ML20004E891
| ML20004E891 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/10/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20004E890 | List: |
| References | |
| 50-413-81-02, 50-413-81-2, 50-414-81-02, 50-414-81-2, NUDOCS 8106160093 | |
| Download: ML20004E891 (4) | |
Text
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APPENDIX A NOTICE OF VIOLATION Duke Power Com, 3 Docket Nos. 50-413, 50-414 Catawba 1 and 2 License Nos. CPPR-116, CJPR-117 As a result of the inspection conducted on January 26 - February 6, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the following violations were identified.
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 management. Duke Power Company Topical Report, Section 17.1.16, the Engineering QA Program, contains procedures for resolving conditions adverse to quality. Design Engineering j
Department Procedure DP-220, Nonconforming Item Reports, Section 2.2, requires the responsible Engineer to evaluate the nonconformance to ascertain if it is reportable to management under the provisions of Procedure PR-290, 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 appro-priate levels of management are not adequate.
The responsible evaluating design engineer did not perform an adequate evaluation of Nonconforming Report Nos. 9755, 10665, 10684, 10721, 10745, 10752, 10818 and 10852 (covering 13 defective 600V safety-related circuit breakers) in that no information was forwarded to management for reportability evaluation.
This is a Severity Level IV Violation (Supplement II.D.2.) applicable to Unit 2 only.
B.
10 CFR 50, Appendix B, Criterion II, 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 Assurance, Section 17.1.2, requires that formal training be conducted in specific topics such as NRC Regulations and l
Guides and quality assurance procedures, and that retraining be performed as required.
Contrary to the above, measures were not establised to assure adequate training of personnel relative to NRC evaluation and reporting requirements l
'8106100 09,3 l
Duke Power Company 2
Docket Nos. 50-413 and 414 Notice of Violation License Nos. CPPR-116 and 117 (10 CFR 50.55(e) and 10 CFR Part 21) and the applicable DPC controlling procedures as evidenced by:
1 Personnel do not understand when a basic component is considered to be delivered; 2
Personnel do not understand when DPC becomes the responsible evaluating agent; 3
Personnel de r,ot 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 t h... training sessions given 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 revision of evaluation and reporting procedures during the period May - November 1980; and 5
Personnel performing screening or evaluation activities have not been provided adequate instructions or guidance to perform a meaningful evaluation.
This is : Severity Level V Violation (Supplement II.E.).
C.
10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions, procedures. <; drawings of a type appropriate to the circumstances and shall be accon elished in accor-dance with these instructions, procedures or drawings.
Instructions...
shall include appropriate qualitative acceptance criteria....The Duke Topical Report on Quality Assurance, Paragraph 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 activities affecting the quality of safety-related items and determine that all criteria have been met.
Contrary to the above, site procedures and drawings did not contain accept-ante criteria as evidenced by:
1.
Pr:cedures and drawings for installation of pressurizer relief tanks die not include inspection requirements nor acceptance criteria for the location of sliding supports.
l
Duke Power Company 3
Docket Nos. 50-413 and 414 Not'.ce of Violation License Nos. CPPR-116 and 117 2.
Procedures and drawings did not require documentation of stati 4 of partially completed work that is transferred from the fabricatien shops to the field for completion.
This is a Severity Level V Violation (Supplement II.E.).
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 CFR 50.55(e) or 10 CFR 21."
Contrary to the above, the established site measures were not adequate to 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 had been identified as suspect in earlier nonconformances.
This example is applicable to Unit 2 only.
2.
Multiple NCI's, which were written to report unacceptable weld config-uration on welds 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 1 weld in the Unit 1 safety injection system was nonconformed for improper welding - excessive weld weave The corrective action required removal of improperly welded 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 1A seal water piping was assemoled 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 l
l l
Duke Power Company 4
Docket Nos. 50-413 and 414 Notice of Violation License Nos. CPPR-116 and 117 direction of the NSSS site representative without documenting how much cold spring was involved or what effect the cold spring could have had on the safety of the plant.
This example is applicable to Unit 1 only.
This is a Severity Level V Violation (Supplement II.E.).
E.
10 CFR 50, Appendix B, Criterion XVII, requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.
Duke Quality Assurance Program Procedure Q-1, Control of Nonconforming Items, requires that the Senior QA Engineer review NCI reports for clarity, completeness and proper content.
Contrary 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 personnel showed that the NCI originator misread the plan and the NCI should have been voided.
2.
NCI No. 9933 corrective action was changed from unacceptable to use as is status without documenting the justification for use as is.
This is a Severity Level VI Violation (Supplement II.F).
Pursuar.t to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within twenty-five days of the date of this Notice, a written state-ment or explanation in reply, including: (1) admission or dental of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date:
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