IR 05000324/1987021

Insp Repts 50-324/87-21 & 50-325/87-21 on 870706-10.No Violations or Deviations Noted.Major Areas Inspected:Actions Taken to Implement Generic Ltr 84-11 Re Insps of BWR Stainless Steel Piping

ML20236L517
Person / Time
Site:	Brunswick
Issue date:	07/28/1987
From:	Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236L485	List: IR 05000324/1987021 ML20236L483
References
50-324-87-21, 50-325-87-21, GL-84-11, IEB-82-03, IEB-82-3, IEB-83-02, IEB-83-2, NUDOCS 8708100274
Download: ML20236L517 (13)

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UNITED STATES l g'o,, NUCLEAR REGULATORY COMMISSION 2* REGION il l

~* . $. 101 MARIETTA STREET, N.W., SUITE 2900 .

o f ATLANTA, GEORGI A 30323 I

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Report Nos.: 50-325/87-21 and 50-324/87-21 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 ,

Facility Name: Brunswick 1 and 2 Inspection Conducted: July 6-10, 1987 Inspector: , ,

Lo 7!2.f R) l J. L. Coley /

U Date Signdd Approved by: , [- O b, 7 2_9 Y )

J. J. Blake, Chief Materials and Processes Section

/ V Date Signed Division ,f Reactor Safety SUMMARY Scope: This routine, announced inspection involved a review of actions taken to implement Generic Letter 84-11 concerning inspections oT boiling water reactor stainless steel pipin )

Results: No violations or deviations were identified, i

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REPORT DETAILS

Persons Contacted Licensee Employees

• R. Dietz, General Manager

• E. A. Bishop, Manager Operations

• R. Eckstein, Manager, Technical Support

• L. Parks, Supervisor, Engineering

• J. O'Sullivan, Manager, Maintenance

• L. E. Jones, Director, QA/QC

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• R. M. Poulk, Senior Regulatory Compliance Specialist

• L. Wheatley, Inservice Inspection (ISI) Project Engineer 1 1 NRC Resident Inspector i

• B. Ruland, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summerized on July 10, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during this inspectio . Inspection Scope and Objectives Background Inspections conducted at several BWR facilities as a result of IE Bulletins 82-03, Revision 1, and 83-0? and the NRC August 26, 1983 Orders revealed intergranular stress corrosion cracking (IGSCC) in large diameter recirculation and residual heat removal piping l

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system The results of these inspections led to an ongoing program j for similar inspections at all operating BWRs. Repairs, analysis, '

and additional surveillance may be required to ensure the integrity of the susceptible piping in those areas where IGSCC is discovered or indicated by nondestructive examinatio Basic Requirements The items to be verified have been divided into several areas:

inspection program, competence of ultrasonic (UT) examiners, leak 4 i detection, performance of inspection and subsequent action J

' GL 84-11 was issued on April 19, 1984, and while almost all of the affected operating BWR plants have an inspection program, the inspection may not be complet Some licensees have replaced all or a portion of the piping suscep-tible to IGSCC; sc .e licensees did not install IGSCC susceptible I material. Documentation of the inspection program and plans for subsequent activity should be limited to the remaining susceptible piping. Installation of the new pipe or examination of the remaining pipe or both should be used to verify the competence of UT examiners and performance of inspectio The inspection requirements are contained in NRC Temporary Instruc-tion 2515/89, " Inspection of Licensee's Actions Taken to Implement Generic Letter 84-11: Inspections of Boiling Water Reactor Stainless Steel Piping."

6. Inspection Program The licensee program should require the inspection of 20% of the welds not inspected previously (four minimum) for each pipe siz I Unit 1 CP&L's letter NLS-84-436, dated October 9,1984, subject:

Supplemental Response to Generic Letter 84-11, stated that,100% of the welds not previously inspected would be examined during the November 1984 outage. The outage program listed 124 Class 1 welds to be examined. The inspector's review revealed the 124 welds examined not only included 100% of the welds not previously inspected, but also included 100% of the total population of pipe welds susceptible to IGSC Unit 2 CP&L's letter BSEP-83-3748, dated November 28, 1983, responded to NRC's letter, dated August 26, 1983, which had transmitted an order for effected licensee's to shutdown and examine for IGSCC. The licensee's response reported that 131 welds were examined during the November 1983 outage. This represented 100% of the total population of IGSCC susceptible welds on Unit 2. Therefore, CP&L did not have any IGSCC susceptible welds that had not been inspected to the requirements of IE Bulletin 83-02, when Generic Letter 84-11 was issue > .

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b. 'he licensee's program should require the inspection of 20% of the welds previously inspected and found not to contain cracks (two minimum) for each pipe siz Unit 1 As stated in a. above, welds inspected during the November 1984, outage included 100% of the total population of IGSCC susceptible weld Unit 2 CP&L's letter NLS-85-390, dated November 1, 1985, reported that induction heat stress improvement (IHSI) would be performed on selected recirculation system and residual heat removal system weld joint !

All welds were to be UT inspected after IHSI in addition the licensee 4 intended to examine a representative sample prior to IHSI. CP&L j letter NLS-86-158, dated May 8, 1986, Subject: IGSCC Inspection

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Results, reported that UT examinations had been puformed on 100% of j the total IGSCC susceptible stainless steel weld ]

c. The licensee programs should require the inspection of all unrepaired welds previously found to contain cracks or indication of crack l l

Unit 1 Review of licensee submittals, NRC Safety Evaluation Reports i and Region II Inspection Reports indicated that prior to issuance of l Generic Letter 84-11 CP&L had weld overlay repaired all welds that UT j or visual inspection had identified as containing IGSC Unit 2 CP&L's letter NLS-85-390, dated November 1,1985, Subject:

IGSCC Inspections, reported that 11 welds that contained IGSCC indications but were not overlayed would be reinspected and re-evaluated during the December 1985 outage. This was the total population of unrepaired welds. Indications in these unrepaired l welds had also been re-sized during the Spring 1984 outag d. The licensee program should require the inspection of all weld overlays on top of welds containing cracks or indications of cracks longer than 10% of the pipe circumferenc Unit 1 CP&L's letter NLS-84-436, dated October 9,1984, Subject: l Supplemental response to Generic Letter 84-11 Inspections of BWR '

Stainless Steel Pipe, reported that CP&L would re-examine five weld overlays repairs during the March 1985, outage. This was the total population of welds overlayed on Unit Unit 2 CP&L letter NLS-84-055, dated February 10, 1984, identified all welds that had been overlayed as a result of IE Bulletin 83-02 inspection activitie None of the welds listed had IGSCC indica-tions that exceeded 10% of the pipe circumference. However, CP&L's letter NLS-85-390, dated November 1,1985, reported that five weld overlays would be re-examined in the December 1985 outag These

! five welds contained the largest circumferential IGSCC indications.

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e. The licensee's programs should require the inspection of all welds treated by the IHSI technical and not previously examined after IHSI Treatmen Unit 1 CP&L's letter NLS-85-288, dated August 16, 1985, reported that CP&L had performed IHSI on 79 welds and that all welds had been UT ex6.,ined after IHSI in accordance with Generic Letter 84-11.

! Unit 2: CP&L's letter NLS-86-158, dated May 8,1986, Subject: IGSCC Inspection Results - Brunswick 2 Reload 6, reported that IHSI was performed on 65 recirculation system weld joints and that a post-IHSI, UT examination was performed on each weld, f. The licensee's program should require a visual examination for leakage of the reactor coolant piping during each plant outage in which the containment is deinerte CP&L Brunswick Steam and Electric Plant, Periodic Test Procedure PT-80.3 " Reactor Coolant System Inservice IGSCC Pressure Test" is

. performed each outage in which the containment is deinereted unless l the procedure has been performed during the previous 92 days. CP&L's

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letter NLS-84-485, dated December 10, 1984, requested NRC approval to allow the 92 days relief from the visual inspection requirement l Test data packages, dated April 1,1986 and August 24, 1986, were I reviewed for Unit I and test data packages, dated October 9,1985, l October 18, 1986 and February 6,1987 were reviewed for Unit 2. The i results indicated pressure and leakage testing to be satisfactor Findings i

No items of nonconformance or deviation were identifie . Competence of Ultrasonic Testing (UT) examiners a. The licensee's program should require qualification by a formal performance capability demonstration test such as that being conducted at the Electric Power Research Institute (EPRI) Nondestruc-tive Examination (NDE) Cente Unit 1 CP&L's letter NLS-87-102, dated May 19, 1987, Subject: IGSCC Inspection Results - Refuel 5, included a summary of the susceptible weld population describing mitigative actions and repairs applied to dat The letter also stated that ultrasonic examinations were performed by General Electric (GE) Compan The UT personnel were qualified in accordance with Generic Letter 84-11, and the EPRI/

BWROG/NRC requirements, including the latest requalification progra The examinations incorporated the use of the fully automated GE

" SMART UT System" where geometrically feasibl Manual exams supplemented the SMART UT exams where geometrical limitation existe The inspector reviewed all Generic Letter 84-11 activities and verified that only EPRI qualified examination personnel for detec-tion, evaluation and sizing were used by the license l .

Unit 2 CP&L's letter NLS-86-158, dated May 8,1986, Subject: IGSCC i Inspection Results - Brunswick-2 Reload 6, included a summary of the susceptible weld population describing mitigative actions and repairs !

applied to date. The letter also stated that ultrasonic examinations )

were performed by G The UT personnel were qualified in accordance with Generic Letter 84-11 and the fall 1985 EPRI requalification l

program. The examination incorporated the use of the fully-automated ]

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GE _ " SMART UT System" where geometrically feasible. Manual exams supplemented the SMART UT exams where geometrical limitation existe ;

The inspector reviewed all Generic Letter 84-11 activities and '

verified that only EPRI qualified examination personnel for detection evaluation and sizing were used by the licensee.

l b. The licensee's program should require personnel who are performing as I SNT-TC-NDT Level I examiners to demonstrate field performance

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I capabilit As a alternate, document that Level I examiners work only with or under the direct supervision of Level II or III 1 personne I Manual UT examinations were performed by GE in 1984 and early 1985 1 using examination teams that were divided into a master / slave arrangemen The master directing the examination was located outside the drywell and communicated with the slave with headset ;

Both slave and master were provided with duplicate oscilloscope '

displays. The slave performed the actual scanning under the director of the maste ;

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The " masters" were Level II or Level III personnel qualified per IEB i 83-02 and graduates of the 40-hour EPRI course on IGSCC which was uader the review of an NRC representative. The " slaves" were Level I/II personnel qualified per IEB 83-02 (except for the length of cracked pipe on which the proficiency demonstration was performed which was limited by the availability of cracked specimens). The Level II slaves who were graduate of the 40-hour EPRI course on IGSCC were deemed qualified to scan without further demonstratio Other Level I/II slaves were required to demonstrate scanning ability on a Nine-Mile Point Plant pipe sample containing known areas of IGSC Sizing was performed by Level III inspectors who had successfully ,

completed the EPRI sizing cours l l

The inspector reviewed the qualification records for all examiners required to perform proficiency demonstration examination Level I examiners were not used for the recent IGSCC susceptible weld examinations performed in accordance with Generic Letter 84-11. The examinations performed were geometrically feasible using the fully l automated GE " SMART UT System" and were full scope inspections for '

both Units 1 and l c. Findings No items of noncompliance or deviation were identifie ,

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6 Leak Detection and Leakage Limits The Technical Specification should require a plant shutdown for inspection and corrective action when any leakage detection system indicates, within any 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an increased in the rate of unidenti-fied leakage in excess of 2 gpm or its equivalen Units 1 and 2 The leakage and shutdown _ requirements appear in the ,

BSEP Technical Specifications in paragraph 3.4.3.2. and include the requirement that an increase in the rate of unidentified leakage in l excess of 2 gpm or its equivalent within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period requires j plant shutdow l The Technical Specification should require that at least one of the leakage measurement instruments associated with each sump shall be operabl The outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the licensee shall immediately initiate an orderly shutdow Units 1 and 2 BSEP Technical Specifications in paragraph 3.4. also included the above requirements. In addition, CP&L's Operating Instruction 03.1, Attachment 1, page 11-17 requires that the level be monitored every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and .if the floor drain leak rate exceeded 5 gpm average over a 24-hour period or increases by 2 gpm over any previously calculated leak rate for the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, actions of Abnormal Operating Procedure (A0P-01) should be followed (Plant Shutdown). Findings No items of nonconformance or deviations were identified.

i 9. Performance of Inspection

, The inspection should check three or more pipe sizes to verify that the welds have been inspected by the licensee according to their program.

l The inspector reviewed documentation to verify that, as a minimum, welds had been reinspected in accordance with the guidance of Generic ;

Letter 84-11. Welds in the 28 inch, 22 inch and 12 inch recircula- l tion system were selected for this review.

l Unit 1 Table 1 to CP&L's letter NLS-84-436, dated October 9,1984, Subject: Inspection of BWR Stainless Steel Pipe - 1984-1985 Outage was initially reviewed to determine what welds were to be j l

re-inspected in the pipe sizes and. selected for revie However, i this review revealed that CP.&L had performed re-examinations on 100% j the total IGSCC susceptible population, j Unit 2 Table 1 to CP&L's letter NLS-86-158, dated May 8,1986, !

Subj ect: IGSCC Inspection Results, reported that UT re-examinations j had been performed on 100% of the susceptible weld populatio !

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The inspector reviewed the completed examination records for Units l' i and 2, this included all pipe size !

b. The inspector should check that at least six of the UT examiners demonstrated their competence prior to examining welds using the l essential parameters of their qualified procedures.

l The inspector reviewed qualification records for UT examiners to determine if all had demonstrated competence prior to examining welds for IGSC Unit 1 March 1985 Outage j EPRI IGSCC EPRI Flaw UT Examiner Level Company Detection Qual . Sizing Qua T. L. Brinkman L-II GE September 16, 1983 September 14, 1984 J. Briggs L-III GE September 16, 1983 August 3, 1984 D. Edgel L-II GE November 4, 1983 D. Hall L-II GE September 20, 1983 R. Hart L-II GE November 4, 1983 T. Kimball L-II GE September 13, 1983 Unit 2 December 1985 Outage EpRI IGSCC EPRI Flaw UT Examiner Level Company Detection Qua Sizing Qua D. R. Bajula L-II GE June 7, 1985 June 24, 1985 i

T. L. Brinkman L-III GE December 3,1985 March 1, 1985 l R. M. Lester L-II GE December 3,1985 -------------

l S. S. Meeker L-II GE December 3,1985 March 6, 1985 R. A. Seal L-III GE December 3, 1985 November 22, 1985 M. C. Stanm L-II GE December 3, 1985 March 6, 1985 In addition to the review performed above, the inspector also verified licensee's examination activities to Generic Letter 84-11, the qualification / certification of UT examiners and examination proce-dures during each outage of Units 1 and 2. This inspection effort is reported in the following Region II inspection Reports:

NRC Report No ,324/84-22 325, 324/85-30 325, 324/84-24 325/86-07 and 324/86-08 325, 324/84-32 325/86-09 and 324/86-10 325, 324/84-32 325, 324/87-04 325, 324/85-08 325,324/87-08 325, 324/85-10 325,324/87-14 325, 324/85-15 325,324/87-18 325, 324/85-23

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l Findings No items of noncompliance or deviation were identifie . Subsequent Activity The licensee should provide for scope expansion and additional inspection when cracks are found or existing cracks grow to an unacceptable siz CP&L did not define a program for expansion. However, each letter of corresporidence stated that inspections would be performed in accordance 1 with Generic Letter 84-11 which invoked IE Bulletin 83-02 requirement '

These requirements stated that if flaws indicative of cracking are found in the above examination, additional inspection is to Le conducted in accordance with IWB 2430 of the ASME Code,Section X In practices, CP&L exceeded these requirements.

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August 23, 1983 LAP-83-390 " Response to Confirming Order" CP&L will examine three large diameter pipe welds per IEB 83-02 LAP-83-432 " Inspection of BWR Stainless Steel Piping" Alternate weld selection during outage schedules October 1983 January 31, 1984 NLS-84-045 "Intergranular Stress Corrosion I Cracking" l CP&L comment to mid-cycle by l October 1984 l February 27, 1984 NLS-84-087 "Intergranular Stress Corrosion Cracking" Response to concerns regarding October 1983 inspection June 1, 1984 NLS-84-222 " Response to Generic letter 84-11, Inspections to BWR Stainless Steel Piping" i August 24, 1984 NLU-84-547 "IGSCC Inspection in 1983" SER accepting exams as basis for continued operation until November 1984

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October 9, 1984 NLS-84-436 " Supplemental Response to Generic Letter 84-11, Inspection to 8WR -

Stainless Steel Piping" CP&L will inspect 100% of welds in next outage scheduled in November 1984 December 5, 1984 NLS-84-502 "IGSCC Inspection Results" December 6, 1984 "IGSCC Inspection per Generic Letter 84-11" l

NRC finds inspections complied with 84-11 and authorization to resume power operations February 26, 1985 NLS-85-045 "IGSCC Inspections" CP&L plans for refuel scheduled for March 1985 July 1, 1985 NLS-85-417 " Response to Generic Letter 84-11 Regarding Stainless Steel Piping l ;

Reinspection" l i

NRC Accepts Plans i August 16, 1985 NLS-85-288 "IGSCC Inspection Results" September 25, 1985 NLS-85-326 "Intergranular Stress Corrosion Cracking Design Report" July 17, 1986 NLS-86-430 " Safety Evaluation of IGSCC Program" NRC acceptance of November 1984 and refuel 1985 inspection results l October 31, 1986 NLS-86-401 "IGSCC Inspection Plans" CP&L plans for refuel scheduled for 1987 March 4, 1987 NLS-86-401 "Intergranular Stress Corrosion Inspection Program for Reload 5 Outage" l

NRC acceptance of inspection plans '

May 19, 1987 NLS-87-102 "IGSCC Inspection Results -

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June 4, 1987 "Intergranular Stress Corrosion Cracking - Inspections or Repairs Brunswick Steam Electric Plant, Unit 1" NRC acceptance of results and authorized continued operation, 1 SER to follow b. Unit 2 l

July 28, 1983 LAP-83-351 " Response to Request for Additional Information, Inspec tion of BWR Stainless Steel Piping" October 14, 1983 LAP-83-438 " Response to Confirming Order, Inspection of BWR Stainless Steel Piping" Novembe" 28, 1983 "IGSCC Inspection Results" Results of full scope inspect per IE8 83-02 1 December 13, 1983 " Order Confirming CP&L Commitment i Re: IGSCC Inspection" NRCs SER regarding inspections February 10, 1984 NLS-84-055 " Unit 2 IGSCC Inspections" CP&Ls plans for March 1984 Outage August 10, 1984 NLS-84-358 " Justification for Continued Opera tion" CP&L submittal of design report and results September 28, 1984 NLU-84-626 " Reinspection of Brunswick Unit 2 Unrepaired Piping Welds" 3 NRC acceptance and SER

November 1, 1985 NLS-85-390 "IGSCC Inspections CP&L plans for outage scheduled December 1985 ,

November 27, 1985 NLS-85-423 "IGSCC Inspections" May 8, 1986 NLS-86-158 " Inspection Results-Brunswich - 2 Reload 6" .

CP&L inspection results and design l report l

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June 12, 1986 NLS-86-347 "Intergranular Stress Corrosion Cracking Program for Reload 6 Outage" SER on inspections and request for mid-cycle inspection on the 2 cracked inconel letter July 15, 1986 NLS-86-264 "Intergranular Stress Corrosion i Cracking Program for Cycle 7 Operator" l

CP&L justification for no mid cycle inspection l

October 5, 1986 "Intergranular Stress Corrosion Cracking - Mid-cycle Inspection" 4 NRC SER on not requiring mid-cycle inspection i

c. Miscellaneous

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Coordination Plan for NRC/EPRI/BWROG Training and Qualification Activities of NDE Personnel, dated June 22, 198 Engineering Procedure ENP-16, Rev. 22, Procedural for Administra-tive Control of Inservice Inspection Activitie EPRI Registry of Qualified Personnel of UT of IGSC . Summary of Susceptible Weld Population a. The susceptible weld population at BSEP-1 consists of 108 weld The current status ci this weld population with respect to mitigative actions and repairs is summarized below:

Category of Welds Unit 1 Total number of IGSCC-susceptible welds 108 Number of welds repaired by weld overlay 36 Number of welds mitigated by IHSI 56 ,

Number of welds mitigated by solution annealing 9 .

Number of flawed welds operating under analysis 1 (1) j Number of walds not mitigated 7 l Note: (1) This weld has IHSI as mitigatio The reduced number of susceptible welds in the population from the initial inspections resulted from pipe replacement on the 4" and 6" diameter reactor water cleanup system. Nonconforming piping in this system was replaced with Nuclear Grade 316 stainless steel material.

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) The susceptible weld population at Brunswick Unit 2 consists of 107 )

weld The current status of this weld population with respect to q mitigative actions and repairs is summarized below: q l

Mitigation / Repair No. of Weld Joints IHSI 58 Weld Overlay Repair 32 IHSI & Weld Overlay Repair 7 Solution Anneal 8 Unmitigated 2 Total 107 The reduced number of susceptible welds in the population from the initial inspections resulted from pipe replacement on the 4" and 6" diameter reactor water cleanup system. Nonconforming piping in this '

system was replaced with Nuclear Grade 316 stainless steel materia Findings The licensee has exceeded Generic Letter 84-11 recommendations for 1 Units 1 and 2 as reported in a. and b. above. Future examinations of the IGSCC susceptible welds will be performed to NUREG-0313, .

Revision I, and Generic letter 84-11 on an outage-by-outage basis I until NUREG 0313, Revision II, is approved in final form by NR Within the areas examined, no violations or deviations were identifie I I

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