IR 05000269/1971011
| ML19322A709 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/03/1972 |
| From: | Kelley W, Moseley N, Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322A707 | List: |
| References | |
| 50-269-71-11, 50-287-71-05, NUDOCS 7911210753 | |
| Download: ML19322A709 (12) | |
Text
o.
..
.
.
UNITED STATES ATOMIC ENERGY COMMISSION
,
- f (* I DIVISION OF COMPLIANCE I
e REGloN 11 - SulT E 818 230 PE ACHT R EE ST R EET. NoRT MWEST
,
,
AT L A NT A. GEORGI A 30303 TESTING AND STARIUP INSPECTION REGr.T e
C0 Report Nos. 50-269/71-11, 50-270/71-5, and 50-287/71-5 DUKE POWER COMPANY Oconee 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287, License Nos. CPPR-33, 34 and 35, Category:
31, A2, and A2 Seneca, South Carolina Type of Licensee: PWR-2452 MW(t), B&W (each)
Type of Inspection: Routine, Announced Dates of Inspection: December 7-10, 1971 Dates of Previous Inspection: November 9-11, 1971 (Unit 1)
June 29 - July 2,1971 (Unit 2 and 3)
Principal Inspector:
/ 7M fat'e C. E. Murphk Re/cto p)nspector (Testin and Startup
.
d'
.u
- / IE Accompanying Inspector:
,
,
W.D.Kelley,RedctorIngector D'a t'e (Construction)
Other Accenpanying Personnel:
F. Jape, Reactor Inspector (For Training)
Revleved By:
W 3 /74
N.C.Moseley,SeniorReacprInspector Dat6 (Testing and Startup)
Proprietary Information: None 49110
,
-
.
.,
C0:II 269,270,287/71-2-
,
SECTION I Enforcement Action A.
Noncompliance Items 1.
Criterion XIV of Appendix B to 10 CFR 50 - Failure to develop adequate procedures to control electrical jumpers and bypass mechanisms.
(See Section II, Paragraph 5)
2.
Criterion XVIII of Appendix 0 to 10 CFR 50 - Failure to develop procedures for the conduct of audits.
(See Section II, Paragraph 4)
3.
Criterion VI of Appendix B to 10 CFR 50 - Failure to establish control of plant drawings.
(See Section II, Paragraph 6)
,
4.
Criterion XVI of Appendix B to 10 CFR 50 - Failure to correct
'
deficiences in the welding program.
(See Section II, Paragraph 7)
'
5.
Criterion VIII of Appendix B to 10 CFR 50 - Failure to maintain quality assurance documents in a manner to assure that identity is maintained and that records are traceable to specific items.
6.
Criterion IX of Appendix B to 10 CFR 50 - Ineffectiva control of welding in that the following specific deficiencies were identified:
a.
Welding procedure qualification test coupons not prepared in accordance with the thickness requirements of ASME Code,Section IX.
b.
Welding procedure and welds - Qualification face and root bend test coupons ground in excess of that allowed by ASME Code,Section IX.
Records of Welding Procedures P-1 and P-2 qualification c.
indicate that they were not performed consistent with the requirements of the procedures, d.
Records of five of six welds examined in the main steam piping did not indicate preheating as specified in Procedure P-5.
Use of verbal instructions to specify which variables the e.
weldors use of a variety contained in Procedure P-5.
.
.
...
-
-
.
,
Duke Power Company, 269,270,287-3-7.
Criterion VIII - Inaccurate records to assure that identity of items is maintained in that weld data computer cards stated that material is A-106 whereas QC forms show it to be A-155.
,
B.
Nonconformance Items
%
None
,
C.
Safety Items None Licensee Action on Previously Identified Enforcement Matters Corrective action has not been completed on items identified in CO
'
Report Nos. 50-269/71-7, 71-8, 71-9 and 71-10.
Unresolved Items Effect of rerouting cable on preoperational testing.
(See Management Interview.)
Status of Previously Reported Unresolved Items
'
1.
The licensee has rerouted the reactor coolant flow transducer tubing to obtain maximum separation outside the shield walls, atthistime.l.7onsidersthisitemcompleteandplansnofurtheraction The inspector i
2.
Both Construction and Operations have established a system for logging all personnel admitted to the plant area. Physical barriers are being erected to prevent the entry of unauthorized personnel into the Unit 1 area.
The adequacy of the barriers will be reviewed prior to core loading. The inspec or does not plan any further action on this item at this time.2, 3.
The variation notice procedure has been revised to require verification that the design drawings are revised to reflect plant changes.
The inspector plans no further action on this item at this time.3/
I 4.
Thelicenseedoesnotplantoverifythatadequacyofthesafet{j feature valves wall thickness or the operability of the valves._
.-
C0 Rpt. No. 50-269/71-2-2/
-1/
C0 Rpt. No. 50-269/71-8 CO Rpt. No. 50-269/71-9-4/
--3/
CO Rpt. No. 50-269/71-7
_
-
.
- _
-
.. {l
.
.
,
Duke Power Company 269,270,287-4-
,
-
Unusual Occurrences None Persons Contacted
- W. S. Lee - Senior Vice President, Engineering and Construction J. E. Smith - Plant Superintendent J. W. Hampton - Assistant' Superintendent'
L. E. Summerlin - Staff Engineer, Operations.
O. S. Bradham - Instrumentation and Control Engineer, Operations R. M. Koehler - Technical Support Engineer L. Lewis - Staff Health Physicist, DPC
- T. F. Wyke - Mechanical Design Engineer A. J. Kuck - Electrical Design Engineer D. G. Beam - Project Manager D. L. Freeze - Principal Field Engineer K. S. Canady - Staff Engineer, Steam Production Department Management Interview The following subjects were discussed with Smith, Hampton, Summerlin, Bradham, Koehler, Beam, and Freeze at the Management Interview conducted
!
on December 10, 1971:
l 1.
The inspector reviewed the status of the outstanding items list i
maintained by Compliance.
2.
The inspector reviewed the discussions held with Lee regarding the measurements of valve wall thicknesses and the need to test the valve operators. Lee had stated that based upon sample measurements that had been made and analysis of operator requirements, Duke
'
s management was satisfied that the valves met requirements and planned
\\g no further action. He requested a meeting with Compliance management to discuss the valve problem. The inspector agreed to pass this request to his supervisor.
(See Section II, Paragraph 2)
3.
The inspector discussed the deficiencies which he had found in the information contained in the data packages for the HP injection
!
the LP injection pumps, and the reactor building spray pumps.
- pumps,_hEiciencies had been.previously found in the licensee's QA
,
Since d
!
documentatlds 4he inspector advised Beam and Kuck that it appeared
'
v that the licensee *e. failure to take'carrective action was contrary to the requirements of Appendix B to 10 Cra-5q. Kuck stated
,
'
that Duke Engineering would review and correct tn--QA, data packages.
(See Section II, Paragraph B)
..
h.
- By Telephone
's
!
l
,
-
.
.
Duke Power Company 269,270,287-5-
,
4.
The inspector reviewed the discussions held with Lewis relating to the General Office Review Committee. The inspector stated that it was his understanding that Lewis had committed to produce a procedure for the operation of this committee.
Smith confirmed this understanding.
(See Section II, Paragraph 4)
5.
The inspector advised Smith, Beam, and Bradham that the procedure for the control of jumpers and lifted leads was inadequate since it does not provide a means for identifying all lifted leads and jumpers or for interface with Construction. Smith agreed to review the problem and correct their weakness.
(See Section II, Paragraph 5)
6.
Beam and Smith were advised by the inspector that the control of drawings appeared to be inadequate. During an inspection of the drawings in the control room and the shift supervisor's drawing racks, he had found many superseded drawings.
Superseded drawings had also been found in the files used by the construction crafts.
The inspector reminded Beam and Smith that this problem of document control had been previously identified and that Thies had committed Duke to correcting this deficiency.1/
(See Section X, Paragraph 6)
7.
The inspector advised Smith and Beam that Duke must be able to document that changes to the cable routing do not negate testing. Smith stated that operations will discuss this interface problem with Beam and Freeze. Kuck maintained that the changes had been documented but agreed that Duke had no procedures to cover these changes.
The inspector stated that making changes to the design without procedures to assure that previously-tested circuits were retested may be contrary to the requirements of Appendix B to 10 CFR 50.
Smith said that he would review the problem with Construction.
8.
Kelley then described the deficiencies that he had observed in the audit he had conducted of the welding program. Murphy reminded Beam and Fg eze that at the conclusion of the previous inspection of Unit 1,1 they had stated that the welding procedures would be rewritten and deficiencies corrected within four weeks. This period had expired and according to information given b3 Freeze, four procedures had not as yet been rewritten and those that had been rewritten appeared to contain significant errors either in requirements or in qualification. Since Blaisdell, the Duke welding engineer, could not be at the management interview, Beam asked if Kelley
'would discuss those items that appeared to be violations of the
_1_/ 50-270/71-2
--2/
C0 Rpt. No. 50-269/71-10
.
.
.,
^;
CO:II 269,270,287-6-
,
Code of Federal Regulations with Blaisdell by telephone or December 13, 1971. During this telephone conversation, Blaisdell and Freeze agreed to make corrections to the procedures and procedure qualifications.
They also stated that equipment was being purchased with which to fabricate bend specimens. At the same time, Beam advised Murphy that Duke would bring in outside consultants to evaluate their entire welding program.
Murphy advised Bean that this review should include the effect that the deficiencies had upon the welding which had been done to date, cad particularly as to the effects on the quality of the Unit 1 welding. Beam agreed that this would be done.
(See Section II, Paragraph 7, and Section III)
.
9.
Murphy then advised Smith, Beam.and Kuck that the implementation of the Duke quality assurance program did not appear to be effective.
He cited as examples Construction failure to correct welding deficiencies, Design's failure to correct deficiencies in the design of the cable routing,l/ and Operation's failure to correct deficiencies in the implementation of the quality assurance programs in these areas raises questions as to the effectiveness of the whole program.
.
1/ C0 Rpt. No. 50-269/71-10
_
_
-~
.
.
,
CO:II 269,260,287-7-
'
SECTION II Prepared by:
C. E. Murphy, Reactor Inspector (Testing and Startup)
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED-IN SECTION I, WHERE NO DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND 1.
General The reactor coolant pumps are expected from the manufacturer in February 1972. Core loading is scheduled for late April 1972.
DETAILS OF SUBJECTS DISCUSSED IN SECTION I 2.
Safety System Valves Lee in a telecon to the inspectors during the inspection discussed Compliance's concerns with valve operators and valve wall thicknesses.
Lee stated that Duke Design had reviewed the valve design and were convinced that the designs. met code requirements. He stated that they had measured the wall thicknesses of eight valves and found that they met design requirements. The had also reviewed the methods used by Crane-Chapman to determine the requirements for motor
,
operators and were satisfied that the motor operators would be adequate. Kelley advised Lee that he had found valves at other sites whose wall thicknesses did not meet code. requirements. Kelley also told Lee that the problems with wall thicknesses was that due to pecularities in valve design, i.e.,
large flat plate areas, some valves would not withstand the design operating conditions and, therefore, they did not meet the codes.
In order to determine the required wall thicknesses, it would be necessary to review the design analysis to determine that they were adequate. Lee stated that all their valves were hydrostatically tested. The inspectors advised Lee that a hydrostatic test was a short-time application of pressure and might not show up the defective valses.
It became obvious to Murphy that an impasse had developed and he advised Lee that he had no choice but to carry the valve problem as an out-standing item. Lee asked the inspector to arrange a meeting between Compliance management and Duke management to discuss the valves.
Lee stated that he wished to have the Crane-Chapman chief design engineer at the meeting. Murphy advised Lee that he would pass the request for the meeting to his supervisor but that he could not make a. commitment for the meeting.
3.
Quality Assurance Data Packages The inspector reviewed the licensee's quality assurance data packages for the high pressure injection (HPI) pumps, the low pressure
l l
l I
..
.
.
CO:II 269,270,287-8-s injection (LPI) pumps and the reactor building spray pumps. The data packages for Unit 1 HPI and LPI pumps had been previousi, reviewed 1/ and deficiencies had been found in the records. Oae of the reactor building spray pumps for Unit 1 had failed during test and it had been returned to the factory. A Unit 2 pump had subsequently been installed in the Unit 1 position. The review during this inspection was to ascertain if the records had been updated as well as to determine if the Units 2 and 3 records were complete. The inspector again found deficiencies in the documentation.
Some of the documentation did not contain adequate identification to relate it to a particular pamp. Documents for the several pumps was intermixed and only identified, for example, by serial number, and documents for the reactor coolant sustem piping were found in the packages with the Unit 1 pump documents. These deficiencies were discussed in the management interview. Beam and Kuck were advised that the implementation of document control procedures did not appear adequate and that tne licensee's failure to take corrective action appeared to be contrary to the requirements of Appendix B to 10 CFR 50.
Beam and Kuck stated that the data packages would be reviewed and corrected.
4.
General Office Review Committee (GORC)
The inspector reviewed the minutes of the meetings held by the GORC. This committee, according to the licensee's " Guide for Conducting the Initial Test Program," is charged with the responsibility for auditing the work of the plant operating group.
Meetings had been held in May, June, and July 1971. The next meeting had been held in November 1971. The inspector questioned Lewis about the prudence of meeting so infrequently, particularly considering tae problems being experienced by operations. Lewis stated that the Technical Specifications did not require that the committee meet more often than three times a year and that he did not see the necessity to meet more frequently. The inspector questioned Lewis about the procedures used by the GORC in the conduct of its business. The inspector was shown a document entitled " Guidelines for GORC Review of Nuclear Safety Related Procedures." After reviewing this document, the inspector advised Lewis that this documor.t was what its name implied, i.e., a guide. It did not give such details as standards for evaluation, minimum tests to be audited, responsibility for resolution of problems, and the like. It also did not provide a method for assuring that the GORC would be advised of the action taken by Operations relative to-1/
C0 Rpt. No. 50-269/70-9
__
.-
.
.
.
.
.
C0:71 DPC 269,270,287-9-deficiencies identified by the GORC. Smith advised the inspector that the GORC was now maintaining a punch list that would indicate the disposition of all GORC comments. The inspector also advised Lewis that the GORC should have procedures for perforning other functions as well as for their audit of testing. Lewis agreed to develop the procedures after the inspector reminded him that Appendix B 'co 10 CFR 50 required that audits be conducted in accordance with written procedures. This item was discussed in the management inte rview. The inspector plans to verify during future inspections that adequate procedures are developed.
.
5.
Electrical Interlock and Circuit Bypass Procedure The inspector reviewed an approved copy of MP/1400/20, " Electrical Interlock and Circuit typass Procedure," dated November 30, 1971.
The stated purpose of this procedure is to provide a means to control and document the installation and removal of jumpers or opening of electrical circuits for specific requirements as dictated by test or maintenance program. The inspector advised Smith and Bradham that the procedure was considered to be inadequate for the following reasons:
a.
It does not provide for control of circuits or portions of circuits that have not been turned over to Opera.tions by Construction.
It also does not provide for control of circuits that have been returned to Construction for correction.
b.
The procedure provides no effective mechanisms for audits to assure that all jumpers and open circuits have been identified.
c.
It does not take into account temporary jumpers and lif ted leads that have been accomplished by Construction.
d.
It does not provide a mechanism for identifying jumpers and lifted leads on circuits placed in operation which have not been turned over by Construction.
It does not provide a mechanism for determining that test e.
results have not been negated by jumpers and lif ted leads.
Bradham agreed with the inspector's comments and stated that test results had indeed been negated by tempors.ry connections.
This item was discussed in the management interview and Smith agreed to correct the deficiencies discussed by the inspector.
_..
.____ __-_
_ _ _ _ _
_ _ _ _ _ _ _
,
,
.
CO:II DPC 269,270,287-10-
6.
Drawing Control The inspector obtained a current drawing revision list from Freeze for use in checking the implementation of the document control procedure. The inspectors reviewed drawing files maintained by the Construction crafts in the Unit 2 reactor building and in the auxiliary building. They also inspected the drawing files maintained by Operations in the control room Numerous instances of outdatad
,
revision were identified in the drawings maintained by Construction and by Operations. The inspectors discussed the details of their findings with Smith and Beam including the locations where out-dated drawings..had.been found.
The inspectors.r d d them that thissameprobleahadbeenpreviouslyidentifiedgyine and that Thies had committed Duke to better document control. The failure to take effective corrective action appears to be contrary co the requirements of Appendix B to 10 CFR 50.
The inspector discussed this item in the exit interview and both Smith and Beam agreed to take steps to correct this deficiency.
7.
Welding Program The inspector participated to a limited extent in the review of the welding program by Kelley. During the management interview, the inspector summarized the deficiencies that Compliance had previously identified in the welding _ program.and the commitments that had been made by the licensee to correct the deficiencies.6,/ He reminded Beam and Freeze that they had stated that the procedures would be re-written and the deficiencies would be corrected within four weeks at the conclusion of the previous inspection. Not only had the deficiencies not been corrected, but the rewritten procedures still did not meet the requirements of Section IX of the ASME Code. The inspector advised Beam that he now questioned the adequacy of the welding for Unit 1.
f-1/
Letter to C0:II (Davis) from Duke Power Company (Thies) dated April 22, 1971 1'l CO Rpt. No. 50-269/71-10
<
,
.,
.
.
CO:II DPC 269,270,287-11-SECTION III Prepared by:
W. D. Kelley, Reactor Inspector (Construction)
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERZ NO DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND None DETAILS OF SUBJECTS DISCUSSED. IN. SECTION I 1.
Welding Procedure Qualification Test Coupons A large percentage of the welding procedure qualification test coupons were not prepared in accordance with the requirements of Section IX of the ASME Code. The code states that the coupons'
thickness shall be 3/8 inch and the DPC has used thickness that exceeded this dimension.
2.
Welding Procedure Qualification and Weldor Qualification Bend Test Coupons Numerous welding procedure qualification and weldor qualification face and root bend test coupons had been ground into the base metal in the weld area which is not permitted by Section IX of the ASME Code.
3.
DPC Welding Procedure P-2 Not Qualified DPC Welding Procedure P-2 was written for the use of the Grinnell insert; however, the procedure qualification states that the root pass was made with the tungsten inert gas process with bare filter wire.Section IX of the ASME Code requires requalification of the procedure if a eSange is made from a consumable insert to a filler wire.
4.
Control of Weldor Performance Welding Procedure P-5 is a broad procedure which because of the variety of essential variables has a number OL qualification data sheets.
This, in effect, makes Pracedure P-5 a group of subprocedures.
The system in effect at Oconee is that the foreman gives verbal instructions to the weldors concerning which variables to use or which subprocedure applies. No records are made of these instructions; therefore, it is not possible to assure that appropriate variables were used, that unapproved changes were not made, or that proper weldor and procedure qualifications have been maintained.
This system does not appear to satisfy the requirements of Criterion IX of Appendix _ _.
'
..
.
,
,
CO:II DPC 269,270,287-12-5.
M.2n Steam Piping Buttweld Not Preheated An audit made of six main steam. piping.buttwelds_ records revealed that five (Isometric Drawing 2W0, welds 1-B, 3-B,17-B,18-B, and 19-B) were not preheated 3000F as required by the DPC Welding Procedure P-5 for material in excess of one inch in thickness.
6.
Weld Data Computer Cards Not Agreeing With Duke QC-37 Form Twelve data computer cards.for.the. main. steam-piping buttwelds stated the material was A106; however, the DPC Form QC-37 lists the material as A155. Criterion VIII, " Identification and Control of Material, Parts, and Components," requires measures be established to assure identification of item being maintained.
7.
DPC Welding Procedure P-1 Not followed in Procedure Qualification DPC Welding Procedure P-1 requires the first and second pass to be made with gas tungsten are using E309 wire and the balance of the weld with shielded metal arc. The procedure qualification states the first pass was made using E308 wire and the balance using shielded metal arc.
8.
Valve Wall Thickness Verification DPC has not developed a valve wall thickness verification program.
DPC (Lee in telephone conference call) asked if the Compliance inspector would meet the Crane-Chapman Company for a d1scussion of their valve. The Compliance inspector stated he would discuss this matter with his supervisor and inform DPC of Compliance's position on the meeting by telephone at a later date.
-