IR 05000280/1981011

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IE Insp Repts 50-280/81-11 & 50-281/81-11 on 810331-0403. Noncompliance Noted:Failure to Establish Adequate Controls for Protection of Installed Equipment & Failure to Follow Welding Control Procedure
ML18139B452
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/21/1981
From: Herdt A, Kleinsorge W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18139B447 List:
References
50-280-81-11, 50-281-81-11, NUDOCS 8107240400
Download: ML18139B452 (10)


Text

UNITED STATES e

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/81-11 and 50~281/81-11 Licensee:

Virginia Electric and Power Company Richmond, VA 23261 Facility Name:

Surry Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection at~~y/.s~~near Williamsburg, VA Inspectob::-:-~--=---=-~=~--=-~~~~~~~~~~~~~~~~~~

qi W. P. Kleinsorge Approved by: t:tl;4d/J SUMMARY A. R. Herdt, Section Chief Engineering Inspection Branch Engineering and Technical Inspection Division Inspected on March 31 - April l, 1981 Areas Inspected Date Signed This routine, unannounced inspection involved 27 inspector-hours on site in the areas of storage of installed equipment (Units 1 and 2), steam generator replace-ment - observation of welding and welding activities (Unit 1), nondestructive examination - steam generator replacement - observation of work (Units 1 and 2),

and allegation concern regarding reactor coolant system design and modification (Unit 2).

Results Of the four areas inspected, no violations or devi.ations were identified in two-areas; two violations were identified in two areas (Violation -

Failure to establish adequate controls for protection of installed equipment - paragraph 5.b., and Violation - Failure to follow welding material control procedure -

paragraph 6.a.(l)(a)).

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  • Persons Contacted Licensee Employees REPORT DETAILS
  • J. L. Wilson, Station Manager

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S. McKay, Engineer, SGRP

  • R. Driscott, Resident QC Engineer, SGRP
  • J. Patrick, Superintendent Maintenance
  • 0. J. Costello, Staff Assistant Other licensee employees contacted included construction craftsmen, techni-cians, *security force members, and office personne Othef Organizations Stone and Webster
  • T. Sowers NRC Resident Inspector
  • D. Burke
  • M. Davis
  • Attended exit interview Exit Interview The inspection scope and findings were summarized on April 3, 1981 with those persons indicated in paragraph 1 abov The inspector described the areas inspected.and discussed in detail the inspection findings listed belo No dissenting comments were received from the license (Open) Violation 280, 281/81-11-01: "Failure to establish adequate controls for protection of equipment" - paragraph (Open) Violation 280/81-11-02:

11 Failure to follow welding material control procedure" - paragraph 6.a.(l)(a).

(Open) Unresolved Item 280/81-11-03:

"Welder qualification test visual inspection" - paragraph 6.a.(3).

(Open) Unresolved Item 281/81-11-04:

"Section XI inspection of weld buildup

- paragraph 8.b.

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(Open) Inspector Followup Item 281/81-11-05: _HVerification of weld stress analysis 11

- paragraph.,

(Open) Inspector Followup Item 281/81-11-06:

11Verification of seismic analysis 11

- paragraph (Open) Inspector Followup Item 280, 281/81-11-07: Disregard for radiolog-ical warn*ing signs" - paragraph.

Licensee Action on Previous Inspection Findings Not inspecte.

Unresolved Items

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Unresolved items are. matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraphs 6.a.(3) and.

Independent Inspection Effort (Units 1 and 2) Construction Progres The inspector conducted a general inspection of the Unit 1 auxiliary and reactor buildings to observe construction p~ogress and construction activities such as welding, material handling and control, housekeeping and storag Storag~ of Installed Equipment*

With regard to the inspection of paragraph 5.a., the inspector on April 1, 1981, accompanied by a representative of the licensee, noted two examples of scaffolding supported by safety-related piping in the Unit 1 reactor and auxiliary buildings when questioned by the inspector the licensee stated that they control scaffolding on installed piping by the "good judgement of the craft".

The inspector informed the licensee that the above indicated inadequate controls for _protection of installed equipmen Failure to establish controls for protection

  • of equipment in accordance with instructions to prevent damage, is in violation of 10 CFR 50, Appendix B, Criterion XII The above vio-lation will be identified as 280. 281/81-11-01:

"Failure to establish adequate controls for protection of installed equipment".

Within the areas examined, no violations or deviations were identified except as described in paragraph *

e 3 Steam Generator Replacement Observation of Welding and Associated Activities (Unit 1)

The inspector observed/reviewed welding, welding activities and programs described to determine whether these are relative to the steam generator rep 1 acement a re being accomp 1 i shed in accordance with regulatory requfre-ments, applicable codes standards and licensee commitment The applicable codes are. as follows:

for piping fabrication is USAS 831.1 (1967), f6r main steam* supports is AWS Dl.l-77, and for welder qualification is ASME Section IX (edition and addenda in effect at the time of qualification). The inspector observed in-pro~ess welding activities of field welds described be 1 ow to determine whether app 1 i cab 1 e code and procedure-requirements were being me (1) Welding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure; WPS assignment welding technique and sequence; materials id~ntify; weld geometry; fit-up; certified welding filler material; weld identification; surface preparation; weather protection; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition;- interpass temperature; interpass cleaning; process control systems; identity of welders; qualification of inspection personnel; and weld history record Main steam support on Design Change 79532R711 Reactor Coolant Weld No. 4 on ISO E-100 With regard to the above inspection, on April 1, 1981, the inspector accompanied by*a representative of the licensee noted an unplugged electrode caddie.containing cold type 7018 electrode The electrodes were being used by the welder on the main steam support abov DCC Construction. Procedure WP-502, 11Control of Welding Materials 11, Revision 3, paragraph 4.4-2 requires caddies to be plugged in at all time Failure to follow procedure fo activities affecting quality is in violation of 10 CFR 50, Appen-dix 8, Criterion This violation°will be identified as 280/81-11-02:

11 Failure to follow welding material control procedure 11 *

(2)

Wel~ Heat Treatment

. The inspector reviewed the DCC program for weld heat treatment for compliance with QA procedure and Code requirement The weld~

listed in paragraph 6.a.(1) were examined in process relative to

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weld joint preheating to determine; procedures available; proce-dures specify acceptable preheating method; procedures provide monitoring and recording requirements and procedure complianc (3) Welder Qualificatio The inspector reviewed the DCC program for qualification of welders and welding operators for compliance with QA procedures*

and ASME Code requirement The following welder qualification status records and 11 Records of Performance Qualification Test

. were reviewed relative to the weld joints listed in paragraph 6.a.(1).

Welder Symbol Unit Organization Application 098'

Dcc*

Main Steam Support 035

DCC Main Steam Support 263

DCC Main Steam Support 342

DCC Reactor Coo 1 ant 152

DCC Reactor Coo 1 ant 360

DCC Reactor Coo 1 ant 156

DCC Reactor Coo 1 ant 246

DCC Reactor Coo 1 ant With regard to the above, the inspector, on April 3, 1981, noted that the welder qualification test records, for Test 8-8-M-22, Revision 1, had visual inspection documented on approximately*50%

of those records examine The licensee indicated that they would look further into the matter. The inspector stated that the above would be unresolved item 280/81-11-03:

11Welder qualification test visual inspection 11 * *

(4) Welding Filler Material The. inspector reviewed the DCC program for control of welding materials to determine whether materials are being purchased, accepted, stored and handled in accordance with QA procedures and applicable code requirement The following specific areas were examined:

Purchasing procedures, receiving, storing, distributing and handling pro~edures, material identification Welding,material purchasing and receiving records for the fo 11 owing materi a 1 s were reviewed for conformance with applicable procedures and code requirements:

e Process*

GTAW GTAW GTAW SMAW

Type 308L-Insert ER 308 ER 308 7018

  • Gas Tongsten Arc Welding - GTAW
  • Shi e 1 ded Meta 1 Arc We 1 ding - SMAW (5)

Repair Welding e

Heat/Lot Number 4363-308L A4311T-308 Y4070L-308 0268202 The inspector reviewed the DCC program for control of weld repairs and weld repair documentation to determine the adequacy of proce-dures, and to verify implementation of these procedure (6)

Personnel Protection In order to determine that procedures and equipment-were in place to protect cutting and welding personnel, the inspector observed/

reviewed the following:

(a)

VEPCO Health Physics (Radiation Protection) Manual has been issued and in use. The above requires Radiation Work Permits (RWPs). to be issued for all work to be performed in radiation area (b)

The inspector observed that for the welding of Weld No. 4 on ISO ElOO reactor coolant system piping RWP No. 81-SGRP-RWP-192 had been issued and poste Within th*e areas examined, no violations or deviations were identified except as described in paragraph 6~a.(l)(a). Nondestructive Ex~mination - -Steam Generator Replacement - Observation of Work (Units 1 and 2)

.The inspector observed radiographic inspection in progress and reviewed the radiographic film for the below listed joints. The above inspection was compared with the applicable procedure in the areas of type of material, surface condition, material thickness, type of radiation source, film brand/type, minimum source to film distance, type and thickness of screens, exposure condition, radiographic film processing, quality of radiographs, film density, use of dens-itometer, radiographic identification, use of location markers, method of reducing and testing for back scatter, selection and use of penetrameters, and evaluation and disposition of radiograph Weld No Unit

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ISO N E-100

Size

11 Sch 160 System Chemical Volume and Control With regard to the above inspec~ion~ the inspector on April 1, 1981, in the auxiliary building, observed two individuals moving a radiological warning sign ( 11 Radi at ion Area Radi ographi ng In-Progress Keep Out 11 ) ahd went under the 2MR*barrier rope. After crossing the barrier rope, they were stopped by the radiography cre The 68 Curie source was exposed at the time of the crossin In addition to the warning sign and barrier rope, four verbal warnings were made over the public address system just prior to the source exposure and the crossing. A representative of the licensee informed the inspector that he had noted a number of similar occurrences. The inspector then contacted *the RII office arid communicated his concerns in this matter to a Regional radiation specialist. This inspector (radiation specialist}

then contacted both the facility health physics supervisor and NRC resident inspector and obtained from the former a commitment to carefully examine the licensee's practices with regard to training of construction workers to observe radiological warning signs and also to ~eview with his management policy and practices to ensure proper discipline in similar cases. The NRC senior resident inspector agreed to coordinate with the facility HP super-visor to ensure the evaluations and actions taken were adequat During a futur~ radiation protection inspection, RII:IE will followup on this ite This item will be identified as inspector followup item 280, 281/81-11-07:

11Disregard for radiological warning signs".

Within the-areas examined, no violations or devi~tions were identifie.

Concern Regarding Reactor Coolant Sys~em-Desig~ and Modificatibns (Unit 2)

. The NRC was contacted by an i ndfvi dual who expressed the fo 11 owing concerns in substance:. Concern - In some cases, the weld buildup process used to prepare reactor coolant piping for reuse durin~ the steam generator replacement at Surry Unit 2 required the deposition of approximately four inches of weld material which may constitute a potential safety hazard. There.

. was no engineering evaluation of the buildup process to ensure reactor coolant system integrity;* only an assumption that the weld metal would serve as an exact replacement of the original base materia Inspection - The use of weld buildup i's a standard industry proces The inspector reviewed the certified material test reports for welding*

filler material used for the buildup in question and the welding procedure qualification test report for the welding procedure speci-fication employed for the deposition of the buildup in questio '

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The inspector determined that the physical properties. of the weld buildup would exceed the minimum required by the material specifica-tions for the reactor coolant system piping materials. In view of the above there appears to be no basis for the concer Concern - There are no requirements for inservice inspection of these weld buildup areas as they are not* specifically addressed in ASME Code Section X Inspection - The inspector discussed this matter with the license The licensee stated that the weld buildup was inspected prior to welding the fabrication butt weld in accordance with USAS B31.l, employing radiographic and liquid penetrant methods, as required. (The weld and ~-inch or adjacent base material.)

The applicable code for inspection method was ASME Band PV c*ode Section The applicable code for acceptance was the more restrictive

. of USAS B31.1 or ASME Section III, Subsection N The licensee further stated that they considered the weld buildup as a base material repair and therefore part of the base material, and not part of the subsequent fabrication butt weld. Further the licensee stated that they inspected (ultrasonic) the fabrication butt welds and one wall thickness of 11base

  • material" (base material and repaired base material) beyond the weld as required by ASME B&PV Code,Section XI, Table IWB-2500 B-The licensee considers they are in full complianc ASME Section XI, IWB-2100 and IWB-2500 B-J require that 100% of Class 1 circumferential pressure-retaining welds in piping and the base material for one wall thickness beyond the edge of the weld be volumetrically (ultrasonic or radiographic technique) inspected. The weld buildup is a full thick-ness pressure retaining wel ASME Section XI is not clear as to

_whether the buildup is to be considered as base material or an ex.ten-sion of the fabrication butt wel The licensee indicated that they would look further into the matte The inspector stated the above wou*ld. be an unreso*lved item identified as 281/81-11-04: "Section *IX inspectfon of weld buildup". Concern - Installation of the reactor coolant p1p1ng induced stresses in the steam generator lower support rings which may not have been considered in calculations to determine serviceability of the supports; vertical stresses induced in the reactor coolant piping due to weld,

shrinkage may not have been taken into account in the analyses of the steam generator supports and the reactor vessel nozzle Inspection - The inspector discussed this. matter with the license The licensee stated that weld stresses induced into the support system, steam generator and reactor vessel nozzles were analyzed by the nuclear

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steam supply system manufacturer, Westinghous Westinghouse deter-mined that the loads resulting from the welding stresses were accept-able and consistant with the design basis. At the time of this inspec-tion, the existence.of the above analysis could not be verifie The inspector stated that the above would be an inspector followup item pending the verification ~f the analysis existence. This item will be identified as 281/81-11-05: "Verification of weld stress analysis". Concern - Comparison of the reactor coolant system supports with those on le.ss massive systems indicates that the reactor coolant system supports would fail under seismic loadin Inspection - The reactor coolant system supports were designed by Stone and Webster Engineering Corporation as described in the Surry Units 1 and 2 FSA At the.time of this inspection it could not be verified whether seismic loading considerations were included in support system analysi The inspector stated that the above would be an inspector followup item pending the verification of the inclusion of seismic considerations in design of reactor coolant system supports. This item wil 1 be identified. as 281/81-11-06:

"Verification of seismic ana lysi s 11 * Concern - All records of the 100% ultrasonic and magnetic particle.,

inspection of the support rings performed during original construction have been misplaced; however, it was determined it was not necessary that a 100% reinspection be performed to ensure no degradation of the ring Several cracks in high stress areas of the steam generator support rings were identified by spot magnetic particle inspection

  • during steam generator replacement, but only one or two were repaire Inspection - The inspector discussed the above matter with the licensee who stated that during the original fabrication 6f the support ring the castings were examined by magnetic particle and ultrasonic examination methods~

At that time~ magnetic particle and ultrasonic indications attributable to nor~al casting shrinkage wera noted and found to be acceptab 1 e by the engineers. These records were not retained by the manufacture The inspection program on the support rings during the SGRP consisted of a complete visual examination and magnetic particle examination of the steam generator support seats and the points where the 1 ower support ring meets the lower ring support rod Also, areas where visual indications were found were inspected by magnetic particl Recordable indications found during the magnetic particle examinations were reported to engineering for evaluation and disposition. It should be noted that indications found were typical of those noted during original fabrication (shrinkage).

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Exploratory grinding was initiated to determine the severity of the indications note In order to fully evaluate the condition of the ring castings stress analysis and fracture toughness calculations were performed, as reported in Stone and Webster 1 s 11 Evaluation of Steam Generator Lower Ring Castings 11 dated April 7, 198 The support rings were modeled by finite element methods and the s~ress analysis was performed using the STARDYNE computer pro*gra The conclusions drawn from this stress analysis work are that verification has been provided that the lower ring ~astings meet the original design criteria and that the maximum nominal stresses indicated in the ring are less than 18 KS! and are due to design basis loadings (accident conditions).

Normal stresses are significantly below 18 KS!.

This compares to the material allowable stress of 36 KS!.

In addition, a fracture mechanics analysis was performe This resulted in a critical crack size of dimensions 4 to 12 inches deep and 20 to 30 inches 1 on On the basis of these ca lcul ati ons it was determined that most of the recordable indications were 11acceptable -

as - is 11 *

The other areas were weld repa-ire The inspector reviewed the Stone and Webster evaluation and no incon-sistencies were identified. In view of the above, there appears t~ be no basis for the concer Within the areas inspected, there were no violations or deviations identi-fied.