ML20030D485
| ML20030D485 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/24/1981 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20030D477 | List: |
| References | |
| NUDOCS 8109010443 | |
| Download: ML20030D485 (6) | |
Text
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DUKE POWEIf COMPANY
- 510WER UUILDING 422 Sourn Cnuncu STuxuT. CnAHLOTTE, N. C. 26242 a \\ pt 3\\
P \\ '. 5 WI L LI AM O. PA R M E R. J R.
Ver Patsiorwr T tt t P*+o h t:AntA 704 373-*o83 set. enoove % ~
July 24, 1981 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:WPK l
50-413/81-10 50-414/81-10
Dear Mr. O'Reilly:
Please find attached a response to Infractions No. 413/81-10-01, 413-414/81-10-02 and 413-414/81-10-03 which were identified in the above referenced Inspection Report. Duke Power Company does not consider any information contained in this report to be proprietory.
I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge.
l Ver truly yours, L4_, - k as, e,
William O. Parker, Jr.
l RWO/php Attactnnent cc: NRC Resident Inspector Catawba Nuclear Station 8109010443 810824 PDR ADOCK 05000413 G
PDR>
Duke Power Company Catawba Nuclear Staticn Violation:
A.
10 CFR 50, Appendix B, Criterion V as impicmented by Duke Power Company (DPC) Topical Report " DUKE 1-A",
Section 17, paragraph 17.1.5 requires that " Activities affecting quality shall be prescribed by
... procedures...and shall be accomplished in accordance uith those...
procedures." Babcock and hilcox (B&W) Inservice Inspection Procedure ISI-120, Rev. 11, references B&W's Surface Preparation Procedure ISI-50 for ultrasonic examination surface preparation. B&W's procedure ISI-50 requires that the finished contact surfaca shall be free from weld spatter and any roughness that would interfere with free movement of the search unit or impair the transcission of ultrasonic pulses.
Contrary to the above, on May 21, 1981, activities affecting quality were not accomplished in accordance with documented procedures in
- c. hat Reactor Coolant System Welds Number 1NC-44-7, INC-31-1 and 1NC-44-20 were observed with surface conditions that interfered with tree movement of the search unit and impaired the transmission of ultrasonic pulses (tape residue and/or raised metal). All three weld joints had been preservice inspected and accepted by the licensee prior to the NRC reinspection.
Response
During the inspection conducted May 18-22, 1981, three weld joints which had received preservice ultrasonic examination were observed to have tape residue on the surfaces from which the examinations had been conducted. DPC acknowledges that the residue was present.
The preservice ultrasonic examinations of Catawba Unit I have bsen contracted to Babcock and Wilcox by Duke Power Company. d&W has developed procedures to be used in the performance of the examina-tions. These procedures include requirements for the cleannees of surfaces from which the ultrasonic examinations are to be conducted.
The residue observed on the three welds resulted from a B&W Techni-cian failing to follow those procedures. This technician will be 10ferred to as " Technician X" in this response.
Corractive Actions which have been taken are as follows:
A visual examination of all 230 welds which had been ultrasonically examined during the time " Technician X" was working at Catawba was conducted. Tape residue was found on the surfaces of 4 welds (in addition to the 3 welds observed by the NRC Inspectors). Of the total of 7 welds observed to have tape residue, " Technician X" was the Inspector on 6.
Duke Power Company Catawba Nuclear Station July 24, 1981 Page 2 Response (Continued)
Sixteen (16) of the welds that " Technician X" ultrasoni,: ally examined have been re-examined ultrasonically. No reportable indi-cations were found. An additional 12 of the welds " Technician X" examined will be re-examined ultrasonically (for a total of 28) as well as 16 welds which were examined by other Technicians. The NRC l
will be notified immediately if any reportable indications are found as a result of these e-examinations, and an additional sample will be selected for re-excmination.
" Technician X" was terminated by B&W effective 6/4/81. He was first certified Level II Ultrasonic (UT) Inspector 5/4/79 and Level II Dye Penetrant Inspector (PT) 10/3/78. He never performed any dye penetrant inspections at Catawba as this work is all done by Duke Power Company personnel.
Corrective steps which will be taken to avoid further violations are as follows:
The B&W group leader will do a random ultrasonic re-examination to check the results of the initial examinations and at the same time will check for tape residue. These random re-examinations will be documented.
In addition, all of the B&W Technicians working at Catawba have been to review sessions with the B&W Level III Examiner in which the ultrc-sonic procedures were reviewed with special emphasis on removal of contarinants from surfaces from which ultrasonic examination is *o be conducted.
j I
Preservice inspection work by B&W is presently suspended at Catawba in order to provide increased manpower for Inservice Inspection work at Oconee. Full compliance will be achieved prior to resumption of
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work at Catawba.
Violation:
B.
10 CFR 50, Appendix B, Criterion V as implemented by Duke Pever Company (DPC) Topical Report " DUKE l-A", Section 17, paragraph 17.1.5 requires that " Activities affecting quality shall be prescribed by... procedures
...and shall be accomplished in accordance with those procedures."
ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, Storage, and Hand-ling of Items for Nuclear Power Plants (During the construction phase)"
has been identified as the enplicable standard for storage and preser-vation. Duke procedure P-3 revision I? " Storage Inspection" implements the storage and preservation requirements of ANSI N45.2.2.
Duke Power Company Catawba Nuclear Station j
July 24, 1981 Page 3 Violation (Continued) 1 requires items in storage to have caps, covers and closures intact.
d P-3 requires diesel generator starting air compressors to be inspected monthly and, to assure that their crankcase is full of oil'.
P-3 requires that steam generator primsry nozzles be inspected monthly to insure freedom from rust.
Contrary to the above, on May 21, 1981, storage procedure require-tients to control and preserve materials and equipment from damage or l
deterioration were not being implemented in that:
f 1.
Diesel generator starting air compressor 1B1 had no documented storage inspections after October 1979.
i I
I 2.
The a#- 'd'eer on the air intake part of diesel generator j
starting air compressor 1B1 was missing.
3.
Diesel generator starting air compressor lAl was low on oil.
4.
A severe rust condition was evident on the primary nozzle of Loop No. 3 steam generator (Unit 1).
5.
Gage pressures of stored components, under nitragen purge, were being inspected without adequate acceptance criteria.
P?sponse:
The diesel generator starting air compressor 1B1 was placed in service to provide coupressed air for turning the diesel engine flywheel and, therefore, no storage requirements existed during this time. A Form P-3A should have been initiated when the compressor was placed back in storage, but was not. The compressor was inspected for damage (reference NCI 17.023) and found to be acceptable. A Form P-3A has~
1 been generated specifying the required storage inspections. We feel that this incident is an isolated case.
The air filter on the diesel generator starting air compressor 1B1 was broken off during construction. This has been documented on NCI 12181 and is presently awaiting Design Engineering disposition which will be provided prior to August 14, 1981.
h.: feel that this incident is an isolated case because a construction procedure is in effect to monitor equipment such as this after it has been installed.
Form P-3A, Serial No. M-199, states that the diesel generator starting air compressor IA1 ba checked for adequate oil level each month. This storage inspection has been performed monthly, and oil has been added
Duke Power Company Catawba Nuclear Station July 24, 1981 Page 4 Response (Continued) as required. The small amount of oil usage was due to the compressor's being operated for a short period of time.
The rust condition which was evident on the primary nozzle of Loop No. 3 steam generator has been properly cleaned, and a coating of neolube applied.
Craft personnel have been properly trained as to the requirements of the applicable P-3A Form as indicated by NCI 11866.
We feel that we have provided adequate acceptance criteria for gage pressures of stored components under nitrogen purge because any amount j
of positive N2 pressure is adequate for protection of this equipment.
j Quality Control feels it has an adequate understanding of the require-ments and notifies the appropriate personnel for evaluation if the N2 pressure drops significantly (1 scale graduation) during an inspection period.
f Violation:
C.
10 CFR 50, Appendix B, Criterion XIII as implemented by Duke Power Company (DPC) Topical Report " DUKE 1-A", Section 17, paragraph 17.;,'3 requires measures be established to control handling of materials and equipment in accordance with work and inspection procedures to prevent damage and deterioration. ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, and Handling of Items for Nuclear Power Plants (During the construction phase)" has been identified as the applicable standard i
for material and equipment handling. ANSI N45.2.2 paragraph 7.4 requires an inspection program to be established for rigging and con-i sideration for acceptability of all rigging after each inspection.
Contrary to.the above, on May 21, 1981, adequate measures were not established to control handling of material and equipment in accordance l
with work and inspection procedures in that the licensee had no docu-mented program for the inspection of rigging slings or chokers used for handling safety-related materials or equipment.
Response
k Duke Power Company denies thic violation for the following reasons:
L Our present program satisfies the requirements of ANSI N45.2.2.
ANSI N45.2.2, Paragraph 7.4 requires a documented inspection program prior to handling of items described in Subsection 7.2 of ANSI M45.2.2.
1Property "ANSI code" (as page type) with input value "ANSI M45.2.2.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 1
b i
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Duke Power Company Catawba Nuclear Station July 24, 1981 Page 5 Response (Continued)
ANSI N45.2.2, Subsection 7.2, requires detailed handling instructions and precedures be prepared for items requiring special handling instruc-tions because of weight, size, susceptibility to shock damage, high nil ductility transition temperatures, or any other conditions which warrant special instructions.
Items not specifically covered above shall be handled in accordance with sound material handling practices.
Some construction procedures which were written to comply with ANSI N45.2.2 are:
CP 183 NSSC Vessel Installation CP 195 Offloading and Installation of Pressurizer At the time of this inspection, our program for inspection of slings and chokers for routine rigging was as follows:
Our first-line supervisors were charged with the responsibility of inspecting slings and chokers that his crew used. They were informed through communications meeting that this was their responsibilicy.
Our Safety group does constant surveillance of the job site and looks for damaged slings and chokers. Our Safety Awareness Team makes two surveillance tours per week and looks for damaged slings and chokers.
Slings and chokers which are damaged are destroyed. Suspect slings and chokers are taken to Safety for an evaluation of their integrity.
The above is our program. It is not a formal program or a documented inspection program. ANSI N45.2.2 does not require a formal or docu-mented inspection program for routine rigging.
At the time of this inspection, Duke was about eight months into devel-oping a rigging training program for Catawba which is now :omplete.
This training program will inhance our present program.
Duke recognizes the fact that there may be isolated cases where damaged slings and chokers could be used. However, with the safe working capacity of slings and chokers having a 5 to 1 safety f actor built in, these isolated cases are insignificant. Employees and/or supervisors observed using damaged slings or chokers will be disciplined under our normal disciplinary procedure.