ML20214Q448

Responds to NRC Re Violations Noted in Insp Rept 50-219/86-12.Corrective Actions:Memo Issued to All Maint, Const & Facilities Production (Mcf) Production Supervisors Emphasizing Mcf Policy Re Control of Pipe Hangers

ML20214Q448
Person / Time
Site:	Oyster Creek
Issue date:	09/11/1986
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Kane W NRC
References
NUDOCS 8609240360
Download: ML20214Q448 (6)

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GPU Nuclear Corporation Nuclear  ::=:r388 Forked River.New Jersey 08731-0388 609 971-4000 i Writer's Direct Dial Nurnber:

September 11, 1986 Mr. William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 50-219/86-12 Attachment I to this letter provides GPU Nuclear's responses to the identified violations in Appendix A of your letter dated August 8,1986. An extension of the due date to September 12, 1986 was granted by Mr. A. R. Blough, Chief, Reactor Projects, to allow for integration of this response with the material to be presented at our meeeting at Region I headquarters on that date.

If any further information is required, please contact Mr. John Rogers of my staff at (609)971-4893.

Very truly yours, P

Vice President and Director Oyster Creek PBF/JR/ dam:0227A Attachment cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission

631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 l

Mail Stop No. 314 NRC Resident Inspector Oyster Creek Nuclear Generating Station 8609240360 860911 PDR ADOCK 05000219 \

G PDR f_TE o \ '

GPU Nuclear Corporation is a subsidiary of the General Pubhc Utilities Corporation

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ATTACHMENT I Violation A 10 CFR 50 Appendix B Criterion V and Section 3 of the Oyster Creek Operations Quality Assurance Plan require, in part, that activities affecting quality be prescribed by procedures.

Contrary to the above, as of April 21, 1986, pipe support, FP-008, which had been recently installed as part of a seismic upgrade of the spent Fuel Pool Cooling System was disassembled after its acceptance hy QC-without procedures to control the rework and to ensure reinspection.

Response

GPUN concurs in the violation.

Immediate corrective action was taken to issue a memorandum to all Maintenance, Construction and Facilities (MCF) Production supervisors emphasizing the MCF policy relating to control of pipe hangers which states:

"If any hanger needs to be temporarily removed (partially or completely), written authorization must be obtained from Engineering to do so. In addition, the work of removing and reinstalling the hanger (partially or completely) must be controlled via Procedure or the Job Order. Both the Plant Materiel Department and QC must be involved in developing requirements for the Procedure or the Job Order."

To preclude recurrence of this type of event, the MCF Work Management System procedure will be revised to include the following precaution:

Pipe hangers which must be temporarily removed or reworked (partially or completely) must have written authorization from Engineering and QC prior to any hands-on-work, the written authorization must be

included with the work package.

Additionally, MCF will evaluate the need for a generic work procedure on i pipe hangers.

Full compliance will be achieved when all the identifiea new procedures and/or procedural revisions are issued as part of the MCF Procedure Upgrade Program, presently projected for completion in August 1987.

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Violation B 10 CFR 50 Appendix B Criterion IV and Section 5.1 of the Oyster Creek Operations Quality Assurance Plan required, in part, that measures be established to assure applicable design bases and other requirements necessary to assure adequate quality are suitably included or referenced in documents for procurement of services.

Contrary to the above, as of April 21, 1986, documents involved in procurement of services by the licensee to design seismic supports for the Spent Fuel Pool Cooling System did not contain specific information as to limitations regarding attachment of seismic supports to existing

. components. As a result seismic restraints FP-001 and FP-002 were welded to non-seismic, not important to safety floor penetrations to transfer seismic loads to the building structure.

Response

l GPUN concurs in the violation.

To preclude recurrence of this type of event, Technical Functions Standard ES-014, " Piping Design Standard for TMI-l and OCNGS", Rev. O, was issued effective August 15, 1986. It includes the following statement:

I " Pipe supports for seismically supported piping systems shall not be

! attached to structures such as floor drains, blockwalls, etc. without documentation to demonstrate the load carrying capacity of the structure."

t j Additionally, Technical Functions Division is presently revising 4 procedure EMP-013 " Professional Services" to reference ES-014. This will assure that contractors are aware of this concern.

Full compliance will be achieved when the procedural controls to address i the adequacy of supports to transfer seismic loads to existing building

> structures are issued. The completion date of these actions is presently projected for October 31,.1986.

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Violation C ,

10 CFR 50 Appendix B Criterion IX and Section 6.4 of the Oyster Creek Operations Quality Assurance Plan require, in part, that special ,i processes, such as welding, be controlled and accomplished in accordance with codes, standards, specifications, criteria, and other special requirements. 10 CFR 50 Appendix 8 Criterion X and Section 6.12 of the QA Plan require, in part, that a program for inspection of activities affecting quality shall be executed to verify conformance with documented instructions, procedures, and drawings. s Paragraph 4.2.4 of the GPUN Welding Manual requires that engineering documents and Weld Package Information Requests must specify base material specification and grade for new and e<isting material used in structural welding appIlcations.

Contrary to the above, as of April 21, 1986, engineering documents and weld packages controlling welds connecting seismic support FP-001 and FP-002 for the Spent Fuel Cooling System to existing floor penetrations did not specify the material specification and grade of the existing floor penetrations. This resulted in issuance of weld packages and filler metal to make a weld between two pieces of material, one of which

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was unknown.

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Response

GPUN concurs in the violation. ,

Immediate corrective action was taken to remove a portion of the base material and forward it to our Reading Laboratory for analysis. This was controlled under maintenance short form no.34-060. The results of this analysis will be evaluated by GPUN's Project Engineering and Special Processes and Programs departments. If the base material is found toebe unsatisfactory from a welding perspective (procedure qualification), then '

a Material Non-Conformance Report will be issued. Corrective actions ,

will be taken as appropriate, including reworking the subject supports, if necessary.

To preclude recurrence of this type of event, Quality Assurance procedure 6150-QAP-7200.01 " Control of Welding and Brazing" is being revised to require that Site Weld Engineering (SWE) record the Specification and Grade or P-number designation of existing material on Held History Records, Pipe Weld Record Sheets or Structural Held Record sheets before the documents are issued to the field. Also on Structural Weld Record Sheets (SWRS), MC&F Production has been directed not to weld on existing material if it is not identified on the SWRS. Revisions also were made to clarify ~ instructions for the use of SWRS. These changes include:

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- (a) Printing a form on the back of the original SWRS to record the results of inspections on incomplete structures to eliminate the need for attachments.

(b) Only one structure be listed on a SWRS. Welds are not identified individually which then provides space for Production to record the required information.

(c) Clarifying the requirement for Production to identify base metal on the SWRS by piece number when it represents only one piece number on the structure or by description when it represents more than one piece number on the structure.

Additional instructions have been given to QC inspectors that they are not to inspect welds to existing structures / materials unless SWE has identified the material on the applicable Weld Record.

Changes in the use of the SWRS were implemented at Oyster Creek on September 29, 1986. OC, MCF, and Catalytic Welding Engineers were trained in the new requirements on August 8, 1986.

Full compliance will be achieved with the issuance of the revision to 6150-QAP-7220.01, presently projected for November 3, 1986.

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