ML19316A328
| ML19316A328 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/19/1971 |
| From: | Thies A DUKE POWER CO. |
| To: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19316A322 | List: |
| References | |
| NUDOCS 7912050896 | |
| Download: ML19316A328 (7) | |
Text
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J DUKE POWER COMPANY' Powra Bmt.orwo 4aa SouTu Camica SrazzT. CuAatartz, N. C. asaos A. C. Turns se..v.a ~, cc.,
November 19, 1971 P. o. Box as78 m,
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Mr. John G. Davis, Director U.S. Atomic Energy Commission Divn of Complia 2e Region II - Suite 818
' 230 Peachtree Street, Northwest Atlanta, Ga 30303
Subject:
CO:II:CEM 50-269/71-7
Dear Mr. Davis:
In answer to your letter of October 1,1971, concerning items of apparent non-compliance with Criterion VIII of Appendix B to 10 CFR 50
" Identification and Control of Materials, Parts, and Components" - Duke Power Co has carefully reviewed this whole matter.
We appreciate the extension of time for reply to enable us to provide a more complete answer.
Attached is a statement which has been prepared in an effort to fully outline the problem, our adjustments to our Quality Assurance Program, and the improvements which we have been able to make in the overallidentification of materials.
We believe that these steps will adequately answer the concerns expressed in your letter, but if there is any further information, please advise.
Sincerely, tA A. C. Thies ACThr Attachment cc: Mr. W. S. Lee Mr. W. H. Owen Mr. E. D. Powell y M2L/Q/9 Mr. C. E. Watkins g<
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$ NOV 221971$
9' 791205.0
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.y Oscumentation c( Piping Materials
,:omplianca (Lotter of 10-1-71) O AEC Division c 1.
Statement of the Problem:
On October 1, 1971, Mr. John G. Davis of the AEC wrote Duke Power Company a letter indicating a non-compliance item of Criterion 8, Appendix B, 10CFR50, " Identification and Control of Materials. Parts and Components (June 27,1970)."
Th /c are some materials erected in Unit i piping systems that cannot be % tally traced and identified to its unique Mill Test Report herein-after defined as " Untraceable" materials. These " Untraceable" materials resulted'due to one or more of the following documentation' discrepancies, a) Incorrect heat number recorded - does not agree with any MTR b) Heat numbers obliterated during contruction c) Heat number on component o.k. but no MTR available (Duke trying to obtain these) d) Failure to record heat numbers.
Overall, the materials involved represent less than 5% of the total traceable materials for Unit 1 2.
Duke's Response to the Problem:
Duke Power Company's QA program for piping materials began in late 1967 when Duke recognized the need for certain non-destructive testing and documentation of piping systems.
Duke produced a Power Piping Quality Assurance Manual (PPQA Manual) which was formally issued in 1968, defining those classes of materials that requi red 'special certification and hand-ling on a system basis.
Duke also purchased piping for ~ portions of engi-neered safety feature systems in late 1967 with documentation and non-3 destructive testing requirements prior to any official nuclear guidelines in the way of a code, star.dard or other regulation, in February, 1968, the ANSI B31.7 was published for trial use only and Duke worked this requirement into the PPQA Manual on the premise that this document would be a requirement and guideline for the purchase, erection and NOT of piping systems.
The piping menticned above did in fact meet all require-ments of this publication. The PPQA Manual is sub-divided into three separate sections.as follows and has been reviewed by the AEC on a previous visit to Duke's General Offices.
Section I: Indicates Duke Power Company's position and attitude toward quality Assurance and defines in detail the various job assignments to all parties for the procurement of materials.
Section II: Defines theDuke Engineering Department's design criteria, piping system classifications and detail piping specifications including non-destructive test r4quirements, documentation, etc. and sets forth Vendor requirements for handling of piping materials.
Section Ill: Defines the Engineering Department requirements for field work in handling, erection and cleaning of nuclear materia 1s. The Construction Department is responsible for
.detalle.f procedures in this area.
Duke's QA program includes qA Audits for initial qualification and followup surveillance 'of suppliers and vendors. As a, result of Duke's QA program, Duke actually received some of the first Class i nuclear In addition, materials produced by several manufacturers in this Country.
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Documentstion of Piping Materials
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2 AEC Divisicn cNomplienca (Letter of 10-1-71) O I
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I the PP Manual requires that critical Class *l and C ass ll nuclear material components receive 100% source inspection at the place of manufacture prior to shipment. This PPQA Manual has continually been under improvement and revision to meet all current standards and practices insofar as possible for the Oconce station.
During the riocumentation process for Oconee 1 after initial construc -
tion was essentially cocMete, i t was found that recording of heat nurnbers for some piping components was impossible as discussed in T
St tement of the Problem above. At the time the AEC reviewed,the docu-i mercation records of piping systems, the documentation process was not complete and a substantial number of components were identified as
" Untraceable."
Since the problem has b*een identified and quantified, Duke Engineeri'ng.
and Construction have worked together to justify or ~ replace materials as required. As Unit I system erection, hydro testing, flushing and preoperation check-out was essentially complete when Duke's Quality Assurance program noted traceability discrepancies, a high level of confidence had already been established in the design and construction of most systems for the service requirements intended.
For these systems; a program to justify the actual " Untraceable" materials was put into action.
For those systems on which less time, testing and overall Company confidence had been gained, a program of replacement for " Untraceable" materials went into effect.
Most systems affected are stainless steel; thus, the ' program of justi-fying erected materials is more attractive as the' cutting and rewelding.
of stainless materials is undesirabic in' many respects.
Since critical-
- r materiais received source inspection and since Mill Test Reports sent to the jobsite were checked and approved by Duke Engineering, it is felt that erected " Untraceable" materials meet specification require-ments; and to replace these materials with only an equal traceable material does. not appear to be the best solution to the problem.
Duke's pr'ogram to, justify " Untraceable" materials consists of the foi-lowing:
a) The Construction Department has reviewed all systems requiring traceability and documentation. Each " Untraceable" component has been identified and noted on a print of the p.iping system drawings with a full description of the component.
b) The Engineering Department has reviewed each " Untraceable" com-ponent noted on the piping drawing and has defined those materials which are acceptable to remain or which must be replaced within i
the system, j
c) The justification for utilizing " Untraceable"-materials in a J
' system has been carefully examined by Duke's management; and
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Duke feels that there are four (4) very sound reasons, any one
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or more of which may be basis for the justification of leaving a material component within a piping system as follows:
1.
System " traceability" is a Duke requirerrent only for Quality' Crntrol purposes and is not required by Code. Therefore, the material is acceptable without replacement.
2 By Engineering review, the material component is of the cor-rect generic type material and pressure-rating per detalled piping specifications. Therefore, the material is acceptable without replacement.
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.D:cumentetion of Piping Mrtaricis ~
AEC Divisicn ] Complianca (Lotter of 10-1-71 P,
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3.
Based on design makeup capacity, a postulated failure of the material component would not render the system inoper-able for safety function intended.
4 Postulated failure of the material component would not I
cause uncontrolled release 'of radioactivity per established criteria.
d) If " Untraceable" materials do not meet one of the four criteria listed above, they are replaced within the system.
Currently, all replacement work has been done and only those materials which
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are justifiable remain within the systems.
A review of the Con-struction site records indicates a significant reduction in "Untrac able" materials. This is the result of having obtained the proper documentation for some materials, of having replaced some materials that could not be justified, and of having com-pleted most of the quality Assurance documentation work.
e) Not only were materials required to be justifiable from an Engi-neering viewpoint, but the material item itself had to be visibly examined by Construction Department personnel and confirmed to be the correct generic type material and pressure-rating by visi-ble marking, magnetic check, necess'ary NDT measurement and/or physical measurements, etc.
f) Utilizing the design drawings marked with " Untraceable" materials, i
the Engineering Ocpartment prepared a formal Deviation Report on a systems basis which will become a part of the QA documentation package for that system to be turned over to the Steam Production Department after total system completion.
It is important to recognize, however, that this Deviation Report as forwarded by the Engineering Department was only a starting point and the Deviation l
Report only became valid af ter the Construction Department certi-fled the correct generic type material and pressure-rating as discussed above in item c). ~
g) Deviation reports have been completed by Engineering for Unit I and are being completed by Construction. A sample Deviation Report i,s attached to illustrate the " Untraceable" materials justification program.
3.
QA Program imorovements:
As the prob *1em of " Untraceable" materials became evident, both Duke Engi -
neering and Construction Departme.1ts took steps to improie the overall program.
Four basic changes were made as follows:
a) The Engineering Department now requires that all Mill Test Reports be shipped with the material itself from the Vendor, b) The Construction Department has expanded its piping inspection program such that no piping materials are received into issuable inventory at the site unless proper documentation is delivered
-lj with the material and processed.
c) Construction has expanded the QA program in that a completely neW procedure for piping inspection and welding inspection of piping systems is being put into effect. This procedure has mandatory hold points in it, one of which is that before welding begins at
, a join. the two pieces of material are checked for a heat number; and heat number is checked against a listing of valid heat numbers.
At this point.' the valid heat number is recorded so that tracea-ability can be maintained in the event the heat number is oblit-erated.
If no heat number exists on the pipe or if a number exists
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D:cumentation_of Piping Msterials 4
AEC Di-visicni ) Compliancs (Lotter of 10-1-7( )
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i but is not valid, the joint is not made until acceptable material is used.
This procedure will be complete and in full ef fect by 12-1-71 This inspection is for both field-shop and in-place erection.
d), Temporarily for Units 2-3 systems until 12-1-71 when the pro-cedure discussed above in c) becomes effective, the Construction Department has expanded the piping inspection program so that piping will be inspected for. heat number traceability within -
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i two or three days af ter erection. This allows Construction to know the status of traceability of all. erected systems for Units 2 & 3 and, i f necessary, to remove any " Untraceable" material before entire systems are completed.
Th.'s inspection is for' both field-shop and in-place erection.
With the above changes in Duke's quality Assurance, the problem of
" Untraceable" materials should be minimized for Units 2 & 3.
4.
Summary of Overall Situation:
I Duke's response to the Unit 1 "Untraceabic ' materials problem, above, describes in detail the work done to define and resolve the problem, and the solution presented represents the best overall Engineering solu-tion when all aspects are considered.
Ma t'e r ia l identification problems on Oconee I were partially due to changes in criteria and developing codes and standards. Many materials were ordered prior 'to release of the AEC's Appendix 8. All of these facts contributed to the loss of effectiveness in some areas of the Duke quality Assurance program.
Appropriate steps have been taken to:
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a) Remove or justify use of " Untraceable" materials on Unit 1 b) Avoid use of " Untraceable" materials on Units 2 & 3 e
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DESIGN DEVIATION REPG. )
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Date:
11-12 71 Repsrt No:
MDG DR # 37.8 To:
C. E. Watkins Originated By:
S ta tion:
Oconee 1 Approved By:
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System:
60(1)
Sheet I
of 2
File f,:
05 27.4
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Deviation Reported 83y and Date:
D. L. Freeze 10-19-71 Nature of Deviation:
Inability to properly document traceability of pi' ping system materials.
i Engineering Analysis Required:
Review of system deficiencies and classiTy material based on one or more of the folicwing i tems:
1.
System " traceability" is a Duke requirement only for Quality Control purposes and is not required by Code.
Therefore,,the material is acceptable without replacement.
2 By Engineering review, the material component is of the correct'
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generic type raaterial and pressure-rating per detailed piping specifications. Therefore, the material is acceptable wi thou t replacement.
3.
Based on design makeup capacity, a postulated ' failure of the material component would not render the system inoperable for sa fety function intended.
Therefore, the material is acceptable without replacement.
4 Postulated failure of the material component would not cause uncontrolled release of radioact,ivity per established criteria.
Therefore, the material is acceptable without replacement.
5.
The material is not justified by any one of the four (4) reasons above. Removal and replacement is mandatory.
Engineering Disposition of Deviation:
Forwarded to the Construction Department for documentation purposes in QA records.
, Engineering Ocpartment Certification:
Construction Department Certification:
S. K. Blackley, Jr.
This certifies that subject listed Principal Mechanical Engineer materials have been inspected and confirmed to be the correct generic
[ f(* 77 type material and pressure rating.,
By:
R.
E., Miller Senior Engine:r Construction Representative Date REM: rje cc:
D. G. Beam J. M. Curtis
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n Justificatien for not j
ttstarial Ccmponent i tem No.
Drawing ns.
Documantina Materials 1" 5. 40 S.S. A-376 Gr. TP 304H Pipe 1
0-435A 2,4 4" 5. 10 S.S. A-376 Gr. TP 304H Pipe 2
0-435A 2,4
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4" 5. 10 S.S. A-376 Gr. T' 304H Pipe 3
0-435A 2,4 1
1" 5. 40 J.S. A-376
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Gr. TP 304H Pipe 4
0-435A 2,4 1" 5. 40 S.S. A-376 Gr. TP 304H Pipe 5
0-435A 2,4
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