ML19317D317

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Insp Repts 50-270/70-03 & 50-287/70-03 on 700323-26.No Nonconformance Noted.Major Areas Inspected:Primary Coolant Pressure Boundary Piping,Electrical & Instrumentation Components Welding & Preoperational Testing
ML19317D317
Person / Time
Site: Oconee  
Issue date: 05/04/1970
From: Kelley W, Murphy C, Seidle W
US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML19317D316 List:
References
50-270-70-03, 50-270-70-3, 50-287-70-03, 50-287-70-3, NUDOCS 7911270499
Download: ML19317D317 (15)


Text

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!^j U. S. ATOMIC ENERGY COMIISSION REGION 11 DIVISION OF COMPLIANCE Report of Inspection i

CO Report Nos. 50-270-70-3 30-287/70-3 Licensee:

Duke Power Company Oconee 2 and 3 Licens ee Nos. CPPR-34 and 33 Category A Dates of Inspection:

March 23-26, 1970 Date of Previous Inspection:

February,19-20, 1970 Inspected By:

I / [Jo C. E. Murphy', ReaEtor Inspector Date (In Charge) 8 Y< h l-4ho W. D. Kelley, Rhaetor Inspector (Construction)

Date

~~-A1*L N hlf - O F.U.

over, Re ctor Inspector (Construction)

Date Reviewed By:

f-Y - 70 W. C. Seidle, ' Senior Reactor Inspector Date NOTE: The sections of this report relating to welding and piping were prepared in the main by W. D. Kelley and those relating to electrical / instrumentation by F.11 Bower.

Proprietary Information:

None SCOPC An announced inspection was made of the 2568 Mwt pressuri::ed water reactors under construction near Seneca, South Carolina, known as Oconee Station Nos. 2 and 3.

Purposes of the inspection were:

(1) to determine the con-struction status and significant changes to schedule dates; (2) review the electrical / instrumentation QC program and work perfor._ance; (3) review records and work performanca relating to mechanical equipment and piping and; (4) to review the preeperational testing program.

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. ~.. _ _ _.. _. _. _ C0 Rpt. No. 50-270/70-3 - 50-287/70-3

SUMMARY

Safety Items - None Nonconformance Items - None Status of Previously Rerorted Problems - The valves pr/viously identified as possibly having improper weld end 1. e preparatio.7sl have been placed in quarantine. (See Section I.) 2. The skimmer weir h,gs been repaired and tested. No leaks were detected through the weir.S 3. The polar crane control circuit repairs that would prevent over travel of the hook on loss of power have not been ecmpleted. Duke Welding Procedure DP-62/ as now been properly qualified in h 4. accordance with the ASME Code, Section IX. (See Section C.) 5 The revising and rewriting of the welding procedures to eliminate the previously-reported deficiencies are in process. (See Section C.) Other Significant Items - 1. The licensee does not presently have procedures that would ensure dccumentation that the installation of materials and equipment would meet FSAR comnitments. (See Management Interview and Section F.) 2. There have been no significant changes in the plant construction schedule. (See Section E.) 3. Procedures have not been established to document that transducer senscrs tubing sdll be routed to meet the single failure criteria for redundant systemt. sed for safeguards and safety-related installations. (See Management Interview Section and Section F.) l 4. 1? inspectors were advised by Wells that no ATAPCO piping.was being uted at Oconee. 1/ CO Report Nos. 50-270/70-2and-50-287/70-2. 2/ CO Report Prescon 70-1, 1/ CO Report Mos. 50-270/70-1 and 50-287/70-1.

t CO Rpt. Nos. 50-270/70-3

  • 50-287/70-3 Management Interview - The management interview was held en March 26, 1970, and was attended by Dick and Wells.

1. Field Routing of Instrumentation Hydraulic Lines The problems associated with the field routing as safety-related instrumentation sensor tubing were discussed in some detail. Dick stated that he could see the need for an engineering determination of the routing of those lines and that he would pursue this matter. (See Section F.) 2. Documenting PSAR Installation Recuirements The need for documenting that the installation of materials and equip-ment satisfied FSAR requirements was discussed. Dick agreed that formal documentation was needed and that procedures for obtaining the documentation would be developed. (See Section F.) 3 Allovco Valves Dick assured the inspectors that the Alloyco valves would remain in quarantine until the licensee received disposition fran B&W. This item will be reviewed during the next audit. (See Section I.) 4. Arc Strike Procedure Wells stated that work has started on a procedure for the detection and repair of are strikes and that the procedure would be ccmpleted within a month. (See Section C.) DETAIIS A. Persons Contacted C. E.. Watkins - Vice President, Production and Operation R. L. Dick - Projects Manager J. C. Rogers - Project Engineer J. R. Wells - PrL cipal Field Engineer J. E. Smith - Stai *n Superintendent J. W. Hampton - Assistant Station Superintendent M. D. McIntosh - Operating Engineer 1 l l J

CO Rpt. Nos. 50-270/70-3 50-287/70-3 E. D. Brown - Maintenance Supervisor L. E. Sw=:erlin - Technical Support Engineer G. L. Hunnicutt - Field Engineer, Ciril R. E. Blaisdell - Welding Engineer C. B. Aycock - Field Engineer, Electrical . E. Cater - Instrwnentation Engineer D. Kennedy - Preseen Corporation Field Supervisor B. Administration and Creanization 1. No significant changes have been made in the site constructicn QC staff since the previous inspection. 2. The licensee now Fas 75 people en the plant test and operations staff. These include the superintendent, assistant superintendent, 39 operators and supervisers,10 maintenance men and supervisors, ~ 20 technical support persennel, and 4 clerks. All key positiens have been filled. C. Quality Assurance 1. Weldine a. General Blaisdale has revised the welding procedure identificatien system which separates the structural steel welding precedures designated by the prefix "S" and the pipe welding procedures designated by the prefix "P." The new welding procedure nu:n-bering identificationeia to be used en all records and testing effective March 2, 1970. l b. Structural Weldine Procedures Welding Procedure DP-6, which has been redesignated as Welding Procedure 3-6, has been requalified in accordance with ASME Code, Section IX. It had been previously reported that enly two bend tests had been performed for the qualification test where four were required by the ecde. A complete new qualifi-catien test was performed which included two tensile tests and four bend tests. __J

C0 Rpt. Nos. 50-270/70-3 50-287/70-3 9 c. Fire Welding Procedures The Welding Procedures 0-WPS 1, 2, and 8, which have been redesignated as Welding Procedures P-1, 2, and 8, have been revised. It had been previously reported that these welding precedure voltage and ampere values had not been followed in the welding of the procedure qualification test plate. The revised welding procedures voltage and ampere values now agree with the electrode manufacture's recommended range and the range used in the welding of the procedure qualification test plates. The procedures are considered by Region II inspector to be qualified in accordance with ASME Code, Section IX. d. Censumable Inserts It was previcualy reported that the use of consumable insert rings was not covered in the essential or nonessential variables in the ASME Code, Section IX, and that both the Grinnell type and EB type were permitted in Welding Procedure O-WPS-8 (now P-8). Blaisdale was asked on the previous inspection if the two censumable inserts were interchangeable. Blaisdale informed the inspector that he had investiated the use of the Grinnell versus EB consumable insert rings for the same welding proce-dure by running tests using the EB insert with the Grinnell insert weld preparation and vice versa. The difference in the weld preparation for the two types of consumable inserts is the thicker welding lands (or lip) for the Grinnell insert. Blaisdale was of the opinion that if the wrcng consumable insert was used, it would be recognized by the welding inspector when he inspected the joint fitup as required for his signoff of quality control, Form QC-36. Should the inspector not cbserve that the wreng consumable insert was used, the weldor would recognize the difference in the welding characteristics when he started to weld the jcint. Finally, radiographic examination of the weld would reveal unconsumed insert if an EB insert was used with the thicker lands of the weld prepara-tion for the Grinnell insert and if a Grinnell insert was used with the thin lands of the EB weld preparation, the radiograph would reveal concavity or "suckup." e. Arc Strikes An are strike removal procedure is being prepared by Blaisdale. The procedure will establish when the welding inspector is to visually inspect the equipcent, valves, pipe, and fittings in L.

(. ~ ... ~.... - - .-s..- b i f. 4 C0 Rpt. Nos. 50-270/70-3, 50-287/70-3 i j a system for the detecticn of are strikes and the method of repairing them and nendestructively testing the repairs. The inspection, arc strike repair, and nondestructive testing of the repair will be made before the hydrostatic test of a system, f. Quality Control An oxygen analyser (Beckman Model D-2) has been purchased and is presently being used in the welding of stainless steel piping systems when =aking tie-in welds or closure welds in long runs of pipe. The maximum oxygen content permitted in i the purge is 1.0%, i i Welding inspectors have been assigned certain areas of the project for which they are responsible for inspecting for uncontrolled electrodes and electrode ovens being connected and at temperature, f 2. Other quality assurance items are discussed under the individual j inspection items. l D. Construction Procress 1. Placement of concrete for the Unit 2 containment is up to the eleventh ring. 2. Placement of concrete for the Unit 3 base slab continues. I j 3. All major equipment has been placed in the 100 kv emergency power j switchyard. Stringing of the transmission line to this switchyard is in progress. ( L. Construction progress photographs are filed in the Region II office. E. Schedule Dates It is new believed that Unit 2 will be delayed scmewhat but that Unit 3 will be on schedule. F. Electrical and Instrumentation 1. .Implementatien of CA Procras (5105.03) The QA program devised by Aycock for control of the electrical / instrumentation systems has not yet been completely implemented - i installation of due to the minimal-progress in the receipt a a ,w.y -~ - c-m , _. - +, -y ..mw-- -w--%- o 9- .,y y, s,-- +

m -. ~ s j l CO Rpt. Nos. 50-270/70-3 ! 50-287/70-3 equipment.for these systems. In those areas reviewed, however, evidence of program implementation was evident with inconclusive results since nothing had reached a ecmpletion stage. A follow-on inspection will be required to confirm that QA progran j implementation is adequate. 2. CC Procedure Review (General) The QC manual developed by Aycock contains a number of procedures 4 l that describe actions taken to ensure the installation quality j for a number of systems and functions. 1 In fact, it can be stated that the actions they have taken in this l regard probably exceed anything that can be considered a " require-4 i ment" since issuance of proviaional construction permits for the Ocenee units preceded the development of the QA cencepts imposed upon present day applicants. The site QA manual is not, as a rule, j completely specific since most of the chapters centained therein are better described as general descriptiens of proposed actions l with references to manufacturer's requirements rather than detailed procedures, Aycock recognizes this characteristic and plans to expand the procedures and provide more detail as engineering provides him with the specifics of the installation. a. Special Handling and Storage Recuirenents (5105.04.b.6) Timing of this site visit was fortuitous in that this inspector was able to observe the receiving inspection and site handling i of electrical equipment as it came to the site as well as review receiving procedures and observe the received equipment stcred at the site. Based cn these observations and reviews, a finding 1 .can be made that the requirement of the referenced inspection point was met. Tha specific equiptent and materials cbserved were the Unit No.1 main transformer and sixteen 4000-foot reels of centrol cable. b. Quarantine of Nonconformine Comronents (5105.06.b.7) (5105.06.b.1) 2 l A receiving and storage precedure exists for quarantine of non-conforming components. Evidence of implementation of this pro-cedure was observed by visual inspection of the storage facility wherein a number of instruments were isolated and tagged as i quarantined. The QC-31 document (receiving inspection) revealed that these instruments were discrepant because they had not yet rw e __..,y--


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C0 Rpt. Nos. 50-270/70-3 50-287/70-3 been certified through the regular channels as suitable for installation. Aycock stated that these instruments would be released for regular storage when the documentation was cleared through the procedures established. c. Handlinc and Installation Srecifications (5105.0L.c.1) A procedure has been established for QC inspection and dccumentation for pneumatic and hydraulic instrument systems installation. This precedure was reviewed for suitability and for implementatien since it has been implemented for the cenventional portions of the plant where seme system instal-lation work has econenced. 'dhat is conuidored to be a weakness in the installation precedures, with the potential of creating a nonconformance in the installed system hardware, was identified. This weak-ness is the dependancy placed on the site staff to field rcute the sensor lines for transducers and/or instruments requiring tubing. The problem associated with this concept is the dif-ficulty of meeting, with assurance, the single failure criteria for redundant and/or multiple systems used for safeguards and safety-related installation. The licensee was quick to reccgnize the problem when it was pointed out to the= and agreed that enly a thorough engineering design effort could provide the necessary routing information for those systems that must meet the single failure criteria. They agreed to resolve this discrepancy prior to installation of any related systems and implied that this procedure wculd be altered to confirm that pertinent insta11atiens met the single failure criteria requirement. A reinspecti.n will be required to qualify this inspection point. This item was re-viewed in detail in the management meeting, d. Material Certificatiens (5105.05.b.1) Discussiens with Aycock regarding material certifications and a review of the site QC procedures revealed that the entire program related to providing these certificates is within the purview of the engineering group. Engineering is charged with the responsibility of identifying what certificates are required, inclusion of the requirement in the purchase documents, and ultimate procurement of the documents themselves.

s C0 Rpt. Nos. 50-270/70-3 50-287/70-3 The site procedure re quires that engineering sign the QC-31 form which certifies that all such documents are within its centrol. This enginaering signature indicates to the field that all QC provisi>ns have been fulfilled and the component cleared for instal?.ation. Aycock stated that all such documents will eventually be availab,le at the site, but at this time none of them are available. He has verbal notice that a large number cf such documents, presently in Charlotte, will be sent to the site in the immediate future. Ocepleted copies of a few of these forms hsd been noted by the inspector during a previous inspec-tion of records maintained at Charlotte. This inspection point can be considered ccmplete, since the procedures as implemented by the field cover the point adequately. e. Installation Insrection ( 5105.05. a.3 ) Since some cable trays and a few miscellaneous instrument rack and motor control centers had been installed in the con-ventional portions of the plant but only a small quantity of tray fer the safeguards systems had been installed, the dis-cussion with Aycock and Cater was directed toward the detailed QC inspection procedures to be used for the remainder of the safeguards equipment. One feature not included in the procedure was the requirement for the inspector to document his acceptance of all installa-tiens that =ust meet requirements as set forth in the licensee's application and FSAR. The particular requirement associated with cable trays and assemblies of electrical equipment, such as panel boards, that could and should be certified as acceptable, are these special features provided to meet seismic events. l Aycock confirmed that he had not considered this item and agreed to try to develop some type of form or procedure that would produc3 a certified record of acceptance that would confirm that all requirements, particularly those in the FSAR, had been fulfilled. The need for such a procedure was discussed in the management meeting, and was expanded to include mechanical items as well as electrical items. The progress made in estab-lishing such a procedure will be reviewed during the next inspection. 1

l C0 Rpt. Nos. 50-270/70-3 50-287/70-3 3. Discrecancy Disposition System Aycock and Cater have developed an informal system for tracking and disposing of identified electrical and instrument discrepancies. This system, as described, incorporates the use of a form created by Aycock for this purpose kncwn as a " Discrepancy Werksheet" (DR). The DW is used to identify the deficiency and related reference documents and as a log of the actions taken to dispose ef the deficiency and the names of those contacted. The system as presently implemented has weaknesses, the most sericus being the initiation of changes and corrective action on the strength of telephone agreement s as logged on these DN's. The merit of preparing a procedure to regulate this activity and pro-vide more formality in the decision-making cycle was discussed with . Ayc ock. He did not feel that the number of active discrepancies would warrant this action. He had developed the system more or less as an expedient and did not foresee any difficulty administering the system as long as it remained with 10-15 items open at any one time. He did admit that it probably could not be managed in its present fonn if an appreciable number of items were involved. In the discussion with Ayecek and Cater, the inspector stated-that within his experience a system of this type, properly managed, is almost indispensible to a functional QC organization since it provides a documented procedure to dispose of the multitude of discrepancies identified by any viable QC crganization. An attempt to handle large numbers of difficiencies informally invariably leads to a breakdcwn in the QC program. This item was also discussed with Welle, both as to the work presently being done and also the applicability to the civil and mechanical systems. Although a " punch list" is planned for the future, Wells was nonecmmittal as to developing written procedures to ensure an adequate system for the civil and mechanical items. G. Containment - Attac'rment C 1. Welding to Centainment Idner .The inspector noted that temporary scaffold clips and knee braces had been welded to the liner plate and the inspector was unable to determine if this work had been performed by certified weldors using qualified precedures. Some of the clips and knee braces had been removed frcm the liner and these areas had not been properly repaired. Blaisdell -and Hunnicut inspected the liner and stated that-they would establish procedures for the detect'on, repair, and inspection of these veld areas.

1 ~ s + i i CO Rpt. Nos. 50-270/70-3 50-287/70-3 2. Concrete Placement - Unit 3 i The placement of concrete in the Unit 3 base slab, pour No. 4, was observed by the Regicn II inspecter. Seven concrete mixing trucks were at the site; two were being unloaded and five were waiting. Although two inspectors were en hand, one inspector was testing the concrete for slump and air entrainment and preparing 4 test cylinders for the concrete being placed by conveyor belt. The second inspector was witnessing the placement of concrete at the tendon trumpets. The Region II inspector observed the conveyor operator permitting the cencrete to pile up approximately seven feet high which could conceivably have required transporting the cencrete as much as ten feet with the vibrators. It was further noted that the ccunter on truck No. 64 was inoperative. This truck had arrived at 1:35 p.m. and was discharged at 2:23 p.m. The slump of the concrete was within permissib2-limits. It was ob-served that the counter on truck No. 92 had recorded 516 revolu-tions which would be in excess of that permitted by ASTM Standard C94. A comparison of the counter indication with the narimum drum speed and time of operation indicated that this counter probably had not been properly reset when the mix was leaded. When these items were brought to Hunnicutt's attention, he immediately'investi-gated and found another truck whose counter was inoperative. He later informed the inspector that although four yards of concrete from truck No. 92 had been placed, the remainder had been dumped. Although C94 permits the user to waive the drum rotation count, Wells instructed his men to reject any truck with an inoperative counter or any truck whose counter indicated in excess of 300 revolutions. Although Wells and Hunnicutt censidered the piling and transporting of concrete to be an isolated case, Wells did call the concrete inspector to his office and instruc ed him that this condition was not to be pennitted again. H. o 4-=-v Coolant Pressure Poundary - Main Coolant Looe - Attachment F PI 5000 1. Weldine - Review of.QC System (4805.0L. a.1-L. b.1-6l c.1-6. d.1-1 e.1-2. and c.1-5) a. Weld Procedures A special welding procedure has been written for welding the =ain ceolant loop piping. The procedure will be for welding both the carben stee3 / stainless steel clad pipe welds to the vessels and the cold leg butt weld and the stainless steel safe end to the stainless steel pump volute. Since the procedure

i s I .~ CO Rpt. Nos. 50-270/70-3 50-287/70-3 is for Oconee main coolant loop pipe welds only, Blaisdale has decided not to include it as a Duke standarc welding procedure. When all the procedure qualification tests are ccmplete in accordance with ASE Code, Section IX, the proce-dure will be issued to the welding supervisor and inspectors. Only selected weldors who have been qualified to weld the carben steel / stainless steel clad spent fuel tank and transfer canal will qualify in accordance with the special procedure for welding of the carben steel / stainless steel clad pipe welds. The welders who have been welding en the stainless steel safety injection welds will be qualified for welding of stainlese steel safe end welds to the main coolant pump volute, b. Insrection The nondestructive technique and nondestructive technicin 3 and welding inspectors will be the same as those used in the low and high pressure safety injection systems. These items wereauditedinAttachmentGforthesafetyinjectionsystems.M Each weld joint has been aseigned a number and this number is used as the file number for the data sheets in the field weld inspection and NDT record book. The data sheet is a ecmplete record of the welding and nondest m etive test procedures used, the identification of the weldor that performed the welding, the nendestructive-test procedure used, the NDT technician that perfo: red the test, and the NDT results. The data from the visual inspection of the veld joint alignment, root gap, joint prepa-ration, envircnmental control, root pass, and finally, the complete weld is furnished by the welding inspector and recorded en the data sheet. The preheat minimum base metal temperature during welding of the carbon steel welds is maintained by electric coils and must be checked by the welding inspector ence per shift. The interpass temperature of the welding of the stainless steel safe ends and stainless steel cladding of the carbon steel weld will be checked by the weldor and welding inspector with temperature indicating crayons. The final carben steel weld will be postweld heat treated in accordance with the special Duke welding procedure which meets the require-ments of USAS 331.7. g C0 Report Nos. 50-270/70-1 and 30-287/70-1.

CO Rpt. Nos. 50-270/70-3 50-287/70-3 c. Radiocrarhs The quality of the radiographs has improved and Grier is insisting that all radiographs meet ASME Code requirements, especially the fiLn density. The Level II radiographers have had enough experience on the Oconee site to be able to evalu-ate weld quality as meeting code; however, radiographs that they consider borderline are reviewed by a Level III radio-grapher frcm B&W. d. Welding Rod Control The welding rod centrol frem receipt and storage through issue control and onsite control to final disposition of unused mate-rial has been audited in previous inspection of main steam imping for the carben steel welding electrodes and the safety injection systems for stainless steel ww1 ding electrodes, wire, safety injection ystems for stainlees eteel velding electredes, wire, and gases 2. Pir,ing - Review of QC System (5005.04 b.1-3, e 4, d. 2. d.3. and f.3) a. Insrection The material certification and nondestructive testing records of the fabricated spool pieces are at 914 and will be sent to the Duke Charlotte eng.neering office. The spool pieces are inspected by Duke upon delivery and a receiving report, Fon: QC-31, issued. b. Installatien The piping system is designed as a free system suspended frem reactor vessel and steam generator no::les. No bellows are used in the system; however, a spring hanger and snubbers are currently being designed which will support the weight of the pump motor for seismic protection. The pipe will support the weight of the pump volute. An allowance has been made in the field for shrinkage during welding of the main coolant loop piping. Blaisdale estimates this will amount to approximately 3/8-inch weld for the stainless steel welds and 1/4-inch weld for the carben steel welds. 1/ C0 Report Nos. 50-270/69-2 and 50-237/69-8.

C0 Rpt. Nos. 50-270/70-3 50-287/70-3 c. Safe Ends The main coolant icop piping has safe ends for welding to the stainless steel pump volute. These safe ends were added by 5&W in their shop after stress relief of the carbon steel welds. I. Alloveo Valves (Attachment G. PI 5005.051 The Regien II inspector requested that he be shown the B&W supplied Alloyco 2-1/2-inch stainless steel valves. A review of the drawings for these valves du/ ring a previous inspection at the licensee's engineering officel had indicated that the weld end preparatiens were not in accordance with ASA B16.25 as required by the FSAR. The site piping engineer was not aware that the valves might be discrepant, and it was determined that some had been issued for installation. When it was determined by the licensee that the valves' wela ends were not in accordance with the applicable cede, the valves were returned to the warehouse and placed in quarantine. The inspectors were advised at the management interview that the valves would remain in quarantine until the problem of the weld 2nd preparations had been resolved. J. Test Program 1. Test Specifications Test, or systems, specifications are being prepared by B&W, Sechtel, and the licennee for the Cconee Statione. These specifications are being usert by the operations group in the preparation of test procedures. The inspector reviewed the specificati:ns for the "High Pressure Injection System Hydrostatic Test and Functional Operation," and the " Reactor Coolant System Hydrostatic Test." In general, the specifications were very detailea and well written. It was noted, however, that calculational methods were not always presented to indicate hcw required computations were to be made and that the points for making measurements wsre not always identified. In additi:n, in a few cases, the specifications were vague with respect to values and limitations. !hese weaknesses were brought to the attention of Hampton who assured the inspector that when the test procedures are prepared, care would be taken to correct such items. 1/ C0 Report Nos. 50-270/70-2 and 50-2S7/70-2. i

s CO Rpt. Nos. 50-270/70-3 15 - 50-287/70-3 2. Test. Procedures l During a.discussien of the test program, Smith stated'that as a means of expediting the review of the test procedures, he planned 4 - to place the inspector on the distributien list to receive most of the test procedures. He also stated that the inspector could i obtain a copy of any other procedure that he wished to review. i The inspector had previously received a preliminary index of all the plant test pr:cedures. The inspector was given copies of preliminary procedures entitled, "New Fuel Inspection and Storage" and " Equipment Hatch I4ak Rate Test." i 3. Test Program (5?05.01 and.02) 4 i i The inspector was given preliminary copies of the "Oconee Test Program Index and Schedule" and the " Guide for Conducting the i Oconee Initial Test Program." It would appear from a teview of these documents that the licensee has included those t+sts to I which he is ccmmitted and that he has a suitable method for recording, reviewing, approving, and retaining test data and I results and for identifying and correcting deficiencies. K. Work Cbservation i 1. Housekeerine The inspectors noted some improvements in housekeeping in the construction and storage areas. In particular, scrap pipe was being removed frem the pipe storage areas. Wells stated that an j attempt was being made to segregate all scrap frem the pipe stcrage are a.a. i 2. Other Cbservations { For other observations, refer to sections relating to the particular d' ems. 5 i h 1 l l-I 1 l Wu = M e hhWm e a m*,. gg ._y_ 4.,9 q.39 <4q_, ,..,a g ..v_r g.> wg

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