IR 05000395/1987007

Insp Rept 50-395/87-07 on 870223-27.No Violation or Deviation Noted.Major Areas Inspected:Licensee Actions on Previous Enforcement Matters (92701B) (92702B),inservice Insp & Inspector Followup Items

ML20207T506
Person / Time
Site:	Summer
Issue date:	03/13/1987
From:	Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T504	List: IR 05000395/1987007 ML20207T503
References
50-395-87-07, 50-395-87-7, NUDOCS 8703240080
Download: ML20207T506 (15)

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Report No.: 50-395/87-07 _ i 3 1'

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Licensee: -South Carolina' Electric and Gas Company -

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Docket No.: 50-395 "' y License ' No. : 'NPF-12

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Facility Name: Summer i', ;Y Inspection C  : February 23-2711987

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Inspect : 3 5 7 insorge Date' Signed-Appro ed : 3 J/ 7 J. J/Blake, Section Chief Date Signed gfneering Branch ivision of Reactor Safety

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SUMMARY

.. Scope: , This routine, unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters (92701B) (927028), Inservice Inspection, and Inspector Followup Item Results: No violations or deviations were identifie .

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REPORT DETAILS Persons Contacted Licensee Employees

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• 0. S. Bradham, Director, Nuclear Plant

• D. Moore, Director, Quality & Procurement

• M. D. Quinton, Manager, Maintenance Service

• S. Hunt, Manager, Quality Control (QC)

• T. A. McAlister, Quality Assurance (QA) Supervisor

• A. D. Torres, NDE QC Supervisor Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspector

• R. Prevatte, Senior Resident Inspector

• Attended exit interview Exit Interview (30703B)

The inspection scope and findings were summarized on February 27, 1987, with those persons indicated in paragraph above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license (0 pen) Inspector Followup Item 50-395/87-07-01: "UTL Procedure Discrepancies" paragraph 5b(6)(a)

i L (0 pen) Inspector Followup Item 50-395/87-07-02: " Code Case N-401 Approval" paragraph Sb(6)(b)

(0 pen) Inspector Followup Item 50-395/87-07-03: " Unavailable CE Procedures" paragraph 5b(6)(c)

(0 pen) Inspector Followup Item 50-395/87-07-04: "SCE&G NDE Procedure Discrepancies" paragraph Sb(6)(d)

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The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

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2 Licensee Action on Previous Enforcement Matters (UNR 92701B)'(VIO 92702B)

(0 pen) Unresolved Item 50-395/86-18-01 "VT-2 Eye Examination"

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The-inspector discussed this matter with the licensee and determined that this matter has not yet been resolved. Therefore, it will remain ope _4 . Unresolved Items Unresolved items were not identified during this inspection.

' Inservice Inspection (ISI)

.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. The plant,

which commenced commercial operations January 1,1984, is in the first 40 month period of the first ten year ISI interval (January 1,1984 to December 31,1993).

ISI for the upcoming outage will in part be performed by Universal Testing Laboratories, Inc. (UTI) of Ceder Grove, New Jersey under the umbrella of the UTI QA Program as modified by a " Memorandum of Understanding" dated January 22, 1987. Eddy Current Examination of the steam generators will

, be performed by Babcock & Wilcox (B&W) under the umbrella of' the B&W QA l Program. Mechanized ultrasonic examination of the reactor vessel will be performed by Combustion Engineering (CE) under the umbrella of the CE QA Program, Review of Program (73051)

(1) Program Organization The inspector reviewed the licensee and ISI contractor's QA programs to verify the following: procedures for the mainte-nance of required ISI records; QA review includes assurance that plans and procedures have been reviewed by appropriate personnel and meet regulatory requirements; procedures are established for the corrective action of conditions adverse to quality as detected during examination, including provisions to preclude repetition of such adverse conditions; audits or surveillance of ISI activities are conducted by qualified QA personnel to verify compliance with the ISI program; and procedures are established to effectively oversee contractor activities concerned with

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ISI/ PSI.

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y (2). Program Approval-The inspector interviewed . personnel and reviewed- documents indicated below to determine whether requirements were: met in-the following area: Services of'an Authorized' Nuclear Inservice Inspector (ANII) have been procure .The inspector was able to substantiate that the licensee's program requires the services of an ANII.' The' licensee was unable to provide objective evidence that the services of the .

ANII' have been in fact = contracted .for during the . upcoming ISI outag Documents Reviewed Combustion Engineering, Power Systems Group, Nuclear Field Manual, Rev. 2, No. 345 MW "Special Products & Integrated Field Services Quality Assurance Manual for Inspection Services", Copy.7, Rev. 4 UTL " Quality Assurance Manual", Rev. 7 UTL - Memorandum of Understanding, dated January 22, 1987 Review of Procedures (73052)

'(1) Program Requirements The inspector reviewed the licensee's commitments in the SAR,

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Technical Specification (TS), and approved ISI program to ascertain whether ISI procedures adequately cover all ' areas 4- specific:in the licensee's commitments for ISI and PSI require-ments.

[- (2) Procedure Approval l

F The inspector reviewed the below listed procedures to determine whether the- ISI procedures have been approved by authorized licensee personnel and by the ' Authorized Nuclear Inservice Inspector (ANII) where applicable.

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Documents Examined

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Identification Title i

UTL-VT-01, Rev. O " Visual Examination"

UTL-PT-01, Re " Liquid Penetrant Examination L (color contrast solvent i removal)"

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Identification Title UTL-PT-02, Rev. 0 " Liquid Penetrant Examination (water washable fluorescent and color contrast)

UTL-MT-01, Rev. I " Magnetic Particle ' Exami-nation (MT), Prod and Yoke Dry Method" UTL-UT-02, Re " Ultrasonic Examination of Bolt Studs" ULT-UT-08, Rev. O " Manual Ultrasonic Examina-tion of Vessel Welds" ULT-UT-01, Re " Ultrasonic Examination of Piping Systems" UTL-QAP-09.1, Rev. 2 " Qualification Certification of Nondestructive Examination (NDE) Personnel" U11-QAP-09.2, Rev. I " Qualification of Visual Examination Personnel (VT-1 through VT-4)

B&W-ISI-424, Rev. 9 "Multifrequency Eddy Current Examination of .0750 OD x

.044 Wall RSG Tubing for ASME Exam and Tube Wear at Support Plates"

{ B&W-ISI-460, Rev. 14 Technical Procedure for the Evaluation of Eddy Current Data of Nuclear Grade Steam i Generator Tubing" B&W-ISI-462, Rev. 2 " Technical Procedure for the Evaluation of Eddy Current Data for Debris and Sludge in Steam Generators" B&W-ISI-463, Rev. 6 " Technical Procedure for the l

Evaluation of Eddy Current Data Generated From the Multi element Probe"

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Identification Title B&W-ISI-464,-Rev. 4 " Technical Procedure for the Evaluation of Eddy Current Bobbin Coil ' Data -.for -Weat Fretting and AVB Wear" B&W-ISI-510, Rev. 2 " Eddy-360 System Operating Procedure"

'(3) Code Repair.and Replacement Procedure Review

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The inspector reviewed repair and replacement procedures indicated below to ensure that the elements of the procedures are consistent with the applicable areas of the ASME Code and the approved ISI progra The specific elements examined were:

Repair: identification of the NDE method that revealed the flaw and the description of the flaw; description of the flaw removal method; procedure for weld and postweld heat treatment, if applicable, including review of procedures for welding prior to authorization of the repair and review of qualifications of welders performing the repair; provisions for using the services of an Authorized Inspec-tion Agency when making a weld repair, as well as for having the ANI review and approve the repair procedure before its performance; description of the NDE program to be used after the repair'is completed; and delineation of the scope of work and division of responsibilities between-the licensee and contractor, if a contractor is used.

Replacement: provisions to verify that the replacements met the requirements of the edition of the Construction Code to which the original component /part was constructed, the provisions of later editions of that same Code, or Section III of the ASME Code; provisions to ensure that the replacements ordered as spares met the requirements of the appropriate Construction Code used for the part/ component it ' was intended to replace, the provisions of later editions of that Code, or Section III of the ASME Code; justification, consistent with NRC guidelines, for not requiring a Code Stamp; evaluation of the suitability of the replacement prior to authorizing its installation; retention of reports and records as required by the Construction Code and ASME Code Section XI; and performance of a PSI prior to the return to service of the replacement component or part in accordance with the applicable Cod With regard to the inspection, the inspector noted numerous examples of procedure numbers used in documents without the associated procedure title ever having been identifie In

addition, numerous examples were noted of acronyms used in l'

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documents without definition or identification. The above are for human factors engineering practices and as such should be -

avoided in order to minimize misunderstandings that could ' lead to personnel error Documents Reviewed

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Identification -Title SCE&G-SAP-304, Rev. 2 "ASME Code,Section XI Repair Program" SCE&G-SAP-300, Rev. 3 " Conduct of Maintenance"

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SCE&G-SAP-302, Rev. 3 " Administration of Main-tenance Welding" SCE&G-WM-1.0, Rev. 9 " Welding Manual Procedure"-

SCE&G-WM-2.0, Rev. 8 " Welding Materials Procedure" SCE&G-NQCP-1, Rev. 2 " Qualification of NDE Procedures" SCE&G-NQCP-2, Rev. 4 " Solvent Removable Liquid Penetrant" SCE&G-NQCP-3, Rev. 2 " Water Washable or Post Emulsification Liquid Penetrant" (4) Non-destructive Examination (NDE)

(a) Procedure Review The inspector reviewed the procedures indicated in para-graph (b) below to determine whether requirements are specified and agree with licensee's commitments including specified or referenced acceptance levels; qualifications of NDE personnel are specified in accordance with the licensee's approved ISI program; methods of recording, evaluating, and dispositioning findings are established and reporting requirements are in compliance with applicable Code requirements; and procedures delineate the scope of work and division of responsibilities between the licensee and the contracto ,

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(b) _ Technical Content 1)- Visua1' Examination The inspector reviewed the below listed visual'

examination procedure to determine whether _it contain information or reference -to a general inspection procedure or supplementary _ instructions sufficient to ~ assure - that all parameters are specified and controlled within the ' limits permitted by the applicable Code and -other additional _ specification requirements; each essential examination variables are defined and whether these variables. are controlled within the limits specified by the applicable Code and other specification / contract requirements. Specific areas examined were: method;' application; how visual-examination is to be performed; type of surface condition; method or -tool for surface preparation; direct or remote viewing; 'special illumination, instruments, or equipment; sequence of performing examination; data to be tabulated; acceptance criteria are specified' consistent with the applicable Code and report form or general statement to be complete Procedure Examined-UTL-VT-01 2) Liquid Peratrant Examination The inspector reviewed the below listed liquid penetrant examination procedures to determine whether they contain information or reference to a general inspection procedure or supplementary instructions sufficient to assure that all parameters are specified and controlled within the limits permitted by the

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applicable Code and other additional specification i requirements; each essential examination variables are defined and whether these variable are controlled

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within the limits specified by the applicable Code and other specification / contract requirements. Specific areas examined were: specified test method is consistent with applicable Code requirement; brand names and specific types (number or letter designation if available of penetrant, penetrant remover, emulsifier and developer are specified; penetrant materials used for nickel base alloys are required by procedure to be analyzed for sulfur using the method

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prescribed by the applicable Code; penetrant materials used for the examination of austenitic stainless steel are required by procedure to be analyzed for total halogens using the method prescribed in the applicable Code; method for acceptable pre-examination of surface preparation are specified and consistent with the applicable Code, area to be cleaned is consisted with applicable requirements, cleanliness acceptance requirements are consistent with applicable Code requirements, surface area to be examined is consisted with applicable Code requirement; procedure estab-lished a minimum drying time following surface cleaning; method of penetrant application and penetra-tion (dwell) time are specified and that the penetra-tion time is consistent with the penetrant manu-facturer's recommendation; examination surface is specified and is consistent with the applicable Code; procedures (when applicable) specify acceptable methods for removing water-washable penetrant consistent with the applicable Code; method of applying emulsifier (when applicable) and the maximum emulsification time is specified and consistent with the applicable Code; method for removal of solvent removable penetrant when applicable) are specified; method and time of surface drying prior to developing is specified; type of developer to be used, method of developer-application and the time interval between penetrant removal and developed application specified; exanination technique is specified and the permitted time interval during which the " final interpretation" is performed within the range of 7-30 minutes after developer application; minimum light intensity at the i inspection site is prescribed; technique for evalua-tion of indications is specified, acceptance standards are included and these are consisted with applicable I Code and specific contract requirement; reporting l requirements are specified; and procedure requires

requalification when changes are encountere *

! Procedures Examined l UTL-PT-01 UTL-PT-02 SCE&G-NQCP-2 SCE&G-NQCP-3 l

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The . inspector reviewed ..the 'below listed magnetic '

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particle examination procedure- to determine whether

- it contains information or references to a general j inspection procedure or supplementary ' instructions sufficient to assure'that all parameters are specified and controlled within, the limits permitted by the applicable Code and other additional specification i requirements; each essential _ examination variable is

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defined and whether these . variables are controlled within the limits specified by the applicable Code and other specification / contract requirements. Specific areas examined were: method - continuous; surface '

preparation; particle contrast; surface temperature; light intensity; coverage; prod spacing; magnetizing current and yoke pole spacing; and acceptance criteria-are specified consistent with the applicable ASME Code ?

Section and specific contract requirement j Procedure Examined UTL-MT-01 4) Ultrasonic Examination ,

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The inspector reviewed the below listed ultrasonic examination procedures to determine whether they contain information or references, a general inspec-tion procedure or supplementary instructions suffi-cient to assure that all parameters are specified and controlled within the lii..its permitted by the applicable Code and other additional specification requirements; essential examination variables are

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defined and whether these variables are controlled )

within the limits specified by the applicable Code

and other specification / contract requirement ,

i Specific areas examined were: type of apparatus to be used including frequency range as well as linearity i and signal attenuation accuracy requirements, is

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specified; extent of coverage (beam angles, scanning -

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! surface, scanning rate and directions) as well as the scanning technique are specified and are consistent

! with the applicable ASME Code and contract require-i ments; calibration requirements, methods, and i- frequency including the type, size, geometry, and

material of calibration blocks as well as location and i' size of calibration reflectors within the block are

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clearly specified and consistent with the applicable ASME Code - and contract requirements; sizes and frequencies of search units are specified and are consistent with the applicable ASME Code and contract requirements; beam angles are specified and are consistent with the applicable ASME Code and contract requirements; methods of compensation for the distance traversed by the ultrasonic-beam as it passes through the material including distance - amplitude correction curves, electronic distance - amplitude correction and transfer mechanisms, if used,- are specified and are consistent with the applicable ASME Code and contract requirements; reference reflectors for accomplishing transfer and the frequency of use of transfer mechanisms, if applicable, are specified and in accordance with ASME Code and contract requirements; the reference level for monitoring discontinuities is defined and the scanning gain setting specified and that these values are in accordance with the appli-cable ASME Code and contract requirements; methods of demonstrating penetration and coverage are estab-lished; levels or limits for evaluation and recording of indications are specified and are in accordance with applicable ASME Code and contract requirements; nethod of recording significant indications is established and that the reporting requirements are in accordance with applicable ASME Code and contract provisions; and acceptance limits are specified or referenced and are in accordance with the applicable ASME Code and specific contract requirement Procedures Examined ULT-UT-01 ULT-UT-02 ULT-UT-08 5) Eddy Current Examination The inspector reviewed the below listed eddy current examination procedures to ensure that the: multi-channel examination unit is specified; method of examination is described; method of calibration and sequence of calibration is described; requirements of TS or ASME Code Section XI (whichever is applicable)

have been addressed; procedures meet the requirements and intent of RG 1.83; licensee has written approval for use of Code cases such as "N-401".

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Procedures Examined B&W-ISI-424 B&W-ISI-42 B&W-ISI-460 B&W-ISI-462 B&W-ISI-463 B&W-ISI-464 B&W-ISI-510 6) With regard to the above inspection:

a) The inspector was informed that the procedures reviewed were draft versions currently under

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SCE&G review. The ANII will be provided the procedures after the resolution of the SCE&G ,

comment The inspector noted the following '

discrepancies:

• UTL-VT-01, R0 does not provide specifi acceptance criteria for VT-1 and VT-4

• UTL-MT-01, R1 does not address maximum temperature of 600 F as required by ASME V, T-725-1; does not require " adequate contrast" of particles with the background as required by ASME V T-725.1; and does not provide specific acceptance criteri * UTL-PT-01, R1 does not provide specific acceptance criteri i

• UTL-PT-02, R0 does not address the prohibi-tion of fluorescent liquid penetrant exami-nation after a visible examination as i required by ASME V, T-630(c); fluorescent I examiners shall be in darkened area for at ;

least five minutes prior to performing the I examination to enable his eyes to adjust to dark viewing and if examiner wears glasses or lenses, they shall not be photo ;

sensitive. This is contrary to good I industry practice. The ASME has added this l as a requirement to the 1983 Edition of Code Section V; and does not provide specific acceptance criteri l l

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• 'UTL-UT-02 specifies transducer size larger than allowed by ASME V.T525.2(a) is confused as to inspection techniques straight beam or angle beam technique; is not clear which surface is to be examined; and does not provide specific acceptance criteri * UTL-UT-01, R1 and UTL-UT-08, R0 do not provide specific acceptance criteri * UTL-QAP-09.2, R1 paragraph 4.5.4.c does not describe how "a composite grade 80%" is determine Pending NRC review of the SCE&G and ANII approved / reviewed UTL procedures this matter will be identified as inspector followup item 50-395/

87-07-01: "UTL Procedure Discrepancies."

b) The inspector noted that B&W procedure ISI-424, Rev. 9 specifies ASME Code Case N-401. The inspector discussed the same with the licensee who indicated that they were in fact intending to use the code case which permits the use of digital data collection for eddy current examina-tions. The licensee was however unable to provide objective quality evidence of approval for the use of Code Case N-40 This matter will be identified as Inspector Followup Item 50-395/87-07-02: " Code Case N-401 Approval."

c) The inspector was informed that the CE procedures for the examination of the reactor vessel would not be on site until March 6, 198 Pending NRC review of the CE reactor vessel examination procedures this matter will be identified as Inspector Followup Item 50-395/87-03: "Unavail-able CE Procedures."

d) The inspector found the following discrepancies in SCE&G N0E procedures:

• T-NQCP-1 does not specify the year edition of SNT-TC-1 .

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T-NQCP-2 and T-NQCP-3 do not address the prohibition of fluorescent liquid penetrant examination after a visible examination as required by ASME V, T-630(c); fluorescent examiners shall be in darkened area for at least five minutes prior to performing the examination to enable his eyes to adjust to dark viewing and if examiner wears glasses or lenses, they shall not be photo sensitive. This is contrary to good industry practice. The ASME has added this as a requirement to the 1983 Edition of Code Section V; do not define the examination area of interest; do not address the calibration or accuracy verification of the light meter used to verify the intensity of the ultraviolet; and do not specify the changes that require procedure requalifica-tion as stated in ASME V, T-68 The licensee indicated that would make appro-priate change Pending NRC review of the amended procedures this matter will be identified as Inspector Followup Item 50-395/87-07-04: "SCE&G NDE Procedure Discrepancies".

Within the areas examined, no violations or deviations were identified.

6. Inspector Followup Items (Closed) Item 50-395/84-31-02: " Stroke Time Limits" The inspector of record for Report 50-395/84-31 noted that 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 meaningles 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 second 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 seconds. The licensee stated that because the TS permit 40 seconds for isolation (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 compan _ __ ____-_________- _ _ ________- _ ______

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The licensee has" revised procedures GTP-302, " General' Procedure for Inservice Testing of Valves" and GMP 103.001' " Pump and; Valve

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Trending" to bring the maximus' stroke times of containment isolation valves in line with' the NRC staff's position .as stated in NRR

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memorandum - for. R. L. Spessard, Director, Division of Reactor Safety,.

Region II, from H. L. Thompson,~ Jr., Division - of Licensing, Office

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of Nuclear Reactor Regulation, dated April 11, -1985,. for docket '

No.'50-341. The inspector.has no further questions. This matter-is-considered close (0 pen) Item. 50-395/85-08-02:

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This ' item concerns whether valves XVG- 9503A and B in the component cooling water system should be included in the inservice test'(ISI)

progra The licensee claims that these valves were not included. in the ISI-program based on discussions which occurred during meetings held on

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February 24-25, 1982, between NRC and SCE&G regarding the IST program for pumps and valves. This meeting was documented .in a March 16, 1982,, letter to the licensee. The licensee contends that inclusion of. the subject valves and other valves of similar function which do L not receive an automatic ESF signal represents a departure from 'a previous NRC interpretatio The March 16, letter indicates " Listed Valves" have no - safety function. Therefore, it follows that the " Listed Valves" would not be required to be included in the .ISI program. Unfortunately, the March 16,1982, letter does not identify the " Listed Valves." The licensee presented this inspector a photocopy of .an- unsigned hand-written document; apparently the notes from which the March 16, 1982 letter was written. This document indicates that Valves ~XVG 9503A and B are 'among the " Listed Valves." Pending the legitimization of the unsigned photocopy of handwritten notes, this matter remains ope (Closed) Item 50-395/86-18-02: "QA Auditor Qualification" NRC Report No. 50-395/86-18 noted that the licensee's procedure for qualification of QA auditors was cancelled effective August 1.1986, and its replacement was in preparation. The licensee has issued Al-205 Revision 0, " Quality Assurance Personnel Indoctrination and Training" effective October 22, 1986. The inspector has no further questions. This matter is considered closed.