ML20138Q864

Responds to NRC Re Violations Noted in Insp Repts 50-269/85-27,50-270/85-27 & 50-287/85-27.Corrective Actions: Nci 0-1461 Issued on Receiving Errors & Application of Filler Matl Determined Not to Require Stress Relieving

ML20138Q864
Person / Time
Site:	Oconee
Issue date:	10/31/1985
From:	Tucker H DUKE POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8511180294
Download: ML20138Q864 (6)

Text

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DuxE POWER GOMI%NY P.O.390 K CKil80 CitAHLOTTE N.C. 28242 IIAl,11. TUCKER E5 M0V 0 P3 52 = = e> -

7.*..","E" October 31, 1985 Dr. J. Nelson Grace, Regional Administrator U. S. Nucicar Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Subject:

Oconce Nucicar Station IE Inspection Report 50-269/85-27 50-270/85-27 50-287/85-27 j Dear Dr. Grace In response to your letter dated October 1, 1985 which transmitted the subject Inspection Report, the attached response to the cited items of non-compliance is provided.

Very truly yours, J

pgx Ital D. Tucker PFGisib Attachment cc: Mr. J. C. Bryant NRC Resident Inspector Oconee Nucicar Station OS11100294 051031 PDH ADOCK 05000269 G PDR l

IVOI

1. Violation 10 CFR 50, Appendix B, Criterion V as implemented by Topical Report Duke 1-A Section 17.2.5 requires, in part, that activities affecting quality shall be accomplished in accordance with the requirements imposed by instructions, procedures, and drawings.

Transfer Requisition (TR) No. 852205 dated June 3,1985, specified that filler metal must meet the requirements of ASME Section III, Subsection NB, Paragraph NB-2400. NB-2431(c) requires that weld test coupons be tested in the applicable post weld heat treated condition of the pro-duction weld.

Contrary to the above, on September 4, 1985, the inspector determined that filler metal received on TR-852205 had been receipt inspected, OA approved and issued to the field without meeting NB-2400 requirements, in that, no weld coupons had been tested in the heat treated condition.

Moreover, this material had been used to f abricate certain welds requir-ing post weld heat treatment. A similar situation involving receipt and use of nonstress relieved material was identified on an earlier inspection and discused with the licensee's representative who issued nonconforming item report 0-730, dated February 3, 1982, to investigate and take appropriate corrective actions.

Response

1) Admission or denial of the alleged violation:

This violation is correct as stated.

2) Reason for the violation:

This violation was a result of several personnel errors. Catawba Inventory Control erred by missing the special requirement that the welding material be impact tested and stress relieved as they prepared to ship the material to Oconee. These requirements did not mean anything to Catawba Inventory Control as they were more concerned with the welding material size and type. Catawba Projects QA, when completing the site sending C of C, stated that the material had been received and stored in accordance with the Projects QA Program, but failed to note the special requirements on the transfer requisition. When the welding material was received at Oconee, the receiving inspector only verified the presence of the site sending C of C as noted on the transfer requisition and did not check the material documentation against the special requirements of impact testing and stress relieved. The welding material was received and placed on the Released Welding Material Log, but was not listed as being impact tested and stressed relieved.

3) Corrective steps which .have been taken and the results achieved:

NCI 0-1461 was issued on the receiving errors. The actual application of this filler material has been determined not to require stress relieving, and requisition 7310 852205 has been revised to remove the post weld heat treatment requirement.

All Released Welding Material Log entries were compared against their respective QA documentation packages to verify that those filler materials noted as being impact tested and stress relieved were properly noted on the 109. Noted deficiencies from this review were identified on NCI No.'s 0-1495, 1496, 1532 and 1533. No field work is required. All log entries have been corrected.

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4) Corrective steps which will be taken to avoid further violations:

All involved personnel are to be instructed to review transfer re-quisitions against the material requirements for the items being shipped and received as noted in the R-6A Significant Corrective Action Evaluation, for NCI 0-1461.

l 5) Date when full compliance will be achieved:

All corrective actions noted in (4) above are to be completed by i December 1, 1985.

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2. Violetion l

10 CFR 50.55a requires that structures shall be constructed to quality standards commensurate with the importance of the safety function to be performed. ASME Boiler and Pressure Vessel Code, Section IX, paragraph l

QW-407.2 requires weld procedure qualification tests be subjected to heat treatment essentially equivalent to that encountered in the heat treatment of production welds.

Contrary to this requirement, on September 4,1985, main feedwater flow nozzle welds 1 A, IB,1C, and ID on IS0s 46 and 48, respectively, had been fabricated per Field Weld Data Sheet L-246, Rev. 2, which had been qualified to a seld procedure that did not require post weld heat treatment (PWHT).

This is a Severity Level IV violation (Supplement I).

Response

1) Admission or denial of the alleged violation:

This violation is admitted as stated.

2) Reason for the violation if admitted:

This violation resulted from inadequate review of the selected weld procedures.

3) Corrective steps which have been taken and the results achieved:

The cited welds and procedures have been reviewed by Duke Design Engineering and Nuclear Production, and have been determined to be acceptable in meeting applicable codes. No re-work of the welds is required.

4) Corrective steps which will be taken to avoid further violations:

A weld documentation checklist will be developed to ensure proper review of weld cards and piping isometrica. Since the applicable weld procedure is specified on each veld card, future use of the checklist will assure that proper procedures are used for welding.

5) Date when full conpliance will be achieved:

The checklist noted above will be implemented by January 2,1986.

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3. Violation 10 CFR 50, Appendix B, Criterion V as implemented by Topical Report Duke-1-A, Section 17.2.5 requires, in part, that activities affecting quality shall be accomplished in accordance with requirements imposed by instructions, procedures, and drawings.

Quality Control Procedure QCG-1 paragraph 4.4.1.c states, in part, that items shall be verbally released when the required QA documents are not present on site, but are located within the Duke system. Also, para-graph 4.5 of the same procedure states, in part, that items conditionally ,

released shall be tagged with a " hold" tag and may be installed, but shall not be declared operable until the conditional release is cleared.

Contrary to the above, on September 6, 1985, the licensee failed to accomplish activities affecting quality in accordance with prescribed instructions, procedures, or drawings in that replacement Reactor Coolant Pump (RCP) studs were installed and Unit 2 reactor was returned to power prior to receiving final QA approval on the supplier's material quality records.

This is a Severity Level V violation (Supplement 1). This applies to Unit 2 only.

Response

1) Admission or denial of the alleged violation:

This violation is correct as stated.

2) Reason for the violation:

This violation was the result of a misunderstanding between Oconee QA and Vendors QA Division, resulting in personnel error. Site QA had received a verbal release on the studs and was not aware of any problems with the studs until April 17, 1985 at which time the QA Vendors Division notified Oconee QA of a possible paperwork pro-bicm. A misinterpretation of the procedural and Topical Report re-quirements, resulted in Unit 2 Start-Up without final written appro-val of the vendor documentation.

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3) Corrective steps which have been taken and the results achieved:

Final approved QA documentation has been received from the QA Vendors Division and all items with the vendor, as documented on NCI 0-1234, have been corrected. An internal incident report has been written by the Oconee Safety Review Group (0SRG) citing personnel errors.

All involved QA personnel have been counseled regarding their errors in this matter. Oconee QA and Vendors QA have met at Oconee concerning the actions that transpired leading up to and in correcting this incident. This interface meeting and counseling was beneficial in resolving the sequence of events and raising the awareness level of what the requirements are. Personnel ,

errors involving site QA and Vendors Division Personnel have been adequately addressed.

4) Corrective steps which will be taken to avoid further violations:

Vendors QA will continue to monitor the vendor under their audit and surveillance program.

5) Date when full compliance will be achieved:

All corrective actions noted in (3) above were completed on September 3, 1985. Thecorrectiveactionnotedin(4)above is ongoing.

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