IR 05000263/1974003
| ML20024G158 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 05/06/1974 |
| From: | Dance H, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024G156 | List: |
| References | |
| 50-263-74-03, 50-263-74-3, NUDOCS 9102070605 | |
| Download: ML20024G158 (21) | |
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U. S. ATOMIC ENERGY COMMISSION DIRECTORATE OF REGULATORY OPERATIONS
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REGION III
Repre of Operations PO Inspection Repes t !:u. 050-263/74-03 Licensee:
Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 Monticello Nuclear Generating Plant License No. DPR-22 Monticello, Minnesota Category:
C Type of Licensee:
BWR (CE), 545 MWe Type of Inspection:
Routine, Announced Dates of Inspection:
March 26-29, 1974 w. '
Dates of Previous Inspection: March 5-8, 1974 (Operations)
an
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. Principal Inspector:
',1 Johnson
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'(Date)
Accompanying Inspectors:
L. J. Hueter J. W. Sutton Other Accompanying Personnel: None f-f Reviewed By:
.I n
, Senior Reactor Inspector E
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heact' r Operations Branch TDate)
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9102070605 740514 PDR ADOCK 05000263 G
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SUMMARY OF FINDINGS Enforcement Action The following violations are considered to be of Category Il severity:
A.
10 CFR Part 50, Appendix B, Criterion V, states, in part, that:
" Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings
. and shall be accomplished
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in accordance with these instructions
." The special General
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Electric Company Installation and Service Engineering Quality Assurance Manual for the Monticello Safety / Relief Valve Addition describes the procedures to be followed during the course of the addition work. Sections 9.0 and 17.0 of this manual establish requirements for procurement activities and the handling of non-conforming material, respectively.
Contrary to these requirements, site quality control personnel failed to impicment the quality assurance procedures as follows (Paragraph 15.c):
1.
Nonconforming weld rod.was being stored in a holding oven with
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conforming weld material.
2.
Nonconformance reports had not been prepared, in three instances, for nonconforming weld material.
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3.
Material purchase orders were being processed without first being
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approved by the General Electric Company Quality Assurance Specialist or Quality Assurance Engineer.
4.
Material was received onsite, inspected, and approved for use by site quality control personnel without the required quality assurance documents being available.
B.
10 CFR Part 50, Appendix B, Criterion XVIII, states, in part, that:
"A comprehensive system of planned and periodic audits'shall be carried out to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program."
In addition, the Northern States Power Company Quality Assurance Program Sammary for the Monticello Safety / Relief Valve Addition, Sections 0.1, 0.2.2(4), and 0.2.3(18) requires auditing of the implementation of the Quality Assurance Program.
Contrary to the above, planned audits had not been conducted by Northern States Power Company or Bechtel Corporation to determine the effectiveness of their portions of the Quality Assurance Program.
(Paragraph 15.d)
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10 CFR Part 50, Appendix B, criterion XVIII, states, in part, that:
" Audits shall be performed in accordance with written procedures or checklists.
." In addition, the special General Electric Company
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Installation and Service Engineering Quality Assurance Manual, Section 18.0, states that site audits will be performed using checklists, and the results of the audit will be distributed to designated personnel.
Contrary to these requirements, site audits were performed without the use of audit checklists.
In addition, the results of the audits were not distributed according to the procedure requirements.
(Paragraph 15.c(4))
Licensee Action on previously identified Enforcement Matters Not reviewed.
Unusual occurrences None Other Significant Findings A.
Current Findines Fuel sipping activities completed subsequent to the inspection showed 83 of the 484 fuel bundles to be leaking.
These will be replaced with new fuel during the current outage.
(Paragraph 4)
g)
B.
Unresolved Items 1.
Weld Rod Storage ovens - Calibration. Original manufacturer's calibration documentation for the weld material storage ovens was not available for review at the time of the inspection.
(Paragraph 15.e)
2.
Welder Qualification Records. A welder's qualification record had not been processed prior to indication on the welder's master record sheet that the welder was qualified to weld.
(Paragraph 15.f)
3.
Nondestructive Testing (NDT) Qualification Records.
The qualification record of one NDT examiner was found to be incomplete, in that his current qualification and eye test results were not included in the site records.
(Paragraph 15.g)
4.
In-Service Inspection Program.
The responsibilities and authority of quality assurance personnel monitoring the performance of the Monticello in-service inspection progran. had not been established in writing.
(Paragraph 14.a)
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Status of Previously Reported Unresolved Items
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The approval status has been determined for respiratory protective equipment used at the facility.
(Paragraph 11)
Mananement Interview Mr. Johnson conducted interviews with Messrs. Wachter (Vice President
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Power Production and System Operation) and Gilberts (Manager of Power Produc t ion) on March 27 concerning the establishnrnt of an operational quality assurance program for the Monticello Plant.
The inrpector stated that comment s related to weaknesses in the on-site program had been given to the plant staff.
lie also identified several areas of involvement in plant safety-related activites by offsite groups not governed by a quality assurance program.
Formulation of en operational quality assurance program for company activities not conducted by the plant staff was noted to be in progress. The inspector stated that this program could be expected to provide coverage of the areas identified but not in the near future, lie stated that these areas of activity should be addressed by interim measures to provide guidance until the company-wide program is implemented, by either directing offsite groups to conform.o plant procedures or by establishing separate directives as appropriate.
Messrs. Vachter and Gilberts stated that attention would be given to establishing meaningful direction in the areas identified.
(Paragraph 3)
Messrs. Johnson and llueter conducted an interview with Messrs. Larson (Plant Manager), Clarity (Superintendent - Plant Engineering and Radiation Protection), and Eliason (Radiation Protection Engineer) at the conclusion
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of the inspection. Other members of the plant s taf f also attended.
(Further discussion was conducted with Mr. Eliason on April 10 regarding respiratory protective equipment).
The following matters were discussed:
A.
The inspector summariced his comments related to review of the Administrative Control Manual.
Representatives stated that attention would be given to the areas identified.
(Paragraph 3)
G B.
The inspector stated that comment on restorative actions planned for the off-gas system recombiner would be deferred until after review of the licensee's report.
(Paragraph 6)
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C.
The inspector discussed the licensee's instruction of personnel and suggested that the licensee consider documenting the coverage during-instruction sessions of specific items set f or th in 10 CFR 19.12.
- (Paragraph 8)
D.
The inspector discussed the unresolved item noted during a previous inspection regarding the approval status of respiratory protection equipment in use at the facility.
The licensee was inforned that based upon review of his related actions the matter was considered to be resolved.
(Paragraph 11)
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I E.
The inspector stated that the inspection included a tour of tbs facility for observation of radiation protection practices and
coverage and that no problems had been noted.
Messrs. Sutton and Johnson conducted a management interview with Messrs.
Dienhart (Vice President - Engineering), Gilberts (Manager of Power Production), and Tice (General Manager - Plant Engineering and Construction)
at the conclusion of the inspection to discuss activites related to in-service inspection and the relief valve modification. Other NSP personnel and representatives of General Electric Company Installation and Service Engineering Department (GC 1&SE) and Bechtel Corporation also attended. Matters discussed were as follows:
A.
The inspector stated that apparent violations of the CE I&SE QA manual requirements were found during his review of records for the
" Safety / Relief Valve Addition" work.
lie added that this was also an apparent violation of the requirements of 10 CFR Part 50, Appendix B, Criterion V.
(Paragraph 15.c)
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B.
The inspector stated that violations of the NSP QA Program Summary and the special GE I&SE QA Manual, pertaining to audit requirements, were evident.
Documentary evidence that audit s had been conducted by NSP and its contractors in accordance with the QA program requirements was not available. The innpector added that this was an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVIII, requirements and would be brought to the attention of corporate management along (j
'with the matters discussed in paragraph A above in a letter summarir.ing the results of this inspection.
(Paragraphs 15.c and 15.d)
C.
With regard to the Monticello Plant valve body wall thickness measurement program, the inspector stated tFat the records reviewed were found to be in order, and this matter would be closed as a result of the inspection.
(Paragraph 16)
D.
The inspector stated that the duties and authority of NSP QA personnel monitoring the in-service inspection program were not established in writing. The inspector stated that except for this. deficiency, records for the conduct of the in-service inspection program were found to be in order. A licensee representative subsequently stated that written definition of the QA responsibilities and authority would be provided.
(Paragraph 14)
E.
Mr. Dienhart acknowledged the inspector's comments and stated that prompt attention would be given to the deficient areas identified.
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EEPORT DETAILS Part I Prepared by P. H. Johnson 1.
Persons Contacted Northern States Power General Offices L. Wachter, Vice President - Power Production & System Operation D. Gilberts, Manager of Power Production L. Mayer, Director of Nuclear Support Services C. Neils, General Superintendent, Nuclear Power Plant Operation T. McFadden, General Superintendent, Operational Quality Assurance J. Meier, -Quality Assurance Engineer Monticello Plant Staff C. Larson, Plant Manager M. Clarity, Superintendent - Plant Engineering & Radiation Protection W. Anderson, Superintendent
. Operation & Maintenance G. Jacobson, Plant Engineer, Technical F. Schober, Shif t Supervisor M.. Hammer, Engineer jg D. Wolfe, Quality Engineer 2.
Cencral The plant was in a cold shutdown condition for refueling and maintenance operations, in-service inspection, and installation of four additional Target Rock relief / safety valves and their associated dis-charge lines. The plant was expected to return to power in May.
3.
Quality Assurance Manuni The Monticello Administrative Control Manual was reviewed against the 18 Criteria of 10 CFR 50 Appendix B and discussed with licensee representa-tives during the inspection.
The manual consists of 53 Administrative Control Directives (ACD's), 49 of which were issued and effective at the I
time of the inspection. One additional directive which covers the handling, storage, shipping and preservation of material had been issued in draft form for trial use and comment pending completion of an analysis of man-power requirements and possible facility modifications to provide impicmentation. Although the quality assurance program includes other levels and types of implementing procedures and instructions, this review was limited to the scope and content of the ACD's.
Implementation of the program was not reviewed during this inspection, j
Review of the Administrative Control Manual against.the requirements of 10 CFR 50 Appendix B showed the program to provide coverage of quality-related activities under the cognizance of the plant staf f, with a few weaknesses noted in specific areas.
In general, however, plant-related-6-f
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activities performed by groups not under the authority of the plant manager are not required to conform to the methods outlined in the ACD's and in most cases no separate direction has been provided to assure that these activities satisfy the 1:quirements of Appendix B.
A tabulation of areas needing further definition os requirements, the applicable criteria of Appendix B, and indication of whether each coe. ment is applicable to the plant staff and/or offsite supporting groups is provided as follows:
Plant Offsite Criterion Item Description Staff _
Groups I
Authorities and duties of Plant Quality X
Engineer are not clearly established.
I Operating QA Program should be estab-X lished to govern activities of offsite
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groups (e.g., breaker mair.tenance crew, Engineering-Construction Department, contractors).
II Q-list is still to be promulgated.
X III No design control procedures (such as X
described in ACD's) govern related activities of offsite groups.
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IV Established procedures do not govern X
quality-related procurement activities of offsite groups.
VI Procedures for the issue and control of X
documents should be formaliced.
IX More specific instructions governing the X X
requirements, approval authority, and
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control of special processes (welding, nondestructive examination) should be provided.
IX Responsibilities for conduct and review X
X of the in-service inspection program are not established.
XIII Handling, storage, and shipping procc-X X
l dures are still being developed (f acility
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improvements needed).
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Plant Offsite (~
_ Criterion Item Description Staff Groups
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XV Procedures governing control of non-X conforming materials by offsite groups should be established.
XVII More specific re,uirements for inclusion X
of personnel qualifications in QA records should be provided.
XVII Procedures shuuld require identification X
in QA records of inspectors or data takers, observations and results, actions tahcn, etc, XVII Coverage for original plant construction X
QA records should be included in records management procedures.
Facility representatives stated that some earlier ACD's were being reviewed for possible revision to make them consistent with re finements which had been incorporated into more recent ACD's, and that additional coverage would be provided in the areas identified.
Quality Assurance coverage for in-plant activities by of fsite groups was discussed with representatives of the NSP Power Production Department during the inspection. A representative presented the outline of an
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administrative controls manual which would provide coverage to NSP groups
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other than the plant staff.
The program was still in a formulative stage, and representatives.<tated that the groups or departments to be covered by the program (or programs) had not yet been firmly established.
The representatives indicated that this manual could not be expected to give effec tive guidance in the near future to all offsite groups involved in safety-related plant activities.
This c,atter was discusstJ further during management interviews with the Vice President - Power Production and System Operation and the Manager of Power Production.
During the inspection the inspector also obtained a copy of an administrative guide titled " Independent Audit of Nuclear Plant Operations," which was issued in response to the requirements of Criterion KVIII of Appendix B.
The inspector commented to the licensee subsequent to the inspection that the guide should Le more specific in its discussion of identification, review, and reporting to the AEC of violations noted during the conduct of audits. The licensee stated that the comment would be incorporated.
into a pending revision.
4.
Refueling Activities Refueling activities in progress during the inspection were reviewed without comment. Areas reviewed included the following:
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a.
Observation of activities on the refueling floor, including fuel
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transfers, sipping operations, adherence to procedures, communications, and accountability procedures, b.
Establishment of prerequisites for fuct handling operations:
reactor mode switch locked in refuel position, and required source range monitors operable.
c.
Performance of initial and periodic surveillance test required by the Technical Specifications for refueling interlocks, source range monitors, and intermediate range monitors.
Out-of-core sipping operations were in progress during the inspection.
In-core sipping of the entire core prior to the inspection had identified 56 Icaking fuel bundlec. A licensee representative stated during a sub-sequent telephone conversation that out-o'f-core sipping of all but 80 peripheral bundles had identified an additional 27 leaking fuel elements.
As stated in previous correspondence 3/, plans call for insertion of 116 8 x 8 fuel bundles and 7 reconstituted 7 x 7 fuel bundles during the current refueling outage.
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5.
Electrical Maintenance Procedures 2/ discussed the need for control A previous abnormal occurrence report of electrical rnaintenance performed by of fsite groups and stated that additional administrative control procedures for electrical maintenance of safety equipaent would be developed prior to the 1974 refueling
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outage. The inspectur discussed the matter with a licensee representative and examined examples of the documents which have been issued. Main-tenance activities were being accomplished in accordance with written procedures prepared by the Maintenance and Teat Group and approved by a cognizant engineer on the plant staff. A separate Operations Control Document (OCD) for each related procedure was being used to establish '
system requirements, identify applicable Technical Spec ifications requirements, accomplish isolation of the equipment and its restoration to service, and specify required post-maintenance testing. A space was provided for shift supervisor approval for work to proceed after pre-requisite are accomplished. OCD's are reviewed by the Operations Committee prior to issue.
The representative stated that the new procedures were providing effective control of electrien1 maintenance activities.
1/ Letters, NSP to Directorate of Licensing, dated 11/1973 and 2/8/74 2/ Letter, NSP to Directorate of Licensing, dated 4/10/73.
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6, Of f-gas System Licensee representatives stated the status of the off-gas system testprogramtobeessentiallyasdescribedinthepreviousinspection report. _/ The licensee's plans called for a retreatment of the recombiner vessel which will include an in-place anncaling process at 1225 F followed by a hydrostatic test at the original test pressure.
Plans also called for modification of the heater controls to provide complete independence of the heater cutout function from the normal heater control.
The inspector obtained a copy of the licensee's report (which provides an analysis of the overheating incident and describes the planned corrective actions to restore the recombiner to a suitable condition) and stated that he vauld defer comment on the licencee's plans until after review of the report.
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3/ RO Inspection Rpt. No. 050-263/73-02.
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REPORT DETAILS Part II f /d W
Prepared by (
1MJ,Hueter Date U,11 f/ //7 Reviewed by
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W. L. Fisher 7.
Persons Cont ac ted C. Larson, Plant Manager Plant Engineering and Radiation Protection M. Clarity, Superintendent
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L. Eliason, Radiation Protection Engineer F. Fey, Assistant Radiation Protection Engineer P. Yurcr.yk,llealth Phy:les Technician G. Mathiason, llealth Physics Technician 8.
10 CFR 19 The applicabic documents specified in Part 19.11 were either posted as required or instructions posted as to location where the documents could be inspected.
The bulletin boards at the raain entrance and on the third level of the Administration Building are used for postJng.
Instructions required by Part 19.12 are provided to personnel.
In general, the
d licensee does not document the coverage given during instruction sessions of the specific items set forth in Part 19.12.
9.
IJhole llody Countinn The li asce continues to contract the performance of annual whole body ct. ants at the end of the spring refueling outage.
In 1973, 177 individual whole body counts were performed including 10 General Electric employees. The largest burdens reported, all well below permissible limits, were as follows:
Cesium 137 52 nanocuries (nC1)
Iodine 131 10 nCi Zirconium-Niobium 95 38 nCi Zinc 65 274 nCi Cobalt 60 56 nci Cobalt 58 70 nCi The contractor has generally concluded that very little radioactivity of plant origin has been detected in those counted.
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10. Exposure Reports The annual personnel exposure and monitoring report for 1973 was reviewed and found to be in agreement with film badge vendor supplied data and in accordance with the requirements of 10 CFR 20.407.
There were no personnel
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Records showed that reports of personnel exposure on termination of employment or work were sent to the commission and the individual in accordance with 10 CFR 20.408 and 20.409.
11. Respiratory Protective Equipment The inspector had previously questioned whether respiratory protective enuipment in use had been approved by the Bureau of Mines (BOM)
or h.tional Institute for Occupational Safety and llealth (N10Sil) or h d
been shown to be equivalent to or better than approved equipment.h'
It has been determined that the only item of respiratory protective equipment in use by the licencec that does not nie e t the criteria stated above involves the sorbent (charcoal) contained in a canister used in atmospheres containing some radiciotline. No approvals have been granted by BOM or NIOSil for use of sorbents for this purpnae.
The licensee has not used these devices under circumstances where measured air concentrations of radiciodine in conjunction with length of exposure time would require application of a protection factor.
In telephone conversation with the licensee on April 10, 1974, it was pointed out that in Section E.1.5 of their Operations Manual, they have authorized a protection factor of 10 when the referenced canister containing the sorbent is used in an atmosphere containing radiciodine.
The licensee stated that the procedure would be changed so that no protection factor would be granted for use of the sorbent, in conformity with BOM and NIOSl! standards and the licensee's actual practice to date.
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12. Conditions __and Health Phvsica Coverate nuring Current Outane a.
A tour of the facility provided observation of the licensec's implementation of security measures, access control, airborne and particulate contamination control, personnel exposure control, and usage of Radiation Work Permits. No problems were noted.
b.
The services of several General Electric health physicists have been contracted and three health physicists from another NSP nuclear plant have been temporarily assigned during the outage to assist this facility in radiation protection coverage. Assigned responsibility is in a small area of the facility for the temporarily assigned personnel, The highest radiation levels in work areas during the outage have c.
been in the heat exchanger rooms and the drywell area where 1cvels have ranged up to about 5 roentgens per hour. Air sample records showed presence of iodine 131 in the reactor building for a few days early in the outage. The highest concentrations of iodine 131 measured were 3 x 10-8 microcuries per milliliter (3.3 times the maximum permissible concentration (MPC) based on a 40-hour week exposure). Most measured levels in the work areas of the building averaged 2-5 x 10-9 microcuries per milliliter for iodine 131 during the 3-day period of highest iodine activity.
4/ RO Inspection Report No. 050-263/73-02.
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Althoup,h respiratory equipment was used when iodine 131 concentration reached one third of MPC, the licensee, by close surveillance of iodine concentrations and limitations of hours of exposure in a given week, could demonstrate that overexposure would not have occurred even without use of respiratory equipment.
d.
For the first quarter of 1974, the highest individual exposure was slightly over une rem.
Four others were approaching 1 rem.
Special daily records are raaintained for any individual whose exposure is approaching an administrative limit. All personnel are required to have a respirator equipment face fitting test using amyl acetate before being permit ted to t.se the equipment. Records maintained of the fitting results are ut!.lized to prevent authorizing individuals into areas where respiratory equipment wit h which they cannot be fitted may be needed.
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REPORT DETAILS CT'
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Part III Prepared by
. Le
.f_{0 3'-3'7Y Qi.W.'Sutten (Date)
Reviewed by
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rya 5"- I 7 V D. W. Hayes,/ Senior (Date)
Reactor Inspector 13. Persons Contacted Nocthern States Power company (NSP)
A. Dienhart, Vice President - Engineering D. Gilberts, Manager of Power Production C. Tice, General Manager - Plant Engineering and Construction G. Neils, General Superintendent - Nuclear Power Plant Operation J. Swedberg, Project Managcr - Site C. Harmsen, Supervising Quality Assurance Engineer P. Krumpos, Quality Assurance Engineer - Power Production Department J. Meir, Quality Assurance Engineer - Construction Department O. Iverson, Field Engineer - Construction Hartford Steam Boiler Inspection a Insurance Conp_any (HSB)
'J D. Votier, Supervising Inspector Nuclear Services Corporation 0;SC)
T. Lambert, Manager - Nondestructive Evaluation Services V. Lovelace, Nondestructive Evaluation Technician M. Teskey, Nondestructive Evaluaticn Technician General Electric Company (GE) Installation and Service EngineciInc bepartment (16SE)
R. Wills, ILSE Supervisor - Minneapolis, Minnesota W. Kozik, Nuclear Quality Assurance Specialist - Headquarters C. H. Scot t, Proj ect Manager - Site W. Lowe, Quality Control Supervisor - Site E. Taillet, Welding Supervisor - Site Bechtel Corporation C. Hogg, Engineer - San Francisco Home Of fice 14. In-service Inspection a.
Quality Assurance Program.
During t he inspcetor's review of the NSP QA Engineer's activities in monitoring the in-service inspection program, it was noted that a directive defining his responsibilities
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and authority was not evident.
During the previous in-service inspection 5/ the Monticello Operational Quality Assurance Program had been reported to be in draft form.
During the current inspection the manual was noted to have been issued, although in-service inspection was not included, since it was stated not to be a responsibility of the plant staf f.(also see paragraph 3).
The inspector reviewed an unsigned, unapproved draft copy of a QA procedure for the in-service inspection. The draft was in the possession of the NSP QA engineer monitoring the in-service inspection. This mat ter was further discussed during the exit interview.
b.
Hapection Procram - In-rervice Inspection.
The inspection of Lne ir,-s e rv ic e inspection progran included a review and examination of all applicable QA/QC provisions, nondestructive test procedures, and Technical Specifications requirements. The examinations were being performed pursuant to the requirements of AStE Section XI,
" Rules for In-service Inspection of Nuclear Reactor Coolant Systems", 1973 Summer Addenda.
NSP had defined the scope of their conmitment to ASSE Sec t ion XI in the "Monticello Technical Specifications", Table 4.6.1, Revision 0-9-8-70.
The nondestructive examination procedures and scope of inspection for the Monticello in-service inspection program were submitted to the Monticello plant manager for review and approval on March 15, 1974. The program was submitted prior to the start of examination.
The examinations were conducted under the direction cf the Power Production Department quality assurance engineer, who holds a j
Level III ASNTC certification. Tests and examinations were per-formed by NSC personnel, under the direction of an NSC senior consultant f or N DE.
The arsigned code inspectors reviewed each procedure, witnessed each tect, ard signed the data sheets. A Hartford Insurance code inspector had previously reviewed and concurred with the various procedures.
c.
Review of the Mnnricello Technical Specification Requirements Table 4.6.1.
The portion of the required ten-year examination the progrcm, accomplished during this reactor outage appears to meet intent of the requirements of Section XI, subject to the restrictions of component accessibility.
The inspector was informed that a revised in-service inspection pro; ram is to be prepared to meet the latest revision of ASME Section XI requirements. A change to the Monticello technical specification is to coincide with this revision.
d.
Examination Techniques and Procedures. All nondestructive test procedures were provided by NSC. The following procedures were reviewed:
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_s (1) SPl-C-II, Revision 0, Organirstion Chart and Operational Procedures (2) NVT-NC-1, Revision 3. Direct Visual Examination Procedure (3) NUT-NC-1A, Revision 3, Ultrasonic Inspection of Welds (4) NUT-NC-1B, Revision 2, L-Wave Ultrasonic Inspection of Forgings, Studs, and Nuts
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(5) NUT-NC-lC, Revision 2, Ultrasonic Examination of Inner Radius of Pressure Vessel Nozzles (6) NUT-NC-3, Revision 2, Procedure for Automatic Recording of Ultrasonic Test Data (7) NOT-NC-lD, Revision 1. CRD llousing Stub Tube Veld Inspection (8) NUT-NC-lE, Revision 3, Calibration Procedure
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(9) NUT-NC-7, Revision 0, Ultrasonic Examination of RPV Butt and Nozzle Ucids (10) NPT-NC-1, Revision 1, Nuclear Penetrant Testing Procedure e.
Qualification of Nondestructive Examination Personnel. Revies: of the test vendor's personnel qualification documentation indiented conformance to the requirements of SNT-TC-1A, its supplements, and appendices as applicabic for the examination tect.nique vad methods used.
Full resumes, written tests and results, employment and experience' history, were available for each member of the crew.
Additionally, the status, criteria, and results of vision examinations were available. All documents had been reviewed 'oy NSP QA and the assigned code inspector.
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f.- Basic Calibration Status of Instruments.
The electronic equipment
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and the search transducers calibration records were reviewed and found to be in order.
g, Material Certifications. Material' cr.rtification for all liquid penetrant materials, couplant, and the UT calibration reference block was reviewed and found to be in order, h.
Test Records.
The inspector reviewed reports of test results and found that requirements of ASME Section X1 regarding documentation of the examinations had been met.
Each data sheet was signed by the vendor's representative, r.he assigned code inspector, and NSF QA.
Data acquisition was taken manually and by automatic analog printer, as appropriate for the examination method.
15. Safety /Helief valve Addi tion a.
Gene *al.
A report to the Directorate of Licensing from NSP, dated January 23, 1974, titled " Permanent Plant Changes to Accommodate l
Equilibrium Core Scram Reactivity Characteristics for the Monticello Nuclear Generating Plant" was reviewed by the inspector to determine l
the QA/QC activities to be conducted during the installation of the four adtitional Safety / relief valves and the associated prompt relief i-36-l
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trip system.
The entire program had been reviewed by the Plant Operations and Safety Audit Committees and had been appreved prior to the start of work.
The NSP Construction Department has been assigned the overall responsibility for the QA conduct of the entire project.
NSP prepared a "QA Program Summary", plus the special GE I&SE QA manual and applicable requirements from the Bechtel QA manual to delegate QA/QC responsibilities to the two major subcontractors, CE and Bechtel. The QA program is based on the quality assurance requirement.s for Class 3 components of Article NA-4000 of the AstE Code Section 111, 1971 edition, with 1973 Summer Addenda.
CE I&SE is responsible for installation and field fabrication for the enLire project.
In addition, CE 1&SE is responsible for the coordination of the QA interfaces between NSP, Bechtel, and GE 16SE.
Bechtel was assigned the responsibility for design reinted to the project and the procurtment of certain portions of the materials.
Each of the organizations is responsible for implementing the requirements of the "QA Program Summary" in the areas of their responsibility.
The USP manager of QA was delegated the overall responsibility for the QA program. The entire program was approved and signed by NSP, GE, and Bechtcl.
b.
Special GE i&SE Quality Assurance Manual. The GE I&SE QA manual was reviewed by the inspector and was found to have the necessary sections and procedures to conform to the requirements of Article NA-4000 of the ASME Code,Section III, 1971 edition, with 1973 Summer Addenda, gy; c.
impicmen'ation of the GE ILSE QA Manual (1) Section 9.0 - Procurement control - Purchase orders.
The GE I&SE QA manual requires, in Section 9.2.3, that the site QC manager be assured that each purchase order has been approved by the nuclear QA specialist prior to release.
The RO inspector reviewed purchase orders issued for weld rod material that had not been given prior approval. Approval authority has not been provided for onsite personnel.
All purchase orders are to be approved at the CE I&SE headquarters in Illinois.
(2) Section 9.0 - Procurement control - Material Receivinn.
The CC I(SE QA manual, Sec tion 9.5, requires the site to have on hand all specifications and drawings necessary to determine that
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material received has met all requirements.
The inspector reviewed the receiving records for the nozzle penetrations for the containment vessel and found that the penetrations had been
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reviewed and sigt.ed off by the site QC manager, without the required receiving records.
The package reviewed during the current inspection did not contain the necessary records required for receiving the components.
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(3) Section 17.0 - Nonconformities. The GE I6SE QA manual states, in Section 17.0 that nonconforming material, when received
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onsite, is to be yellow tagged and segregated.+ In addition, a nonconformance report to be issued covering the discrepancy.
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Contrary to this, the in%..ctor noted that three heats of weld rod r.aterial had been received onsite and yellow tagged as nonconforming, but no nouco,nformance reports had been issued by the site QC personnel.
In addition, part of the material had been segregated, but the contents of one can, which had been opened, was found stored in a holding oven containing conforming material.
(4),S e c,t i on 19.0 - Audi t s.
The GE 1&SE QA manual, Section 18.2.4, requires that audits perfortaed onsite be made using checklists, and Section 18.2.5 states that the results of the audits are to be distributed to GE 1&SE headquarters and site QC and project managers.
Two audits had been perforned by the QA specialist prior to the current inspection.
An audit was being conducted by the CE QA specialist during the current inspection. The current audit was being conducted without the use of a audit checklist. The records of the fomer audits were reviewed by the inspector, and it was noted that copies of the audit had not been distributed as required by the GE I&SE QA manual procedure.
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d.
NSP QA Program Summary - Audits. The NSP QA Program Summary, Section 0.2.2(4) states that NSP is responsibic for auditing, or arranging for the auditing of, the implerentation of the QA Progrem Summary.
Sectinn 0. 2. 3(18) states that Dechtel is responsible for auditing the implementation of the Bechtel QA program f or the projec t.
During the current inspection, evidence was not available that would indicate that NSP had performed, or planned to perform, a
QA audit of Bechtel's QA activitice on or of fsite.
In addition, documentary evidence was not available that Bechtel had conducted an internal audit of the project activities, as required by the Bechtel QA Manual, Section 6.0.
NSP QA personnel had conducted a
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QA audit of GE I&SE site activities on March 21, 1974, and were presently conducting an additional audit of CE's site activities.
Audit checklists were used for these audits, c.
Wid P,od S torare ovens - Calibration.
During the inspection of the weld material storage area, the inspector requested documentation that would indicate the rod ovens had been properly calibrated.
The inspector uns infomed that the ovens were new and had been checked cntite with a thermometer. The inspector was informed that the manufacturer had calibration records for the ovens. The
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manufacturer's calibration records were not available but are to be made available to the RO inspector during a followup inspection.
f.
Wolders' Ou'lification Records.
During the review of CE I&SE Welders' Qualification Records, it was noted that the master log indicated that a welder was qualified to weld to a certain pro-cedure. The welder's records were requested, and the inspector was informed that the welder had taken his qualification test but that his papers had not been prepared, due to clerical problems.
The inepector was inforced that the welder in question had not welded on the p'.oject, as of the curceat inspection, and that the recorJs would be prepared as soon as clerical help was available.
This matter will be reviewed during a subsequent inspection.
g.
Nondentructive Testine Q.qlification Records _.
X-Ray Engineering Company has been contracted by CE 16SE to conduct NDE for the project. The records reviewed indicated that the inspection personnel were qualified to SNT-TC-1A requirements, except for the records of one examiner. The icvel of qualification and eye test data were not current for the examincr. The inspector was informed that the examinct was also working at a nearby site and that he had,
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in his possession, his current records.
The records are to be sent to the Monticello site for inclusion in his file.
This matter will be reviewed during a subsequent inspection.
16. Valve Wall Thickness Verification Program E/
a.
General.
NSP informed RO:III by a letter dated March 12, 1974, that the valve wall thithness verification program for the
!!onticello Nuclear Generating Plant had been completed in l
accordance with the criteria established by the RO:III letter I
of June 29, 1972.
The records of t he evaluation and inspec tion (
data for this program were reviewed by the inspector. An NSP letter to K0:III, dated Novemb:r 3, 1972, stated that the innpection program would include approximately 72 valves.
The scope of the I
program, as indicated in an NSP letter, dated March 12, 1974, indicated that the inspection scope had been increased to 98 valves.
The wall thicknesses of all 98 valves were found to satisfy th'ir service requirements.
There were two valves whose measured minimum wall thickness did not meet design values.
However, these wall thicknesses were determined to be adequate in that actual tensile and yield strengths of the valve body material exceeded the minimum j
specified by the ASTM Standard.
S/ RO Inspection Report No. 050-263/73-04, Paragraph 20.
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Inspection Criteria and Resultn. A total of 98 valves were identified by NSP that required measurements to verify that valve wall thickness requirements had been met.
A listing of all valves to be examined was prepared in cabular form by NSP. The listing identified the valves by valve internal diameter, piping and instrument drawings, type, material, size, manufacturer, code, and minimum wall thickness (required vs. ac tual). NSC was contracted by NSP to perform all valve wall thici tess measurements.
NSC Procedure No. NUT-NC-2, " Nuclear Components Valve Thickness",
had been reviewed and approved by NSP.
The qualification records of NSC NIE personnel and certification records for t.be measuring, devices were reviewed and found to be in order. A grid pattern for valve measurements was prepared b'f USC and reviewed and approved by NSP QA.
Documentation photographs and detailed drawings of each valve were prepared and made part of the procram package.
All readings were given to !!SI' QA personne t for evaluation against GE specifications. m asurements for valvec that were found to be below minimum wall thickucss requiren.ents were also submit ted to CE for their evaluation.
GC indicated there valves that could be acceptod per codes or standards. Two vcives were found to fall in this category. Valve Nos. LL-1122 and LL-1128 were accepted "as is",
as indicated in a CE letter to NSP, dated November 14, 1973.
The letter indicated that the valves met MSS-SP-66 requirements, because the tensile st rent th of the valve body r..aterial exceeds the spect-fication ninimum by an amount sufficient to ccepensat e f or the measured reduction la wall thickness.
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The results of the valve wall thickness vertfication program had been reviewed by the Plant Operat i ons Cocai t tee.
Acceptance of the two valves, found to have volve wall thickness under code specification, was discussed during meetings of October 9 and December 12, 1973, and re solved a t the March 8, 1974, meeting.
The results have been doctenenteJ in minut es of the Operc tions cowait tee meeting.
The completed measurements and supplementary documentation for all valves were examined and found to be in order.
The licensee's valve wall thickness verification program is considered to have been successfully completed.
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UNITED STATES
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l ATOMIC CNCRGY COMMISSION
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t,'*'%.
OIRECTOft ATE OF REGULATORY OPERATIONS g'
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REOlON lil 8EC'
799 ROCSEVELT ROAO g w,,mg OLCN ELLYN. ILLINOIS 6o137 01.t;sts.3660
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A.
RO Inspection Report No..050-263/74-03 i
Transmittal Date
- __May 14. 1974 Distribution:
Distribution:
PO Chief, FS&EB R0 Chief, TS&EB RO:3Q (,4)
RO HQ (4)
DR Central Files L:D/D for Fuels & Materials Regulatory Standards (3)
DR Central Files Licensing (13)
RO Inquiry Report No.
Transmittal Date
Distribution:
Distribution:
R0 Chief FS&EB RO Chief, FS&EB
'.'0 HQ (5)
RO:HQ
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SR Central Files DR Central Files Regelatory Standards (3)
RO Files Licensing (13)
RO Files C.
Incident Notification From (Licensee & Docket No. (or License No.)
Transmittal Date
Distribution:
Distribution:
R0 Chief FS&EB RO Chief, FS&EB RO:5Q (4)
RO:HQ (4)
Licensind (4)
L:D/D for Fuels & Materials DR Central Files DR Central Files RO Files RO Files
.