were associated with elbow to pipe welds. In the. case of the

.HVK Chiller B SW outlet line, a licensee inspection had identified that the leak was associated with pitting in the heat affected zone of a shop fabricated weld, and that the pitting was located under a tubercule of approximately 1 1/2 inch diameter. The inner contents of the tubercule were noted to emit a' sulfur odor, which suggests that the attack mechanism was microbiological 1y induced corrosion resulting from the presence of sulfate reducing bacteri (2) Leakage was found in a SW piping expansion' joint, which inspection indicated was the result of galvanic corrosion between dissimilar metals;.i.e., austenitic stainless steel i bellows welded to a carbon steel flang ,

(3) Other examples of corrosive attack were found which were associated with dissimilar metal combinations present in components; e.g., residual' heat removal heat exchangers,

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hydrogen cooler (4) Local leak rate test failures of SW isolation valves had occurred as a result of accumulation of corrosion products in the valve SW Treatment Practices From discussions with licensee personnel, it was ascertained that shallow well water of low pH had been used in 1985 for testing, which

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in the NRC inspector's judgement may have been a contributory factor ^ '

to establishment of bacteria that subsequently produced observed

. pitting >in SW piping. During unit' operation, a biocide (sodiu j hypochlorite) has been added to the.SW and circulating water (CW). I systems to minimize fouling and preclude development of Asiatic l clams.- An automated system for control of total residual chlorine- l levels is nearing completion. Control of pH is maintained by

. sulfuric acid additions. Review of.pH data showed that excursions into the acidic range occurred during 1987 and that the pH value tended to be lower in the SW system than the CW system in this time period.- In November 1987, a permanent modification was completed which provided for automated control of pH. Review of pH data showed that an improving trend of pH control occurred after th modification, with pH being maintained consistently in a narrow band after relocation of the acid addition poin In December 1987, the ;

licensee also initiated a corrosion control program utilizing a '

carbon steel corrosion inhibitor. In late 1988, a change in inhibitor was made with the effectiveness being monitored utilizing test samples in the syste ~ Review of Licensee Actions on SW System Piping and Components Licensee personnel outlined the inspection, cleaning, ~and life extension actions being taken on the SW system during a meeting held on March 27, 1989. The actions included: (1) replacement of Auxiliary Building unit cooler internals, with a change to a copper header (from the original mild steel) to eliminate a dissimilar metal interfacewiththecoppertubes;(2)cleaningofheatexchangersand use of coatings to minimize galvanic corrosion between dissimilar raetal combinations; (3) use of sacrificial anodes to~ minimize component corrosion; and (4) detection of any other through wall leaks in the standby SW system by a 100 percent visual inspection of welds as part of the inservice inspection progra The NRC inspector and the NRC resident inspectors had the following ,

four basic areas of concern relative to the information provided by  !

the licensee: i (1) Reliance on visual inspection of standby SW piping welds for detection of through wall leaks gave no meaningful information regarding the condition of the piping and the Normal and Standby

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SW systems. As a result of this concern, the NRC inspectors requested the NRC Nondestructive Examination (NDE) van (which was performing a concurrent inspection of inservice inspection, modification activities, and NDE practices) to perform a radiographic examination of a sample of SW piping welds in available drained lines, in order to ascertain whether there was any evidence of significant corrosion present. Only cne drained

.line (i.e., 1-SWP-025-310-3, ASME Code Section III, Class 3, 2 1/2 inch) was identified. Five shop fabricated welds in this

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line were radiographically examined by the NDE van, the results of which indicated significant through wall corrosion in two of j the welds (Shop Welds 1 and 4). This method of examination does i not allow quantitative assessment of wall thickness loss, but was estimated by NDE van to be in excess of 50 percent of wal In a postexit meeting with licensee personnel.on March 31, 1989, ,

the NRC inspectors were informed that a sample of SW welds in !

locations with different flow conditions (i.e., from stagnant to I high flow) would be subjected to ultrasonic examination during :

the outage to provide quantitative information on the extent of !

corrosion damage present. Information was not provided at this l time with respect to how the examination results would be assessed in terms of needed repairs and criteria for escalating examination sample size. This subject is considered to be an inspector followup item (458/8916-02).

(2) The NRC Inspectors questioned the status of fire protection system piping which it was understood had been filled initially with shallow well water. Licensee personnel informed the NRC inspectors that a sample of areas had been ultrasonically examined for minimum wall conditions present during the first refueling outage, with no problems identified. A repeat examination was being performed during the current outage to .i further check the status of this piping. Review of the ultrasonic examination results is considered to be an inspector-followup item (458/8916-03). [

(3) The local leak rate test failures of isolation valves, as a result of. corrosion product buildup, was questioned in terms of what actions would be taken to preclude future failures-resulting from renewed buildup during system operatio Licensee personnel infonned the NRC inspectors that header cleaning would be performed during this outage with the isolation capability of the valves being checked during a planned mid-cycle outage. Verification of these actions is I considered an inspector followup item (458/9916-04).

i (4) The NRC inspectors questioned licensee personnel in terms of (

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program actions to be taken regarding systems and components impacted by SW corrosion product buildup in small bore piping and instrument lines. Ongoing cleaning actions were discussed but a long-term program was not fully articulated. Review of program actions in this area is considered an inspector followup item (458/8916-05). Exit Interview The NRC inspectors met with the licensee representatives denoted in paragraph 1 on March 31, 1989, and summarized the inspection scope and findings. The NRC inspectors indicated that the additional test

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n: implementation reviews of the IST program will be conducted during a subsequent NRC inspection. No information was presented to the NRC inspectors that was identified by the licensee as proprietary. In a pos,texit meeting, licensee personnel gave a review of planned SW system actions.:

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