ML19322A932
| ML19322A932 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/26/1975 |
| From: | Epps T, Long F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322A925 | List: |
| References | |
| 50-269-75-01, 50-269-75-1, 50-270-75-01, 50-270-75-1, 50-287-75-01, NUDOCS 7911270819 | |
| Download: ML19322A932 (28) | |
See also: IR 05000269/1975001
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UNITED STATES
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Q-
NUCLEAR REGULATORY COMMISSION
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REGION ll
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2JC PE ACHYR EE $7R ECT, N. W.
$UlTC 318
ATLANTA, GEORGI A ~20303
IE Inspection Report Nos. 50-269, 50-270 and 50-287/75-1
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Licensee:
Duke Power Company
Power Building
,
422 South Church Street
Charlotte, North Carolina
28201
Facility Name: Oconee Units 1, 2 and 3
Docket No. :
50-269, 50-270 and 50-287
License No.:
DPR-38, 47 and 55
Category:
C, B2 and B2
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Location:
Seneca, South Carolina
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Type of License:
Type of Inspection: Routine, Unannounced
Dates of Inspection: January 27-31 and February 4-7, 1975
Dates of Previous Inspection: October 29 - November 1 and
November 4-8,1974 (Unit-1)
.2-A'tN.$
Principal Inspector:
/[
W
T. N. Epps , Redctor Inspector
Date
Facilities Opdra'tions Branch
Accompatiying Inspectors:
G. R. Jenkins, Radiation Specialist
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Radiological and Environmental Protection
Branch (January 29-31, 1975)
H. L. Whitener, Reactor Inspector
F cilities Test and Startup Branch
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Reviewed By:
M[
g/ Dats
F. J. Long, Chie'f
[
FacilitiesOperations].anch
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IE Report Nos. 50-269, 50-270-
and 50-287/75-1
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SUFMARY OF FINDINGS
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1.
Enforcement Items
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A.
Infractions
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1.
Contrary to Technical Specification 6.4.1.e, repair and testing
was performed on a type A clectrical containment penetration
in Unit. 3 on December 30, 1974, without an approved procedure.
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(Details II, paragraph 3)
This infraction was identified by the inspector and had the
potential for causing or contributing to an occurrence with
safety significance.
(Unit-3)
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2.
Contrary to CrJ terion V of 10 CFR 50 Appendix B, a number of
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deficiencies were observed in implementation of the controlling
procedures contained in the Duke Power Company Steam Production
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Department Administrative Policy Manual for Nuclear Plants
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(APM), Quality Assurance Department, Quality Assurance Manual
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(QAM), and Oconee Nuclear Station Administrative Procedure No. 9,
Equipment- Renoval and Restoration.
(Details II, paragraph 3
and 4)
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This infraction was identified by the inspector and had the
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potential for causing or contributing to an occurrence with
safety significance.
(Units 1, 2 and 3)
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3.
Contrary to Technical Specification 4.0.2, several Oconee-2'
annual surveillance items have exceeded the 18 month limit.
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(Details I, paragraph 14)
This infraction was identified by the inspector and had the
potential f or causing or contributing to an occurrence with
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safety significance.
(Unit-2)
4.
Contrary to 10 CFR 20.103, two individuals, on separate occasions,
were exposed to airborne radioactive material in excess of the
limits specified in 10 CFR 20, Appendix B, Table 1.
,
This -infraction was identified by- the licensee and caused or
constituted an occurrence'with safety significance.
Each expo-
sure was reported to the Ccomission by the licensee pursuant
to 10.CFR 20.405.
(Details III, paragraph 3)
(Unit-1)
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IE Rpt..Nos. 50-269, 50-270
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and 50-287/75-1
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B.
Deficiencies
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1.
Contrary to Technical Specification 6.5.2.h, records of re-
calibration of the flux /ficw/ imbalance trip setpoints for units
2 and 3 could not be produced by the licensee.
This deficiency
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was identified by the inspector.
(Details I, paragraph 11)
(Units 2 and 3)
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2.
Contrary to 10 CFR 19.13, the licensee had not.provided a
written report to the two individuals exposed to airborne
radioactive material in excess of 10 CFR 20 itnits. This
deficiency was identified by the inspector.
(Details III,
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paragraph 3)
(Unit-1)
3.
Contrary to 10 CFR 20.401, the licensee's fourth quarter,
1974, personnel exposure records were not accurate, in that a
determined correction factor was not uniformly applied. This
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deficiency was identified by the inspector.
(Details III,
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paragraph 4)
(Unit-1)
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II.
Licensee Action on Freviously Identified Enforcement Matters
1.
Unit. Vent Particulate Air Monitoring (RO Inspection Report Nos.
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50-269/74-3 and 50-270/74-2, Item I.A.1.e.)
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To ccmply with Technical Specification requirements, the licensee
is analyzing daily air samples from all three unit. vents. This
item is closed.
(Details III, paragraph 7)
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2.
Procese Radiation Monitor Setpoints (RO Inspection Repoce Nos.
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50-269/74-3 and 50-270/74-2, Item I.A.l.f.)
The licensee has' issued a periodic test procedure that specifies
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setpoints for process radiation monitors.
This item is closed.
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(Details III, paragraph 6) .
Noncompliance items identified in inspection report 50-169/74-11
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are closed.
III.
New Unresolved Items
None
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IV.
Status of Previously-Reported Unresolved Items
Oconee-1 (50-269)
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73-12/1 Calibration of Effluent Monitors
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IE Rpt. !!os. 50-259, 50-270
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and 50-287/75-1
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This is included as a Deviation in Section V.A.2.
This item
remains open.
(Details III, paragraph 5)
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73-13/1 Wastewater Collection Basin Modification
.
This item remains outstanding until the new wastewater
collection basin is ccmplete and operational.
73/13/2 control Rod Failures
This item is closed.
(Details I, paragraph 3)
74-3/3 Training of Unlicensed Utility operators
This item remains open.
74-5/1 Incomplete Power Escalation Testing
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This item remains open.
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74-9/1 Radiological Environmental Monitoring Procedures
This item remains open.
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74-11/1 Emergency Procedure for Loss of Instrument Air
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Work has begun on this jtem.
It remains open.
(Details I,
paragraph 4)
74-12/1 Incomplete Inservice Inspection Plan
This item re=ains open.
Oconee-2 (50-270)
74-7/1 Completioq_of Power Ascensinn Testing
This item remains open.
74-7/2 Activity in the Component Cooling System
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Work continues on this item.
It. remains open.
(Details I,
paragraph 5)
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IE Ep t . ::os . 50-269, 50-270
and 50-287/75-1
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7!-7/3 Hotwell Level Control and Emergency Feedwater System Failures
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This item is closed.
(Details I, paragraph 9)
74-7/4 LPI Valve Failure
Corrective measures to prevent recurrence have not been fully
implemented. This item remains open.
(Details I, paragraph 10)
Oconee-3 (50-287)_
74-13/1 Preventive !!aintenance Program for Eneincered Safe 2uards
Systems
A preventive maintenance program is being established to tighten
wire terminations and clean electrical contacts on a periodic
basis. This item remains open.
74-13/2 Reactor Coolant Flow Ancmaly
Excess reactor coolant flow has been observed and its cause
or explanation has not been determined. Licensee is conducting
tests to resolve the matter. This item renaits open.
74-14/1 Deferral of Loss of Centrol Room Test
.
This itcs remains open.
74-14/2 Ventilation Control Between Auxiliary and Turbine Buildings
This item remains open.
(Details I, paragraph 6)
74-13/3 RPS Pressure Transmitter Check
Licensee plans to check the calibration of the reactor protec-
tive system (RPS) pressure transmitters to determine the cause
for a calibration drif t.
This item remains open.
74-5/12 Handling, Storace and Shipping
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Not-inspected.
Estimated completion date is April 1, 1975.
Item remains open.
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IE Rpt. Nos. 50-260, 50-270
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and 50-287/ 75-1
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74-5/16 Quality Assurance Records
Not inspected.
Estimated completion date is April 1, 1975.
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Item remains open.
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Oconee 1, 2 and 3 (50-269, 50-270 and 50-287),
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74-10, 08, 11/1 Training of Auditors
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A program has been established to train auditors in
reactor operations.
This item is closed.
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74-10, 08, 11/2 Training Program for Mechanics and I&C Personnel
This item remains open.
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74-10, 08, 11/3 Ooerator Reolacement Training
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This item remains open.
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74-10, 08, 11/4 SRC Quorum
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This ites remains open.
74-10, 08, 11/5 Procedure Changes
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This iten remains open.
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74-10, 08, 11/6 Review of Technical Specification Changes
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SRC is now reviewing all Technical Specification
changes before they are sent to Licensing.
This
item remains open.
(Details I, paragraph 7)
74-10, 08, 11/7 NSRC Review Capability
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This item remains open.
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14-10, 08, 11/9 Unreviewed Safety Question
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Administrative : procedures still do not. assign final
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. responsibility for determining if an item : involves an
unreviewed saf ety question.
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IE Rpt. Nos. 50-269, 50-270
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and 50-287/75-1
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74-10, 08, 11/8 NSRC Meeting Frecuency
This iten remains open.
74-10, 08, 11/10
Shutdown Rate _
.
The licensee issued a standing order on this
subject.
This item is closed.
(Details I, para-
graph 8)
74-10, 08, 11/11
Non-Technical Specification Violations
This item remains open.
V.
Other Significant Findings
Deviations
The licensee has failed to meet written co=mitment dates for
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corrective action required to resolve problems with various
effluent radiation menitors.
(Details III, paragraph 5)
VI.
Manacement Interview _
The management interview for this inspection was conducted in two
pcrts as follows.
On January 31, 1975, T. N. Epps, H. L. Whitener and G. R. Jenkins
=et with J. W. Hampton, Acting Plant Manager, and other r2mbers of
Ite=s discussed included the noncompliance ited
the Oconee staff.
The inspec:or
involving =aintenance of a centainment penetration.
this item illustrates the multiple problems that can
emphasized that
develop when established management centrol systens are bypassed.
The taintenance, portion of the semi-annual report was also discussed.
that some areas of the report do not
The inspector pointed out
contain enough infor ation to identify the significance of the items listed.
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!c npt. Noa. 50-269, 50-270
and 50-287/75-1
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The principal inspector reviewed the status of previously identified
unresolved items in Section IV of this semnary and the reportable
occurrences in Details I, paragraph 12,a.
Also discussed were items relating to health physics identified in
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this summary.
On February 7,1974, T. N. Epps and H. L. yhitener met with J. E. Smith,
Plant Manager, and other ncmbers of the DPC staff. The inspectors
summarized items covered in the management interview held the previous
week and discussed other items as follows.
The inspectors discussed the lack of calibration records of the RPS
flux / flow / imbalance trip setpoints on Units 2 and 3; annual calibra-
tion of equipment on Unit 2; shutdown of Unit 3 on February 4,1975,
and lack of implementation of administrative controls in the area of
maintenance including the maintenance and operations organizations.
T. N. Epps informed the Plant Manager by phone on February 12, 1975,
that the item concerning annual surveillance (Summary Section I. A.3)
would appear as an infracticn in this report and not an unresolved item
as previously discussed.
G. R. Jenkins informed the Plant Manager by phone on February 18, 1975
that the item concerning the fourth quarter personnel exposures would
appear as a deficiency in this report, and not an unresolved item,
and the item ccncerning resolution of radiation monitor probicas
would appear as a deviation.
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IE Report Nos. 50-269, 50-270
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DETAILS I
Prepared By:
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T. M. Epps ,/Rgaetor Inspector
Date
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Facilities Operations Branch
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Dates of Inspection: January 27-31 and February 4-7, 1975
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Reviewed By b
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F. J. Long, Chief
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Facilities Operations Branch
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1.
Individuals Contacted
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Duke Power Company (DPC)
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J . E. Smith - Manager, Oconee Nuclear Station
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J. W. Hampton - Director, Administrative Services
L. E. Schmid - Operating Superintendent
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0. S. Bradham - Maintenance Superintendent
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R. M. Koehler - Technical Services Superintendent
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T. S. Barr - Technical Services Engineer
R. P. Bugert - Training Supervisor
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R. L. Wilson - Performance Engineer
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k . Brown - S taf f Chemist
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W. M. McClain - Shif t Supervisor, Procedures
J. Cox - Station Senior QA Engineer
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2.-
Reactor Coolant System Pressure Transmitters
a
An Oconee.1 abnormal occurrence was reported in May, 1974, when all
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four narrow range RCS pressure transmitters were found to be out of
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calib- tion in the positive direction. These transmitters provide
reactor coolant pressure information to the reactor protective system
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and provide high and low pressure trips.
The transmitters were recali-
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brated and similar transmittersson Units 2 and 3 were checked and
found to be within calibration-limits.
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The licensee's corrective action included plans- to check calibration
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of the transmitters on Unit 1 each 100 effective full power days.
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When this was done on October 30, 1974, all four transmitters had
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drif ted out of calibration in the negative direction by a maximum of
3.3 percent. This is contrary to Oconee Technical Specification
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Table 2.3-1A which requires a lcw reactor coolant system trip setpoint
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of-1800 psig minimum.
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IE Rpt. Nos. 50-269, 50-270
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and 50-287/75-1
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This was reported by the licensee in Abnormal Occurrence Report
50-269/74-18, dated November 13, 1974.
The Pressure Transmitters involved are Motorola Type 56PH, ID No.
1224-0301.
On November 2,1974, the calibration of the reactor coolant pressure
transmitters on Oconee Unit-3 was checked. The Channel A pressure
transmitter RC3A-PT1, was found to be out- of calibration in the posi-
tive direction by 3.2 percent.
On December 15, 1974, a calibration check of Oconee Unit 2 reactor
coolant pressure transmitters was performed.
The channel A transmitter
(RC3A-PTI) was found to be out of calibration in the positive direction
by 2.85 percent.
As a result of the above occurrences , the licensee conducted a test.
program on three transmitters of the above type and one Rosemont
transmitter of similar design.
The testing involved pressurizing the
transmitters in a centrolled environment and varying the surrounding
temperature from 80*F to 120*F and re-checking calibration setpoints.
It was determined that the setpoints on the Motorola transmitters
shifted frem 4 to 5 times as much as the Rosemont transmitter.
The licensee has decided to replace the Motorola RCS narrow range
pressure transmitters with Rosemont transmitters on all three Oconee
Units. Motorola transmitters used for wide range applications will
not be replaced.
This is being carried as an unresolved item.
3.
Control Rod Failures
Previous design changes including change of insulating material used
in control rod drive stators appear to have improved stator reliability.
No control rod drive stator failures have occurred during the past five
conths that can be attributed to the original deficiencies.
This unresolved item is closed.
4.
Emergenev Procedure for Less of Instrument Air
Work had not begun on this item until this inspection. A draft proce-
dure was prepared and has been distributed for ccanents.
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lE Ept. Nos. 50-269, 50-270
and 50-287/75-1
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5.
Activity in the Component Cooling Water (CCW) System
The licensee hydrostatically tested the reactor coolant pump cooler and
found no leaks that could have contaminated the CCW system.
A modification has been approved to add another valve in a pipe connecting
the CCW drain tank header with the miscellaneous waste tank header and
a leak detection tap between the two valves in this pipe.
This is an
to isolate another possible source of CCW system contamination.
attempt
This item remains open.
6.
Ventilation Control Between Auxiliary and Turbine Buildings
A task force is being formed that will study this problem.
This item remains open.
7.
Review of Technical Specification Changes
The licensee stated that the SRC is now reviewing proposed Technical
Specification changes before they are sent to licensing for approval.
Administrative procedures still do not address this subj ect.
This item remains open.
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8.
Shutdown Rate
Standing Order No. 19, dated Nove=ber 14, 1974, requires that a shut-
down rate of "no less than 10"/hr" will be used when a limiting condi-
tion for operation is not met.
This item is closed.
9.
Hotwell Level Control and Emergency Feedwater System Failure,s
The inspector reviewed this incident and had no further questions.
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This item is closed.
10.
LPI Valve Failure
The licensee's corporate office has been requested to evaluate vibra-
tion prcblems in all three Oconee LPI systems.
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IE Rpt. Nos. 50-269, 50-270
and 50-287/75-1
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An interim measure is planned involving rencval of the pins f rom the
subject valves.
This action has been agreed to by the valve vendor
and will be accomplished within 1 month.
This item remains open.
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11.
Calibration of Ecuipment
The inspector reviewed calibration of equipment for Units 2 and 3.
Oconee Technical Specification 6.5.2.h requires that records be prepared
and retained for a minimum of 6 years of periodic checks and calibra-
tions.
Contrary to the above reccrds of re-calibration of the flux / flow /
i= balance trip setpoints for Units 2 and 3 could not be produced by the
licensee. These settings were adjusted after the Unit-1 flux / flow /
imbalance trip settings were fcund to be in error in March 1974. A
licensee representative stated that these calibrations were accomplished
on both Units 2 and 3.
12.
Unusual Occurrences
a.
Infractions Indentified by Licensee
(Unit-1)
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1.
Oconee Technical Specification Table 2.3.-LA requires a caximum
high reactor coolant system pressure trip setpoint of 2355 psig.
Contrary to the above on October 30, 1974, all four primary
coolant system pressure transmitters were found to be out of
calibratica by as much as + 5.9 percent.
Cc rective acticns described in the licensee's abnormal occur-
. .tce report- (AO-269/74-18) dated November 13, 1974, were
reviewed and the inspector had no further questians.
The problem
with the transmitters involved is being carriad as unresolved
item 74-13/3 on Unit 3.
(Details I, paragraph 2)
2.
Oconee Technical Specification 4.6.1 requires a =onthly test
of the Keewee hydro units.
Contrary to the above there was an interval between Keowee
operational periodic tests f rca August 15 to October 1, 1974.
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(Unit-3)
6.
Oconee Technical Specification 3.5.2.4e requires that reactor
quadrant power tilt be monitored on a frequency not to exceed
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during power operation above 15 percent of rated power.
Contrary to the above, on December 10, 1974, quadrant tilt was
not accurately determined for 3 1/2 hours.
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Corrective action described in the licensee's abnormal' occur-
rence report A0-287/74-11 dated December 26, 1974, was reviewed
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and the inspector had no further questions.
7.
The licensee's abnormal occurrence report A0-287/74-10 dated
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December 4, 1974, involved a similar violation of Technical
,
Specification 3.7.l(g) as item 4 aoove.
There are no further
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questions on this item.
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8.
Oconee Technical Specification 3.6.4.a.1 requires that if a
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reactor building hatch is inoperable the re=aining door of the
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affected hatch shall be closed and sealed.
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Contrary to the above on November 14, 1974, maintenance person-
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nel opened the outer personnel hatch door to repair a leak on-
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the inner door.
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Corrective action described in the licensee's abnormal occur-'
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rence report A0-287/74-9 was reviewed and the inspector had no
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further questions.
b.
Other Licensee Reported Occurrences Reviewed
The inspector also reviewed the following occurrences during this-
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inspection.
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1.
A0-269/74-14 RCS pressure switch failure.
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2.
A0-269/74-16 Waste gas release.
3.
UE-269/74-6 CRD breaker-cabinet seismic requirements not met.
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4.
A0-269/74-17
"B" LPl and R3 spray pump room in water.
5.
A0-269 / 74-20 RC pressure transmitters out of calibration.
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This subj ect is being carried as an unresolved
item on Unit. 3.
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6. 'AO-270/74-19 Valve 2 LP-22 failure.
7.
A0-287/74-4 Excess RCS flew. This item is being carried as
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an unresolved item.
8.
A0-287/74-7
R,C. pressure transmitter out of calibration.
inis item is being carried as an unresolved item.
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9.
A0-287/74-8. RPS bistable failure.
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IE Ept. Nos. 50-269, 50-270
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and 50-287/75-1
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Corrective actions described in the licensee's Unusual Event
Report U.E.-269/74-7 dated December 20, 1974, were reviewed
and the inspector had no further questions.
(Unit-2)__
3.
Oconee Technical Specification 6.4.1 requires that the station
be operated in accordance with approved procedures.
Operating Procedure OP/A/1104 requires that low pressure
service water be established to the low pressure injection
coolers in the decay heat removal mode.
Contrary to the above on October 4,1974, while Unit 2 was in
the decay heat mode, low pressure service water was not pro-
vided to the LP1 coolers.
Corrective action described in the licensee's abnormal occur-
rence report A.0.-269/74-14 dated October 18, 1974, were ini-
tiated and there were no further questions.
4.
Oconee Technical Specification 3.7.1(g.) requires all 125 VDC
insttumentatien and control batteries and associated equipment
supplying the units vital instrumentation and the four instru-
centation control panel boards to be operable when reactor
temperature is above 200*F.
Contrary to the above on Novecher 19,1974, the 2D13 static
inverter was found to be inoperable and bypassed.
Corrective action described in the licensee's abnormal occur-
rence report A.0.-270/74-18 dated December 4, 1974, was
reviewed and the inspector had no further questions.
5.
Oconee Technical Specification 3.3.7 requires redundant ccepo-
nents to be tested to assure operability prior to initiating
,
maintenance.
Contrary to the above, on September 28, 1974, the circuit breaker
for the 2LP-22 salve notor was opened, to check the thermal
overload coils, without verifying cperability of valve 2LP-21.
The licensee's abnormal occurrence report A.O.-270/74-13 dated
October 11, 1974, was reviewed and the inspector's questions
were satisfactorily answered.
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IE-Rpt.~"os. 50-269, 50-270
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13.
Reactor Operations (Units 1, 2 and 3)
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The inspector reviewed plant operations including records reviews and
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plant tours.
Unit-3 was the only . unit operating during this inspection.
On February 4,1975, Unit-3 was shut down due to a feedwater leak in
Difficulties
the penetration room' causing high humidity in the room.
were encountered with 2 RC system temperature indications drif ting lower
than actua1' temperature, causing 2 out of 4 high RC temperature trip
settings to be less conservative than required by Technical Specifications.
4
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The first temperature indication to drif t was in channel "C" which
was picced in trip bypass at 9r26 a.m.
The second was in channel "D"
which was placed in trip bypass at 6:19 p.m.
RPS channel "C" was
tripped at 7:12 p.m. to comply with Technical Specification 3.5.1
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which requires 2 RPS reactor ecolant temperature instrument channels
]
to be operable with a minimum degree of redundancy of 1.
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The inspector stated that Technical Specification 3.5.1 was not met
for about one hour after the second channel was placed in trip bypass
until channel "C" was tri),.d.
The inspector expressed concern that no SRC meeting was held to
evaluate the safety implications of continuing operation at 99. percent
power until unit shutdown was initiated at 9:00 p.m. that evening.
The licensee stated that plant personnel reviewed the conditions and
informed the DPC corporate of fice that day.
The licensee will submit an abnormal occurrence report on this inci-
dent.
The inspector stated that further evaluation of this incident would be
conducted af ter the licensee's report is received.
14.
Annual Surveillance
Oconce Technical Specification 4.0.2 requires that the maximum allowable
interval between annual surveillances be 18 months.
i
Contrary tos the _above , several Oconee-2 annual surveillance . items have
not been conducted within the 18 month limit.
Following are some
. examples-of this. condition.
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Unit-2
Unit-2
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Annual Surveillance Item
Date of Lact. Calibration
,
Reactor Ccolant Temperature
July ~30, 1973
(IP/0/A/305/1 EFG&H)
Control Rod Absolute Pos1*. ion
August-1, 1973
(IP/0/A/340/4-1)
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Steam Generator Water Level
June 23, 1973
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Pu=p. Flux Comparator
July 30, 1973
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Core Flood Tank Pressure
December 3, 1972
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Core Flood Tank Level
November 6, 1972
Reactor Building Emergency Sump Level
October 12, 1972
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15.
Regulatorv Operations Bulletins
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The licensee's responses to the following ROB's were reviewed and
the inspector had no further questions.
.
R0B 74-12 " Incorrect Coils in Westinghouse Type SG Relays"
a.
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b.
R03 74-13 " Improper Wiring on GE Electric Motor Control Centers"
R0B 74-15 " Misapplication of Cutler-Hammer Three Position Main-
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c.
tained Switch"
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d.
R0B 74-16 " Improper Machining of Pistons in Colt Industries
(Fairbanks-Morse) Diesel-Generators.
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IE Rpt. Nos. 50-269, 270, 237/75-1
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?6 70
DETAILS II
Prepared by:
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H. L. Whitener, Reactor Inspector
Date
.
Nuclear Engineering Group
Facilities Test and Startup Branch
Dates'of Inspection:
January 27-31, 1975
<-
Februar* 4-7, 1975
,
4[27/pf
Reviewed by:
_.
W. C. Seidle, Qbief
Date
Facilities Test and Startup Branch
1.
Individuals Contacted
J. E. Smith - Panager, Oconee Nuclear Station
-
J. W. Hampton - Director, Administrative Services
O. S. Bradham - Maintenance Superintendent
F. E. Schmid - Operating Superintendent
R. M. Koehler - Technical Services Superintendent
T. S. Barr - Technical Services Engineer
R. L. Wilson - Performance Engineer
A. Franklin - Administrative Assistant
D. Thompson - Mechanical and Electrical, Maintenance
R. Adams - I&C, Maintenance
J. Davis - Planning Engineer, Maintenance
J. Cox - Senior QA Engineer
J. Brackett - Assistant QA Engineer
.
2.
General
The purpose of this inspection was to review the licensee's control of
maintenance activities for the Oconee Nuclear Station.
Types of docu-
mentation of which portions were reviewed.during the inspection includ 4:
a.
Work Request Files.
b.
Work Clearance Permits (Adm. Proc. No. 9).
c.
Maintenance Procedures.
d.
Instrument Procedures.
QA inspections /results,
e.
f.
Station modification, performance testing and results, containment-leakage
calculations, periodic tests and incident reports where these items had a
bearing on a specific maintenance item or limiting condition for operation
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Semi-annual report on station maintenance activities.
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h.
Duke Power Company Quality Assurance Department Quality Assurance
Manual (QAM), Steam Production Department Administrative Policy
Manual (APM), Administrative Procedure No. 9, Oconee Technical
Specifications and FSAR, and licensee internal correspondence.
.
3. - Containment Penetration
A breakdown of =anagement control systems was observed which
involved maintenance on a containment electrical penetration.
Internal
pressure in the canister containing reactor coolant pump cables for unit
3 was found to be leaking off.
The canister internal pressure boundaries
are formed by double seals on the cables penetrating the canister. The
licensee ran a local leak detection test by an approved procedure,
PT/0/A/150/17, to identify the leaking area.
The test summary indi-
cated that a major separation between the glass to metal seal had occurred
on the outer canister seal (Penetration room side) .
In repair of this
leak, the licensee failed to conform with a number of requirements for
maintenance of safety related equipment as noted below:
An approved maintenance repair procedure was not developed and
a.
followed.
This is contrary to Technical Specification Section 6.4.1.e, QAM Sections
3.3.2 and 3.3.3, and the APM, Sections 3.3
and 4.3.
The QAM and A?M requirements encompass the appropriate
procedure review for adequacy and quality control and appropriate
followup review and corrective action if discrepancies are identified.
b.
A Work Request (WR) was not written for repair of the leak.
.
This is contrary to Section 3.3.3 of the QAM which specifies
that Work Requests will be reviewed for QA requirements, QC
hold points and approved by Station Senior QA Engineers prior
to initiation of the work.
c.
A Work Clearance Permit (WCP) was not issued for accomplishing
~
the equipment removal and restoration to service.
This is con-
trary to Administrative Procedure No. 9 which implements control
to assure adequate removal and restoration of equipment to service.
.
d.
Discussion with licensee personnel indicated that the leakage
repair and subsequent testing, although not accomplished by an
approved procedure, were performed in accordance with written
instructions contained in a letter; Wylie to Parker dated
September 19, 1974
The inspector reviewed this letter and
found that it' contained' precautions to be taken prior to
implementing repair and specifications for epoxy materials
to be used in the. repair.
However, deficiencies in'the use
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of these instructions were observed as follows:
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.(1) Approval of the instructions as a temporary maintenance procedure
was not indicated by the Station Manager's signature as required
by Section 4.3.-2.2.3 of the APM.
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(2) A precautionary note in.the instructions specified that this
repair technique was for use with small cracks in the glass
'
and where the glass to metal seal is not leaking.
In this
case a major glass to metal separation existed.
Failure to follow
the written instructions which were being used as a temporary
procedure is contrary to Section 3.3.2.4. of the AIM which requires
that maintenance be accomplished in accordance with the written
4
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procedure.
[
(3) The instructions specified that after the repair was made, the
penetration canister should be pressurized to 60 psig to assure
an effective repair.
In this case three unsuccessful attempts
4.
were made to pressurize the canister to 60 psig.
The canister
was left capable of holding about 10 psig.
Failure to meet the
!
test pressure specified by the instructions being used as a
temporary procedure represents a discrepancy as defined by
Section 4.3.2.2.7 of the APM.
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(4) A Discrepancy Notice was not written to indicate that the
l
penetration as left did not meet the pressure test specified
in the instructions.
This is contrary to Section 4.3.5.2 of
l
the APM which requires that a Discrepancy Notice be attached
i
to the procedure, in this case the instructions contained in
the letter of September 19, 1974, when the conditions of the proce-
dure are not met.
The purpose of this notice is to bring the
discrepancy to the attention of appropriate management levels
during procedure review and to document the action to determine
and perform corrective action and to verify the adequacy of
corrective action.
4
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(5) A Review of Completed Procedures form was not completed far-
the repair work as required by Section 4.3.5.2 of the APM.
.i
This requirement is'to assure that appropriate levels of
management review the procedures and are cognizant of any
discrepancies.
(6) Failure to follow established procedure could also result in the
loss of this ites as a piece of maintenance history since the
-
history is compiled from the work request file.
At.the >bnagement Interview the inspector identified the failure to
develop and follow an approved procedure for maintenance on a contain-
,
ment penetration as an apparent item of noncompliance with the Technical Specification, Section 6.4.1.e, which requires - that' approved detailed
written procedures which contain appropriate checklists and instructions
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be used for preventive and corrective maintenance which could affect
nuclear safety or radiation exposure to personnel.
The inspector further
emphasized to manage =ent that this situation demonstrates the results
likely to occur when the =anagement controlling procedures are not
rigorously followed.
4.
Control of Maintenance Activities
Failure to adequately i=plement management controlling procedures was
observed in a number of instances.
Criterion V of Appendix B to
10 CFR 50 requires that, " Activities affecting quality shall be pre-
scribed by documented instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomplished in accordance
with these instructions, procedures or drawings.
Instructions, procedures,
or drawings shall include appropriate quantitative or qualitative acceptance
criteria for determining that important activities have been satisfactorily-
accomplished." Management control to ensure that these requirements are
met is implemented by controlling procedures which are ' delineated in docu-
ments such as the Quality Assurance Manual, Ad=inistrative Policy Manual,
Administrative Procedures and Management Directives.
,
thintenance activities were reviewed to determine compliance with
the appropriate sections of these documents.
Results of this review
based on discussions with licensee personnel and examination of
maintenance documentation are discussed below:
a.
Administrative Procedure No. 9 was issued July 16, 1974,
i
(Revision 10/15/74) to establish a program to control
removal from and return to service of equipmer.t affecting
'
the proper operation of the station.
The procedural require-
ments are implemented by a form called a Work Clearance Permit
which is used to control and document that equipment:
(1) Is identified when removed from service.
(2) Is placed in a safe condition for work.
(3) Receives proper review of impact that removal or
1
work en this equipment has on plant or system operation.
(4) Receives adequate review and two-party verification
that equipment has been properly returned to service.
b.
Observations regarding implementation of Administrative
Procedure No. 9 vere as follows:
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(1) Contrary to the requirements of Administrative Procedure
No. 9, Work Clearance Permits were not issued for the following
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(a)' The repair of containment electrical penetration
WMV-1 in Unit 3, 12/30/74.
(discussed in paragraph 3)
'(b) Removal and replacement of Source Range Detector NI-2-
on Unit 1, 12/28/74.
(c) Replacement of motor on the Limitorque Operator for-
LP-22, ES valve between Low Pressure Injection Pump.
.' .
and Borated Water Storage Tank on Unit 2, 12/21/74.
,
(d) tbdule Change Out on Reactor Coolant Narrow Range Pressure
Channel A, on Unit 1, 1/7/75.
,
(2) Contrary to the instructions of Administrative Procedure
'
No. 9, a number of Work. Clearance Permits (WCP) which were
issued were not completed.
Some examples, typical of the
discrepancies observed, are noted below:
(a) Re= oval and re-installatien of the High Pressure
Injection Pv:i 1A minimum recirculation ori.fice in
d
Unit 1, 12/14f74.
The Work Request for this job
!
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was signed off as completed on 12/16/74; reviewed
and accepted on 12/18/74.
Information in the WCP,
dated 12/12/74, did not specify:
a
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- Other components or systems affected.
- Special precautions or conditions required.
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- Component identified as being out of service.
- Special precautions reviewed.
'
- System returned to normal.(two-party verification).
,
.
In response to the inspector's question, a licensee
$
representative stated that a separate procedure was
not written for the isolation and preparation of the
system for welding.
(b) Removal of.the High Pressure Injection Pump 2A minimum
' !
recirculation orifice on Unit 2, 12/16/74.
t
The same conditions as. stated in item 2.a. above were'
identified with an additional omission; the cognizant
{
maintenance representative had not signed'the WCP.
Both operations and maintenance representatives are
required to sign the WCP.
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Rpt.-Nos. 50-269, 27], 287/75-1:
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c.
Section 3.3.3 of the Quality Assurance Department Quality
Assurance Manual.(QAM) requires that maintenance Work Requests
.
shall be reviewed for quality assurance requirements and
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quality control hold points and approved by the Station
Senior Quality Assurance Engineers prior to initiation of
!
work.
Contrary to this requirement, Work Requests were not
issued for:
(1) Repair of containment electrical penetration WMV-1
,
on Unit 3, 12/30/74
(discussed in paragraph 3)
"
(2) Change out of module in the Reactor Coolant Narrow
Range Pressure Channel A cn Unit 1, 1/7/75.
d.
Sections 3.3.2.10.(f) and 3.3.3.10.(g) of the Actinistrative
!
Policy Manual require that unit status be specified in a
mechanical or instrument maintenance procedure and appropriate
provision shall be made to document compliance with the re-
quired status.
Contrary to this requirement, provision for signoff indicating
,
compliance with unit status was not included in procedures as
'
follows:
,
(1) IP/0/A/301/3B: Nuclear Source Range Calibration
(2) IP/0/A/301/3J:
Nuclear Detector Re= oval And Installation
'
.(3) IP/0/A/305/1M: Reactor Coolant Pressure Instrument Calibration
e.
Sections 3.3.2.4 and 3.3.3.4 of the Administrative Policy Manual
require that =aintenance be performed in 'accordance with written
7'
procedures and references section 3.3.2.10 fo contents of
=echanical procedures and 3.3.3.10 for contents of instruzent-
<
procedures.
Sections 3.3.2.10.(g) and 3.3.3.10.(e) state that
maintenance and instrument procedures will contain a list of
j
prerequisites and provision made to verify compliance with
I
these prerequisites.
Contrary to this requirement, procedures which did contain the-
prerequisites and provisions for verification of compliance with
'
the prerequisites were used for multiple equipment =anipulations
with a single signoff after a significant time lapse as follows:
(1) IP/0/B/301/3J was dated 12/23/74.and 12/28/74
~ The procedure
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was:used to' replace detector N1-7 on 12/23'and N1-2 on 12/28.
Only a single checkoff of prerequisite conditions was performed.
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-(2) MP/0/A/1200/7 was dated 1/21/75 for Units
1 and 2 and
a second procedure was dated 1/27/75.
Each of these
procedures contained removal and installatien steps
'
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for pressurizer relief-valves.- However, in the case
of. Unit 1, removal and installation of the valves were
perfor=ed approximately one week apart with only a
single checkoff of initial conditions.
f
5.
Maintenance Report
The inspector discussed the reporting of station maintenance
history in the Semi-Annual Report which licensee management
submits to NRC. Maintenance items need to be more clearly
identified.
The inspector found it difficult to assess the
significance of =any maintenance entries in the January-
- -
June 1974 report and in the preliminary compilation of items
i
for the July-December 1974 report on the basis of the informa-
i
tion provided. When questioned on this catter, licensee
-personnel found it necessary in many cases to refer to Work
Requests, valve lists and plant draw 1ngs to determine the
'
significance of an item. The inspector urged the licensee
3
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to consider making the report more descriptive and that the
items in the report be identifiable with onsite maintenance
l
records.
Licensee manage =ent agreed to take steps to improve
the usefulness of this report.
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DETAILS III
Prepared by*
/u,
v2 , -
G.. k. JknjFF, Radiation Specialist
Date
Reactor Mcility Section
~
Radiological and Environmental
,
Protection Branch
Dates of Inspect on: Jan try 29-31, 1975
7h
Reviewed by:
7
i NT
,
A. F. Gfbson, Senior Health Physicist Date
Reactor Facility Section
Radiological and Environmental
Prottetion Branch
All infor:::ation in the details applies equally to Units 1, 2 and 3 except
where information is identified with a specific reactor.
1.
Individuals Contacted
Duke Power Co. (DPC)
R. M. Koehler - Superintendent of Technical Services
C. L. Thames - Health Physics Supervisor
D. C. Smith - Chemist
T. S. Barr - Technical Services Engineer
C. T. Yongue - Assistant Health Physics Supervisor
M. C. Williams - Assistant Health Physics Supervisor
L. Lewis - System Health Physicist (telephone contact)
.
2.
Unit 3 Power Ascension Tests and Surveys
The inspector reviewed the results of TP/3/A/800/3, " Biological
a.
Shield Survey," and reviewed records of other radiation, conta=i-
3
nation, and airborne surveys made during the powey ascension phase
of Unit 3.
The inspector had no questions on these surveys,
b.
The inspector noted that, during a preoperational inspection of
Unit 3, the licensee had agreed to make measurements, after startup,
to evaluate any losses of particulate activity in the reactor
building air monitor sample line. A licensee representative stated
that these measurements have not been made, but stated that they
would be completed by March 1, 1975.
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Regulatory Guide 1.68, "Preoperational and Initial Startup Test
c.
Programs for Water Cooled Power Reacters," includes tests for
verification of calibration of effluent monitoring systems by
.
laboratory analysis of samples.
Such tests are to be conducted
l
as early in power ascension as possible and repeated at major
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power plateaus.
When questioned, a licensee representative
l
stated that such tests had not been conducted during the Unit 3
,
!
power ascension test program.
A licensee representative stated
that comparison tests will be made by March 1, 1975, for the
waste gas and vent gas monitors.
He stated that the vent particu-
late and iodine monitors, currently considered inoperable, will be
tested after the monitor problems are resolved.
3.
Exposures of Individuals to Airborne Radioactive Material
a.
On November 4,1974, and again on November 9,1974, separate
individuals participating in Unit 1 refueling activities were
exposed to concentrations of airborne radioactive material
l
which exceeded the limits of 10 CFR 20.103.
Each of these
incidents was reported to the Commission in accordance with
l
,
In each case, the licensee used whole body
"
counting results to determine that exposure to airborne con-
"
centrations above limits had occurred.
The inspector discussed
the circumstances with licensee representatives and reviewed
the corrective action taken.
In both instances, the basic
cause was failure to use respiratory protection while working
'
with equipment which had been exposed to reactor coolant water.
In one case, the personnel involved did not contact health .
physics for a radiation work permit specific to the werk to be
done; in the other case, health physics personnel failed to
recognize the need for and to specify the use of respirators.
As a result of these incidents, the plant manager issued an
intrastation letter cautioning all personnel to follow procedures
l
and use good health physics work practices to protect from internal
'
exposures.
In addition, the health physics supervisor stated that
health physics policy now requires use of respiratory protection for
any work on equipment that has been in contact with reactor coolant
water.
He stated that this policy had been provided to h alth physics
i
personnel by handwritten memo and discussion.
The inspector stated
l
that, unless this policy.was incorporated into a written procedure,
I
its application could not be assured. The licensee representative
'
agreed and, during the inspectica, a change was issued to HP/0/3/1000/05,
"Use of_ Protective Clothing and Related Equipment," incorporating the
above policy.
The inspector had no further cuestions regarding correc-
tive action.
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1E apt. Nos. 50-269, 270, and
287/75-1
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b.
10 CFR 19.13 requires that a written report of exposure be
provided to the individual involved not later than when the report
of exposure is transmitted to the Commission.
When questioned,
a licensee representative stated that written reports had not been
the re-
provided to either of the two individuals discussed above;
ports to the Commission were dated December 4,1974, and December 9,
1974.
He stated that the exposures had been discussed with each
individual, but that written reports had not been planned until
all quarterly exposures had been tabulated. Written reports were
transmitted to each individual during the inspection.
4.
Personnel Radiation Exposure Results
a.
A licensee representative brought to the inspector's attention a
situation wherein the possible overexposure of two contract per-
sonnel had been investigated.
He stated that the contractor that
provides the dosimetry service (TLD) for the station had reported
two exposures in excess of 3 Rem for the . fourth quarter,1974
The specific values reported were 3410 mrem and 3040 mrem.
Subse-
quently, the contractor provided letters to Duke describing
uncertainties in the TLD results, and concluding that all fourth
quarter badges were reported high by 15% to 30%.
-
b.
As part of the investigation of possible overexposures, Duke
determined that the total dosimeter results for each of the
tyo individuals mentioned above were significantly less than
3 Rem for the quarter.
Also, one of the two individuals.was
stated to have worn the film badge assigned by his empicyer
(Todd Shipyards Corporation) throughout the quarter; the
quarterly film badge total was 2100 mrem.
As a result of the
investigatien, Duke assigned one individual a fourth quarter
dose of 2110 mrem, based on film badge - dosimeter readings,
and assigned the other individual a fourth quarter dose of
2965 mrem, based on TLD readings corrected as 15% too high.
Therefore, Duke's investigation concluded that no overexposures
had occurred.
On questioning, a licensee representative stated that, except
c.
for the two possible overexposures, the TLD doses reported by
the contractor had been assigned as personnel exposures.
The
inspector stated that it was inconsistent to correct the con-
tractor's reported results for those two individuals and not
correct all cthers.
He noted that this resulted in apparent
inaccurate personnel 3xposure records, and : hat this was
particularly significant since the plant hed experienced
t
its maximum quarterly total man-rem during that quarter
due to the Unit 1 refueling activities.
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IE Rpt. Nos. 50-269, 270, and
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III-4
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287/75-1
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5.
Effluent Radiation Monitors
V
The inspector discussed with licensee =anagement the status of
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efforts to resolve problems previously identified with various
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effluent radiation monitors.
In October 1973, inspectors
identified large differences between monitor values and sample
results when comparing the liquid effluent monitors (RIA-33 and
RIA-34) and waste gas monitors (RIA-37 and RIA-38).
The licensee
subsequently stated that the liquid monitors would be relocated
to the turbine building and dual chambers installed for ease
of decontamination.
In a letter dated September 9,1974, Duke
stated that this would be done by November 15, 1974. At the
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2
time of this inspection, the status was that the required piping
had recently been received, but additional engineering work was
planned before the modification was to be made.
The licensee had
determined that a collimator needed to be installed in the waste
gas monitor, and the September letter provided a completion date
of November 15, 1974.
At the time of this inspection, the status
was that the-licensee had determined that a collimator would not
resolve the problem, and that further studies would have to te
.
made to determine if the present monitor could be modified or if
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a new, higher range monitor would be necessary.
In March 1974,
operation of the unit vent and reactor building particulate and
iodine monitors was determined to be unreliable. The licensee
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decided to relocate the prefilter in the iodine monitors upstream
from the detectors to improve the background problem, and stated
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in the September letter that this would be done by November 1,1974.
At the time of the inspection, the status was that the needed. parts
had not been received.
With regard to the particulate monitors,
the licensee initiated an in-house development program, and in a
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letter dated November 27, 1974, stated that a test and evaluation
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period for the Unit 1 monitors would commence on December- 15, 1974.
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Equipment for the test program was installed on January 28, 1975, and
the evaluation was scheduled to begin after startup of Unit l'in February.
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The inspector stated that, in view of the above history and
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status, it appeared that resolutien-of radiation monitor problems
had not received sufficient impetus. A management representative
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acknowledged that some engineering problems had-not been foreseen, and
that proper planning would have cnabled the ' station to meet the
completion dates that were provided.
6. -Process Ridiation Monitor Setpoints
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The inspector reviewed a copy of PT/0/A/230/01, " Radiation Monitor
Check," which establishes setpoints for all process radiation moni vrs.
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The inspector had no further questions.
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IE R t.
?o s . 50-269, 270, a,2
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287/75-1
III-5
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7.
L* nit Vent Particulate Air Monitorine
An inspector has reviewed records to verify that the licensee is
analyzing daily vent air samples until the operability of the vent
monitor is established.
The inspector had no further questions on
this technical specification requirement,
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