IR 05000269/1971010
| ML19322A689 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/15/1972 |
| From: | Moseley N, Murphy C, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322A679 | List: |
| References | |
| 50-269-71-10, NUDOCS 7911210734 | |
| Download: ML19322A689 (15) | |
Text
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AT LANT A, GEORGI A 30303 TESTING AND STARTUP INSPECTION REPORT C0 Report No. 50-269/71-10 Duke Power Company Oconee 1 Docket No. 50-269 License No. CPPR-33 Category A3/B1 Seneca, South Carolina Type of Licensee: PWR-2452 MW(t), B&W Type of Inspection: Routine, Announced Dates of Inspection: November 9-11, 1971 Dates of Previous Inspection: October 5-8, 1971 November 3,1971 //1 b Principal Inspector: C. E. Rurfhy,[ Reactor Inspector bate' (TesLing and Startup) /h[d) M' 2-N-n Accompanying Inspectors : R. F. Warnick, Reactor Inspector Date (Testing and Startup) / h/s5Y72-- ' /s - . N. C. Moseley, Senior g etor Inspector date' (Testing and StartupV Other Accompanying Persennel: None 2[[/72-Reviewed By: e
N. C. Moseley, Senior Reactorgnspector 6a't e ' (Testing and Startup) Proprietary Information: None l l _ 791121073'I
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CO Report No. 50-269/71-10-2-SECTION I Enforcement Action A.
Noncompliance Items 1.
Criterion XI of Appendix B to 10 CFR 50-Failure to demonstrate that components systems and structures will perform satisfactorily in service.
(Section II, Paragraph 2) 2.
Criterion XVI of Appendix B to 10 CFR 50-Failure to identify conditions adverse to quality and to take corrective actio. n (Section II, Paragraph 2) B.
Nonconformance Items - None C.
Safety Itens - None j Licensee Action on Previously Identified Enforcement Matters 1.
Arc strikes on safety feature and safety-related piping. Action completed.
(Section II, Paragraph 1) 2.
Discrepancies in waste disposal systecs. Action completed.
(Section II, Paragraph 1) 3.
Corrective action has not been completed on iters identified in C0 Report Nos. 50-269/71-7, 71-8, and 71-9.
Unresolved Items 1.
Flowmeter error analyses and tests.
(Section II, Paragraph 4) 2.
Verification of loop backflow analysis.
(Section II, Paragraph 4) Status of Previously Reoorted Unresolved Items (See Section II, Paragraph 1, for discussion.)
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~ .. ~. -.. - . . e . _ . i 00 Report No. 50-269/71-10-3-1.
Penetration room flow indication and adjustment.
Resolved.
2.
Damage to safety feature switchgear bus.
Resolved.
3.
Spent fuel pool lamps operating depth. Resolved.
4.
Tape on safety feature system pipe.
Resolved.
Unusual Occurrences - None . Persons Contacted J. E. Smith, Plant Superintendent J. W. Hampton, Assistant Superintendent L. E. Summerlin, Staf f Engineer J. C. Roger, Project Manager D. G. Beam, Assistant Project Engineer D. L. Freeze, Principal Field Engineer R. E. Miller, Mechanical Design Engineer J. L. L. Ostertag, Mechanical QC Engineer A. Kuck, Electrical Design Engineer K. S. Canady, Steam Production Department C. J. Wyle, Principal Electrical Engineer K. W. Schmidt, Electrical QC Engineer P. H. Barton, Manager, Technical and Nuclear Services Management Interview l.
The inspector advised Smith that he had reviewed Test Procedures ' TP-270-6-3, TP-200-23-1, TP-204-5-2, TP-270-6-B-0, TP-204-5-2, and TP-204-4-1 and noted deficiencies in them.
(Details of the deficiencies were discussed by telecon on November 12, 1971.)
(Section II, Paragraph 2) 2.
Moseley stated that his review of Test Procedures TP-202-5-2 and TP-203-6 indicated that the acceptance criteria in these procedures did not agree with limits stated in the FSAR.
(Section II, Paragraph 2) , 3.
Moseley stated that his review of the prerequisite tests to the containment leak rate tests indicated that the leak rate test was inadequate to demonstrate that the leak rate was within acceptable-limits.
(Section II, Paragraph 2) _
_ . s . , , CO Report No. 50-269/71-10-4-4.
Murphy reviewed the discussion held with Wylie and other members of the staf f relating to the cable tray overfill. Kuck concurred that Duke in their answer to the enforcement ' correspondence will arrive at a proposed resolution of the problem. (Section II, Paragraph 3) 5.
Murphy stated that the documentation of the vendor tests of the reactor coolant flow-sensing element did not appear sufficient to , demonstrate the accuracy of the calibration. Because the accuracy of flow measurements would affect heat balance calculations and safety system operation, the inspector stated that he wanted to review an error analysis on the element. Since the licensee proposes to use a single calibration test for all units, the inspector will also want to review the plant test data that indicates that the flow-sensing elements' outputs are essentially equal at rated flow.
(Section II, Paragraph 4) 6.
The inspector reviewed the discussions held with Miller and Ostertag. In response to their questions, the inspector advised them that his present instructions would not permit him to accept anything less than complete traceability for those components whose failure could lead to an uncontrolled release of radioactivity or whose fcilure would cause the makeup capability of the safety feature systems to be exceeded. Miller stated that the inspector's position , would be relayed to Duke management.
(Section II, Paragraph 5) ' ' 7.
The inspector advised Smith, Rogers, and Beam that it appeared that many of the deficiencies that had been identified could be attributed, at leas t in part, to the failure of communications within the Duke organization. In particular, the inspector saw a need for improvement upward and within the organization. Although they expressed the feeling that this was being accomplished, all three agreed to see what could be done to improve communications.
8.
Murphy stated that it was his understanding that Duke design would review the layout of the reactor coolant flow sensing lines to assure that the FSAR commitments were being met.
Miller agreed that this would be done.
9.
Freeze advised the inspector that the welding procedures would be revised within four weeks.1/ i 1/ 00 Report No. 50-269/71-9 . - - -
. . . ' . CO Report No. 50-269/71-10-5-10.
Freeze stated that the Oconee engineers.had received copies of Appendix B to 10 CFR 50 prior to the inspector's previous visit even though individual engineers had professed ignorance of the requirements of the appendix to the inspector.1/ Freeze showed the inspector a list of the individuals and the dates that they had been given copies of the document.
The inspector advised Freeze that he should assure himself that the engineers were familiar with the contents of Appendix B.
It does little good for them to have received copies without making themselves aware of the contents.
11. Warnick discussed the following items : a.
Loss of Instrument Air Test Duke was not planning to conduct a preoperational test to determine the effects of the loss of instrument air. Smith and Hampton agreed to consider this. The inspector stressed the importance of this test and stated that he would pursue the matter further should Duke elect not to run such a test.
(Section III, Paragraph 3) b.
Control Rod Drive Drop Time Test The inspector indicated the procedure for the control rod drive drop time test appeared to be inadequate. The procedure specifies an insufficient number of rod drops.
In addition, the section entitled " General Description" does not follow the style and language of the other procedures reviewed. Smith and Hampton agreed to review this procedure.
(Section III, Paragraph 4) c.
Low Pressure Injection Svstem Functional Test Test Procedure TP-1A-203-5, Revision 4, does not fulfill the commitments specified in the abstract of the test on page 13-22 of the FSAR.
Hampton indicated the procedure was being revised.
(Section III, Paragraph 5) , 1/ CO Report No. 50-269/71-9 . ,
. _ - - .-. - -. -. . . , . W Report No. 50-269/71-10-6-12.
FSAR Testing Requirements for Preoperational Test Procedures - On November 17, 1971, in a telephone conversation with Murphy, Smith indicated Duke would review the FSAR for preoperational testing requirements to ensure that all testing requirements are fulfilled by the tese procedures.
(Section III, Paragraph 6) i . ! . I t i
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.' ' . - 00 Report No. 50-269/71-10-7-SECTION II Prepared By: C. E. Murphy Reactor Inspector ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND 1.
Previousiv Identified Unresolved Items The inspector reviewed the outstanding items list maintained by CO:II with Freeze, Smith, and Canady.
a.
A procedure for the detection and repair of are strikes on safety feature piping and components has been written which, if followed, should result in the removal of these defects. The inspector plans no further action on this item at this time.
b.
Revision 11 to the FSAR included revisions to the waste disposal system drawings. A spot check by the inspector indicated that the actual installation now corresponds to the details shown on the FSAR drawings. No further action is planned on this item at this time, c.
Canady advised the inspector that the penetration room ventilating system had been modified to conform to DRL requirements.
(S chwencer, DRL, at a meeting on November 30, 1971, confirmed this statement.) The inspector plans no further action on this item.
d.
Freeze advised the inspector that repairs and testing of the safety feature switchgear had been completed. The inspector plans no further action on this item at this time, e.
Wylie advised the inspector that the manuf acture's limitation on the operating depth of the spent fuel pool lamps was based on tests performed to obtain Underwriters' approval for use of the lamps in swimming pools. Tests conducted by Duke indicated that the lamps could be operated at depth of forty feet without failure. The inspector plans no further action on this item at this tim.- __ __.
~ .- 00 Report No. 50-269/71-10-8- , DETAILS OF SUBJECTS DISCUSSED IN SECTION I 2.
Test Program a.
Review of Preoperational Tests and Test Results (1). TP-200-23-1 - Exterior Stainless Steel Pipe and/or Component Cleaning A review of this procedure indicated that it did not include a method for insuring that areas would be reeleaned if the initial cleaning did not achieve acceptable results. Smith agreed to revise the procedure to eliminate this weakness.
(2).
TP-204-4-1-RB Spray System Functional Tests The following deficiencies were noted in the data obtained during this test: (a) The test was accomplished on September 2-17, 1971.
The acceptance criteria specified in the test procedure were revised on October 4,1971, to match the test data. Acceptance criteria should be as required by the FSAR. The procedure specified a minimum flow rate of 900 3pm for each pump. Cection 6.2.3 of the FSAR specifies a flow rate of 3000 gpm for two pumps.
(b) The bearing housing of pump B reached the operating limit of 160*F specified in the test procedure and the test was aborted.
A deficiency worksheet was not completed as required by administrative procedures and corrective action was not recorded.
(c) Test procedure specified run in time of four hours.
Data indicates that test was terminated after two hours.
(3).
TP-204-5-2 - Reactor Building ES System Spray Test i The acceptance criteria in the test procedure do not include the FSAR requirements relating to valve operating times and system flow. The procedure referenced the manufacturer's data. However, measured pump performance in every case was less than indicated by the pump manufacturer's curves. Test indicates that opening times -
.. . _.. __ - -. .. . . , C0 Report No. 50-269/71-10-9-of LP-21 and LP-22 were 12.0 and 12.6 seconds, respectively, which does not meet the requirements of the FSAR. Section 6.1.3.2 of the FSAR requires that the valves operate in ten seconds.
(4). TP-270-6-3 - Steam Generator Secondary Side Cleaning (a) A review of the procedure indicated that the method of flushing and the flush times involved would be inadequate to demonstrate that the steam generator is clean. Less than five volumes of water yps introduced into the steam generator. The intake and discharge points, were such that the tie sheets would be in a stagnant region. The flow of 4000 gpm is extremely small as compared to operating flow.
(b) The procedure specified a maximum flow of 4000 gpm as a precaution. Actual flow used was 4200 gpm.
(c) Valve FDW-35 leaked past the seat. No deficiency notation was recorded in the test records.
(5).
TP-270-6-B-0 - Main and Startup FDW Header Flush (a) The test log indicated that difficulty was experienced i in the operation of various motor-operated valves. The data did not indicate the resolution of this difficulty.
(b) Because of problers experienced with temporary test lines, the flow was reduced so as not to exceed the pressure limits of the test lines. The final docu=entation did not indicate the actual flow rates us ed.
i (c) Although this test preceded the SG flush (TP-270-6-3),the data included with the SG flush indicated that particulate matter war l found in the FW nozzles. j (6).
IP-202-5-2 - HP Injection System Flush
_ _..___ k . i CO Report L;. 50-269/71-10-10-The procedure referenced manufacturer's data for permissible valve operating times. The FSAR, Section 6.1.3.1, requires that the valve operating times not exceed ten seconds which is less than that given in the manufacturer's data. The following valves did not meet the ten-second requirement: Valve No.
Opening Time ( 0.6 see) _Run 1 Run 2 HP 3 28.2 27.6 HP 4 29.4 28.6 HP 20 27.0 26.6 HP 24 10.2 10.2 HP 25 10.0 10.0 HP 26 9.6 9.6 HP 27 10.8 10.8 The test data did not include a deviation sheet.
(7). TP-203-6-2 - LP Injection ES Test The test procedure referenced manufacturer's data for valve operating ' times and not the FSAR. The FSAR Section 6.1.3.2, states that the time should be ten seconds. The following valves did not meet this requirement.
Valve No.
Opening Time ( 0.6 see) Run 1 Run 2 LP 17 10.4 LP 18 10.8 10.6 LP 21 11.8 12.6 LP 22 12.6 12.2 (8). Reactor Building Leak Rate Prerequisite Tests A review of the documen+ation associated with these tests raised questions regarding the validit; of the leak rate test.
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_ _ _. . 00 Report No. 50-269/71-10-11-(a) Strong backs were used on both doors of the emergency hatch.
(b) Leaking valves were valved out of the system.
(c) Temporary gaskets were used on the fuel transfer tube.
\\ ' (d) It was not apparent that valves were closed by normal means.
Smith was advised that the findings relating to the RB leak rate tests would be referred to Headquarters for review.
Smith was advised that the implementation of the test program did not appear to meet the requirements of the FSAR and Appendix B to 10' '3 50.
The details of the deficiencies were discussed in the Management Interview and by telecon on November 12, 1971.
3.
Cable Tray Overfill During the inspection, a meeting was held with Wylie and other members of the licensee's staff relative to the problem of overfilled cable trays.
Wylie, during this meeting, agreed that cables of redundant systems could have as little as two inches physical separation and that many of the cable trays in the cable spreading room and the cable shaf t were overfilled. He advised the inspectors that, other than for dressing the cables in the trays, Duke planned to do very little toward correcting the problem in the Unit 1 area.
For Units 2 and 3, however, the licensee plans to use smaller cable and to use a computer program to aid in preventing overfill. In response to the inspectors questions, however, he stated that the actual determination of tray fill must be determined in each instance by manual calculations. The inspectors stated that this was not unlike Unit 1 in this respect and gave no assurance that the trays in the Units 2 and 3 areas would not be overfilled. The inspector advised Wylie that the licensee's proposed resolution of this problem did not correct the deficiencies that had been brought to their attention.
Wylie agreed to restudy the problem and to propose a resolution in the licensee's response to the CO:II lette. _ ._ _ - __ ___ _. _ _ ' . CO Report No. 50-269/71-10-12-( 4.
Reactor Coolant Flow-Sensing Element The inspector reviewed the vendor test report relating to the reactor coolant flow-sensing element tests and discus' sed the report with Barton.
From the information contained in the report, it was uncertain that the Reynold's number had been accurately determined for the flow-sensor tested. The report indicated that the error in measuring total volume of water during the test could be as much as 0.25%. Other possible errors were not discussed. The report stated that the results of the test for the one unit were considered to be valid for all units since the dimensional tolerances were very small. The inspector advised Barton that for the data to be considered to be acceptable by Compliance, an error analysis should be prepared to demonstrate that the ac curacy of the flow measurements would be within acceptable limits.
In addition, the inspector stated that he would want to review the installed test data to verify that the delta pressure outputs of the flow elements were in substantial agreement with given inputs. This item was discussed in the Management-Inte rview.
It was also pointed out that the licensee would be expected to verify, by testing, their analyses of backflow in idle loops.
5.
Traceability of Piping g The inspector met with Miller and Ostertag to discuss the licensee's progress in resolving this problem. Miller advised the inspector that the E censee had been unable to trace some piping and fittings to sourma.
Rather than to cut out the unidentified items, the licensee proposed to justify their use based upon one or more of the following criteria: a.
The only requirement for traceability was that which Duke had imposed upon itself.
b.
The system had been overdesigned relative to actual operating temperatures and pressures, c.
Failure of the item would not result in the loss of ability to preclude an accident because of system redundancy.
d.
Not safety related.
j . The inspectors pointed out that redundancy was a requirement to allow for unforseen failures and could not be considered as justification for not maintaining traceability. They also pointed out that the' criteria did not consider uncontrolled releases. Miller agreed to review the criteria based upon these comment. .. . . . . s CO. Report No. 50-269/71-10-13-SECTION III Prepared By: R. I'. Warnick, Reactor Inspector ADDITIONAL SUBJFCTS INSPECTED, NOT IDENTIFIED IN SECTION 1, WHERE NO DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND 1.
General Summerlin provided the following status of completion data regarding the facility procedures and the preoperational testing program: Total Approved Tes ts Results Numb er Procedures Completed Approved Tests before hot functionals 357 327 (92%) 238 (67%) 79 (22%) Tests during hot functionals 130 90 (69 %) 9 ( 7%) - Tests prior to core loading 130 85 (65%) 52 (40%) 31 (24%) Total Preoperational Tests 617 502 (81%) 299 (48%) 110 (18%) 2.
Preoperational Test Procedures The inspector compared fourteen preoperational test procedures against the test abstracts in Table 13.1 of the FSAR. The following test procedures were found to be in agreement with the test abstracts: TP-1A-110-2-1 - Penetration Room Pressure Drop and Filter Test TP-1A-160-2 - Reactor Building Coolers Functional Test TP-1A-161-3 - Reactor Building Purge System Functional and Operational Test TP-1A-201-3-3 - Core Flooding System Functional Test TP-1A-203-6-2 Low Pressure Injection System Engineered - Safeguard Test TP-1A-204-4-1 - Reactor Building Spray System Functional Test ~ i i k
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.... _ J % . .. ',' CO Report No. 50-269/71-10-14-DETAILS OF SUBJECTS DISCUSSED IN SECTION I 3.
Loss of Instrument Air Test At the inspector's request, Summerlin was comparing Duke's preoperational test program against the AEC's " Guide for the Planning of Preoperational Testing Programs." Although the review had not been completed by the close of the inspection, the inspector did identify one test the licensee was not planning to conduct. That test is" Loss of Instrument Air."i Af ter some discussion with Summerlin and Hampton, Hampton agreed to reconsider.
This omission from the testing program was discussed at the exit interview.
Smith and Hampton agreed to consider doing such a test. The inspector stressed the importance of the test and stated he would pursue the matter further should Duke elect not to perform it.
4.
Control Rod Drive Drop Tire Test The inspector reviewed Test Procedure TP-1A-330-3A, " Control Rod Drive Drop Time Test," and discussed his comments with Hampton.
The test does not require sufficient nunber of rod drops. The procedure only requires a trip test at no-flow conditions and again at full-flow conditions. The slowest rod is to be repeated at least once.
The section of the test procedure entitled " General Description" appears to be confusing and lacking in details and does not follow the style and language of the other Duke procedures reviewed.
It appears to have been scissored from a computer program.
This was discussed in the exit interview. Smith and Hampton agreed to review this procedure. This will be followed up on the next inspection.
5.
Low Pressure Injection System Functional Tes t The inspector reviewed Procedure TE-1A-203-5-4 and discussed his comments with Hampton.
As written, the procedure does not fulfill the intent and commitment made in the FSAR, page 13-22.
In particular, the FSAR indicates the reactor coolant system will be at elevated temperature and pressure. The procedure does not require this.
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- s CO Report No. 50-269/71-10-15-
' ' l The acceptance criteria in the FSAR test abstract are not accomplished by the test procedure.
ilampton indicated this procedure is being revised.
' 6.
FSAR Testing Requirements for l'reoperational Test Procedures The inspector reviewed fifteen preoperational test procedures and compared fourteen of them against the test abstracts in Table 13.1 of the FSAR.
The inspector's comments on eleven procedures were discussed with Hampton.
j Although Hampton made but few commitments, he did record all the inspector's comments and appeared to be receptive to them.
During a telephone conversation on November 17, 1971, with Murphy, Smith , ' agreed to review the FSAR to ensure that all testing requirements ara ' fulfilled by the test procedures.
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