IR 05000280/1987011

Insp Repts 50-280/87-11 & 50-281/87-11 on 870427-0501.Three Potential Enforcement Findings Noted.Major Areas Inspected: Audit Performed in Feb 1987 by Util of Industrial Distributors

ML20237F629
Person / Time
Site:	Surry
Issue date:	06/22/1987
From:	Conway J, Stone J Office of Nuclear Reactor Regulation
To:
Shared Package
ML18150A513	List: IR 05000280/1987011
References
50-280-87-11, 50-281-87-11, NUDOCS 8708130105
Download: ML20237F629 (9)

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U.S. NUCLEAR REGULATORY COMMISSION Report Nos.: 50-280/281/87-11 Licensee: Virginia Power Corporation Richmond, Virginia 23261 Docket Nos.: 50-280/281 License Nos;: DPR-32/37 Facility Name: Surry Nuclear Power Station l Inspection Conducted: April 27-May 1, 1987 Inspector: \ [

4.\T. Conway, Progfim Development and Reactive

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\Jnspection Sectiqn (PDRIS)

Accompanying Personnel: B. W. Bro a, EG&G Idaho Approved by: w [i J. F. Stone, Chief, PDRIS, Vendor Inspection Branch 5/IY#'/

'Date SUMMARY Scope This routine, announced inspection at the Surry Nuclear Power Station was conducted to obtain information on the audit performed in February 1987 by Virginia Power Corporation (VPC) of Industrial Distributors, review records pertaining to the installation of the moisture separator reheater internals by Southwestern Engineering Company /Powerplant Specialists in 1984, review records of NDF personnel from U.S. Testing Company (USTC), and view radiographs taken by USTC in June and November 1986 and January and February 198 Results Within the areas inspected, several items of concern are addressed in the report for followup during future inspections. Three potential enforcement findings will be forwarded to NRC Region II for followup. Also the Senior Resident Inspector was notified of the crack indications in radiographs of the Recirculation Spray System for future followu l l

8708130105 870810 PDR ADOCK 05000200 G PDR

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REPORT DETAILS

' Persons Contacted Licensee Employees

• E. J. Grecheck.. Assistant Station Manager R. J. Hardwick, Jr., Corporate QA Manager

• J. A. Price, Site QA Manager

• E. W. Throckmorton, Manager - NDE Services

• D. Grady, Supervisor QA/hDE R. Schaffer, Supervisor QA  !

• E. T. Shaub, Licensing Engineer D. S. Hart, Staff Engineer - Quality '

H. McCallum, Supervisor Training T. Lambert, Senior Word Processor D. Spooner, NDE Level III C. Holladay, Document Clerk E. Humphrey, Senior QC Inspector ,

D. Sommers, Licensing Engineer NRC Resident Inspectors

• E. Holland, Senior Resident Inspector

• L. E. Nicholson, Resident Inspector ,

• Attended exit meetin . Exit Meeting The inspection scope and findings were summarized on May 1, 1987 with those individuals indicated in Section 1 above. The licensee was informed of and acknowledged the inspection findings listed belo The licensee did not identify as proprietary any of the materials provided to or reviawed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items j Unresolved items were not identified during this inspectio . Nondestructive Examination (NDE)

There are two radiographic (RT) examiners at the VPC Surry Nuclear Power i '

Plant who hold current certification. Mr. D. L. Spooner is the certified Level III RT examiner. Mr. Spooner's Level III RT certification was issued on January 2,1987; its expiration date is May 1,1987. D. L. Rogers is a certified Level IIA RT examine VPC certification procedures provide-2-

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for a limited Level IIA certification in radiography. This limited certi-fication permits certification of an individual for radiographic interpre-

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tation only. The VPC procedures for qualification and certification of NDE RT personnel, as well as the individual training and certification records (including eye examination results) for the above RT examiners, were examined and found to be in compliance with the guidelines of SNT-TC-1 The inspector reviewed the following procedures contained in the NDE har.ual (through Distribution No. 21 dated August 12,1986), and they appear to meet the applicable Code requirements:

NDE Responsibilities and Organization of VEPCO NDE Program, Revision 1, dated December 7, 1903; NDE Requisition and Reporting of NDE Services (Nuclear Facilities), Revision 1, dated August 12, 1986; NDE Nondestructive Examination Personnel Certification and Training, Revision 7, dated September 12, 1984; NDE Nondestructive Examination Vendor Qualification and Observation, Revision 0, dated January 1, 1984; NDE General Requirements for Nondestructive Examinations, Revision 2, dated July 17, 1984; and NDE-RT-1 Radiographic Examination, Revision 0, dated December 1, 198 The inspector reviewed Contract No. QAC-C-0086005 between VPC and USTC for NDE and other associated services. Section 7.D of General Terms and Conditions imposed the requirer,ients of 10 CFR Part 21 upon USTC. Release No. 05-02-S16R dated April 29, 1986 was to provide RT services at Surry during the Unit i refueling outage, and RT of various piping welds was covered by Release No. 05-05-S27R dated January 8, 1987. A VPC memo dated October 31, 1986 indicated that VPC's corporate NDE Level III reviewed and approved USTC's written practic The qualification records in the possession of VPC for the examiners from USTC were reviewe There was no documented evidence that the VPC Level III or a designee had reviewed and approved the certifications of seven examiners who performed R1 in June and November 1986 and January and February 1987 as required by Procedure No. 4.1. In addition, certifications were not available for one individual who performed RT in February 198 (See PEF 87-011-03.) Training records indicated that 10 individuals had been instructed at the site by VPC and had passed basic radiation worker trainin A review of NDE records indicated that VPC's NDE department had not observed, reported on or retained records of RT activities that USTC performed in 1986 and 198 (See PEF 87-011-01.) ,

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During the review of the radiographs, it was noted that a copy of

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Procedure No. NDE-RT-1, Radiographic Examination wa's not available in the storage cabinet with the other NDE procedures at the facili ahere radiographic interpretations were being made. (See PEF 87 ,.1-02.) This procedure is necessary for radiographic review, as it contains the radiograph acceptance criteria. A copy of the procedure was obtained from the Quality Assurance office for use during the radiograph interpretation It was also noted that the densitometer used for checking radiograph densities did not display a calibration sticker. When asked about calibration certifications on this instrument, the licensee reported that'this was not the densitometer that was normally used to check radiograph densities and that the densitometer normally used was currently off site for calibratio . Evaluation of Radiographs The radiographs selected for evaluation were radiographs taken during 1986-1987 by USTC of Hoboken, New Jersey. The radiographs supplied by VPC and selected for viewing are listed below:

Job EWR87-139 - Extraction Steam (Unit 2)

Line N Drawing N Weld N "SIE-105-301 E200 W1 14"SIE-105-301 E200 W2 14"SIE-105-301 E200 W3 14"SIE-104-301 E200 W4 14"SIE-104-301 E200 W6 Job EWR87-003 - Replacement of Feedwater Piping Components -(Unit 2)

Line N Drawing N Weld N "WFPD-101-901 E206 W5 8"WFPD-101-901 E206 W5R 8"WFPD-101-901 E206 W5R1 14"WFPD-117-601 E215 W12 14"WFPD-117-601 E215 W23 14"WFPD-117-601 E215 W24 18"WFPD-101-901 E207 W2 18"WFFD-101-901 E206 W3 18"WFPD-101-901 E206 W3R 18"WFPD-101-901 E206 W4 16"WFPD-101-901 E206 W4R1 18"WFPD-101-901 E206 W6 18"WFPD-101-901 E206 W17 18"WFPD-101-901 E206 W17R 10"WFPD-101-901 E206 W24 18"WFPD-102-901 E210 W2 18"WFPD-102-901 E210 W3 18"WFPD-102-901 E210 W4

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Job EWR87-003 - Replacement of Feedwater Piping Components (Unit 2) ;

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Continued Line N Drawing N Weld N "WFPD-102-901 E210 W5 18"WFPD-102-901 E210 W6 18"WFPD-102-901 E210 W7 18"WFPD-102-901 E210 W8 18"WFPD-104-901 E217 W1 id"WFPD-104-901 E217 W3 18"WFPD-104-901 E217 W4 18"WFPD-104-901 E217 W5 18"WFPD-104-901 E217 W6 18"WFPD-104-901 E217 W7 18"WFPD-104-901 E217 W8 18"WFPD-105-901 E216 W1 18"WFPD-105-901 E216 W2 18"WFPD-105-901 E216 W3 Job EWR87-007 - Replacement of Condensate Piping Components (Unit 2)

Line N Drawing N Weld N "WCPD-121-301 E203 W1

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18"WCPD-121-301 E203 W2 18"WCPD-128-301 E202 W3 10"WCPD-128-301 E202 W4 18"WCPD-128-301 E202 W5 18"WCPD-128-301 E202 W6 18"WCPD-128-301 E200 W1 18"WCPD-128-301 E200 W1R 18"WCPD-128-301 E200 W2 Job EWR86-569 - Replacement of Feedwater Piping Components (Unit 1)

Line N Drawing N Weld N "WFPD-5-901 E112 W1A 18"WFPD-5-901 E112 W2 18"WFPD-5-901 E112 W2R 18"WFPD-5-901 E112 W7A 18"WFPD-2-901 E108 W1 18"WFPD-2-901 E108 W3 18"WFPD-2-901 E108 W4 18"WFPD-2-901 E108 W5 18"WFPD-5-901 E103 W1 18"WFPD-5-901 E103 W2 16"WFPD-5-901 E103 W2R 18"WFPD-5-901 E103 W3 IS'"WFPD-5-901 E103 W4 18"WFPD-1-901 E101 W11 10"kFPD-1-901 E101 W12-5-

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Job EWR86-569 - R@ placement of Feedwater Piping Components (Unit 1)

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Continued Line N Drawing N Weld N '

18"WFPD-1-901 E101 W6 18"WFPD-1-901 E101 W7 18"WFPD-1-901 E101 WC 18"WFPD-1-901 E101 W4R Job EWR37-569 - Replacement of Feedwater Piping Lomponents (Unit 1)

Line N Drawing N Weld N "WFPD-2-901 E108 W2R 18"WFPD-1-901 E101 W13 18"WFPD-1-901 E101 W14 18"WFPD-1-901 E101 W15 18"WFPD-1-901 E101 W18 18"WFPD-1-901 E114 W1 18"WFPD-2-901 E114 W2 Job EWR86-564 - Replacement of Condensate Piping Components (Unit 1)

Line N Drawing N Weld N "WCPD-27-301 11448-SK-2 W1 18"WCPD-27-301 11448-SK-2 W1A 18"WCPD-27-301 11448-SK-2 W1AR 18"WCPD-27-301 11448-SK-2 W1AR1 18"WCPD-27-301 11448-SK-2 W1B 18"WCPD-27-301 E100 W15 18"WCPD-27-301 E100 W7R Job EWR87-047 - Replacement of Condensate Piping Components (Unit 1)

Line N Drawing N Weld N "WCPD-26-301 E100 W1 18"WCPD-26-301 E100 W1R 18"WCPD-27-301 E101 W1 18"WCPD-27-301 E101 W1R 18"WCPD-27-301 E101 W2 Job 3800037266 - Chemistry and Volume Control (CVC) System Line N Weld N CH-301-1502 W25A 3-CH-301-1502 W26A 3-CH-301-1502 W28A 3-CH-301-1502 W29A 3-CH-301-1502 W29AR1-6-

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Miscellaneous Radiographs - Recirculation Spray System (Unit 2)

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Job N Line N Drawing N Weld W EWR86-507 10"RS-109 W17 EWR86-507 10"RS-109 W18 EWR86-502 10"RS-109-163 W8 EWR87-215 8" - FM-66A W14A EWR87-215 8" FM-66A W15A EWR87-215 8" FM-66A W15AR NDER86-546 4"SHP-137-601 FM-64A W4A NDER86-546 4"SHP-137-601 FM-64A W5A NDER86-506 10"RS-110-153 VIR-1-4657 W16A NDER86-506 10"RS-110-153 VIR-1-4657 W17A NDER86-506 10"RS-109 VIR-1-4657 W17B NDER86-507 10"RS-109 VIR-1-4657 W5 NDER86-507 10"RS-109 VIR-1-4657 W8 NDER86-507 10"kS-109 VIR-1-4657 W10 The following observations were made during the review of the USTC radio-graphs and reader sheets by an NRC consultant who is an NDE Level III:

Although several of the radiographs required reshooting because they did not meet the procedure requirements for radiograph density and/or sensiti-vity, all'of the final radiographs appeared to meet these requirement Of the 103 reader sheets reviewed, a VPC Levs1 II accepted 15 welds that had been rejected by a USTC Level II. When there-is disagreement between two Level IIs on the interpretation of a radiograph, it is standard industry practice to have a Level III review the film. There was no documentation to show that VPC had followed this practice. The inspector concurred with VPC's decision to override USTC's rejection on 12 of the 15 welds. However, two of the welds showed indications that were unacceptable per the applicable Code requirements (ANSI B31.1 - Power Piping), and one weld showed a rejectable indication that neither USTC or VPC had reported. The three subject welds are identified as follows:

Job EWR87-007 - Replacement of Condensate Piping Components (Unit 2):

Line 18" WCPD-128-301, Drawing E202, Weld W6 has an unacceptable slag indication (greater than 1/4" long) in radiograph view 2- Line 18"WCPD-128-301, Drawing E200, Weld W2 has an unacceptable cracklike indication, as reported by USTC, in radiograph view 4-0. VPC reported that this indication is within acceptable limit Job EWR87-569 - Replacement of Feedwater Piping Components (Unit 1): Line 18"WFPD-1-901, Drawing E101, Weld W18 is listed by USTC as having a rejectable slag indication in view 2- VPC reported this slag indication is the maximum acceptable size (1/4 inch) and, therefore, acceptabl During review of these radiographs, a rejectable indication (greater than  ;

1/4-inch long) was noted in radiograph view 0-1. Neither USTC nor VPC 1

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rejected this indicatio All three of the above subject welds were rejected by the USTC RT Level II and were subsequently accepted by the VPC RT Level II \

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A ravicw of the miscellaneous Recirculation Spray System radiographs for

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Unit 2 (Job Nos. EWR86-502, EWR86-507, and NDER86-507) showed the evaluation of unacceptable crack indications in the piping. VPC listed these radiographs as "information only" to monitor crack growth. The Senior Resident Inspector was notified of this condition for future followu . Moisture Separator Reheater (MSR) Modification The NRC inspector reviewed VPC Purchase Orders (P0s) ET-41600-SC and ET-41586-SC which were issued to Southwestern Engineering Company (SEC)

for materials and engineering services related to the modification of the four MSRs .~ar both Unit I and Unit 2. Each P0 contained several attachment Attachment IB, "VEPC0 Special Terms and Conditions for Nuclear Work" (STC 1-STC 13) was dated February 18, 1983 and was included in each P0.Section II of Attachment IB stated that the provisions of 10 CFR Part 21 may be applicable to the work performed, and the supplier shall comply with the requirements of 10 CFR Part 21 to the extent applicable. Section II:

Attachment IB stated that the supplier shall adopt and implement a quality assurance (QA) program that meets all NRC requirements including 10 CFR Part 50, Appendix B. Attachment IIA referenced the technical specification for each project. In a review of SEC documentation packages sent to VPC, it was noted that SEC did not take any exception to the requirements of the PCs or specifications as referenced in Certificate of Compliances signed and dated December 17, 1984 (Job Nos. 84-20-02/03/04) by the QA Manager or his equivalent. It was noted that the 10 CFR Appendix B and Part 21 requirements were imposed by VPC even though the material and services supplied were not designated as safety-relate The inspector reviewed Contract No. PSC-C-0184704 between VPC and SEC for MSR modifications at Surry, Unit Nos. I and 2. The scope of work in the contract was for SEC to provide services and materials for the removal and installation of the new MSRs at both units. Section 5 of PSC-C-0184704 addressed the applicability of 10 CFR Part 21, and stated in part, " Contractor understands that the provisions of the Title 10 Code of Federal Regulations (CFR) Part 21 apply to this contract."

A further review of the SEC documentation packages sent to VPC indicated I that the MSR internals were designed, manufactured, and tested to the i requirements of Section VIII of the ASME Code and had been shipped to the Surry site in September, October, and December 198 The NRC inspector reviewed the design change packages (DCPs) 84-17 and 84-18 for the MSR modifications at Unit I and Unit 2, respectivel In general, the DCPs consisted of field changes, specification ME-NUS-2004, Final Design Controlling Procedure (FDCP), material lists, drawings, NDE liquid per.etrant reports, welding inspection checklists, Standard Operating Procedure from SEC, SEC welding procedures and procedure qualification records, and Vendor Surveillance Inspection Reports. A VPC inspector indicated that weld maps were not used on the work performed by SEC but that an SEC inspector signed off for completion of activities on the FDCP which was similar to a " traveler."

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It was noted that VPC completes a Receipt Inspection Report (RIR) for

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each individual who performs work under a service contract. A number o RIRs for personnel supplied by SEC were reviewed. In addition, Welder Qualification Test (WQT) records for approximately 15 individuals were reviewed. The WQTs appeared on SEC letterhead and had been signed by G. A. Johansen of SEC. A review of training records indicated that-individuals furnished by SEC were trained at the site by VPC and had successfully passed General Employee Training and Radiological Protection test . Industrial Distributors .

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On April 10, 1967, the Resident Inspector at Surry was informed of the -

results of a VPC audit of Industrial Distributors which indicated that the vendor's QA program did not meet the requirements of 10 CFR.Part 50 Appendix These concerns were brought to the attention of the NRC headquarters staff on April 13, 198 The NRC inspector discussed the results of VPC's Audit Report No. 87-11 dated February 26, 1987 with the auditor and his supervisor. The results of this discussion are as follows: 4 The material, piping and fittings, supplied to VPC's North Anna facility on four P0s were non-safety relate . Of approximately 155 P0s for Surry, it was determined that two orders were for safety-related material (i.e., requirements of 10 CFR Part 21 were referenced on the P0s). One order was for 3/4" stainless steel pipe and the other was for five Cu-Ni valves. VPC is currently evaluating the location and safety significance of these items in the plan Based on the results of the February 1987 audit, VPC removed Industrial Distributors from its Safety Related Vendors Lis .

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