IR 05000412/1986037

Insp Rept 50-412/86-37 on 861020-24.No Violations Noted. Unresolved Item Re Storage & Security of Onsite Radiography Opened.Major Areas Inspected:Preservice Insp Activities Including Procedures,Nde & Data Records

ML20212G924
Person / Time
Site:	Beaver Valley
Issue date:	01/14/1987
From:	Lodewyk A, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212G906	List: IR 05000412/1986037 ML20212G900
References
50-412-86-37, NUDOCS 8701210235
Download: ML20212G924 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-412/86-37 Docket No. 50-412 License No. CPPR105 Licensee: Duquesne Light Company P. O. Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Station, Unit 2 Inspection At: Shippingport, Pennsylvania Inspection Dates: October 20-24, 1986 Inspector: l9m /2/2)l16 A/J/Lodewyk, Pfactor Engineer dhte Approved by: I d&-

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J/ R. S(trosnider7 Chief, Mat ials and

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1. rocesses Section, EB, DRS, I Inspection Summary: A routine, unannounced inspection was conducted during October 20-24, 1986 (Report No. 50-412/86-37) of the licensee's Preservice Inspection (PSI) activities. Those areas inspected include the licensee's responses to previously identified NRC items, PSI procedures, observation of nondestructive examination activities, and data record Results: During this inspection, two previously identified NRC items were closed and no violations were identified. However, one l unresolved item was opened regarding the storage and security of the onsite radiography source.

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8701210235 870115 PDR ADOCK 05000412 G PDR

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DETAILS 1.0 Persons Contacted Throughout this inspection, various site and corporate office representa-tives were interviewed for information and auditing purposes. Those persons contacted include the following:

Duquesne Light Company (DLCo)

• William Sikorski, Director of ISI

• Ronald Perry, Supervisor of NDE Services (ISID)

R. Coupland, Director of QC C. Majumdar, Assistant Director of QC M. Hartman, Training Administrator

• J. Jaworski, Senior Engineer, SQC T. Kocher, NDE Services Department G. Buck, NUE Services Department

• D. Rohm, Asst. Dir. of QA

• A. Crevasse, Dept. QA Manager

• R. Wa11auer, Lead Compliance Engineer

• Williams, Dir. Start-up

• R. Swiderski, S.U. Manager

• R. Wittschen, Licensing Engineer

• A. Mosso, NDE Coordinator

• J. Johns, Supvr. QA Surveillance US Nuclear Regulatory Committee

• A. hsars, Resident Inspector

• J. Beall, Senior Resident Inspector

• L. Tripp, DRP Section Chief

• denotes those persons present at the exit meeting conducted at the close of this inspection on October 24, 1986.

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2.0 Licensee Actions on Previous Inspection Findings l

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2.1 (Closed) Violation (50-412/86-13-01) regarding linear indications visible to the surface in Steam Generator C. Specification 2 BVS-43, Fabrication of Steam Generators, requires that structural shapes with thickness between 3/8 and 2 inches be conditioned by the removal of injurious linear imperfections which exceed 1/16 inch in dept Contrary to this, an NRC visual examination during June 9-20, 1986 l disclosed that a previously inspected and accepted lower support

! assembly for Steam Generator C had a linear indication which was l

approximately 3/16 inch deep, that had not been recorded or disposi-tioned as required.

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The licensee issued Nonconformance and Disposition report N and the final indication size was determined to be 18 inches in length and 3/16 inch in depth. The flaw was blended into the surrounding base metal and an engineering review indicates the structural integrity of the support member has not been compromise SWEC procurement inspection records and Quality Control installation documentation did not disclose any information which would show that the indication was reported previously. However, at the time of the NRC inspection, the succort had not been painted and thus, the pre painting inspection governed by the following procedures had not been completed:

a) IP-6.3.3, " Inspection and Testing of Protective Coatings" b) FCP-804, " Inspection and Testirg of Category I Coatings" The inspector reviewed these procedures, onsite training and quali-fication of personnel certified to visually examine surfaces for defects and finish. The procedures specified the visual acceptance criteria, including rejectable surface laminations. The inspector determined the course outline and training tapes adequately adcrcised surface preparation and the effect of sharp edges on surface tension and capillary actio Course examinations were reviewed for evidence of questions regarding the potential problems due to surface discon-tinuities and weld spatter. Personnel are trained and certified onsite to perform these inspections in accordance with ANSI N45.2.6-1978 " Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants". Personnel certification packages for Level I and Level II individuals were inspected for education, training, examination and experience requirements. The personnel certification records, training materials and examinations were found adequate to address the concern for identification of surface discontinuitie The subject defect has been acceptably dispositioned, and an acceptable program is in place to identify the defect. This item will remain open pending completion of the licensee's pre painting inspection and NRC review of the subsequent documentation identifying the results of the inspectio .2 (Closed) Violation (50-412/86-13-92) regarding liquid penetrant test (PT) indications on the facility Spent Fuel Racks. Nuclear Engineering Services (NES) Specification 80A7780, " Fabrication and Inspection of the Neutron Absorber Spent Fuel Storage Racks",

states that any cracks or linear indications greater that 1/16 inch shall be considered unacceptable. During liquid penetrant examination of a sample of critical welds denoted on detail drawing NES 80E7653, an NRC inspector found linear indications in two fillet welds on fuel bundle #16. The result of a Duquesne

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Light Quality Control (DLC/SQC) reexamination, substantiated the indications found by the NRC and the indications were documented on Nonconformance and Disposition Report (N&D) No. 3247 NES Specification 808A7780 states that critical welds may be examined using an approved sampling plan. The vendor supplied documentation for Fuel Rack NES-16 showed the two welds in question had not been PT inspected under this sampling pla The two 3/32 inch fillet weld areas found deficient, exhibited a multi pass weld operation that was considered as indicative of a repaired area. As the defect would not be ground out, per Engineering instructions, the bottom critical welds were examined on all 17 racks for indications of multi pass applicatio The results of this examination entailed detailed rework as noted on N&D 3341 Rework was completed under DLC/SQC surveillance. QC visually inspected welds on the Spent Fuel Racks and suspect welds received liquid penetrant examinations. Finally, all welds were satisfactorily reworked, repaired, or dispositioned under the following reports: N&D 33415, N&D 33415A, N&D 20174A, N&D 32471 or N&D 32471 The licensee has notified NES of the problems associated with the multi pass welds and Specification 2BVS-40 will be revised to require that all shop-repaired welds be liquid penetrant inspected for future purchase of Spent Fuel Racks. The inspector had no further questions at this time. This item is close .0 Preservice Inspection (PSI) Activities 3.1 Observation of Work Activities The inspector reviewed the licensee's nondestructive testing activities being performed as part of the Preservice Inspection Program. Those

activities reviewed and discussed in further detail below include liquid penetrant examinations, ultrasonic and radiographic testin . Liquid Penetrant Examinations Those activities observed during this inspection include the liquid penetrant testing of Residual Heat System (RHS) vessel E21A, item no. B8.40, weld 1WS. The specific procedure steps verified during completion of the liquid penetrant exam include:

- surface preparation, cleaning and temperature requirements penetrant application, dwell time, removal and surface dryinc

- developer application, evaluation and recording of linear and

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curvilinear indications

- type of cleaner, penetrant and developt- materials used

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will remain open pending further review of the RT technicians train-ing and the sequence of events by a nuclear materials license specialis (Unresolved Item 86-37-01)

3.2 Review of Data and Records Data associated with the nondestructive examination of various welds and components were reviewed to ascertain compliance with applicable code and administrative requirements. The following data sheets were included in the inspector's review:

- PT data sheet for RHS-E21A, weld IWS, item no. 88.40

- UT data sheet for 2CHS-FLT24A, weld 2, item no. C1.20

- UT data sheets for Pressurizer nozzle welds 10 to 14

- UT data sheets for 2CHS-E23, weld no. 8 and no. 11 This review indicated that the methods, techniques and extent of examinations comply with PSI Program and procedural requirements as do the recording, evaluation and disposition of findings. The inspector had no further questions regarding the documentation of examination results at this tim .3 Review of Procedures Throughout this inspection, various procedures were reviewed, in part, to facilitate observation of work activities in the fiel Some of the procedures reviewed include the following:

- RT-10, " Radiographic Examination"

- LP-101, " Solvent Removable Visible Dye" The procedures were reviewed for. compliance with ASME Code and regulatory requirements and were referenced during verification of field activitie No discrepancies were identifie .4 Summary Those procedures and records reviewed during this inspection appeared to be adequate, complete, and in accordance with regulatory require-ments. However, there appears to be a lack of management oversight and support of certain PSI activities. This is evidanced by the removal of the radiography source from its vault for approximately three (3) hours, without use, and the circumstances surrounding the potential violation of the source protection requirements as discussed in section 3. .0 Random Sampling of Bolting for Independent Analysis-Unrelated to the PSI activities, bolt and stud storage, distribution and documentation practices were examined. The following sample of L

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Meanwhile, after many delays and in an effort to expedite completion of the radiographic examination, the technicians decided to survey those areas necessary to establish the RT boundaries. For radio-logical exposure purposes, the room boundary or access area to be roped off included elevation 735 and the two elevations belo Technician A had surveyed the areas and returned to show technician B where the boundaries could be placed. Technicians A and B walked approximately five (5) steps away from the RT source when one technician recalled the source protection responsibilities and returned to the sourc Approximately forty-five minutes later, technician A was away from the area investigating where the RT ropes were to be placed. The cover had been removed from the filter, water was found within, and an internal component was found to interfere with internal position-ing the RT equipment. The radiography could be completed externally, using a lengthy exposure time. However, a concern existed for arriving first shift personnel and the high potential of crossing the RT boundaries on the 735 elevation for access to work station Technician B considered performing an alternate ultrasonic (UT)

examination from inside the filter cavity, and proceeded to search for technician A for consultation. Technician B was approximately fifty (50) feet away from the source and through a doorway, when the inspector felt it necessary to remind the technician of the source protection requirements. The technician returned and shortly there-after, a decision was made to attempt the alternate supplemental UT examinatio The UT equipment was obtained, calibrated and logged in for access to the clean area. Technicians A and B were dressed out for clean area access. Technician A was descending the ladder to the filter room and technician B was proceeding with the UT equipment when the inspector reminded technician B, a second time, of the RT sourc Technician B reminded technician A, who then ascended the filter room ladder and remained within sight of the source throughout the UT exam. The supplemental UT examination was successful in resolving the previous UT indication and use of the RT source in the filter room was not necessary. The source was returned to its vault, unused, at approximately 5:30 Throughout the evening, on three separate occasions, the RT techni-cians appeared to be distracted by delays to the point of neglecting their responsibilities for protection of the RT sourc If the radiographic source had been left unattended, this would have been in violation of radiographic exposure device storage requirements as stated in 10CFR 34.23. The technicians had been observed throughout this inspection, and otherwise appeared to be competent and conscien-tious workers. The apparent lack of management control and support for this activity created unusual working conditions in which to perform radiography. Communication and coordination between personnel was less than adequate throughout the event. This item

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bolts were obtained for chemical analyses, visual examination, hardness testing and comparison to ASME specification requirements:

Sample Grade, Type Size Description 1 SA 325, T1 1/2" x 2" C/S bolt 2 SA 193, Gr 87 1/2" x 2" C/S bolt 3 SA 193, Gr B8 1/2" x 2" S/S bolt 4 SA 325, T1 1/2" x 2" C/S zinc coated bolt The documentation for these samples (including purchase order, material test report, and QC receipt inspection report) was readily availabl No violations were identifie .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. Unresolved items are discussed in section 3.1.2 of this repor .0 Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of.this inspection on October 24, 1986. The inspector summarized the purpose of this inspection and discussed the relevant findings. At no time during this inspection was written material provided by the inspector to the license . - -. - .. .

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No discrepancies were identified during review of the penetrant testing techniques in use at BVP .1.2 Radiography and Ultrasonic Testing Prior to this inspection, ISI personnel had completed supplemental surface examinations on Seal Water Injection Filter 2CHS-FLT24A to resolve a PSI ultrasonic indication. An alternative volumetric examination (radiography) was then required to properly disposition the indication. Radiography (RT) should be performed during third shift to avoid inadvertent radiation exposure Completion of this radiography had been established by the operations department as a priority task item so the filter system could be released for testing. The RT schedule had previously been delayed one day as the preparation work had not been completed for the RT examination. The following evening, while attempting to complete the radiographic testing, the following sequence of events was observed:

Upon arrival at the site, the RT technicians were notified the filter would not be prepared at 1 a.m. as scheduled, but that radiography would be delayed one hour. The technicians prepared the equipment and film necessary for the examination in accordance with site procedure RT-10. When the technicians were not notified of any further delays, the RT source was removed from its vault at 2 a.m. and was transported to the Auxiliary Building, elevation 735, for access to the filter room. Transporting _the source lasted approximately five (5) minutes, by truck, around site constructio The filter is installed in a room just below elevation 735 with controlled (clean area) access from abov At this time, the preparation work necessary to complete the radiography had not been performed. When found and questioned, area supervisors stated the work request for preparation had been received approximately thirty (30) minutes earlie The preparation work which proceeded, involved personnel from the following departments, as a minimum: operations, carpenters, mechanics, security and DLCo QC. The equipment preparation steps included:

- determining if the filter had been drained

- establishing a clean area

- disassembling the filter

- tagging and storing of removed parts The work being performed was in a heavy traffic area for access between the site buildings. Frequently, throughout the evening, in excess of twenty people were present in this area.