ML20197B181

Insp Repts 50-321/86-11 & 50-366/86-11 on 860324-27. Violation Noted:Failure to Perform Section XI Pressure Tests

ML20197B181
Person / Time
Site:	Hatch
Issue date:	04/23/1986
From:	Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197B152	List: ML20197B148 ML20197B164 ML20197B181
References
50-321-86-11, 50-366-86-11, NUDOCS 8605120473
Download: ML20197B181 (10)

See also: IR 05000321/1986011

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMisslON

[" o REGION ll

3 j 101 MARIETTA STREET N.W. *-

• i e ATL ANTA. GEORGI A 30323 j

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Report Nos.: 50-321/86-11 and 50-366/86-11

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Licensee: Georgia Power Company -

P. O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5

Facility Name: Hatch 1 and 2

Inspection Co . M ch 24-27, 1986

Inspecto : " J3 86

.R y Date Si ned

Approve by: J3 8b

J. 8 -(e, Section Chief Date Signed

'En ne ring Branch

D is on of Reactor Safety

SUMMARY

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Scope: This routine, announced inspection involved 33 inspector-hours on site in

the areas of licensee action on previous enforcement matters (Units 1 and 2);

inservice inspection (ISI) (Unit 1); and inspection followup items (Units 1 and

2).

Results: One violation was identified - Failure to perform Section XI pressure

tests - Paragraph 5.c.(2)(a).

8605120473 860430

PDR ADOCK 05000321

G PDR

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REPORT DETAI:.S

1. Persons Contacted

Licensee Employees

• H. C. Nix, Site General Manager

• T. V. Green . Deputy General Manager

D. S. Read, General Manager, Quality Assurance (QA)

• T. R. Powers, Manager of Engineering

• T. Setz, Manager of Maintenance

P. E. Fornel, Manager of QA

• L. Sumner, Manager of Operations

D. A. McCusker, Superintendent of Quality Control (QC)

J. Hadden, QC Supervisor

• T. L. Elton, Supervisor of Regulatory Compliance

0. M. Fraser, QA Audit Supervisor

• C. M. Dixon, Engineering Support Supervisor, QA

T. S. Huckaby, ISI Engineer

• C. R. Goodman, Senior Plant Engineer - Regulatory Compliance

P. Norris . Senior Plant Engineer

G. R. Brinson, Senior QC Specialist

R. K. Moxley, Associate QA Field Representative

Other licensee employees contacted included construction craftsmen,

engineers, technicians, operators, mechanics, security force members and

office personnel.

Other Organizations

. M. Belford, Supervisor, Inspection Engineering, Southern Company

Services (SCS)

D. R. Graham, Senior Engineer, SCS

NRC Resident Inspectors

• P. Holmes-Ray, Senior Resident Inspector

G. N. Nejfelt, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 27, 1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below. No dissenting comments were received from the licensee.

(0 pen) Unresolved Item 321, 366/86-11-01, Performance of System Leakage

and Hydrostatic Tests Using Nuclear Heat - Paragraph 5.b.

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(0 pen) Violation 321, 366/86-11-02, Failure to Perform Section XI

Pressure Tests - Paragraph 5.c.(2)(a).

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(0 pen) Inspector Followup Item 321, 366/86-11-03, Review of Procedures

Addressing ASME Section XI VT Requirements - Paragraph 5.c.(2)(b). -

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The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

(0 pen) Unresolved Item 321, 366/85-14-02, Resolution of Requirements for

Increase in Inspection Scope When Corrective Actions are Required for Pipe

Supports. This item was opened to resolve questions relative to the

licensee's program for re-examination of problem supports and expansion of -

inspection scope when results of pipe support examinations require

corrective actions. The licensee has revised procedur( 45QC-INS-001-OS to

cover scope expansion when problems are found. In addition, the licensee

has reviewed past practices and found that Section XI has not been violated

in the area of scope expansion. In the area of re-examination, the licensee

is. in the process of reviewing the Winter 1981 Addenda to the ASME

Section XI to revise procedure 45QC-INS-001. For the current outage and

previous outages, the Winter of 1980 Addenda, which does not provide details >

for re-examination, was in effect. Procedure 450C-INS-001 will be revised

prior to the next Unit 2 outage.

(Closed) Unresolved Item 321, 366/85-14-01, Clarification of Requirements for

ISI of Snubbers. This item was opened to resolve. differences in the

Technical Specification (TS) snubber program and the ASME Section XI

requirements. The licensee submitted a ravised ISI program (See Georgia

Power Company letter NER-85-483, dated June 25, 1985) updating to the W81

addenda of ASME Section XI for the second 10-year interval. In the revised

program, relief was requested to perfora _ snubber inspections in acco~rdance

with the TS program in lieu of ASME Section XI. Also, the program for:the

first 10-year interval to the 1974 ASME Section XI, S75 addenda, contained

relief requests (requests 2.1.2 and 3.1.1) to use the Tech Spec Program in

lieu of ASME Section XI. See NRC letter dated July 29, 1983, approving the

relief request for the 1974 Code.

(Closed) Violation 321/86-02-01 "3 lyn to Follow Procedure for Signoff of

Traveler Steps for IHSI. Gec/g l Pa u- Company's letter of response

(SL-460), dated March 14, 1986, 9 s cet1 reviewed and determined to be

acceptable by Region II (RII). The inspector examined corrective actions as

stated in the letter of response and discussed the corrective actions with

j responsible licensee personnel. In order to verify corrective action, the

inspector reviewed:

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Management Memorandum MM-MGR-002-0186, dated January 15, 19S6

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Departmental Directive 86-06, dated February 10, 1986

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Nutech travelers for welds 1831-1RC-12AR-G-1, 1831-1RC-12AR-F-1,

IB31-1RC-22AM-3BC-1, 1B31-1RC-12AR-K-1, 1831-1RC-28A-16,

IB31-1RC-28A-3, 1-G31-1RWCU-6-0VT-12, 1-G31-RWCU-6-0VT-10 and

1-G31-RWCU-6-0VT-11,

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. One new unresolved items identified during this inspection are

discussed in paragraph 5.b.

5. Inservice Inspection - Review of. Procedures (730528) (Unit 1)

The inspector reviewed ISI procedures as indicated below to determine

whether procedures were consistent with regulatory requirements and licensee

commitments. The applicable code is the ASME Boiler and Pressure Ves el

(B&PV) Code,Section XI, 1980 Edition, W80 Addenda.

The following plan documents govern the ISI:

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" Modified First Ten-Year Inservice Examination Plan for Class 1

Components - Edwin I. Hatch Nuclear Plant Unit 1"

- " Nondestructive Examination Outage Plan - Edwin I. Hatch Nuclear Plant

Unit 1 - 1985 - Full Outage"

a. Procedure Scope

The Nondestructive Examination Outage Plan and Associated NDE

procedures for the areas of examination listed below were examined to

determine whether the procedures were consistent with licensee TS

commitments and specified the examination category, method of

examination and extent of examination:

- Stainless Steel Components

- Reactor Pressure Vessel Shell and Head Welds

- Feedwater System Pipe Welds

- High' Pressure Coolant Inject System Welds

b. Reactor Vessel System Leakage and Hydrostatic Tests

Based on BWR Owners Group comments to a revision to Regulatory

. Guide (RG) 1.99, questions have been raised relative to the method used

at plant Hatch to obtain Section XI system leakage and hydrostatic test

pressures and temperatures for reactor vessel tests. Hatch performs

both tests (system leakage and hydrostatic) using nuclear heat during

startup at operating pressures and temperatures. Questions have been

raised relative to use of this method based on the fact that under

operating pressures and temperatures, any leak would be a steam leak

rather than a water leak which would normally da expected from a

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hydrostatic test. Other questions center around whether ASME

Section XI requirements are being met. Most other BWR utilities use

methods other than nuclear heat to obtain required pressures and

temperatures.

During the current inspection, the inspector reviewed with the licensee

their practices . relative to the above question including procedures,

code requirements and reasons for their method of testing.

The applicable procedure is plant procedure 421T-TET-001-05,

Revision 1, Pressure Testing of Piping and Components. This is a

general procedure used for all pressure testing. The procedure

provides administrative controls, a " fill-in-the-blank," " Pressure Test

Specification," and a " Pressure Test Data Sheet."

The applicable code is the ASME B&PV Code,Section XI,1980 Edition,

W80 Addenda. Article IWB-5000 of Section XI requires a system leakage

test after each refueling outage and a system hydrostatic test at the

end of each interval (ten years). Note 5 to table IWB-2500-1 requires

that the system leakage test be performed prior to " plant startup".

The licensee has interpreted " plant startup" to mean " roll" of the

turbine. The ASME Code does not provide a definition of " plant

startup." If the TS definition of startup is used, startup would be

when the reactor is taken critical. If this definition is used, Note 5

of table IWB-2500-1 of Section XI cannot be met using nuclear heat for

obtaining pressure and temperature.

The main reason the licensee gave for performing the test using nuclear

heat was that they considered it safer for the reactor vessel since

performing the test under these conditions would result in pressure and

temperature further to the right of the pressure / temperature curve.

The licensee also noted that performing the test under conditions other

than nuclear heat would require gagging the safety relief valves with

fuel in the vessel which they considered to be undesirable.

Based on BWR Owner's Group comments to RG 1.99, Georgia Power Company,

by letter, dated November 11, 1986, requested SCS to evaluate the

acceptability of using nuclear heat for hydrostatic testing. At the

time of the inspection, SCS was still evaluating the question.

Pending resolution of the question relative to the ASME Code

requirement / intent for performing the reactor vessel system leakage

test and/or hydrostatic test prior to " plant startup", Unresolved Item

321, 366/86-11-01, Performance of System Leakage and Hydrostatic Tests

Using Nuclear Heat, is identified.

c. Pressure Testing Program

In the process of reviewing the reactor pressure vessel leakage and

hydrostatic test requirements, the inspector made a general review of

the Hatch program for pressure testing of ASME Class 1, 2 and 3

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components and piping to ASME Section XI as detailed below:

(1) Requirements

In general,Section XI requires:

Class 1 - System leakage test follexing opening and reclosing

of a component after each refueling outage

- System hydrostatic test during plant shutdown near

the end of each inspection interval (ten years)

Class 2 -

System pressure test during system functional test

of systems not required to operate during normal

reactor operation - each inspection period

-(40 months)

- System hydrostatic test during plant shutdown near

the end of each inspection interval (ten years)

Class 3 - System inservice test at operating pressure

(categories DA and DC) - each inspection period

(40 months)

- System pressure test during _ functional testing

(category DB) - each inspection period (40 months)

- System hydrostatic test near the end of each

interval (ten years)

The Section XI requirements and the test boundaries are identified

in the Hatch Ten-Year Examination Plans. The only procedure for

implementing the Ten-Year Plans is procedure 42IT-TET-001-0S, a

general procedure for performing all pressure tests. Prior to the

current outage, there was no formal document identifying the

required tests for each outage. For the current Unit 1 outage,

the required hydrostatic tests are listed in the Nondestructive

Examination Outage Plan.

(2) Problems Identified

The following problems were identified during the above review:

(a) There are no formal implementing procedures for scheduling

and tracking ASME Section XI pressure tests with exception of

the hydrostatic tests listed in the current Unit 1 Inservice

Examination Outage Plan. Discussions with licensee and SCS

personnel revealed that in the past, the scheduling and

tracking have been on informal lists.

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Based on discussions with licensee and SCS personnel, lack of

implementing scheduling and tracking procedures has resulted

in Class 3 and possibly some Class 2, 40 month pressure tests

not being performed. The licensee pointed out that some of

the tests were probably performed in the process of

performing other tests. However, it is not clear for these

cases that VT-2 qualified examiners were used as required by

ASME Section XI.

The failure to have implementing procedures is in violation,

TS 6.8.1. The failure to perform required Section XI tests

is in violation of 10 CFR 50.55(a). This violation is

identified as 321,366/86-11-02, Failure to Perform Section XI

Pressure Tests.

(b) In reviewing procedure 42IT-TET-001-0S, the inspector noted

that the procedure did not reference a procedure for the

required VT-2 inspection. The procedure only specifies a QC

walkdown and inspection for leakage without details or

reference to VT-2. Discussion with licensee personnel

revealed that personnel performing the walkdown are qualified

to VT-2 requirements. However, no procedure exist detailing

the code requirements for a VT-2 inspection.

During investigation of this finding, the inspector found

that site QA had an open audit finding (audit 85-ISI-02,

finding 85-ISI-2/165) identifying the fact that procedures do

not address VT-1, VT-2, VT-3 and VT-4 requirements of ASME

Section XI. Pending review of the QA audit finding

corrective actions, Inspector Followup Item 321, 366/86-11-03,

Review of Procedures Addressing ASME Section XI VT

Requirements, is identified.

Within the areas inspected, no violations, except as noted in

paragraph (2)(a), or deviations were identified.

6. Inservice Inspection - Observation of Work and Work Activities (737538)

(Unit 1)

The inspector observed the ISI activities described below to determine

whether these activities were being performed in accordance with regulatory

requirements and licensee procedures. See paragraph 5 above for the

applicable code.

Since the ISI work for the current outage was essentially complete and no

work was in process for observation, the following records were reviewed in

lieu of work observation:

a. Magnetic particle (MT) inspection records for the following welds were

reviewed:

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1821-1MS-24A-8PS-B-1

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IB21-1MS-24A-8PS-B-2

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1X13A-RHR-1

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1X13A-RHR-2

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1X13A-RHR-3

The records were reviewed in the areas of:

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Availability of and compliance with approved NDE procedures

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Use of knowledgeable NDE personnel

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Use of NDE personnel qualified to the proper level

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Recording of inspection results

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Examination method

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Contrast of dry powder particle color with background and

surface temperature

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Examination overlap and directions

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Pole spacing and lifting power for yoke method

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Acceptance criteria

b. Liquid Penetrant (PT) inspection records for the following welds were

reviewed:

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SA-PL-1

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SA-PL-2

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1E11-1RHR-20B-D-5

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IB31-1RC-12AR-K-3

The records were reviewed in the areas of:

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Availability of and compliance with approved NDE procedures

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Use of knowledgeable NDE personnel

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Use of NDE personnel qualified to the proper level

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Recording of inspection results

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Method consistent with procedure

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Penetrant materials consistent with ASME Code materials

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Surface preparation

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Drying time following surface cleaning

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Penetrant application and penetration time

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Examination surface temperature

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Penetrant removal

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Drying of surface prior to developing

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Developer type, application, and time interval after penetrant

removal

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Time interval between developer application and evaluation

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Evaluation technique

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Reporting examination results

Within the areas inspected, no violations or deviations were identified.

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7. Inservice Inspection - Data Review and Evaluation (737558) (Unit 1)

The inspector reviewed the ISI NDE records indicated below for the current

'ISI to determine whether the records were consistent with regulatory

requirements and licensee procedures. See paragraph 5 above for the

applicable code.

NDE records for the following pipe welds were reviewed:

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1G31-1RWCV-6-D-20: UT (45 , 60 )

PT

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1G31-1RWCU-6-D-16: UT (45 , 60 )

PT

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1E11-1RHR-208-D-1BC: UT (60')

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1E11-1RHR-20B-D-1: UT (45 , 60 )

PT

The records were reviewed in the areas of:

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Calibration data sheets

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Proper recording of recordable indications

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Evaluation of examination data by a Level II or Level III examiner

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Evaluation of data complies with applicable procedures

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Evaluction of indications complies with applicable procedures

Within the area inspected, no violations or deviations were identified.

8. Inspector Followup Items (927008) (Units 1 and 2)

a. (0 pen) Inspector Followup Item 321, 366/85-26-01, Examination of New

Welding Program. The inspector reviewed the status of development and

issue of the new welding program. Based on review of interoffice GPC

correspondence LR-ENG-029-0286, completion and issue of the new program

has been delayed. As noted in RII report 50-321, 366/85-26, the program

was to be implemented by March 31, 1986. The first draf t of the

program was completed by December 1,1985. Due to Unit 1 outage

demands, personnel were not available to complete review and issue of

the program. Therefore, procedure 42SP-MNT-001-0S, Temporary Welding

Controls, was issued for the Unit 1 outage. Completion of the welding

program is estimated to be eight weeks after unit 1 startup,

b. (Closed) Inspector Followup Items 321, 366/85-14-03, Clarification of

Procedures for ISI Inspection of Pipe Supperts. Licensee procedures

have been clarified and revised in the six areas identified in the

inspector followup item.

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c. (0 pen) Inspector Followup Item 321, .66/85-14-04, Update of ISI Plan

Pipe Support Sketches to Reflect Latest Design Information. This item

identified a problem with sketches for ISI of supports not being

updated to reflect the latest design information. As noted in RII

report 50-321, 366/85-14, QA audit 85-ISI-1 identified the identical

finding. Prior to the Unit 1 outage, the licensee walked down all

accessible systems and compared existing support sketches with all

design change information (IEB 79-14, DCR, etc.). During the outage,

inaccessible systems were walked down for the same purpose. Sketches

were or will be updated as necessary. The same procedure will be

followed for Unit 2 prior to and during the next outage.

During investigation of this problem, the licensee found that there is

a possibility that design change information, other than for supports,

may not have been incorporated into the ISI program since 1980 when the

ISI contract was changed from Southwest Research to SCS. Another

change that may have influenced the problem was a change in AE. To

determine extent of the problem, all DCRs since February 1980, are

being reviewed for ISI impact. In addition, procedures are being

changed to insure that DCRs that impact ISR are factored into ISI

requirements. SCS is assigning a permanent engineer at the site for

review of DCRs that affect ISI and to take action to include changes in

the ISI program.

d. (Closed) Inspector Followup Item 321/85-35-04, Review of ISI Inspection

Plans to Insure That Ten-Year Requirements are Met. The inspector

reviewed deviations 008 through 016 to the NDE Outage Plan and

deviations 002 and 003 to the Modified First Ten-Year Plan and found

that all items identified in this inspector followup items had been

corrected. The deviations also include items identified in SCS's

review of the plans. In addition, the inspector reviewed SCS

memorandum, dated March 25, 1986, indicating that their review had been

completed and all errors corrected.

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