ML19322A631

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Responds to AEC Noting Noncompliance W/Fsar Sections Re QA Program.Corrective Actions:Analysis of Over Filled Cable Trays Underway,Addition of Cables to Overfilled Trays Stopped, & Addl Trays Installed
ML19322A631
Person / Time
Site: Oconee Duke Energy icon.png
Issue date: 05/13/1971
From: Thies A
DUKE POWER CO.
To: Jennifer Davis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19322A606 List:
References
NUDOCS 7911210701
Download: ML19322A631 (4)


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May 13, 1971 Mr. John G. Davis, Director U. S. Atomic Energy Cc~ission Division of Compliance Region II - Suite 818 230 Peachtree Street, Northwest Atlanta, Georgia 30303

Dear Mr. Davis:

The following are our responses to your letter of April 14, 1971 questioning items which apparently do not conform with statements in the Oconee Nuclear Station Final Safety' Analysis Report or with Appendix 3 to ICCFR50, " Quality Assurance Program for Nuclear Powar Plants."

1.

Per nissible Cable Trav Fill - Final Safety Analysis Report, Section 8.2.2.13 Original cable tra; requirements were based.on estinated quantitics and cable types foreseeable at the time. The cable trays actually installed included these requirements, plus nargins for the unforseen.

In many places, as much cable tray as practical with respect to the available physical space was installed.

Since then, many additional cable requirements have developed over and above those for which cable tray provisions were made. In addition, higher grade cables with overall protective ar ors have been selected and installed. These cables have approxi=ately 50 percent greater diameters than originally anticipated.

The result of this has been that some cable trays containing centrol.

and instrumentatica cables have beccca overfilled _above the existing cable tray side rails.

The following action has been or vill be taken with regard to this problem:

a.

The cable tray overfill situation has been reviewed and identified by both the Engineering and Construction Departments.

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(O Mr. John C. Davis Page 2 May 13, 1971 b.

An analysis has been =ade of tha cable tray overfill situation.

This indicates that overheating is not a problem since the cables are control and instrunent cables and carry little or no current.

The cable tray physical loading is found to be within allowable loading. The worst case cf overfill was found to be within acceptable values with a safety fccror of 2.3.

c.

An analysis of the effects of the overfill on the seisnic icading on trays and hangers is "ceing parformed. If found to be necessary, structural modifications or additions will be nade to tha hangers l

1 or cable trays.

d.

The addition of cables in the overfilled cabic trays has been j

stopped and additional cable : rays have been added whcre necesscry i

and practical.

e.

For those cable trays which are filled above the tray rails, rail extensions will be provided to adequa:ely protect the cable.

t 2.

Reactor Coolant Puno Data Packaes - Appendix 3 to 10CFR50 - Cri: erica VIII The Reactor Coolant pump data packages have been reviewed by B&W and Duke Power and the data packages have been changed to corraspend with i

the pump position. The revised records are available for review.

3.

Control Rod D.C. Breaker Cabinet Dnrate and Inseection - Append 1n 3 to 10CFR50 - Criterion XV The control rod drive DC breaker cabinet was received by 3&W on the site November 17, 1970, and a receip inspection was prepared by Johnny F. Stokes of B&W. On Novenbar 18, 1970, the DC breaker cabinet-was over turned while'being handled in the #4 Warehouse, resulting.in visible damage to the cabinet door. This da= age was noted on the 317 receiving report. Inspection of the DC breaker cabine: was perfor:ad by C. B. Aycock, Field Engineer-Elec:rical,=and a breaker specialty crew, a few days later, when the. crew was on the job. A visual and mechanical check was made of tha DC breaker cabinet,.and no damages vere found-other than to the door, and the door was repaired.- The-

.results of~the check were verbally given to Bill Faasse, 35W Site

, Construction Manager, who requestad the inspection. B&W and Duke Engineering gave verbal per=issien to C. 3. Aycock to install the OC breaker cabinet, and a yellow QC 31 tag was applied to the breaker-cabinet prior to installa: ion. Af:er installing the DC breaker cabinet, s:

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O Mr. John C. Davis Page 3 May 13, 1971 an electrical control functional check was performed by the Duke Steam Department, and no proble=s were observed. The AEC Compliance In-spector observed no tags on the CC breaker cabinet during his inspection on April 6 - 9, 1971. Apparently, the tag had been removed while work was being perfor:ed on the DC breaker cabinet. Our tagging procedure does not require that tags be =aintained on equipment after installatica, only that tags must be placed on the equipment prior to installation to reflect the disposition of the equipment and associated Quality Control docu=entation. B&W had inadvertently neglected to document the checking of the DC breaker cabinet prior to installation, as reflected in chair incomplete data packaga. 21W will insert into their data pcekage the documentation of the inspectic.n check perfor1 d by C. B. Aycock, and the circuit breaker special:7. crew which will verify that the DC breakers or internal cc=poe.a :s were not damaged.

4.

Identification of Weldin2 Ee:s - Appendix B to 10CFR50 - Criterion VIII Appendix B, Criterion VI!!, of 10CFR50 states that the requirements ara such that identificatien and control are designed to prevent the use cf incorrect or defective ite=s.

The requirements of ANSI 231.7, Paragraph 1-725.2, indicate that legible =arkings are required to assure positive identification of the =aterial until it is actually consumed in the process.

Duke Power Company orders filler retal to specification requirements such that coated electrodes are clearly marked with ink sta= pings on the coating designating the electrode type, and bare filler =etal is flag-tagged with the filler metal type. The =sterial is received with mill test reports which give chc=ical, physical and other pro-parties of the filler =et:1.

The type designations on the filler metal are verified by these mill test reports. A general issue control systes is in effect to assure that only filler metal which has been properly received under the purchase specifications is issued to the welding crews. Verification of filler matal identification is acccc-plished by the welding inspectors prior to usa.

The legibility of weld metal type designations is =aintained cc the point of usage.

This type of procedural control assures a continuous monitoring systa=

that prevents the wrong type of filler cetal being used in a welded joint.

It is our opinion that the above procedure provides appropriate =eans to assure the identification of filler metal and prevents the use of incorrect or defective ite=s.

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Mr. John G. Davis Page 4 May 13, 1971 5.

Corvliance with coeratine ?recedure 0? 1503 02 - Final Safety Analysis Report, Section 12.3.1 Fuel is unloaded, unpackaged, inspected, and stored in the te=porary fuel storage building according to a written procedure. Attached to this procedure is a checklist for inspection and storage. Several of tha items of the checklist ara performed during the unloading, un-packaging, and inspection. Several items of the checklist are completed upon final storage of fuel assenbly in the fuel storage rack. One stap of the checklist for inspection and storage calls for the fuel assembly ID number to be recorded on a status board which is a diagram showing the location of the fuel assemblies in the fuel storage racks. During the fuel unloading operatien on April 1, 1971, Fuel Assembly 1C44 was placed in the fuel storaga rack. Upon completion of the storage operation the supervisor in charge init_. led the re=aining steps on the checklist, includict the item called icr recording the location on the status board. The ites was initialed with the full intention of i==cdiately performing the notation en the status board but due to a diversion of his attention at this point tha notation was not perfor:ed. This omission was noted by the A2C Cc=pliance Inspector on April 9, 1971.

I==ediately following the notation of the deficiency, the Operating Engineer discussed individually with each supervisor and the operating group the need for extra care to assure that each step of every pro-cedure or check list is completed prior to being initialed. In addition to this, the Superintendent held a meeting'of station supervisors to stress the importance of following written procedures and the docu-mentation thereof.

Also, a per=anent status board has been installed in the te=porary fuel storage building to give additional e=phasis to this part of the procedure.

We hope that this adequately answers your concerns, and if you need further infor=ation, please advise.

Sincerely,

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, vw-m A. C. Thies"l'y ACT:vr cc:

Mr. W. S. Lee Mr. E. D. Powell Mr. C. E. Wa: kins

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Mr. J. E. Smith 1,

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