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Insp Repts 50-269/85-06,50-270/85-06 & 50-287/85-06 on 850318-21.Violation Noted:Failure to Implement Design Spec Requirements for Main Feedwater Flow Nozzles
	ML20127F122
Person / Time
Site:	Oconee
Issue date:	04/04/1985
From:	Blake J, Economos N; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20127F041	List: ML20127F036; ML20127F102; ML20127F122;
References
	50-269-85-06, 50-270-85-06, 50-287-85-06, NUDOCS 8505200332
	Download: ML20127F122 (7)
	v • d • e

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UNITED STATES

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NUCLEAR RE ULAT!RY COMMISSION

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Report Nos.: 50-269/85-06, 50-270/85-06, and 50-287/85-06

Licensee: Duke Pcwer Company

422 Sout5 Church Street

Charlotte, NC 28242 l

Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and

DPR-55

Facility Name: Oconee 1, 2, and 3

Inspection C e. March 10-21, 1985 '

Inspect r:

N. Fe4mo

o '/Date

4 6f Signed

Approv d by. Y!hf

J/ f./ 31ake, Section Chief

Engineering Branch

D'a te Signed

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Jivision of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 31 inspector-hours in the

areas of Unit 2 inservice inspection (ISI), work observation, review and record

evaluation, main feedwater flow-nozzle modification, closing of open items, and

high pressure injection (HPI) thermal sleeve examination.

Results: One violation was identified - Failure to implerr.ent design specifi-

cation requirements, paragraph 6.

l 8505200332 850409

gDR ADOCK 05000269

PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

M. S. Tuckman, Station Manager

T. B. Owen, Superintendent, Maintenance

J. N. Pope, Superintendent, Operations

R. J. Brackett, Senior QA (Quality Assurance) Engineer

R. H. Ledford, QA Technical Support Supervisor

W. R. Hunt, ISI Coordinator

J. M. Crowe, Technical Support QA

C. R. Hensen, Welding /NDE (Nondestructive Examination) Inspector QC

(Quality Control)

T. C. Matthews, Compliance

Other Organizations

Babcock-and Wilcox (B&W), Special Products and Integrated Field Services

W. J. Persinger, ISI Coordinator Level II Examiner

R. A. Mechalski, Supervisor, ARIS Operations

Bruce Goranowski, Level II U/T (Ultrasonic Test) Examiner

R. G. McMillan, Level II U/T Examiner

NRC Resident Inspectors

J. C. Bryant, Senior Resident Inspector

K. Sasser, Resident Inspector

L. King, Resident Inspector

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 21,1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below. No dissenting comments were received from the licensee.

(0 pen) Violation 270/85-06-01, Failure to implement design specification

requirements, paragraph 6.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

Not inspected.

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4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Inspector Followup Items (IFI)

(Closed) 269/83-19-01, Core Barrel Bolt Calibration Block Certifications and

Thermal History

The licensee provided a written response from B&W's Level II U/T Examiner

addressing this matter. The inspector reviewed the submittal and found that

the information provided in the material certification along with the above

mentioned submittal demonstrate the calibration block and material from

which it was produced were adequate for the job.

(Closed) 269/84-27-01, U/T Level III Approval for QCL-13, QCL-14, and QCL-15

U/T NDE Procedure

. The licensee provided revised copies of the subject procedures with

Level III Examiner approval indicated.

(Closed) 269/84-27-01, Adequate Preservation and Storage of U/T Calibration

Blocks

The licensee has designed a fixture which protects calibration blocks

against damage while providing easy access for calibration and is suitable

for storage purposes between fuel outages.

(Closed) 287/84-10-01, Corrective Measures on Nonconforming Items (NCIs)

1031'and 1033

This IFI was identified when a review of subject NCIs disclosed that certain

Code violations had occurred during the repair of reactor coolant pump 3Al

bolting ring (flange). These violations included failure to apply preheat

prior to welding and failure to perform NDE (surface examination) upon

completion of the weld repair.

The licensee provided for review the resolution to subject NCIs, and the

justification for leaving the flange as-is. The justification was based on

results of a U/T examination performed by B&W and stress analysis by

Dominion Engineering. Results of the U/T examination showed no detectable

cracking and the stress analysis calculations showed the repaired section

was under compression and therefore not subject to cracking.

6. Independent Inspection Effort, Unit 2(92706)

At the time of this inspection, work on replacement of the main feedwater

flow nozzles was complete. The inspector observed the completed welds #85,

86, #87, and #88 on 150-16, Rev.19, which had been approved on March 8,

1985, by Station Engineering and QA. This portion of the system has been

classified as Class G, and would normally be under ANSI B31.1 requirements;

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however, the licensee elected to invoke ASME Section III, Class 3 require-

ments for the installation of piping. Discussions held with cognizant QA/QC

personnel on the fabrication, inspection and testing of these welds

disclosed that, although the ASME Code had been invoked, none of the Code

required inspections were performed. That is, there was no issuance of weld

cards, or miscellaneous NDE forms (QCI-1A), QA did not perform fitup

inspections, or final visual. Also, there was no objective evidence to

verify that the appropriate preheat temperature was attained and that

interpass temperature requirements were adhered to. Further discussions

disclosed that the decision to install the piping under ASME Code require-

ments was based on the fact that under this Code, postweld thermal treatment

(stress relief) was not required, instead radiography could be used as the

acceptance criterion to verify weld integrity. It is the inspector's

understanding that the licensee's reasoning for not generating the appro-

priate forms and documenting / performing the required inspections was based

on the fact that this piping was classified as part of a Class G system and

therefore subject to ANSI B31.3 requirements which do not require this type

of documentation.

.

In response, the inspector's position was that, in so far as this modifica-

tion was concerned, electing to invoke ASME Section III Class 3 requirements

gave this Code and its requirements precedence over ANSI B31.1 Code and,

therefore, the documents and inspections required by ASME Section III Class

3 should have been adhered to. Moreover, the inspector stated that failure

to assure that the appropriate forms had been issued and QA inspection

requirements determined and implemen+ed indicates an apparent flaw in the

QA/QC program which permitted the welds to be fabricated without the

required inspections being performed and two of the four welds being radio-

graphed before issuing a nonconformance for failure to follow Code require-

ments. In a similar event involving repair of reactor coolant pump 3A1,

identified as Inspector Followup Item (IFI) 287/84-10-01 and discussed in

paragraph 5 of this report - a failure to apply preheat and perform surface

examination subsequent to welding went undetected until after the pump had

been assembled.

This failure to determine inspection requirements affecting quality prior to

implementation of the modification is in violation of 10 CFR 50, Appendix B,

Criterion III as implemented by Duke-1-A, Section 17.2.3. This violation

was identified as 270/85-06-01, Failure to implement design specification

requirements.

7. Inservice Inspection - Observation of Work Activities (Unit 2)

The inspector observed the ISI activities described below to determine

whether these activities were being performed in accordance with regulatory

requirements and licensee procedures. The applicable code for the ISI is

the ASME Boiler and Pressure Vessel Code,Section XI,1980 Edition, with

Addenda through the Winter of 1980.

a. Personnel qualification records for two Level II examiners were

reviewed.

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b. The inspector observed the in process UT inspection of the following

welds:

Reactor Vessel Head

B01.021.001 2RPV-WHS 0* to 120' closure head cap to

closure head ring

B01.040.001 2RPV-WH7 0* to 120' closure head flange to

closure head ring

Core Flood Tank 2CF-TIA

C1.02.003/ Pump valve O' to 360'

E05/001.001 flange to

head weld

The inspection was compared with applicable procedures in the following

. areas:

(1) Availability of and compliance with approved NDE procedures

(2) Use of knowledgeable NDE personnel

(3) Use of NDE personnel qualified to the proper level

(4) Recording of inspection results

, (5) Type of apparatus used

(6) Extent of coverage of volume

(7) Calibration requirements

(8) Search units

(9) Beam angles

(10) DAC curves

(11) Reference level for monitoring discontinuities

(12) Method for demonstrating penetration

(13) Limits for evaluating and recording indications

(14) Recording significant indications

(15) Acceptance limits

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8. Inservice Inspection, Data Review and Evaluation, Unit 2(73755)

Records of completed nondestructive examinations were selected and reviewed

to ascertain whether: the method (s), technique and extent of the examination

complied with the ISI plant and applicable NDE procedures; findings were

properly recorded and evaluated by qualified personnel; programmatic devia-

tions were recorded as required; personnel, instruments, calibrations blocks

and NOE materials (penetrants, couplets) were designated and qualifications /

certifications were on file. The applicable Code for this activity was

discussed in the paragraph above. Records selected for this review were as

follows:

Radiographs

C05.021.054 2-03-FWD 64-C 14"x.750"

C05.021.055 2-03-18.2-36 20"x1.03"

C05.021.070 2-03-18.1-22B 24"x1.219"

'

E04.01.001A Nozzle for Pump Thermal sleeve

2-Al

E04.01.003 Nozzle for Pump Thermal sleeve

2-B1

Radiographs showed both thermal sleeves were in position.

Weld C05.021.070 had been fabricated with a backing ring and the original

radiographs taken in March 1982, depicted burn-through in the 0-1 and 3-4

stations resulting in a violation of minimum wall acceptance criterion. The

weld condition was evaluated by Duke Power Company Design and the plant was .

permitted to resume operation with the weld in the as-is condition with the l

provision that it (weld) would be repaired when valve 2-FDW-46 adjacent to

the weld was disassembled on a regular refueling outage. Discussions with

cognizant licensee representatives disclosed that there were no plans to

repair the weld during this outage. However, the inspector expressed

concerns over leaving the weld in its present condition and postponing its

repair for another refueling cycle when the physical appearance of the

defect, and the soundness of the affected material were unknown. Subsequent

to the close of this inspection, the licensee informed the inspector that it

had been decided to repair the weld in question during the current outage.

Ultrasonic Examination

B09.011.066 A Hot Leg, Circle Seam 42.75"x3.00"

B09.012.044 A Hot Leg Outside Long 33.5"x3.00"

Seam

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B09.012.046 A Hot Leg Outside Long 33.5"x3.00"

Seam

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809.012.043 A Hot Leg Inside Long 33.5"x3.00"

Seam

809.012.045 A Hot Leg Inside Long 33.5"x3.00"

Seam

805.05.002A A 1 Discharge Pump S. E. ;

To Elbow ;

B05.05.002 A 1 Discharge Pump S. E, t

To Elbow

C01.03.004 S/G "B" Shell to Lower

Tube Sheet

E4.01.001 A 1 Discharge Make-up

. Nozzle S. E.

270' Outlook Nozzle Z to Shell; From Nozzle ID (ARIS)

B03.090.002A 2RPV-WR13A

B03.100.002 2RPV-WR13A

,

B09.011.069 2PHA-1

90' Outlet Nozzle to Shell; From Nozzle ID (ARIS)

B03.090.001A 2RPV-WR13

B03.100.001 2RPV-WR13

809.011.057 2PHB-1

Liquid Penetrant

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805.051.002A 2P0Al-11

B05.050.00BB 2P0Al-2 -

CO2.010.003 2LPCB-inlet ,

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C05.011.033 2-538-19.1-59

Within the areas inspected, no violations or deviations were identified.

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ML20127F122

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