IR 05000395/1986018
| ML20213D070 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/04/1986 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20213D064 | List: |
| References | |
| 50-395-86-18, NUDOCS 8611100413 | |
| Download: ML20213D070 (9) | |
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101 MARIETTA STREET,N.W.
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Report No.: 50-395/86-18
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Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.: 50-395 License No.: NPF-12
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Facility Name: Summer s
Inspection Conducted: September 29 - October 3, 1986
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Inspector:
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W. P., K r
Date Signed
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8 / 86 Approved by:
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J'.//. AYaM, Sec Tath Signed
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En(igeering
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Division Re tor Safety p
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SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters (92701B)(927028), housekeeping (548348), material identification and control (42902B) material control (429408),
inservice inspection - review of program (73051), ultrasonic examination volume, s
inspector followup items and review of periodical and special reports.
Results: No violations or deviations were identified.
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P 8611100413 861106 PDR ADOCK 05000395 G
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REPORT DETAILS
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Persons Contacted
Licensee Employees 7, 3.,
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'" % 0.'Aradham, Director of Nuclear Plant Operations
- J. Moles, Deputy Director of Operations and Maintenance
- Di R. Moore, Director, Quality and Procurement Services
- >O N.'becwn, Group Manager - Technical and Su
- F. J. l.c3ch, Manager. Quality Assurance (QA) pport Services A
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- S.,RxHont, Manager Quality Control (QC)
- M. D. Quintan, Manager, Maintenance Services
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- A. R, Koon, Jr.,' Manager, Technical ' Support v
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Other licensee employees contacted included engineers, ' technicians, and
.of[ ice personnel.
ilRC kesident Inspectors
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- R. Prevatte, Senior Resident Inspector
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- P. Hopkins, Resident Inspector
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- Attesied exit interview J. %'
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2.~ Exit Interview (30703B)
O n i^ inspection scope and findings were summarized on October 3, 1986, with those persons indicated in paragraph 1 above.
The inspector described the
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arcat inspected and discussed in detail the inspection findings.
No dis-Smitinc comments were received from the licensee.
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(0 pen) Unresolved Item 50-395/86-18-01:
VT-2 Eye Examination"
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-paragraph 3b.
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!i C ~(0 pen) Inspector Followup Item 50-395/86-18-02:
QA Auditor Qualification
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N Procedure" - paragraph 6b.
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The' licensee did not identify as proprietary any of the materials provided i
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to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (UNR 92701B) (VIO 92702B)
a.
(Closed) Violation 50-395/84-31-01:
Procedures Do Not Assure Valve
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i Remote Position Indicator Checks at the Frequency Required."
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SCE&G letter of response, dated December 27, 1984, has been reviewed b
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and determined to be acceptable by Region II.
The inspector held
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3 discussions with the responsible engineer and examined the corrective actions as stated in the letter of response.
The inspector concluded that SCE&G had determined the full extent of the subject violation, performed the necessary survey and follow-up actions, to correct the prese.;t conditions and developed the necessary corrective actions to
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preclude recurrence of similar circumstances.
The corrective actions identified in the letter of response have been implemented.
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b.
(Closed) Unresolved Item 50-395/85-22-02:
" Training for Visual Examiners."
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This matter concerns,the adequacy of the. training and qualification programs for VT-2, visuals examiners (inspectors). The inspector inter-
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viewed licensee personnel, reviewed procedures and examined records and determined that the program is adequate with the exception noted below.
The acceptance criteria for VT-2 inspectors as specified in SCE&G Procedure NTCI-18, Revision 3, paragraph 4 states:
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"4.
The VT-2' inspector shall satisfactorily complete the following eye
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exams on an annual basis.
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a.
Jaeger-1 (near ' vision) at a distance of not less than 12 inches in at least one eye.
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Snellen'(distant vision) at 15 feet in at least one eye.
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Color vision (distinguishing and differentiating contrast between colors) in at least one eye."
I The documentation attesting to visual acuity found in the qualification folders for Nuclear Operations VT-2 examiner folders was unsigned and stated in part the following:
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Eyes:
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DistantVision(snellen): without glasses: Right 20/
Left 20/'
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Near Vision (14 to 18 inches):
(V50D to V200D)
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Corrective prescription with glasses:
Right Left Addsfor near (if any)
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Evidence of disease or injury
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Lens (with dilated pupils)
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Intra-ocular tension:
(with Schiotz Tonometer)
Right Left
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Color Vision Method Used
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The licensee was unable to provide documented correlation between the acceptance criteria of Procedure NTCI-18 and data presented on the
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unsigned document in the qualification folders.
The inspector discussed the above with the licensee, who indicated that they assure that the acceptance in Procedure NTCI-18 was consistent with the ASME Code'Section XI requirements for visual acuity ter VT-2
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'y examiners and correlates directly with certified (signed) documented
evidence of visual acuity for each visual VT-2 inspector. This matter i ~
will be closed Unresolved Item 50-395/85-22-02. Pending NRC review of licensee actions concerning the clarification of above, and the deter-mination whether all VT-2 examiners (inspectors) had visual acuity consistent with ASME Code Section XI, at the time of their last VT-2
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examination, this matter will be identified as Unresolved Item 50-395/86-18-01:
"VT-2 Eye Examination."
4.
Unresolved Items 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 paragraph 3b.
5.
Independent Inspection Effort Housekeeping (54834B), Material Identification and Control (429028) and Mqterial Control (429408)
The inspector conducted a general inspection of auxiliary building to
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observe activities such as housekeeping, material identification and con-A trol;' material control, and - torage.
Within the areas examined, no violations or deviations were identified.
6.
Inservice Inspection (ISI) - Review of. Program (73051)
The inspector reviewed procedures, interviewed licensee / contractor personnel and reviewed records to determine whether the licensee's program pertaining to the ISI is complete and in conformance with regulatory requirements and the licensee's commitments, as indicated below. The applicable Code for ISI is ASME Boiler and Pressure Vessel (ASME B&PV) Code Section XI 1977 Edition, Summer (Winter) 1978 Addenda.
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a.
Program Approval The inspector interviewed personnel and reviewed documents indicated below to determine whether requirements were met in the following areas:
ISI program, including examinations and. tests, is in confor-mance with relevant ASME Code Section XI editions and addenda, and Code cases proposed for use as part of the plan; services of an Authorized Nuclear Inservice Inspector (ANII) have been procured and the ISI plan has been reviewed by the ANII in accordance with Article IWA-2120 of the ASME. Code; and the ISI plan has been reviewed by the licensee's site nuclear safety review committee, or equivalent licensee review and approval has been documented.
With regard to the inspection above, the inspector noticed the following:
Requests for relief from Code requirements have been submitted to the
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Commission, however, as of the date of this inspection, no approval or denial has been received by the licensee from the Offir.e of Nuclear Reactor Regulation (NRR).
The current revision of the ISI plan has not been reviewed by the Site
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Nuclear Safety Review Committee. The licensee indicated that this will be accomplished at the October 8,1986, meeting of the committee.
October 8,1986, is within 30 days of the date of issue of latest revision. The above is permitted by the licensee's program.
b.
Program Organization The inspector reviewed the licensee and ISI contractor's QA programs to verify the following:
procedures for the maintenance of required ISI records; QA review includes assurance that plans and procedures have been reviewed by appropriate personnel and meet regulatory require-ments; procedures are established for the corrective action of condi-tions adverse to quality as detected during examination, including provisions to preclude repetition of such adverse conditions; audits or surveillances of ISI activities are conducted by qualified QA personnel to verify compliance with the ISI program; and procedures are estab-lished to effectively oversee contractor activities concerned with ISI/ PSI.
With regard to the inspection above, the inspector noted that the licensee's procedure for qualification of QA auditors was cancelled effective August 1, 1986, and its replacement is still in preparation.
Pending NRC review of the licensee's auditor qualification procedure, this matter will be identi-fied as Inspector Followup Item 53-395/86-18-02:
"QA Auditor Qualification
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Procedure."
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Repair Program The inspector reviewed the licensee's administrative and maintenance procedures indicated below to verify that the requirements of Article IWA-4000 of the ASME Code, and NRC supplementary requirements, are included or referenced.
d.
Replacement Program The inspector reviewed the licensee's administrative and maintenance procedures indicated below to verify that requirements of Article IWA-7000 of. the ASME Code, and NRC supplementary requirements, are included or referenced.
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Records The inspector reviewed procedures and records indicated below to determine whether provisions for the maintenance and retention of records, including inspection, examination, test reports, repair and
. replacement, QA, and -NDE records have been established in the ISI'
program.
f.
Qualification of Personnel The inspector review procedures indicated below to determine whether the ISI program specifies personnel' qualification requirements consis-tent with the ASME Code, plant Technical Specifications (TSs), and
other applicable documents.
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Reporting Requirements The inspector reviewed procedures indicated below to determine whether the licensee's ISI program includes the ASME Code and plant TS require-ments for submittal of written reports of ISI results, repairs, and replacements.
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Relief Requests
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The inspector reviewed procedures indicated below to determine whether
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the licensee's program contains guidance regarding the identification and processing of requests for relief from ASME Code requirements. The
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inspector conducted a walkdown inspection as indicated below to detennine whether the bases for the relief requested are valid and accurate.
Relief Request No.
Weld No.
2-Pipe-2 49-2523 2-Pipe-2 50-2523 2-Pipe-2 89-2523-
2-Pipe-2 90-2523
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'6 Documents Reviewed Identification Title A-NQCP-13, Rev. 2
" Nuclear Operations Records Accumulation and Retention" A-NQCP-14, Rev. 2
" Transmittal and Maintenance of Records in the Plant Record System" A-NQCP-15, Rev. 2
" Nuclear Storage Facilities"~
A-NQCP-8, Rev. 5
" Qualification and Certification of Nuclear Quality Control Inspection Personnel" WM-1.0, Rev. 8
" Welding Manual Procedure"
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CLA, B&C WM-2.0, Rev. 8
" Welding Materials Procedure" QPS-10, Rev. 0
" Audits / Surveillance Report' Preparation" QPS-101, Rev. 0
" Internal SCE&G/QA Audits" QPS-5, Rev. O
" Release to Work" SAP-145, Rev. 2
" Inservice Inspection" Rev. 15
" Operational Quality Assurance Plan" GTP-303, Rev. 3
" Inservice Inspection Nondestructive Examination" GTP-304, Rev. 1,
" Inservice Inspection System Pressure Testing" Change A GTP-305, Rev. 4
" Inservice Inspection for Component Supports" SAP-145, Rev. 2
" Records Management and Document Control" SAP-139, Rev. 8
" Procedure' Development, Review Approval &
Control" SAP-146, Rev. 2
"Nonconformance Control Program" A-NQCP-2, Rev. 5
"Nonconformance Control" Within the areas examined, no violations or deviations were identified.,
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Ultrasonic Examination Volume
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Operating-License Condition 2.c.11 states:
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"(11)
Inservice Inspection and Testing (Section 5.2.4, SSER 3)
i SCE&G shall perform the following actions in conjunction with the first inservice examination:
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Demonstrate the ability of the ultrasonic examination proce-dure to detect actual flaws and/or artificial' reflectors in
the volume subject to examination to the_ acceptance standards of Paragraph IWB-3500 in weldments representative of the
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design and materials of construction, b.
In the event that one-third thickness semi-circular reference flaws cannot be detected and discriminated from inherent anomalies, the entire volume of the weld shall be examined
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during the inservice inspection."
NRC Report 50-395/84-13 documents that SCE&G's successfully demonstrated the ability of their ultrasonic examination proce~ dure -and equipment (which
included a new design transducer) to detect and locate flaws and artificial reflectors in the volume subject to examination (to the acceptance standards l
of paragraph IWB-3500 of ASME Code,Section XI) in weldments representative r
of the design and material of construction.
SCE&G discussed:the above with the inspector indicating that they would like to propose and implement a change to their current ultrasonic examination procedure T-NQCP-10, Revision 4.
For ISI examinations, change the volume coverage from full volume to the-inner 1/3 as detailed in ASME Section XI.
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SCE&G's basis for this change is supported by previous examinations per--
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formed during preservice inspection which covered the full volume and the demonstration performed by SCE&G's staff level III establishing their
ability to detect and locate actual flaws and artificial reflectors in a weldment representative of. the design and material of construction.
In addition, the SCE&G ISI plan delineates the code requirements for surface examination for Classes I and II component and piping.
This exam coupled with the code volume of inner 1/3 serves SCE&G with the necessary informa-tion to determine the acceptability of their welds.
For all new welds requiring PSI data, a full volume code exam would be performed.
An addi-t tional consideration is the reduction in personnel exposure which can be expected as a result of this change.
The above clearly indicates that the proposal is consistent with their-
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commitments and ASME Code Section XI, 1977 Edition, Summer 1978 Addenda.
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Inspector Followup Items (0 pen)InspectorFollowupItem 50-395/84-31-02:
" Stroke Time Limits" The inspector of record for Report 50-395/84-31 noted the maximum acceptable stroke times specified for valves XVT-8149 A, B, & C by the licensee were 40 seconds. These are fast-acting air operated valves. Typically, such valves operate in under two seconds.
The inspector informed the licensee that he believed that setting a 40 second maximum stroke time for such valves was almost meaningless.
This inspector looked further into this matter and found that valves XVT-8149 A, B & C are among 52 valves of varying sizes and types that are listed in Table 3.6-1, " Containment Isolation Valves," of the TS, all of which have a specified maximum isolation time of 40 seconds. Of the 52 valves, 40 valves have actual average closure times less than 10 seconds, and 38 valves have actual average closure times less than 5 sec-onds. ' The licensee stated that because the TS permit 40 seconds for isola-tion (the time to perform their safety function). They will use that value for ASME P&BV Code Section XI stroke time.
The licensee further indicated that to select a value more restrictive than the TS-requirements would set a bad precedent for the company.
The inspector reviewed the stroke times for approximately 150 other valves in the ISI program that are not containment isolation valves and found with only a few exceptions those valves had maximum IST program specified stroke times of 120 to 200% of the actual average stroke times observed for the valves.
The licensee was not able to tell this inspector whether any of the other 150 valves were of the same manufacture and model as the containment isola-tion valves and whether the non-containment isolation valves.are exposed to the same environment as the containment isolation valves.
In addition, because ASME Section XI is concerned with determining component performance prior to failure so repairs can be made prior to failure during an opera-tional emergency, considerations must be given to component (valve) degrada-tion as well as operational considerations. This item remains open.
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Review of Periodical Special Reports (90713)
The. inspector reviewed SCE&G Steam Generator Tube Eddy Current Examination report submitted September 1986 to NRC Region II pursuant' to Summer TS 4.4.5.5(B).
This review was performed to evaluate the adequacy, complete-ness and timeliness of the report as it relates to ASME Section XI and other regulatory commitments.
Within the areas examined, no violations or deviations were identified.
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