ML19322A671
| ML19322A671 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/01/1972 |
| From: | Jape F, Kidd M, Murphy C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322A656 | List: |
| References | |
| 50-269-72-08, 50-269-72-8, 50-270-72-07, 50-270-72-7, 50-287-72-05, NUDOCS 7911210726 | |
| Download: ML19322A671 (40) | |
See also: IR 05000269/1972008
Text
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UNITED STATES
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ATOMIC ENERGY COMMISSION
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REGION 11 - SutT E 818
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2 0 PC ACHT HEC ST REET. NOR1 HWEST
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A f e. A N T A , G E ORG e s 30 30 3
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DIRECTORATE OF RT Q TORY OPERATIONS
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RO Report Nos. 50-269/72-8, 50-270/72-7 and 50-287/72-5
Duke Power Company
Oconee 1, 2 and 3
License Nos. CPPR-33, 34 and 35
Oconee County, South Carolina
Docket Nos. 50-269, 50-270 and 50-287
Category A3/B1, A3/B1, A2
Type of Licensee: PWR-2452 MW(t) each, B&W
Type of Inspection: Routine, Announced
Dates of Inspection: August 22-25, 1972
Dates of Previous Inspection: June 27, 1972, and July 18-21, 1972
Principal Inspector:
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C. E. Murph), geactfr Inspector
D(te
Reactor Test and ftartup Branch
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Accompanying Inspectors:
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Date
F. Jape, ReactoV Inspector
Reactor Test and Startup Branch
WZ1ll2-
M. S. Kidd, Reactor Inspector
Date
Reactor Test and Startup Branch
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W.'W. Peery,4t:iidiation Specialist
Date
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Reactof p rations
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W. D. Kelley, Reacto Mnspector
Dste
Reacto Cons ruc
Branch
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N. Economos,Netor Irispector
<DatV
(Metallurgy)
Reactor Construction Branch
Other Accompanying Personnel:
C. M. Campbell, Radiation Specialist
Reactor Test and Startup Branch
1811sio 72 g
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,RO Report Nos. 50-269/72-8,270/72-7
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Reviewed By: [ #
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C.E.Murph,AEtin
ief, Reactor Test and
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Startup Branch
Proprietary Information: None
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R0 Rpt. Nos. 50-269/72-8,270/72-7
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SECTION I
Enforcement Action
A.
Noncompliance Items
1.
Criterion VI of Appendix B to 10 CFR 50 - Failure to provide
approved procedures for electrical quality centrol.
(See
Section II, paragraph 9)
2.
Criterion VII of Appendix B to 10 CFR 50 - Installation of
cable without documentary evidence that cable met procurement
specification.
(See Section II, paragraph 15)
3.
Criterion V of Appendix B to 10 CFR 50 - Failure to implement
approved procedures for control of nonconforming items.
(See
Section II, paragraph 10)
4.
Criterion VI of Appendix B to 10 CFR 50 - Failure to distribute
welding procedures to welding stations where they would be used.
(See Section III, paragraph 2)
5.
Criterion XIV of Appendix B to 10 CFR 50 - Failure to establish
measures to indicate the status of cable.
(See Section II,
paragraph 14)
6.
Criterion XV of Appendix B to 10 CFR 50 - Failure to maintain
accurate records of nonconforming cable.
(See Section II,
paragraph 8)
7.
Criterion VIII of Appendix B to 10 CFR 50 - Failure to follow
procedures which resulted in use of incorrect material in Class
I systems.
(See Section III, paragraph 5)
8.
Criterion XVI of Appendix B to 10 CFR 50 - Failure to identify
the cause of weld defects and to take corrective ccrion; failure
to report the weld defects to appropriate levels of management.
(See Section III, paragraph 7)
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9.
Criterion XVIII of Appendix B to 10 CFR 50 - Failure to conduct
effective audits of electrical construction QC activities.
(See
Sectior. II,
paragraph 12)
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10. Criterion VI of Appendix B to 10 CFR 50 and Section IV, B
of the Guide for Conducting the Oconee Preoperational Test
Program - Major changes made to test procedure were handled
as minor changes.
(See Section V, paragraph 4)
11.
Criterion VI, Appendix B to 10 CFR 50 and Section II, A of
the Guide for Conducting the Oconee Preoperational Test Program -
Approval of a test procedure was delegated to the operating
engineer rather than be approved by the plant superintendent.
(See Section V, paragraph 4)
12.
Criterion VI of Appendix B to 10 CFR 50 and Attachment C to
Guide for Conducting the Oconee Preoperational Test Program -
Changes were made to a procedure which were not identified
in the body of the procedure.
13.
Criterion XI of Appendix B to 10 CFR 50 and Attachment B to
the Guide for Conducting the Oconee Preoperational Test Program -
Failure to document the results of a test. An item that requires
signoff during performance of a test was not signed off.
(See
(Section V, paragraph 4)
Licensee Action on Previously Identified Enforcement Matters
None
Unresolved Items
A.
Liquid Waste System
Calibration had not been completed on the flow meter for liquid
waste discharges.
(See Section VI, paragraph 1)
B.
Caseous Waste System
1.
Five gaseous effluent monitors were not ready for operation.
(See Section VI, paragraph 2)
2.
Verification was not available that the stack sampling probe
is isokinetic.
(See Section VI, paragraph 3)
3.
The possibility of air flow from waste handling areas to clean
areas exists.
(See Section VI, paragraph 4)
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C.
Solid Waste System
1.
The solid waste compactor has not been installed nor exhaust
duct attached.
(See Section VI, paragraph 5)
2.
A detailed procedure has not been written for solid waste
packaging.
(See Section VI, paragraph 5)
3.
A procedure for spent resin transfers to a truck mounted cask
had not been written.
(See Section VI, paragraph 6)
D.
Radiation Protection
1.
Training of health physics personnel is continuing as well as
health physics training of operations personnel.
(See Section VI,
paragraph 7)
2.
The Beckman Beta Mate II counter in the health physics counting
room had not been calibrated.
(See Section VI, paragraph 8)
3.
Change rooms in the pool area and hot machine shop have not
been fully supplied.
(See Section VI, paragraph 9)
4.
Only one of twenty-one count rate meters has been installed
ne monitoring points for personnel.
(See Section VI, paragraph 10)
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5.
None of the area monitors had been calibrated.
(See Section VI,
paragraph 11)
6.
Seven process monitors were not ready for operation.
(See Section VI,
paragraph 12)
7.
Decontamination facilities were not comolete.
(See Section VI,
paragraph 13)
8.
Hood flows have not been shown to be satisfactory.
(See Section VI,
paragraph 14)
9.
Air filter tests had not been completed.
(See Section VI,
paragraph 15)
E.
Environmental Monitoring
A flow control problem exists with the continous water sampler in
the Keowee tailrace. -(See Section VI, paragraph 16)
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R0 Rpt. Nos. 50-269/72-8,270/72-7
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Status of Previously Reported Unresolved Iteus
A.
Initial Fuel Loading Procedure (R0 Report'No. 50-269/72-3)
Action on RO's comments regarding the initial fuel loading procedure
has not been completed yet. The author of the original procedure has
terminated his employment with DPC and the procedure was completely
rewritten and is currently being reviewed by the SRC. Smith stated
that RO will receive a copy of the new procedure by mid-September.
(See Section V, paragraph 3)
B.
Drawing Control Procedure (R0 Report No. 50-269/72-4)
This
Administration controls and procedures have been implemented.
item is resolved.
(Sea Section V, paragraph 5)
C.
Control of Lifted Leads and Jumpers (R0 Report No. 50-269/72-7)
DPC provided RO with a list of tests to be redone prior to hot
functional testing, fuel loading, and startup. The list is currently
under review by RO.
(See Section V, paragraph 6 and Exhibit A of
this report.)
B&W Procedure for Control of Small Parts and Tools (R0 Report No.
D.
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50-269/72-5)
B&W has written a procedure for control of small parts and tools
during repairs to Unit I steam generators.
The procedure, FC0 # 2,
NSS-2, Rev. 3, was issued May 29, 1972. This item is resolved.
E.
DPC Audit of B&W Quality Assurance Program (R0 Report No. 50-269/72-5)
This item has been resolved by virtue of an audit by DPC of the
QA program generated by B&W to govern repair work on the reacter
vessel and steam generators. The audit was conducted July 6, 1372,
and showed that B&W had developed a satisfactory p:ogram.
Design Changes
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None
Unusual Occurrences
None
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,RO Rpt. Nos. 50-269/72-8,270/72-7
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Persons Contacted
DPC - Construction
- R. L. Dick - Vice President
- C. B. Aycock - Senior Field Engineer
- D. L. Freeze - Principal Field Engineer
- D. C. Beam - Project Manager
K. W. Schmidt - Associate Field Engineer - Electrical
D. E. Hatley - Assistant Field Engineer - Electrical
B. H. Webster - Associate Field Engineer - Systems
L. R. Davison - Associate Field Engineer - NDT
A. R. Hollins - Associate Field Engineer - Welding
J. M. Curtis - Senior Design Engineer (QA) - (Charlotte - Design Engineering)
M. Ray - Associate Engineer - Welding - (Charlotte - Construction Departmen
Consultant
H. Thielsch - PE
DPC - Operations
- J. E. Smith - Plant Superintendent
- J. W. Hampton - Assistant Plant Superintendent
- L. E. Summerlin - Staf f Engineer
R. M. Koehler - Technical Support Engineer
O. S. Bradham - Insttument and Controls Engineer
C. T. Yongue - Health Physics Technician
W. G. Itin - Laboratory Technician, Health Physics
J. R. Leonard - Laboratory Technician, Health Physics
D. Rains - Assistant Staff Engineer
Babcock and Wilcox Construction Company
W. Faasee - Field Project Manager
C. D. Thompson - Field Quality Control Supervisor
These persons attended the first management interview.
These persons attended both canagement interviews.
Management Interviews
24, 1972.
At Dick's request, a management interview was held on August
A final management interview was held at the conclusion of the inspection
on August 25, 1972. The following items were discussed-
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RO Rpt. Nos. 50-269/72-8,270/72-7
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1.
Cable QC Documentation
Dick was advised by Murphy that cable had been installed prior to
the receipt of certification in the field that the cable QC docu-
mentation was in order. Failure to have certification from engineering
is contrary to the requirements of Oconee Procedure D1.0. and also
,
to Criterion VII of 10 CFR 50. Freeze confirmed the inspector's
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understanding that henceforth completed certifications would be
obtained prior to installing the cable.
(See Section II, paragraph 15)
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2.
Use of Informal Procedures
Murphy advised Dick that the electrical QC group was using numerous
informal procedures in performing their work. For example, there are
no procedures approved by authorized personnel for the storage
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maintenance of motors and for batteries. Failure to provide procedures
approved by authorized personnel is contrary to the requirements of
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Criterion VI of Appendix B to 10 CFR 50. Dick agreed to provide
the inspector with a schedule of completion for the DPC procedures at
the time of the next inspection.
(See Section II, paragraph 9)
3.
Familiarity with Procedures
Murphy advised Freeze that he had deterrined that Oconee had no
established procedure to assure that inspectors and engineers were
aware of new or revised procedures. DHk and Freeze agreed to
develop a method prior to the next inspection. One method discussed
was the use of a routing stamp on the procedures.
(See Section II,
paragraph 13)
4.
Implementation of Procedures
<
Dick was advised by Murphy that he had found DPC procedure Q-1,
" Nonconforming Items," for Oconee had not been implemented by the
electrical group. In that this procedure is mandatory for Oconee 1
with an effective date of January 20, 1972, failure to implement
the procedure is contrary to the requirements of Criterion V of
Appendix B to 10 CFR 50. Dick agreed to provide the inspector a
resolution to this problem at the next inspection.
(See Section II,
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paragraph 10)
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A0 Rpt. Nos. 50-269/72-8,270/72-7
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5.
Construction Electrical Audits
Murphy advised Beam and Freeze that he ha'd reviewed the documentation
relating to an audit conducted on June 8, 1972, of the electrical
construction QA program. Numeroas deficiencies had been observed
in the audit and the inspector did not consider that the audit
met the intent of Criterion XVIII of Appendix B to 10 CFR 50.
Beam
concurred with the inspector and stated that a reaudit had been
scheduled. Murphy also pointed out, however, that it was incon-
sistent for a management audit team to make a finding that work
was being accomplished without written procedures and for manage-
ment not to take immediate corrective action and provide procedures.
Beam stated that this area was under review but he could not give
any details of what corrective action would be taken.
(See Section II
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paragraph 12)
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6.
Turnover of Electrical Equipment
Murphy advised Dick that contrary to DPC procedure S2, " Control
of Records," and Criterion XIV of Appen lix B to 10 CFR 50, records
were not maintained in every case of cables turned over to operations
by construction. Dick agreed that DPC would review this area
and attempt to resolve the problem prior to the next inspection.
(See Section II, paragraph 14)
7.
Incompiere QC Documentation
Kidd stated that he found nine Report of Receiving Inspection
(QC-31) forms which had not been signed by the principal field
engineer during his review of electrical cable QC documentation
for Unit 2.
Freeze stated that these forms had been signed after
the subject was brought to his attention.
(See Section II,
paragraph 8)
S.
Inaccurate Records of Nonconforming Cab 1_e,
Kidd stated that QC documentation for safety cable on reel No. 04521
was found to be in error. A letter from D. E. Roberts to Dick dated
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January 5, 1972, gives information that reel 04521 did not meet specifi-
(
cation and should not be used in safety applications. However, this
reel was cleared for installation in a safety application on form QC-31
on July 18, 1972. Aycock stated that this reel has been quarantined
but not segregated and that the engineering department will be requested
to correct the QC-31. Dick was advised that failure to properly document
nonconforming material is contrary to the requirements of Criterion XV
of Appendix B to 10 CFR 50.
(See Section II, paragraph 8)
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9.
. Painted Cable
Kidd stated that it is possible to have conflicting pieces of docu-
mentation for cable which is painted after installation. Aycock
proposed that for Unit 2, a flagging statement to the effect that
cable had been painted be written on the Cable Installation and
Termination Report. For Unit 3, Aycock stated that a note would
be made on the computer installation card if cable were painted.
Kidd stated that RO saw no problems with the proposals.
10. Welding Review
Kelley stated that he had discussed the review of radiographs,
repair welding, documentation of material on Unit 1 Class I piping
with their consultant (Thielsch).
It is RO's understanding that
as each phase of the corrective action is completed, Thielsch will
issue a separate report which will include his audit and when all
corrective action is completed, Thielsch will issue a summary report.
Dick stated that this understanding was correct. Kelley stated
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that RO would not audit these items until the consultant has issued
his reports on each phase of corrective action and that the final
audit would be made after the summary report is submitted.
Kelley stated that he had been informed by Thielsch that the corrective
action being taken on Unit 2 regarding the artifacts (pencil marks)
on radiographs was to correct all isometric drawings and apply correct
weld identification numbers. Kelley stated that Thielsch had indicated
that his summary report for Unit 1 would be submitted to DPC in
January 1973, and in April 1973 for Unit 2.
Dick stated that this
was correct.
(See Section III, paragraph 1)
11. Welding Procedures
Kelley advised Dick that welding procedures approved in June 1972
had not been issued to craft personnel or welding inspectors and
they were in noncompliance with 10 CFR 50, Appendix B, Criterion VI.
Freeze stated that the revised procedures would be issued by
September 1, 1972.
(See Section III, paragraph 2)
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Kelley stated that his audit of welding procedures P7 and P8 re-
vealed that they were extremely broad in scope. Dick stated that
someone within their organization would review the procedures and
discuss them during the next inspection.
(See Section III, paragraph 3)
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12. Improperly Punched Cards
Kelley stated that he had reviewed the corrective action DPC was
taking on improperly punched IBM cards (Form QC-36) and had no
comments.
(See Section III, paragraph 4)
13. Use of Incorrect Materials
Kelley stated he had reviewed nonconforming item report sheets 84
through 91 and these indicated that 316 stainless steel pipe and
fittings had been used instead of the 304 stainless steel specified
and that DPC would be cited for being in noncompliance with 10 CFR 50, Appendix B, Criterion VIII.
Kelley stated that he had been advised by their consultant that
he was studing the use of 316 stainless steel piping which had been
incorrectly identified as 304 stainless steel in Unit 2 and the use
of E308 welding filler metal and that his findings would be reported.
Kelley stated that the report would be audited.
(See Section III,
paragraph 5)
14. Traceability of Material
Kelley stated that Thielsch advised him that it was impossible to
trace welding filler metal material by heat number in Unit 1 and
this may also be true for Unit 2 and possible to some extent on
Unit 3.
Kelley stated that he would audit Thielsch's report when
completed.
15. Stop-Work Orders
Kelley stated that he had noted that only seven stop-work orders
had been issued at Oconee since the first of 1972 with the last
being May 25, 1972. This number for an eight-month period indicates
the inspectors were not stopping deficient work.
(See Section III,
paragraph 6)
16. Weld Defects
Kelley stated that he had reviewed core flood spool piece (System 53A
Iso 15) records and found that four 14-inch welds contained eleven
defective areas that did not meet code for a total length of 18 inches
and that neither the associate field engineer - welding or associate
field engineer - NDT were aware of or had been informed of this
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large number of defects. Kelley stated he could not find any
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corrective quality control action planned or initiated and that this
was in noncompliance with 10 CFR 50, Appendix B, Criterion XVI.
Kelley also stated that he could not locate the DPC welding inspector
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in his assigned area on two separate occasions.
(See Section III,
paragraph 7)
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17. Health Physics Program
In the interview with management on August 24, 1972, Murphy reminded
Smith of the outstanding items discussed at the conclusion of the
last inspection of the health physics program (R0 Report No. 50-269/71-7)
which are also contained in the licensee's list.
In the second
management interview on August 25, 1972, Peery presented additional
items as follows:
It was pointed out that air flows in sample and hot laboratory
a.
hoods had not been verified. Smith agreed with health physics
personnel commitment to accomplish this.
(See Section VI,
paragraph 14)
b.
Management was informed that the question of air flows from waste
handling areas exists.
Smith agreed that tests would be made to
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evaluate this.
(See Section VI, paragraph 4)
c.
The lack of completion of calibration of the flow meter on the
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liquid effluent line was pointed out.
Smith indicated that
completion was in progress.
(See Section VI, paragraph 1)
d.
Management was informed by Peery that the question exists of
verification by the licensee that the stack sampler has been
installed to be isokinetic. Smith indicated that this would
be accomplished.
(See Section VI, paragraph 3)
e.
Peery pointed out that testing of air filters has not been
completed. Smith indicated awareness of this.
(See Section VI,
paragraph 15)
f.
Managenent was informed by Peery that a flow control problem
exists with the continuous water sampler on the Keowee tailrace.
Health physics personnel were aware of the valve problem associated
with this inadequate flow control and already had plans to
correct it.
Smith indicated concurrence.
(See Section VI,
paragraph 16)
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R0 Rpt. Nos. 50-269/72-8,270/72-7
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The remaining items that the inspector had reviewed during the
inspection were reviewed briefly and Smith was advised by
Murphy that all items must be completed prior to fuel loading.
18. Preoperational Test Program
Jape stated that during his review of the performance of the pre-
operational test program, four items of noncompliance with Appendix B
to 10 CFR 50 and the Guide for Conducting the Oconee Preoperational
Test Program were discovered.
(See Section V, paragraph 4)
19. Initial Fuel Loading Procedure
Jape indicated that RO is very much interested in reviewing this
procedure. Smith stated that the newly rewritten procedure should
be available for our review by mid-September.
(See Section V, paragraph 3)
20. Unit 1 Test Plans
Jape asked if DPC has developed a test program for Unit 1 to be
performed after repairs to the reactor coolant system are completed.
Smith indicated that the complete package had not been finalized,
but that they are currently working on the program.
(See Section V,
paragraph 7)
21. Reactor Coolant Systems Repairs
,
Murphy stated that Economos had reviewed B&W repair work on reactor
coolant systems and that RO had no comments on this item.
.
22. Request for Guides
1
Canady promised to send copies of the DPC guides for preoperating
,
testing and for the operating program to the inspector by September 1,
1972.
23. Request for Procedures
Smith committed DPC to supply the fuel loading procedure by September 8,
1972, and the controlling procedure for zero power physics test by
1
October 1, 1972. The status of the procedures for ascension to
power with expected completion date will be given the inspector at
the time of the next inspection.
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.R0 Rpt. Nos. 50-269/72-8,270/72-7
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SECTION II
Prepared By:
M. S. Kidd, Reactor
Inspector, Reactor
Test and Startup Branch
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO
DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND
1.
Plant Schedule
The following dates were provided by Smith:
Unit 1
Unit 2
Unit 3
Start Hot Functional Testing
12/01/72
2/15/73
12/01/73
Core Loading
1/15/73
4/15/73
2/01/74
Commercial Operation
6/01/73
9/01/73
6/15/74
2.
Instrument Air
The instrument air lines have been removed from the battery rooms.1/
3.
Fire Alarm System
The inspector witnessed a satisfactory test of the Unit 1 cable
spreading room fire detector.
4.
Electrical Cable Installation Inspection
a.
Flamastic will be used between congested cable trays of Unit 1
cable spreading room for fire protection.
Example: Southeast
corner of room above emergency power switching logic panel.
b.
Cable and cable tray installation was inspected in Unit 2
cable spreading room. No deficiencies were noted.
c.
Cable associated with Unit 2 control batteries 2DCB and 2DCA,
static inverters 2DIC and 2DID, and 4160 volt standby breakers
B2T-6 and BlT-8 were inspected in the field. No deficiencies
were noted.
5.
Electrical Cable QC Documentation
The inspector reviewed QC documentation for cable used for the
following Unit 2 instruments:
1/ R0 Report No. 50-269/72-4
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RO Rpt. No. 50-269/72-8,270-7
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Primary coolant temperature - from sensor to B&W cabinet,
a.
b.
Primary coolant pressure - from transducer to B&W cabinet.
Uninterrupted a.c. power source - d.c. cable from batteries to
c.
tie breakers.
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d.
Instrument batteries - from batteries to panel board.
Documentation for these cable was in order.
6.
Electrical Component Installation Inspection
The following Unit 2 electrical equipment was inspected. No
deficiencies were noted.
a.
Control batteries 2CA, 2CB.
b.
Static inverters 2DIA, 2DIB, 2DIC, 2DID.
c.
4160 volt breakers B2T, B1T.
7.
Electrical Component QC Documentation
The inspector reviewed QC documentation for static inverters 2DIA,
2DIB, 2DIC, and 2DID; breaker cabinets B1T and B2T; and control
batteries 2CA and 2CB. No deficiencies were noted.
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DF.TAII.S OF SUBJECTS DISCUSSED IN SECTION I
8.
Electrical Cable QC Documentation
The inspector reviewed QC documentation for cable used for Unit 2
breakers 2EBIT and 2EB2T. The engineering folders contained nine
QC-31, Report of Receiving Inspection, forms which had not been
signed by the principal field engineer.
In each case, the cable
reels involved had been checked as clear for installation-QC docu-
mentation in order. These forms were signed by Freeze after the
deficiency was brought to his attention.
this folder also contained two pieces of QC documentation for cable
on reel No. 04521 which were not in agreement. A letter from D. E. Roberts
(January 5, 1972) to Dick gives information that reel No. 04521 contains
cable which does not meet specification and should not be used in
safety applications. Contrary to the requirements of this letter,
however, the QC-31 form for this reel had been marked clear for
installation - documentation in order by the engineering department
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on July 18, 1972. This reel was marked with two quarantine tags
after the letter to Dick was received at the site but was not
segregated from cable whose use had been~ approved. The inspector
received a commitment from Aycock to request the engineering de-
partment to correct the QC-31. The inspector stated during the
management interview that failure to identify and document non-
conforming material is contrary to the requirements of Criterion XV
of Appendix B to 10 CFR 50.
'
9.
Use of Unapproved Procedures for Electrical Quality Control
Murphy reviewed the electrical QC procedures in use at Oconee Nuclear
Station for Units 2 and 3.
The inspector determined that the pro-
cedures fell into three categories. Most of the procedures were in-
formal documents that had been prepared by the electrical QC engineer
for use during the construction of Unit 1 (Category 1).
The second
category of procedures were those prepared under the direction of
the principal field engineer and approved by the project manager. The
third category are those procedures prepared under the direction
of and approved by the Vice President, Construction, for use at all
DPC facilities.
A DPC audit team in the report of its audit conducted on June 8,
1972, made reference to the informal procedures. This report stated
that these procedures were not approved and should not be used. Schmidt
advised the inspector that these procedures included those for such
operations as storage inspection of electric motors, inspections of
batteries, and the procedures used by the electrical inspectors in
performing QC reviews of cable installation.
Murphy advised Aycock and Schmidt that the failure to provide procedures
that had been approved by authorized personnel was contrary to the
requirements of Criterion VI Appendix B to 10 CFR 50. This item was
discussed in the management interview.
10. Failure to Implement Approved Procedures for Nonconforming Electrical Items
Procedure Q-1, " Control of Nonconforming Items," a Category 3
procedure, establishes the requirements f.c the handling of nonconforming
material at Oconee. This procedure was to have been implemented
20, 1972. Schmidt stated, however, that the electrical
by January
QC group had not fully implemented this procedure, e.g., nonconforming
Both Schmidt
material is not always placed in separate storage.
and Aycock stated that the informal procedures used in the
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electrical group would accomplish the same results as Q-1, but
This item was discussed in the manage-
required less paperwork.
ment interview and Dick was advised that. failure to implement approved
procedures was contrary to the requirements of Criterion V of Appendix B
to 10 CFR 50.
11. Work Stoppage Procedure
In reviewing the Category 3 procedure, R-1, " Work Stoppage Procedure,"
and in discussing this procedure with Freeze, the inspector found
that in practice, work is not stopped until the Work Stoppage
Freeze
Notification Form had been completed by the inspector.
agreed to review this procedure with his management to determine
if agreement could be reached to require that work be stopped
This item will be
prior to the completion of the paperwork.
reviewed during a subsequent inspection.
12. Electrical QA Audits
The inspector reviewed the records of an audit of the Oconee electrical
The following weaknesses were observed by the inspector:
QC program.
The audit team did not identify the limited scope of their
'
a.
inspection nor refer to the controlling procedures.
The audit team did not determine the basis'for the electrical
b.
equipment storage requirements.
The basis for QC reinspections was not determined nor was the
c.
acceptability of reinspeccions determined.
The audit team d'.d not inspect for instrument calibrations.
d.
The audit did not cover documentation of corrective actions
e.
nor the methods used and documentation relating to nonconforming
items.
The audit team did not determine the need for field installation
f.
The audit team did not complete their checklist
procedures.
for this audit,
The check 11ts used by the audit team did not reference the
g.
governing codee, regulations or procedures.
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In discussions with Freeze and Beam, the inspector advised them
that the audit was superficial and did not meet the intent of
Criterion XVIII of Appendix B to 10 CFR 50.
Beam advised the in-
spector that he had objected to the adequacy of the audit to Dick
and Dick had promised a reaudit. This item was discussed in the
exit interview.
13. Inspector Training
During the discussions of the electrical QC procedures, Murphy
asked Schmidt to describe the methods used by DPC to insure that
each inspector was familiar with each procedure and revision.
Schmidt stated that every inspector was required to take a test
to demonstrate his knowledge of applicable procedures. He
admitted that there was no followup and that procedures and procedure
revisions were somtimes filed in the procedura.s manuals without
the inspectors being made aware of their existence. This item
was discussed in the management interview and Freeze stated that
all procedures and revisions would be routed through all the affected
inspectors. The initials on the routing stamp would become the
record confirth d that each inspector had seen the procedure.
14. Transfer of Systems
A Category 3 procedure, S-1, specifies the requirements for the
transfer of systems from construction to operations.
In response
to the inspectors' questions, Schmidt stated that the identification
of cable involved in the turnover of safety related systems was
not always known and was not identified in the turnover records.
Tnis item was discussed in the management interview.
Dick was
advised that failure to maintain records of the operating status
of systems was contrary to the requirements of Criterion XIV of
Appendix B to 10 CFR 50.
15. Receipt Inspection
The procedures for receipt inspection and storage are detailed
in procedure D.1.0, " Receiving Inspection of Safety Related Material
and Equipment," a Category 2 procedure. Although DPC has a Category 3
procedure for receipt inspection, it has not been implemented at
Oconee. Murphy reviewed the implementation of procedure D1.0 with
Schmidt.
In response to Murphy's questions, Schmidt admitted
that on occasion cable and equipment was installed on the basis
of verbal concurrence from engineering rather than waiting for
written approval as required by procedure D.l.0.
There is no
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record maintained of these 'rarbal approvals and no system to
assure that written approval is eventually received. Murphy advised
Aycock and Schmidt that the installation of cable without documentary
evidence thae cable met procurement specifications was contrary to
the requirements of Criterion VII of Appendix B to 10 CFR 50.
This item was discussed in the exit interview.
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SECTION III
Prepared By:
W. D. Kelley, Reactor
Inspector, Reactor
Construction Branch
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN$SECTION I, WHERE NO
DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND
None
DETAILS OF SUBJECTS DISCUSSED IN SECTION I
1.
Radiographic Artifacts (Pencil Marks)
The DPC consultant (Thielsch) informed the RO inspector that four
lists had been prepared on Unit 1 for following the review of the
radiographs for artifacts, reradiography, and reinterpretation.
Thielsch also inform,
the inspector that DPC had found radiographs
shot as late as March 1972 that had artifacts (pencil marks).
The
first list is called " List of 141" which is a list of all pipe
buttwelds - 10-inch nominal pipe size and larger that are to be
reradiographed 100%. The reradiography is 40% complete and has
been reviewed by the consultant.
If a repair is required of the
'
buttweld by the reradiography, it is added to one of the subsequent
lists.
--
Completing the reradiography is handicapped by water being
in some of the piping system which interfers with the radiography.
The consultant stated that some of the buttwelds may be embedded
in concrete but these will be evaluated on an individual basis.
The second list is called " List of 52" which are the 52 buttwelds,
selected at random, from the 708 buttwelds that are 8-inch nominal
pipe size and smaller, that are to be used for the basis of the
engineering evaluation for acceptance of the balance (656) which have
radiographic film with artifacts (pencil marks). A total of 2857
radiographic film for the 708 buttwelds had artifacts (pencil marks).
')
An attempt wat made by DPC personnel under the direction of the
consultant to clean the pencil marks from the radiographic film using
a Kodak film cleaner but it damaged the film where heavy pressure
was exerted on the pencil. Approximately 10% of the 52 buttwelds
has been reradiographed and reviewed by the consultant.
All radiographs for Unit 1 have been reviewed by Level II radio-
graphers and the radiographs of the buttwelds they questioned were
added to the " List of 164."
The buttwelds on'this list are to be
reradiographed to resolve lack of radiographic film overlap, film
artifacts, density not meeting code recuirements, and where griding
was required to meet code requirements.
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The last list is the " List of 44" which are buttwelds that must be
repaired and reradiographed. This list may have buttwelds that
were first listed on either the " List of'141" or the " List of 52."
The repair and reradiography is 100% complete but the radiographs
have not been reviewed by the consultant.
Presently, DPC personnel are comparing the installed piping system
in Unit 2 with the piping isometric drawings to ascertain that the
piping was installed in accordance with the drawings and that the
buttweld identification numbers are correct. The drawing and the
buttweld identification numbers will be corrected if necessary. After
the review and corrective action is completed, the radiographic film
will be reviewed for artifacts (pencil marks). When the tabulation of
the number of buttwelds that have radiographic film with artifacts
(pencil marks) is complete, the consultant will meet with DPC manage-
ment to determine the course of action to be taken for the engineering
evaluation.
The consultant stated that each problem encountered during the
investigation of the welding procedures and documentation in answers
to R0 citations of DPC's failure to comply with 10 CFR 50, Appendix B
would be covered in separate reports; however, a summary report which
{~
will include his summary audit would be issued by him by January
1973 for Unit 1, and April 1974 for Unit 2.
2.
Approved Welding Procedures Not Issued
The RO inspector audited the DPC welding procedures P1 through P9
in their fabrication shop, weldor qualification shop, Unit 3 inspector's
office, and the quality control engineer's office and found that 23
out of 24 had approval dates prior to the RO inspection of December 9-10,
1971, when DPC was cited for their welding procedures being in
noncompliance with 10 CFR 50, Appendix B, Criterion VI.
The RO inspector (Kelley) informed DPC in a management interview
at the Oconee sita / that his audit revealed
l
on December 10, 1971,
their welding procedures were deficient. The welding procedures
did not receive a thorough review until April when DPC associate
field engineer, M. Ray, (Charlotte - Construction Engineering),
reported to work. Two of the deficient welding procedures required
requalification, one because of thickness range and the second to
increase the shielding gas flow.
1/ R0 Report No. 50-269/71-11
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All welding procedures had been revised between June 2 and 26, 1972
(approval dates), incorporating the RO inspector's comments and to
meet ASME Code. These procedures have been informally reviewed by
their consultant but he has not performed a formal audit. The
procedures were not issued because DPC wanted to issue them as a
" package" rather than " piecemeal." Therefore, the inspector advised
Dick that DPC was in noncompliance with 10 CFR 50 Appendix B,
Criterion VI.
3.
Audit of Welding Procedures
The RO inspector reviewed DPC welding procedures P7 and P8 and they
are extremely broad in scope covering the welding of materials that
were not used on the Oconee site. Welding procedures P7 and P8 both
require the welding of 304 to 304 use 308 welding filler metal, 304
to 316 is to be welded with either 308 or 316.
However, if 316L
is welded to 316L, then 316L welding material is to be used or if
i
304L is welded to 316L, then 304L or 316L welding material is to be
used. The RO inspector was informed by the DPC associate engineer-
welding (Ray) that it took him a week to review their welding
procedure P-5 and the associated data to determine that it met
Section IX of the ASME Code. With the broad scope of procedure
P7 and P8, DPC could not expect a welding inspector with no
technical education to interpret these procedures. DPC vice
president, construction (Dick) stated he was aware of the broad scope
of some of the welding procedure and that someone within their
organization would review the procedure for possible corrective
action.
4.
Improperly Identified Material
The RO inspector audited DPC nonconformance report No. 40 which
identified that their IKH card QC Form 36 had been incorrectly
punched identifying the piping material as 304 stainless steel
where the material was actually 316 stainless steel. The audit
~'evealed that all of the QC Form 36 cards for 20-1/2 inch socket
r
welds had been signed off at the same time and stamped with the
'
same date for all inspections. The RO inspector had been informed
by their associate field engineer-NDT (Davison) that prior to
December 1971, the QC Form 36 cards were punched for an isometric
drawing and given to the inspector and after that portion of a
system was completed, all cards were then stamped with the date.
The RO inspector had been informed that DPC procedure E-1 was
approved in December 1971 which established card boxes at the
work area with mandatory hold points. DPC was informed that the
RO inspector had no comment on their corrective action.
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5.
Nonconforming Material
DPC Nonconforming Item Report, Form Q1-A, for Unit 2 shows on
sheet numbers 84 through 91 that 316 stainless steel material was
used rather than the 304 stainless steel specified. Report No. 86
states welds 36E and 36F on isometric drawing 27 were welded with
308 filler metal in violation of the welding procedure. Serial No.
84 states " Attached sheet for weld nonconformity to be covered in
report by Hilmut Thielsch."
Attached to the above form Q1-A are the isometrics indicating where
316 stainless steel fittings and pipe were used and were welded to
the 304 stainless steel welding procedure requirements. The use
of nonconforming material is in noncompliance with 10 CFR 50, Appendix B, Criterion VIII.
The consultant stated he was aware that 316 stainless steel pipe
and fitting in Unit 2 had been welded with E308 welding filler
metal and that he was conducting tests for an engineering evaluation
of the, welding and the test results would be included in a report
and also in his summary report.
6.
Stop Work Orders
The following DDC stop work orders were audited:
No. 1 - Weldor in Unit 2 in possession of 308L and 316L welding
filler metal. Only 308 was authorized material for welding in this
area. Q-1A form states weld was cut in center and prepared for
rewelding but did not specify or require the removal of all heat
affected zone.
No. 2 - Weld in Unit'2 completed without root being inspected, weld
cut out and rewelded. Work was completed and work stoppage used
as means of applying hold tag.
No. 3 - Approximately 10 pounds of 308L welding material was de-
posited in first layer of the cladding of Unit 3 main coolant loop.
Q-1A form states that cladding was removed and weld area sketched
to show complete removal of heat affected zone.
Only seven work stoppages have been issued since January 1972 and
the latest May 25, 1972.
7.
Lack of Corrective Action on Welding
The RO inspector audited the quality control records of a 14-inch
-
core flood system spool piece (System A33 Iso-15) fabricated onsite
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by DPC employees.
It was found that four of the welds contained a
total of eleven defective areas that did not meet the applicable
code requirements for a total length of eighteen inches. The records
revealed that one weldor (74) had welded on each of the welds and
that only one heat of electrodes (Arcoloy 33302C) had been used in
the area of the defects. Neither the associate field engineer-
welding or the associate field engineer - NDT was aware of the
defects in the spool piece welding nor were they aware of the
defects. The RO inspector was unable to locate the DPC welding
inspector assigned to the shop area on two different occasions
to discuss the welding difficulty. The failure to identify conditions
adverse to quality and report them to management is in noncompliance
with 10 CFR 50, Appendix B, Criterion XVI.
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SECTION V
Prepared By:
F. Jape, Reactor Inspector
Reactor Test and Startup
Branch
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO
DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND
1.
Preoperational Test Program Status
.
a.
The status on August 25, 1972, of the preoperational test program
for Oconee 1 is summarized below:
Total
Approved
Tests
Results Approved or
Number
Procedures
Completed
Tests Signed off
Tets before hot
functional
380
380 100%
380
100%
380
100%
Tests during hot
functional
161
159
99%
117
73%
103
64%
Tests prior to
core loading
138
136
99%
103
75%
90
65%
Total preoperational
tests
679
675 99.4%
600
88%
573
84%
The above summary does not include the testing required as a
consequence of the damage to the reactor coolant system.
In-
formation relating to the tests that must be repeated will be
obtained during the next inspection.
b.
The preoperational test program for Oconee 2 is currently in
preparation. To date, four t'.sts have been performed and two
others are partially complete.
2.
Dates for Oconee Nuclear Station
The following dates were received from Smith, Plant Superintendent:
Plant
Core Loading
100% Power
Oconee 1
1-15-73
6-1-73
Oconee 2
4-15-73
9-1-73
Oconee 3
2-1-74
6-15-74
DETAILS OF SUBJECTS DISCUSSED IN SECTION I
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3.
Initial Fuel Loading Procedure
The initial fuel loading procedure, which was reviewed by RO and
comments discussed with DPC, has been completely rewritten. RO
has been told that all of our comments have been incoorporated into
the newly prepared procedure and that a copy should be available by
mid-September for rereview.
4.
Conduct of the Preoperational Test Program
An audit of the " Guide for Conducting the Oconee Preoperational
Test Program" (Guide) was conducted to determine if the test program
was being conducted as described in the Guide. The findings were
as follows:
a.
TP 1/B/202/72-5, "HPI Operational Test." A section was added
as Change No. 3 to " assure proper valve alignment of HPIP C
before operation." Another section was added to check the CRD
dilution interlock.
Both of these additions were handled as minor changes but should
have been treated as major changes.
b.
TP 2/B/250/6, "HPSW nydro Test."
This procedure was approved by
the Operating Engineer on June 13, 1972, rather than by the
plant superintendent as required by the Guide. Although DPC is
currently revising their Guide to allow this delegation of
authority, the approved revision has not yet been issued.
Failure to obtain approvals for changes from authorized personnel
is contrary to the requirements of Criterion VI of Appendix B
to 10 CFR 50.
Apparently the revised guide, if approved, will
allow the operating engineer and the technical support engineer
to approve flushing and hydrotesting procedures.
c.
TP 1/B/25J/2, " Loss of Instrument Air."
The test was conducted
I
on June 29,30, 1972, and changes No. 1 and No. 3 are not in the
I
body of the procedure as stated on the cover sheet. This is
contrary to instructions stated in the current Guide. Failure
to properly document procedure changes is contrary to the requirements
of Criterion VI of Appendix B to 10 CFR 50.
d.
TP 2/B/250/6, "HPSW System Hydro Test."
Item 9, which required
that the test coordinator check to ensure that he is using the
latest RO drawing when performing the hydrotest, was not initialed
to indicate that it had been done as required by the Guide. This
omission occurred in Section 12.1 of the procedure for both the
orange and purple portions of the test.
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Item 9 was handwritten in and Summerlin stated that this item
was added to the procedure before it was approved and, hence,
was not an addition to the test. Thus, it does not appear on
the cover sheet as a change. However, in discussing this item
with Smith, he agreed that such changes should be identified by an
explanatory note or treated as a change to avoid confusion.
Failure to document that the check had been made is contrary
to the requirements of Criterion VIII of Appendix B to 10 CFR 50.
5.
Drawing Control
During a field audit in March 1972, it became evident that there was
a looseness of control of drawings that were removed from a controlled
file. At that tfme, the licensee had agreeded to place into effect a
record control system. This was checked by the inspector and found
to be satisfactory. The drawing control procedure which is described
in DPC's administrative procedure No. 1, dated February 22, 1972,
was not being followed at the time of the audit.
6.
Control of Lifted Leads and Jumpers
A concern had been expressed regarding the validity of tests results
following repairs to the RC system.
(See RO Report No. 50-269/72-7.)
To provide assurance that lifted leads and jumpers have not negated
the results of test performed prior to damage to the RC system,
Smith presented a list of tests to be rerun before hot functional
testing, fuel loading and startup. The list is given in Exhibit A
of this report. RO is currently reviewing this list to ensure that
it does resolve the lifted lead and jumper question.
7.
Unit 1 Test Plans
'
A discussion was held with Summerlin regarding test plans for Unit 1
following completion of repair to the reactor coolant system. Summerlin
stated that they are currently working on a schedule for resuming
ho't functional testing. The list of tests to be rerun, which was
received during the July inspection, is under review by RO.
(See
RO Report No. 50-269/72-7).
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C.
SECTION IV
Prepared By:
N. Economos, Reactor
Inspector, Reactor
Construction Branch
ADDITIGNAL SUBJECTS INSPECTED NOT IDENTIFIED IN SECTION I, WHERE NO
DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND
General
An inspection was made of the progress by B&W in repairing and modifying
the reactor coolant system components.
DETAILS OF SUBJECTS DISCUSSED IN SECTION I
None
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SECTION VI
Prepared By:
W. W. Peery, Radiation
Specialist
ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO
DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND
None
DETAILS OF SUBJECTS DISCUSSED IN SECTION I
1.
Smith advised the inspector that the calibration of the flow meter
on the liquid waste system was in progress and expected to be completed
in a few days.
2.
Incomplete gaseous effluent monitors were the unit vent particulates,
unit vent iodine, reactor building particulates, reactor building
iodine and spent fuel building gas. Assurance was received from
management that these monitors will be completed promptly.
3.
Smith indicated that verification would be obtained that the
stack sampling probe has been installed to be isokinetic.
4.
Smith agreed that a study would be made to determine that in-plant
air flows are not from waste handling areas to clean areas.
.
5.
Management acknowledged that the solid waste compactor, its exhaust
system and operating procedures will be completed with priority.
6.
Management indicated that as soon as exchange of information with the
vendor is complete, a procedure will be completed for spent resin
transfers to a truck mounted cask.
7.
Training of health physics personnel and operations personnel in
.'
health physics is continuing. Management was made aware of the need
for updated and complete records of this training.
8.
Management acknowledged that the calibration of the Beckman Beta
Mate II counter in the Health Physics counting rocm will be completed
within a few days.
9.
Management was informed that it is understood that on-hand protective
clothing will be supplied to the pool area and machine shop change
rooms promptly.
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10.
Management was informed that the inspection revealed that only one
of twenty-one count rate meters had been installed at monitoring
stations although the installation of racks for the instruments
was noted to be in progress.
11.
Although all area monitors RIA 1 through 17 have been installed,
it was pointed out to management that none had been calibrated.
Management duly noted this.
12.
Process radiation monitors RIA 31 through 51 were installed but
calibration on seven units was not complete. Also, right angle
turns in sample lines to four of the units are to be removed.
Management agreed that the right angle turns will be removed and
calibrations completed as soon as possible.
13.
The drain was not operable to a large ultrasonic unit in the
decontamination facility. A special hood had not been installed
over the stainless steel decontaminated tank in this facility.
Management was provided this information through the health physics
group.
14.
Management acknowledged that air flows on sampling hoods and the
hoods in the health physics and radiochemistry laboratories will
be measured and any inadequacies corrected.
15.
Management agreed that tests of reactor building purge and hydrogen
system filters will be completed in accordance with licensee pro-
cedures promptly.
16.
Smith was agreeable to the proposed replacement by health physics
of a valve on the continuous water sampler on the Keowee tailrace
to achieve needed flow control.
Attachment:
Exhibit A
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Ltr to Duke Power Company fm J. G. Davis
dtd 11/3/72
Ltr to J. G. Davis fm A. C. Thies, DPC, dtd 7/27/72
DISTRIBUTION:
RO, AD For Inspection and Enforcement
L, DD For Reactor Projects
RO, Chief, Reactor Testing and Operations Branch
,
RO, Chief, Reactor Construction Branch
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RO Files
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