ML19352A075
| ML19352A075 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/19/1977 |
| From: | Ross D JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-77-06, IEB-77-6, NUDOCS 8103020792 | |
| Download: ML19352A075 (5) | |
Text
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Jersey Central Power & Light Company MADISON AVENUE AT PUNCH BOWL ROAD
- MORRISTOWN, N.J. 07960
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December 19, 1977 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Bulletin No. 77-06 The purpose of this letter is to forward the attached supplemental information to the response to item 3.2 in my letter of December 2, 1977 on the same subject.
Jours very truly, W
i Donald A. Ross, Manager Generating Stations-Nuclear i
cs Attachment
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IE Bulletin No. 77-06 Item 3.2 (Supplemental Information)
December 19, 1977 DRYWELL PENETRATION TESTING - COMPLIAr1CE TO 10CFR50, APPENDIX B The evaluation of the testing organization's compliance to 10CFR50, Appendix B, is stated below.
Criterion 1 - Organization l
At the time the testing laboratory tested the Oyster Creek drywell penetrations, It had a quality Assurance Program which met the requirements of MIL Standard MIL-l-45208-A. The testing laboratory did have an organization headed by a l
General Manager of the facility.
Reporting to the General Manager was a Test Department Manager and a quality Control Supervisor.
Since the Quality Control Supervisor and the Test Department Manager reported independently to the General Manager, it is felt that there was adequate independence afforded to the quality Assurance function.
Jersey Central Power & Light Company (JCP&L) feels that the substantial requirements of Criterion I were met by the testing organization.
Criterion 11 - Quality Assurance Program This criterion is a general criterion specifying that a Quality Assurance Program shall be suitable for the activities performed.
As stated under Criterion I, the testing laboratory did have a quality Assurance Program that met the require-l ments of MIL-l-45208-A.
The other aspects of Criterion il will be discussed under specific criterion throughout the remainder of this evaluation.
Criterion lli - Design Control it has been interpreted that the test of the drywell penetrations was a design verification test as permitted by Criterion Ill.
In this test, the testing laboratory was an independent organization in that it and the design organization were two completely different companies.
In this light, JCP&L feels that the test was a design verification and it was, in fact, done by an independent organization satisfying the independence criteria of Criterion Ill.
Criterion IV - Procurement Document Control Burns & Roe established the original design and test criteria for the drywell penetrations. They,in turn, Issued procurement documents to General Electric who designed and manufactured the penetrations.
General Electric, in turn, issued procurement documents to the testing laboratory who did the independent design verification test of the penetrations. This activity occurred between December 1966 and May 1967 Appendix B to 10CFR50 was not utilized because it had not been issued at that time.
JCP&L does not have copies of the.piocurement documents between Burns & Roe and General Electric and General Electric and the It is apparent from an evaluation of the testing laboratory l
testing laboratory.
test reports against the Burns & Roe specifications, that there were procurement document control requirements in place at the time because the test reports l
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J IE Bulletin No. 77-06 Page 2 Item 3.2 (Supplemental Information) l December 19, 1977 do demonstrate that the design criteria, as stated by Burns & Roe, was, in fact, satisfied. The degree of this procurement document control has not been established, but since the test records are directly traceable back to the Burns & Roe specification requirements, it is felt that a complete understanding a
of the compliance to this criterion is not important.
Criterion V - Instructions, procedures and Drawings The testing laboratory did have general, administrative and test procedures.
When issued a specific procurement contract, they did the test in accordance with the specifications provided. Again, it is apparent that the procedures, instructions, and drawings were adequate in that the results as presented to General Electric do satisfy the Burns & Roe testing requirements. JCP&L feels that the substantial requirements of Criterion V have been satisfied in this case.
Criterion VI - Document Control The testing laboratory, as stated ea'rlier, had a quality Assurance Program meeting the requirements of MIL-l-45208-A.
This standard, in Sections 3.2.1 and 3.2.4, discusses document control. JCP&L feels that these requirements parallel the substantial requirements of Criterion VI and, therefore, the testing company did comply with the requirements of Criterion VI.
Criterion Vil - Control of Purchased Material, Equipment, and Services l
The testing laboratory did not procure services or specific material and equip-l i
ment related to this test and, therefore, the criterion is not applicable to l
the testing laboratory.
On the other hand, the testing laboratory did provide Certificates of Conformance to General Electric, which attest to the conformance of the tests to the General Electric Specification 74968.
In fact, the actual test results were also submitted as part of this certification. The General Electric Specification 74968 was written in response to the Burns & Roe specifi-cation on the drywell penetrations. Although JCP&L has been unable to obtain a copy of this specification, we are convinced that the specification doet parallel the requirements of the Burns & Roe specification because the testing organization's test results do satisfy the Burns & Roe specification requirements as stated under our comments on Criterion IV above.
JCP&L feels that the Certificates of Conformance which were provided by the testing laboratory were valid since they were attested to by the testing organization's General Manager, the Test Engineer, the Test Department Manager, and the Quality Control Supervisor.
As a result, JCP&L feels that the substantial requirements of Criterion Vil have been implemented by the testing organization.
Criterion Vill - Identification and Control of Materials, Parts, and Components With regard to the penetrations, each one was identified and the identification number is traceable to the test results.
In this light, JCP&L feels that the substantial requirements of Criterion Vili, as they relate to the testing of the drywell penetrations, have been fulfilled.
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IE Bulletin No. 77-06 Page 3 Item 3.2 (Supplemental Information)
December 19, 1977 Criterion IX - Control of Special Processes JCP&L has interpreted that this criterion does not apply to the testing of the drywell penetrations.
Criterion X - Inspection As stated earlier, at the time of these tests, the testing laboratory did have a MIL-l-45208-A program in place.
MIL-l-45208-A, Section 3.2.1, does require clear, complete, and current inspection instructions. These instructions shall be established so that inspections assure that the specifications and contract requirements are met.
With regard to actual QC inspection functions, the Quality Control organization was continually surveying and observing the performance of tests.
In addition, as stated earlier, a quality Control Supervisor reported independently to the General Manager of the facility and, therefore, the inspection function was an independent function.
JCP&L feels that the criterion of the MIL Standard and Criterion X of 10CFR50, Appendix B, are substantially equal.
Criterion XI - Test Control The testing personnel employed by the testing laboratory were qualified to the MIL specification inspection requirements. With regard to testing procedures, the testing procedures did not include accept / reject criteria in that the testing organization was chartered to perform a test and provide the results to General Electric.
General Electric then evaluated the test results. Therefore, JCP&L interprets that including accept / reject criteria in testing procedures is not relevant.
As stated earlier, testing was done in accordance with general, administrative and test control procedures, and the specifications were referred For to with regard to specific, technical requirements relating to the test.
thic reason, JCP&L feels that the substantial requirements of Criterion XI as they apply to the testing of the penetrations have been satisfied.
Criterion Xil - Control of Measuring and Test Equipment The testing laboratory did have a calibration program which satisfied the requirements of MIL-C-45622; therefore, the calibration program was controlled.
in addition, the standards utilized in calibrating test equipment were traceable to the National Bureau of Standards.
In this regard, it is felt that the sub-stantial requirements of Criterion Xil were satisfied in testing the drywell penetrations.
Criterion Xill - Handling, Storage, and Shipping l
There are no specific records which are available regarding this criterion, but JCP&L feels that improper handling, storage, or shipping prior to the test would have effected the results.
Since the results were acceptable to the is moot.
specification requirements, the compliance to this requirement
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IE Bulletin No. 77-06 Page 4 Item 3.2 (Supplemental Information) i December 19, 1977 Criterion XIV - Inspection, Test, and Operating Status MIL-I-45208-A, Section 3 5, requirements parallel Criterion XIV.
In addition, the penetrations were uniquely identified and the identifications are traceable to test results. The test results are complete, and therefore, JCP&L feels that the substantial requirements of Criterion XIV, as they relate to testing drywell penetrations, were satisfied.
Criterion XV - Nonconforming Materials, Parts, or Components MIL-I-45208-A, Section 3 7, parallels Criterion XV.
In addition, the items of concern to this test would be test Instrumentation.
Since JCP&L has the test instrumentation records which provide equipment identification, next calibration date, etc., we feel that the substantial requirements of this criterion was satisfied on the testing of the drywell penetrations.
Criterion XVI - Corrective Action Refer to JCP&L's response to item 15.
Criterion XVil - Quality Assurance Records JCP&L feels that this criterion has not been complied with.
We do, however, i
have the Burns & Roe specification, test results, instrument calibration records, and valid Certificates of Conformance from the testing laboratory. We believe that these records are adequate to attest to the test results and the requirements to which the tests were accomplished.
Criterion XVill - Audits f
MIL-l-45208-A has no specific requirements for audits, but the government l
representatives were free to monitor the program since the testing laboratory was involved with government contracts.
In this light, the program implementation, i
in the general sense, would have been evaluated.
in addition, although there are no specific records available, the testing laboratory remembers that General Electric l
was involved during the period in which the testing of the drywell penetrations was accomplished.
A representative of the testing laboratory is quite sure that General Electric did witness some or all of the tests of penetrations.
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