ML20004E614

Ack Receipt of IE Insp Repts 50-413/81-02 & 50-414/81-02 on 810126-0206.No Proprietary Info.Corrective Actions: Procedures on Reportability Clarified.Personnel Retrained

ML20004E614
Person / Time
Site:	Catawba
Issue date:	05/13/1981
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20004E610	List: ML20004E614 ML20004E616
References
NUDOCS 8106120394
Download: ML20004E614 (13)

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ViCr Pe:SIO cas t May 13, 1981 reu~o c 4.c. ro.

s?c. p. coco,. 3 7 3-.C S 3 Mr. James P. O'Reilly, Director

! U. S. Nuclear Regulatory Commission

! Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:JC3 l 50-413/81-02 L

50-414/81-02

Dear Mr. O'Reilly:

Please find attached a. response to Infraction Nos. 413/81-02-02, 414/81-02-02, t

413-414/81-02-03, 413/81-02-04 and 413-414/81-02-05 as identified in the above referenced Inspection Report. Duke Power Company does not consider l any information contained in this inspection report to be proprietar/.

I declare under penalty of perjury, that the statements setforth herein are true and correct to the best of my knowledge.

Very truly yours,

[

William O. Parker, Jr.

RWO/djs Attachment i

cc: NRC Resident Inspector Catawba Nuclear Scation i

l 810612o3%

DUKE POWER COMPANY CATAWBA NUCLEAR STATION NOTICE OF VIOLATION (Paragraph A) l l

As a result of the inspection conducted on January 26 - February 6,1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 i (October 7,1980), the following violations were identified.

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A. 10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that identification of significant conditions adverse to quality be reported to the appropriate levels of manage-ment. Duke Power Company Topical Report, Section 17.1.16, the Engineering QA Program, contains procedures for resolving conditions adverse to quality. Design Engineering Department Procedure DP-220, Nonconforming Item Reports, Section 2.2, requires the responsible Engineer to evaluate the nonconformance to ascertain if it is re-portable to management under the provisions of Procedure PR-290, 1 Nuclear Regulatory Commission Reporting Requirements.

Contrary to the above, the measures established to assure that significant conditions adverse to quality are properly evaluated and reported to appropriate levels of management are not adequate.

l The responsible evaluating design engineer did not perfom an ade-I quate evaluation of Norconfoming Report Nos. 9755, 10665, 10684, 10721,10745,10752,10318 and 10852 (covering 13 defecthe 600V safety-related circuit breakers) in that no infonnation was forwarded to management for reportaoility evaluation.

This is a Severity Level IV Violation (Supplement II.D.2.) applicable to Unit 2 only.

RESPONSE

1). The alleged violation is denied for the following reasons.

2) The conditions reported on Non-conforming Item Reports 9755, 10665, 10684,10721,10745,10752,10818, and 10852 were properly evaluated and forwarded to management for reportability evaluation. Additional coments are also included on Non-confoming Item Report 10727.

a) Non-conforming Item 9755 on a 4160 volt switchgear breaker

! serial number (50465E-1-10225)for 2ETAl2 was found in. the..switchgear

! cubicle by the Transmission Department to rave a broken control contact block. The breakage was considered to be isolated field damage based on discussions between the responsible equipment engineer and site technical support engineer. A new block was purchased and installed on the breaker.

The reportability was again reviewed and verified on 10/28/80 with final technical approval and verification of non-report-ability on 10/29/80.

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b) Non-Conforming Items 10665,10684,10721,10727,10745, and 10818 issued on sir. 600 volts loadcenter breakers with cracked arcing contacts were received by Design Er.gineering Electrical Division on 1/29/81 and 2/2/81 (NCI 10818 only) and reviewed for reportability.

Potential Reportable Item CA-80-14 was issued to management on 2/3/81. The final determination of reportability was made on 2/10/81 and reported to NRC Region II on the same day.

Non-Confoming Item 10752 issued on one 600 volt loadcenter breaker with cracked are chute retainer molding was incorrectly included with the Non-confoming Items on cracked arcing contacts. This damage found by Transmission Department during initial inspection of the breaker was evaluated to be due to breaker handling during

long tem ' storage and general weakness of the breaker packaging.

The non-reportability was determined and documented on 3/6/81 with final technical approval and verification of non-reportability on 3/9/81 Non-Conforming Item 10852 issued on eight 600 volt loadcenter breakers for cracked arcing contacts, broken control contact blocks, and cracked arc chute was received by Design Engineering Electrical Division on 2/6/81. The cracked arcing contacts found on five additional breakers were evaluated as reportable and considered in the scope of Reportable Item CA-80-14. The broken control ccntact blocks found during the inspection for cracked arcing contacts were evaluated for reportability. It was determined that these broken

> control blocks were not a new reportable item and an evaluation was included in Report Number SD-50-413-414/81-02. The cracked arc chute was evaluated and detemined not reportable. The control block and arc chute breakage was evaluated to be due to breaker handling during long term storage and a general weakness of the breaker packaging.

3) It should be noted that the NRC Inspector reviewed these Non-confom-ing Item Reports (Except 9755) during the same period that Catawba QA was reviewing for assignment of resolution. Thus the appropriate reviewing authority, Design Engineering Electrical Division, had not had a chance to evaluate for reportability to management prior to the alleged violation being made by the NRC.

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Catawba Switchgear And Loadcenter Breaker Nonconformance Reports Catawba Originated Received Potential Reported 30 Day Notes NCI Senior Engr Review By Pwr Reportable To Report Number QA Review Equip Group Item NRC Issued To SRAL Division 9755 10-10-80 10-10-80 l 10-14-80 10-22-80 N/A N/A N/A i 10665 01-13-81 1 01-15-81 01-20-81 01-29-81 02-03-81 02-10-81 03-02-81 2 1

10684 01-15-81 l 01-15-81 ~

01-20-81 01 81 02-03-81 02-10-81 03-02-81 2 10721 01-16-81 01-16-81 01-20-81 01 81 02-03-81 02-10-81 03-02-81  ?

10727 01-19-81 01-19-81 01-22-81 01-29-81 02-03-81 02-10-81 03-02-31 2 10745 01-20-81 01-20-81 -

01-22-81 01 81 02-03-81 .02-10-81 03-02-81  !

10752 01-21-81 01-21-81 01 81 01-29-81 02-03-81 02-10-81 N/A 4 l

10818 01-26-81 01 81 x 01-26-81 02-02-81 02-03-81 02-10-81 03-02-81 2 10852 01-28-81 01-29-81 01-29-81 02-06-81 N/A 02-10-81 03-02-81 2,3 l

Catawba Switchgear And Loadcenter Breaker Nonconformance Reports Scope of Nonconformance Reports Catawba Number NCI Of Number Breakers 4160 Volt Switchgear 9755 1 1 Switchgear breaker with broken control contact block.

600 Volt loadcenter Breakers nreing Contact Arc

_ Contacts Blocks Chute Serial Number 10665 1 X (S) 50583-Kl-13-02078 10684 1 X(M) 50583-Kl-12-04078 10721 1 X(M) 58583H3-11-01224 10727 1 X (M) 50583H3-11-02224 10745 1 X'(M) 50583H1-12-01224 10752 1 X 50583k3-11-01078 10818 1 X (M) 50583H1-12-02224 10852 8 X (M) 50583H1 03224 X 50583Hl-11-01224 X (M) X 50583H1-ll-02224 X(M) X 50583K3-13-01078 X (M) X 50583H1-12-05224 X 50583193-12-01078 X 50583K3-11-02078 X (M) 50583H3-ll-01224 l M-movable arcing contact S-stationary arcing contact i

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.' l Catawba Switchgear and Loadcenter Nonconfonnance Reports Notes On Nonconformance Reports

l. NCT 9753 issued on a 4160 volt switchgear breaker l Serial Number 50465E-1-10226 with a cracked control contact block.  !

l Breakage was considered to be isolated field damage and not reportable. )

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2. NCI's 10684,10721,10727,10745, and 10818 were issued on cracked moving  !

arcing contacts for 600 volt loadcenter breakers.NCl 10665 was issued on :

a cracked stationary arcing contact for 600 volt loadcenter breaker. J These were reported to management on Potential Reportable Item Serial  !

Number CA-80-14 dated 02-03-81. This was determined reportable and  !

reported to NRC on 02-10-81.

3. NCI 10852 was issued on eight 600 volt loadcenter breakers with cracked l arcing contacts, bmken control contact blocks, and cracked are chute molding. The cracked arcing contacts found on five additional breakers were evaluated as reportable and considered in scope of Reportable Item CA-80-14 dated 02-03-81. It was detennined that these control blocks 1 were not a new reportable item and an evaluation was included in the  :

30-day Report Number SD-50-413-414/81-02. The cracked arc chute was  !

evaluated and determined not reportable.

4. NCI 10752 issued on one 600 volt loadcenter breaker with cracked arc l chute retainer molding was incorrectly included with the Nonconforming '

Items issued on cracked arcing contacts and Reportable Item CA-80-14.

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Notice of Violation (. Paragraph B) 1 B. 10 CFR 50, Appendix B, Criterion 11, requires that the program shall provide for training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Duke Topical Report on Quality Assurace, Section 17.1.2, requires that formal training be conducted in specific topics such as NRC Regulations and Guides and esality assurance procedures, and that retraining be performed as required.

Contrary to the above, measures were not established to assure adequate training of personnel relative to NRC evaluation and reporting requirements (10 CFR 50.55(e) and 10 CFR Part 21) and the applicable DPC cor. trolling procedures as evidenced by:

1. Personnel do not unde;3tand when a basic component is considered to be delivered;

2. Personnel do not understand when DPC becomes the responsible evaluating agent;

3. Personnel do not know how responsible officials are Informed of possible reportable matters when the concerned Individual is not assigned as the evaluating Individual.

4. Review of site training records and discussions with site personnel reflect that training sessions givsn on October 22, 1979, and November 27, 1979, consisted of presentations of only the direct words of the regulations with no reference to other issued NRC guidance and there were no handouts. Additionally, DPC provided no additional training at the site after a complete refision of evaluation and reporting procedures during the period May - November 1980; and 5 Personnel performing screening or evaluation activities have not been l provided adequate instructions or guidance to perform a meaningful evaluation.

l This is a Severity Level V Violation (Supplement II.E).

RESPONSE

(1) We admit that personnel training relative to NRC evaluation and re-porting requirements and the applicable Duke Power controlling pro-cedures was not completely adequate.

l (2) This problem occurred because of unclear procedures and inconsisten-l cles in training by persons responsible for training.

! (3) Duke Power procedures on reportability have been clarified. All responsible persons have been trained by the QA Manager, Technical Services, to ensure consistency of training. These stept %ere com-pleted on April 17, 1981.

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a (4) The steps outlined in (3) above should preclude recurrence of this situation.

(5) Full compilance has now been achieved.

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Notice of Violation (Paragraph C)

C. 10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions . . .

shall include appropriate qualitative acceptance criteria . . . The Duke Topical Report on Qus11ty Assurance, Pargaraph 17.1.5.2, requires that the acceptance criteria established by Design Engineering are incorporated in the instructions, procedures or drawings used to perform the work.

Procedures also provide for review, audit, approval and documentation of j activities affecting the quality of safety-related items and determine that all criteria have been met.

I Contrary to the above, site procedures and drawings did not contain accept-ance criteria as evidenced by:

1. Procedures and drawings for installation of pressurizer relief tanks did not include inspection requirements nor acceptance criteria for the location of sliding supports.

2. Procedures and drawings did not require documentation of status of

, partially completed work that is transferred from the fabrication shops to the field for completion.

RESPONSE

(1) The alleged violation is denied for the following reasono:

I Pressurizer Relief Tank i

Drawings CN-1050-6, R18 and CN-1050-7, R20 provide adequate i instructions for installation of the special sliding support including

! a minimum acceptance criteria of 3/4 inch clearance between the anchor .

! belt and support slot. Drawing CN-1050-6 shows the building location l

of the concrete support pad and anchor bolts. Section S-S is clearly l noted. Drawing CN-1050-7 shows the anchor bolt detail S-S. Also reference is made to Section U-U. Section U-U provides details of the bolt relative to the slotted support. The 3/4 inch clearance is noted on Section U-U. Erection and inspection did not comply with

. these drawings during the installation of the pressurizer relief tank.

Non-conforming item report 11420 was issued regarding the anchor bolt gap on the pressurizer relief tank sliding support. It has been established that a minimum 5/8 inch gap is necessary and the slots will

be increased. Drawing CN-1050-7 will be revised to show the 5/8 inch gap per the "as built" condition.

This situation is considered to be an isolated incident and the drawings comply with 10 CFR 50, Appendix B, Criterion V.

l Partially Completed Work i Improper control of partially completed work that is transferred from the fabrication shops to the field for completion did occur in the case of Containment Spray Heat Exchangers 1A, LB, 2A, and 23 as stated. The fabrication shop failed to install the correct size weld as required by the drawings and procedures, and inspectors

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failed to verify correct weld size before allowing -he partially com-pleted work to be transferred from the shop.

A re-Inspection of all mechanical equipment supports to the require-ments of QAP M-18 (Inspec'!on of Structure Steel Erection) has been completed by structural an) welding inspectors to assure conformance with design drawings. The re-Inspection did identify undersized welds on Containment Spray Heat- Exchangers IA, 18, 2A, and 28. Non-conforming item Report 9725 addresses this problem. The ' solution for NCI 9725 failed to address the possibility of over- ssed welds due to loading by setting the equipnent in place p sr to weld completion. Nonconforming item Report 11513 addresses the possibility of over-stressing the welds due to loading. To preclude any future problems a hold point will be placed in the equipment setting package per Procedure M-9 that will renuire structural Inspection prior to equipment retting.

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Nc. ice of Violation (Paragraph D)

D. 10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that identification of significant conditions adverse to quality be reported to the appropriate levels of management. Duke Power Company Construction Department quality Assurance Program Procedure Q-1, Control of Nonconforming items, requires that " Based on thorough evaluation, the appropriate box shall be checked to indicate whether the nonconformance should be evaluated by management for reportability under 10,0FR 50.55(e) or 10 CFR 21."

Contrary to the above, the established site measures were not adequate to 4

assure that generic nonconforming items and trends were being thoroughly evaluated and reported to appropriate levels of management as evidenced by the following:

1. Multiple nonconformances reporting a linear Indication extending the full length of stainless steel piping, used to fabricate ASME class 2 piping subassemblies, were being handled as individual insignificant problems even though the originator of later nonconformances stated that the material involved has been identified as suspect in earlier nonconfornances.

This example is applicable to Unit 2 only. -

2. Multiple NCl's, which were written to report unacceptable weld config-uration on welde which had been accepted by QC, were handled on an Individual basis to repair unacceptable weld joints without evaluating the cause of the acceptance of the welds during original inspection.

This example is applicable to Unit 1 only.

3. An 8-inch diameter ASME Class I weld in the Unit I safety injection system was nonconformed for improper welding - excessive weld weave .

The corrective action required removal of improperly we!ded material without establishing significance or providing a mechanism for estab-lishing how much material was affected.

This example is applicable to Unit 1 only.

4. RHR pump 1 A seal water piping was assembled by the manufacturer for the NSSS with apparent residual stress caused by cold springing of the piping. The condition was nonconformed and corrected under the direction of the NSSS site representative without documenting how much cold spring was invloved or what effect the cold spring could have had on the safety of the plant.

This example is appilcable to Unit 1 only.

This is a Severity Level V Violation (Supplement II.E).

RESPONSE

i (1) We admit that established site measures were not adequate to assure that generic nonconforming items and trends were thoroughly evaluated and reported to appropriate levels of management.

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1 (2) T. tis violation occurred for the following reasons:

a. Some personnel believed a conservative approach to resolution of nonconformances was sufficient, perhaps not fully recogniting the potential impact on other projects.

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b. Minor deficiencies in vendor supplied items were sometimes treated in the same manner regardless of the fact that the items may have already been accepted by receipt inspection. Personnel, not being aware of the philosophy behind 10 CFR 21, and 10 CFR 50.55(e), judgmental 17 believed this to be sufficient.

(3) The corrective measures taken as a result of this violation are:

a. Personnel have been retrained as discussed in Violation B (3).

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b. A review of all nonconformances originated after January 1, 1978 has been completed. These nonconformances were screened to identi-fy those for which reportability should be reconsidered. The initial review has been completed and the re-evaluation for reportability is well underway. Several nonconformances have been reported as a result. The complete evaluation process will be completed by August 26, 1981.

(4) The corrective measures detailed in (3) above are sufficient to preclude recurrence.

(5) Full compliance will be achieved by August 26, 1981.

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Notice of Violation (Paragraph E)

E. 10 CFR 50, Appendix B, Criterion XVil, requires t!.at sufficient records shall be maintained to furnish evidence of activities affecting quality.

Duke Quality Assurance Program Procedure Q-1, Control af Nonconforming items, requires that the Senior QA Engineer review NCI reports for clarity, completeness and proper content.

Centrary to the above, the below listed NCI's did not contain the clarity, completeness, and content to satisfy the requirements of Procedure Q-1,

1. NCI No. 9926 reported that a part of a penetration was only one-half as thick as required by the plan; the disposition simply states that the part and the plan are both right and, therefore, the part was accept-able. Discussion with the involved personael showed that the NCl originator misread the plan and the NCI should have been volded.

2. NCI No. 9933 corrective action was changed from unacceptable to use as is status without documenting the justification for (V, as is.

RESPONSE

(1) We admit that in some cases nonconformances did not contain the clarity, completeness and content to satisfy the requirements of Q-1.

(2) One reason for this violation is that the reviewers of the noncon-formances were within easy access to those persons completing the Q-1A's and verbal discussions many times were relied upon for clarification. Other Q-IA's were not properly completed because individuals were inadequately trained in the details of Procedure Q-1.

(3) The corrective steps taken to include the retraining discussed in Violation B(3) and the review of nonconformances discussed in Violation D (3) b . The review of nonconformances included screening for complete-ness, clarity, and content; and training session stressed the re-quirements for canpleteness, clarity and content.

(4) The steps described in (3) above will preclude recurrence of this violation.

(5) Full compliance with be achieved upon completion of the evaluation of nonconformances which is scheduled for August 26, 1981.