ML19322A593

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Insp Rept 50-269/71-05 on 710504-07.Nonconformance Noted: Lack of Structural Controls & No Audits of Tests Assuring Compliance W/Qa Program.Followup Review Performed on Electrical Installation of Control Rod Drive Controls
ML19322A593
Person / Time
Site: Oconee 
Issue date: 06/28/1971
From: Murphy C, Seidle W, Warnick R
US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML19322A589 List:
References
50-269-71-05, 50-269-71-5, NUDOCS 7911210672
Download: ML19322A593 (27)


Text

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n U. S. AIOMIC ESERGY C03011SS10N REGION II DIVISION OF COMPLIANCE Report of Inspection CO Report Nc. 50-269/71-5 Licen.ce:

Duke Power Company Oconee 1 License Nc. CPPR-33 Category B Dates et Ins peticn:

May 4-7, 19 71 Dates of F:svicos Ir.spetticn:

April 6-9, 1971

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Inspected Bf:

(Date' C. E. !!ut;[)f, F[ actor Inspector (Operations)

(In Charge f5 a

4-2/- 7/

R. F. Warnick, Reactor Inspector (Operations)

Date

%L n' nM'A' L cAdu

$. L.tTiteneri d(or Inspector (Operations) date g

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4 L... _ - e.1 C. Seidle, $enior Reactor inspector Dale ~

W.

Fr@rtetat. lar rmation:

None SCGPE A r :u;1:.e, 3:.n:e.ced tnspe ti:n was made of.he 2452 >9(t) pressurized water reactor un de.r ;;ns tr a~t ien near seneca, Scush Carolina, known as Oconee stati;n L.

1.

Farpaes e t the inspc ti.n were :

1.

T; dutirait.e the c;n3truction status and significant changes to schedule dates.

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.; ce. t c < cne autatandtag items remaining cc be conpleted at,the tacklitr.

3.

To :evia. trie pr;gres= of the test program and to evaluate the test re i u t t.,.

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00 Rp t. No. 50-2o9/71-5 --

SUMMARY

Safety It ems - None a

Ncnconf o r mance I ems -

1.. Criteri:n XI ci 10 CFR 50, Appendix B, states in part,' "A test program shall be eatablished to assure that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.... Test results shall be documented and evaluated to ass ure tha: tes t :equirements have been satisfied."

Contrary to this requirement, the inspectors observed lack of adequate tes t control.

The reactor inspectors reviewed four test procedures, TP 200 16 - Reactor Coolant System Cleaning, TP 2012 - Core Flood System Hydrostatic Tes*., TP 202 8 - High Pressure Injection System Flush

.and.TP 203 7 - Lcw Pres ure Injection and Core Flood System Flush. Three aof the four procedures reviewed contained either major or minor changes

.which were not made in ac:ctdance with Duke Power Company's (Duke) approved j

" Guide for Condaccing the Oconee Initial Test Program." The procedure for cleaning the reactor coolant system did not contain suf ficient. test i

result documentation to verify that acceptance criteria had been satis-fled. A timely review of the test results of the cleaning of the reactor

]

coolant system had not been conducted by station personnel even though i

the. reactor vessel head was ready to be installed.

2.

Criterion XV11I of 10 CFR 50, Appendix B, states in part, "A comprehensive system of planned and periodic audits shall be carried out to verify com-pliance with all aspects of the quality assurance program and to determin2 the ef fectiveness of the program.... "

Contrary to this requirement, the inspectors could not find evidence of audits having been conducted to assure that tests are performed according to wri: ten test procedures. and in accordance with Duke's " Guide for Con-l ducting the Oc: nee initial Test Progra=."

. Unusual Occurrences - None 4

Status aof Previousiv Reoorted Problems -

4

1. - The licensee's response to the CDN relating to the ' polyethylene trapped

.in.the reactor vessel internals has been' referred to Compliance manage-ment for resolution..l/

1/CDN to Duke dated Nbrth.8,1971, and licensee's letters in response dated Ap ril '5, 19 71, and April 14, 1971.

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f CO Rp t. No. 50-269/71-3 -m The licensee's response to the CDN relating to weld ro'd control and egble 2.

tray fill has been referred to Compliance management for resolution.1/

Other Significant Irens -

1.

The licensee has determined that the internal short circuits in the containment electrical penetrations were caused by metal shavings.

t (See Section G.)

l 2.

The licensee has completed his audit to verify thac the Table A require-ments have been mat.

(See Section C.)

1 Outs tanding Items - See Exhibit A for current status of outstanding itens.

Management Interview - The Management Interview was held on May 7,1971.

In attendance were Rogers, Beam, Hunnicutt, Smith and Hampton.

1.

The inspector cpened the meeting by advising the group that in the future the. major inspection effort would be shif ted toward test and operations and that the licensee might want to consider having someone in the opera-tions grcup as the inspector's prime contact. Af ter some discussion,

. Rogers and Smith decided that Smith should be the contact.

2.

The inspector advised Hunnicutt that he had reviewed the status of the electrical installation with Aycock and particularly those items on

. Aycock's outstanding items list which had been previously identified as areas of cencern.2/ Many of the items had been corrected but a few new items of a minct nature had been identified. Hunnicutt stated that he would review the list with Aycock and that he did not feel that it was necessary to discuss them at this meeting.

(See Section G.)

3.

The inspecter inf ormed Huanicute that he would expect a dry run with dummy fuel assemblies to be performed prior to use of the fuel handling cranes for fcel loading to verify the performance of the cranes.

He-further s tated that he would expect documentation of the test to include tolerances and would review the test results when available. Hunnicutt agreed that' a test wculd be performed, documented, and made available to the Cocpliance inspector.

(See Section F.)

4.

.The. inspector inf ormed Hennicutt that he had reviewed the damaged B2T switchgear with Ayccck and would expect to review results - of checkout

. tests perfersed on the repaired equipment. Hunnicutt stated that the test informatten would be available to the inspector.

(See Section G.)

1/

-- CDN. to Duka 3ated April 14, 1971, and _ licensee's response dated May 13, 1971.

2/00 Report Nc 50-Je9/ 70-11 and 50-269/ 71-1.

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gai e,wr6h wb e s-4 CO Rp t. No. 50-269/71-5 l-r 1

5.. The. inspector discussed the licensee's response to the CDN./ relating to weld rod c:ntrol. The inspector pointed out that the traceability of the welding rods und in a system is as important as the traceability of 3

the pipe and fittings in the system.

In the event that at some later date.the. licensee determined that a particular lot of rods were defective, i

be must be able to identify all welds in which the rods were used. Since

.the.. heat number is the only way to identify the rods, then the licensee

.must.p reserve this identification. Hunnicutt did not_' concur in this

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i position but stated that he interpreted the welding rod control as backfitting.

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.The inspe::or stated that he. did not interpret welding rod control as l

backfitting as defined in the Code cf Federal Regulations but if 1

Hunnicutt cculd show this to be the case, then the inspector would take this fact into consideration.

l 6.

Hunnicutt was advised that the inspectors had observed an oxygen bottle on.the edge of a platform near the 131 reactor coolant pump.. The bottle was not capped or tied ofi.

Hunnicutt stated that he would follow up on this item and would take appropriate action to prevent recurrence.

i 7.

The inspector dist.ussed the need for the construction and the operations 1

. groups. co devalcp consolidated lists of items ' requiring work for completion j

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.and.of. deficiencies tha* had been noted. The inspector stated that Aycock j;

had. developed a sys tem used by the electrical group and that Hunnicutt

.had. implemented a similar sys tem for piping.

The inspector asked if similar systems cculd be develcped for the mechanical and civil items

and.for items identitied by the cperations group. Hunnicutt stated that-

.he was considering the extension of this type control into the otha i

areas but rather than a single lis t, there would probably be several lists

.since. the lists would be maintained by the engineers responsible for a j

. phase.of.the proje:c. The inspe: tor stated that he could see no objec-j tion to. tbere being more than one lis t, as long as. the information was

.readily retrieveable and would represent all the deficiencies relating

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to a single phase of the work, e.g., the piping lis t.

Smith would not L

  • commit _ the operations group to establishing a cocnon lis t.

(See Section

.C.)

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8.. The. inspector. advised Smith that it was his understanding that a procedure would be. developed establishing _ control of lif ted leads and jumpers used l

in. tes ting. of cirtuits - and sys tems. He stated that he would expect to i

review.the procedure during the next inspection. Smith agreed that the -

j

. procedure would be devel; ped for this purpose. The inspector stated _that j

in his' discussions with Bradham, the use of tags and color coded wires

.had.been discussed and Smith might want to consider their use. L Smith t

j s tated that he whuld discuss their use -with Bradham.

(See Section L.)

@CDN dated April ly,1971.

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00 Rpt. No. 50-2e9/71-5 !.

9.. The inspector teminded Smith that during a previous inspection Smith

.had agreed to revise the adminis trative procedure, " Guide for Conducting the.0canee Initial Ies t Program" (Guide), to more clearly define

.the.ducles of the test coo rdinato r.1/ The inspector stated that he would like to review the revised guide. Smith stated that the

. guide was currently beir.g rewritten and that a copy would be provided the inspector as soon as it became available.

The inspector will follcw up en this item.

10..The.inspectcr reviewed his previous discussions of the general inadequacies of.the.0 cnee tes t proceduras.2/ The inspector advised Smith that he would review several precedures during the next inspection to determine if,they could n:w be censidered adequate. Smith stated that the work of upgrading the procecures was in pregress and some would be available for. review at that time.

(See Section H.)

11.

The.1nspector then proceeded to discuss deficiencies noted in review of the precperational test results.

Ihe inspector presented examples of discrepancies observed during tha review, such as:

a.

Modift:4tions te procedure without rec rding changes on cover sheet.

(Fer example, HPI, LPL and CF flush tes ts.)

b.

Omittir.g portions of the system from testing as a minor change to pro-cedure.

(For example, boric acid pump in CF hydro.)

c.. Failura to record changes in valve lineup to be consistent with pro-cedure changes.

(For example, HF155 ard 156-not added to valve list

.in LPI and CF flush test.)

d.

Failure to followup cn disstepancies tnat had been noted, e.g.,

failure to dccument reeleaning and tes ting a section of surge piping

.af ter initial testing had sh:wn a hign fluoride content.

.The.inspecter advised Smith that Regten II was very concerned about the adequacy.cf. be implementation ;f the Oconee tes t program.

He then

. advised Smith that the licensee appearad to be in nonconformance with-

.10.CFR 50, Appendix B, Criterien XI, in 'that the test procedure changes

.were. improperly made and test results were not evaluated.

In addition,

.the. licensee also appeared to be in nonconformance in that the require-ments for audits specified in Criterica XVIII were not being met.

(See Section H.)

1/CO. Repo rt No. 30-269/71-3.

2/

-- 00 Repo r t No. 50-269/71-4 m.

C0 Rpt. No,'50-z69/71-5

-o-n 12.

In.respcase to a CDN relating to dert lenci.es that had been observed in the constructi:n of the :eactor building,l! the licensee had made a commitment to pe rt zm en analysis of the ef fects of all discrepancies

.in the pres tress system. Ihe inspectcr advised Rcgers that he had received a ctpy of this analysis and that it would be returned to the licensee af ter it had been reviewed by Compliance.

13...The.inspettor stated that he had examined the areas of the reactor vessel

. internals.which had been damaged by the dummy fuel assemblies.2/ In response. to his questi ons, Hunnicutt and Smith stated that the damaged areas.would be repaired using approved procedures af ter the completion

.of.the hot functional tes ts.

Iha inspect:r advised Hunnicutt that he would want tc review the documentati:n : elating to the repairs. Hunnicutt stated that this inf orma:1cn would be available for review.

DEIAILS A.

Persons Centacted Duka.P wcr Coccany (Duke)

J. C., Rogers - Project Engineer, 0;snee and M;Guire D. G. Beam - Assis tant Project Engineer, Oc; nee G. L..Hunnicutt - Principal ileld Endineer C. B..ayceck - Field Engineer, Electrital J. M..Curtin - Quality assuranta Supervisor, Mechanical T. H..McDaniel - Assis tant Field Engineer, Civil J. E. Smith - Plant Superintena-nt J. W. Hamp ton - Ase le tant Superintendent M. D. McIntcsh - Oper3 ting Er.gtnaa r R. M. Kcehler - Iechnical Sapp:::

Ea lace:

s O. S. Bradham - Ins er :mentatica ar.d Con: rs -. Engineer 3.

Organizati:n and Adm! nis t ratica 1.

.Cc epar ate Organ;2ation The licensee has made extensi.e changes in his corporate organization.

The. principal individuals aire:ted and their'new titles are as follows:

Charl tte Corpcrate Crrice C. Hc en, J r. - Pres ident 1/ Letter. tr:m Duke. (Thies) c: Regica l' -(Davis) dated August 6,1970, 2/

-- Inquiry Memc:andam, ' Region II (Sciale)"ta C:mpliance Headquarters dated May 2,-1971.

C0 Rpt. No. 50-269/71-5 #r W. S. lee - Senicr Vice President, Engineering and Construction W. H. Owen - Vice President, Engineering I. F. Wyke - Erincipal Mechanical Engineer Oc nee Field Office D. L. F:eeze - Field Engineer, Civil E. E. Sibley - Field Engineer, Mechanical R. E. Blaisdell - Field Engineer, Welding - NDT M. W. Fester - Field Engineer, Office 2... Review and Audit Ccomit tees

.The menbership of the Station Review Committee (SRC) and the General Office Review Committee (GORC) are as follows:

SRC i

J. W. Hampton - Assistant Plant Superintendent, Chairman M. D. McIntosh - Operating Engineer R. M. Koehler - Technical Support Engineer E. D. Brown - Maintenance Supervisor C. L. Ihames - Health Physicist GORC L. Lewis - Duke Statf Health Physicist, Chairman

. S. E. Nahow - System Production Engineer.

.P. H. Barton - Manager, Technical and Nuclear Services J. E. Smith - Plant Supa rin tenden t E. C. Fiss - Staff Nuclear Engineer J. L. Ellict - Engineer, Design Department Dr. R. L. Murray - Head, Nuclear Science Research Center, e

North Carolina State Univetsity C.

Quality Assurance 1.

Table A Reautrements The inspestor was shewn a copy of a letter f rom Owen., Principal hachanical Engineer, to Watkins, Vice President, Construction, dated Ap r11. 5, 19 71.

This letter s tated in part:

"... Enclosed are the final certification noticer, Form QA-6, f or the follcwing preces of equipment for Oconee 1.

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h CO Rpt. No. 50-269 71-3.

B ea : rc t-Cccler.c Piping Re.ctor Ccolant Pumps RC-PlB2 Reactor C clant Pumps RC-PlA2 Reat:ct Caolant Pumps RC-PIBl Re ctor Coal.nt Pumps PC-PlA1.

Valve LP suction lLP-V6B

"... This csmpletes Table "A" quality assurance final certifica-tien requirements...."

The inspector considers this item to be complete and plans no further

. action at this time.

2.

Consolidated Listing cf Ccnstruction Cccoletica Items Hunnicutt advited the inspector that since the last inspection the

. licensee had instituted a procedure for the documentation of dis-crepancies noted in the piping systems, the action taken to correct

.the defic 1=ncy, and a certification by the QC inspector when the

. corrective acti:n had been completed.

He had also instituted a consolidated list of items remaining to be completed for each piping

. system. The inspectcr did not note any deficiencies in the method

.as. described. The inspector asked if the same system was being

.used for cther =4ch&nical and civil items. Hunnicutt advised the

.inspecter that this question had not as yet been resolved but he

. believed that the same or a similar system would be developed for other. items.

Ihe inspector told Hunnicutt that the documentation would be re viewed during future inspections. This item was discussed

.during the Management Interview.

3.

Verificat lin ct Nuclear Valves to Design Scecificationsl/

.The. inspector advised Curtis that the licensee would need to provide Compliance with aosurance that valves manuf actured by Crane Valve Divisi:n, Crane C,.spany (Crane-Chapman) and Darling Valve Company

.(Darling; had been dimenstenally checked to verify wall thicknesses.

In.additicn the iicensee must be able to verify the operability of the valves at d= sty. :caditions.

Curtis advised the inspector that

.he would try to provide this information during the next inspection.

1 D.

Construction Progress

.l.

.The health phystem f acilities, with the exception of the laundry facilities, have been completed.

1/ Letter from Cemplian;e Headquarters (Engelken) to Region II dated April 12, 1971.

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00 Rpt. Gi. 50-269/71-5,

2.

Ite chemis try labor.cory f acilities are essentially complete.

3.

Insta11stica cf the medifications to the main steam line pipe hangers has been c:mpleted.l!.

4.

Instal 15tica ci replamement strain gages to be used during containment praof testing has been completed.2f 5.

The scdificaticus to the Keowee bat:ery room ventilation system have been tcmpleted.2/

6.

Ihree cf the reacccr coolant pump motors have been operated for perieds of cne hour prior to coupling to their respective pumps.

E.

Construction Schedule The fc11 swing dates were given the inspector by Hunnicutt as the best informacien a;ailable to the licensee.

1 Earliest Las t 1.

.Reactcc C;olant System Hydrostatic Ies t 5/25/71 6/22/71 2.

Main St.am and Feedwater Systems Hydrostatic Test 5/28/71 6/25/71

3... Start S z cuctural Integrity Tes t 6/10/71 7/10/71

.4.

_ Start Het f..cticnal res t 7/14/71 7/14/71 5.

Recwee Fa.tctional Test 6/10/71 7/10/71

.6.

. Fuel Lcading 8/71 8/71 F.

. Fuel.Baaditcg Cranes

.The. inspector was shcun a copy of an in-house report relating to the

..correctica ci the deficiencies previcusly reported relating to the

. indexing or the trollies en the fuel handling cranes.S/ The report indicated tha: :he excess tie lateral (or north-south) movement of

.the. trollies had been corrected. The correction had been achieved ~

.by.installicg additicnal guide rollers, realigning the bridge rails,

.and taking up backlash in the gears. In respcase to the inspector's

. ques tions, Hunnicutt stated that the licensee was of the opinion that the excessive lateral cotton of the bridge could be corrected in the 1/ Outstanding Itums List, Item 2 7.

1'/ uts tanding Items L s t, Item 54, 0

3/ Outs tanding I tems L = t, Item 55.

4[/C0ReportNo. 50-269/71-4

CO Rpt. No. 50-269/71-5 ~3, same manner as used to correct the lateral motion of the trolly. He further stated that the rotational motion of the fuel in the mast

.was not now considered to be a problem since some freedom of movement was desirable. The inspector reminded Hunnicutt that the clearances between the fuel asser'ly lower end fitting and the lower grid pads

.were very small and st ted that prior to fuel loading he would want to see the results of the licensee's evaluation of the problem together with the results of the tests using dummy fuel assemblies. The evaluation would be necessary to assure that the fuel assembly with the smallest as-built clearance would enter the lower gris with maximum deviations of

.the fuel handling crane mast. Hunnicutt advised the inspector that the in-house report relating to the cranes would be available for the

. inspector's review and that the cranes would be tested with dummy assemblies.

G.

Electrical and Instrumentation 1.

Control Rod Drive Controls - Attachment H a.

Followup Records Review and Observations of Work (5105)

The control rod drfve AC component cabinets were visually inspected and found to be installed in accordance with approved drawings with the following exceptioc:

A field modification made in the CRD AC regulator mountings was not indicated on the drawings. This modification was required because the anchor bolt holes in the base angle of the cabinets were at 90' to the floor surface. The base angles of the cabinets were welded to the floor insert plate.

Based on the licensee's agreement to revise the Duke drawings, no further action on this item is planned at this time.

b.

Records Review (5105.05)

The inspector audited the " Electrical Instrumentation Equipment

. Installation Inspection" records. These records documented equipment initial ins tallation inspections, deficiencies, followup inspections, and completion signoff by the QC inspector. The Compliance inspector found the documentation in order and plans no further action on this item at this time.

c.

. Control Rod Drive DC Breaker Cabinet The licensee has performed functional tests on the equipment in the control rod drive DC breaker cabinet which had been damaged in

. storage.1/ The inspector informed the licensee that he probably would review the test results during a future inspection.

1/C0 Report No. 50-269/71-4.

CO Rpt. No. 50-269/71-5...

2.

. Nuclear Instrumentation - Attachment H Follewup Racceds Review and Observations of Work (5105)

The nuclear instrumentation rack installaticn drawings were reviewed and spot checks were made of the anchors. No deficiencies were observed and the inspector plans no further action on this

. item at this time.

3..Pressurizar Level Instrumentation - Attachment H

. Followup Re ctd Review and Ctservations of Work (5205)

The inspector verified that the installation and routing of the pressurizer level instrument cables were in agreement with cable routing sheets and approved drawings. The cables were inspected

.from the level transmitters through the containment penetration

.EA9.to terminati:n at the ICS cabinets in the control room. No deficiencies were observed in these installations and the inspec-

.. tor. plans no furhter action en these items at this time.

4...Uninterrruoted AC Power Sys tem - Attachment I

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..Follcwup Observattens of Werk (5105)

.The.9.3 KVA static inverter installaticas were visually inspected and the drawings reviewed. No defi:lencies were noted and the inspectar plans no further action en this item at this time.

5.

Battery Sys tem - Attachment I a.

Foll wuo Aecords Review and Observations of Work (5105) i The inspecter reviewed the control battery installation drawings

.and inspected the battery room.

The installation of the battery was in acccedance with the approved drawings and no ' deficiencies were cbserved.

Ihe inspector plans no further action on this

. item at this time.

b...Other Items Inspected in Batterv Rcom

.Ihe inspector cbserved that an instrument air line remained in the battery room and a 11oor drain 'line serving the elevation

.above the batteries did not have a guard installed to prevent

. spills ento the batteries. At a previous inspection the

. licensee -had agreed te remove the ' air line and install the guard.1/

These itees remain unresclved.

1/C0 Report No.-50-269/71-2.

ab 1

i C0 Rpt. Uc. to--ic4<.;-5 t -s 6.

Cab l.2 3 Ihe it enice :+ c c:.t i. a ag,

c, g: &2crai cable installations-by

. adding trays aa-1 sup;~ r t i ihs laspe :t.r s reviewed the installations to det.a rs:ne p. g:ce s 2.l>

a. r rs: ting de t'iciencies observed during a prev;cus inspe;:1cn.1/

i: w a, cbe e rved that power cables approaching

.pcwer panel baarda IDsD ca t 1KVIL, yellow cable in vertical. trough

.lT44, p:wer caole IEA *4, cabic ItX514, cable 1DiL479 and gray cables through 51c=ve N.

6 in cable spreading cc a now appear to be

. adequately auppetted and pretected.

in additbn, cables to the power panei boards and the 500MCM battet;..bles had been field painted.

.These seven items are n 4 censidered resolved.

The inapector discussed tr.e remaining unresolved items with Aycock.

. Aycock agreed c: the installation of a metal barrier plate to pro-

.tect the green cablea ta Icgic panel EF5LP2 and the installation of additi:nal tray hangers tc sapport 90 bends in sagging cable trays

.near logic panel boards Ef 5LP1 and 3.

Excessive tray fill continues to tna a pt;blem. The : aspect:r advised Ay c k that these unresolved

. items wculd be reviewed at a future tnspection.

7.

.B 2T. 5vi tch ge a r kflashcVec,duec:. ch;rc stetutt,

.,c

.arred in the B2T switchgear when an attemp t aas mad tc Supply tr.= Unit 1 41t0 volt main feeder bus fcca Lee 6:4am stati:a.O Ihe C pliance inspector examined

. the.b reake r inte rnals b at its cet _Le erve any significant damage. The

.inspectar advi3ed Aycccr. cnat he ;uld be interested in reviewing the test results ef the t apal:sd unit.

Aycock stated that the

.results wauld te tale avallatl- :: tne inspector.

8.

. Fuel Handia:..: i_ i L i g:. :,

.During the inspe :::ca ut tns ts2_: : s =asel internals, the inspectors

.cbserved'that the p :1 lamps had

acning note cast into the

. housing wht:h ststed that the larpo

4 t nat be immersed in water to.

.a. greater depth than t42 fiet D.e inapuctors advised Hunnicutt,

. 5:1th and Aycect tn.t the licantee cuat be able to document that the lamps w;uld with:tand being sub e:ged to greater depths prior to fuel

'loadiag. Hann:c ut t aa;; sed tre insp4;t; that this would be done.

11.

P re:pe rat ic s ol re s t a r._z - ur nhn<.c: M 121 3s0d/2)

.1.

lhe ; asp,ct;ra.teu i t s e i. u. e p t p cat; nat testing program to further evaluate he',dequa.j;. tr.,pr..s22:23, the results of the tests,

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1/C0 Repert Na.-50-2ci4 ?l-1, 2/ inquiry nescr.:.a.: 2 tm2 M.g. a 29,1.

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CO Rpt. No. 50-269/71-5 -

adherence tc the Guide and compliance with the testing evaluation i

and audit requirements of Appendix B tc 10 CFR 50.

The following four precperational tests were reviewed:

IP 200 16, Reactor Caclant System Cleaning IP 2012, Ccre E1:od System Hydrostatic Iest TP 202 8, High Pressure Injection System Flush IP 203 7, Lcw Pressure injection and Core Flood System Flush The inspectcrs observed inadequate control in each of the four pre-operational test procedures reviewed. Three of the four tests contained from one to eight changes that were not made as described in Duke's Guice At least one tes t cantained insufficient documentation to verify that all points of the acceptance criteria had been The results of one test had not been reviewed in sufficient met.

detail :o ensure tha: all incended cleaning had been completed and that all discrepant items had been noted, The first procedure reviewed was the Master File copy of TB 1 B a.

202 81, High Pressure Injection Flush. The test was conducted between January 19 and 29,1971. As per Duke's test program Guide (February 5,19 71>, the mas ter file contained the record 1

of the tes t perfo:mance and the approved minor changes to the procedure. Seventeen minor changes to the test procedure were recorded and approved. The inspector reviewed the changes to the precedure and noted the following discrepancies:

(1) Changes in paragraphs 9.0,12.29 and 12.30 were not documented and appec<4d.

(2) Minor ch nge N 12 Indicated paragraph 12.21 had been char.gea and apptc ved but in reality, paragraph 12.21 had not been changed.

(3) Paragrapn 12.25 centained cne change. This change was'docu-mented and approved under min:r change No. 5 on January 15, 1971, and also under =inor change Fo.16 on January '20,1971.

(4) Minct change Ncs.13 and 15 did not satisfactorily document the changes that were made to the test procedure. In addi-ti:n, paragraph 6.9 had been changed but not adequately documented.

b.

Procedure TP 1 B 203 71, Lcw P: essure injection and Core Flood System F.csh, was e elesed by the inspectors and the following items were noted:

T

CO Rpt. No. 50-209/11-3 (1) Ihe blue change opptc /ai sheets listed 32 minor changes.

(2) A minot char.ge to the procedure in paragraph 12.10 was not recorded ar.d appes ved on the char ga approval sheet.

(3)

Valves HP 155 nd 156 were acded in paragraph 12.2 by an approved minor change without a corresponding change to the valve lineup sheet.

(4)

Data entries at the apparent conclusion of portions of the system flush indicate a slight discoloration of filter paper in violaticn of acceptance criteria of no discoloration.

Two tests which had been c:nducted more recently were reviewed in an effort to determine whechar cr not the licensee was, with experience, improving in following the Guide.

a.

The reactor inspector reviewed Tes t Procedure TP 2012, Core Flood System Ccntrolling Procedure for Hydrostatic Test, which was ccnducted between February 28 and March 3,1971. Three minor changes to the procedure were recorded on the blue change approval sheet. One of the three approved minor changes permitted relocating the hydro pump to a pcint downs tream of the boric acid pump, CA-P3.

This change was required because the hydro pump 4

could not pump through CA-P3.

This change resulted in the boric acid pump and the section of piping between valves CA-25 and CA-26 not being hydrostatically pressure tested. The failure to hydre tes t chts pump and piping was not recorded on the discrepancy sheet, which by the licensee's procedure is the proper place to itemize all tes t deficiencies.

Furthermore, the licensee furnished no evidence which wculd indicate the discrepancy had been picked up and chat the pump and piping would be hydrestatically tested at a la te r da te. Since the above =odificaticn actually changed the intant cr the procedure, it was a major change and by Duke's rules shculd have been reviewed and approved by the SRC. McIntosh disagreed with the inspector's interpretation of major change and indicated that in his opinion the change had been handled correctly as a minor change.

b.

Test Procedure IP 200 16, Reactor Coolant System Cleaning, had just been ccmpleted and preparaticas were being made to instali the reactor vessel head. The reactor inspectors reviewed the

~

test procedure, a lagbook recording threnological cleaning progress, the summary of sample results, and portions of the chemical laboratcry analysis reports.

The procedure appeared

mad' ge% Eme; %

-m----

C0 Rpt. No. 50-269/ 71-5 m to be well' written and tollowed the Guide.

In addition to a record of the cleaning, the logbcck notao changes to the reaccor coolant system which afiected the cleaning; for example, when a pu=p was removed or a section ci piping was opened.

The legbeck also documented the results of samples such as patch test discoloration, and flush water chloride, floride, and conductivity.

Ihe results ci the cleaning samples were recorded en several chemical laboratory analysis reports, and a su= mary of these reports had been prepared.

The f cilcwing cbservaticns were made during the review of the test procedure, the logbcok, and the cleaning results:

(1)

There were ne changes to the precedure recorded on the blue change approval sheet although the procedure had been changed.

For example, the main ecolant joint identtication numbers for Unit 1, which is a part of Procedure TP 200 16, were not used to identify test results.

(2) A1:htugh sample results had been simmarized, there was insuf fi;1ent dccumentation to verify that all points of the acceptance criteria had been tet.

(3)

Ihere was nc evidence that the procedure, logbook, and sarple results had been reviewed to pick up all discrepancies.

Koehler ackn:wledged that tes t results had not been reviewed to ensure that all intended cleaning had been completed and acceptan;e criteria had been met.

(4) Ne audits had been made of these tests as required by the licensee's Guide.

The results et the inspector's review or the tes t procedures and data were discussed with Smith, Ha=pton, McIntcsh and Koehler.

They were advised that based upon this review, the implementation of the test program appeared-to be inadequate to satisf actorily demons trate that the plant could be safely operated. The inspectors reminded Salth that during the previous inspection,l/

the general inadequacies of the test precedures had been discussed.

Smith was advised that the licensee appeared to be in nonconformance with 10 CFR 50, Appendix B, in that the test procedure changes had not been prcperly documented, that correction of discrepancies in test -results had not been made and the results of the tests had not been adequately evaluated.

In addition the licensee had 1/CD Report No. ' 50-269/ 71-4.

_ -. ~ _..

C0 Rpt. No. 50-269/ 71-5,

not perf ormed as requi:ed by 10 CFR 50, Appendix B, to determine that his test pr: gram was be:ng properly implemented. Smith was informed that 2 CDN wonid pecbably be issued relating to these two items.

These dericiencies were discussed in ;he Management Interview. Ihe inspector will continue to review the implementation of the test pregram during future itspections.

2.

Reactor Buliding Scrav system Tes ts The licenseo has experienced numercus problems with the reactor building spray-pumps.

These included motor bedplate vibration, pump shaf t misalignment, off tenter impeller and out-of-round casing.

The pumps were returned tc the manurscturer for repair in March 1971.

The inspecter was sh;wn a report prepared by the manufacturer that indicates. that the defects wece ccrrected and that the pumps were run at the design peint for cne-half hsur.

In response to the inspecter 's questi:n, Smith s tated that the licensee did not plan to functionally test-the pumps to demons trate that they would deliver water at dasign operating pressure to the elevation of the reactor Ihe inspettor had i

l discussed the

. building spray header.

this sys:em with the licensce / prev ous y l and DRL has indicated testing ct that. the pump delivery perfc cmance must be demonstrated.2/ The inspector advised Smith that all s alety feature systems should be l

tested under cp= rating canditicns. - The previous failures of the spray pumps moxe their testing particularly important.

3.

Safety In3ettien systees Testing Smith. advised the inspe:cor that the licensee did not plan to test the high pressure injecticn system at operating ' conditions. He f urther uds ised the inspectcr that the low pressure injecticn system would not be tes ted in the cecirculaticn mode, i.e.,

taking suction f rom the emergency susp, althcugh this mode of operation would be necessary in the event of an accident.

The licensee considers the normal operatica of the high pressure injection pumps in supplying seal water tc the reactor c olant pu=ps and makeup water to the coolant sys tem as suf ficient to demonstrate the pumps capability to. perform its emergency fun.tien.

The emergency sump elevation is insufricicnt to provide the new positive suction head required for the operation of the Ics pressure injection pumps. Under accident 1/C0 Report Nos. 50-269/70-!1, 71-1 and 71-2.

1/DRL Report Ne. 2 cc ACR5 dated deptember 2, 1970.

i CO Rpt..No. 50-269/71-5,

conditions, the water level in the reactor building would provide -

the addittenal head required for these pumps. The inspector advised Smith that the licensee's pcsitica en these tests would be referred to Compliance management for, resolution.

I.

Startup. and Pcwer Ascensten Tes ts 1... Generator Irip Iest

.. The inspectors were advised by Smith and Hampton that the licensee

.would perform a generator trip test at 100% power.

2.

.Centrol Red Testing Smith advised the inspector that the 11;ensee did n:t plan to perform

a. simulated r;d ej=~ tion tes t at a high pcwer level nor did the licensee plan to perform a red decp test.

Ihe' licensee does not

. consider that useiul information could be obtained from these tests.

Smith was advised that the licensee's position relating to these

. tests would oe dis cussed with Compliance management.

3.

Miscellanecos Tests t

.The licensee is ;or.sidering pertarming a pressurizer effectiveness

. test.and a measurement of the pressure reactivity coefficient but

- has.not stated a positica on these two tes ts.

The inspector will

. review.this item en the next inspe: tion.

The licensee will re=ove the acceleremeters trom the reactor vessel after the hot functional

.. test.and will not monitor fer internals vibration af ter core loading.

J.

Health Physics Prcgram The. inspectors dia ussed the health phy'si-:s manaal and health physics Procedures EP 1, HP 2, HP 3 and RP 7.

(See Exhtbit B.)

Ha=pton advised the inspectors that :he c=ments would be ::rwarded to Lewis, Duke Staff

. Health. Physicist.

K.

.ControlRod Drive Mechanis=a - Ins ta11atica ( 5105.05)

The. reactor inspe;tc r reviewed th:ee logs maintained at various periods

between; January 23 and March 12, 1971, by perscnnel of Babcock and Wilcox Company (B&W) and Duke during the installati n of the centrol red drive

~

. mech anis :s. (CRDM's ). Ihe reatter inspector noted six log entries which described problems encountered during the installation of the CRDM's,

.for.which there were :no sLbseqoent Icg entries describing the resolution

.of _ these.appa rent p r;b ie ms.

Ihe six leg entries were discussed'with

.Hunnicutt, and.M:Daniels, who fcli ved 'the installation.cf the CRDM's'.

They' were able. to 3hmw cocumentatiec c c otne rwise indicate to the inspector that these pecblems had been satisfatterily resolved.

CO Rpt. No. 50-269/71-5,.

The progress and pt blems of installing the CRDM's was recorded daily by

.B&W's.Ellison who was the engineer in charge of the actual work. Ellison's log entries were detailed in the daily progress, but were limited in

. details of the problems encountered. When his log entries did contut

. descriptions of problems, the solution was generally included.

Roberts a

. and.his supervisor, McDaniels, followed the installation of the CRDM's for Duke. Their log entries were generally more problem oriented and contained less inf ormation r-14tive to the solution of the pro'alem.

The. inspector was satisfied as to the adequacy of the installation of the CRDM's and the apprcpriateness of followup actions. No further action

.is. planned on this item at this time.

L.

Control of Temocracy Circa;c Madifications In response to the inspector's questions, Smith stated that the licensee

.did.not. presently have a procedure that would ensure that a record would be kept.of the temporary jumpers that were installed or the leads that

.were. disconnected to permit testing cf the variors systems. He stated

.that.a. procedure would be developed and that it would be available for

. review.during the next inspectica. The inspector advised Smith that he

.would. periodically inspect to assure that all lif ted leads and temporary

. connections could be identified. The inspector will follow up on this i

.iten.during the next i n.s pec ti:n.

M.

Temocrary Storage Facilities for Fuel Assemblies

.During.the previous inspection,l/ the inspector had emphasized the need for periodically load tes ting the storage building crane and the mobile

. crane which is used to unload the shipping containers from the transport

. truck.

Smith advised the inspector that testing these cranes was now required prior to moving the f uel.

In addition, Smith s tated that the

. building was being cleaned and wculd be kept clean.

N.

. Reactor Ceolant Puens (4905)

..The. inspector witnessed the operacien of the lB2 reactor coolant pump

. motor...Each. pump motor mus t be run for one hour prior to coupling it

.wi th i ts. p ump.

Ihree of the motors had been operated satisfactorily at

.the. conclusion of the inspection. The fourth motor could not be run

.because.of a defec tive electrical penetration. No deficiencies were i

. noted in the ins tallation and protection of these components and the l

. inspector plans no further action en this item.

Attachment :

1

. Exhibits A and B 1/C0 Report No. 50-269/71-4.

l

~V LICENSEE Duke Power Company j

i FACILITY Oconee Station No. 1 i

DOCKET E: LICFliSE NOS.

50-269, CPPR-33

'REACTUR OUTSTANDING' ITEMS f

IDENTIFIED ITEM CLOSED I

i 1.

68-2,3/5/68, Concrete test cylinder breaks belov specs

.68-3, D.5.,

i NC 6/19/68 2.

68-3,6/19/68, Unauthorized revision to cadveld specifications 68 h, Su-ry, E

9/25/69 l

3.

68-3, 6/19/68,.

Failure to provide concrete inspector 68-h, Su m ry, E

9/25/69 l

4.

68 h, 9/25/68 Failure to properly test Cadweld splices 69-1, Sumary, E

1/6/69 l

5 69-8,.9/9/69, Failure to properly qualify veld procedures 69-9,G,11/3/69l E!

l 6.

69-8,!9/9/69, Failure to properly qualify veldors 69-9, o, 11/3/69 i g ;.

7 IZB,I6/11/69.

Procedure for repair of are strikes not available 70-5, Su=ary, h/27/70

.8 CDN,1/8/70 NDT of core flooding valves Me=o, WCS to HQ, l 2/2/70 I

9 70-1, 1/6/70, Welding and NDT deficiencies, CDN issued Memo, WCS to HQi,

E, 3/26/70' 10.

m,'ngham 69-1, Main coolant pump discrepancies Hemo,'WCStoHQ,l 12/9/69, E h/21/70 L1.'70-h,h/27/70',

Lov strength concrete 1~

Memo, WCS to HQ, f -

E 8/7/70 I

l L2.

IEB,5/1/70 Pressure vessel safe ends Memo,WC5toHQ,!

8/5/T0 i

L3.

70-6, 5/25/70, Tenden stressing discrepancies Mer.o,WCStoHQ,[

E 8/7/70 th.

70-8, 8/3/70, Tendons and stress gages Memo,WCStoHQ,l E

10/8/70 i

15.. 70-8, 9/1/70,-

Fissures in primary coolant pipe cladding' FSAR, Amend.24, t E

12/17/70 l

4 L6. IZ3,9/11/70, a.

Determination of safety system respense to axial l

E pcVer imbalances b.

Availability of in-core detectors For IDENTI/IED Column: S, safety item; NC - noncompliance or nonconformance '

item: UM - unresolveE ltcm; IN - inquiry itcm; IEB - Reactor Insnoctioni-and! EnTErececnt branen requesC; ~O - other source of identi. fist. inn (tpi.r il'sp: w rn 8 Q Q e

l Exhibit A

'5 j

. t.'.

t,' -

Pyge1of'7 j

NM i

h.t 4

J i

LICENSEE Duke Power Company FACILITY Oconee Station No. 1 i

DOCKET E: LICFRSE NOS. 50-269, CPPR-33 !

j l

REACTOR OUTSTANDING ITEMS l

IDENTIFIED ITEM l

CLOSED I

I

16. (Cont'd) c.

Measurements of flow and temperature during initial operation d.

Verification of bypass flow e.

Verification of axial peak effects en DNBR f.

Data during startup for single loop, two pump operations jl g.

Inspection of reactor internals after completion of preoperational tests

- ' ~ ~ ~

~

b.

Field test of steam generator l

i. Lov strength concrete and omitted tendons Memo, WCS to IQ, 10/8/70 l

J.

Penetration room valves 70-12,Summarh 12/1/70 l

k.

Strain gauge failures Memo, WCS to HQ, g

lag 8/70 1.

HP and LP injection system startup times m.

Core flooding u.r.a MO valve s

n.

Reactor building spray pump performance o.

Condenser cooling water crossover header valve l

p.

Spent fuel ' accident filters e

q.

Administrat'ive control of MCP startup r.

Flev tests her 200/12 and 200/13 i

l s.

Flev distribution chart 6

P - IDENTIFIED Column: S - safety item; NC - ncncomoliance or nonconformance Atem; UN - unresolvec item; IN - inquI"Ty item; IIB - Reactor Inspection and EnTercement Branch requeliT; ~O - other source of identification Q1tri nNft :nnccitts) f Exhibit A

-- ) -

5 y,'y..

l e

r:.:Page 2 of.7 e.,

.u

[:.t-

.1.. y 4

.u+

D i

i LIC ENSEE Duke Power Company l

FACILITY Ocor.ee Station No. 1 I

_l i

?

l DOCKFf 8: LICFllSE NOS. 50-269, CPPR-33i l

i REACTOR OUTSTA!iDII;G ITEMS _

IDENTIFIED ITEM l

CLOSED 17 70-2,2/19/70, Vendor NDT records, for safeguards systems cables 70-11, F, 10/26/70 g

j

18. 70 h, 3/23/70, verification of separation of transducer tubing E

19 70-8,8/3/70, control rod drive guide bushings and torque tubes 71-3I, 2/24/7:;

E 20.

70-8,8/3/70, Completion of HP facilities (laundry facilities)

E i

21.

70-8, 8/3/70, Completion of HP procedures E

22.

70-8,8/3/70, Completion of HP personnel training 70-12, summary E

12/1/70 l

23.

70-8,8/3/70, Crane load test 71-1, 1/4/71 E

24.

70-8,8/3/70, Veriff that test procedures are properly revised and E

approved when changes are requirea 25 70-8,8/3/70, Verify that analysis of containment is made FSAR, Amend.

24 E

'26.

70-8,8/3/70, A..d.e'qdatd] fuel handling precedures 27

'to-8,8/3/70, Main steam pipe hangers 71-5, Section D, E

5/1h/71 1

28. 70-9,9/1/70, Steem generater skirt adapter indicaticns E

29 70-9,9/1/70, HP injection pump QC records 70-11, C, UN 10/26/7C 30.

70-9,9/1/70, Basis for particle size in flushing procedures 70-11, G, 71-4, C 10/26/70 and UN 7

I 4/6/71

, 31. 70-9,9/1/70, Protection of i;nstrumentation during hydro test 71-4, G, 4/6/71 1

UN

{

~

. ' 32.

7050,9/28/70, Fuel transfer tube expansion joint replacement

-- 713i], T[2477f 7

3

33. 70-10,9/28/70, Ecuting of cables exterier to cable trays Memo, WCS to HQ 1/18/71 E

l l

~ 2 or IDENTIFIED Column: S - safety item; NC - noncompliance or nonconformance UN - unresolvec item; IN - inquEy $ tem; 2E3 - Beactor Inspection' item; ?orcement Eranch requcliT; O - other source of identificaticn.

andi Fa

~

Ulri,PWFr nneciCyd l

Exhibit A l

11 ~ e.y rf l

'm y Taggr3 o.t 7

p

)

LICEIISEE Duke Power Company l;

6 FACILITY Oconee Station No._1-

,e i

DOCKET & LICiUISE NOS.

50-269, CPPR-33

{

REACTOR OUTSTMIDING ITEMS i

i IDENTIFIED L ITEM CI,0 SED 3h. DRL Rpt. No. 1 Installation of additional environmental monitoring 7/P4/70, E equipment 70 -4.

I,

35. DRL Rpt. No. 1 Vent valve replace::ient test 4/6/71

,7/2h/70, E

36. DRL Rpt. No. 1, Strong motion accelercaeter installation 7/2h/TO, E 37 DRL Rpt. No. 1, Penetration roca flov indication and adjustment 7/2h/70, E

, 38. DRL Rpt. No. 1, Instrumentation typass keys Tech Specs Change 7/2h/70, E 12/70

39 DRL Rpt. No. 3, Internals vibration test 9/15/70, E

'h0.

DRL Rpt. No. 3, Core flooding tank valves 9/15/70. E i

70-10,9/28/70, Hydrostatic test pressures 71-1, 1/4/71 E

h2. 70 b.,10/26/70,Cleaning reactor coolant system piping and equipment 71-2, 1/25/71 E

h3. 70-11,10/26/70,Sensiti::ed stainless steel in reactor coolant pump i

g discharge piping 71-1, 1/4/71

' 44.

IEB, 12/22/70 Reactor coolant pump tests 45.

IEB,;10/30/70 safety inj ection systen testing 46.

70-12, 12/1/70 Vibration tes ting - equipment and piping g

G 47.

70-12, 12/1/70 Location of station batteries (air piping and floor sc.

drain 4 l

'48.

70-12il2/1/70 Nuclear instrumentation vendor tests 71 h, G, h/6/71 6.'l l

'49.

70-12, 12/1/70 Electrical QC data packages 71-4, G, 4/6/71 E

t P3r IDENTI/IED Column: S - carecy item; NC - noncompliance 'or nonconformance Item: l'N - unresolve? Itc.v.: IN - inquIfy item; IF2 - Reactor Insnectioni and FnTErececnt branch requeTC; O - other source oi' identification (si.: < @ ;/. p + 'p, W g

k

~

Duke P'wer Company I

l LICENSEE

~'

o 1

i FACILITY Oconee Station No. 1

+

l l

DOCKET 6: LICi2iUE NOS. 50-269, CPPR-33l REACTOR OUTSTANDING ITDIS I

l IDENTIFIED I

ITEM l CLOSED 50.

70-12, 12/1/70 ITE relays

{

E j

51.

70-12, 12/1/70 Heater and heat tracing tests E

. 52.

70-12, 12/1/70 Control rod drive cooling system tests

, 53.

70-12, 12/1/70 Containment and auxiliary building vent system filters j

and tests 54.

FSAR, Amend 25 Installation of strain gages 71-5, Section D,

.12/30/70 5/h/71 UN 55.

71-2,1/25/71 Keewee battery room ventilation 71-5, Section D, uN i 5/h/71 I

71-2, 1/25/71 Switchyard battery blocking diode tests E

! 57.

7162, 1/25/71 Remove temporary steam line at 4 kv switchgear E.

I 58.

71-2, 1/25/71 Controlled leak rate tests UN l 59.

71-2, 125/71 Penetration room elevator opening 71-4, K, 4/6/71 EI t

60.

71-2, 1/25/71 Verification of separation of redundant circuits 61.

71-2,1/25/71 Cleanup of cab's trenches uni

-l 4

i 62.

71-2, 1/25/71 Adequacy of leak rate tests Telecon, 3/2/71 El Duke to CO:II 63.

71-2, 1/25/71 Replacement of feedvater pipe 71-4, K, 46/71 I

I 64.

71-3, 2/24/71 Cleanliness of reactor vessel and internals NC

~

j l

i i

T '" IDEIiTI/IED Co.iumn: S - cafety ite:n; E item; IED - Reactor Insncetion -

noncompliance or nonconformance item: UN - unrecolvec item:

IN - f.nquary and EnTerccment tranen request; O_ - other source c2 identification l(NtWi t ;r,r'cM'f9h j

Exhibit A 2.' '

A yf.j j

${

"?fg 5 of 7 -

f c :. ;

t

.a -

t

)

i

^i i

LICENSEE Duke Power Company i

h e

FACILITY Oconee station No.1 DOCKET 6: LICFli3E NOS.

50-269. CPPR-33 REACTOR CUTSTAiDING ITEMS _

i I

I I

ITEM CI.0 SED IDENTIFIED i

i 65.

71-3, 2/24/71 Drip pans on fuel handling cranes 71-4, K 4/6'71

/

E i

i j

Telecon,3/2/71 66.

71-3, 2/24/71 Containment leak rate tests W

Duke to CO:II 67.

71-4, 4/6/71 Cable tray fill E'

68.

71-4', 4/6/71 Reactor coolant pump QA documentation Mecio WCS to HQ E:

I 69.

71-4, 4/6/71 Control rod drive system d.c. breaker cabinet Memo WCS to HQ E

70.

71-4, 4/6/71 Welding rod control E

I 71-4, 4/6/71 Fuel storage records Memo WCS to HQ NC

~)

72.

IN, 5/3/71 Possible damage to vessel internals 73.

IN, S/3 /71 Damage to safety feature switchgear bus 74.

IN,34, 4/6/71 Fuel Handling Cranes

__,m-E 75.

71-4, 4/6/71 Testing Safety ; feature systems E

76.

71-4, 4/6/71 Power ascension test program WI I

77.

71-4, 4/6/71 Protection of safety feature switchgear i

78.

71-4, 4/6/71 Viking penetrations El 79.

71-4, 4/6/71 Procedure for coolant pump flows E

80. 71-h,5/h/71 Spentfuelpooklampsoperatingdepth W

For IDEI.71/IED Column: 3 - safety item; iry item; IE" - Reactor Inspection' NC - noncomoliance or nonconformance itom: UN - unresolveli iten:

IN - inqu and EnT6rccment branch requesC; ~O - other source of identification Qw."rmv: :neWW%

i Exhibit A x

.r

i

-: r *

,K C P,sge 6 ot 7 e

n.s i.e

't*

l

U I

i i

i LICEIISEE Duke Power Cn=pany m

{

FACILITY Oconee Statien No. 1 i

DOCKET & LICEilSE IiOS.

50-269, CPPR-33 REACTOR CUTSTA iDI:iG ITE'Q l

IDEtiTIFIED ITEM H

CLOSED

81. 71-5,5/4/71 Procedures for control of lifted leads and te=porar/

E jumpers l

l 82.

71-5. 5/h/71 Test procedure changes, evaluatiens and audits NC 1

83. 71-5,S/h/71 verification of nuclear valves to design specifications E

4 i

d m

\\

i

\\

i i

i.

I i.

i I

For IDE!iTIFIED Column: S - safety item; NC - noncompliance or nonconformance Iten; UN - unresolvec item; IN - inquI?y item; IES - Reactor InspectionI and lEn?Ercement Branch requeliT; ~G - other source of identification (fjer > C1.'t ct# ct t h)

Exhibit A 4 -

{

h..',$;,

7..

7 #I

,l' 73l. 7:.,.

i

=

HEALTH PHYSICS PROCEDURES t

COMMENTS j

.l. Procedures for Use of H. P. Portable Instruments Ins trument Comment PAC-4S No deficiencies noted PNR-4 No deficiencies noted PNC-4 No deficiencies noted FM-11 No deficiencies noted Model 490 No deficiencies noted E-120 No deficiencies noted PMC-4A No deficiencies noted PMC-4A (monitor) i Under " Operating Instructions" the limit of 1.0 mrad seems too high. A limit of 0.4 mrad /hr is nearer the current accepted practice.

RM-14 No deficiencies noted RM-15 No deficiencies noted 2.

H.P. Manual Page 6 - E.3(d) - The 500 mrem / year dose limit stated here for people a.

in unrestricted areas is not in keeping with the 170 mrem average for the population or the low as practicable approach now being taken by AEC with licensees.

b.

Page 8 - 5. Radiation Exoosure Control Measures C.

Although respiratory protective equipment should be worn when the unusual condition occurs that air concentrations exceed MFC, this is the nonroutine condition. The licensee must obtain specific authoriza-tion from the AEC to take credit for more routine use of masks in areas approaching or exceeding MPC. This involves a well planned and executed mask control program; i.e., fitting, cleanliness,

training, assignment of personal mask and proper storage, c.

Page 23 - 2.

Items of materials and equipment should not be con-ditionally released (~100 d/m/100 cm2,,,2 mr/hr @ 1 f t.) to unrestricted areas onsite unless health physics maintains complete control of these materials in the unrestricted area.

Pages 26 d.

Working Limits Contamination The contamination Z

2 levels (20,000 d/m/100 cm, beta gamma, 5000 d/m/100 cm ci) quoted la this section as levels that could routinely exist without efforts te decontaminate are considered to be high.

This is not good practice.

You do not want to establish a type operating procedure or criterion that leads to laxity.

Page 27 - 2.a - Not clear what applicable limits apply.

Exhibit B Page 1 of 2 3y.

Pags 29 - More than " reasonable" ef forts will be made to see that liquid and airborne effluents meet Part 20 limits.

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g H. P. Procedure No.1 Page 39 - Item 5 - Why record only 50 mr.

Page 40 - Item 6 - Should also investigate if only one dosimeter or pocket chamber is off-scale.

H. P. Procedure No. 2 Page 41 - Procedures should include statement that a lost film badge or other monitoring devices should be reported immediately.

H. P. Procedure No. 3 Page 43 - Provision should be made for periodic, complete reevaluation of Standing Work Perndts by Health Physics with corresponding updated approval of the Superintendent.

H. P. Procedure No. 7 Page 57, (3) - Should give some indication of actual level of contamina-tion on clothing or person.

If monitor shows high or off-scale reading, should get assistance in obtaining additional readings with appropriate survey instruments and handling of contaminated clothing, decontamina-tion of person and close control of cross contamination of other areas.

Page 59 - 6.

Conditional release and " released" tools should be com-pletely segregated rather than just placing all together on a shelf of the " cold" side of the Decontamination Facility.

Pages 62 H. P. needs to be in on decontamination of personnel.

Page 63 - Need precaution about using only proper sink for decontamination.

Page 65 - Procedure needs to specify H. P. participation in these activities.

Pages 72 p. 344 - H. P. should be in on spills, etc., in an earlier stage to assis t in, evaluation.

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