ML19322A655

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Discusses Insp Repts 50-269/72-08,50-270/72-07 & 50-287/72-05 on 720822-25.Noncompliance Noted:Qa for Nonconforming Items Re Fuel Handling Not Implemented & Cable Installed Prior to Receipt of QA Documentation
ML19322A655
Person / Time
Site: Oconee  
Issue date: 10/26/1972
From: Jennifer Davis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Thies A
DUKE POWER CO.
Shared Package
ML19322A656 List:
References
NUDOCS 7911210717
Download: ML19322A655 (6)


See also: IR 05000269/1972008

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Ltr to Duke Power Comper.y

dtd 10/26/72

DISTRIEUTIO?f:

J. B. Hendersen, RO

J. G. Keppler, R0

RO Office of Operations Evaluatien

R0 Asst. Dir. for Precedures

R0 Asst. Dir, for Inspection & Enforcement

L, DD for Resctor Projects

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UtHTED STATES

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ATOMIC ENERGY COMMISSION

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W P C A C * T H E E 57 a C E 7. NC A T M * EST

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At _ ANT A. OCO AG' A KM3

DIRECT 0PATE OF REGULATORY OPERATIONS

In Reply Refer To:

October 26, 1972

RO:11:CEM

50-269/72-8

50-270/72-7

50-287/72-5

Duke Power Company

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Attn:

Mr. A. C. Thies, Senior Vice President

Production and Transmission

Power Building

422 South Church Street

Charlotte, North Carolina 28201

Centlemen:

This refers to the inspection conducted by Mr. Murphy and other members

of this office on August 22-25, 1972, of activities authorized by AEC

Construction Permit Nos. CPPR-33, 34, and 35, and to the discussions of

our findings held by Mr. Murphy and other members of this office with

Mr. Dick and other members of your staff at the conclusion of the inspection.

Areas examined d':-ing this inspection included reviews of repairs to Unit

i reactor coolrit system components, the program for resolving alteration

of radiographs, documentation of Class I piping, electrical component

and cable installation for Units 2 and 3, health physics and environmen-

tal monitoring programs for Unit 1, and preoperational testing programs

for Units 1 and 2.

Within these areas, the inspection consisted of selec-

tive c:caminations of quality control, test, and welding procedures and

representative records, interviews with plant personnel and observations

by the inspectors.

During this inspection, it was found that certain of your activities

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appear to be in noncompliance with AEC requirements. These items and

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reference to pertinent requirements are listed in Enclosure A of this

letter. Regarding item 5, it is our understanding that steps have been

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Iluke Power Company

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October 26, 1972

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taken to correct the documentation involved. No reply on this item is

For all other items, please provide us within 30 days, in

necessary.

writing, with your comments concerning these items, any steps which have

been or will be taken to correct them, any steps that have been or will

be taken to prevent recurrence, and the dates all corrective or preven-

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tive measures were or will be completed.

Our inspection of the vaste handling systems, radiation protection, and

environmental protection areas revealed cany items that remain to be

completed. These items were discussed with you. It is our understanding

that these items will be completed sufficiently prior to Unit 1 fuel

loading, to permit our review and evaluation.

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In regards to the items of noncompliance brought to your attention in our

letter, dated April 21, 1972, this is to advise you that we have no further

questions at this time regarding these items

Should you have any questions concerning this letter, we will be glad to

discuss them with you.

Very truly yours,

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John C. Davis

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' Director

Enclosure:

Description of Items

of Noncompliance

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ENCLOSURE A

DOCKET NOS. 50-269

50-270

50-287

Certain activities under your license appear to be in noncompliace with

10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power

Plants and Fuel Reprocessing Plants," as listed below:

1.

Criterion V, " Instructions, Procedures, and Drawings" requires in

part that " Activities affecting quality shall be prescribed by

documented instructions, procedures, or drawings .

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be accomplished in accordance with these instructions, procedures

or drawings."

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Contrary to the above, the inspector determined during dis-

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cussions with your field engineers that several procedures

which had not received approval according to your Quality

Assurance Program, Plan A are used by the electrical quality

cont ol group at Oconee. Examples of these are the storage

maintenance procedures for motors and for batteries.

b.

Contrary to the above, the inspector determined through discussions

with your field engineers and observations that Procedure Q-1,

" Control of Nonconforming Items," issued December 20, 1971, has not

been fully implemented by the electrical quality control group at

Oconee.

2.

Criterion VII, " Control of Purchased Material, Equipment, and Serviccs,"

requires in part that measures shall be established to assure that

purchased material, equipment, and services conform to procurement

specifications. Also, the documentary evidence that material and

equipment conform to procurement requirements shall be available

at the site prior to installation or use of such material and

equipment.

Contrary to the above, the inspector determined in discussions with

your field engineers that electrical cable has been installed prior

to receipt at the site of quality assurance documentation or receipt-

the site of certification that such documentation had been received

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by you from the vendor

3.

Criterion VI, " Document Control," states in part, " Measures shall be

established to control the issuance of . . . procedures, . . . including

changes thereto, which prescribe all activities affecting quality.

These measures shall assure that documents, including changes, are

reviewed for adequacy and approved for release by authorized personnel

and are distributed to and used at the location where the prescribed

activity is performed."

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Contrary to the above, the measures required by this criterion had

not been accomplished. Specifically:

Welding procedures revised and approved in June 1972 had not

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been distributed to the craft personnel or the field engineers

responsible for quality control.

b.

Test procedure TP 250/6, "HPSW Hydrotest," was approved by the

operating engineer on June 13, 1972, rather than by the plant

superintendent.

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Two changes made to TP 202/7, "HPI Operational Test," were major

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changes according to the definition as given in the " Guide for

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Conducting the Oconee Preoperational Test Program." These were

handled as t'nor changes. The first change is labeled as

Change No. 3 and added a section "to assure proper valve alignment

of HPI Pump "C" before operation", and the second is labeled as

Change No. 5 and added a requirement to check the CRD dilution

interlock.

d.

Changes made to TP 255/2, Loss of Instrument Air, were identified-

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in the body of the procedure. Change No. I was not listed anywhere

within the procedure and Change No. 3 could not be found on pages

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10,13, and 18 as stated on the cover sheet of the procedure.

4.

Criterion XIV, " Inspection, Test, and Operating Status", requires

in part that " Measures shall be established for indicating the

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operating status of structures, systems, and components

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Contrary to the above, the inspector determined through discussions

with your field engineers that the identification of cable involved

in the turnover of safety related systems was not always known and

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was not identified in turnover records.

5.

Criterion XV, " Nonconforming Materials, Parts, or Components", requires

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in part that " Measures shall be established to control materials. .

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which do not conform to requirements in order to prevent their inadver-

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tent use or installation."

Contrary to the above, the inspector observed quality control documen-

tation which cleared a defective reel of cable for installation in

safety.related systems. This reel,' Serial No. 04521, did not meet the

cable specifications-for color coding of the conductor insulation.

Your representative agreed to correct the documentation and prohibit the

use of this cable in safety related systems.

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6.

Critorion VIII, " Identification and Control of Materials, Parts and

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Components," states in part, " Measures shall be established for the

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identification and control of material . . . . These identification

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and control measures shall be designed to prevent the use of incorrect

. . . material . . . ."

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Contrary to the above, 316 stainless steel pipe and fittings were

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installed in systems.where 304 stainless steel is specified.

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Criterion XVI, " Corrective Action," states in part, " Measures shall

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be estab'ished to assure that conditions adverse to quality, such as

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. . . nouconformances are promptly identified and corrected. In the

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case of significant conditions adverse to quality, the measures shall

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assure that the cause of the condition is determined and corrective

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action taken to preclude repetition . . ."

Contrary to the above, one spool piece of fabricated. pipe for the core

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flood system contained eleven defective areas in four welds or eighteen

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linear inches that did not meet code requirement. The four velds had

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a total length of approximately 168 inches and the defects, therefore,

involved over 10% of the linear weld. The welding inspectors,

though aware of the defects, had not advised the field engineers

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who were responsible for quality control. No action had been planned

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to identify and correct the condition causing the deficiency and to

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preclude its repetition.

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Criterion XVIII, " Audits", requires ro part that "A comprehensive

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system of . . . audits shall be carried out to verify compliance with

all aspects of the quality assurance program and to determine the

effectiveness of the program."

Contrary to the above, the inspector noted during his review of an audit

of the Oconee electrical quality control program that the audit team

.did not identify the limited scope of their audit, determine the basis

for electrical equipment storage requirements, inspect for instrument

calibrations, inspect documentation of corrective actions or noncon-

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forming itens, or complete their check list for the audit. , In addition,

the check list used did not reference governing codes, regulations, or

procedures or otherwise provide acceptance criteria,

9.

Criterion XI, Test control, states, in part, "A test program shall be

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established'. . . (and) . . . test,results shall be documented . . ."

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Contrary to the above, in test procedure, TP 250/6 HPSW Hydro Test,

Section 12.1, item 9 had not been initialed or signed off as required

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by administrative procedures to indicate that the item had been

completed for those portions of the system coded orange and purple.

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