IR 05000400/1982007

IE Insp Repts 50-400/82-07 & 50-401/82-07 on 820308-12. Noncompliance Noted:Audits Not Performed for Concrete or Protective Coating Activities,Reinforcing Steel Controls & Mechanical Equipment Installation Activities

ML20054G948
Person / Time
Site:	Harris
Issue date:	04/14/1982
From:	Debbage A, Deggage A, Merriweather N, Upright C, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054G931	List: IR 05000400/1982007 ML20054G930 ML20054G938 ML20054G941 ML20054G945
References
50-400-82-07, 50-400-82-7, 50-401-82-07, 50-401-82-7, NUDOCS 8206220439
Download: ML20054G948 (16)

Text

.

/ 'o g UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION

• r REGION 11

• 8 101 MARIETTA ST., N.W., SulTE 3100 n%, / ATLANTA, GEORGIA 30303

.....

Report Nos. 50-400/82-07 and 50-401/82-07 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Shearon Harris Docket Nos. 50-400 and 50-401 License Nos. CPPR-158 and CPPR-159 Inspection at licensee's corporate offices in Raleigh, North Carolina-fM7 //42&h 7" Y /I/ 2-Inspectors:[W. WrigTt/

~ ~

~ Oate Signed fjtif lbc<h T -. 4/f4/8e Date Yigned A.G.Debbagg ,

N $' N. Merriweath fDLA f Y/$hL Fate Signed

/ j Approved by: [M/h/ [ht /C f 4//5f 'L C. M. Upright, 54ctio[ Chief

.

Ofte 71gned Engineering Ipipection Branch Division of Engineering and Technical Programs SUMMARY Inspection on March 8-12, 1982 Areas Inspected i This routine, announced inspection involved 94 inspector-hours at licensee headquarters in the areas of the licensee's quality assurance program, design control, procurement activities, and audits.

I I Results

! Of the four areas inspected, no violations or deviations were identified in three l- areas; one violation was found in the corporate audit program area in that l certain construction activities were not audited during calendar year 1981 -

l paragraph 7.a.

i l

l l

8206220439 820608 PDR ADOCK 05000400 Q PDR

.. .- . _ _ _. -_ h - _ _- . - - -

. .

1 REPORT DETAILS , Persons Contacted Licensee Employees

• S. D. Smith, Vice President, Nuclear Plant Construction

• P. W. Howe, Vice President, Technical Services

• H. R. Banks, Manager Corporate Quality Assurance

• N. J. Chiangi, Manager Engineering and Construction QA/QC

• D. A. McGaw. Principal Vendor Surveillance Specialist

• I. A, Johnson, Principal QA Specialist, Performance Evaluation

• S. N. Hamilton, Manager Construction Procurement and Contracts

• L. E. Jones, Principal QA Engineer

• K. V. Hate, Principal QA/QC Engineer

• W. P. Tomlinson, Principal Engineer, Mechanical L. Loflin, Manager Engineering, Harris Plant, Nuclear Plant Engineering Department J. V. Gailey, Project Vendor Surveillance Specialist S. R. Zimmerman, Manager, Nuclear Licensing

^

H. Love, Project QA Specialist, Training and Procedures Unit

• Attended exit interview Exit Interview The insoection scope and findings were summarized on March 12, 1982, with those persons indicated in paragraph 1 abov . Licensee Action on Previous Inspection Findings Not inspecte . Unresolved Items Unresolved items were not identified during this inspectio . Quality Assurance Program (350608) QA Program Changes The SHNPP PSAR Chapter 1.8 ( Amendment 74) and CP&L's letters to NRR dated March 26, 1981, June 2, 1981 and a letter submitted around June 23, 1981 describe the licensee's QA program as last reported to the NRC. Section 1.8 of the SHNPP FSAR reflects the current Regulatory l Guide commitment This program complies with the requirements of 10 CFR 50, Appendix B, and ANSI N 45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants.

l l

i

_ _

.

.

.

CP&L has incorporated changes to their corporate QA program (CQAP)

which have been documented by the above mentioned letters to NRR and are reflected in Revision 3 to the CP&L Corporate QA Manua'. CP&L revised it's CQAP by creating a new Corporate QA Departmont which reports directly to the Executive Vice President for Power Jupply and Engineering and Construction. This reorganization consolidated into one department the QA functions from Technical Services, Nuclear Safety and Research, and the Nuclear Operations departments. Currently inclu-ded in the Corporate QA Department are Engineering and Construction QA/QC, Operations QA/QC, the Performance Evaluation Unit, and the Training and Procedures Unit. The above consolidation has improved CP&L's QA effectiveness in that all QA units now under one umbrella receive uniformity in QA training, direction, guidance, and written procedures since these areas are better controlled by one department head than by the previous fragmented system. Discussions with respon-sible unit supervisors revealed that there has been little turnover of their corporate QA staff and numbers of personnel assigned to the units have remained relatively stable since the last NRC inspectio The Training and Procedures Unit is in the process of phasing out various individual QA unit procedures by replacing them with Corporate QA Department Procedures which should unify and enhance the Corporate QA Program effectiveness. The following Corporate QA Department Procedures approved February 1,1982 were examined by the inspector:

CQAD 70-1, R0 Procedure for Reporting of Defects and Noncompliance In Accordance With 10 CFR 21 CQAD 70-2, R0 Procedure for Reporting of Deficiencies In Accordance with 10 CFR 50.55(e)

CQAD 80-1, R0 Procedure for Corporate QA Audits CQAD 80-3, R0 Procedure for Collection, Storage and Maintenance of QA Audit Records CQAD 80-5, R0 Procedure for Participating In Joint QA Audits and Preparing, Distributing and Maintaining the QA Audit Documents The Nuclear Plant Engineering Department (NPED) procedures and the Corporate QA Department Engineering and Construction QA/QC Unit (E&C QA/QC) procedures listed below were reviewed for changes (revisions) to verify that these changes were approved at appropriate management levels and to ensure that document control (distribution) requirements had been effectively complied with as specified by controlling proce-dures NPED 2.1, Control of Procedures and AQAS-2, Initiation, Revision, and Withdrawal of Procedures respectively:

NPED 3.3-1 Design Verification NPED Handling of Reportable Items Under 10 CFR 50.55(e)

NPED 3.11 Handling of Reportable Item Under 10 CFR 21 NPED 4.1-1 Procurement of Engineered Items L

.

AQAS 5 Reportable Items Under 10 CFR 50.55(e) & 10 CFR 21 EQA 1 Review of Documents for QA Requirements VQA 2 Vendor Shop Surveillance The inspector verified that controlled manual holder copies nos. 002, 003, 062 for NPED procedures and controlled manual holder copies no , 007 and 015 for E&C QA/QC procedures had been updated to the latest procedural revision b. Licensee Review of QA Program Effectiveness The Director-Corporate Health Physics conducts on a semiannual basis an independent assessment of CP&L's compliance with appropriate aspects of the Corporate QA Plan and applicable regulatory requirement This independent assessment is conducted in accordance with " Procedure for Management Review of Independent Nuclear Safety Review and QA Audit Activities." This report is distributed to the Chairman / President, Vice Chairman, Executive Vice President and the Corporate QA Manage In addition to the above reviews, CP&L is continually assessing their internal audit and independent authorized nuclear inspector program findings. Monthly Project Review Meetings are conducted with senior management in attendance to review not only planning schedules but engineering and QA matters of concern pertinent to SHNP Senior Management Reviews conducted on a six month frequency along with Special Meetings (for specific items of concern, at no established frequency) are convened to discuss status and implementation of the QA program at SHNP The inspector examined the following QA effectiveness reviews: Monthly Project Review Meeting minutes, Special Meeting minutes; and, Senior Management Review minutes for recommendations made and disposition of those recommendations:

Management Review of Independent Safety Review & QA Audit Activities MR-6 conducted 11/5,6,7 & 19/80 MR-7 conducted 6/9,10,11/81 MR-8 conducted 11/10,11,12/81 Monthly Project Review Meetings conducted for July 81 through January 198 Special Meeting conducted 2/2/82 Senior Management Meetings conducted 7/28/81 and 12/8/81

.

4 Corporated QA - Site QA Interface The Manager of Corporate Engineering and Construction QA/QC, and the Director QA/QC at SHNPP site exchange weekly "QA/QC Activity Reports,"

monthly " Status of Open Deficiency and Disposition Reports (DDRs),"

monthly status of "NRC Open Item Summary Reports," and all potential and reportable 50.55(e) and 10 CFR 21 items. The Ebasco QA Compliance Coordinator publishes their vendor audit concerns (Ebasco Progress Report) once a month which is monitored by CP&L Corporate Q The site prepares quarterly trend analyses (SHNPP Nonconformance Trend Reports) for submittal to Corporate QA in accordance with procedure QCI 2.2, Nonconformance Trendin The inspector examined SHNPP weekly QA/QC Activity Reports for the period January 1, 1982 through February 12, 1982, monthly DDR status reports for August 20, 1981 through January 22, 1982, monthly NRC Open Items Summary Reports for August 18, 1981 through January 7, 1982, Ebasco Progress Report No.119 dated January 8, 1982, and quarterly SHNPP Nonconformance Trend Reports No. 11 through No.15 (4th Qtr.1980 through 4th Qtr.1981). This review was conducted to verify that these reports identified problem areas, proper corrective action, licensee followup and received proper management attentio Within this area, no violations or deviations were identifie . Design Review - External A/E (35060B) Documents Examined:

CQAD 80-3, RD Procedure for Training and Qualification of Quality Assurance Program Audit Personnel CQAD 80-5, R0 Procedure for Participating in Joint Quality Assurance Audits and Preparing, Distributing and Maintaining the QA Audit Documents EQA-1, R12 Review of Documents for Quality Assurance Require-ments CQAD 80-1, R0 Procedure for Corporate QA Audits R3 Corporate Quality Assurance Program NPED 2.11, R1 Correspondence / Document Processing TSD LAP Incoming Nuclear Regulatory Commission (NRC Corre-spondence

, TSD LAP Outgoing Nuclear Regulatory Commission (NRC)

i Correspondence l

!

<

QAA/170-6 ASME Audit of SHNPP Construction Site and General Office TSD Format and Approvals of Procedures TSD Control and Revision of Technical Services Depart-ment Manual b. Design Assurance The inspector reviewed the CP&L organization to understand the internal and external interfaces for design assurance. The inspector determined that the licensee has established a three year audit program and annual evaluation to measure the effectiveness of AE design assurance acti-vities and design adequacy is determined by the Harris Plant Engi-neering Section reviewing selective drawings and specifications for technical adequacy. The Engineering and Construction QA Unit (E&CQA)

review specifications to ensure that the appropriate QA requirements are incorporated. E&CQA comments on specifications are routed to the Manager of the Harris Plant Engineering Section. Interface with the AE will be handled through the Manager, Harris Plant Engineering. Once all QA and Engineering concerns are satisified, CP&L will issue approval to the AE for release of specification The implementation of the design review performed by QA was examined by the inspector for Ebasco specifications: CAR-SH-M-67H, Emergency Service Water Pumps; and CAR-SH-E-6B, 6.9kv Metal-Clad Switchgear Type Class 1 Within this area, no violations or deviations were identified.

c. Design Assurance Audits The inspector reviewed the licensee's master audit plans for calendar years 1979 thru 1981 and 1982 thru 1984 to assure that an audit plan was documented, the frequency and scope of audits was sufficient, and that representative design groups and safety functions were include Lead auditors are assigned to the master audit plan by the Principal QA Specialist who also has responsibility for approving the audit schedule. Technical Specialists from outside the E&CQA unit are brought in as needed to be members of audit team The inspector selected CP&L's audits of Ebasco for calender year 1981 for examination. These audits are identified as QAA/70-16, QAA/70-17, and QAA/70-18. The areas examined in audit report QAA/70-16 included previous audit findings, organization, QA Program, design control architectural and structural and design control radwaste and water treatmen The areas examined in audit report QAA/70-17 included previous audit findings, design control electrical and instrumentation, design control concrete and hydraulic, corrective action, and standards

__ . _

___ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

l l 6 and procedures. The areas examined in audit report QAA/70-18 included previous audit items, design control electrical and instrumentation, design control health physics, design control materials and corrosion, and design control for piping stress analysi These reports were examined to determine if the objective and scope established in the audit plan was accomplished, whether followup on audit findings was timely and whether corrective action was adequat The qualifications of the lead auditors were also examined and found acceptabl With this area, no violations or deviations were identifie Bulletins, Circulars and Information Notices The inspector reviewed the licensee's program for handling NRC bulle-tins, circulars and information notices to assure that the NRC require-ments and positions transmitted to the licensee are reviewed by the appropriate organizations for applicability to the Shearon Harris Plant. The inspector reviewed Technical Services Department Procedures LAP 1.1, Incoming Nuclear Regulatory Commission (NRC) Correspondence and LAP 1.2 Outgoing Nuclear Regulatory Commission (NRC) Correspondence to understand the licensee's program for coordinating bulletins, circulars and information notice The inspector selected NRC bulletins 81-02 and 79-15; circulars 81-14, 81-12, 81-09, 81-03 and 80-23; and information notices 81-23, 81-21, 80-44 and 80-2 The documentation for these bulletins, circulars and information notices was reviewed to assure compliance with implementing procedures LAP and Within this area, no violations or deviations were identifie . Audits (350608) Audit Program The inspector examined the following controlling documents:

PSAR Section XVIII Audits FSAR Section Conformance to NRC Regulatory Guides CQAP Section 16 Audits CQAD 80-1 Procedure for Corporate QA Audits CQAD 80-2 Procedure for Training & Qualification of QA Program Audit Personnel CQAD 80-3 Procedure for Collection, Storage & Mainten-ance of QA Audit Records CQAD 80-5 Procedure for Participating in Joint QA Audits

& Preparing, Distributing and Maintaining the QA Audit Documents

.- _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ . _ _ . _ .____a

- . . _ =_ .- . - - - _ . -. -- - - - - _ - . . -.

. .

l

,

.

ANSI N45.2.12 Requirements for Auditing of, QA Programs for Nuclear Power Plants '

. ANSI N45.2.23 Qualification of QA Program Audit Personnel

!

for Nuclear Facilities j R.G. l'144

. Auditing of QA Programs for Nuclear Power i Plants

CP&L's Performance Evaluation Unit (PEU) has the responsibility to develop and implement a comprehensive, regularly scheduled system of planned internal and external audits that will include an objective

, evaluation of the QA Program and the effectiveness of the implementa-tion of the Program in meeting requirements of the construction permi t Unscheduled licensee internal or external audits may be conducted at '

any time at the direction of the Manager - Corporate QA Departmen Audit schedules (projected and completed) for 1981 and 1982 were exam-ined and the PEU supervisor was interviewed to ascertain that the licensee's audit program encompasses all internal and external organ-

izations and extends to all elements of the QA program at the required i frequency. Examination of audits conducted by the PEU during calendar year 1981 revealed no audits had been performed for concrete or protec-

'

tive coating activities, reinforcing steel controls, or for mechanical

equipment installation activities although such activities were in  !

l progress at SHNPP during that time. The licensee has committed to the audit provisions of Regulatory Guide 1.144. Paragraph 3a(2) of the ,

' '

subject Guide for internal audits of design and construction phase

! activities requires CP&L to audit all applicable elements of an organ-ization's QA program at least annually or at least once within the j life of the activity, whichever is shorter. This item of noncompli-ance is identified as violation 400-401/82-07-01, 1981 Construction

, Activities Not Audited at Required Annual Frequency by Corporate PE !

The audit team size, composition, and use of specialists routinely i

assigned from other organizations was discussed with the Corporate PEU supervisor.

l The inspector examined the auditor training, experience, and certifica-

! tion of the CP&L auditors who participated in the audits examined in

! paragraph 8.b and found the auditors were all qualified to the licen-see's applicable procedure and ANSI N45.2.23 requirements.

i Audit Review I

~

.

The following audits and respective audit plans were examined to I

determine applicability to the QA element audited, qualification of

'

audit team members, that audit findings were reported to upper manage-

ment and the organization audited, corrective actions as required are

! being initiated, and that there is followup and re-audit by QA as l necessary:

<

t I

i

- ._~ ._ _ ,..._ .__ ._. _ _ . _ - . - _ _ _ _ - . - - . - - . _ - - _ . . - _ . _ _ . _ . _ . . _ - , . . - . .

.

.

.

QAA/81-11 -

QA Audit of SHNPP Construction QAA/81-12 -

QA Audit of SHNPP Construction QAA/81-13 -

QA Audit of SHNPP Construction QAA/81-14 -

QA Audit of SHNPP Construction QAA/81-15 -

QA Audit of SHNPP Construction QAA/81-16 -

QA Audit of SHNPP Construction QAA/81-17 -

QA Audit of Ski,PP Construction QAA/81-18 -

QA Audit of SHNPP Construction QAA/170-6 -

ASME QA Audit of SHNPP Construction Site and General Offices QAA/170-/ -

ASME QA Audit at SHNPP Construction Site QAA/861-4 -

QA Audit of Law Engineering Testing Within the above areas of auditing examined, no deviations were identi-fied; one violation, "1981 construction activities not audited at required annual frequency by corporate PEU" (paragraph 7.a) was identified and acknowledged by the license . Procurement (350608) Procurement Organization Controls Ebasco New York, New York, is the architect-engineer for Carolina Power and Light Company (CP&L) Shearon Harris nuclear project, with Westinghouse Electric Power Corporation being the NSSS supplie Westinghouse procures items and services for the project as required by its contract with CP&L. Procurement by CP&L and Ebasco is performed in accordance with the requirements of ANSI N45.2.13, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants." The Manager of the Corporate Quality Assurance Department reports to the Executive Vice President, Power Supply and Engineering and Construction. Ebasco and Westinghouse activities are audited by CP&L QA staf Procedures controlling the above activities were reviewed to ensure they contained the essential controls for procurement activity. The procedures reviewed included the following:

ASME Quality Assurance Manual, R 24, Kemper Insurance Companies Section /4/82 Procurement Section 1 /8/81 Nonconformance and Corrective Action Section 1 /8/81 Audits CP&L Corporate QA Program Section 4 R 1 Procurement Control CP&L Nuclear Plant Engineering Department Manual

.

Section 3. Preparation and Control of Specifications Section Procurement of Engineered Items Section Bid Evaluation Section Preparation and Control of Inquiries CP&L Technical Services Department, Engineering and Construction QA/QC Procedures VQA-2,R6 Vendor Shop Surveill.ance VQA-5, R5 Preparation and Maintenance of Approved Supplier List Procurement Document Control Procurement documents were reviewed to ensure that:

-

Applicable regulatory requirements, design bases, and other requirements were included or referenced

-

Procurement document changes were subjected to the same level of control as used in the original preparation

-

3 cope of work to be performed by the vendor was identified

-

Technical requirements referenced the appropriate documents

-

Test, inspection and acceptance criteria were identified

-

Vendors had a documented QA program and were required to incor-porate QA requirements in subcontract documents

-

Special instructions / requirements were included for activities such as designing, identification, f abrication, cleaning, erec-ting, packaging, handling, shipping and extended storage

-

Documents identified which were to be sent to CP&L for review and approval

-

Nonconformance reporting and control were specified

-

Access to the vendor's facilities and records for inspection or audit were incorporate Subjects selected for review included the procurement of main steam power operated relief valves, containment electrical penetrations and the field erection of storage tanks; these were selected because of

.

.

substantial revisions to both the purchase orders and technical speci-fications. In accordance with established procedures, specifications are submitted to CP&L by Ebasco for review and approval. Ebasco A/E activity for CP&L is designated project number NY-435; Ebasco identifi-cation of the main steam power operated relief valves is NY-11 The contract for procurement of these valves is NY-435111 and this was awarded to Control Components, Inc., Irving, California on May 13, 1977. Revision 0 of both the purchase order and specification were not available for review since they were in storage at the Shearon Harris

,

Document Control location. Speci fication CAR-SH-M56, Rev. 4, dated May 19, 1977 was reviewed; the following standards were specified:

ASME Section II and Section III, Subsection NC,Section VIII ANSI B16.5, Steel Pipe Flanges and Flanged Fittings -

SSPC (Steel Structures Painting Council) - SP-8 Pickling SSPC-SP-5 White Metal Blast Cleaning ANSI-B16.104 Control Valve Seat Leakage IEEE 323-1971 Qualifying Class I Electrical Equipment IEEE 343-1975 Seismic Qualification Class I Electrical Equipment 1EEE 382-1972 Test Type Class I Electric Valve Operators

ASME-SA 216 WCB Valve Body Carbon Steel Ebasco Standards 820 Carbon / Low Alloy Steel Castings 821 Austenitic Stainless Steel Castings i 830 Carbon and Low Alloy Forgings I

! 831 Austenitic Steel Forgings

{

850 Examination and NOT Requirements 860 Quality Control Requirements 865 Documentation Requirements for Piping Systems 873 NDT Procedures 884 General Welding Requirements i

.

.

The purchase order was for 12 valves, model M3G9-X88W-10BW, capable of relieving 427,310 pounds per hour of saturated steam at 80% valve stroke. Seismic loads of 3.0g horizontal and 2.0g vertical for natural frequencies of 33 cps or greater were specified. Dynamic analysis was required but the order stated that a test method of seismic qualifica-tion was preferred and could be performed in lieu of dynamic analysi .

Addendums to the technical specifications and supplements to the purchase order were examine Supplement 4 dated November 17, 1977 specified that seismic testing was a requiremen Supplements 5 through 9 (April 25, 1978 through March 6, 1979) were primarily concerned with administrative instructions and shipping schedule Part 21 was not specified for this contract; the valves were being delivered at the time Part 21 became effectiv Procurement of the containment electrical penetrations commenced with purchase requisition 57070 with a subsequent purchase order NY-435144 dated November 28, 1977 to Westinghouse Electric Corporation, Hillside, New Jersey. The original technical specification had been issued August 29, 1974 and this also was in storage at the Shearon Harris site. Specification CAR-SH-E-28, Rev. 3 was reviewed; more than thirty standards were referenced which included the following:

ASTM D-568 Flammability Test for Flexible Plastics ASTM D-635 Flammability Test for Self Supporting Plastics ANSI C.3 A.C. High Voltage Circuit Breakers ANSI C.37.13 A.C. Low Voltage Circuit Breakers IPCEA-S-19-81 Rubber Insulated Wire and Cable IEEE 278 Electrical Insulating Materials Exposed to Neutron and Gamma Radiation IEEE 317-76 Electrical Penetration Assemblies in Containment Struc-tures IEEE 344-75 Seismic Qualification of Class I Electrical Equipment l AEIC-5-74 Polyethylene Insulation Shielded Power Cables l EBASCO 222-72 Containment Electrical Penetrations (Safety Class 2)

l Service conditions for the penetrations were specified for both inside and outside the primary containment. The outside conditions were a temperature range of 65-120 F and maximum radiation of 0.1 Rads / hour.

l The inside conditions were 80-120 F and a 40 year radiation exposure of 8 X 10" Rads. Transient conditions, including high temperatures and radiation levels and exposure to borated water spray were also speci-fied for the inside conditions. Specification revision number 4 dated November 5, 1979 incorporated an additional standard IEEE 383 -

!

Standard for Type Test of Class 1E Electrical Cables, Field Splices and Connections for Nuclear Power Generating Station Contract NPCD-81-P-010 dated August 19, 1981 was awarded to Richmond Engineering Company, Richmond, Virginia (RECO), for the construction of seven storage tanks. These tanks were:

. .

-

refueling water storage tank

-

condensate storage tank

-

reactor makeup water storage tank

-

boron recycle holdup tank

-

clearwell tank

-

2 boric acid tanks The field erection was to be in accordance with Ebasco specification CAR-SH-AS-10 and ASME codes, and the weld filler metal control to comply with CP&L's weld rod control program. Access rights to the work at all times, with right to inspect and reject any portions considered defective, were specified for both the owner inspectors and NRC inspector Materials, components and services were subject to 10 CFR Part 21. The progress of this contract was reviewed. RECO design calculations were sent to Ebasco for review and approved October 21, 198 A pre-construction meeting was held October 28, 1981 in which RECO reported that the design calculations were being revised to include CP&L's comment On January 14, 1982 Ebasco conducted a further review of REC 0 design calculations and gave statements for changes to be mad CP&L's ASME certification was revised on January 11, 1982 to include Class 2 and 3 storage tanks; this permitted RECO to accept CP&L material as an "N" stamp supplie c. Audits of Westinghouse Electric Corporation Audits of Westinghouse Electric Corporation, Monroeville, Pennsylvania, are conducted by Carolina Power and Light three times a year with a total QA program element review over a three year cycle. One of these auJits designated QAA/300-11, was conducted December 11-13, 1979, the

.udit team being F. E. Strehle, Jr. , (lead) and W. M. Nevill An item of concern of Audit QAA/3001-11 was that a review of shop order

1. 185 " Fuel Transfer Tube Calculations", revealed cases where there was no evidence that drawing changes were reconciled with the original design calculations. A review of the stress calculation diagram versus the seismic calculation diagram identified an EBASCO drawing change that had moved a support six inche It appeared that design control measures were not adequate to assure that drawing changes were con-sidered following initial calculation preparation. The audit report required Westinghouse to review the impact of drawing changes on calculations and take measures to assure that design changes are reviewed. Audit reports QAA/300-12, 300-13, 300-14 were not reviewed during this inspection. Audit QAA/300-15 was conducted May 4-6, 1981, the audit team being I. A. Johnson (lead) and M. Chaitoff. The report stated that the item of concern from audit QAA/300-11 was still out-standing with the anticipated date for completion of corrective action near the end of 1982. On May 20,1981 N. J. Chiangi, QA Manager for CP&L Shearon Harris plant, informed the NRC Region II (R. Butcher) of a potentially reportable item under 10 CFR 50.55(e) and 10 CFR 21; the scope of the problem was that preliminary investigations of the r

t ,

.

. .

.

potential generic situation between Ebasco and Westinghouse indicated that dif ferences may exist between later Ebasco design changes to inputs used by Westinghouse in _ their calculatiens and those originally used in the Westinghouse calculations. An interim report issued on June 19.1981 stated that the need for Westinghouse and/or Ebasco reanalysis would be determined by December 1,198 On July 10, 1981 a meeting was held in New York City and Westinghouse and Ebasco agreed to perform a quarterly review of- the design interface informatio The next audit QAA/300-16 conducted September 1-3, 1981 by F. E. Strehle, Jr. , (lead), R. D. Barham and B. Bhushan (trainee)

identified four new nonconformances and two concerns in the area of design control; the audit report stated that corrective action had not been completed on concern QAA/300-11, three nonconformances from QAA/300-14 and one from QAA/300-15. On September 25, 1981 this was brought to the attention of E. E. Utley, Executive Vice President, Power Supply and Engineering and Construction, CP&L. He met with Westinghouse Managers J. Halifax and G. Gilliland on November 3, 1981, for the purpose of expressing concerns regarding continuing noncon-formances being found on QA audits. It was his understanding that the problem was to be reviewed with the top people at Westinghouse and steps taken to improve the progra The next audit QAA/300-17 was conducted December 1-3, 1981 by W. E. C. Monroe (lead), F. E. Strehle, Jr. , R. D. Barham and D. Rudof No new nonconformances were identified. Items remaining open included QAA/300-1 Interim Report #2 was issued December 8,1981 by CP&L to NRC Region I This report detailed steps taken by Westinghouse and Ebasco to improve the method of communicating design changes and to assure the coordina-

, tion of future design changes. From a review by Westinghouse, those 2 Ebasco Design Change Notices which impact the proof-of-design calcu-l lations were listed in the report. The calculations included:

l j -

Emergency Boration Path

-

Charging pump suction from RWST l

-

Excess letdown line flow performance

-

Boric acid transfer to blender j

-

Charging pump suction from VCT and RWST

' -

ECCS analysis

! -

Pressurizer spray; Cv data required for new valve

,

l The reanalysis is scheduled to be completed by July 25, 198 If the l item is deemed to be reportable, the final report is to be submitted by

'

August 25, 1982. During this inspection, CP&L reported the evaluation of the impact of drawing changes on the proof-of-design calculations was continuing and they expected the reanalysis to be completed in l July 1982.

l

!

i

. .

. .

d. Audits of Ebasco Services Inc., NY Audits of Ebasco are conducted by CP&L three times a year for a total QA program element review over three years. Audits conducted from July 1980 through December 1981 were reviewed; most of the noncon-formances identified were in the areas of design control; procurement document control; and instructions, procedures and drawing Audit QAA/70-14 was conducted July 28-30, 1980, the audit team being K. V. Hate (lead) and T. L. James. Six nonconformances and one concern were identifie Audit QAA/70-15 was conducted November 17-19, 1980, the audit team being K. V. Hate (lead) and R. D. Barham. Three nonconformances and four concerns were identifie Audit QAA/70-16 was conducted March 24-26, 1981, the audit team being F. E. Strehle, Jr. , (lead) and R. D. Barham. Four nonconformances and three concerns were identifie QAA/70-17 was conducted July 28-30, 1981, the audit team being 1. A. Johnson (lead), R. D. Barham and L. W. Bissett Three non-conformances and one concern were identified. The report stated that one nonconformance from QAA/70-16 still remained open. QAA/70-18 was conducted December 8-10, 1981, the audit team being K. V. Hate (lead),

D. L. Beidelman (technical specialist), B. Bushan (trainee) and L. W. Bissette. Two nonconformances and four concerns were identified; one of the nonconformances concerned the procurement control of compu-ter service contracts. The audit report stated that one nonconformance from QAA/70-16 and one f rom QAA/70-17 remained ope e. Vendor Evaluation and Audits Engineering and Construction Quality Assurance / Quality Control Section are responsible for development and implementation of a vendor shop surveillance program, for purchases directly by the Nuclear Plant Engineering, Nuclear Plant Construction, Nuclear Operations or Tech-nical Services Departments. Ebasco and Westinghouse, when acting as agents for CP&L, are responsible for development and implementation of a vendor shop surveillance program; CP&L participation is at the discretion of the principal vendor surveillance specialist and/or Manager of Engineering and Construction QA/QC based on information supplied by the A/E in the form of milestones developed from vendor manufacturing sequence The approved suppliers list is maintained by the Engineering and Construction QA/QC section vendor surveillance unit. The list repre-sents approval by Engineering and Construction QA/QC for the letting of vendor contracts for equipment / services without further QA actio Approximately 170 vendors were listed on CP&L's approved suppliers list, revision 15 dated January 6, 1982. This list is reviewed monthly and a corporate memo identifies the list of vendors whose QA qualifi-cation expiration dates fell during the previous month with the reasons for expiration, vendors added to the list, and a list of vendors whose

.-

. .

. .

.

qualification will expire during the forthcoming two months. The memo dated March 1,1982 identified 15 vendors whose qualification expira-tion dates fell during February 1982. Six were deleted because of no orders, one failed an audit, one had an audit scheduled and seven had their expiration extended to February 1983 by annual evaluation. Nine vendors were added to the list and nineteen were identified for quali-fication expiration by May 31, 198 Annual evaluations of vendors by CP&L were reviewed. Approval of vendor was primarily based on review of their QA manuals, vendor audit results, ASME certification, and, to a lesser degree, past performance results. When a review proves inadequate, CP&L recommends that Ebasco perform an audit on the reviewed vendo Ebasco audit reports on vendors were examine A QA evaluation of Samual Moore Corporation, Aurora, Ohio for production of electrical cable was performed September 17-18, 1981. A memo dated November 6,1981 stated corrective action to the audit findings was considered satisfactory and Ebasco purchasing department was notified of the satisfactory audi The qualifications of those CP&L auditors who performed the audits of Westinghouse, Ebasco and vendors were examined. All were found to be well qualified and experienced individual Within the above area, no violations or deviations were identifie , _