IR 05000413/1985049
| ML20137B964 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/06/1986 |
| From: | Belisle G, Latta R, Moore L, Moorman J, Runyan M, Michael Scott, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137B954 | List: |
| References | |
| 50-413-85-49, 50-414-85-58, NUDOCS 8601160139 | |
| Download: ML20137B964 (42) | |
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p ttro UNITED STATES o NUCLEAR REGULATORY COMMISSION
[' , REGION 11 g j 101 MARIETTA STREET, * * ATLANTA, GEORGI A 30323
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Report Nos.: 50-413/85-49 and 50-414/85-58 l
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: November 18-22, 1985 Inspectors: [
R. Latta
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J. Moorman k Le
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Date'Signea ib M. [unyari LM % if f86 I Date Signed m&
M. Scott
& o - c, - 24 Date Signed b%M C. Smith
//2/Rd, Dath Signed Accompanying Personnel: R. Martinez, Comision Nacional DeSeguridad Nuclear Y Salvaguardias Approved by: [ . -Wd G. A. Belisle,'Ncting Section Chief
/ 6//3 Date' Signed
. Division of Reactor Safety
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SUMMARY - - -
Scope: This routine, announced inspection involved 1961:ispector-hours on site in the areas of design control; test and experiments; procurement; receipt, storage, and handling of equipment and materials; document control; records and preoperational test records; audits; offsite review committee; surveillance and calibration control; measuring and test equipment (M&TE); quality assurance (QA)/ quality control (QC) administration; preoperational testing QA; QA for startup testing; and licensee actions on previously identified inspection finding Results: Of the 14. areas inspected, no violations or deviations were identifie PDR ADOCK 05000413 G PDR
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REPORT DETAILS Persons Contacted Licensee Employees
- Beaver, Performance L. Benjamin, Junior Engineer W. Bradley, QA Surveillance Supervisor
- T. Bright, Construction Engineer B. Brown, Support Technician, Maintenance D. Bullins, QA Auditor J. Bumgarner, QA Technical Support
- B. Caldwell, Station Services Supervisor R. Carpenter, Materials Supervisor R. Cole, Nuclear Safety Assurance Technical Specialist J. Coleman, Mechanical Maintenance Supervisor
- J. Cox, Technical Services Superintendent R. Cux, Planning Support Engineer R. Futrell, NSRB Director R. Fralix, Instrument and Electrical (I&E) Supervisor !
J. Frye, QA Audits Manager I
- J. Hampton, Catawba Nuclear Station (CNS) Manager
- C. Hartzell, Compliance Engineer l C. Jenkins, Storekeeper D. Jennings, QA Construction C. Jenson, Scheduling Engineer, Unit 2 R. Johnson, I&E Technician R. Jones, Test Engineering Supervisor J. Kammer, Associate Engineer, Performance
- J. Knuti, Operations Engineer
- J. Knutsen, Station Services / Document Control M. LaForrest, Safety Review Group Engineer R. Lee, QA Receiving Inspector
- P. LeRoy, Compliance W. Love, Materials Supervisor
- F. Mack, Jr. , Project Services, CNS
- McCollough, Maintenance Engineer M. McGuffee, Preventive Maintenance Coordinator l * Miller, QA Surveillance Specialist
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T. Mills, Construction Engineer, Electrical i J. Morgan, Junior Engineer D. Murdock, NSRB Member W. Murphy, Materials Coordinator L
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D. Owers, QA Lead Auditor R. Powell, Clerk, Document Control E. Rabon, Training Supervisor G. Robinson, QA Technical Support Supervisor
- D. Rogers, I&E, Maintenance G. Rogers, Project Engineer J. Sanborn, Construction Planning Supervisor
- K. Schmidt, QA Engineer R. Sharpe, Licensing Engineer D. Simpson, Senior Instrument Technician
- G. Smith, Maintenance J. Stackley, I&E Support Engineer J. Suptela, Junior Engineer, Operations K. Taylor, Technical Specialist Z. Taylor, Associate Engineer, Performance J. Teofilak, Junior Engineer, Operations J. Thomas, Scheduling Support, Integrated Scheduling
- J. Vigor, Mechanical Engineer, Construction W. Watson, Craft Coordinator B. Wells, Nuclear Safety Assurance Technical Associate R. White, Catawba Safety Review Group Chairman M. Wilenshoff, Electrical Maintenance Supervisor
- E. Williams, Project QA Technician
- J. Willis, Senior QA Engineer L. Wilson, Materials Procurement Supervisor NRC Resident Inspectors
- P. Skinner, Senior Resident Inspector (Optrations)
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- K. VanDoorn, Senior Resident Inspector (Construction)
- Attended exit interview Exit Interview The inspection scope and findings were summarized on November 22, 1985, with those persons indicated in paragraph 1 above. The licensee acknowledged the following inspection findings:
Inspector Followup Item: Nuclear Safety Review Board (NSRB)
Irregularities, paragraph 1 Inspector Followup Item: Technical Specification 4.0.5.c, Annual Pump Run Test Time Requirements, paragraph 12.
l The licensee did not identify as proprietary any of the materials provided l l to or reviewed by the inspectors during this inspectio l l Licensee Action on Previous Enforcement Matters i This subject was not addressed in the inspectio ]
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4. Design Control (37702, 35744)
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion III (b) Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants (c) ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (d) Regulatory Guide 1.33, Quality Assurance Requirements (Operations)
(e) ANSI N18.7-1976, Administrative Controls and Quality
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Assurance for the Operational Phase of Nuclear Power Plants (f) 10 CFR 50.59, Changes, Tests, and Experiments (g) Technical Specifications, Section 6.5, Review and Audit (h) 10 CFR 50.54.(a)(1), Conditions of Licenses (1) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9 The inspector r eviewed the licensee's design change program required by references (a) through (i) to determine if these activities were conducted in accordance with regalatory requirements, industry guides and standards, and Technical Specifications. The following criteria were used during the review to assess the overall implementation of the established program:
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Procedures have been established to control design changes which include assurance that a proposed change does not involve an unreviewed safety question or a change in Technical Specifications as required by 10 CFR 50.5 Procedures' _and responsibilities for design control have been
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established including responsibilities and methods for conducting safety evaluation Administ.ative controls for design document control have been established for the following:
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Controlling changes to approved design change documents l Controlling or recalling obsolete design change documents such as l revised drawings and modification procedures i
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'4 Release distribution of approved design change documents
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Administrative controls and responsibilities have been established commensurate with the time frame for implementation to assure that design changes will be incorporated into:
Plant procedures Operator training programs Plant drawings to reflect implemented design changes and medifications
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Design controls require that implementation will be in accordance with approved procedure Design controls require assigning responsibility for identifying post-modification testing requirements and acceptance criteria in approved test procedures and for evaluation of test result Procedures assign responsibility to delineate the method for reporting design changes to the NRC in accordance with 10 CFR 50.5 Controls require review and approval of temporary modifications in accordance with Section 6 of the Technical Specifications and 10 CFR 50.5 .
The documents listed below were reviewed to verify that these criteria had beets incorporated into the licensee design program:
Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Section 17.2.3, Amendment 9 Nuclear Station Modification Manual Section 7.1, Initiation of Nuclear Station Modifications, Revision 0 Section 7.2, Scheduling of Nuclear Station Modifications, Revision 0 *
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Revision 0 Section 7.6, Design of Nuclear Station Modifications, Revision 0 Section 7.7, Drawing Control for Nuclear Station Modification, Revision 0 Section 7.8, Installation and Return to Service, Revision 0
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l-l Section 7.9, Completion of Documentation for Nuclear Station
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i Catawba Nuclear Station Directive 4.4.4, Processing Nuclear Station Modifications, Revision 4 Administrative Policy Manual Section 3.4, Nuclear Station Modifications, Revision 22 Section 4.6, Administrative Instructions for Work Requests, Revision 22 l
Maintenance Management Procedure 1.0, Catawba Nuclear Station Work Request Preparation, Revision 17.
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I The Nuclear Station Modification Manual specifies appropriate requirements which shall be met to implement a modification at an operational nuclear statio The administrative controls delineated in this manual address the requirements for both Design Engineering Designed Modifications (DDMs) and l Station Designed Modifications (SDMs). Inspection Report 50-413/85-30
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documents the findings of an inspection of the design change program conducted af ter its revision in October 1984. The inspector determined then, that the revisions had enhanced the administrative controls applicable to the front end of the design change process. Based on a review of program documents and interviews with licensee personnel, the inspectnr verified
, that no further changes have been made to the program documents.
i Discussions with licensee personnel involved with the design change program also verified that they were knowledgeable of the design change program requirement A perceived weakness in the back end of the design change program was identified in Inspection Report 50-413/85-30. This functional area included the following elements:
l Planning and Scheduling; l System / Component Removal from Service; Post-Modification Testing; System / Component Turnover to Operating Staff; System / Component Declaration of Operability; and Nuclear Station Modification Closeout.
l The inspector conducted interviews with selected members of the licensee staff involved in various activities related to the above elements in order to determine the adequacy of the programmatic controls. These discussions were specifically addressed to the activities performed by Station Support Division (SSD), and the interface requirements with Nuclear Production Department (NPD) for accomplishing these activities.
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Nuclear Station Modification Manual, Section 7.2, delineates the process for scheduling nuclear station modifications. This process uses the milestone schedule concept which consists of major activities and associated dates in a bar chart format extending to the completion of the modificatio A schedule may be categorized as either a Proposal, a Plan, or Final based on a confidence level. Once a schedule has been released as Final, each milestone is suoported by detailed schedules prepared by the cognizant department or grou The inspector discussed the preparation of schedules for the implementation of DDMs by the SSD with the Construction Planning Supervisor. Additional discussions were held with the Planning Support Engineer, NPD, and staff members from the Integrated Scheduling Group. The inspector determined that the Integrated Scheduling Group ( formerly Startup Testing, Planning and Scheduling) is assigned responsibility for the processing of all S-2 documentation associated with system turnover as delineated in Station Directive 3.0.1. The inspector also determined that on a long term basis, the activities of the Integrated Scheduling Group will include integrated scheduling of station organizations activities in connection with the implementation of nuclear station modifications during planned / unplanned outage The activities of this group relative to nuclear station modification implementation for Unit 1, the licensed facility, appears to be still in the formative stag The inspector was informed that written instructions which describe the operation of the Integrated Scheduling Group will be prepcred for activities conducted POST Unit 2 licensin Administrative controls applicable to the implementation of nuclear station modifications by SSD are addressed in Section 7.8.2 of the Nuclear Station Modification Manual. Activities conducted by SSD are performed under the controls of the Construction Department's Quality Assurance Program. With the Near Term Operating License (NTOL) status of Unit 2, licensee management is presently engaged in converting construction activities to the administrative controls delineated in the Operational QA Program Topical Report. The lower tier documents, Administrative Policy Manual and Nuclear Station Modification Manual, will be the quality implementing procedures which delineate the requirements for all SSD activities in connection with the nuclear station modification program. The inspector reviewed the following documents in connection with this QA program change for
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construction activities:
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Attachment 1 to October 21, 1985 Meeting Minutes, Subject: Transition from Construction QA Program to Operations QA Program Meeting Minutes dated November 14, 1985, Subject: Construction Conversion to APM November 8, 1985 Meeting Summary and Status The inspector determined th:t planning arrangements for conversion of SSD activities to the controls of the Operational QA program are still in the formative stage. Various subcommittees have been formed to define required task descriptions, and provide proposed plans with Action Assignments, including implementation dates. Major tasks include the transition of
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Construction procedures to meet the requirements of the operational QA program, and implementation of the Work Request / Program. These tasks will involve numerous activities which form part of the personnel / plant, personnel / procedural, and plant / procedural interface requirement Among these activities are:
Deletion of construction procedures not currently being used; Determination of which construction procedures must be converted to maintenance procedures; Deletion of remaining construction procedures; Preparation of new required maintenance procedures; Full implementation of maintenance procedures by SSD; Development of Station Directive which specifies SSD responsibility for originating and planning Work Requests; Training of SSD Technical Support and craf t personnel on requirements of Work Request program; and Discontinuation of SSD writing F-13A Shutdown Requests and full implementation of Work Request program by SS Proposed completion dates for the above activities covers a time span f rom November 29, 1985, to March 31, 198 It is the inspector's understanding that a scheduled date of April 1, 1986, has been set for completion of all activity procedure A determination of the adequacy of the management controls applicable to the transition of the Construction (SSD) activities to the Operational QA program could not be made because of the early stage of development of this program change. Additional inspections will be required to establish conformance of SSD activities with the Operational QA program requirements af ter this transition is complet The licensee is presently in the process of developing an Implementation Plan. This plan is intended to establish the requirements for implementa-tion of Nuclear Station Modifications at operating stations and was identified in Inspection Report 50-413/85-30 as an Inspector Followup Ite The inspector was informed that the Implementation Plan is still being developed. Additional discussions were held with licensee management concernirg the requirements for incorporating the activities of SSD and the Integrated Scheduling Group into the Implementation Pla . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ ._ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
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The inspector reviewed the following design change packages to verify that selected elements of the design change program are being implemented as specified by procedures:
NSM No. CN-10518/00, Wire anti-hammer limit switch contacts in damper 1 ARF-D-2 and 1-ARF-D-4 control circuits. Revise motor controller seal-in circuit to allow damper to close under revised wirin NSM No. CN-10367, Install one-half inch couplings and thermocouples (DeLaval Part #F-133-105) on cylinders 4 and 5 right and lef t bank, near flange to turbo-chargers, Revision NSM No. CN-10360, Provide permanent wiring for thermocouples added under NSM No. CN-10367, Revision 0, to chart recorder and meter on engine panel, Revision The above nuclear station modification packages are intended for implementation at the first refueling outage for Unit The inspector verified that appropriate administrative controls applicable to the front end of the design change program were correctly implemente Within this area, no violations or deviations were identifie . Tests and Experiments (37703, 35749)
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) 10 CFR 50.59, Changes, Tests, and Experiments (c) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Section 17.2.11, Amendment 9 (d) Technical Specifications, Section 6.5, Review and Audit (e) Regulatory Guide 1.33, Quality Assurance Requirements (Operations)
(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power
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(g) 10 CFR 50.54(a)(1) Conditions of Licenses The inspector reviewed the licensee's test and experiment program required by references (a) through (g) to determine if the program was in conformance with regulatory requirements, commitments in the application, and industry guides and standards. The following criteria were used during this review to assess the overall acceptability of the established program:
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A formal method has been established to handle all requests or proposals for conducting plant tests involving safety-related component Provisions have been made to assure that all tests will be performed in accordance with approved written procedure Responsibilities have been assigned for reviewing and approving test procedure A formal system, including assignment of responsibility, has been established to assure that all proposed tests will be reviewed to determine whether they are as described in the FSA Responsib111 ties have been assigned to assure that a written safety evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specification The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's tests ..rd experiments progra Administrative Policy Manual, Revision 22 Section 3.2.3, Special Testing Section 4.3, Administrative Instructions for Temporary Station Procedures FSAR, Chapter 14.0, Initial Test Program l Table 14.2.11-1, Testing Following Initial Fuel Load Catawba Nuclear Station - Unit 1, Startup Report (Docket No. 50-413, License No. NPF-35)
Based on a review of program documents and discussions with licensee personnel, the administrative controls for tests and experiments appear to be adequate.
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The following licensee document was used to select completea test packages l for review:
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FSAR Chapter 14, Figure 14.2.11-1, Testing Following Initial Fuel Loading, Revision 11.
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The inspector subsequently examined the following test packages to verify that selected elements of the test and experiment program were being implemented in conformance with procedures:
Test Number: TP/1/A/2650/07, Turbine Trip Test Test Dates: 3/27/85 - 3/28/85 Test Number: TP/1/A/2650/06, Unit Loss of Electrical Load Test Test Date: 4/19/85 Changes to the test procedure caused as a result of deficiencies identified during the test performance were documented on Discrepancy Processing Record forms. The inspector performed a review of Discrepancy Processing Record forms and determined that corrective actions were initiated for disposition of identified deficiencie Improper operation of the steam dump valves was identified as discrepancies on both test procedure Discrepancy Processing Record forms. During the performance of the turbine trip test, Hot Zero Power Conditions were not reestablished after the turbine tripped, i.e., the reactor did not run back to Tave (557 F e 2*F). The licensee attributes this to the steam dump and unit auxiliaries imposing an artificial load on the primary system. The
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acceptance criteria delineated in precedure step #11.4 was changed to l acconmcdate this discrepancy. Additional discrepancies associated with the steam dump valves were identified during the Unit Loss of Electrical Load Test. The test acceptance criteria delineated in test procedure step #11.6
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were accordingly changed to facilitate disposition of the discrepancy. The inspector discussed both test procedures with regional management and submitted copies of both test procedures to the Test Program Section for technical review and comment.
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Within this area, no violations or deviations were identifie . Procurement (38701, 35746)
References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Section 17.2, Amendment 9 (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) 10 CFR 21, Reporting of Defects and Noncompliance (e) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
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(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance Requirements for the Operational Phase of Nuclear Power Plants (g) Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Plants (h) ANSI N45.2.13-1976, Quality Assurance Requirements for l
Control of Procurement of Items and Services for Nuclear Power Plants The inspector reviewed the licensee p?ocurement program required by references (a) through (h) to determine if the program had been established in accordance with regulatory requirements, industry guides and standards, and commitments made in the applicatio The following criteria were used during this review to determine the overall acceptability of the established program:
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Administrative controls have been established to identify safety-related equipment, supplies, consumabler, and services to be procured under the QA progra Controls have been established .o provide measures and assign responsibilities for che preparation, review, approval, and changes to procurement document Procedures have been estabiished for qualifying and maintaining a current list of approved vendors, suppliers, and contractor Procedures have been established to assure that vendors, contractors, and suppliers conform to procurement and quality assurance document requirements, industry standards and codes, and that nonconformances are properly reported and correcte Controls have been established to provide for audits and surveillances of vendor and supplier facilities and for witnessing acceptance test The documents listed below were reviewed to determine if these criteria had been incorporated into the procurement program:
QA-115 Handling Procurement and Vendor Records, Revision 2 QA-117 QA Department Procurement, Revision 1 QA-410 Processing of QA Records for Purchased Items, Revision 11 QA-411 Filing of QA Records for Purchased Items, Revision 11 QA-505 Processing of Procurement Documents for Operational Nuclear Stations, Revision 19
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QA-601 Vendor Evaluation, Revision 10 '
QA-602 Vendor Surveillance Procedure, Revision 9 QA-603 Vendor Deficiency Reports. Revision 0 QA-605 Vendor QA Releases, Revision 3 L APM- Control of Materials, Parts, and Components, Revision 22 l
j SD-2.4.1 Purchasing of Materials, Labor, and Services, Revision 12 S0-2.4.3 Control of Materials, Parts, and Components, Revision 0 l SD-2.9.2 Control of Purchased Services, Revision 2 f
j Catawba Nuclear Station Materials Manual, Revision 8 QA Approved Vendor's List,11/1/85 -
The inspector . interviewed personnel and examined procurement documents to determine if tne licensee and vendors had implemented the above procedural requirement: during the initiation, review, approval, and processing of j procurement documents. The documents listed below were examined:
Purchase Order Quality Condition ( K12534 (Diesel Engine Parts) 1 J G36730 (Trar.sitors) 1 l _M26040 (Diodes) 1 l
K40511 (Valve Parts) 1 J37232 (Valve Parts) 1 l K48156 (Steel Plates) 1 l M43147 (Thermocouples) 1 i .
! Examination of the above documents and interviews with licensee personnel [
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confirmed that licensee administrative controls and measures were being ;
implemented during the procurement of safety-related items and services for ;
the operational unit. Interviews with licensee personnel confirmed that I they are currently revising program documentation and conducting training in '
preparation to merge the construction procurement program for Unit 2 into l - the operational procurement program used by Unit Within this area, no violations or deviations were identifie . Receipt,. Storage, and Handling of Equipment and Materials (38702, 35747)
i References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses
! (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Section 17.2, Amendment 9
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(c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide -1.33, Quality Assurance Program Requirements (Operations)
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.(e) ANSI N18.7-1976, Administrative Controls and Quality i- Assurance Requirements for the Operational Phase of Nuclear Power Plants (f) Regulatory Guide 1.38, Quality Assurance Requirements y for Packaging, Shipping, Receiving, Storage, and l Handling of Items for Water Cooled Nuclear Power Plants l
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(g) ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants l The inspector reviewed the licensee program and procedures required by l references (a) through (g) to determine if controls had been established for
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receipt inspections, initiation of nonconformance reports, disposition of l nonconfermances, handling, storage, and issue of safety-related equipment.
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The following criteria were used during this review to determine the overall j~ acceptability of the established program:
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Administrative controls were established for conducting and documenting receipt inspections and reporting nonconformance Administrative controls were established for disposition of items, mt.rking, storing, and protection of items during storag Administrative controls were established for limited shelf-life items and for performing audits and surveys of storeroom activitie Administrative controls were establis.ned for qualification of inspection personnel.
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l The following licensee documents were examined to determine if the licensee I
had prepared procedures to control receipt inspections, handling, storage,
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maintenance, and protection of reactor plant items:
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APM- Control of Materials, Parts, and Components, Revision 22 SD-2.4.3 Control of Materials, Parts, and Components, Revision 0 QA-140 Quality Assurance Inspector Training, Revision 11 QA-512 Review and Control of Onsite Certifications, Revision 2 QC D-1 Housekeeping During the Operations Phase of Nuclear
, Stations, Revision 11 QC G-1 Receipt, Inspection, and Control of QA Condition Materials, Parts, and Components Except Nuclear Fuel, Revision 22 QC G-3 Inspection of Items in Storage, Revision 1 QC K-1 Control of Nonconforming Items, Revision 19 Catawba Nuclear Station Materials Manual, Revision 8 l
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! A walkthrough inspection of the following storage areas was performed to
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l Storage Area Protection Level Outside Warehouse #2 B Inside Warehouse #3 B Cylinder Warehouse #4 C Lube Oil Warehouse #5 B i
Service Building Basement Warehouse #6 B Construction Warehouse #3 B Storage of items in the above warehouses appeared adequate. QA items were segregated, clearly identified, and marked with green tags statint purchase order number, QA control number, inventory control number, and 5 ielf-life i
'information. . Equipment was stored either above floor level on racks, on
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pallets, or in bin Long material subject to bending was adequately supporte Circuit boards and delicate electronic parts were stored on individual shelves or in storage drawers and were packaged to prevent intrusion of contaminants. Resins and sensitive chemicals were found to be stored properl Housekeeping in all storage areas was generally good Environmental controls relative to assigned protection levels were found adequat During the walkthrough inspection, the inspector selected seven items at random to determine if attached identification provided traceability back to the original procurement documents and quality documentation. Documents for all i tems were retrievable and found to be protected properl The inspector reviewed QA Surveillance CN-85-30, dated September 19, 1985, in which a QA inspector chose 17 QA items from various warehouses to determine i if the attached QA tag provided traceability to all necessary documentatio ;
Discrepancies were not identified relative to this revie Three safety-related items with limited shelf lives were examined in the Inside Warehouse #3 to verify that they were being maintained in accordance with administrative controls. The inspector tracked two of these three items on the shelf-life control computer program and on the shelf-life issue print out used by the storekeepe The inspector witnessed a QA receipt inspection conducted for purchase order M43147, Transamerica DeLaval thermocouples, QA condition 1. The receipt- ----
inspector was thorough and cognizant of inspection and documentation requirement Interviews with licensee personnel confirmed that they are currently revising program documentation and conducting training in preparation to merge the construction receipt, storage, and handling program for Unit 2 into the operational receipt, storage, and handling program used by Unit Within this area, no violations or deviations were identifie i_ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . . ..__.
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I Document Control (35742)
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f References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses l
I (b) Duke-1-A, Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9
! (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for l Nuclear Power Plants and Fuel Reprocessing Plants
! (d) Regulatory Guide 1.33, Quality Assurance Program l Requirements (Operations)
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(e) ANSI N18.7-1976, AdmJtdstrative Controls and Quality Assurance for the Operational Phase of Nuclear Power
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! (f) Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Qualitf, Assurance l Records
. (g) ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Qaality Assurance Records for Nuclear Power Plants i
The inspector reviewed the licensee document control program required by references (a) through (g) to determine if the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications. The following criteria were used dur.ing"this l review to determine the overall acceptability of the established progi'am:
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Administrative controls had been established for drawing issuance, drawing change review, obsolete drawing control, and as-constructed and as-built drawing updatin Administrative controls had been established for maintenance of indices for drawings, manuals, Technical Specifications, FSARs, and procedure Administrative controls had been established which assign specific responsibilities for drawing and document control program The following documents were reviewed to verify that these criteria had been ,
incorporated into the licensee's QA program for document controls:
QA-100 Preparation and Issue of QA Procedures, Revision 8 i
QA-107 Temporary Procedure Changes, Revision 2 l APM Document Control, Revision 21 SD 2.1.5 Drawing Distribution and Control, Revision 22
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SD 2.2.1 Procedure for Records Management, Revision 25 The inspector also reviewed the following surveillance reports:
CN-85-28 Document Control, Drawings, and Satellite File Controls, July 30, 1985 CN-85-34 Document Control, Manuals, Microfilming, October 18, 1985, November 12, 1985 These surveillance reports did not identify major programmatic deficiencie Some minor implementation discrepancies were noted and adequate corrective measures were provide The inspector verified that controlled documents in the following remote files contained the latest revision:
Performance Drawings: CNEE-0270-01.16 Revision 1 CNEE-0270-01.32 Revision 0 CNEE-0270-05.09 Re. vision 1 CNEE-0133-0103 ' evision d 3 CNEE-0111-02.04 Revision 2 CNEE-0111-03.02 Revision 3 CNEE-0111-03.06 Revision 3 CNEE-0171-01.19 Revision 3 CNEE-0173-01.05 Revision 0 CNEE-0173-01.13 Revision 1 I&E Office Drawings: CNEE-0145-01.04-03 Revision 6 CNEE-0147-01.03 Revision 10 CNEE-0211-03-05 Revision 0 CNEE-0170-03.01 Revision 9 CNEE-0246-01.03-19 Revision 4 CNEE-0247-07.03-01 Revision 0 CNEE-0260-04.10 Revision 1 Control Room Drawings: CN 2573- Revision 6 CN 2577- Revision 4 CN 2580- Revision 6 CN 2592- Revision 4 CN 1200- Revision 38 CN 1200-1 Revision 37 CN 1200-1 Revision 27 CN 1200-1 Revision 13 CN 1200-1 Revision 6 Within this area, no violations or deviations were identifie . --- --. - - - - . _ . _ . .-- . _ - .- -.
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9. Preoperational Test Records (39301) and Records (35748)
References: (a) 10 CFR 50.54(a)(1), Conditions of Licens,es (b) Duke Power Company Topical Report Quality Assurance l Program, Duke-1-A, Amendment 9 r (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) ANSI N45.2 9, Requirements for Collection, Storage, and .
Maintenance of Quality Assurance Records for Nuclear I Power Plants (e) Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction)
(f) Regulatory Guide 1.88, Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants (g) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants The inspector reviewed the licensee's administrative controls for records generated during the preoperational test program as well as other records I required by references (a) through (g) to determine if the administrative ;
controls were in accordance with regulatory requirements, ir dustry guides l and standards, and Technical Specifications. The following criteria were '
used during the review: '
Administrative controls have been established for maintaining records for the following types of activities during the preoperational testing period:
Preoperational test procedures and results Corrective and preventive maintenance QA/QC audit and surveillance .
Personnel training '
Personnel qualification Design changes and modifications Component, systems, and structure turnover Responsibilities have been assigned to assure that the records identified above will be maintained and the retention periods have been specifie Record storage controls have been established which accomplish the following:
Define the record storage locations for the types of records identified abov . _ _ - _ _ _ _ _ _ _- _-_ - _ _ - _ _ _ . - _ _ _ _ _ _ _
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Designate a custodian (s) in charge of storage of each class of record Describe the filing system (s) to be used to allow for the retrieval of record Establish a method for verifying that the records received for i storage are in agreement with any attendant transmittal document Make provisions for governing access to files and for maintaining an accountability of records removed from the storage facilit Establish methods for filing supplemental information and disposing of superseded record The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedures for records contro APM Records Management, Revision 21 QA-102 Storage of Special Processed Records, Revision 4 QA-111 Transfer of QA Records, Revision 4 QA-116 Quality Assurance Records Collection, Storage, and Retention, Revistor 6 QA-301 Management of Projects QA Records, Revision 8 QA-410 Processing of QA Records for Purchased Items, Revision 11 '
QA-411 Filing of QA Records for Purchased Items, Revision 11 QA-504 Quality Assurance, Operations, Revision 14 50-2.2.1 Procedure for Records Management, Revision 25 S0-3.0.1 System / Structure Turnover and Startup Processes, Revision 9 S0-3.0.3 Management of Turnover Exceptions, Shutdown Requests, and the Short Range Schedule / Activity Forecast, Revision 3 S-2 Construction Procedure - Systems Verification and Turnover, Revision 14 The inspector reviewed the following turnover packages and verified that the administrative controls applicable to the provisional and final turnover of ;
-these Unit 2 packages had been properly implemente '
t 2CM1 2EGA1 2CSI 2EGC1 2 ECD 1 2FW1 2NR1
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In addition, the inspector retrieved the following preoperational test records from document control in order to assure traceability, completeness, l
and quality.
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TP/2/A/1550/03A PT/2/A/4202/04 TP/2/A/1550/03F PT/2/A/4205/05 TP/2/A/1600/08 PT/2/A/4207/07 TP/2/A/2650/01 TP/2/A/1200/03B TP/2/A/1350/13 TP/2/A/1350/12A
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l TP/2/A/1400/13 TP/2/A/1550/03B TP/2/A/1350/128 TP/2/A/1350/27 i
The implementation of the administrative controls during the transition from Construction to Preoperational Test program was verified by review of the above turnover packages and preoperational test records. The inspector noted a number of outstanding exceptions contained in each turnover package and verified that administrative controls were being implemented for tracking and clearance of these exceptions. Prior to final acceptance of a turnover package, the package is reviewed by each of four plant superinten-dents of the various disciplines in the Nuclear Production Department for individual * acceptance before review by the plant manager. These concurrences are documented. The status of the preoperational test program is as follows: hot functional testing was completed on October 14, 1985; preoperational tests are approximately 60 percent complete at the time of this inspection; and startup testing is scheduled to commence in January 198 Plant records are stored in either the QA vault, the document control vault, or various satellite file locations delineated in Station Directive 2. The inspector visited the following record storage facilities; Performance, I&E, Document Control, and the construction vault for Unit 2. All areas visited were controlled in accordance with ' administrative requirements. All records were found to be stored properly, readily retrievable, and complet Particular attention was addressed to the construction vault to verify conformance to requirements. With the exception of sealant on the vault walls, all requirements were clearly incorporated. The sealant issue was identified by a Catawba Departmental audit CD-82-6 (CN) of May 10, 1982. In response to the finding of an' apparent lack of sealant, a Facilities Engineer responded that a sealant had been applied on the walls but due to the rough texture of the walls, it was not apparent. This response was dated June 25, 1982. The inspector additionally verified that temperature and humidity were frequently monitored and recorded in a local lo .
Within this area, no violations or deviations were identifie . Audits (35741) --
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and Fu 1 Reprocessing Plants (b) Regula*.ory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants (c) ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants
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(d) Regulatory Guide 1.146, Qualification of Quality
! Assurance Program Audit Personnel for Nuclear Power Plants
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(e) ANSI N45.2.23-1978, Qualification of Quality Assurance i
Program Audit Personnel for Nuclear Power Plants (f) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
(g) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power l Plants (h) Technical Specifications, Section 6 ,
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(1) 10 CFR 50.54(a)(1), Cond".v of Licenses >
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(j) Duke Power Company To p i t.a i Report Quality Assurance Program, Duke-1-A, Amendment 5 The inspector reviewed the licensee audit program required by references (a)
through (j) to verify that the program had been establ7shed in accordance with regulatery reqJirements, industry guides and standards, and Technical Specification The following criteria were used during this review to determine the overall acceptability of the established program:
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The audit program scope was defined consistent with Technical
, Specificatioas and QA program requirement Responsibilities were assigned in writing for overall management of the audit progra Methods were defined for taking corrective action on deficiencies identified during audit The audited organization was required to respond in writiro tc audit finding Distribution requirements were defined for audit reports anl t' r ective action response .
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Checklists were required to be used in performing audit t
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Measures were established to assure that QA audit personnel met minimum education, experience, and qualification requirements for the audited activit The documents listed below were reviewed to determine if these criteria had been incorporated into the auditing program:
Duke-1-A Duke Power Company Topical Report Quality Assurance Program, t Amendment 9 l
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i QA-100 Preparation and Issue of Quality Assurance Procedures, j Revision 8 QA-111 ~ Transfer of QA Records, Revision 4 -
QA-122 Corrective Action Escalation Policy, Revision 2 QA-123 Processing of Nonconforming Item Reports by Quality Assurance General Office Personnel, Revision 0 QA-130 Qualification and Training of Auditors, Revision 12 l
l QA-140 Quality Assurance Inspector. Training, Revision 11 QA-190 Review of Quality Assurance Procedures, Revision 4 QA-210 Departmental Audit Procedure, Revision 18 QA-230 Departmental Audit Scheduling and Followup, Revision 10 l
QA 500 Operations Division Surveillance Program, Revision 17 APM Review and Audit l
l Administrative Policy Manual for Nuclear Stations (Revision 22)
l Region II Inspection Report 50-413/85-22 dated June 27, 1985, addressed the Duke audit program. This section of this report addresses changes since that t'me. Since May 1985, two audits have been scheduled for performance at Catawba. Audit NP-85-18 (CN) was reviewed by the inspector. The
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inspector observed Audit NP-85-22 (CN) in progress. The inspector verified that this audit was being conducted using an approved checklist. The
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inspector questioned participating auditors as to their methodology for
- conducting this audit, and the findings to date. The auditors informed the inspector that significant findings had not been identified to dat I Since the last inspection, four new personnel were transferred from the Catawba site to Quality Assurance in the corporate offic The inspector
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reviewed their personnel files to insure that their qualifications and training were satisfactory.
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Within this area, no violations or deviations were identifie l I
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11. Offsite Review Committee (40701)
References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9 (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Technical Specifications, Section 6.5.2, Nuclear Safety Review Board (NSRB)
(e) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants Tha inspector reviewed the licensee's offsite review committee, the Nuclear Safety Review Board (NSRB), required by references (a) through (f) to determine if the committee was in conformance with regulatory requirements, industry guides and standards, and the Technical Specifications (TS). The following criteria were used during this review to assess the overall acceptability of the established program:
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The NSRB membership and qualifications were as required by T The NSRB held meetings at the required frequency with the required quoru The NSRB reviewed those items specified in T The iiSRB had cognizance of audits performed in the areas specified by T NSRB meeting minutes were prepared and issued within the required timeframe The second and third criteria listed above are discussed in the text of the paragraohs belo The documents listed below were reviewed to determine if the previous listed criteria had been incorporated into the licensee's NSRB charter and guidance:
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Document Title Revision Charter Charter of the Nuclear Safety Review 3 Board NSRB/1 Processing Nuclear Safety Review Board 2 Review Material NSRB/2 Conduct of On-Site Reviews and Audits 1 NSRB/3 NSRB Record Retention and Handling 1 NSRB/4 NSRB Outstanding Items Accountability 1 NSRB/5 NSRB Review of Documentary Material 0 NSRB/6 Conduct of Nuclear Safety Review Board 1 Meetings NSRB/7 Independent Review of the Nuclear Safety 0 Evaluation Checklist for. Station Procedures, Procedure Changes, and Completed NSMs The inspector reviewed the completed minutes resulting from the following meetings:
NSRC Meeting N Date of Meeting 85-01 1-23-85 85-02 2-13-85 85-03 4-16-85 85-04 6-26-85 85-05 7-10 & 11-85 85-06 8-13-85 85-07 9-10-85 85-08 10-11-85 85-09 10-18-85 85-10 11-14-85 It was noted by the inspector that the September 10, 1985, meeting was one member short of the required number for quorum. It was stated by the Director of the NSRB that the quorum was met by his presence at the meeting, and it was simply a clerical oversight that his name was not on the meeting i minutes cover letter. A violation is not warranted in this area since this
! appears to be an administrative oversight.
! The inspector reviewed the qualifications of the NSRB, The nine member l board and two alternates met the requirements of TS. Two members of the board were consultants and their credentials met TS requirement '
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Audit report NP-85-22 (CN) addressed the qualifications of the Nuclear Safety Assurance Staff (NSA) that supports the NSRB. An audit item relative to personnel was still open at the time of the inspection. The item had escalated to the upper management level and corrective action was being pursue The NSRB conducts business as discussed in the next three paragraphs. The Director of the NSRB, who is also the manager of NSA, is pivotal in the functioning of the boar Documents identified by the TS are funneled from the site to the Director of the NSRB except for procedures; these are normally reviewed in batches by the board members. NSA collates these documents and provides distributio Should board members have questions on the reviewed material, these questions are sent to site groups by the NS NSA employees followup on these questions prior to the next semi-annual board meeting or as directed by the board. At the discretion of the board, the questions and answers can become agenda items at the next meetin Agenda items can be escalated during a board meeting. Should an item be deemed to require corporate attention, the NSRB Director or board member would contact the appropriate corporate entity. Acco-ding to NSRB staff and members, a letter had been generated by the board enca in recent memory, however, the usual mode of board action is on a verbal leve NSRB reviews TS changes more frequently than the semi-annual meeting As plant exigencies occurred, the board did meet to aoprove TS change Amendments are typically presented to the board by licensing personne The inspector reviewed six TS changes approved by the board. These changes must be and were approved by the NSRB and then the NRC prior to
' implementation. Safety evaluations performed by site and corporate personnel appeared adequat The inspector spoke with two NSRB members and it's Director. Discussions involved questions and answers that had been generated by members, NSRB effectiveness, and generic historical issues between the three Duke nuclear station The inspector interviewed Catawba site personnel to understand their perception of NSRB activities. Outside of fielding NSRB questions via a transmittal, NSA staff queries, or when requested to brief the board, site personnel were unaware of NSRB impact. The NSRB impact was being felt or transmitted to site personnel above the middle manager leve Some Incident Reports and Significant Deficiency Reports are reviewed by the NSRB long after issuance of the report. This is mainly due to the frequency of the board's meetings. Typically, six months may pass before some of the reports are reviewed and possibly placed on the board's agenda. Site !
personnel, who generated the reports, may have to reconstruct events to i properly respond to NSRB questions after the fac I l
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Within this area, one inspector followup was identified. Per discussions
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with the NSRB Director, procedures and plant modifications are being reviewed by the NSA staff and himself. Results of these reviews, however, are not being relayed to the NSRB. Until the results of these procedures and plant modification reviews are made part of the NSRB agenda, this is identified as Inspector Follow-up Item 413/85-49-0 . Surveillance Testing and Calibration Control (61725, 35745)
References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) Duke Power Company Topical Report Quality Assurance Program, DUKE-1-A, Amendment 9 (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide 1.33, Quality Assurance Program
, Requirements (Operations)
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(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Technical Specifications, Section 4 The inspector reviewed the licensee surveillance testing and calibration control program required by references (a) through (f) to determine if the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications. The following
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criteria were used during this review to determine the overall acceptability of the established program:
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A master schedule for surveillance testing and calibration delineated test frequency, current status, and responsibilities for performanc The master schedule reflected the latest revisions of the Technical Specifications and operating licens Responsibilities were assigned to maintain the master schadule up-to-date and to ensure that required tests are performe Detailed procedures with appropriate acceptance criteria were approved for all surveillance testing requirement The program defined responsibilities for the evaluation of surveillance test data as well as the method of reporting deficiencies and malfunctions.
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The inspector also verified that similar controls were established for calibrating instruments used to verify safety functions, but not specifically identified in Technical Specifications (TS). The documents listed below were reviewed to determine if these criteria were incorporated into surveillance testing and calibration control program activities:
APM Section 3.2, Testing, Revision 22 SD 2.3.2 Control of Process Instrumentation Used as Test and Measure-ment Equipment, Revision 0 SD 3. Development and Conduct of the Preoperational Testing Program, Revision 4 SD 3.2.2 Development and Conduct of the Periodic Testing Program, Revisison 8 SD 4. Development, Approval, and Use of Station Procedures, Revision 16 Technical Specifications Interpretation Manual ,
Duke Power Company QA Manual for ASME Code Work, P.evision 7 Catawba Nuclear Station Pump and Valve Inservice Testing Program, Unit 1, Revision 10, and Unit 2, Revision 0 The following site QA surveillance reports were reviewed to identify problem areas within the surveillance testing and calibration program:
CN-85-02 Station Testing, Maintenance, Health Physics, Periodic Testing dated January 17, 1985 CN-85-10 Station Testing, Operations Testing dated February 26, 1985 CN-85-12 Station Testing, Independent Verification dated February 26, 1985 CN-85-13 Station Testing, Performance Testing dated March 26, 1985 CN-85-31 Station Testing, Maintenance dated October 14, 1985 Deficiencies identified in these reports included incorrect documentation and other types of administrative problems, but no major programatic breakdown Corrective action for these deficiencies has been expedien Corporate QA audits address many areas within specific plant groups. The following audits contained inspection of at least some aspect of surveil-lance testing and calibration program activities:
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NP-85-8 (CN) Technical Services and Operations Activities, June 3, 1985 NP-85-18 (CN) Technical Services and Administrative Services Activities, October 28, 1985 Significant deficiencies were not identified during these audit The surveillance testing program is generally administered by the Performance Test Group. This group keeps track of all tests required by TS, the Final Safety Analysis Report (FSAR), and the Inservice Inspection Program (ISI) programs for pumps and valves, as well as other requirements and commitments. A computerized master test schedule provides a complete status for each required test including procedure number, responsible group, test frequency, next scheduled date, latest permissable date, and previous performance dates. This is used as a scheduling device for Performance Chemistry and Health Physics. Other groups such as Instrument and Electric (I&E), Mechanical Maintenance and Operations utilize internal handwritten or computerized schedules. However, these groups continue to update the master surveillance schedule for historical documentation. The Performance Group periodically reviews the master schedule to ensure that :11 groups are performing surveillances as required. The inspector reviewed the master surveillance schedule as well as the internal schedules for I&E and Operations and did not find any anomalies or inconsistencie The surveillance test data base is very large and could not be fully inspected within the scope of this inspection. Therefore, a random sample of nine TS requirements was chosen to determine the completeness of the data base. The following TS requirements were selected for rev'ew:
TS Test Description Frequency 4.1.1. Reactor Makeup Water Pump 31 days Demonstrated Inoperable Table 4.3-1(8) Overpower AT Analog Channel 1 month Operational Test
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Table 4.3-1(18d) Reactor Trip System Interlocks 1 month 4.5. Upper Head Injection Accumulator 18 months
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4.5. ECCS System Operability, Valve, 18 months and Pump Operability 4.6.1. Primary Containment Integrity Conditional 4.7.10. Fire Suppression System 18 months Functional Test e
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4.7.10. Fire Suppression System Flow 3 years Test 4.9. Sourc,e Range Neutron Flux 1 week Monitor Analog Channel Operational Test Each test reviewed was scheduled at the correct frequency. Information provided by the data base indicated that these tests were being performed at required frequencies and in accordance with TS restrictions concerning interval extension Implementation of the surveillance testing program was assessed by reviewing the following randomly selected completed test data packages:
PT/0/A/4400/01D-00 Fire Pump A Operability Test (11/16/85,10/26/85)
PT/1/A/4200/10B-04 Residual Heat Removal Pump 1B Performance Test (9/21/85, 6/21/85, 3/26/85, 12/18/84, 10/14/84)
PT/1/A/4200/07B-04 Centrifugal Charging Pump 1B Performance (10/2/85,7/3/85)
IP/1/A/3222/81B-00 Steam Pressure Loop D Channel 4 Functional
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Test (4/30/84)
PT/1/A/4200/05A Safety Injection Pump 1A Performance Test (9/9/85, 6/8/85, 5/15/85, 1/28/85, 10/25/84, 8/3/84,4/29/84)
The above data packages were complete, properly reviewed, and consistent with procedural acceptance criteria. A programmatic scheduling problem with several of the above tests is addressed as an inspector followup ite The licensee is required to establish a calibration program for installed process instrumentation associated with safety-related systems, but which are not specified. in the TS as requiring calibratio TM s program was ,
recently centra'lized and delineated in SD 2.3.2 in response to an NRC violation. The inspector reviewed program documents and chose the following instruments at random to verify their inclusion in the program:
OYCPG 5280 Control Room Chilled Water Pump 1A Suction Pressure 0YCPG 5290 Control Room Chilled Water Pump 1A Discharge Pressure OYCP 5000 Control Room Chilled Water Pump 1A Recirculation Flow ICAPG 5020 Auxiliary Feedwater Pump 1A Suction Pressure ICAPG 5130 Auxiliary Feedwater Pump 1A Discharge Pressure ICAPG 5610 Auxiliary Feedwater Pump 1A Flow Rate IFDLT 5060 Diesel Generator 1A Fuel Oil Day Tank Level IFDLT 5200 Diesel Generator 18 Fuel Oil Day Tank Level
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The above instruments are scheduled for calibration every 18 months and were currently calibrated in accordance with this schedul Within_this area, one inspector followup item was identified. The inservice inspection program for pumps as delineated by ASME Section XI, Subsection IWP-3300, requires a quarterly performance test as well as an annual pump run test, during which the stable bearing temperature is determine Technical Specification 4.0.5.c allows the use of TS grace periods for ISI testing. The maximum time interval between two bearing temperature tests is 15 months and for three consecutive tests, it is three years, three months (3.25 times in three performances). The annual pump run test is presented as an optional requirement on the quarterly test procedure. Since there is no external scheduling mechanism, the technician must consult document control each time to determine whether the annual test is required. Based on interviews and a record review, the annual test is run only if it has not been performed during the past 12 months. Since the periodic test is performed quarterly, this policy insures that the 1.25 requirement is me However, the probability exists that the 3.25 requirement will not be met, if the test slips by an average of more than one month each year. The plant has not been operating long enough for this situation to have developed, but it is clear that this scheduling mechaninm will allow i Until ISI periodic testing schedules are modified to ensure compliance with grace period, this is identified as Inspector Followup Item 413/85-49-0 . tieasuring and Test Equipment Program (61724, 35745)
References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) Duke Power Company Topical Report Quality Assurance Program, DUKE-1-A, Amendment 9 (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Regulatory Guide 1.30, Quality Assurance Requirements
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for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (g) ANSI N45.2.4-1972, IEEE Standard. Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations
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The inspector reviewed the licensee M&TE program required by references (a)
through (g) to determine if the program had been established in accordance with regulatory requirements and industry guides and standards. The following criteria were used during this review to cetermine the overall acceptability of the established program:
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Responsibility was delegated and criteria established to assign and adjust calibration frequency for each type of M&T An. equipment inventory list identified all M&TE used on safety-related components, the calibration frequency and standards, and the calibration procedur Formal requirements existed for marking the latest calibration date on each piece of equipmen The program assured that each piece of equipment was calibrated on or before the date required or stored in a location separate from inservice M&T Written requirements. prohibit the use of M&TE which was not calibrated within the prescribed frequenc When M&TE was found out Jf calibration, the program required documented evaluations to determine the cause of the out-of-calibration condition and the acceptability of items previously teste The program assured that new M&TE was added to the inventory list and calibrated prior to us The documents listed below were reviewed to determine if these criteria had been incorporated into the M&TE program:
APM, Section 2.3, Control of Measuring and Test Equipment, Revision 22 APM, Section 5.1, Standards Laboratory, Revision 22 Quality Control Procedures Manual, Section QC B-1, Control of Measuring Equipment and Calibration and Test Standards, Revision 22 SD 2.3.1, Control of Measuring and Test Equipment, Revision 8 The following site QA surveillance reports were reviewed to gain a perspective of the program's current status:
CN-85-03 M&TE, I&E Section, February 5, 1985
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CN-85-16 M&TE, Mechanical Maintenance, April 12, 1985
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Deficiencies identified in these reports included improper segregation of items, loss of traceability, and failure to calibrate at the frequency prescribed by the program. Corrective action was complete and expedient on these item ~
The following corporate QA audit reports addressed the area of measuring and test equipment:
NP-85-8 (CN) Technical Services and Operations Activities dated June 3, 1985 NP-85-18 (CN) Technical Services and Administrative Services Activities These audits did not identify any major programmatic or implementation problems in the area of M&T Implementation of the M&TE control program was assessed by direct inspection
, in the I&E and Mechanical Maintenance M&TE shops. Most of the site's M&TE is located in these two shops which are shared equally between Units 1 and In the I&E shop, the following instruments were chosen at random to check storage, identification, and documentatio CN1AC 18247 Digital Thermometer CNIAC 18372 DC Shunt CNIAC 18542 Bourdon Gage CNIAC 18949 Digital Pressure Indicator
, CNIAC 19040 Digital Multimeter CNIAC 19043 Digi'.al Multimeter The above equipment was properly stored or checked out and had suitable documentation as to its calibration status and previous usag The following laboratory standards were reviewed for proper certification documentatio CNIAC 18057 Pneumatic Dead Waight Tester CNIAC 18092 Hydraulic Dead Weight Tester CNIAC 18095 Pneumatic Dead Weight Test CNIAC 18305 Fluke Calibration Meter CNIAC 18700 Fluke Calibration Meter Each of the above standards were certified as being traceable to national standards and were calibrated in accordance with the frequency prescribed by the M&TE progra The inspector researched various technical manuals associated with M&TE items stored in the lab to determine if calibration intervals prescribed by the program were in accordance with vendor recommendations. In each case, the licensee's program met or exceeded vendor recommendations.
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The following out-of-tolerance evaluations were reviewe Found Evaluation
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ID Description Out-of-Tolerance Completed
'CNIAC 18255 Function Generator 10/23/85 11/4/85
- CNIAC 18259 Rosemount 262 Calibrator 10/7/85 10/10/85 CNIAC 18286 Digital Multimeter 8/13/85 8/29/85
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CNIAC 18373 DC Shunt 1/19/85 8/8/85 CN1AC 18384- ' Test Gauge 10/15/85 10/21/85 The above out of-tolerance evaluations appeared to adequately address all safety issues associated with the out-of-tolerance condition, and exhibited a conservative approach to the overall evaluation proces The I&E calibration lab was recently moved from the i ssuing shop to a
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separate facility. This move appeared to be beneficial in that the new lab is quieter _and has a more controlled environmen In the Mechanical Maintenance M&TE calibration lab, the following equipment was chosen for review:
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CNMNT 18005 Torque Wrench CNMNT 18167 Hydraulic Wrench CNMNT 18202 Outside Micrometer
- CNMNT 18699 Dial Indicator CNMNT 18827 Optical Flat
The above instruments were either properly stored or well documented as to their locatio Calibration status was well tracked and consistent with attached calibration sticker Rejected equipment was segregated from in-use equipmen Equipment history cards were well maintained, and access to the lab was tightly controlle The following laboratory standards were reviewed for proper certification documentation:
CNMNT 18729 Gage Block Set
. CNMNT 18858 Gage Block Set CNMNT 18859 Dead Weight Tester CNMNT 18905-1 Dial-Indicator Tester Each of the above standards were certified as being, traceable to national standards and were calibrated in accordance with the frequency prescribed in the M&TE program.
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The following calibration procedures were reviewed:
MP/0/B/7650/10 Calibration of 0-60" Outside Micrometer, Change 0 MP/0/8/7650/14 Calibration of Long-Range Dial Indicators, Change 0 MP/0/B/7650/30 Calibration of Spring Scales, Change 1 MP/0/B/7650/50 Calibration of Raymond Hydraulic Wrenches, Change 1 Each of the above calibration procedures clearly stated prerequisite conditions, step-by-step calibration instructions, and criteria upon which to accept the equipment without adjustment. Each calibration procedure required a lab temperature of 68 2 F prior to instrument calibration and a four-hour temperature stabilization for M&TE prior to calibratio The lab temperature is actually maintained at 68 0.2 Within this a'rea, no violations or deviations were identifie . QA/QC Administration (35740)
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plar.ts (b) 10 CFR 50.54(a)(1), Conditions of Licenses (c) Duke Power Company Topical Report Quality Assurance Program, DUKE-1-A, Amendment 9 The inspector reviewed the licensee's QA/QC administration program as required by reference (a) through (c) to determine if activities were conducted in accordance with regulatory requirements, incastry gJides and standards, and Technical Specification The following criteria were used during this review:
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The licensee's QA program documents identify those structures, systems, components, documents, and activities to which the QA program applie Procedures and responsibilities have been established for making changes to these document Administrative controls have been established for QA/QC department procedure review, inspection, and auditin These controls assure review and approval prior to implementation, provide methods to make changes and revisions, and establish methods for distribution and obsolete procedure recal Responsibilities have been established to assure QA program review for overall effectivenes Administrative controls have been established to modify the QA program based on identified problem area . _ _ __ _
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The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedures for QA/QC administration activitie Quality Standards Manual for Structures, Systems, and Components dated 2/20/85 Administrative Policy Manual for Nuclear Stations, Revision 22 Station Directives Manual QA-100 Preparation and Issue of Quality Assurance Procedures, Rev. 8 QA-509 Preparation and Issue of Quality Control Procedures, Rev. 10 QA-210 Departmental Audit Procedure, Rev. 18 QA-230 Departmental Audit Scheduling and Followup, Rev. 10 Quality Control Procedures Manual Quality Assurance Manual for ASME Code Work Joint Utility Management Audit (JUMA) Title: JUMA Audit of Duke, Dated 10/18/85 The inspector reviewed the licensee's QA program on sit Within this area, no violations or deviations were identifie . Preoperational Testing Quality Assurance (35301)
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9, Section 17.2, Quality Assurance for Station Operation
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(c) ANSI N45.2.12-1977, Auditing of QA Program (d) Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants (e) ANSI N45.2.8-1975, QA Requirements for Installation, Inspection, and Testing T
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(f) Regulatory Guide 1.116, Quality Assurance Requirements for Installation, Inspections, and Testing of Mechanical Equipment and Systems (g) ANSI /ASME N45.2.23-1978, Qualification of Quality Assurance Audit Personnel for Nuclear Power Plants (h) Regulatory Guide 1.146, Qualification of QA Program, Audit Personnel (1) ANSI 18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (j) Regulalory Guide 1.33, Quality Assurance Program Requirements (Operations)
(k) ANSI 18.1-1971, Personnel Selection and Training (1) Regulatory Guide 1.8, Personnel Selection and Training The inspector reviewed the licensee's QA program required by references (a)
through (1) and to determine if the program had been developed in accordance with regulatory requirements, industry guides and standards, and Technical Specifications. The following criteria were used during this review:
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Procedures have been developed to conduct audits and surveillances of licensed activities.
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Responsible management personnel have been assigned authorities and responsibilities to implement the QA progra Management has knowledge of the QA program and understanding of their responsibilitie Minimum qualifications and training requirements have been developed for QA personne Systems for handling deficiencies have been established and are functionin The Quality Assurance Procedures listed below were reviewed to determine if the above criteria had been incorporated into the licensee's QA progra QA-100 Preparation and Issue of QA Procedures, Revision 8 QA-121 Nuclear Regulatory Commission Reporting Requirements, Revision 8 QA-122 Corrective Action Escalation Policy, Revision 2
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QA-130 Qualification and Training of Auditors, Revision 12' ,
QA-131 QA Training, Revision 7 QA-140 QA Inspector Training, Revision 11 QA-160 Performance of Corporate QA Audits, Revision 1 QCK-1 Control of Nonconforming Items, Revision 15 QCK-2 Work Stoppage, Revision 4 QA-210 Departmental Audit Procedure, Revision 18 QA-230 Departmental Audit Schedule and Followup, Revision 10 QA-500 Operation Division Surveillance Program, Revision 17 QA-501 Placing, Reviewing, and Verifying QA Requirements on Station Procedures, Revision 8 QA-502 Review and Approval of QC Inspection Records, Revision 5 QA-504 QA Records, Operations, Revision 14 QA-510 QA Review of Work Requests, Revision 6 QA-509 Preparation and Issue of QC Procedures, Revision 10 The audit and surveillance reports listed in paragraph 16 were examined to determine if these audit activities had been planned, scheduled, and implemented as required by the licensee's procedures, regulatory require-ments, industry guides and standard Examination of the audits and surveillances listed in paragraph 16 identified that these reports had been condacted in accordance with a predetermined schedule and that approved aucit checklists were used by qualified persons, appropriately trained and independent. of direct
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responsibility for the activities which they were auditin It was also determined that audit findings were documented and transmitted to management and corrective measures either had been or were in the process of being initiated. The proposed corrective measures appeared adequate to rectify the identified deficiencie As identified by the licensee, the onsite surveillance group has 17 areas that they periodically examine and they had performed 33 surveillances of these areas in 1985. The Audit Department has performed six audits at Catawba in the production area in 1985 and they have plans to complete two additional audits prior to the end of this calendar yea .-_ . - _ _ . . =
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The inspector interviewed licensee management concerning the QA training program for personnel within the QA department. Licensee management stated that training is provided to QA department personnel on a mandatory basis in
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accordance with quality assurance procedures QA-131 and QA-140. The inspector interviewed QA department personnel to determine their under-standing of their responsibilities as applied to the preoperational and start-up test program. Additionally, the qualification and training records for 19 site QA/QC personnel were examine The QA personnel interviewed were knowledgeable in the subject areas and the qualification and training records appeared complet The inspector determined that the Test Engineering group on site has been assigned the responsibility for preoperational testing. At the time of this inspection, no preoperational testing was being co ducted; however, it was stated by the licensee that of the 195 identified preoperational tests,
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approximately 85 percent had been completed. The licensee stated that results from preoperational tests were reviewed by both Design Engineering and the Start-up Test group for acceptability, and that completed test records were maintained in Document Control. The following preoperational test packages were reviewed by the inspector:
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Identification N Subject
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- IP/2/A/3170/02 Hydrogen Mitigation System (EHM) BMU-IN
- and Functional Test of H Ignitors i
TP/2/B/1200/10 Primary Sampling System Functional Test j TP/2/8/1200/03F ESF 1.47 Bypass Identification System (EMA)
Actuation Logic Functional Test
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TP/2/A/1200/03B Upper Head Injection System Functional Test i
. TP/2/A/1350/27 120 VAC Essential Auxiliary Power System Functional Test
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TP/2/A/1550/03A New Fuel Assembly Handling Fixture Preoperational Test TP/2/A/1550/03B New Rod Control Clusters Handling Fixture Preoperational Test TP/2/A/1350/13 120 VAC Vital Instrumentation and Control Power System Preoperational Test
'; TP/2/A/1350/12A 600V Essential Auxiliary Power System Preoperational Test These preoperational test packages appeared complete and documented the test results, signoffs, and acceptance criteri I
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Within this area, no violations or deviations were identified.
16. QA for Start-up Test Program (35501)
References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9, Section 17.2, Quality
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Asrurance for Station Operation (c) Regulatory Guide 1.33 Quality Assurance Program Requirements (Operation)
(d) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (e) Regulatory Guide 1.68 Initial Test Program for Water Cooled Nuclear Power Plant
'The inspector reviewed the licensee quality assurance program for start-up testing required by references (a) through (e) to determine if activities are in conformance with regulatory requirements, commitments in the
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application, and industry guide and standards. The following criteria were used during this review:
Requirements have been established and procedures or checklists developed for inspection of the following activ: ties or a regular basis by the onsite Quality Assurance organization:
Conduct of testing; Tracking of test deficiencies; Test documentation; and Control of measuring and test equipment.
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The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee QA program for the startup testin Catawba FSAR, Section 14.0, Initial Test and Operation
QA-130 Qualifications and Training of Auditors, Revision 12 QA-131 QA Training, Revision 7 QA-150 Trend Analysis, Revision 5 QA-160 Performance of Corporate QA Audits, Revision 1 QA-500 Operations Division Surveillance Program, Revision 17
,- _ _ .__ _ _ _ _ _ . _ _ __ QA-502 Evaluating and Approving QC Inspection Records, Revision 5 QA-509 Preparation and Issue of Quality Co'ntrol Procedures, Revision
-The inspector interviewed licensee QA personnel to deter. ine the extent of surveillance activities conducted during preoperational testing as well as the QA program to be implemented during the start-up test progra Procedure QA-500 delineates the reporting requirements and conduct to be used for performing QA department surveillance during station operatio This procedure is generic in that it addresses surveillances of various plant activities, including station testing, and is the controlling document for performance of surveillance by QA personnel. The inspector reviewed the surveillance schedule prepared for conducting surveillance of statio testing and selected the following packages for detailed review:
Survetilance Number Subject CN-84-51 Station Modifications, Documentation, and Approval CN-84-63 Station Modifications, Retest and/or Functional Verification CN-85-19 Station Modifications, Documentation and Approval CN-85-03 Measuring and Test Equipment, Instru-menti. tion and Electrical CN-85-16 Measuring and Testing Equipment, Mechanical Maintenance CN-85-02 Station Testing, Maintenance, HP, ,
and Periodic Testing CN-85-10 Operations Testing CN-85-12 Independent Verification
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CN-85-13 Performance Testing _
CN-85-31 Station Testing / Maintenance CN-85-05 Operations, Independent Verification CN-85-07 Tour Surveillance CN-85-09 Equipment Status, Tagging CN-85-14 RO/SRO Observation Training
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Surveillance Number Subject (Continued)
CN-85-17 Procedure Administration CN-85-23 Equipment Status The inspector determined from a review of the above surveillance packages that licensee QA personnel performed surveillances of preoperational and functional tests of various QA Condition 1, 2, and 3 systems during the 1984-85 time perio In addition to the above listed surveillances, the following audits of the test program were reviewed to assure that they were performed in accordance with the QA program procedures and requirements:
-QA Audit Number Subject CD-84-4 (SP) Concrete Anchor Program CD-84-10 (CN) Civil and Electrical Activities CD-84-13 (CN) Flush, Hydro, and Systems Turnover CD-84-16 (CN) Civil and Instrumentation NP-85-18 (CN) Technical Services and Administration Service Activities (Preoperational Testing)
The inspector determined that these audits appeared adequate in that they had been planned, checklists were utilized, findings were documented and transmitted to management, and corrective measures either had been or were in the process of being initiated. The proposed corrective measures appeared adequate to rectify the identified deficiencie As stated by the licensee, the start-up test program is being tracked by the Integrated Scheduling group located onsite. This group's function is to schedule and track the turnover of systems and components from construction through turnover to operation Subsequent to system turnover to operations, this group will be utilized to schedule station maintenance and modifications for future outages. As stated by the licensee, all systems have been turned over or have been offered, provisionally, for turnover. In order to determine the adequacy of the licensee's start-up program, the inspector reviewed the following turnover packages:
Turnover Package N Title 2NR01 (Final) NR-Boron Thermal Regeneration System 2EPL-T-1 (Final) EPL-125 VDC Vital Instrumentation and Control Power
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Turnover Package N Title
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2WE-1 (Final) WE-Equipment Decontamination 2NM-T-2 (Provisional) 2NM-Nuclear Sampling System These system turnover packages appeared complete and adequately documented the relative system status and operabilit Within this area, no violations or deviations were identifie ;
1 Licensee Action on Previously Identified Inspection Findings (92701)
. (Closed)' Inspector Followup Item 413/85-19-01: Environmental Controls for
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Calibration of M&TE in the I&E Shop Procedure IP/0/B/3860/01, Fluke 8600A Digital Digital Multimeter ,
Calibration, was revised on June 27, 1985, to require prerequisite
, calibration conditions of 235C and less than 80 percent relative humidit The inspecter discussed this item with the lab technician who was aware of the requirement and demonstrated how the readings are take (Closed) Inspector Followup Item 413/85-19-02: Promptness of Evaluations of
Out-of-Tolerance M&TE
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Station Directive 2.3.1, Section 3.7, was amended August 8,1985, to state that when out-of-tolerance M&TE has been used on safety-related equipment, use, s must be notified within four working days after which they have seven working days to complete the evaluation. A survey of recent evaluations identified that these new time constraints are being followed.
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