ML20008E997

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QA Program Insp Rept 99900401/80-03 on 801209-11.Major Areas Inspected:Followup on Previous Insp Findings
ML20008E997
Person / Time
Issue date: 12/31/1980
From: Brickley R, Chamberlain D, Hale C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20008E996 List:
References
REF-QA-99900401 NUDOCS 8103100751
Download: ML20008E997 (6)


Text

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h U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900401/80-03 Company:

Combustion Engineering Incorporated 1000 Prospect Hill Road W'7dsor, Connecticut 06095 Inspection Conducted:

December 9-11, 1980 Inspector:

.t 4.

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t vt l2 30-6f R. H.vBrickley, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch er onnel:

wul J2-3M'O D. D/ Chamberlain, Contractor Inspector Date Vendor Inspection Branch Approved by:

4

/40 C. J. Qal(, Chief Date ProgramTvaluation Section Vendor Inspection Branch Summary Inspecti w conducted on December 9-11, 1980 (99900401/80-03)

Areas Inspected:

Implementation of_10 CFR 21 and 10 CFR 50, Appendix B, in the area of follow-up on two (2) 10-CFR 50.55(e) reports and action on previous inspection findings.

The inspection involved twenty-four (24) inspector hours on-site by one NRC inspector.

Results:

In the areas inspected, no items of noncompliance, deviations,.or unresolved items were ' identified.

8103100 T Il

2 DETAILS SECTION A.

Persons Contacted J. M. Bahr, Lead Engineer, RCS Analysis C. D. Blanchard, Staff Engineer K. A. Jones, Engineer, Reload Transients Group A. N. Major, Manager, Plant Components H. E. Neuschaefer, Consultant Physicist, Reactor Design E. L. Trapp, Supervisor, Reload Transients Group

0. R. Wade, Supervisor, Pump Group E. M. Weisel, Cognizant Engineer, Plant Components P. W. Wielhouwer, Supervisor, Plant Components B.

Action on Previous Insoection Findinos 1.

(Closed) Deviation (Report No. 80-01):

Certain quality related activities are not documented through written operating procedures for the Project Management organization.

The inspector verified the corrective actions and preventive mea-sures described in the letter of response dated May 30, 1980, i.e.

both QADP 5.7 (Design Change, Field Change, Corrective Action) and 6.3 (Deviation from Contract Requirement) were revised on October 1, 1980, to clarify that the Project Manager's approval is administrative in nature and that the Cognizant Engineer is responsible for deter-mining the safety implication of the item and indicating whether the condition described in a Deviation from Contract Requirement (OCR) is a reportable deficiency.

2.

~(Closed) Deviation (Report No. 80-01):

The responsibility for assuring that personnel performing activities affecting quality are suitably trained has not been met by the Project Management Organi-zation.

The procedural clarifications, identified in the preceding paragraph, that define the activities of the Project Management Organization as not quality affecting eliminate this requirement for that organization.

3.

(Closed) Unresolved Item (Report No. 80-01):

It could not be demonstrated that the Administrative Policy Instruction API-17 (Reporting of Safety Hazards) is' sufficient to provide effective implementation of 10 CFR 21 as described in Section 21.21(a) 1.e.

the activities conducted under QADP 5.7 appear to involve items that have the potential for being reportable, yet nowhere in this procedure is there a reference to 10 CFR 21 or API-17.

3 The examination of additional Field Action Recuests (FAR) during this inspection (80-03) did not reveal any instance of insufficient document-ation or failure to meet NRC reporting requirements.

In view of these results, this item had been reevaluated and found to be resolved i.e.

the existing system does not appear to violate NRC evaluation, cocu-mentation, and reporting requirements for such potential problems.

C.

Shutdown Heat Exchanger Weld Cladding This item was identified by WPPSS - Unit 3 and involved chloride contamination, below minimum design weld overlay thickness, and cracking of weld overlays on two (2) Shutdown Heat Exchangers (SDHX) manufactured by the Ametek, Schutte & Koertering Division, Bethayres Plant.

This item was previously inspected during Inspection No. 80-02 (See Report No. 99900401/80-02, DetailsSection I, paragraph C.2.b.(6)), however, additional defects have been found by C.E. and WPPSS on the two (2) Unit 3 SCHXs.

An examination of a tube sample removed from one of the SDHXs revealed at least two (2) 20% radial defects on the I.D. of the longitudinal joint.

These defects appeared to be a lack of fusion on the I.D. of the tube joint.

In addition, I.D. and 0.0. pits reportedly exceeding code allowables have been found along the I.D. and 0.D. of the weld joint.

Also, eddy current examination of 2244 tubes in the SDHXs revealed that 225 had significant inside surface defect indications.

These tubes were purchased by Ametek from the Allegheny Ludlum Steel Corp., Wallingford Tubular Products Division.

Ametek reportedly has a certification from Allegheny Ludlum that the material was eddy current tested to SA-450 and NC-2550 ASME Section III, Class 2, 1974 Edition thru Winter 1975 Addenda, Method E.T., and found to be acceptable.

This item is currently being processed by C.E. under API-17 as a potential substantial safety hazard.

Preliminary evaluations by C.E. indicate that these defective tubes may not pose a substantial safety hazard in C.E.'s application (SDHX), however, they are concerned that other users (NSSS/AEs) may have more critical applications of these tubes.

No other action at C.E.

appears warranted at this time, but this item will be followed up by our components group.

D.

Partial Drainage of the RCS in Mode 5 This item is a follow-up of a 10 CFR 50.55(e) report by the Licensee (Florida Power & Light Company - St. Lucie Plant).

The Licensee had been informed by C.E. that partial drainage of a St. Lucie 1 type reactor coolant system (RCS) while in Mode 5 is a condition that has not been analyzed for the boron dilution event.

The effect of the reduced RCS volume on I

the analysis would be a predicted time to criticality that is less than the minimum time period for operator action, assuming no more than the Technical Specification shutdown margin of 1% existed at the start of the event.

1.

Objectives The objectives of this area of the inspection were to:

4 a.

Examine the results of the evaluation of this item to determine that a proper evaluation was performed.

b.

Determine whether this item is generic or plant unique.

c.

Determine if the QA program requirements were followed.

d.

Verify that the applicable reporting requirements were followed.

2.

Method of Accomplishment The preceding objectives were accomplished by an examination of the records maintained on this item consisting of a Northeast Utilities letter to C.E. dated February 22, 1980, Millstone No. 2 LER 80-05/IT-0 dated March 21, 1980, C.E. letter to Florida Power & Light Company, and various C.E. internal memos.

3.

Findings a.

C.E. became aware of this situation via correspondance from North-east Utilities in February of this year.

Millstone 2 performs some maintenance in Mode 5 with the RCS partially drained.

Reportedly, this is inconsistent with C.E.'s interpretation of allowed operational conditions in that mode and the assumption of a full RCS (except for the pressurizer) used in all analyses for the plant from the time the FSAR was prepared.

b.

It was found that this situation could exist in other St. Lucie 1 type plants, i e. Calvert Cliffs 1 & 2, Fort Calhoun, and Mill-stone 2.

c.

The affected Licensees were notified of this possible condition and provided with modified plant conditions that would permit these actions without compromising the boron dilution analysis, i.e. increase the shutdown margin from 1% to 2% preclude operation with all three (3) cnarging pumps on at one tim,e, or specify surveillance requirements on the monitoring of the boron concentra-tion which is a function of the number of charging pumps running.

d.

The inspector concluded that a proper evaluation had been made and that reporting requirements had been met.

E.

Compliance with 10 CFR Part 21 1.

Inspection Objective To determine whether Combustion Engineering and appropriate responsible officers had established and-implemented procedures and other instruc-tions as required to ensure compliance with 10 CFR Part 21 requirements relative to the reporting of defects.

Inspector determinations are based on the reauirements of 10 CFR Part 21 as clarified by USNRC staff positions is NUREG-0302, Revision 1.

5 2.

Method of Accomolishment The preceding objectives were accomplished by an examination of appli-cable procedures and the following Field Action Requests (FAR) and supporting documentation:

a.

, Steam Dump Valve Failure This item (FAR 6370-357) was identified by ANO-Unit 2 and involved the operation and subsequent failure of an atmospheric steam dump valve and a condenser steam dump valve manufactured by Copes Vulcan Inc.

The failure of these valves was valve operator damage which resulted in the valves becoming inoperative.

The failure was determined to be caused by flow and differential pressure induced forces due to valve trim design.

The valve trim design used was unique to AN0-Unit 2.

These valves are 2 of 7 valves purchased for ANO-Unit 2 on P.O. 9203753.

FAR Supplements A, B, C, D, E, & F describe the modifications, testing and failures of the steam dump valves that have occurred since the initial failures.

The final resolution is still pending.

b.

Miniflow Orifices - Low Pressure Safety Injection (LPSI) and Containment Spray (CS) Pumps C.E. had determined that the existing miniflow bypass orifices for the LPSI and CS pumps will provide an unacceptable excessive head loss.

The size of the orifice was established by the supplier, Ingersoll-Rand Company, reportedly based on shut off head and not on C.E. supplied data.

(This item was identified on FARs 14273-90 & -91, 14373-22 & -23, and 14H73-05 & -06).

The corrective action was to increase the orifice size from.62 to.75 inches for the LPSI pumps and fron,.69 to.88 for the CS pumps.

The safety signi-ficance of the undersized orifices could not be assesed by C.E.

engineering personnel therefore it could not be determined that reporting requirements were followed.

This discrepancy was found to exist on Palo Verde 1, 2,-& 3, and WPPSS 3 & 5 and the licensees were advised.

c.

Low Excore Subche..nel Readings The Channel D excore subchannels at Arkansas Nuclear Ore - Unit 2 (FAR 6370-502) showed lower than expected readings at all power levels.

Gain adjustments failed to increase the readings enough to make them corsistent with the readings of similar channels.

The conclusion of the C.E. analysis of this condition was that the channel still remains within the range expected from uncer-tainty analysis.

This item is unique to ANO-2.

i

6 d.

Control Position Isolation Assembly Buffer Amolifier Card Failure The Position Isolation Assembly failed in service at ANO-2 (FAR 6370-486).

The board was tested and found to operate properly at room tempgratuSe; h wever, upon retesting at an elevated temper-ature of 140 F (5 F above Specification 00000-ICE-3009 require-ments) channels 1 & 2 drifted higher.

The proolem was traced to capacitors that were considered thermally sensitive, causing an unstable output.

The defective components were replaced and the board retested satisfactorily at high and ambient temperatures.

Records indicated that there were no other similar failures reportad, therefore this failure is considered an isolated case unique to ANO-2.

3.

Findings a.

There were no items of noncompliance, deviations, or unresolved items identified.

b.

The examination of the above identified FARs and their supporting documentation did not reveal any instance of insufficient docu-mentation or failure to meet NRC reporting requirements.

However, to obtain a complete picture of each deficiency, one must obtain records from many sources within C.E. resulting in many delays.

A central file of FAR documentation is highly desireable.

F.

. Exit Interview An exit interview was held with management representatives on December 11, 1980.

Those in attendance were:

L. B. Dungan, Senior Engineer, Engineering Quality Assurance (EQA).

T. C. Ennaco, Licensing Engineer P. D. Ford, Supervisor, Group Quality Systems (GQS)

C. W. Hoffman, Directnr, Group Quality Assurance (GQA)

G. J. Huba, Manager, EQA T. R. Swift, Manager GQS The inspector summarized the scope and findings of the inspection.

Manage-ment Comments were generally for clarification only, or acknowledgement of the statements by the inspector.

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