IR 05000338/1990026

Insp Repts 50-338/90-26 & 50-339/90-26 on 900924-28 & 1009- 12.No Violations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Maint/Housekeeping,Ros, Thermal Sleeve Weld Exam & ISI

ML20058H026
Person / Time
Site:	North Anna
Issue date:	10/22/1990
From:	Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058H024	List: IR 05000338/1990026 ML20058H021
References
50-338-90-26, 50-339-90-26, NUDOCS 9011140189
Download: ML20058H026 (19)

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s UNITED STATES -

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.$* ,j 101 MARIETT A STREET, ~t ATLANTA,OEORol A 30323

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I Report Nos.: 50-338/90-26 and 50-339/90-26 Licensee: Virginia Electric and Power Company-Glen Ailen, VA 23060 Docket Nos.: 50-338 and 50-339 . License Nos.: NPF-4--and NPF- .

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Facility Name: North Anna 1 and 2 r .

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Inspection Conducte - Se t be 24-28,s and October 9-_12,'1990 Inspector.._ .

er e--P:'E.--_ r - sQ n & lfdt96 }

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_K (i Date Signed Approved by: /c '2 90 J . Blake, Chief' -Dat'e Signed l

.a rials and Processes Section i

gineering Branch Division of Reactor Safety- ,

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i SUMMARY Scope:

This routine, unannounced inspection was- conducted in the areas of licensee -

actions on previous inspection findings', maintenance / housekeeping, reportable occurrences, thermal sleeve weld examination, and Inservice Inspection (ISI)

including the eddy current examination of the Unit 2 steam ' generator tubin The inspection included a review of the Unit 2 ISI plan -for this . outage; reviews of nondestructive examination (NDE) procedures;Dobservations of in progress NDE examinations; reviews of NDE personnel qualifications; reviews of 4 NDE equipment calibration and material ' certification documentation; ~ and, a  !

review of completed NDE examination data.' i Results:  ;

This inspection indicated that ISI nondestructive examinations were being conducted adequatel The NDE personnel conducting the examinations appeared well qualifie The inspector noted . weaknesses celated to the following:

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the inability to retrieve documents - Unit 2 Ten (*ar ISI Plan- (Paragraph 3.e.(1)(b)) and .

radiographic film (Paragraph 3.e.(3)); present mo'nitoring program for special  !

process ISI . records (Paragraph 3.e.(1)(c);. suitability _ analysis for non pressure retaining components in the ASME Section XI Repair and Replacement ,

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9011140189 901029 PDR ADOCK 05000338

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• Program ;(Paragraph 3.e.(1)(d)); equipment protection (Paragraph -3.e.(2);

inattention-to procedure details:(Paragra

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to monitor thermal- sleeves (Paragraph'-5) ph 3.e.(1)(e); and: lack of. a- program One unresolved item -relative to an -inoperative fire door was,- identified -

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(Paragraph 4and6).

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REPORT DETAILS Persons Contacted Licensee Employees M. Bowling, Assistant Station Manager

• G.-Kane, Station Manager

• P. Kemp, Supervisor, Licensing

• J. Leberstien, Licensing Engineer

• T. Porter,:SupervisorInserviceInspection(ISI)

• J. Smith, Manager, Quality Assurance (QA)

• C, Sorrell., Supervisor, Engineer Mechanics

• J. Stall,~ Superintendent of Operations

• H. Travis, Supervisor, NDE Services Other licensee employees contacted during this inspection included craftsmen, engineers, security force members, technicians, and administrative personne NRC Resident Inspectors M. Lessor, Senior Resident inspector-L. King, Resident Inspector

• Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragrap . Licensee Actions On Previous Inspection Findings (Closed) Violation 50-338/89-18-01: " Failure To Provide For The Evaluation of Radiographs at Break Point 851 on The Feedwater System"'

VEPC0 letter of response' dated June 10, 1989, has been reviewed and

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determined to be acceptable by Region II. The inspector held discussions with cognizant ' licensee personnel and examined the corrective actions as stated in the letter of respons The inspector concluded that VEPC0 had determined the, full extent of the subject violation, performed the necessary su:vey and follow-up actions to correct the present conditions, and developed the ' i necessary corrective actions to preclude recurrence of similar, circucstances. The corrective actions identified in the letter of response have been implemente !

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(Closed) Violation 50-338/89-18-02: " Fire Watch Asleep On Duty."

VEPC0 letter of response _ dated' June 10, 1989, has-been reviewed and ,

determined to be -acceptable by Region -II. The inspector held ;

discussions _ with ~ cognizant licensee personnel and examined the !

corrective actions as stated .in the letter of respons The i inspector concluded that VEPC0 had determined the full extent of the subject violation, performed the necessary survey and follow-up! i actions to correct the present conditions, and developed the

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i necessary corrective actions to preclude recurrence of similar circumstances. The corrective actions identified -in the letter of response have been implemente Inservice Inspection l The inspector reviewed documents and records and observed activities, as I indicated below, to determine whether ISI was - being conducted in 1 accordance with applicable procedures, regulatory requirements, and- :

licensee commitments. The applicable code for ISI, for Unit 1 is the -

American Society of Mechanical Engineers Boiler and Pressure-Vessel (ASME B&PV) Code,Section XI,1983 edition with ' addenda through Summer 1983 (83S83) for the second ten year interval (December 24, 1988 - December 24, 1998). The applicable code for ISI, .for Unit 2 is the ASME B&PV Code, o Section XI, 74S75 for the first ten year interval- (December 14,.1980 - ;

December 14, 1990), and 1986 edition for the second ten' year _ interval !

(December 15, 1990 - December 14, 2000). Unit 1~ received'its Operating ;

Licensee on April 1,1978, commenced commercial; operations on June 6,1978 3 and is currently operating in the first 40 month period of the second ten year interval. Unit 2 is in the third outage of the third 40 month' period l of the first ten year interval. The Licensee,. Virginia Electric Power C (VEPCO) conducts business in Virginia under the 'name.of ' Virginia Power, i VEPC0's nondestructive examination personnel,'provided by. Westinghouse (W)

and Virginia Corporation .of Richmond. (VCR),are performing the liquid penetrant (PT), maonetic particle (MT), radiographic' (RT), and visual

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(VT), ultrasonic (UT) examinations. The Reactor ~ Vessel (RV) UT i examinations were accomplished by W. Steam generator tubing eddy current ;

(EC) examination were accomplished' by ~W. All work is being performed- !

under the envelope of the VEPC0 Quality hssurancet(0A)" progra f ISIProgramReview, Units 1and2-(73051)'

The inspector reviewed the following documents relating to the ISI )

program to determine whether the plan lhad been approved by th licensee and to assure that procedures and planschad been established .

(written, reviewed, approved and issued)' to' control and accomplish I the following applicable activities: organizational ' structure -

including qualifications, training, resp'onsibilities, and duties of personnel responsible for ISI; audits including ' procedures, frequency, and qualification of personnel; general Qual _ity Assurance- i requirements including examination reports, deviations 'from -

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previously established program, material certifications, and i

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identification of components to be covered; work' and inspection . '

procedures; control of processes including suitably controlled work:

conditions, special methods, and use of qualified personnel; corrective action; document control;. control ~ of examination equipment; quality records including documentation of indications-and ,

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NDE findings, review of - documentation, provisions .to : assure -

legibility and retrievability, and corrective action; scope. of the -

inspection including description of areas to be examined, examination category, method of inspection, extent of examinations,- and justifi- ,

cation for any exception; eT!.71 tion of' inspection -interval _-and extent of examination; qualification ef NDE personnel; and, controls ,

of generation, approval, custody, 5 tora 9: and 'maintenanco of NDE- I record ;

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Examination Program . Plan Reactor Vessel . Interval l', Period 3, Outag , and Interval 2, Period I, Outage VEPC0VAP-0307(R7) . Repair and Replacement Program for ASME :

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Section XI Component VEPC0151-1.0(3-3-89) Inservice' Inspection Organization and-Responsibilitie VEPC0151-4.0(5-3-90) :ASME Section XI Component '-Support Visual Examination Progra VEPC0151-7.0(3-3-89) ASME_Section'XI NDE Examination Progra .

VEPC0 ISI-10.0 (3-3-89) ASME 'Section XI ' Class' l' Valve Visual-

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Examination Progra ,

VEPC01S1-17.0(12-30-88) Processing' New ~and Revised ISI Administrative 1 Procedures and ISI'

Component Listing !

VEPC0ISI-19.0(5-3-90) Inservice ; Inspection

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Repair and Replacement Program.-

VEPC0ADM-16.1(10-11-89) Station. Deviation Procedur VEPC0 VPAP 1-5A (4-90) North Anna Power Station _-Units 1 and;2 Operational Quality Assurance Program 1 Topical Repor !

VEPC0 VPAP-0502 (RO) Procedure! Process. Contro VEPC0N005-QA-02(R6) Quality Assurance Audit Progra VEPC0 DCM-63 (11-18-88) General Microfilmin ;

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VEPC0 Memorandum- (2-4-10)1990 North Anna. Quality Assurance LAudit Schedule, b. Review of NDE Procedures, Units 1 and~2 (73052) l (1) The inspector reviewed the procedures listed below to determine whether these procedures. were consistent with regulatory requirements and licensee commitments. =The procedures were also reviewed in the areas of procedure approval, requirements for qualification of NDE personnel, and compilation of: required records; and, if applicable, division of responsibility between the licensee and contractor personnel -if contractor < personnel ;

are involved-in the-ISI effort,

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VEPC0 (R2)- NDE Services Administrative Manua Section 4 - Proficiency Training and Examination

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- Section 11 - Evaluation of NDE Performance)

- Section 12 - Contractor Evaluation Syste Section 13 - Contractor. Audits VEPC0NDE-2.4(R3) Requesting and . Reporting, of. NDE-

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VEPC0NDE-3.1(R6)- Preparation, Issue, and Control of Nondestructive Examination Procedures, i VEPC0NDE-4.1(R11) Virginia Power Written Practice : for Certification- of- Nondestructive Examination Personne VEPC0151-5.0(3-3-89) Inservice Inspection Per's onnel Certifi-cation and Training Requirements for Visual Examinations VT-l',. VT-2, J and VT- VEPC0NDE-6.2(R2) Review of Nondestructive: Examination Interpretation .by Virgi~nia.-Power Personne VEPC0 NDE-6.3 (R1) Storage and Control of NDE Calibrated Equipment, Calibration Standards an Consumable NDE Materials VEPC0 NDE-7.3 (RI) General Requirements forLISI'

Nondestructive Examination VEPC0NDE-MT-301(R1) Magnetic Particle Examination

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VEPC0 NDE-MT-302 (RI) Magnetic-Examination of. Boltin VEPC0 NDE-PT-301 (RI) Liquid Penetrant Examination VEPC0NDE-PT-302(RI) Liquid Penetrant Examination of Bolting Material VEPC0 NDE-UT-301 (RI) Manual Ultrasonic Examination of Piping Welds VEPC0 NDE-UT-302 (RI) Ultrasonic Examination of Vessel Welds Less Inan 2" in Thickness VEPC0 NDE-VT-303 (RI) Ultrasonic Examination of Vessel Welds Greater than 2" Thicknes VEPC0 NDE-UT-304 (R1) Instrvice Ultrasonic Examination of Boltin VEPC0 NDE-UT-305 (R1) Manual Ultrasonic Examination of Reactor Coolant Piping Welds VEPC0 NDE-UT-306 (R1) Ultrasonic Inspection of Studs & Bolts Less Than-2" in Diameter VEPC0 NDE-RT-101 (R1)- ; Radiographic Examination of Weld VEPC0151-16.0(5-31-90) Inservice Inspection Visual-Examination Procedure W VPC-ISI-254 (RI) Remote Inservice Inspection'of Reactor Vessel W MRS-2.3.2 VRA-17 (RO) Mechanical Tube Pluggihg of Steam Generator Tube IMP WMRS-2.4.2VRA-4(RS)- Digital Multi-Frequency Eddy Current Inspection of Preservice and. Inservice Heat Exchanger Tubin (2) Ultrasonic: Examination (UT)-

The inspector reviewed the UT procedures to. ascertain whether they had been reviewed 'and approved in accordance -with the licensee's established QA procedures. . The procedures were also reviewed for technical- adequacy. and conformance with ASME,Section V,: Article 5 and other licensee commitments / requirements in the following areas:, type of apparatus used; extent - of coverage of weldment;" calibration requirements; search units; beam angles; . - DAC curves; reference level for ' monitoring discontinuities; method for demonstrating penetration; limits

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for evaluating and recording indications; recordin5 significant-indications; and.. acceptance limit l (3) LiquidPenetrantExamination(PT)  ;

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had been reviewed and approved in accordance with the licensee's established QA procedures.- The procedure was also reviewed'for technical adequacy and conformance with ASME,Section V, Article 6, and other licensee commitments / requirements in -the q following areas: specified method; penetrant material  ;

identification; penetrant materials analyzed for sulfur;- l pene+. rant materials' analyzed .for total- halogens; surface

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temperature; acceptable pre-examination. surface conditioning; method used for pre-examination surface cleaning; surface drying time prior to penetrant application; : method of penetrant 1 application; penetrant ; dwell time; method . used for excess penetrant removal; surface drying. prior to developer-application, if applicable; type of-. developer; -examination technique; . evaluation; techniques; and, procedure requalificatio (4) Magnetic Particle Examination (MT) .

The inspector reviewed the MT procedure to ascertain whether it had been revie.>d and approved in accordance with the licensee's

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established QA procedures The dprocedure ' was reviewed - for- 1 technical adequacy and for conformance ' with the ASME- Code Section V, Article 7, and;other licensee commitments / requirements >

in the following areas: .examinatiori methods; contrast of_ dry l powder particle color with ' background; surface- temperature;  ;

suspension medium and surface itemperature requirement for wet particles; viewing conditions; examination ' overlap and'

directions; pole' or prod spacing;' current or lifting power (yoke); and, acceptance criteri '

(5) Radiographic Examination (RT-)

The inspector reviewed the RTl procedure'to determine whether it contained sufficient 'information Lto ' assure that . the Lfollowing parameters: were specified1and controlled within the limits -

permitted by the applicable code . or-'any other specification requirement: type of materialsto be radiogr phed; material:and ,

weld surface condition requirements; type; of: radiation source, I'

effective focal spot or effectiveusourcensize; film brand or, type; number of films in cassette;L minimum -source to film distance; type and thickness ' off intensifying ' screens - and- -

filters; quality of radiographs; : film density -and contrastc for single and composite viewing;Tusetof densitometers for assuring ,

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compliance with film density.- requirements; system of- radiograph identification; use of locatio'n markers; methods'of reducing and-d y , ,

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testing for back-scatter; selection of penetrameters including j

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penetrameter placement; number of penetrameters;- shims under '

penetrameters; radiographic technique for double wall viewing; and, evaluation and disposition of radiograph (6) Visual' Examination (VT)  ;

y The inspector reviewed the VT procedures to determine whether I they contained sufficient instructions to. assure that th following parameters were specified and controlled within the - s limits permitted by the applicable code, standard, or any other a specification requirement: method -' direct visual, remote l visual or translucent visual; application - hydrostatic testing, J fabrication procedure, visual examination 'of welds, leak _ y'

testing, etc.; how visual examination is to be performed; type of surface condition available; method or implement used for surface preparation, if any; whether direct or remote viewing is-used; sequence of performing examination, when applicable; data to be tabulated, if any; acceptance criteria is specified and consistent with the applicable code sectionL or controlling-specification;. and, report form completio .

(7) EddyCurrentExamination(EC) {

The inspector reviewed the EC procedures for technical contentL ,

relative to: multichannel examination unit,' multichannel examination indication equipment -is .specified,- examination y sensitivity, method of examination, method of calibration- and '"

calibration sequence, and acceptance criteria.-

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All procedures reviewed appeared to contain the necessary elements for conducting the specific examinatio c. Observation of Work and Work Activitie', Unit 2.(73753)

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The inspector observed work activities,- reviewed certification records of NDE equipment and materials, and reviewed NDE personnel qualifications for personnel that had been utilized during the required' ISI examinations during this outag The observations and reviews. conducted by the inspector are documented belo (1) Ultrasonic Examination (UT)

The inspector observed calibration activities and the in-process a UT examinations as indicated below. These observations were compared with the applicable procedures and the ASME B&PV--Cod ;

in the following areas: availability lof and compliance with r approved.NDE procedures; use.of knowledgeable NDE personnel; use . 1 of NDE personnel qualified to the proper level; type of ' 7 apparatus ;used; calibration requirements;. search. units; beam

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angles; DAC curves; reference level 'for monitoring !

l discontinuities; method of demonstrating penetration; extent of i L weld / component examination coverage; limits of- evaluating ,and i recording indications; recording significant indications; and, acceptance limit '.;

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Examinations Observed i The inspector observed.in process UT examination activities on .

l the reactor vessel and-feedwater-piping, and reviewed records of UT examinations 'of piping _ welds, studs and nuts on reactor coolant and safety injection system _

The inspector reviewed selected calibration and certification documentation for the UT instruments, calibration blocks, and couplant, and spectrum analysis data for the ultrasonic transducers used in the examinations listed abov j (2) LiquidPenetrantExamination(PT) l The inspector observed .the in process __PT examinations as j indicated below. ' The observations were compared with the applicable procedure and?the ASME B&PV Code in the_ following areas: specifiedCmethod, penetrant materials identified;-

penetrant materials-analyzed for halogens and sulfur; acceptable pre-examination surface; . surface temperature; surface drying ,

time prior to penetrant' application;- method of ~ penetrant !

application; penetrant dwell time;- method used for excess penetrant removal; surface drying . prior to developing, if ,

applicable; type of developer; examination technique; evaluation j technique; and, reporting of examination result i l

Examinations Observed  ;

The inspector observed.PT examination activities associated with the safety injection system. The inspector reviewed-records of PT examinations of Lthe reactor coolant and ~ safety injection t systems  !

. i The inspector's review. of the liquid penetrant- materials _

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l cer:ification records,Lfor, the. examinations indicated above, tha: the sulfur and halogen content of the material was withi acctptable' content limits.;.

(3) Magnetic Particle 'Exaniination~

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The inspector observed . the ? in-process MT examinations as indicated belo The . observations were compared with the applicable procedures andothe' Code in the following areas: .

examination methods; contrast of dry powder particle color with )

background; surface temperature; - suspension medium for wet particles, if applicable; viewing conditions; examination

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overlap and directions;-pole or prod spacing; current or lifting power (yoke);andacceptancecriteri '

Examinations Observed The inspector observed MT examination activities associated with i the main steam system. The . inspector reviewed records: of MT examinations performed , on the reactor ' coolant and safety -;

injection system '

The inspector reviewed documentation indicating that the -10 pound. lif t test had been performed on magnetic particle alternating current (AC) yokes observed abov The certification records for the lift test plates that were used to conduct the tests,cwere- reviewed to confirm the weight of the test plate '

A review of the material certification: records for the particles? J used in the examinations above met the applicable specification requirement (4) RadiographicExamination(RT)

The inspector evaluated -the below listed film that was i radiographed under the licensee's' ISI program in order to o determine if the radiographic quality was in accordance with the l applicable procedure and ASME Code requirements and to specifically verify the'following: penetrameter type, size, and - a placement; penetrameter sensitivity; film density and density variation; film identification; . film- quality; weld. coverage; and, disposition of the welds radiographe }

The inspector reviewed film associated with the feedwater syste The inspector confirmed the calibration status for the J densitometer and density film table used in the examination !

above ascertaining that the documentation -was retrievable, complete, and accurate.' '

t (5) Visual Examination'(VT)-

The inspector observed the below indicated in-process VT

, examination These observations were made to: determine whether the applicable drawing, instructions or travelers .a

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clearly specify the procedure to be used and that a copy of the .

procedure is available in the area where -the work is- being - i performed; identify for- record review- the personnel performing .;

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the examination' and ascertain whether they are qualified to perform the assigned task; determine whether the required tools and examination aids'(as specified in the examination procedure); !

are available at the work -location; determine whether the x -

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- 10 specific areas, locations and extent of examination are clearly defined; detenn'ce whether the test attributes are as specified in the applicable test procedure; ascertain whether the defects are evaluated in accordance with the procedure requirements, correct acceptance criteria is used, and'the inspection results are reported in a prescribed manne Examinations Observed The inspector observed VT- examination activities associated with i the safety injection and main steam systems. The inspector reviewed records of VT examinations performed on the reactor ;

vessel internals and reactor coolant' system studs.and nut (6) SteamGeneratorTubingEddyCurrentExamination(EC)

The inspector observed the EC activities indicated below.. Th observations' were. compared with .the applicable procedures and the ASME Code in the following . areas: method for maximum-sensitivity is' applied; method of examination has been recorded; (

examination equipment has been calibrated in accordance with the applicable performance referense; amplitude and phase angle have been calibrated' with the. proper calibration . reference and is recalibrated at predetermined frequency; required coverage of steam generator: tubes ~ occurs during the eumination; acceptance criteria is spet;ified or ' referenced and is consistent with the procedure or the ASME Code;'and, results are consistent with the acceptance cr'.teri ' Activities Observed

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The -inspector reviewed records of EC examination of steam

generator tube examinations.

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Certification records'for EC calibration standards were reviewed for material type, correct- fabrication, and artificial flaw location and siz (7) Personnel Qualification The inspector reviewed personnel ~ qualification-documentation.for

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the examiners indicated below. .These personnel qualifications ;

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were reviewed in the. following . areas: employer's name; person certified; activity qualified to _ perform; ' current ' period of.-

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certification; signature. -of employer's designated'

representative; basis used for certification; and, annual visual acuity, color vision examination, and periodic recertification.

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EC 1 j 1 Data Review and Evaluation, Unit 1-(73755)  !

Records of completed ISI nondestructive examinations indicated:

below were selected and reviewed: to ascertain whether: the method (s), technique, and extent of the examination complied with the ISI plan and applicable NDE procedures; findings were <

properly recorded and evaluated by. qualified personnel; programmatic deviations were recorded as required; personnel, i instruments, calibration blocks, and NDE materials (penetrants,

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couplants) were designate Records Examined The inspector examined records of , UT , MT, PT, _ and VT- l examinations performed on the safety injection, reactor coolant and residual heat removal systems during the: last unit 1- '

refueling outag i All of the examination reports reviewed appeared to contain the required examination ~information including disposition of indications, if an A random sample of current examination results were compared- ,

with historical examination results- No' major discrepancies

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were noted 'Jring the comparison, e. Observations  !

(1) As a result of the review 'of the licensee's 'ISl program i and procedures the inspector noted the following:

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(a) For Unit 2 during this outage, the licensee has performed UT examinations .on the reactor vesselLthat were scheduled to be performed in the third _40 month period of the firs ten year interval and additional: UT- examinations- that were scheduled to be performed duringLthe first:40 month net iod--

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of the second ten year interval, thereby-. performing the second inte'rval examinations prior to the start' of the second interval, due to start December 15, 1990. Th licensee indicated - that the exmninations were performed early to reduce personnel rediation exposure aN in'

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addition for ~ economic and - scheduling; coniideration However, the licensee was unable to provide the inspector with an ASME Code basis for those early- examination After discussions with the inspector and the Office of Nuclear Reactor Regulation, the licensee-indicated that

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i they would submit a relief. request to the Commission for i this departure from code requirement i

(b) The licensee was unable to provide- the inspector.with a-copy of the Unit.2 Ten Year ISI Plan, or any evidence =that one ever existed.- The licensee did however, provide the i inspector with a copy of the 40 month period plans.for~each 1 of the three 40. month : periods in thel first . ten year-. 1 interval and an audit ,to assure that all the: necessary

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examinations had been accomplished or scheduled. to ' be ; l accomplished. at schedule and. frequency , consistent with j Section XI of the ASME B & PV Code. The Unit 2 Ten Year l ISI Plan for the second ten year interval is in preparatio now and is scheduled' to be issued prior to the- end of the 1 fiat interval in December 199 (c) The licensee has established a' program to evaluate quality ,

record microfilm film quality to detect potential film or '

image degradation, accomplished by an annual examination.of a one percent sample of the total microfilm on' hand. 'The licensee does not.have a similar program howeverffor other' "

special process - records generated by the ISI- program such o as radiographic film, magnetic ~ data ' tape and computer 1 disks and optical _ disks.; The licensee-indicated that the :

record management'~ program is;in the process of revision to -

provide a uniform system for the entire utility, in which quality sampling.for other special process' records will. be

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addresse (d) For Mechanical Engineers ~ Boiler and u America Society (ASME B & PV) Code Section XI, Paragraph Pressure Vesse IWA 7220 requires the Owner to conduct an evaluation.of the- i suitability of replacements,. prior * to authorizing :the installation of those replacements. This requirement is implemented by VEPC0 VAP-307,- Rev ' The licensee- g informed the inspector that! VEPC0 VAP-307.is applicable to I pressure retaining component: and their supports only i (items covered by ASME B & PV Code Subsections IWB, IW I IWD, and IWF). The' licensee's program does not; address the - ll IWA 7220 suitability analysis requirements for.non pressure

retaining replacement parts, such .as bearings, bushings, i springs, stems, disks and shafts (items covered by ASME B &

'PV Code Subsections IWP and IWV).s The-licensee was unable to provide aL single example where there- was objective -l quality evidence attesting to the fact that a responsible 1 individual had made a conscious decision that replacements- 'l l

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"in kind", of non pressure rete ning parts.for Section XI ;

components, were suitable for the intended servic "

The inspector concluded' that a weakness exists in the licensee's program - related to the implementation of the suitability analysis requirements of ASME B & PV Code- -

Paragraph IWA 7220 for nen pressure retaining components cnd for the documentation of suitability analysis for all ,

first time replacements "in kind."

(e) The following six items are of relati,ely minor safety significance, however they are indicative of inattention to '

detail: 1

- Procedure VEPC0 NDE 6.3," Storage and Control of NDE <

Calibrated Equipment, Calibration Standards and Consum6bles", . P:ragraph 5.0 " Records", does not i specify .that certification records for calibration standards contain " material specification", " product '

form". or'" heat treatment" contrary to Article 4 and 5 -

of ASME B&PV code Section !

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The index of the NDE Manual and The NDE Administrative Manual contained several errors in procedure revision '

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Manual contained both Revision 0 and Revision 1 (which I

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supersedes Revision 0) of procedure VEPC0 NDE-6.3, ~,

contrary to VEPC0 NDE-3.1, " Preparation, Issue and Control of Nondestructive Examination Procedures", '

Revision 5, paragraph 3.2.2 c, which requires the l manual 2 older to destroy all canceled and superseded '

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Controlled copy No.13 of the " Inservice Inspection Manual" contained co)ies of VEPC0 151-5.0, VEPC0 151-8.0, and VEPC0 JSI-8.1, which the table of contents indicated were deleted on 3/3/89, 5/31/90 and '

I 5/31/90 respectively.

l - Several NDE procedures contain ASME BSPV Code Section references with unclear or missing " Edition and Addenda" informatio .

Procedure VEPC0 NDF-UT-301, useo "may" vice "shall" in

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the specification of calibration block hole diamete '

(2)-During the - observation of UT activities in the Unit 2 containment building, the inspector noted that licensee and contractor personnel were forced to climb on installed plant :

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equipment due to the lack of scaffolding to perform their dutie The equipment included cable trays, piping, electrical !

conduit, piping supports, instrument tubing, and heating :'

ventilating and air conditioning ducting. Alt .ough, in the areas where the inspector made these observations no damage was i noted, damage from personnel climbing on installed equipment could exist elsewhere. The inspector's concern.in this matter is: equipment important to safety could be damaged and thus be ,

unable to perform its safety function when needed. The licensee ;

indicated that the prohibition on climbing on installed !

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equipment is verbally included in the new employee training, but it is not formally documented anywhere in the licensee s ,

progra The above indicates a weakness in the area of )

equipment protectio (3) Relative to the examination of radiographs, the inspector reviewed five licensee-evaluated, and accepted, film packages .

(weld joints). The licensee's radiography policy and procedure require the exposure of two film per shot there was only one film for the radiographic exposures listed belo Joint N Segments With Missing Film BPL-505 0-9 i

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BPL-281 0-5 & 10-15 I

The next day the licensee was able to locate some of the missing film , but not all. They indicated that they would reradiograph those segments for which the film could not be located. The above is indicative of carelessness and lack of attention to detai (4) Relative to the steam generator examinations the licensee visually identified leak indications (boron deposits, dry, wet, or dripping) at tube plugs in all three steam generators. EC examination indicated that the plugs were cracked. All the leaking plugs were from the same heat (Ht. No. 6323) of inconel 600 material. The' licensee removed all hot leg Ht. No 6323 Inconel 600 plugs and replaced-them with Inconel 690 plugs (S/G A 17, S/G B 18 & S/G C 45). There are a-total of 181 Ht. N ;

6323 Inconel 600 plugs in the three Unit 1 steam generators. In addition, as a result of the EC examination of steam generator tubing, the licensee plugged a total of 100 additional tubes (S/G A 33, S/G B 23, & S/G C 44).  ;

In the areas examined, no deviations or violations were identifie . Maintenance / Housekeeping The inspector made a general walk-through inspection of- the turbine, auxiliary, and the Unit 2 containment buildings and the exterior protected areas to observe maintenance and housekeeping activitie _ _

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Relative to the inspection above, the inspector noted one side of double door S7128, the access to the plant cafeteria, located in the main hallway on the ground floor, of the administration building, one of- the highest

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traffic areas in the plant,. marked " FIRE DOOR KEEP CLOSED" was blocked open, due to an inoperative fusible lin This link would normally hold :

1 the door open when the room temperature is below the fuse temperature, i This condition has existed from before the, start of this inspection to October 3,1990 when the fusible link was repaired, as the result of this inspector's identificatio When questioned about this condition the ,

licensee indicated that this door is part of the fire boundary as defined

! by Appendix A, to Branch Technical Paper 9.51 'The licensee was unable to

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determine how long the fusible link door closer' had been inoperative causing the door to be blocked open. The above is a clear indication of complacency and lack of attention to detail on the part of all the  ;

licensee personnel who pass that door on a daily basi During this inspection, the relative safety significance of- the above i discussed circumstances could not be determined, as well as whether those circumstances are in violation of regulatory requirement Pending additional NRC review in this ~erea, this matter wa: identified as e unresolved item 50-338, 339/90-26-01: " Inoperative Fire Door". (NOTE:

THE MATTER WAS RESOLVED AFTER THE INSPECTION AS NOTED IN PARAGRAPH 7)

In the areas examined, no violations or deviations were identifie > ReportableOccurrences(92700)

The LERs listed below were reviewed to determine if the information provided met NRC requirement The determinations included the verification of compliance with TS and regulatory requirements, and addressed the adequacy of the event description, the corrective actions

, taken, the existence of potential generic problems, compliance with ,

reporting requirements, and the relative safety significance of each

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I event. Additional in-plant reviews and discussions with plant personnel,

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as appropriate, were conducte ,

(Closed)LER 338,339/90-09, " Service Water System Support Design Error".

This LER was associated with a design error. that had the potential to over stress anchored service water system pipe supports and cause a failure of the service water system piping during a design basis acciden The inspector reviewed documentation provided by the licensee to verify the completeness of the corrective action. The. inspector determined that the licensee's corrective actions have been adequate to prevent recurrence of this event. This item is close In the areas examined, no violations or deviations were identified, f

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6 Thermal Sleeve Weld Examination In 1982 VEPC0 found some thermal sleeve retaining welds in the reactor coolant system were cracked. The affected sleeves were removed. The remaining sleeves were committed to be monitored with temporary loose parts monitoring system until the sleeves were removed. The temporary loose parts monitoring system has failed and will be removed. The licensee has committed, by VEPC0 letter dated June 15, 1990, to monitor the remaining sleeves by radiography every third outage until all the sleeves are remove The inspector reviewed the radiographs made during.this outage for the four remaining sleeves in Unit 2. The. licensee to date has not provided a programmatic means to assure that the remaining sleeves will be inspected cs comitted. The licensee indicated that the radiographic monitoring of l the thermal sletves will be iRluded as an augmented examination in the respective ISI plan . Exit Interview The inspection scope and results were summarized on October 12, 1990, with those persons indicated in paragraph-1. The inspector descrit,; the areas inspected and discussed in detail the inspection results listeJ belo Although reviewed during this inspection, proprietary informat;on is not i contained in this repor The licensee objected to the inclusion, in this report, of the of the unresolved item related to the fire door and it's ignored sign, which is discussed in paragraph 4 abo"e. The inspector, noted, as he left the rite, that the fire door sign was being remove ,

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(Closed) Unresolved Item 50-338, 339/90-26-01: " Inoperative Fire Door"-

t Paragraph 4 l After the exit interview the licensee provided the senior resident l inspector a Title Ten, Code of Federal Regulations, Part 50.59 safety

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evaluation No.90-SE-0T-163 dated October 12, 199 The senior resident inspector contacted this inspector and informed him that he had looked into this matter and determined that there is no violation of regulatory requirements cs this door is not included in the Technical Specification The senior resident inspector indicated some concern over the apparent licensee complacency with fire door warning signs and its potential to occur in other areas. Based on the above this issue is considered close The licensee was so notified on October 18, 1990, by telephon . Acronyms and Initialisms

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AC - Alternating Corrent i ASME - American Society of Mechanical Engineers B&PV -

Boiler and Pressure Vessel DAC - Distance Amplitude Curve EC - Eddy Current

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10 - Identification l

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151 - Inservice !nspection 1 MT - Magnetic Particle I NDE - Nondestructive Examination j N Number ,

NPF - Nuclear Power Facility l NRC - Nuclear Regulatory Commission 1 OD - Outside Diameter Professional Engineer PT - Liquid Penetrant  :

QA - Quality Assurance  ; Revision 1 RT - Radiographic Test SG - Steam Generator .

U1 - Ultrasonic  !'

VT - Visual VCR - Virginia Corporation of' Richmond-VEPC0 - Virginia Power and. Electric Company VPC - Virginia Power Compan I

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