IR 05000413/1985043

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Insp Repts 50-413/85-43 & 50-414/85-46 on 850926-1025. Violation Noted:Failure to Follow Procedure for Control of Nonconforming Items
ML20205G409
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 11/04/1985
From: Dance H, Skinner P, Van Doorn P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205G350 List:
References
50-413-85-43, 50-414-85-46, NUDOCS 8511130239
Download: ML20205G409 (10)
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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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l Report Nos.: 50-413/85-43 and 50-414/85-46 Licensee: , Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and CPPR-117 Facility Name: Catawba 1 and 2 Inspection Conducted: ptember 26 - October 25, 1985

, Inspectors: d, P. K. Van

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///4/W Date'Kigned Accompanying Per r . Schepens (September 30 - October 4, 1985 Approved by: nell: //

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/b M. C. Dance, Section Chief Ope Yigned Division of Reactor Projects SUMMARY Scope: This routine, unannounced inspection involved 173 resident inspector-hours on site in the areas of followup of licensee and NRC identified items (Units 1 and 2); review of Part 21 implementation (Units 1 and 2); plant operations (Unit 1); fuel receipt and storage (Unit 2); followup of nonroutine events (Unit 1); surveillance observation (Unit 1); maintenance observation (Unit 1); preoperational test program implementation (Unit 2); comparison of as-built plant to FSAR description (Unit 2); and information meetings with local officials (Units 1 and 2).

Results: Of the 10 areas inspected, no violations or deviations were identified in nine areas; one apparent violation was found in one area (Failure to follow procedure for control of nonconforming items, paragraphs 3.b and 8.e).

8511130239 851106 PDR O ADOCM 05000413 PDR

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s REPORT DETAILS

' Persons Contacted Licensee Employees-J. W. Hampton, Station Manager

  • H. L. Atkins, QA Engineering Supervisor
  • H. B. Barron, Operations Superintendent W. H. Bradley, QA Surveillance
  • H. D..Brandes, Analytical Engineer J. W. Cox, Superintendent, Technical Services T. E. Crawford, Operations Engineer L. R. Davison, Project QA Manager J. R. Ferguson, Assistant Operating Engineer
  • L. Hartzell, Licensing and Projects Engineer R. A. Jones, Test Engineer C. S. Kelly. Instrumentation / Electrical Technical Support
  • R. D. Kinard, HP Coordinator
  • J. Knuti, Operating Engineer
  • P. G. LeRoy, Licensing Engineer E.. Muse, Operating Engineer T. D. Mills, Construction Engineer, Electrical
  • D. B. O'Brien, Administrative Methods Supervisor
  • T. Robertson, Construction Engineer
  • G.' Robinson, QA Engineer, Operations
  • F. P. Schiffley, II, Licensing Engineer G. T. Smith,' Maintenance Superintendent
  • D. Tower, Operating Engineer
  • E. G. Williams, Project QA Technician Other licensee employees contacted included construction craftsmen, technicians, operators, mechanics, security force members, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on October 25, 1985, with those persons indicated in paragraph 1 above. The violation and unresolved items described in paragraphs 3, 7 and 8 were discussed in detail. The licensee acknowledged the findings and had no dissenting comments. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

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. Licensee Action on Previous Enforcement Matters (92701) (Units 1 and 2) (0 pen) Unresolved item 414/85-31-02: Failed Containment Spray Pipe Suppor This item involved a failed hanger discovered by an NRC inspector which the licensee was requested to evaluate. The licensee was asked in a later inspection to address a lack of communication problem which contributed to the failed hanger The inspector reviewed licensee evaluation of the communication issui uhich appears adequat The inspector requested the licensee's evaluation as to why the failed hanger was not identified by the licensee and other generic implications. The licensee informed the inspector that this evaluation was in progress. This item remains open pending further licensee and NRC evaluatio (Closed) Unresolved Item 413/85-41-02, Evaluation of Instrument Problem Identified on NCI CN-304. This item concerned an apparent incomplete evaluation of a nonconforming condition involving installation of unqualified covers on environmentally qualified transmitter The licensee reopened the Nonconforming Item Report (NCI) and conducted further evaluation which resulted in: the discovery that Instrument and Electrical Section personnel had installed the wrong covers, removal of additional unqualified covers from the warehnuse and review for possible generic implication Licensee QA Procedure No. QCK-1, Control' of Nonconforming Items, Rev.19, requires NCIs to be forwarded to the appropriate departments for resolution and corrective action, NCI resolutions to be sufficiently detailed to clearly identify the action necessary to correct the deficiency, and QA review of NCI resolutions for clarity and completeness. Contrary to these procedure requirements, the resolution of the deficiency identified in NCI N CN-304 was incomplete since it had not been forwarded to the appropriate personnel for evaluation and QA personnel failed to detect the incomplete evaluation in their review. This is in violation of 10 CFR 50, Appendix B, Criterion V which requires that activities affecting quality be accomplished in accordance with established procedures. Therefore the item is upgraded to violation 413/85-43-01:

Failure to Follow QA Procedure for Control of Nonconforming Items. For an additional example of this violation, see paragraph (0 pen) Unresolved Item 414/85-43-01: Fillet weld Leg Size Joint Geometry Configuration for (1/16" - 3/16") Gap not considered at Final Visual Inspectio This item concerned whether the licensee had appropriately considered joint gap in weld size inspections for AWS Code welding. The inspector held discussions with licensee personnel who indicated that they felt the code had been followed and that the welds were technically adequate. The inspector requested the licensee to document their position relative to code interpretation and technical adequacy for further NRC revie No violations or deviations except as described in paragraph 3 b., were identifie f

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. Unresolved Items *

New unresolved items are identified in paragraphs 7 and . Licensee Identified Items 50.55(e) (99020) (Unit 2) (Closed) CDR 414/85-06: Overpressurization of Volume Control Tan Reports for this item were submitted on May 22,1985; July 15,1985; July 24, 1985 and August 15, 1985. The inspector reviewed these reports and verified implementation of corrective actions identified in the reports and considers licensee actions to be acceptabl The licensee has included additional information in the applicable Nonconforming Item Report by attachment or reference as previously requeste ' (Closed) CDR 414/85-08: Overpressurization of the RHR System. Reports for this item were submitted on May 31, 1985; July 15, 1985 and July 24, 198 The inspector reviewed these reports and verified implementation of corrective actions identified in the reports and considers licensee actions to be acceptable. The licensee has included additional information in the applicable Nonconforming Iten Report by attachment or reference as previously requeste The inspector also observed areas in Unit 2 where plastic had melted on stainless steel piping during Hot Functional Testing. This item was reported to the NRC as a potentially reportable item on October 10, 1985. This inspection was conducted to get a preliminary assessment of the extent of this proble The licensee is still assessing this proble No violations or deviations were identifie . Previously Identified Inspector Findings (92701) (Units 1 and 2)

(0 pen) Inspector Followup Item 413/85-41-01, 414/85-40-01: Evaluation of Testing of PORV NC34A. The inspactor reviewed the licensee's evaluation of this question for Unit I documented in a Memo to file from D. M. Robinson dated October 10, 1985. The valve was tested for opening time and calibrations of instrumentation to assure the valve receives the open or close signal at the appropriate setpoint. It should be noted that this valve had not been upgraded to safety related for Unit 1. Additional discussions is needed with the vendor representative and evaluation of the Unit 2 test is required by the licensee and NR No violations or deviations were identifie *An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio T

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. CFR Part 21 Inspection (36100) (Units 1 and 2)

The inspector reviewed two 10 CFR Part 21 records to determine if evaluations were conducted to ascertain that a substantial safety hazard does not exis The first 10 CFR Part 21 reviewed was associated with a report from Ruskin Manufacturing Division dated November 6,1984, concerning a deficiency with fire dampers that would not close under air flow conditions. This review was conducted in conjunction with a fire protection inspection conducted by region based inspectors (see Inspection Report No. 50-414/85-50). The-10 CFR 21 notification from Ruskin was sent to Duke Power Company (DPC) on November 6, 1984. OPC Licensing personnel sent the 10 CFR 21 notice to all three nuclear stations and to Mechanical Design Engineering. Mechanical Design Engineering determined that the Ruskin concerns did not apply to the Duke plants on January 4, 1985. This determination did recommend additional fire brigade training to address the fire damper's inability to close with the systems operating. The letter of January 4,1985, was transmitted to each nuclear station in correspondence from Licensing dated January 11, 198 The training that was recommended for Catawba was defined in a memo to the station from Civil / Environmental Division dated April 4 and the training specified was conducted by the Catawba training department from May 7, 1985 to June 27, 1985. One area of concern was identifie Quality Assurance Procedure PR-290, Revision 13, Nuclear Regulatory Commission Reporting Requirements, requires that a Form 290.1, Potentially Reportable Item, be generated and within 30 days an evaluation as to the significance and reportability of the item will be made. A form 290.1 has not been found as of the date of this report and it also appears from documentation provided that the evaluation exceeded the 30 days specified in PR-290. The licensee is continuing to investigate this lack of documentatio This concern is combined with the concern identified below to constitute an unresolved ite The second 10 CFR Part 21 reviewed was associated with a letter dated September 3, 1985, from American Air Filter Company regarding possible welding problems with the intake silencer associated with the standby diesel generators received by the resident inspector on September 12. Since the copy of this letter came to the resident inspectors office, a copy was provided to the site DPC personnel on September 12, 1985. During the followup of this item, the inspector requested to see the evaluation of this ite This item was evaluated for Unit 2 as discussed in potentially reportable item (Form 290.1) serial number CA-85-33 which was reported to NRC Region II,on October 15, 1985. There does not appear at this time that an evaluation was made for Unit 1. According to the PR-290 procedure and Station Directive 2.8.3, Revision 0, 10 CFR 21 Reportability Guidance, documentation and evaluation of this item should be availaol In the utilities investigation to date, the licensee has performed an inspection

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for the problem on the 1A diesel generator and found that the problem did not exist on that diesel generator. Another question that confused this issue is whether the utility received the 10 CFR 21 notice " officially".

The licensee is continuing its investigation into this item. The lack of documentation identifying the evaluation process for the Unit I diesel generators required by PR 290, SD. 2.8.3, and determination as to whether DPC has received the 10 CFR 21 from American Air Filter er Trans American DeLaval is combined with the item discussed above to constitute an unresolved item (413/85-43-02, 414/85-46-01): Lack of 10 CFR 21 evaluation documentation for American Air Filters and Ruskin Fire Dampers. Plant Operations Review (Unit 1) (71707 and 71710) The inspectors reviewed plant operations throughout the reporting period to verify conformance with regulatory requirements, Technical Specifications (T/S), and administrative controls. Control room logs, danger tag logs, Technical Specification Action Item Log, and the removal and restoration log were routinely reviewed. Shift turnovers were observed to verify that they were conducted in accordance with approved procedure The inspectors verified by observation and interviews, that measures taken to assure physical protection of the facility met current requirements. Areas inspected included the security organization, the establishment and maintenance of gates, doors, and isolation zones in the proper condition, that access control and badging were proper, and procedures followe In addition to the areas discussed above, the areas toured were observed for fire prevention and protection activities. These included such things as combustible material control, fire protection systems and materials, and fire protection associated with maintenance and construction activitie During several tours by the inspector of areas in the auxiliary building several valves which should have been in a locked condition were noted to be either improperly locked or not locked at all ( chain and lock not installed or installed in such a manner that the valve could still be fully operated). These discrepancies were identified to the shift supervisor who took immediate corrective action to assure valves were in their correct positions and locked appro-priately. An investigation was commenced to determine how the valves got into these configurations. This is identified as an Unresolved Item (413/85-43-03); Correction and Investigation of Problems Associated with Locking Methods of Valves, pending the results of this investigation and corrective actions taken. The inspector will review this area during a subsequent inspectio _ _ - _ - - - _ - _ _ _ _ _ _ _ _ _ -

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. A special inspection was conducted of valves in the Nuclear Service Water System since inconsistencies had been noted for similar valves at the licensee's McGuire Station relative to valve position indication and direction of operation. The inspector observed 22 valves in the fiel The valve position indication was clearly visible, was marked using permanently affixed metal tags, and was consistent. Valves which operated by turning handwheels opposite to normal were clearly marked with a permanently attached red tag, The inspector reviewed the licensee's Reactor Coolant System leak rate calculations in detail due to problems identified with unidentified leakage. The reactor was shut down to Mode 3 or lower twice during this reporting period due to unidentified leakage exceeding the Technical Specification (3.4.6.2) limit of 1 gpm. The inspector also participated in the evaluation of emergency technical specification change requests made during this reporting period. The licensee was given authorization on October 18, 1985 to remain in Mode 3 for an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> beyond the time when the reactor would have been required to be placed in Mode 5 per Action Statement b. of Technical Specification 3.4.6.2. This extension allowed increased opportunity for leakage paths to be identified for correctio The inspector reviewed operations NCI's to determine if documentation was clear and complete and whether appropriate resolution and corrective action was specified. In addition, the inspector requested information as to the operations QA review of a problem identified by Construction NCI No.19773. Licensee QA Procedure No. QCK-1, Control of Nonconforming Items, Rev.19, requires Operations QA evaluation of Construction NCI's sent to operations by Construction for applicability

< to Unit 1. The problem of instrument cable separation described in NCI 19773 had a high probability of having occu red in Unit 1. However, the evaluation of this problem for Unit i did not recognize that fact and no field observation was required. At the request of the NRC inspector, a field observation was conducted and two discrepancies were identified. A new NCI, CN-340, was issued. This is the second example (see paragraph 3.b) of violation 413/85-43-01: Failure to follow QA Procedure for Control of Nonconforming Item No violations or deviations, except as described in paragraph 8.e., were identifie . Fuel Receipt and Storage (605018) (Unit 2)

The inspector observed receipt of fuel modules in progress to verify that the licensee was meeting requirements of approved procedures and Materials License SNM-1949. Attributes considered in this review included personnel training, housekeeping / cleanliness control, health physics controls, security, receiving inspection (assemblies NIS, M13, L63 and L64) and documentatio No violations or deviations were identifie _ __ __ _ _ .

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10. ~ Review of Licensee Nonroutine Event Reports (92700) (90711) (Units 1 and 2)

The-below listed Licensee Event Reports (LER) were reviewed to determine if the information provided met NRC requirement The determination u included: adequacy of description, verification of compliance with Technical Specifications and regulatory requirements, corrective action taken,- existence of potential generic problems, reporting ' requirements

' satisfied, and the relative safety significance of each event. Additional inplant reviews and discussion with plant personnel, as appropriate, were

. conducted for those reports indicated by an asterisk (*). The following LERs are close LER 85-44 Reactor Trip Due to Lo Lo SG Level LER 85-45 Reactor Trip Due to Isolation of Incorrect Steam

Pressure Transmitter

  • LER 85-50 Inadvertent Isolation of the Main Fire Protection System

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LER 84-6 Improper Boron Sampling As Required by the Operating License No violations or deviations were identifie . Surveillance Observation (61726) (Unit 1)

During the inspection period,. the inspector verified plant operations were in compliance with various Technical Specifications requirements. Typical '

of these requirements were confirmation of compliance with the Technical  ;

Specifications for reactor coolant chemistry, refueling water tank,  !

emergency power systems, safety injection, emergency safeguards systems,

~ control room ventilation, and direct current electrical power sources. The inspector verified that surveillance testing was performed in accordance -

with the -approved written procedures, test instrumentation was calibrated, limiting conditions for ' operation were met, appropriate removal and i restoration of the affected equipment was accomplished test results met l requirements and were reviewed by personnel ' other than the individual directing the test, and that any deficiencies identified during the testing [

were properly reviewed and resolved by appropriate management personne ;

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Typical of 'the surveillance items that .were witnessed in part or in full were Lvarious calibrations of the nuclear instrumentation radiation monitoring systems instrumentation, battery . testing, auxiliary feedwater system' testing, and heat removal system testing No violations or deviations were identifie . Maintenance Observations (62703) (Unit 1)

Station maintenance activities of selected systems and components were observed / reviewed to ascertain that they were conducted in accordance with the requirements. The inspector verified licensee conformance to the requirements in the following areas of inspection: the activities were accomplished using approved procedures, and functional testing and/or calibrations were performed prior to returning components or systems to e service; quality control records were maintained; activities performed were

' accomplished by qualified personnel; and, parts and materials used were properly certified. Work requests were reviewed to det, ermine status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may effect system performanc No violations or deviations were identifie . Preoperational Test Program Implementation (70302 and 71302) (Unit 2)

The inspector conducted tours to verify that turned over equipment was adequately protected and controlled. This review included observation of construction activities, . observation for fire hazards and observation of security boundarie The inspector observed conduct of the Hot Functional Test portion of the preoperational ' test program.. This included discussions with the test program director and test engineers, general observation of testing and operations in the control room and observation of a specific test described below. This inspection was performed to assess whether the licensee was conducting a well organized program, personnel had a good understanding of responsibilities and conduct of specific tests, control of organizational interfaces was good, procedures were properly approved, control of test schedule was adequate and current drawings and manuals were used by the licensee. The inspector specifically reviewed Procedure No. TP/2/A/1400/15, Rev. O, Auxiliary Shutdown Panel Cooldown Functional Test and also witnessed the test described in the procedur No violations or deviations were identified.

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i 14. Comparison of As-built Plant to FSAR Description (37301) (Unit 2)

The inspector compared the latest as-built field drawings for a selected l system to the FSAR drawings and descr*ptions and the draft Technical (- Specifications to determine if these documents were in agreement regarding f

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piping, components and control and logic instrumentation. This review

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included flow diagrams and electrical one line drawings. The system selected was the Component. Cooling System (KC) shown on Drawings CN-2573-1.0, Rev. 6; 1.1, Rev. 6; 1.2, Rev. 6; 1-3, Rev. 4; 1.4, Rev. 5;-

1.5, Rev. 3; 1.7, Rev. 5 and 2.1, Rev. 1. The inspector performed a detailed field walkdown inspection to determine if the system was as described in the as-built drawings for portions of the KC systems shown ~on Drawing Nos. CN-2573-1.0, 1.1 and .No violations or deviations were identifie . Information Meetings with Local Officials (94600 (Units I and 2)

A meeting was held with local Tega Cay city government officials on October 21, 1985. This meeting was conducted to familiarize the local officials with the mission of the NRC, to introduce key NRC personnel associated with Catawba, to discuss lines of communications available between local officials and the NRC, and to discuss the status of the facility and related community concerns with these local officials. A copy of general . information was provided.to the major and council members. The following local officials were present:

Mr Hubert Graham, Mayor Ms. Kathryn Updike, Council Member Mr. Cecil Suite, Council Member Mr. Stephen Forrest, Cou,1cil Member Mr. Frank Thompson, Council Member Ms. Jean Varner, City Administrator

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