ML19317D760
| ML19317D760 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/21/1972 |
| From: | Thies A DUKE POWER CO. |
| To: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 7912100524 | |
| Download: ML19317D760 (7) | |
Text
..
tf. s. h. E. C..
(
ChPU M;0E il
' DUKE POWER COMPANY hTL!SII" 6 A*
pm, sun.on,o g g $ d 4ae Sourn Gnunen Srazer, CuAntoTrr,N. C. asso A c. THets P. o. Box 217e tenson voce enessormt Pacoucreon meeo Taa esanissio June 21, 1972 Mr. John G. Davis United States Atomic Energy Commission Directorate cf Regulatory Operations Region II, Suite 818 230 Peachtree Street, Northwest Atlanta, Georgia 30303 Re: CO:II:CEH 50-269/71-9 50-269/71-10 50-269/71-11 50-270/71-5 50-287/71-5
Dear Mr. Davis:
Please refer to my letter of May 3, 1972 which was in response to your letter of March 8, 1972. As agreed to in our meeting at Oconee Nuclear Station on May 19, 1972, the following comments supplement my letter of May 3.
1.
construction Department Certain members of our Quality Assurance organization have recently received additional training in various subjects related to our Quality Assurance program. All engineers in our Welding /NDE section, 11 engineers from other areas and 14 Welding /NDE inspectors completed an 18-hour course in welding metallurgy sponsored by the American Welding Society.
In addition to our Quality Assurance personnel, one member of our welding craft also completed this course. On May 8, 9, and 10, the Project Manager and Principal Field Engineer attended the 26th annual technical conference of the American Society for Quality Control. During this conference, they attended the tutorial session on nuclear power. This two-day session dealt j
with quality assurance requirements for nuclear power plants with emphasis on the implementation of AEC regulatory document 10CFR50, l
Appendix B and ANSI Standard N-45.2.
Representatives from various j
organizations such as Bechtel, B&W, Westinghouse, etc., including the United States Atomic Energy Comission spoke during this session.
1 7 91210 0 f2p' i
Mr. John G. Davis Page 2 June 21, 1972 Two engineers in our Welding /NDE section attended the American Welding Society School of Welding Technology on pipe welding and testing and inspection of welds May 22 through 25, 1972.
On May 31, 1972, one of our NDE technicians completed an 80-hour course of instruction conducted by General Public Utilities at Harrisburg, Pennsylvania. This course covered a broad area of code requirements, welding and material technology and welding inspection techniques.
The above exampics represent some of the most recent training experiences of members of our QA/QC organization.
It has been a long standing practice for Duke to make available the opportunity for its employees to participate in schools, seminars, conferences, etc., so that we may stay abreast of the latest technical information and codes.
Also, as part of our QA program for the Construction Department, pro-cedures are being prepared for the certification of our inspection personnel in all areas.
At the direction of the Vice President, Construction, supervisory review of QA/QC functions has been implemented on a scheduled basis with documentation of results.
The status and adequacy of the total Quality Assurance Program is regularly reviewed and documented. At the Oconee job-site, weekly meetings are held with the Project Manager, Principal Field Engineer, Field Engineer-Civil, Field Engineer-Electrical, Field Engineer-Mechanical, Field Engineer-Office, and Field Engineer-Welding /NDE in attendance.
The purpose of these l
meetings is to review the activities of the Field Engineers as related to QA/QC functions.
Suggestions and recommendations are presented and discussed as to the adequacy of the program and how it can be improved.
Changes in existing QA procedures and the instructions for implementation of new procedures are presented at these meetings.
To gain a more detailed review as to the status and adequacy of the total progra.s each area of responsibility will be audited by site personnel. Two areas, mechanical and electrical, have been audited as of this date. Audits of the other areas will be conducted at future dates.
Engineering Department During early 1972, 260 members of Design Engineering Department whose work is directly affected by the Quality Assurance Program attended a QA orientation meeting.
These meetings were conducted within the Civil, Electrical, and Mechanical Sections by responsible members of each section.
These meetings provided description of the Design 1
Mr. John G. Davis Page 3 June 21, 1972 Engineering Department QA Program, the 18 AEC Criteria, and imple-mentation in each section of the QA Program with respect to calcu-lations, drawings, specifications, audit and surveillance activity, and QA documentation. New employees will be given the same training within several months of joining the Design Engineering Department.
In addition to the above "in-house" program, appropriate members of Design Engineering Department have received training by Duke Con-struction Department, Hobart Company, Magnaflux Corporation, and KraatKramer Ultrasonics, Inc., in non-destructive examination techniques (liquid penetrant, magnetic particle, ultrasonic, radio-graphy). This additional training is to strengthen the audit and surveillance activities which these men perform.
2.
Construction Department A check of engineering drawings at all locations has been completed with out of dcte drawings either destroyed or properly marked to indicate that they are superseded.
The Oconee site has now implemented Document Control Procedure G-1 which requires that all engineering drawings be issued from the field engineering office.
Control sheets are main-tained which show how many copies are received, who receives each copy and whether the copies which are revised are destroyed or retained. This method of controlling documents provides positive accountability for all engineering drawings received at the site.
3.
Documentation for three high pressure injection pumps, three low pressure injection pumps and two building spray pumps was intentionally placed in the folder for B&W supplied Ingersoll-Rand pumps. The pumps were purchased and manufactured together, and the associated docu-mentation was kept together in the one folder under one purchase order with each unit being identified. We reviewed this particular record folder following the initial indication by the Compliance inspector that it was deficient. We have not identified any deficiency in this record folder. There was no unidentified documentation in the record packet, and each record packet was complete. Therefore, there must have been a misunderstanding or an oversight.
Subsequently, these records were separated by system as the Construction Department transferred records to the Steam Production Department.
Following separation of the documentation into system records, the~high pressure, low pressure and building spray pump packets were reviewed by Design Engineering and found to be satisfactorily transferred to the system record file.
Each packet was found in order.
l
\\
,n-w
(-
Mr. John G. Davis Page 4 June 21, 1972 Quality assurance documentation for mechanical equipment (except valves in Duke scope) supplied by both B&W and Duke is reviewed by Decign Engineering as a part of their Quality Assurance Program before transfer to the Construction Department. Documentation for valves furnished by Duke is reviewed by Pittsburgh Testing Laboratory (with sus 22,cact spot check by Design Engineering) prior to transfer to Construction Depart-ment.
Thus, documentation for all mechanical equipment has been reviewed prior to transfer to Construction Department.
The documentation file at the site has and will continue to be periodically reviewed and audited.
6,9.
To assure that FSAR requirements such as the valve opening times on the low pressure injection system and high pressure injection system are properly incorporated into test procedures the Superintendent of Oconee Nuclear Station has taken the following steps:
A.
The " Guide for Conducting the Oconee Preoperational Test Program" has been revised to specifically require that the Final Safety Analysis report as well as test specifications and instruction manuals, drawings, and system descriptions be used as source of material for the development of the test procedure.
(
Reference:
Guide for Conducting the Oconee Preoperational Test Program, February 1, 1972, Attachment A)
In order to assure that test procedures written before the guide was revised contain proper FSAR and technical specification information, a memorandum was sent to each test coordinator requiring that he fill out a " Test Procedure Validation Checklist".
This checklist requires that the FSAR be searched and appropriate sections referenced and/or incorporated into the test procedure. A copy of the Test Procedure l
Validation Checklist is attached.
l l
B.
In addition, Mr. J. E. Smith, on November 15, 1971, held a meeting I
with all supervisory personnel to stress the necessity for performing a more detailed and thorough audit.
Emphasis was placed on audits which would include the proper documentation of unresolved problems, and assurance that requirements of the test procedure have been successfully completed.
C.
Mr. Smith also in the memorandum dated February 29, 1972, to all supervisors and test coordinators, stated that the following require-t ments would be in effect:
1.
That the test coordinator consult the FSAR and technical specifi-cations in the preparation of the test procedure.
2.
That the FSAR requirements be referenced in the references section and the acceptance criteria sections of the test procedure.
I
1 l
Mr. John G. Davis Page 5 June 21, 1972 3.
That the group head will audit the completed test to verify that FSAR and/or technical specification requirements have been met.
The foregoing are examples of steps that have been taken within the Oconee Nuclear Station to strengthen the test program to assure that all in; a s pertinent to any test procedure are properly included in the pr n: dure, that the test results are carefully and properly documented it luding any discrepancies, and that audits are performed to assure tLac the documentation is correct.
In addition, I advised you in my letter of June 2, 1972 that an audit team has been appointed within the Steam Production Department to begin detailed audits at Oconee Nuclear Station.
One of the functions of this audit team will be to make a random selection of requirements from the FSAR and to check to see that these requirements are incorporated in the test procedures and that the test results are properly met.
Regarding the Reactor Building Spray System ES -Test, a discrepancy for the Unit 1 test is attached to that test procedure stating that the Unit 1 test procedure could not be completed until the Unit 2 test had demonstrated the successful operation of a similarly designed system.
Therefore, the operation of Unit 1 is prevented until the successful completion of the Unit 2 Reactor Spray ES Test.
Regarding the valve opening times referred to as part of the Reactor
-)
Building Spray ES Test, we assume that these valves are the suction valves for the reactor building spray and low pressure injection pumps.
These valves rere timed on both the low pressure injection and Reactor Building Spray ES test.
It is true that the valve opening times were not identified on a discrepancy sheet on the Reactor Building Spray ES Test; however, administrative procedures such as those outlined pre-viously have been implemented to prevent this type of problem. The valves on the discharge of the reactor building spray pumps do not have a specific opening time requirement, but must be opened in sufficient time to allow a spray flow of 1500 gpm in each line within 37 1/2 seconds after initiation of engineered safeguards channels 7 or 8.
This requirement was successfully demonstrated.
7.
Procedures for the control of wiring jumpers, lif ted leads, and bypass mechanism in electrical cabinets are now being implemented at Oconee Nuclear Station. At the present time, all Unit 1 panels that contain exclusively Unit 1 safety-related cable terminations have been turned over to Steam Production and are under Steau Production control. Any further work in these cabinets must be cleared with the Oconee shift supervisor before it can proceed. Unit 1 cables in cabinets that contain Unit 1 and Unit 2 cables are being marked and identified.
Construction has been notified to make no revisions to Unit 1 cables within these cabinets without first obtaining clearance from the shift supervisor.
1
t Mr. John G. Davis Page 6 June 21, 1972 All safety related circuits necessary for the operation of Oconee Unit 1 are now under the control of the Steam Production Depart-ment.
We have no evidence to indicate that on tests previously completed the results have been affected by lif ted leads, wiring jumpers, or bypass mechanisms.
However, after identification and controls have been established, Oconee Nuclear Station personnel will conduct enough tests to assure them that the system operates properly.
10.
The attached letter of instructions should clear the matter of requiring the General Office Review Committee to follow the " Guide-lines for the General Office Review Committee Review of Safety lelated Test Results".
The matter of audit functions of GORC is to be discussed with your Mr. Murphy on Tuesday, June 27, 1972 and we will follow this meeting with a letter answer to your concern.
We trust the above responses supply sufficient supplementary information to my letter of May 3, 1972 for you to complete your review of the items identified in your letter of March 8, 1972.
Very truly yours, A. C. Thies ACT:vr Attachment ec:
Mr. W. S. Lee Mr. W. H. Owen Mr. R. L. Dick Mr. E. D. Powell
Attachment to June 21, 1972 letter
^
from A. r.Thies to J. G. Davis, AEC/R0 \\
s.
June 20,1972 MEMO TO:
Chairman, General Office Review Committee FROM:
A. C. Thies
Subject:
Test Review Guidelines It is noticed that included with the bylaws of the General Office Review Committee there are " Guidelines for the General Office Review Committee Review of Nuclear Safety Related Procedures" shown on page 6, and
" Guidelines for the General Office Review Committee Review of Nuclear Safety Related Test Results" shown on page 7.
These " Guidelines" shall be followed at all times, unless a deviation is specifically approved by the head of the Steam Production Department. Any such requests for variation from these " Guidelines" should be made a matter of record.
cc: Mr. B. B. Parker Mr. E. D. Powell 0
l l
t
_ _