ML19336A642

Responds to NRC 800718 Ltr Re Violations Noted in IE Insp Repts 50-369/80-08,50-370/80-05,50-413/80-09,50-414/80-09, 50-491/80-07,50-492/80-06 & 50-493/80-06.Corrective Actions: Records Storage Facility Constructed

ML19336A642
Person / Time
Site:	Mcguire, Catawba, McGuire, Cherokee
Issue date:	08/15/1980
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19336A640	List: ML19336A642
References
NUDOCS 8010300385
Download: ML19336A642 (7)

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bS DUKE POWER COMPANY '

PowEn BUII.DINO h 422 Socin Cncacu ST[tEl ' JB1.OTTE, N. C. 28242

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W ILLI AM O. PA R M ER J R.

%CF P#tStCENT , TtitPMONE; Anta 704 STt*M P#0DvCYtose j 373-4063

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August 15, 1980 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Cocmission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:VLB 50-413/80-09, 50-369/80-08, 50-491/80-02 50-414/80-09, 50-370/80-05, 50-492/80-06 50-493/80-06

Dear Mr. O'Reilly:

Please find attached a response to the infractions which were identified in the above referenced inspection report. Duke Power Company does not consider any information contained in this inspection report to be proprietary. j l

Very truly yours, .

p y (

William O. Parker, Jr. h7 RWO:vr Attachment cc: NRC Catawba Resident Inspector I

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DUKE POWER COMPANY McGuire Nuclear Station I and 2 Catawba Nuclear Station 1 and 2 Cherokee Nuclear Station 1, 2 and 3 Response to Infraction 369/80-08-01, 370/80-05-01, 413, 414/80-09-01, 491/80-07-01, 492, 493/80-06-01.

" Temporary Record Storage Facilities - Fire Protection" Infraction:

As required by 10 CFR 50, Appendix B, Criterion XVII, and as implemented by Duke Power Company Topical Report Section 17.1.17.4 which states: " Record storage facilities are constructed, located, and secured in accordance with ANSI N45.2.9."

Contrary to the above, temporary record storage facilities in the Engineering and Services Division and Design Engineering Department fail to meet the fire protection requirements of ANSI N45.2.9-1974, Paragraph 5.6.

Response

Permanent records storage facilities for Design Engineering are constructed, located and secured in accordance with ANSI N45.2.9 temporary record storage facilities in Design Engineering are not meant to meet the fire protection requirement of ANSI N45.2.9-1974, Paragraph 5.6. Until that time when the design quality assurance records are collected, indexed and stored in the permanent records storage facility, we will continue to duplicate records as a satisfactory alternative to the establishing of a temporary record storage facility which would meet the r?quirements of ANSI N45.2.9. Design calculations will be maintained in work areas until related calculations are completed.

Then the calculations will be transferred to General Services for storage in the permanent storage facility. All design quality assurance records for a given unit will be in the permanent storage facility not later than six months following receipt of the operating license for that unit.

Records temporarily stored by Quality Assurance, Engineering and Services are supplier records and in the event of their destruction, could be duplicated ty the suppliers. In addition, the QA Department will continue to send these records to permar.ent storage facilities at the plant site will in advance of plant operation.

Response to Infraction 369/80-08-02, 370/80-05-02, 413, 414/80-09-02, 491/80-07-02, )

492,* 493/80-06-02. l

" Procedures Implementing ANSI N45.2.9 for the Corporate Records Vault" Infraction:

1 As required by 10 CFR 50, Appendix B, Criterion V, and as implemented by Duke Power Company Topical Report Section 17.1.5 which states in part: " Activities i affecting quality shall be p.escribed by ... procedures ... and shall be

, I accomplished in accordance with instructions, procedures ..." In Table 17.0-1 of Duke Power Company Topical Report, Duke Power Company has committed to implementing Regulatory Guide 1.88, Revision 2, which endorses ANSI N45.2.9. ANSI N45.2.9, Paragraph 2.1 requires that the quality assurance records system shall be defined, implemented and enforced in accordance with written procedures, instructions and other documentation.

Contrary to the above, no departmental procedures have been developed for the control and retention of records as required by ANSI N45.2.9-1974.

Response

Contrary to the stated infraction, Duke Power does have in-place departmental procedures for the control and retention of records. In fact, the existence of the procedure is referenced on pages 20, 21, and 22 of the audit report.

In point of fact, the existing facilities (i.e., the Corporate Records Vault) meet all of the requirements of ANSI N45.2.9. However, the existing acknowledged procedures fail to require or take credit for this fact. This procedure will be revised by November 1, 1980, to procedurally implement all requirements of N45.2.9 including receipt of records, preservation, and facility requirements. This action will preclude any further indications of noncompliance.

Response to Infraction 369/80-08-03, 370/80-05-03, 413, 414/80-09-03, .

491/80-07-03, 492, 493/80-06-03

" Corporate System of Audits of All Aspects of the QA Program" Infraction:

i As required by 10 CFR 50, Appendix B, Criterion XVIII, and as implemented by Duke Power Company Topical Report Section 17.1.18 which states in part "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program." Duke Power Company Topical Report Table 17.0-1, states that the program conforms to ANSI N45.2.12, Draf t 3, Revision 4, dated February 1974. ANSI N45.2.12, Draft 3, Revision 4 dated February 1974, Paragraph 3.4.2 requires that " Applicable elements of the quality assurance program shall be audited at least annually".

Contrary to the above, the following examples of failure to meet the audit requirements were identified:

1. A comprehensive system of audits has not been developed to assure coverage for all aspects of the QA program on an annual basis.

2. Audits of the minimum requirements specified by ANSI N45.2.9 Paragraph 5.7 have not been performed.

Response

A review of the existing schedule was made to assure all aspects of the Duke QA Program had either been audited or scheduled to be audited on an annual basis. Although we feel the present program is adequate, we have made revisions to now require the Audit Division to further document the system in an effort

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to eliminate further misunderstanding. These procedures were issued 7/17/80.

Response to Infraction 491/80-07-06, 492, 493/80-06-06 "Use of Curing Compound on Construction Joints" Infraction:

As required by 10 CFR 50, Criterion V, Appendix B, and as implemented by Duke Power Company Topical Report Section17.1.5 which states in part:

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, ... and shall be accomplished in accordance with these instructions, procedures, ..." Cherokee specification P815-1109.00-00-0001 requires concrete to be cured in accordance with the requirements of Chapter 12 of ACI 301-72. Paragraph 12.2.1.7 of ACI 301-72 specifies that curing compound shall not be used on any surface which additional con-crete is to be bonded, unless it is proven that the curing compound will not prevent bond, or unless the curing compound is removed.

Contrary to the above, curing compound was used on construction joints at Cherokee project without performance of adequate testing to demonstrate that during compound would not affect bond. The curing compound was not removed.

Response :

The design methods used to transfer shear at construction joints do not take i credit for bond as a measure of shear or tensile resistance. Where shear transfer is required in the Auxiliary and Reactor Buildng structures, the shear friction method has been employed in accordance with Section 11.15 of ACI 318-71, " Building Code Requirements for Reinforced Concrete." This method requires only a specified roughness and area of reinforcing steel to be provided at the joint for fresh concrete placed against hardened concrete.

These requirements have been specified on Duke construction drawings as appropriate for design conditions. In other safety related yard structures both shear friction and shear key methods have been employed, neither of which depend on bond for 'ser tensile or shear resistance. The requirements for shear transfer hav. 'larly been specified on the Duke construction drawings for these structures as appropriate for design conditions.

Duke Specification P81S-1109.00-00-0001, " Specification for Concrete for Category I Structures," adopted the provisions of Chapter 12 of ACI 301-72,

" Specifications for Structural Concrete for Buildings," for Cie curing of concrete. In doing so the specification failed to clarify our position on the requirements of paragraph 12.2.1.7 concerning the use of curing compounds on surfaces to which concrete or other materials are to be bonded. Section 5.4 of Duke's specification requires that joints not be bonded in accordance with Section 8.5 of ACI 301-72 except as specified on the drawings. Our intent is to specify on the drawings the joints which require bond and the method which sheuld be used to achieve bond. Since bond has not been a design factor for shear transfer in joints to date, the reference to bond requirements in ACI 301 paragraph 12.2.1.7 is not applicable.

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We are presently engaged in rekiewing the design calculations fer all safety related concrete structures to' ensure that design requirements for shear transfer have been met at all construction joints. We have also discontinued the use of curing compounds on joint surfaces to accommodate a revised method of providing joint roughness. Construction joints are currently cured by absorptive fabrics kept continuously wet. To avoid further question of whether a noncompliance does or does not exist, Specification P81S-1109.00-00-0001 is being revised to clarify and address provisions which will be required when bond is required in consturction joints. This specification revision will be issued and ou* review of design calculations will be completed by October 1, 1980.

Response to Infraction 369/80-08-06, 370/80-05-06, 413,~414/80-09-06, 491/80-07-07, 492, 493/80-06-07

" Errors /0mmissions in Civil Design Calculations" Infraction:

As required by 10 CFR 50, Appendix B, Criterion V, and as implemented by Duke Power Company Topical Report, Section 17.1.5 which states in part: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, ... and shall be accomplished in accordance with these instructions, procedures ..." Paragraph 1.1.9 of Design Engineering Procedure PR-101 requires complete presentation of the calculation such that anyone appropriate qualified could review the calculation. Paragraph 2.2.1 of Procedures PR-101 requires the checker to review data and design method used and to check the calculation step by step. Paragraph 2.3 of Procedure PR-101 requires the approver to sign and date the calculation certification page.

Contrary to the above, the following examples of failure to follow procedure were identified:

1. In civil design calculation number CKC 1112.12-02, (design of Cherokee NSW electrical equipment building) the concrete and reinforcing steel strength used in design were not documented in the calculation. The calculation can not be reviewed without this information.

2. In civil design calculation number MCC-1112.06-00-0004 (design of McGuire reactor refueling water storage tank missile wall), design shear values for walls 8 and 7 and 9 were transposed. This error was not detected by the checker.

3. In civil design calculation number P81C-1144.03-17 (design of Cherokee  ;

primary shield wall) an incorrect value was used for the coefficient of  !

friction in computation of shear friction reinforcement. This error was not detected by the checker.

4. The certification page for Revision 2 to calculation number P81C-1144.03-17 was not signed by the approver.

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_ Response:

Calculations CKC 1112.12-02, MCC 1112.06-00-0004 and P81C-1144.03-17 have been revised to correct deficiencies listed. Individuals performing the checking and approving of calculations will receive additional training in PR-101, Engineering Calculations. The additional training will be completed by October 1, 1980.

Response to Infraction 369/80-08-07, 370/80-05-07, 413, 414/80-09-07, 491/80-07-08, 492, 493/80-06-08 "Nonconformance Procedures" Infraction:

As required by 10 CFR 50, Appendix B, Criterion III, and as implemented by the Duke Power Company Topical Report Section 17.1.3 which requires control of the design process. Duke Power Company Topical Report Table 17.0-1, states that the program conforms, with clarification relative to immediate super-visor performing verification, to Regulatory Guide 1.64 Rev. (2) which endorses ANSI N45.2.11-1974. Section 4.3, 4.4 and 4.5 of ANSI N45.2.11-1974, as amended by Regulatory Guide 1.64, Rev. 2, 1976, Paragraph C.4, requires that procedures be established to document nonconformances with procedures for the preparation and control of drawings, specifications, and other design documents during the design process.

Contrary to the above, the Engineering Design Department QA program does not contain procedures addressing Engineering Design activities which will assure that identified noncompliances with procedures for the preparation and control of dracings, specifications and other design documents will be docu-mented, evaluated and appropriate corrective action taken.

Response

Currently, there are procedural changes under review in the Design Engineering Department formances. and the QA Department which are intended to cover design noncon-Review and ultimate reissuance of revised procedures will be implemented on or before November 1, 1980. l I

I Response to Infraction 413, 414/80-09-08

" Cable Termination Sheets" i

Infraction: i As required by 10 CFR 50, Appendix B, Criterion V, and as implemented by Topical Report, Duke 1-A, Section 17.1.5 which states in part: " Activities affecting -

I quality shall be prescribed by documented instructions, procedures, ... and shall be accomplished in accordance with these instructions, procedures ...". i Duke Power Company Design Engineering Department QA Procedure EPR-130, RI, *,,4 entitled " Electrical Division Special Drawings" requires preparation of cable ,

termination sheets to show cable terminations by color code for each cable and 24 4 provides a cable termination sheet example in Enclosure 7.  !

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( 4 Contrary to the above:

1. Cable termination sheets for cables 1*EPC 511, 512 and 513 did not show

cable teminations to 4160V panel 1 ETA or to diesel generator No. lA.

The cable teminations were shows as " SPARE".

2. Cable temination sheets for cables 1*EPC 511, 512 and 513 were not per the enclosure 7 form authori::ed by the procedure.

Response

l The cable temination sheets for the power cables identified in the inspection report will be deleted. In order to prevent a recurrence of this situation,

{ QA Procedure EPR-130 is Eting revised to clarify and accurately describe the proper u1e and purpose of cable teminations sheets. All corrective actions will ae completed by September 30, 1980.

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