IR 05000729/2008001
| ML20140D946 | |
| Person / Time | |
|---|---|
| Site: | 05000729 |
| Issue date: | 11/12/1985 |
| From: | Alexander S, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20140D907 | List: |
| References | |
| REF-QA-99900930 NUDOCS 8602030149 | |
| Download: ML20140D946 (6) | |
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, ORGANIZATION: RESEARCH DYNAMICS INCORPORATED CINCINNATI, OHIO REPORT - INSPECTION INSPECTION NO.: 99900930/85-01 DATE(S): 7/29-8/1/85 ON-SITE HOURS: 52 CORRESPONDENCE ADDRESS: Research Dynamics Incorporated ATTN: Dr. J. M. Anno President 637 Redna Terrace, Unit 1 Cincinnati, Ohio 45215 ORGANIZATIONAL CONTACT: Ms. Linda A. Rieser, Assistant Project Engineer TELEPHONE NUMBER: (513) 772-8400 PRINCIPAL PRODUCT: Environmental Testing Services NUCLEAR INDUSTRY ACTIVITY: Research Dynamics Incorporated (RDI) conducts equipment qualification testing for the commercial nuclear power industr vp:. . n_ p. .
ASSIGNED INSPECTOR: twdb D.~ Alexander, Equipment Qualification
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' Da'te Inspection Section (EQIS)
OTHERINSPECTOR(S): U. Potapovs, Chief, EQIS M. Jacobus, S panational Laboratories
)I APPROVED BY: b haL(LA M U.Potapovs, Chief,EQISlVendorProgramBranch Il-(h ff Date
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INSPECTION BASES AND SCOPE: BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.
i SCOPE: This inspection was conducted to review the qualification program on an NDT International acoustic flow sensor for the safety
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relief valve status indication system (SRVSIS) for South Texas Project
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Units 1 and 22 PLANT SITE APPLICABILITY: South Texas 1 and 2 (50-498/499); Peach Bottom 1, 2, & 3 (50-171/277/278); Limerick 1 and 2 (352/353); Brunswick 1 and 2 (50-325/324); Dresden 1, 2, & 3 (50-10/237/249); Quad Cities 1 and 2; (50-254/265); Hope Creek 1 and 2 (50-354/355).
8602030149 851113 PDR G A999 EECRESDY 99900930 PDR
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ORGANIZATION: RESEARCH DYNAMICS IN CINCINNATI, OHIO REPORT INSPECTION N0.: 99900930/85-01 RESULTS: PAGE 2 of 6 VIOLATIONS:
Non NONCONFORMANCES:
Contrary to the requirements of Criterion V of Appendix B to 10 CFR Part 50, RDI calibration procedure for test pressure transmitters, RDI-INT-060, did not contain acceptance criteri UNRESOLVED ITEMS:
Non STATUS OF PREVIOUS INSPECTION FINDINGS: (Closed) Violation (83-01, Item A.1): RDI had not adopted procedures pursuant to 10 CFR Part 21. The NRC inspector reviewed RDI procedure RDI-IP-001 implementing the requirements of 10 CFR Part 21 and reviewed documentation of an instance in which RDI had had occasion to use their procedure. The requirements of the RDI procedure as well as 10 CFR Part 21 were met. However, the inspector noted that following this procedure without referring to 10 CFR Part 21, could result in violation of the 10 CFR Part 21, two-day time limit for the initial report. This will be reexamined in a future inspectio . (Closed) Violation (83-01, Item A.2): RDI had failed to post Section 206 of the Energy Reorganization Act of 1974. The inspector verified that Section 206 of the Energy Reorganization Act of 1974 as well as 10 CFR Part 21 and the procedures adopted pursuant to 10 CFR Part 21 were properly poste . (0 pen) Violation (83-01, Item A.3): RDI had issued a purchase order for safety-related testing services without specifying that the provisions of 10 CFR Part 21 apply. The inspector noted that RDI purchasing procedures now provide for this to be included, but RDI had issued no safety-related purchase orders since the previous inspection with which to verify complianc ~
, ORGANIZATION: RESEARCH DYNAMICS IN CINCINNATI, OHIO REPORT INSPECTION NO.: 99900930/85-01 RESULTS: PAGE 3 of 6 1 (0 pen) Nonconformance (83-01, Item B.1): RDI's procurement documents did not impose applicable requirements of 10 CFR Part 50, Appendix B on subcontractors. The inspector noted in this inspection that RDI's procedures now provide for imposing applicable require-ments of Appendix B on subcontractors where appropriate. However, since no procurement documents to which this requirement would apply had been issued by RDI since the last inspection, compliance could not be verifie . (Closed) Nonconformance (83-01, Item B.2): RDI had not established certain QA implementing procedures. In this inspection, the NRC inspector reviewed the QA implementation procedures which had been established. Other documentation was reviewed to verify compliance where availabl UNRESOLVED ITEMS:
Non OTHER FINDINGS AND COMMENTS: Wito respect to nonconformance B above, the practice was for the QA officer to review calibration data and determine if it was acceptable. However, the procedure in question had no written criteria with which to evaluate the data and make a determination. RDI stated that, normally, the technical manual accuracy specifications are used as a guide. The NRC inspector reviewed the latest set of calibration data for RDI's test instrumentation and found that the record of calibration of pressure transmitter No. TC0019 dated 7/6/85 showed that the j instrument was out of tolerance at the 50, 100 and 150 psig I points compared to the stated accuracy in its technical manua The data sheet was also lacking data at the full scale point and 10% overrange as specified in the procedur . It was revealed in interviews with RDI personnel that during the first run of the LOCA test on the flow sensor, distractions and interference by non RDI observers had caused considerable confusion l
and prevented the test facility operator from manipulating certain
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system valves at the appropriate times. While this led to not achieving the desired initial LOCA ramp time, the inspector noted that the test procedures did not delineate all the detailed steps l
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. ORGANIZATION: RESEARCH DYNAMICS IN CINCINNATI, OHI0 REPORT INSPCCTION NO.: 99900930/85-01 RESULTS: PAGE 4 of 6 of operating the system, particularly the one missed. It was also learned that RDI did not routinely refer to procedures just before and/or during the operation of the test facility. RDI stated that they were thoroughly familar with the operating steps and that the steps of the initial phases of a LOCA/MSLB transient simulation must be performed in rapid succession, precluding consulting the procedure between each step. The NRC inspector emphasized that equipment operating procedures should include all required steps and while effective use of procedures requires the operator to be familiar with them, it is desireable to review the sequence in the procedure just prior to commencing an operation and refer to it during the operation when possible. Where this is not practicable, convenient checklists can be used. These could be prepared by extracting the applicable action steps from the nominal sequence or standard method in the full procedure, including all necessary, detailed operations and omitting non-essential explanatory material and alternate sequences. These could be referred to if the need should arise and when time permit RDI agreed that this approach may be feasible and added that they intended to exclude visitors and observers in future tests from the immediate vicinity of the test area. The area of test control and use of procedures will be reexamined in future inspection . The inspectors reviewed documentation on the testing of the NDT International flow sensor and made the following observations: The chemical spray flow rate in the sponsor-prepared test plan was specified to be 0 to 0.5 gal / min-ft' allowing technical compliance with no flow at al The specimen
! failed 10 seconds into the test and the test was terminated so the spray was r,ever started. It was clear however, that
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RDI fully intended to use spray had the test continued.
l l The test plan specified 2000 to 4000 ppm boric acid in the spray with sodium hydroxide to be added to a pH of 10.5. RDI's solution, prepared according to their l procedure, also contains sodium thiosulfate in accordance with IEEE standard 323-1974. There was no documented i evidence that the customer had approved this test plan l
deviation, but the solution as noted above was not use 'l I
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. ORGANIZATION: RESEARCH DYMAMICS IN CINCINNATI, OHI0 REPORT INSPECTION NO.: 99900930/85-01 RESULTS: PAGE 5 of 6 The test plan specified that LOCA temperature should be adjusted as necessary to compensate for mounting surface temperature being less than 652.7 F and that such adjustment should be justified by thermal analysi It was not clear to RDI or the inspectors what was required or how it was to be accomplishe The test plan called for certain combinations of temperature and pressure which were not attainable with the saturated steam conditions specified for the tes It was not established how this was to be accomplishe RDI agreed that these issues should be resolved prior to further testing. This will be reviewed in a future inspectio . Data and supporting documentation were examined for the RDI portion of the qualification of the NDT International Model 838-1 acoustic flow sensor, whirh consisted solely of the LOCA/HELB simulatio The test sample cursisted of the sensor itself, ITT Cannon type CE9444-1000 and -1002 connectors and a lead of Rockbestos RSS-6-104 coaxial cable. The +ast objective was to attempt to qualify the sensor, connector and cable together without the use of Raychem shrinkfit sleeving over the connector. The sleeving had been used in previous testing on the same specimen at Wyle Laboratories (Alabama), but results at that time caused Wyle to recommend sleeve replacement at every refueling outage to maintain qualified statu In the first attempt to conduct the LOCA test at RDI without the connector sleeving, the desired ramp was not achieved due to problems noted in paragraph E.2 above. However, the sample went into the fault mode within the first 10 seconds, even under the less severe conditions. The test was stopped and the connector was found to be flooded, shorting out the electrical connections. On the second attempt, after drying and remaking the connection, the initial part of the test profile was achieved, but the sample failed again after 5 seconds of LOCA exposure. Excessive torque had been required to break the connection after the first run and a galled stainless steel compression sleeve was found inside the connector union where, according to RDI, there should have been a brass one. These fail-ures and test anomalies prompted RDI to submit a 10 CFR Part 21 report to the NRC. The sponsor removed all test articles from the chamber (including cutting the cable to allow removal) and further testing was postponed pending resolution of failures, anomalies and test plan problems.
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. ORGANIZATION: RESEARCH DYNAMICS IN CINCINNATI, OHI0 REPORT INSPECTION NO.: 99900930/85-01 RESULTS: PAGE 6 of 6 The temperature plot was not identified as such nor was its scale annotated on the strip chart recorder output. Although temperature channel pretest calibration data could provide this information, the actual test data was annotated only with test name, date and chart spee . RDI did not prepare a checklist for its part of the test plan to be signed off by the QA Officer upon verification of satisfactory completion of each step, as required by item "E" of RDI test control procedure RDI-IP-01 RDI contended that this procedure was meant to apply to RDI prepared test plans only, since that was all they used at the time the procedure was written. They further argued that they had only one actual step of the sponsor-prepared test plan to perform and that they had intended to document its satis-factory completion by a letter report from the QA Officer to the Senior Test Engineer. The NRC inspectors recommended clarification of the test control procedure to indicate the situations in which various provision are or are not applicable and recommended that the use of the checklist not be confined to RDI-prepared test plans since future sponsor prepared ones may well have multiple steps for RDI to perform.
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