ML19322A691

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Insp Rept 50-269/72-01 on 720118-21.Noncompliance Noted: Failure to Use Written Procedures in Performing Const Activities & Failure to Evaluate Test Results Assuring Satisfaction of Requirements
ML19322A691
Person / Time
Site: Oconee 
Issue date: 03/23/1972
From: Moseley N, Murphy C, Warnick R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19322A673 List:
References
50-269-72-01, 50-269-72-1, NUDOCS 7911210735
Download: ML19322A691 (18)


See also: IR 05000269/1972001

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UNITED STATES ( [ 't ATOMIC ENERGY COMMISSION ) DIVISION OF COMPLIANCE I ej + REGION li - SUIT E 818 q 230 AE ACHT R E E STR E ET. NORT HWEST i g ,,L,,,,u, (,,,,,,,,,,,, 14 AT L A NT A. GEORGI A 30303 TESTING AND STARTUP INSPECTION REPORT CO Report No. 50-269/72-1 Duke Power Company Oconee 1 License No. CPPR-33, Docket No. 50-269, Category: B1 Seneca, South Carolina Type of Licensee: PWR-2452, v.w(t), B&W Type of Inspection: Routine, Unannounced Dates of Inspection: January 18-21, 1972 Dates of Previous Inspection: December 7-10, 1971 Principal Inspector: f t '- ^ /7 Mi- 7 . actor Inspector (Testing Dat( C.E.Murph[,p) and Startup Accompanying Inspectors: / k g // 8//7/92 R. F. Warnick, Reactor Inspector Dhte' (Testin and Startup) lI F. Jape M eacfor Inspector Date (Testing and Startup) Other Accompanying Personnel: None 886 /s 3/2.3/72L_ Reviewed By:

_ N. C. Moseley, Senior Reac [ Inspector Date' ' ,(Testing and Startup) Proprietary Information: None .

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. C0 Report No. 50-269/72-1 -2- ,, N .I SECTION I Enforcement Action A. Noncompliance Items 1. Criterion XVIII of Appendix B to 10 CFR 50 - Failure to use ' written precedures in performing audits of construction activities. (See Section II, Paragraph 3) 2. Contrary to Criterion XI, Appendix B to 10 CFR 50, test results are not being evaluated to assure that test requirements have been satisfied. (See Section III, Paragraph 4) B. Nonconformance Items None C. Sa,fe'y Items None Licenste Action On Previously Identified Enforcement Matters ' l. Cable Tra; Overfill - Action completed. (See Letter to DPC (Thies) ' from DRL (DeYoung) dated January 26, 1972.) 2. Corrective action has not been completed on other items in C0 Report Nos. 50-269/71-7, 71-8, 71-9, 71-10 and 71-11. Unresolved Items Valve vall thickness measurements. (See Section II, Paragraph 2) Status of Previously Reported Unresolved Items (See Section II, Paragraph 4 for discussion of each item) 1. The licensee has agreed to perform test during the low power operation of the plant to determine the accuracy of. the primary coolant flow sensing elements. 2. Reactor Building Spray System E. S. Performance Test - Resolved. 3. High Pressure Injection System E. S. Performance Test - Resolved. 4

. _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . - . - . C0' Report No. 50-269/72-1 -3- , Unusual Occurrences None Persons Contrcted Duke Power Company (DPC) J. E. Smith - Plant Superintendent J. W. Hampton - Assistant Superintendent D. L. Freeze - Principal Field Engineer R. E. Miller - Mechanical Design Engineer S. K. Backley - Principal Mechanical Design Engineer. K. S. Canady - Nuclear Engineer, Steam. Production Department W. S. Lee - Senior Vice President, Engineering and. Construction R. C. Blaisdell - Welding Engineer R. L. Dick - Vice President, Construction O. S. Bradham - Instrument and Control. Engineer R. L. Wilson - Performance Engineer M. D. McIntosh - Operating Engineer R. M. Koehler - Technical Support Engineer L. E. Summerlin - Staff Engineer Management Interview s The management interview was held on January.21, 1972, and was attended by Hampton, Canady, McIntosh, Koehler, Bradham and Summerlin. None of the construction management personnel _could attend.the management interview because of a concurrent review..of the construction. activities conducted by Lee. A preliminary meeting.was held with Beam, Freeze and Blaisdell to obtain cheir position on construction items reviewed by the inspectors. The inspector again reviewed these items with Freeze by telecon on Janaury 25, 1972, to assure that there were no misunderstandings. The following items'. ware discussed in the management interview. 1. Welding Program The principal inspector stated.that.it was.his understanding that the following action had been taken by the licensee to correct the deficiencies in the welding program. a. Subdivisions of welding procedures would be clearly defined for recordskeeping purposes or the procedures would be subdivided. b. Procedure P5 has been requalified. c. Weldors will be requalified where the original test coupons - were defective.

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. - CO Report No.- 50-269/72-1 -4- d. The procedure used for welding.the main steam _ system piping has been backqualified without preheat rather then trying to justify the acceptance of the welds for which preheat records do not exist. The procedure, however, will not be used in the future without preheat. e. Instructions have been issued.to the. welding shop to adhere to the dimensional requirements of ASME Code, Section IX, in ! the preparation of test coupons. f. Compliance will receive a copy of the Southwest Research Institute's (SwRI) report of their evaluation of the Oconee velding program. The inspector further stated that he had. advised.Blaisdell,. Beam, and Lee that these corrections do not relieve Compliance of their concern regarding_the quality.of the.0conee. welding..

' Compl: ce is concerned about.the extent of.the identified welding program deficiencies and with the present lack of control and documentation of the exact procedures used in making welds. (See Section II, Paragraph'l) 2. Safety Feature and Safety Related Valves. The principal inspector stated that he.had. discussed with Blackley Compliance's concerns with safety feature.and safety-related valves 4 and had advised Blackley that DPC must be.able to document that the valves had been test operated at design operating conditions and must be able to document that the thickness of the valve walls were adequate for the service. Compliance's. concerns are with those valves whose failure would exceed the makeup capability of the ' injeation systems. The. failure to. maintain sufficient records of tests would appear to be contrar XVIIofAppendixBto10CFR50.-{,totherequirementsofCriterion - Blackley had advised the inspector that he could not provida documentation.that the.. valves were acceptable ' for the service and he would contact his management for a resolution of this problem.. (See.Section.II, Paragraph 2) ' 3. Construction Quality. Assurance Audits I The principal inspector advised Hampton that he had requested to see a copy of the minutes of the QA audits of construction activities, , . -1/ The inspector was advised by Moseley, Senior Reactor Inspector ' Region II, on March 1, 1971, that this was not an item of - noncompliance. 1

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. i CO Report No. 50-269/72-1 -5- - , the procedures used, and the resumes of the members of the audit team. These documents were not immediately available. (Copies of the minutes were supplied at the conclusion of the inspection.) J. M. Curtis, Chairman of the audit team,. advised.the. inspector by telecon on January 25,.1972, that written procedures were not used in the conduct of the audit. The~ inspector, at.that time, advised Curtis and Freeze that the DPC appeared to.be in noncompliance with , Criterion XVIII of Appendix B to 10 CFR 50. (See Section II, l , Paragraph 1) 4. The principal inspector reviewed the items on the outstanding items list with Hampton and Canady. (See Section.II, Paragraph 4) Ca"ady confirmed the inspector's understanding of changes agreed to by DPC concerning the revision to the Oconee test program. The adequacy of the Unit 2 reactor building spray system will a. be demonstrated prior to power operation of. Unit 1. b. The Unit 1 high pressure injection system will be tested by tripping the appropriate engineered safeguards instrumentation channels at a system pressure of 1500 psig. c. DPC will contact DRL to determine the extent of testing required for the low pressure injection system. d. During low power testing of Unit 1, tests will be performed to determine the accuracy of the reactor coolant system flow sensing elements. 5. Warnick stated that he had reviewed and evaluated the results

of eight preoperational test procedures which had been signed off by the plant superintendent. Of the eight tests evaluated, the inspector determined the requirements of five tests had been satisfied, the tequirements of one test had not been satisfied, and it was questionable whether che results'of the other two tests had been satisfied. 4 The inspector indicated that this appeared to be in noncompliance with Criterion XI, Appendix B, 10 CFR 50. Hampton stated that Duke would do a better job of presenting the results of the evaluation. (See Section III, Paragraph 4) .- . T + 4 g . y

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. (~j CO Report No. 50-269/72-1 -6- 6. Warnick also stated that he had discussed the CRD test with Bradham and that it looked like the only points of difference were the number of additional rod drops required of the slowest and fastest rods, and dropping all rods simultaneously. Warnick indicated 25 additional drops of the fastest and slowest. rods were appropriate and that should a lesser number be selected, the inspector would pursue the matter further. (See Section III, Paragraph 5.a) 7. Kodder confirmed that the engineered safeguards portion of the reactor building coolers functional test will be included in hot functional test TP-600-17. (See Section III, Paragraph 5.b) ,

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. CO Report No. 50-269/72-1 -7- , ( , . SECTION II Prepared By: C. E. Murphy, Reactor Inspector i 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. Welding Deficiencies During the previous inspection, numerous deficiencies had been observed in the DPC welding program.1/ At the time of that inspection, Blaisdell was not at the Oconee site and the deficiencies were not discussed with him. Because the number and type of deficiencies observed raised questions concerning the quality of welding in the safety feature and safety-related piping systems, the inspector reviewed the results of previous inspection with Blaisdell to determine the extent of the corrective action planned by the licensee. , Blaisdell advised the inspector that every procedure had been re- viewed and that he was of the opinion that they now met code. He stated that the SwRI had reviewed the corrected procedures on January 4-7, 1972, and had given DPC "a clean bill of health" between words in the procedure and code. SwRI has not provided DPC a written report as yet and the inspector was unable to verify this statement. Blaisdell stated that the following action had been taken to correct the deficiencies observed by the inspector during the previous inspection. a. Preheat records - Records for some welds in the main steam piping did not exist. To correct this deficiency, the welding procedure, P-5, had been backqualified without preheat. Blaisdell advised the inspector, however, that welds would not be made l in the future on thick wall material without preheat. b. Control and documentation of welding - The exact resolution of this problem had not been determined. The QA procedure no. E-1, " Controlling Documentation. of Welding," could be revised to identify the subprocedure used in making welds. Inspection requirements would also be tightened. If this were not 1/ C0 Report No. 50-269/71-11 _ we -. ,4 y-- -

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. () C0 Report No. 50-269/72-1 -8- J done, then the welding procedures would be subdivided to assure that the proper subprocedure would be used in making welds. The subprocedure used would be identified in the documentation. Procedure P-2 not properly qualified - This procedure requires c. the use of a filler metal (EB insert) for the first pass and l F7 for subsequent passes. The records for the qualification . " of this procedure indicates that the first pass was made with E308 bare wire. Blaisdell stated that an error had been ' made in transposing information and that an EB insert was actually used. He also stated that the designation F7 was a typographical error and should have been FS. He agreed that greater care should be used in maintaining the records. d. Test coupons - Blaisdell stated that he had issued explicit instructions to the welding shop to maintain the proper dimensions when preparing weld coupons. He said that every bend specimen that could be found had been measured. Every one that did not meet dimensional requirements was rejected. The weldors whose coupons had been rejected were required to requalify. Blaisdell advised the inspector that DPC was generating a listing of filler metals by heat number. Only those on the list could be used in safety feature and safety related systems. He stated that DPC would have 100% traceability on Units 2 and 3 as well as for any welding done in the future on Unit 1. The inspector advised Blaisdell that he was concerned about the lack of control over the application of the welding procedures in making welds. Blaisdell concurred that the present system of controls would not preclude the welding supervisor from specifying an incorrect procedure. And, since no record was made of the procedure or subprocedure used and this was not a , -QC inspection item. DPC had no way of verifying that the proper procedure was used. Blaisdell stated that he recognized this as a i problem as had SwRI. He advised the inspector that the procedure for the use of the veld data cards would probably be revised to require the recording of this information including the proper welding procedure subdivision. In'additon he was aise considering subdividing-some ci t5e procedures to prevent their misuse. The inspactor advised Blaisdell that he would review the welding at Oconee during a future inspection and would place particular emphasis on the ability of DPC to document the exact procedure used in making welds. . l '-. . - .

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! He advised them of his concerns about the. lack of control of l the application of the welding procedures.used in making a weld ! and their inability to document.which procedure was used. Beam advised the inspector that he would discuss the matter i with Blaisdell and take the necessary steps to correct any I deficiencits in the control and documentation of the welding processes.

The inspector also discussed.his_ concerns with Dick and Lee. At the inspector's request, Dick agreed to provide the inspector

with a copy of the SwRI report. { ! Dick and Lee also. advised the~ inspector.that_although they felt i that the quality of DPC's welding was good, they were also interested in seeing that the regulatory. requirements were met. 4 l The inspector discussed the commitments.made. by .Blaisdell'in -the management interview and statedsthat he would review the welding

program during a future inspection. i 2. Safety Feature and Safety-Related. Valves. At Blackley'n request, the inspector discussed.with him Compliance's concerns with safety feature and safety related valves. The. inspector advised Blackley that DEC must be able to document that the valves had bean test operated ac. design. operating conditions , and must also be able to. document that the walls of the valves , in question were of adequate. thickness.for.the intended service. ,

Blackley requested' clarification as.to.the. valves. involved. The inspector rssponded that,the concern.was.with those valves that

formed a y et of the primary pressure. boundary.and those whose integrity was-.necessary to protect. the.public in the event of an j accident. The inspector stated that.those valves whose gross i failure would not result.in.the loss of the. capability to supply ! normal makaup to the reactor. coolant system were excluded. Blackely advised lthe inspector.that DPC was. concerned because the

' problem se. ems.t'o have. grown.from one' involving.only two valve

manufacturers producing valves whose walls did not. meet drawing requirements.to a much greater problem involving all valve manu- ' facturers and valve operator manufacturers and that.the problem , now included the manufacturer's analysis methods. The inspector ' advised 31ackley that as the.AEC had received more information from licensee's, the extent of the problem bad been shown to be greater j than.was originally known to.be. The inspector also told.Blackley l that DPC had initially advised him that Chapman valves and- i ' Limitorque operators were the onlyf ones involved. He also advised Blackley that the. inspector and other inspectors had , I m . _ .&. . - , _ ' . - . . .. . . . . . - , . .

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. (' ; CO Report No. 50-269/72-1 -10- ' discussed the valve problem with DPC personnel during each inspection DPCMechancialQAEngineer.-{prstbeendiscussedwithJ.M.Curtis since May 1971 when it had. .He advised Blackley that the failure of DPC to have records verifying.that.the valves.had been properly designed, manufactured and. tested appeared to be contrary to the requirements of. Criterion. XVII of Appendix B to 10 CFR 50. Blackley advised.the. inspector that.he did not know how DPC management planned to resolve the problem but that he would again bring the matter to their attention. During the management interview,.the inspcctor was requested by Lee to meet with him privately. He advised the inspector that DPC had actually.maasured the walls of 51 valves in Unit 1 and had not found a single valve whose. wall thickness did.not meet code requirements. He further. advised the inspector that DPC had re- analyzed the design .of one valve and had found no deficiencies in the manufacturer.'s analysis. He stated that he had. personally ordered this information withheld from the inspector since he felt that this was.a backfit item. He.remindedtheinsgectorthathe had requested a meeting .with . Compliance . management _/ .with the chief engineers of Crane-Chapman and Limitorque .present and that this request had not been honored. He asked the inspector what could be done, less than a complete _ test. program,.to satisfy the inspector's requirements.~.The inspector. told.. Lee.that he did not set the requirements and, therefore, could.not reduce them. He advised Lee that he would pass. Lee's co=ments.co his supervisor. Lee told the inspector that the valve problem appeared to be generic in nature and he felt should have been. handled..directly.by AEC Headquarters. He stated that DPC planned no further action but if DPC were cited for a regulatory code violation that: he would direct his reply to the Director of Regulation and would. complain.about.the poor communir.ation between regulatory management and.the.. licensee's. management. The inspector told Lee that he would pass these views on to his supervisor. He further advised Lee that the inability of DPC to furnish documentation that the valves were adequate for the intended service appeared to be contrary to perequirementsofCriterionXVII of Appendix B to 10 CFR 50 --1/ CO Report No. 50-269/71-5 1'/ Telecon to DPC (Curtis and Freeze) from CO:II (Murphy), January 25, 1972 --3/ The inspector was advised by Moseley, Senior Reactor Inspector, Region II, on March 1, 1971, that this was not an item of noncompliance. . _ . - ,

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. () CO Report No. 50-269/72-1 -11- 3. Construction Quality Assurance Audits The inspector asked Freeze.and Beam for.the. records relating.to the QA audits of.the construction. program... Freeze stated that only one audit had been performed.and that the only information that he had was a memor=M" from Curtis,.the Chairman.of the. Audit.. Committee, to. Dick. The memorandum _ discussed.only.those_ items which the committee. considered to violate.the requirements of the Construction Department quality assurance manual. The committee.had found deficiencies in drawing control, material receiving and storage, welding documentation, material and component traceability, qualification..of NDT personnel and control of nonconforming material.

Freeze stated that he did not have a copy.of the procedures used in the audit. The. week following.the inspection the inspector called Curtis and asked if the committee.had used written procedures in conducting the audit. Curtis advised.the inspector that he had used Plan U from the quality assurance. manual. The inspector reviewed this document and found_it to be a plan for conducting audits and not a procedure. Section U.3.1 of the plan specified that the Audit Committee must develop. detailed procedures and i 4 check 11sto.for.each audit. .It.further specified that.the checklist would become.a part.of the. report of the audit. The report of the audit did not contain such.a. checklist...The inspector advised Curtis and Freeze that the failure to have procedures for the conduct of the audit appeared to be contrary to the requirements of Criterion XVIII of Appendix B.to.10 CFR 50. 4. Outstanding Items List The inspector reviewed the status of the Unit 1 outstanding items , with Canady and Hampton. Canady agreed to the following changes to the DPC test program for Oconee. a. The Unit 2 reactor building. spray. system will be functionally tested as a complete system except for the spray nozzles. This test will be performed prior to the power operation of . Unit 1. b. The Unit 1 high pressure injection system will be tested by ' tripping the. appropriate. engineered _ safeguards instrumentation channels at a system pressure of 1500 psig. This test I will be performed during the plant hot functional testing program. ! ! i L

. _ - - - _ - _ _ _ _ _ _ _ _ - . - . . " CO Report.No. 50-269/72-1 -12- ] c. DPC will contact _DRL to determine the extent.of testing required to demontrate the adequancy of the low pressure injection system. d. During the low power testing..of ~ Unit 1, tests will be performed to determine.the accuracy of the rea'ctor coolant system flow sensing elements. Hampton advised the inspector.that the licensee had. removed e. the steam flush line from above the 4 kv safety feature switchgear.1/ The inspector plans no further action on this item at this time, f. Beam advised.the inspector that a woven. wire fence had been. constructed around the 4 kv safety feature switchgear to prevent unauthorized entry. The inspector plans no further action on this item at this time. 2/ The operations group _has. instituted.a. work. order. system to g. ensure correction of- problems identified by the group.3/ The inspector plans no further action on this item at this time. 1/ CO Report No. 50-269/71-2 --2/ CO Report No. 50-269/71-4 --3/ CO Report No. 50-269/71-9 . I .

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. CO Report No. 50-269/72-1 -13- - ( I SECTION III Prepared By: R. F. Warnick, Reactor - Inspector ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND 1. General L. E. Summerlin, DFC's Staff Engineer,.has. prepared a summary of the preoperational.and startup test programs. The status as of January 21, 1972, is as follows: , . Total Approved Tests Results Approved or Number Procedures Completed. Tests Signed Off

Tests Before Hot Functionals. 394 392(99%) 318(81%) 257(65%) Tests During Hot Functionals. 132 104(79%) 47(36%) 36(27%) Tests Prior to Core Loading 125 84(67%) 58(46%) 44(35%) Total Preoperational Tests 651 580(89%) 423(65%) 337(52%) During a telephone conversation on November.17,.1971, with Murphy, Smith agreed tg. review the. FSMR to ensure that all. testing requirements 1 l are fulfilled by the test procedures.1/. While.at the site, the ! inspector received a copy.of.the form DPC uses to assure. testing requirements are not.omitted. The form is attached.as. Exhibit A.. The form provides the administrative control tool to make sure the test author (or equal) reviews the FSAR, Technical Specifications, test specifications, and. precautions.and limitations. 2. Preoperational Test Program - Evaluation of Test.Results I TP-1B-150-1B, Reactor Building Leak Rate Test RTD/ Digital Temperature System. TP-1B-200-3, Rev. 1, Reactor.Coolanc System Hydrostatic Test . TP-1B-200-23A, Reactor Coolant Pump Motors Instrument Calibration TP-1A-201-2, Core Flood Tanks Hydro. Test i TP-1A-201-2A, Rev. 3, High. Pressure Boric Acid Pump Hydro TP-1A-201-3, Rev. 3, Core Flood System Functional. Test TP-1B-203-4, Rev. 3, Low Pressure System Hydro Test --1/ CO Report No. 50-269/71-10, Section III, Paragraph 6. , . - - - ,

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. . CO Report No. 50-269/72-1 -14- ~ TP-1A-204-2, Rev. 2, Reactor Building. Spray. System Hydrostatic Test TP-1A-340-17, CRD System Redundant Trip Confirm and Source Interruption Chassis. Test 3. Preoperational Test Program - Procedure Review TP-1A-110-2, Rev. 3, Penetration Room Pressure Drop and Filter Test TP-1A-160-2, Rev. 1, Reactor Building Coolers Functional. Test TP-1B-202-2A, HPI Letdown Hydro., Red.Section TP-1A-230-5, Rev. 1, Soluable Poison Control Operational Test TP-1A-301-3M, NI & RPS Rod Withdrawal Inhibit Functional Test DETAILS OF SUBJECTS. DISCUSSED.IN SECTION..I . 4. Test Results and Evaluations. The inspector reviewed the results of 19 preoperational tests and evaluated the results of 13. The results of the other.six were not evaluated by Compliance because. all. or part of. three. tests had to be rerun, DPC had.not completed.their evaluation of two tests, and the results of.one test had not been reduced to meaningful and understandable form. Of the 13 tests given a clean bill of health by .DPC, the inspector evaluated the results and. determined the requirements of nine tests had been satisfied, the requirements of.one test had not been satisfied, and it was questionable whether or not the results of the other three tests had been satisfied. The results of eight of the thirteen tests had been approved by the plant superintendent. Of the eight completed tests approved by the plant superintendent, che inspector. determined the requirements of five tests had been satisfied, the requirements of one test had not been satisifed, and it was questionable whether or not the requirements of the other two tests had been satisfied. The inspector's findings were. discussed.with Hampton, McIntosh, and Kaehler during the.. inspection. . The inspector. tried. to get a. commitment from Hampton.to summarize the results of each test in some meaningful and understandable form similar to what the operating engineer had done for each hydro test.

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. CO Report No. 50-269/72-1 -15- - The inspector summarized.his findings.at.the exit. interview and said that they appeared to be in. noncompliance.with Criterion XI, Appendix B, 10 CFR 50. Hampton stated that DPC would do a better job of presenting the results.of the evaluations Details of the tests with unsatisfactory or questionable results are as follows: a. TP-1B-200-3A, Hydrostatic Test of Vent Plugs for Incore Instrument Piping Closure Assembly The inspector reviewed the recorded. data, the. test log, and the test procedure and concluded that the test results did not meet the test acceptance criteria. Fifty-two valves were tested and did not leakt Seventeen valves were replaced because of thread damage. The replacement valves were not. tested. b. TP-1A-201-5, Rev. 2, Core Flood System Flow Test The test was evaluated by.B&W and a letter dated _ July 27, 1971,

stated that the results are acceptable. The letter also states l "the level. instrument on Tank B may have indicated improperly." The letter suggests "that tank level (and Pressure) instrumentation be ( checked carefully prior to operation." The inspector reviewed the completed test and concluded that the results are questionable.since the B tank level instrument indicated below the level of the lower instrument tap. The A tank level instrument drew a horizontal line when the tank level reache'd the* lower tap. c. TP-1B-150-1C, Reactor Building Absolute Pressure Measurement, Texas Instrument The inspector reviewed the test file. Although not specifically . required by the test procedure, there was no recorded data to document'that the purposes of the test had been accomplished. Based on available information the inspector could not conclude that the test purposes had been satisfactorily met, d. TP-1B-150-1A, Reactor Building Leak Rate Test Cambridge Dew Point Hygrometer The inspector reviewed the test data and concluded the results were questionable since two calibration check points exceeded the _

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, C0 Report No. 50-269/72-1 -16- , allowable tolerance of + .250F. A calibration error of .5 F was recorded on page 2 of the data sheets and a calibration error of .6 F was recorded on page 3 of the data sheets. The 0 results of this test had not been approved by the plant superintendent. 5. Comments on Preoperational Test Procedures The inspector reviewed 12 preoperational test procedures and discussed his comments with McIntosh, Koehler,and Bradham. Significant comments are as follows: a. TP-1A-330-3A, Control Rod Drive Drop Time Test This test was discussed with Bradham, who indicated that DPC planned to drop each control rod at least five times under cold conditions and at least three times at operating temperature, pressure, and flow. He indicated they would cycle each rod at least eight times cold and at least two times hot. The drive direction will- be reversed at least five times for each control group. The inter- locks and all instrumentation will be checked. Bradham said DPC would consider dropping all rods simultaneously and also additional drops of the fastest and slowests rods. The inspector ( indicated 25 additional drops would be appropriate and that the inspector would pursue the matter further should they choose a lesser number of additional rod drops. This was discussed at the exit interview. b '. TP-1A-160-2', Rev. 1, Rea'etor Building Coolers Functidnal Test Kmhler indicated the engineered safeguards portion of this test as described in the FSAR abstract on page 13-15 is included in hot functional test TP-600-17. This was confirmed by Koehler in the exit interview. This procedure is considered to be adequate. TP-1B-230-6, Rev. 2, Auxiliary Drains & Liquid Waste Disposal c. Functional Test The procedure does not provide for testing all building floor drains and all systems vents and drains. The inspector explained thst any system with potential for handling radioactive effluent should be tested. McIntosh stated they will look at the procedure, identify system vents and drains and building floor drains with potential for radioactive effluent which are not included in the present procedure, and give the reason for not including them in the testing program. In addition, the inspector stated that the acceptance criteria was weak and the procedure did not check the interlocks associated with valve LWD-132. McIntosh indicated he would look at both 1 these items.

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, , CO Report No. 50-269/72-1 -17- , SECTION IV Prepared By: F. Jape, Reactor

Inspector

i ADDITIONAL SUBJECTS INSPECTED, NOT IDENTIFIED IN SECTION I, WHERE NO

DEFICIENCIES OR UNRESOLVED ITEMS WERE FOUND , 1. General. 4 This inspection was directed toward review of preoperational tests,. . hot functional tests and evaluation of test results.

2. Test Procedures Reviswed a. TP 202-7 - HPI Operational Test i b. TP 301-32 NI-1 and NI-2 HV Interlock Functional Test " c. TP 301-3N RPS and NI Initial Power Applicati6n. , d. TP 310-9 2/3 Logic Functional Test i e. TP 323-5 Neutron Power Error and RCP Interlock calibration j f. TP 1B 600 1 Controlling Procedure for HFT j g. TP 1A 600 10 RCS Hot Leakage Test h. TP 1C 600 24 First-of-8-kind test - RV and OTSG Support Flange Temp.

Test Results Reviewed , " TP 1A 204 5 RBS System ESG test. 4. Results of the Review of Test Procedures i j No deficiencies were identified in the eight tests that were. reviewed. j Comments were prepared on TP 207-7 HPI Oper. Test. These were discussed

with McIntosh. Most were resolved during the discussion and several ' comments were noted by W.Intosh for his review at a later time. S. Results of Evaluation of Test Results l

l TP 1A 204 5 RB Spray System Engineered Safeguard Test was run on September 21, 1971. The test, as run, did not fulfill the requirements 4 stated in Section 6.2.3 of the FSAR. This deficiency was noted in CO Reports Nos. 71-3 and 71-10. The plant superintendent has apparently acknowledged this deficiency since he has withheld his-acceptance signature. The status of this item was discussed with Koehler i ' .and plans are underway to filfill the FSAR requirement. DETAILS OF SUBJECTS DISCUSSED IN SECTION I None . Attachment: Exhibit A i .. .. . 1

-- - _ DUKE POWER COMPANY " "' . ~ OCONEE NUCLEAR STATION (" s . TEST PROCEDURE VALIDATION CHECKLIST , . Date Rev. Procedure number Procedure name Procedure status: Draft Awaiting Test (Circle one) Prel Test ng Final Test Complete SRC Test Approved (Latest FSAR Rev. # ) 1. FSAR Check The following FSAR sections have been checked for agreement with the procedure: -= 2. Tech Spec Check (Tech Spec date ) ' The following Tech Spec sections have been checked for agree =ent with the procedure: , . 3. Test Specification Check Test Specification TS has been checked for agreement with i the procedure. The TS is a (Preliminary / Final) and the TS date is . 4. Lir.its and Precautions Check (DP 1101/01 date ) The following Limi'ts and Precautions sections have been checked for agreement with the procedure: . . -I have checked all of the above noted sou'ces and have found no d'iscrepancies between them and the current TP. Test Coordinator I hive checked all of the above noted sources and have found discrepancies between them and the current TP as noted on the attached sheet. Test Coordinator EXHIBIT A __ , }}