IR 05000280/1979045
| ML18136A213 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/04/1979 |
| From: | Blake J, Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18136A209 | List: |
| References | |
| REF-SSINS-5400 50-280-79-45, 50-281-79-64, NUDOCS 7911260145 | |
| Download: ML18136A213 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/79-45 and 50-281/79-64 Licensee:
Virginia Electric and Power Company Richmond, Virginia 23261 Facility Name:
Surry, Units 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection SUMMARY Inspection on July 30 - August 3, 1979 Areas Inspected Virginia Date Signed 9/Y/zf rfate Signed This special unannounced inspection involved 35 inspector-hours onsite in the areas of feedwater piping repair in Unit 1 and primary shield tank fabrication
-* record review (Unit 2).
Results Of the two areas inspected, no items of noncompliance or deviations were identified in one area; two items of noncompliance were found in one area (infraction - inade-quate procedures - paragraph 5.E., and infraction - failure to follow procedures in maintenance operations - paragraph 5.E.).
'7911260 /~~ Persons Contacted Licensee Employees W. L. Stewart, Station Manager DETAILS
- J. L. Wilson, Superintendent Operations
- R. F. Saunders, Superintendent Maintenance
- T. A. Peebles, Superintendent Technical Services
- M. R. Kansler, Associate Engineer
- F. L. Rentz, Resident QC Engineer
- R. L. Baldwin, Supervisor Administrative Services
- E. P. Dewandel, Staff Assistant
- J.P. Maciejewski, Engineering Supervisor (NDT)
- M. D. Tower, Corporate QA
- D. A. Christian, Engineering Supervisor D. L. Kildoo, QC Staff R.H. Kulp, QC Staff M. Kyght, Mechanical Maintenance Supervisor T. W. Bromback, NDT Technician NRC Resident Inspector
- D. Burke~
- Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on August 3, 1979, with those persons indicated in Paragraph 1 abov The areas of noncompliance and the unresolved item were discussed in detail. The licensee took exception to the inspector's interpretation that welding operations were not exempted from the requirements of VEPCO QA Manual Section 1.
Licensee Action on Previous Inspection Findings Not inspecte.
Unresolved Items Unresolved items are matters about which more information is requi~ed to determine whether they are acceptable or may involve noncompliance or deviation New unresolved items identified during this inspection are discussed in paragraph 5. J
-2-Steam Generator Feedwater Pip.~ng, Inspection and Repair - IE Bulletin 79-13, (Unit 1)
The inspector reviewed the licensee's maintenance activities relative to the nondestructive examinations required by IE Bulletin No. 79-13 and the repair of rejectable indications found. during these examination This review included review of maintenance and welding procedures; discussions with maintenance, quality control and engineering personnel; observation of work activities and results; and review of NDE and welding documentatio The scope of the maintenance repair work included defect removal grinding and weld repair of the following welds in the feedwater lines:
Steam Generator A Weld 113 Weld 114 Weld 115 Weld 1113 Steam Generator B Weld 1110 Steam Generator C weld 115 Weld 116 Weld 119 Weld 1111 Weld 1/13 Weld 1114 As part of this work effort check valves No. 1-FW-10, 1-FW-41, and 1-FW-72 were dismantled to provide access to the inside of the pipin Procedure Review The inspector reviewed the weld repair procedure and the valve repair procedures for compliance with the requirements of VEPCO QA Manual Sections 5 and 16 and Technical Specification Section 6.4 Unit Operating Procedures. The procedures reviewed were as follows:
(1)
VEPCO Welding Procedure and Qualification Manual,,General Welding Procedure No. W-1. 0, Section 14. 3 Weld Repairs. _
(2)
Mechanical Maintenance Procedure No. NMP-C-G-001, Corrective Maintenance Procedure for Valves in General, as implemented for maintenance requests MR /IS 1907250730, MR /IS 1907230931, and MR
/IS 1907231043 for work on the feedwater piping check valve * Discussions with Station Personnel The inspector discussed the weld repair and valve maintenance activities with representatives of the station's engineering, maintenance, and quality control groups. The discussions involved the following areas:
(1)
General Welding Procedure No. W-1.0 specifies that weld repairs of excavations be accomplished in accordance with the instructions of W-1. 0 for minor repairs, but that detailed procedures are required for major repairs. The inspector noted that there were significant differences of opinion between maintenance personnel and QC personnel as to what constituted a major repai The significant factor was that the maintenance foreman makes the decision of "minor" or "major" and if he decides "minor" he puts his crew to work, whereas, ~f he decides "major" he must generate a detailed procedure which must be reviewed and approved by QC and the Plant Safety Review Committe (2)
The fact that the welding maintenance operations are routinely conducted in accordance with a maintenance request and the General Welding Procedure without an implementing mechanical maintenance procedure.The plant personnel felt that welding being a special process covered by Section 9 of the QA Manual was exempted from the QA Manual Section 16 requirements that all maintenance opera-tions be conducted in accordance with detailed maintenance procedure (3)
The question as to why the check valves had been modified to include the seal welded diaphragms was discussed with site engin-eering personnel. At the time of this inspection engineering had verified that the valves had been supplied without a seal diaphragm and the valve manual on file had not been modified to show the sea The engineering personnel stated that they believed that the valves had been modified after the plant went into operation but could not, as yet, find documentation for the modificatio Observation of Work Activities and Results The inspector visually inspected the weld joints being repaired and the check valves which had been dismantle (These weld joints and valves are listed at the start of this section of the report). The inspector noted that in a number of cases the excavations had penetrated the root of the weld with the* resulting hole being two or three inches lon It was also noted that in the area of the check valves the cable tray which passes under those valves was being used for a work platform and an adjacent ventilation duct was serving as a walk wa The inspector noted that a section of the metal cover on the cable tray had moved exposing some of the cable and that the ventilation duct contained several large dents and flat area The inspection of the valves also revealed that one area of Valve N FW-10~* on the "A". line had been damaged by grinding in ':the wrong area in an attempt to remove a seal diaphragm which h~q been welded
-4-into the valve. In addition, all three valves were left open without any type of protective coverin Review of NDE and Welding Documentation The inspector reviewed the radiographs for the welds being repaire This includes the in-process information radiography which was being conducted to verify defect remova Welding documentation reviewed included the weld traveller sheets for each joint being repaired. The inspector noted that only two travellers had been initialled by the mechanic to show that the weld repair area had been ground and prepared for welding even though the inspection of the welds had shown that at least 8 or 9 excavations had one or more weld passes deposited in them. When the inspector asked to see documen-tation of the visual and liquid penetrant inspections of the excavations (as required by 14.3.1.2 of the General Welding Procedure) he was informed that the mechanical maintenance supervisor had not performed the visual inspections and had elected to substitute radiography for the liquid penetrant inspection Conclusions As a result of this review of the maintenance operations the QA Manual and the plant Technical Specifications, the inspector could only conclude that there were several examples of inadequate procedures and failure to follow procedures in this work effort. These were as follows:
(1)
Inadequate Procedures a)
The general welding procedure does not provide a definition for minor or major weld repairs (See 5.b. (1) above).
b)
The weld repair work on the feedwater lines was being conducted in accordance with a maintenance request and the general welding procedure instead of a mechanical maintenance procedure as required by Section 16 of the QA manual (See 5. b. (2) above).
c)
The mechanical maintenance procedure for the work on Valve No. 1-FW-10 referenced a valve manual which did not show the modification to include a seal diaphragm and only included an instruction "grind out seal diaphragm" without specific detail as to ho The result being a damaged valve body because of incorrect grinding (See 5. c. above).
The inspector informed the licensee that these items would be shown as three examples of noncompliance with Technical Specifi-cation 6.4.A requirement for detailed written procedures with appropriate check-off lists and instructions. This is identified as Item No. 280/ 79-45-01, Inadequate procedure.
- )..
.J-5-(2) Failure to Follow Procedures a)
The general welding procedure requires that during a repair operation the excavation is to be liquid penetrant inspected for defect removal and visually inspected by the mechanical supervisor or his direct representative prior to weldin During discussion with the mechanical supervisor it was established that these inspections were not being accomplish-e b)
The MMP' s being used for the work on the check valves require that prior to and during the course of work in the containment provisions are to be made to assure that the surrounding equipment is being adequately protecte The inspector found that instead the surrounding equipment was being used for scaffolding and a work platfor The inspector informed the lic*ensee that these items would be shown as two examples of noncompliance with Technical Specifica-tions 6.4.D requirement that procedures be followe This is identified as Item No.280/79-45-02, Failure to follow procedures in maintenance operation The inspector also informed the licensee that the fact that the valve manual had not been modified to show the welded seal
- diaphragm and the licensee had not been able to locate the document-ation of the modification raises th equestion as to whether this modification had been properly reviewed or constituted an unreviewed safety questio This is identified as Unresolved Item N /79-45-03, Status of Safety Review of Valve Modificatio The inspector also stated that due to the nature of the damage to Valve No. 1-FW-10 the repairs to this valve would be identified for details inspection at a later date. This inspector follow-up item is identified as Item No. 280/79-45-04, Repair of damage to valve 1-FW-1.
Review of Fabrication History for Primary Shield Tank (Unit 2)
The inspector reviewed the records associated with the disposition of welding problems identified in AEC inspection report no. 70-1 and Stone and Webster Rejection and Disposition Report No. 27 These records included the correspondence between the vendor, Newport News Shipbuilding and Dry Dock Company and Surry personnel concerning the problems listed in R/0 Report No. 27 The inspector noted that some of the welds rejected by R/0 No. 270 were accepted by Engineering based on acceptable radio graph The-inspector requested that the licensee retrieve the radiographs for this structure from the vendor for a review by IE:II at a later date. The licensee agreed
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-6-to inform the NRC resident ins.p_ector when the radiographs are at the site and ready for review.