ML18151A116
| ML18151A116 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/16/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-587, NUDOCS 8710230285 | |
| Download: ML18151A116 (3) | |
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VIRGINIA ELECTRIC AND PowER CoMPA1'..-Y USNRC~OS RICHMOND, VIRGINIA 23261 AB1 OCl 22 A IQ: 00 W. L. STEWART VICE PRESIDE1T NUCLEAR OPERATIONS October 16, 1987 U. S. Nuclear.Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-280/87-21 AND 50-281/87-21 Serial No.
NO/GDM:pms Docket Nos..
License Nos*.87-587.
50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of September 16, 1987, in reference to the inspection conducted at Surry Power Station on April 27 - May 1, 1987 and reported in Inspection Report Nos.
50-280/87~21 and 50-281/87-21.
Our response to the Notice of Violation is addressed in the attachment.*
We have no objection to this inspection report being made a matter of public disclosure..
If you have any further questions, please contact us.
Very truly yours,
~\\-~~
W. L. Stewart
- Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
- Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry.Power Station 0110230205 g~b86~ao PDR ADOCK PDR G
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NRC COMMENT:
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED ON APRIL 27 - MAY 1, 1987 INSPECTION REPORT NOS. 50-280/87-21 AND 50-281/87-21 During the Ni.Jcl ear Regulatory Cammi ss ion {NRC) inspection conducted between the period of April 27 -
May 1, 1987, a violation of NRC requirements was identified.
The violation involved vendor programs.
.In accordance with* the-
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C {1987), the violation is li~ted bel~w:
Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "special*
processes, including... nondestructive
- testing are controlled... in accordance with... special requirements."
I.. Section 4. 2 of Procedure No. NDE 6.1, "NDE Vendor Qua l i fi cation and Observation," Revision 1 states, in part, "Vendor observations shall be performed at random... by the coordinators of NDE."
Section 6.1 of
_Procedure No.
NDE 6.1 states, in part, "All observation~ shan be reported in the Vendor Observation report form... '.'
Section 6.2 of Procedure No. NDE 6.1 states, "All vendor observation reports shall
. be forwarded to the Supervisor of NDE Servi ce_s who sha 11 retain them in the vendor's files for one year."
- 2.
Section 7.0 of ANSI N45.2-1977 state, in part, "documents, including changes... are distributed to and used at the location where the prescribed activity is pe~formed."
- 3.
Section 10. 3 of Procedure No. NDE 4.1, "VEPCO Written
- Practice for Certification of Nondestructive Examination Personnel," Revision 7
,states, in part, "Employees of companies supplying NDE services shall be certified...
Their certification shall be reviewetl and approved by a responsible VEPCO Level III Examiner or designee... ".
Contrary to above:
- l. There was no documented evidence that Vendor Observation Reports were generated for U.S.
Testing Company that performed radiographic testing {RT) in June and November 1986 and January and February 1987 at Surry Units 1 and 2.
- 2.
Procedure No. NOE 6.1 "Radiographic Examination,".Revision O was not at the location {i.e., NDE trailer) where RT film is reviewed and accepted or rejected.
- 3. There was no documented evidence that the cert i fi cations of seven individuals from U.S. Testing Company that performed RT activities in June. and November 1986 and January and February 1987 wer_e reviewed and approved by Virginia Electric and Power Company.
This is a Severity Level V violation {Supplement I) and applies to both units.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/87-21 AND 50-281/87-21
RESPONSE
- 1. Admission or Denial of the Alleged Violation:
Items #1 and #2 of. the alleged violation are denied.
Item #3 of the_
alleged violation is correct as stated.
Item #1 Vendor observation reports were not generated for U.S. Testing because Procedure NOE 6.1 *states, in part; "Vendoi obs~rvations shall be performed at random as deemed necessary....
11 Because every radi ograph performed by US Testing during the i dent i fi ed period was *reviewed for acceptance by a qualified Virginia Power examiner, it was deemed unnecessary to document
- additional vendor observations~
Item #2 The procedure was not at the work location at the time of this inspection because no work was in progress, nor was any radiography anticipated. The most recent RT examinations/evaluations, prior to this inspection, were
- performed in the second week of March.
In accordance with station procedure, it is the responsibility of the supervi~or to ensure procedures are current and made available to personnel who are performing work.
At the times when work was being performed at the film viewer, the necessary procedures were present.
It is our intent to continue this practice of having procedures available at.the work station whenever work is being performed.
- 2.
Reason for Violation:
The documented' evidence of the review of-the u~s~
Testing £bmpany
-personnel's certification was misplaced and ~ould ~ot be located.-
- 3.
Corrective Steps Which Have Been Taken and the Results Achieved:
Certifications for the seven individuals in question were obtained from U.S~ Testing Company.
Review of the documentation verified that these individuals were qualified to perform radiography during the time frames referenced. -
- 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
NOE personnel at Surry have been reinstructed on the importance of following procedures and the maintenance of documentation.
Presently, station administrative procedµres specify the processing of.
vendor cert i fi cation documentation. - However, as an enhancement, NOE Procedure 4.1, "VEPCO Written Practic~ for Certification of Nondestructive Examination Personnel", wili be revised to *provide clarification of responsibilities.
The *revision will stipulate which documents must be reviewed and maintained on file arid those responsible for the review.
- 5. The Date When Full Compliance Will Be Achieved:
Full compliance was achieved on September 30, 1987 upon the reinstruction of NOE personnel.