IR 05000413/1986045

Insp Repts 50-413/86-45 & 50-414/86-48 on 861027-31. Violations Noted:Failure to Use Calibr Instrumentation for Tech Spec Required Surveillance & Failure to Provide Adequate Procedure for Nuclear Svc Water Valve Verification

ML20215F686
Person / Time
Site:	Catawba
Issue date:	12/11/1986
From:	Belisle G, Moore L, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F655	List: IR 05000413/1986045 ML20215F651 ML20215F673
References
50-413-86-45, 50-414-86-48, NUDOCS 8612240029
Download: ML20215F686 (15)

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an aseo ONITED STATES .

'o NUCLEAR REGULATORY COMMISSION .

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j REGION ll 101 MARIETTA STREET.N.W.

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Report Nos.: 50-413/86-45 and 50-414/86-48 Licensee: Duke Power Company

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422 South Church Street Charlotte, NC 28242

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Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Conduc ed: Optober 27-31, 1986 Inspectors: / m" n /J / /Y-M. X.~ Scott

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[ Date Signed h

L. R. Moore

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/%]H/bL Dat'e signed Accompanying Personnel: M. C. Shannon Approved by: 'O _ d g /J[h G. AT Belisle,"$betion Chief ~Date Signed Quality Assurance Programs Section Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted in the areas of document control, records, surveillance testing, and audit Results: Two violations were identified - failure to use calibrated instru-mentation for a Technical Specification (TS) required surveillance, and failure to provide an adequate procedure for the nuclear service water valve verifica-tio PDR ADUK 0500

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i REPORT DETAILS Persons Contacted Licensee Employees

• A. Allom, Senior Quality Control (QC) Supervisor

• G. Barrett, Training Supervisor

• Beaver, Performance Engineer G. Bell, Quality Assurance (QA) Supervisor, General Office (GO)

• W. Bradley, QA Surveillance Supervisor S. Cooper, Operations Procedure Supervisor

• J. Cox, Technical Service Superintendent i J. Effinger, QA Supervisor (GO) l C. Gregory, Instrument and Electrical (I&E) Support Engineer

• J. Hampton, Plant Manager

• C. Hartzell, Compliance Supervisor

• D. Jennings, QA Auditor, G0

• G. Johnston, Medical Sections Manager, G0

• J. Kinard, Construction / Maintenance Department (CMD) Engineer

• J. Lanning, Administrative Coordinator S Ledford, QC Supervisor P. Leroy, Compliance Engineer

• McCollough, Mechanical Maintenance Engineer J. Munn, QA Surveillance Technician

• F. Schiffley, Licensing Engineer D. Simpson, Compliance Engineer C. Skinner, Operations Shift Supervisor

• G. Smith, Superintendent of Maintenance

• J. Stackley, I&E Engineer Z. Taylor, Performance Monitoring Test Engineer

• J. Vigor, CMD Engineer

• J. Willis, QA Manager Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personne NRC Resident Inspectors

• M. Lesser

• K. Van Doorn

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 31, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license '

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Violation, Failure to Use Calibrated Instrumentation for a Technical Specification Required Surveillance, paragraph Violation, Failure to Provide an Adequate Procedure for the Nuclear Service Water Valve Verification, paragraph Unresolved Item, Variation in Effective Full Power Day (EFPD) 31 Day l Surveillance Data, paragraph '

Inspector Followup Item, Inadequate Storage of QA Records, paragraph Inspector Followup Item, Unresolved Item Resolution, paragraph Inspector Followup Item, Surveillance Findings Corrective Action, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items *

An Unresolved item was identified and addressed in paragraph . Document Control (35742, 39702)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (c) Duke 1-A, Duke Power Company Topical Report Quality Assurance Program, Amendment 9 (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

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• 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 W

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(f) Regulatory Guide 1.88, Collection,' Storage, and Mainten-ance of Nuclear Power Plant Quality. Assurance Records (g) ANSI N45.2.9-1974,- Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants

The inspector reviewed the licensee's document control program required by references (a) _through (g) to determine if the program had been. estabitshed in accordance with regulatory requirements, industry guides and standards, and technical specifications. The following criteria were used during this-review to determine the overall acceptability of the established program:

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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:

Administrative Policy Manual (APM) 2.1, Document Control, Revision 8 APM Administrative Instructions for Permanent Station Procedures, Revision 23 QA-100 Preparation and Issue of QA Procedures, Revision 9 QA-107 Temporary Procedure Changes, Revision 2 QA-501 Placing, Reviewing, and Verifying QA Requirements on Station Procedures, Revision 8 SD 2.1.5 Drawing Distribution and Control, Revision 25 SD 4.2.1 Development, Approval and Use of Station Procedures, Revision 22 The inspector reviewed document control surveillance reports performed since the previous NRC inspection in this area. These surveillance reports identified one substantial weakness in the document control area related to vendor manual control. The inspectors review of vendor manuals identified that some field manuals had not incorporated recent revisions, although manual revisions were accessible to those personnel whose job function would require use of these manuals. Vendor manual control had been identified as a problem throughout the Duke Power system. The licensee has assigned a

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task force to review vendor manuals and update these on a page by page basis. This effort, The Vendor Manual Upgrade Program, was being performed at each site. Currently, the task force was assigned to Oconee Nuclear Station. The inspector reviewed a letter dated September 22,1986, File

, Number CN-114.89, from the Catawba Station Manager which stated that the

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upgrade program at Catawba was to begin in July 1987.

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contained the latest revision:

Control Room Drawings: CN 2595-1.0

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CN 2593-1.2

! CN 2609- CN 1200- CN 1200-11.1 l CN 1499-WL 36

CN 1499-WN1 l

Performance Drawings: CNEE 0238-01.75 CNEE 0240-01.04 CNEE 0129-08.03-05 CNEE 0156-02.26 l CNEE 0165-01.18 i CNEE 0166-01.49

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! Mechanical Maintenance Drawings: CN 2605-3.2 I CN 2609-1.0 l CN 2609-2.0

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CN 2609- CN 2680- CN 1570- CN 1573- Operations Development Drawings: CN 1558- CN 1562-1.0 l CN 2593-1.0 l CN 2601-1.0 l CN 2593- I&E Drawings: CNEE 0138-01.01-01

. CNEE 0138-01.19

! CNEE 0138-01.23 l CNEE 0118-01.01 l CNEE 0120-02.01-01 Procedures: IP OB 3120 023 IP OB 3181 006 IP 2A 3030 007 0 IP 2A 3173 002 A MP OA 7200 011 MP 2A 7150 047 l

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MP 2A 7150 059-MP 1A 7150 042 g OP OB 6350 011 OP 1A 6100 001 -t OP 2A 6100 004 OP 2A 6250 002 OP 2A 6400 005 PT 0A 4350 008 A PT 1A 4200 002 G PT 2A 4200 018 PT 2A 4200 041 A~

TP 2A 1100 002 A s Discrepancies identified by the inspector were minor and appeared to be o isolated cases, not indicative of program weaknesses. The document control f ;.

program and implementation of these controls appeared adequat i

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Within this area, no violations or deviations were identifie . Records (35748, 39701)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants -

(c) Duke Power Company Topical Report Quality *

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Program, Duke 1-A, Amendment 9 (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 1.88, Collection Storage and Mainten-ance of Quality Assurance Records for Nuclear Power Plants (g) ANSI N45.2.9, Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear .

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Power Plants The inspector reviewed the licensee's administrative controls for records required by references (a) through (g) to determine if administrative i controls were in accordance with regulatory requirements, industry guides and standards, and Technical Specification The following criteria were i, used during the review to determine the overall acceptability of the established program:

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Requirements and provisions were established to maintain essential g quality assurance record '

q- Record storage controls were established in accordance with FSAR commitment c L i

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Record storage controls were described in writin;.

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Responsibilities were assi~gned in writing for overall management of the gc records progra '

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Provisions had been made to establish the retention periods for all

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Provisions had been made 't'o establish methods for filing supplemental

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information and disposing of superseded record ~

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Methods had been established for Yerifying that records received for storage were in agreement with any attendant transmittal document N The documents listed below were reviewed to determine if these criteria had

/ been incorporated into the licensee's administrative procedures for records i control: 's APM Records Management, Revision 21 QA-102 Storage of Special Processed Records, Revision 5 m QA-111 Trt.nsfer of QA Records, Revision 4 QA-116 Quality Assurance Records, Collection, Storage and Retention,

, Revision 9

QA-301 Managementof?NjectsQARecords, Revision 8 (

.1 QA-411 S0-2. Filing of QA Records for Purchased Items, Revision 12s Procedure for R cords Management, Revision 30

? The inspector examined recordt storage locations delineated in Station i Directive 2. QA surveillance CN-86-13 identified idadequacies at satellite file locations regarding receipt inspection of incoming records, lack of a written filing system, and inadequate metheds of maintaining a

, record of the records in the file. These findings appeared to be adequately

'; corrected. With one exception, all records examined were properly stored, readily retrievable, and complet '

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. Within this area, one inspector followup item was identifie Medical records, which constitute a verification of qualifications for various plant i personnel, were inadequately stored in a file cabinet located in a trailer on site. These records were previously stored in the same file cabinet within a building which permitted use of this file cabinet due to the

, characteristics of the structure. When these files were transferred to the trailer, no additional fire analysis was performe The present location 4 did not appear to meet storage requirements for National Fire Protection ( Agency (NFPA) Class I records. The licensee response to this finding was a g

memorandum dated October 31, 1986, file no. CN:100.00. This memorandum i stated that medical records for safety related worxers would be identified

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and adequate impact resistant storage acquired within 90 days. This corrective action would be adequate when completed. Until this action is complete this item shall remain open as Inspector Followup Item 86-45-04, Inadequate Storage of QA Record . Surveillance Testing and Calibration Control (61725, 35745B);

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References: (a) 10 CFR 50.55a, Codes and Standards (b) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants -

(c) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(d) ASME,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components (e) ANSI N510-1975, Testing of Nuclear Air-Cleaning Systems (f) Technical Specifications, Sections 3, 4 and 6 The inspector reviewed the licensee's surveillance testing and calibration contro! program required by references (a) through (f) to determine if the the programs had been established in accordance with regulatory require-ments, industry guides and standards, and Technical Specifications. The following 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 Detailed procedures with appropriate acceptance criteria were approved for surveillance testing requirement The program defined responsibilities for the evaluation of surveillance test data as well as the method of reportic.g deficiencies and malfunc-tion Completed surveillances met the requirements of Technical Specifica-tions (TS).

The documents listed below were reviewed to verify that procedures were written and approved for completing TS Surveillances:

PT/1/A/4200/07A Centrifugal Charging Pump 1A Test, Change 22 PT/2/A 4200/07B Centrifugal Charging Pump 2B Test, Change 8

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PT/1/A/4200/10B Residual Heat Removal Pump 1B Performance Test, Change 25 PT/1/A/4200/05A Safety Injection Pump 1A Performance Test, 0- Change 25

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CP/0/A/8100/16 Chemistry Procedure for The Determination of Boron, Change 11 CP/0/A/8800/05 Chemistry Procedure for Recording and Management of Data, Change 58 IP/1/A/3143/01 Upper Head Injection System Level Transmitters and

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Isolation Valves, Change 17 PT/1/A/4260/10A Residual Heat Removal (RHR) Pump 1A Performance Test, Change 31

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IP/1/B/3222/07 Boric Acid Tank Temperature Loop TT-103 (NVTT

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5720), Change 7

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PT/1/A/4450/01A Annulus Ventilation Filter Train Performance Test, Change 3 PT/1/A/4450/03C Annulus Ventilation System Performance Test, Change 3

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IP/1/A/3240/04F NIS N35 -

Analog Channel Operational Test,

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Change 13 IP/1/A/3240/04J NIS N43 - Analog Channel Operational Test, Change 15

PT/1/A/4600/03B Quarterly Surveillance Items, Change 3 IP/0/A/3710/15 Batteries Periodic Inspection, Change 7 PT/1/A4400/02C Nuclear Service Water Valve Verification, Change 7 PT/1/A/4450/010 Containment Purge Filter Train Performance Test, Change 6 PT/1/A/4150/05 Core Power Distribution, Change 17 Catawba Nuclear Station Directive 3.22, Development and Conduct of the Periodic Testing Program, Revision 8 The following completed surveillances were reviewed for TS compliance:

PT/1/A/4200/07A Centrifugal Charging Pump 1A

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PT/1/A/4200/078 Centrifugal Charging Pump 1B PT/2/A/4200/07A Centrifugal Charging Pump 2A PT/2/A/4200/078 Centrifugal Charging Pump 2B PT/1/A/4200/10A RHR pump 1A PT/1/A/4200/10B RHR pump 1B PT/2/A/4200/10A RHR pump 2A PT/2/A/4200/10B RHR pump 2B PT/1/A/4200/05A Safety Injection Pump 1A PT/1/A/4200/05B Safety Injection Pump 1B ,

PT/1/A/4150/05 Core Power Distribution PT/1/A/4450/010 Containment Purge Filter Train Performance Test (Capacity + AP)

PT/1/A/4400/02C Nuclear Service Water Value Verification PT/1/A/4600/038 Quarterly Surveillance Items, Pressurizer Heaters, Unit 1 PT/2/A/4600/03B Quarterly Surveillance Items, Pressurizer Heaters, Unit 2 IP/1/A/3240/04F NIS N35 - Analog Channel Operational Test, Unit 1 IP/1/A/3240/04J NIS N43 - Analog Channel Operational Test, Unit 1 IP/2/A/3240/04F NIS N36 - Analog Char.nel Operational Test, Unit 2 IP/2/A/3240/04J NIS N43 - Analog Channel Operational Test, Unit 2

, IP/0/A/3710/15 Batteries Periodic Inspection

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(Weekly and Quarterly)

The above listed surveillances were reviewed for proper surveillance intervals, compliance to procedure, meeting acceptance criteria, adequate management review, and meeting TS requirements. The inspector also ques-tioned various members of the plant staff about specific surveillance and calibration program During the review of the quarterly surveillance of pressurizer heater capacity, the inspector noted that current values for an individual heater bank varied by more than 200 amperes from one reading to the next. The

. licensee could not explain this variation. However, all readings in this area met the acceptance criteria.

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Unit 1 and back to 1985 for Unit 2. No deficiencies were identified but the inspector noted that during the Unit 1 outage some pump tests were allowed ,

to slip towards the end of the 1.25 extensio l l

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The inspector noted that some surveillance test procedures do not include the time that the test was completed. This .becomes very important if the plant wishes to take credit for the time extension on shorter interval surveillances. An example of the 1.25 extension, for weekly surveillances,

- would be the one _ day and eighteen hours allowed extensio The exact time becomes critical if the plant exceeds the eighth day and wishes to take credit for the eighteen hour Within this area two-violations.and one unresolved item were identified and are discussed in the following paragraph Use of Non Calibrated . Instrumentation for Technical Specification Required Surveillance TS paragraph 4.9.4.2.D.1 states that the reactor building containment purge system shall be_ demonstrated operable at least once per 18 months by. verifying that the pressure drop across the combined hepa filters, carbon absorber banks, and prefilters is less than eight inches water gauge while operating the system at a low rate of 25,000 CFM 110% (both=

exhaust fans operating).

Procedure, PT/1/A/4450/010 Containment Purge Filter Train Performance Test, dated August 28, 1986, was performed to satisfy TS 4.9.4.2. The test data Section 10.2 Pressure Drop Across the Filters-U-Tube Manometer,-thus indicated that a U-Tube manometer would be used instead of the installed magnehelic (AP Detector). The magnehelic was used to perform this surveillance test. The inspector _ discussed this discrepancy with the performance engineers. .They were aware of the problem and had already modified the surveillance procedure to require use of the U-Tube manometer for the AP reading. They also stated that a plant modification request was generated to allow for connection of the manomete Further discussion with the performance engineer indicated that connection of the manometer would have taken too much time, so it was decided to use the process instrumentation for the test readin Through discussions with another performance Engineer, the inspector was informed that an accuracy check of the magnehelic was made using a U-Tube manometer, at a later dat The inspector contacted I&C personnel and verified that.the process instrumentation, magnehelic, used in the surveillance test was not included in the plant calibration progra The use of non calibrated process instrumentation for TS required surveillance is identified as violation 50-413/86-45-01, Failure to Use Calibrated Instrumentation for Technical Specification Required Surveillanc Inadequate Procedure for the Nuclear Service Water Valve Verification TS paragraph 4.7.4.a states that at least two nuclear service water loops shall be demonstrated operable at least once per 31 days by verifying that each valve (manual, power operated, or automatic)

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servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position. Six manual valves, in the seal water supply to the nuclear service water pumps, are not included in the monthly valve position verification surveill anc The inspector reviewed procedure PT/1/A/4400/02C, Change 7, and found that the following valves 1RN-C21, 1RN-C22, 1RN-21, 1RN-22, 1RN-23, and 1RN-25 are not included in the monthly valve surveillance. These valves are associated with filtering and supplying seal water and cooling water to the nuclear service water pumps and motors. The pump

. seal water ir.jection valves, located just prior to the pump seals, are included in the valve verification surveillance. The utility has recogrized the need for the seal water supply but not the need for the seal water syste The inspector discussed this discrepancy with plant staf They maintain that_ an operator verifies seal flow to the running pump twice a day and that this more than meets the surveillance requirements. The inspector maintained that if the standby pump (s) auto start with inadequate seal flow the pump seals, bearings and motor could be damage There are no alarms in the control room for inadequate seal flo The operations training manual, nuclear service water (RN) handout, on Page 31 of 78, REV 00/04-01-86/GLM, Section 2.2.0.3a' states that each RN essential header provides flow to a redundant set of safety related components and systems. The RN pump motor cooler, strainer, and pump seal injection are listed as essential header component The plant has already acknowledged the fact that this is a safety related system. Licensee oversite in not including these valves in the monthly valve verification surveillance is identified as violation 50-413/86-45-02 and 50-414/86-48-01, Failure to Provide Adequate Procedure for Nuclear Service Water Valve Verificatio (d) Variation in the Effective Full Power Day (EFPD) 31 Day Surveillance Data -

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TS paragraph 4.2.2.2.d.1.6 required that the surveillance to measure core power distribution be completed once per 31 EFP Completed surveillances reviewed by the inspector indicates that the EFPD value was not taken at the same time as the incore flux map and excore power level readings. This indicates that the EFPD value was not reliable for insuring the 31 EFPD surveillance is completed as required.

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The following data needs to be clarified by plant staff. On April 24, 1986, the recorded EFPD value was 265.8 EFPD, System Boron was 184 parts per million boron (PPMB), and plant power level was at 99.6% full power. The next recorded EFPD value taken on June 2,1986, was 296 EFPD, system boron was 75 PPMB and plant power level was at 100% full power. The total time between surveillances was 39 days. The boron burnout was 109 PPMB and would appear to indicate approximately 40 days of full power operation. There appears to be a discrepancy between boron reduction which is relatively linear for core burnup and total accumulated core burnup, which was stated to be 30.2 EFPD. The plant staff needs to document that during the time period from April 24, 1986 until June 2,1986, the total accumulated EFPD was only 30.2 EFPD as recorded. Until the plant staff documents the total EFPD for this period and the NRC reviews the documentation, this item is identified as Unresolved Item 413/86-45-03, Variation in the Effective Full Power Day (EFPD) 31 Day Surveillanc . Audits (35741, 40702)

References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, and Fuel Reprocessing Plants (b) Regulatory 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 (d) Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (e) ANSI N45.2.23-1978, Qualification of Quality Assurance 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 Plants (h) Technical Specifications, Section 6 (i) 10 CFR 50.54(a)(1), Conditions of Licenses (j) Duke Power Company Topical Report Quality Assurance Program, Duke-1-A, Amendment 9

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The above reference documents comprise the regulatory basis of the Catawba Quality Assurance (QA) audit program. The programmatic and some portions of the implementation aspects were examined in NRC Inspection Report No /85-49 and 50-414/85-50 dated January 10, 1985. The licensee stated that the upper and lower tier documents that implemented the QA Audit program had not been altered significantly since the issuance of the above inspection repor During the course of this inspection, the inspector examined the validity of the audit program's implementation using aspects of the above reference documents as criteri The following audits were reviewed by the inspector:

PS-86-1(PS) Scope: Production Support Department,-G0, issued July 2, 1986 NP-86-6(CN) Scope: Maintenance and On Site Transmission, issued April 8, 1986

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NP-85-18(CN) Scope: Technical Services and Administrative Services Activities, issued October 23, 1985 CM-86-1(ALL) Scope Nuclear Station Modification, issued July 15, 1986 NP-86-3(CN) Scope: Departmental Audit, issued February 17, 1986 NP-86-29(CN) Scope: Corrective Actions and Nuclear Station Modifi-cations, issued October 10, 1986 DE-86-3(GO) Scope: Design Engineering Department, Project Manage-ment Division, issued May 23, 1986 NOTES: CM = Duke Construction CN = Catawba Nuclear GO = General Office NP = Nuclear Production The above audit packages were reviewed to determine the following:

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technical merit of the check list

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the focus of the audit

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new issues reviewed

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NRC information notices were part of the audited area

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potential generic problems at other Duke sites were evaluated during Catawba audits

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audit deficiencies had appropriate corrective action

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audit unresolved items were adequately reviewed i

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Construction / Modification Department (CMD) has been in operation at Catawba in their present form for approximately six month Previously, CMD was Duke Construction and they had operated under different regulatory rules during the building of the plants. At the time of this inspection, CMD was to be operating under the site's Nuclear Production Procedure The inspector was told that CMD was proposing a separate set of procedures for their operatio Under the Duke audit program, unresolved items (UI) which are identified in audit reports may or may not be deficient conditions pending additional information and evaluation. The UI were tracked by site compliance but the audit program required no response from site groups which were involved with the UI. Some site groups would respond to the UI by sending followup information to compliance personnel who, in turn, would notify the corporate auditors that the item may be ready for closur The inspector investigated four VI to see whether or not the listed conditions were accurate, were deficiencies, required immediate action at the time of the corporate audit, and were being acted upon by site personnel. The investigation revealed the following:

UI 5 of audit NP-86-6 (CN) indicated undocumented grace period frequen-cies for preventive maintenance. There was no administrative procedure documenting the stated grace period of 50 percent. The Duke auditor had inspected to a portion of reference (g) and followed up on this aspect to the degree necessary. Region wide, the typical grace period or tolerance to a frequency is more in line with technical specifica-tion tolerance of 25 percent. As stated by site production personnel, administrative procedure would be changed to state a preventive maintenance performance toleranc VI 7 of audit NP-86-6(CN) indicated a problem following a weld proce-

- dure for socket welds. The same Duke auditor had previously identified difficulties with procedural adherence which resulted in a comment in an earlier audit. This audit finding escalated the finding to a U Both CMD and Nuclear Production were aware of the auditor's concern but had not taken action on the item; there appeared to be confusion between the groups as to who had action on the ite Site compliance personnel had assigned Nuclear Production action on the item but Nuclear Production thought that CMD had the action. CMD had addressed the issue in a memo when the item was at the comment level (no action taken to correct the procedure) but did not inform compliance of the memo; CMD was unaware of the UI. The Duke auditor's identification of the VI was timely with the additional research he performe The NRC inspector independently evaluated the QC inspection points which would prevent improper socket weld fitup and found that there was a high probability that QC would find the defective weld joints prior to finalizing the weld (QC had found 3 instances in the last two years).

The inspector discussed the issue with CMD and CMD was convinced that a procedural change was in order to aid the welders in fitup require-ments. There was a good likelihood that the Duke auditor would have obtained the fix with the U ,

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UI 8 of audit NP-86-6(CN) identified a concern -with a licensing commitment. The licensee had committed to perform TDI Diesel Generator Maintenance in operating license letters in 1984. As stated by the compliance / licensing group on site, the commitment to check diesel generator pedestal bearing oil level was inadvertently dropped from the final, accepted licensing letter and that the oil level check was not-procedurally described on site. Due to the VI, site personnel stated that the oil level check had been picked up in site procedures. Duke audit personnel are still investigating the ite UI 6 of audit NP-86-6(CN) identified some rigging problems on sit The problems were as follows:

CMD personnel rigged a 20 inch diameter flange off of a eight inch safety related pipe without any prior analysis for potential damag No site procedures were available to provide rigging instructions except a temporary shielding procedur A rigging review to be performed by site planner war not docu-mented as required by procedur It was stated by the licensee that prior to this inspection such rigging problems had been identified as a non conforming condition and evaluated via the site's corrective action system. This post lift evaluation did not occur in this instanc Although no analysis occurred, the Duke auditor who observed the lift and talked with site personnel about the parameters of the potentially deficient conditions did not choose to make the issue a deficienc According to site personnel, no evaluation of lift had been made since the event was made a U The procedure (MMP 1.0) that the planner used to perform the rigging review was interpreted by the planner that if he felt no rigging instructions were required, he did have to address it on the work request. CMD personnel, who were not required to get the work request changed when the job sequence was changed, opted to do the lift with riggin Site personnel had not corrected the procedure that the planner used to perform the rigging review nor had the site issued a rigging procedur The personnel involved with the actual work performance were not required to provide input during the planning phase of a proposed jo ,

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The compliance group had identified the planning grcup as the respon-sible section for resolving VI 6. Per disct.ssions with the planning group, it was thought - that mechanical maintenance had the actio Again, as with UI 7 (in light of no VI written response being required), attention to this VI had low priority (audit issued in April of 1986) and the action group was ill define Due to potential significance of the rigging problems in this licensee identified issue and the multiple actions required, this will be an inspector followup item. Until site personnel and Duke auditors evaluate the lift even" identified in the UI, the need for rigging procedures, and the need to change the manner in which rigging reviews are performed, this is identified as inspector followup item 50-413/

86-45-06 and 50-414/86-48-03, Unresolved Item Resolutio The inspector investigated how NRC Information Notices (IN) were handled by the licensee. The licensee had shted previously that ins were evaluated by the corporate architect / engineer. It was found that site compliance distributed ins to site groups for review. Catawba compliance had files on ins and site group responses which varied from little input to complete evaluations. . Recently issued ins, 86-72 and 86-77 (issued in August), were available with their evaluations. Duke auditors sampled ins during their audits. The depth of the evaluation of ins reviewed by site and corporate audit personnel varied from checking compliance files to reviewing evalua-tion The Duke audit group had not received IN 86-72 and 86-77. IN 86-77 dealt with Computer Program Error Report Handling that addressed computer program error in safety related applications. Without knowledge of IN 86-77 Duke auditors had investigated and were continuing to investigate Duke computer software program benchmarking (accuracy verification) that was being identified in audits. Computer program problems are still being investi-gated by Duke auditor One of the computer systems being evaluated by Duke auditors is the Operator Aid Computer (0AC). The OAC provided plant operations personnel with information on plant status, but this information was not to serve any safety related function. Duke Power Company's response to IE Bulletin 85-01 (letter from Mr. Tucker of Duke to Dr. Grace of the NRC dated February 25, 1986) indicated that modifications surrounding the auxiliary feedwater pumps were underwa Temperature monitoring of the piping near the pumps was stated to be carried out manually until modifications were~ complete which would allow monitoring by the OAC in the control room; this implied that the OAC would take on a safety related function. The inspector determined what means of piping temperature monitoring took place when the OAC was out-of-service. Although manual monitoring was not directly, procedurally addressed in the OAC out-of-service procedure which delineated recovery actions for certain automatic functions Lonitored by the OAC, the piping temperatures were manually monitored on log sheets (at the site, the sheets are called rounds). The log sheets require manual piping temperature monitoring when the OAC was not in operation. The log sheets are loosely

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described (each particular log sheet and the measured parameter were not in the instruction) proced' ally and the sheets were issued by the procedure writers in the operations group in lieu of document control. The inspector reviewed completed log sheets for the past several months up to the present outage and found feedwater piping temperature entries even when the OAC was in operation (conservative). During this inspection, which was an outage situation for both units, no feedwater piping log sheets could be found in the control room and one shift supervisor was unaware that the subject log sheet had been separated from the main body of log. sheets (a recent change).

All three dayshift operations personnel interviewed who routinely used the logs for recording the measurements were-aware of the change. Duke auditors are following up on computer related findings per audit report PS-86-1. The inspector did not followup on any other 0AC functions aside from feedwater temperatur Audit Report NP 86-3(CN) reviewed the Duke position on IE IN 85-71, Contain-ment Integrated Leak Rate Testing. The report stated the position taken by corporate personnel that differed from the IN position and the report made no comment on the position. Region II issued violation 50-369/86-16 and 50-370/86-16 regarding the leak rate testing and this violation is still under contentio A McGuire NRC Inspection Repert 50-369/85-31 and 50-370/85-33 contained an inspector followup item (IFI) on the corporate Prohibited Items List. The intent of the list was to prevent the procurement and use of defective components. The IFI was based on Duke Audit Report NP-84-20(MC). Due to the generic implications of the list, the inspector checked to see that the concern was identified to Catawba personne The problems with the list were identified in a Catawba audit report as a comment and, more impor-

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tantly, in a letter to the site (letter from G. W. Hallman, Manager of Nuclear Maintenance to all Duke sites maintenance superintendents dated September 12,1986). The letter indicated that a change to Nuclear Mainten-ance Administrative Manual was forthcoming that would require additional

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reviews against the prohibited item list. The acceptability of the proposed change is pending closure of the IFI and Duke audit report ite Startup audit reports were inspected separatel The findings regarding

these audit reports are documented in NRC Inspection Report Nos. 50-413/

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86-46 and 50-414/86-4 Duke audits of the Catawba design control program were partially complete at e the time of this inspection. The audits should be completed by the end of 198 The inspector did not specifically review the completed audit findings pending Duke audit completion and NRC inspection of the design control progra .

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Duke auditors did a vertical review of activities at the site and this I review program is supplemented by the surveillance program operated by site QA personnel.- ' As indicated by the Duke audits and this report, Duke auditors do observe some work activities at the site and the licensee did *

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state that this evolution would be expanded. QA surveillance monitored day to day work activities on a much more comprehensive scale. This surveill-ance program was audited by the corporate audit group. .The surveillance program is not required by regulation. The deficient conditions discovered .,

by the program are subject to regulatio Criterion XVI of reference (a) states as follows:

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Measures shall be ' established to assure that conditions adverse to quality, . such as failures, malfunctions,. deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures sha'l assure .that the cause of the condition is determined and corrective action taken to preclude .

repetition. The identification of the significant condition adverse to quality, - the cause of the condition, and the corrective action take '

.shall be documented and reported to appropriate-levels of managemen The key word in the. discussion above is "significant." The word implies a threshold level on findings that. require identification of root cause of a deficiency, method to preclude reoccurrence, and reporting to managemen P The -licensee has initiated a new system for reporting significant deficient  ;

or potentially deficient conditions which was called the Problem Investiga- i tion Report (PIR) system. . Site Directive 2.8.1 listed the determining criteria for initiating a PIR. This criteria provided a threshold in terms of significance of a finding for being entered into the system. The criteria was a positive step in reducing the grey area that is associated -

with the term "significant" in the above regulatio There are three categories of findings included in a surveillance repor The nonconforming item was a deficient condition having significanc Unless a nonconforming item was identified by a surveillance report, no PIR was generally issued. Other items that were reported by a surveillance were called uncorrected (UCC) or corrected conditions . The UCC may or may not be deficient conditions, but supposedly below the threshold level of signifi-canc The UCC were tracked (and uncorrected items corrected) by the QA Surveillance group but the substance of the UCC were not directly reported to management nor were the findings trende The following surveillance reports were reviewed by the inspector:

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CN-84-47 I&E Periodic Testing, October 1, 1984 CN-85-02 Maintenance Health Physic Periodic Testing, January 17, 1985

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CN-85-31 Maintenance Station Testing, October 14, 1985 CN-85-32 Maintenance Testing; General Testing, August 5, 1985 CN-84-42 Performance Testing, August 20,- 1984 CN-85-13 Performance Testing, March 26, 1985 CN-86-10 Performance Testing, February 24, 1984 CN-84-36 Operations Testing, August 14, 1984 CN-85-10 Operations Testing, February 26, 1985 CN-86-16 Operations Testing, April 16. 1986 Surveillance Report CN-86-32 contained two UCC that did not cause a PIR to be written. The UCC and the inspector's comments are as follows:

Uncorrected condition 2 acoressed problems with inspecting fasteners on pipe clamps and snubber pipe attachments. Section 10.0 of Procedure MP/0/A/7650/85 was explicit in requiring that insulation was to be removed to inspect the fasteners. Trades personnel did not remove insulation on the backside of the pipe clamps. A Corrective Action Request (outside of the PIR program) was written by QA. The corrective action consisted of the particular crews being cautioned, the work being reperformed and reverified by the trades, and a note was written on back of the work request involved indicating that the deficiency had occurred and the work crews had been cautione In this case, the error was not undetected due to the presence of the QA inspector observing part of the work. Management above the foreman level was not directly informed of the deficiency. The corrective action may result in no reoccurrence due to the explicit nature of the work instructio Corrected condition - addressed problems with a work request that had not been signed pria to commencing work. Trades personnel involved with the above visual inspection of the snubber fastener (and insula-tion removal) did not obtain a Shift Supervisor signature prior to l

wor The Shif t Supervisor had been telephoned as stated by the

licensee prior to work beginning. The QA surveil'ance personnel had

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the trades personnel have the work request marked "no" in the applic-able signature block by the t Ms foreman. The inspector reviewed the applicable procedure for fili j out the work request, MMP 1.0, Work Request Preparation. The procedure was unclear to the inspector as to who signed the " clearance for work to begin" block. The root cause for the problem may not have been addressed in the surveillance report.

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Per discussion with site planning, a change to MMP 1.0 was probably in

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Corrective action outside of or below the threshold of PIR system could

' receive less evaluation and management attention than is warranted. The five tests of 10 CFR part 2, Appendix C,Section V.A., would be applicable in this cas Pending review of the long term results of the above surveillance findings and review of ether corrective actions for surveill-

-ance reports this issue is identified as Inspector Followup Item 50-413/86-45-05 and 50-414/86-48-02, Surveillance Findings Corrective Actio .

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