ML20010J182

Responds to NRC 810813 Ltr Re Violation Noted in IE Insp Rept 50-395/81-17.Corrective Actions:Complete Insp of Affected Welds Will Be Completed by 810915.Welds Are Being Recleaned

ML20010J182
Person / Time
Site:	Summer
Issue date:	09/04/1981
From:	Nichols T SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20010J179	List: ML20010J182
References
NUDOCS 8109290674
Download: ML20010J182 (3)

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south CAROLINA ELECTRIC a GAS COMPANY post errect son is4 COLUMelA, SOUTH CAROLtNA 29218 , ,

T. C. istCHOLS, JR.

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Mr. James P. O'Reilly, Director U.S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.

Atlanta, Georgia 30303

Subject:

Virgil C. Summer Nuclear Station Docket he. 50/395 RII: JLC-50-395/81-17

Dear Mr. O'Reilly:

Attached is South Carolina Electric and Gas Company's response to the referenced report which summarizes Mr. J.L. Coley's inspection of July 13, 1981 through July 17, 1981. Specifically, we have addressed the violation concerning failure to accomplish ultrasonic inspection activities in accordance with established procedures.

Should you have questions or comments, please contact us at your convenience.

I declare the statements and matters set forth herein are true and correct to the best of my knowledge, information, and belief.

Very truly yours,

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T.C. Nichols, Jr.

JWP:TCN:bsg Attachment cc: V.C. Summ.r B.A. Bursey G.H. Fischer J.C. Ruoff H.N. Cyrus I&E (Washington)

T.C. Nichols, Jr. NPCF i 0.W. Dixon, Jr. F'le l

D.A. Nauman W.A. Williams, Jr.

R.B. Clary 0.S. Bradham A.R. Koon A.A. Smith

! H. Radin M.N. Browne H.E. Yocom J.L. Skolds J.B. Knotts, Jr.

3 8109290674 010924" PDR ADOCK 05000395 PDR; e

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SOUTH CAROLINA ELECTRIC & GAS CO.

VIRGIL C. SUMMER NUCLEAR STATION, UNIT #1 DOCKET NO: 50-395 Page 1 of 2 REPORT NO: RII:JLC 81-17 NOTICE OF VIOLATION EVENT DATE: JULY 17, 1981 DESCRIPTION OF EVENT 10 CFR 50, Appendix B, Criterion V as implemented by V.C. Summer FSAR Section 17.2.5 requires in part that activities affecting quality shall be prescribed by procedures and shall be accomplished in accordance with thcse procedures. Westinghouse procedure ISI-205, Rev. 2, figure 7 requires a minimum scan length of 4 inches when a full node 45 degree examination is performed on material ranging in thickness from I inch to 1.2 inches. In addition, paragraph 3.7 of ISI-205 requires the surface finish on the calibration block to be representative of the examination area and paragraph 2.4 requires the area contacted by the transducer to be checked to ensure that foreign matter that could impair the free movement of the transducer or affect the examination be rectified prior to conducting the examination.

Contrary to the above, on July 15, 1981, activities affecting quality were observed that would have prevented accomplishment of previously reported completed ultrasonic inspections in that Feedwater System welds #121 on Isometric CCE-2-2103 and #4 on Isometric CGE-2-2304 were observed painted within the required UT scan area. The licensee's calibration blocks were not representative of the examination area in that they were not paintei to compensate for signal losses resulting from sound that was attenuated by the paint. In addition, the surface condition at the interface between the non-painted area and the painted area precluded the full inspection of the weld and base metal area of interest.

ADMISSION OR DENIAL OF ALLEGED VIOL /." TONS South Carolina Electric & Gas Company recognizes this item as a violation of the aforementioned Regulatory requirements.

REASONS FOR VIOLATION This event was the result of personnel error and procedure misinterpretation.

The non-destructive examination personnel failed _to recognize the fact that close adhering paint could affect the examination results, and that the cali-bration blocks should reflect the condition of the area to be examined (i.e.,

painted).

CORRECTIVE STEPS TAKEN The following immediate corrective actions are being taken:

a. V.C. Summer Station Nuclear Operations Nonconformance Notice #388 has been written to identify and tra ck resolution of this condition.

b. A complete inspection of all affected welds is being conducted to identify welds which did not have the paint removed the required distance.

e NOTICE OF VIOLATION Page 2 of 2 CORRECTIVE STEPS TAKEN (cont'd.)

c. Welds that are identified as not having been adequately prepared for examination are being recleaned and the examinations re-performed.

c. At present, the effort is approximately 98% complete with a projected completion date of September 1., 1981.

CORRECTIVE STEPS TAKEN TO PRECLUDE RECURRENCE The steps taken to avoid further violations of this nature are as follows:

a. The importance cf NDE procedural requirements, particularly those of procedure ISI-205, and conformance thereto has been emphasized to all NDE operators.

b. A field change to procedure ISI-205 is being implemented to assure that the specified examination area is cleaned of all foreign matter prior to performing the required examination.

c. SCE&G personnel will be required to more closely monitor non-destruc-tive examination activities by contractor personnel.

DATE OF FULL COMPLIANCE The corrective steps taken as spe ified above snall be completed by October 1, 1981 except item c whic will be a continuing practice by SCE6G personnel.

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