ML20004E892
| ML20004E892 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/24/1981 |
| From: | Blake J, Brownlee V, Bryant J, Hunt M, Mcfarland C 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 8106160098 | |
| Download: ML20004E892 (27) | |
See also: IR 05000413/1981002
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REdlON 11
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101 MARIETTA ST., N.W., SulTE 313o
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ATLANTA, GEORGIA 30303
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Report Nos. 50-413/81-02 and 50-414/81-02
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Facility Name: Catawba 1 and 2
Docket Nos. 50-413 and 50-414
License Nos. CPPR-116 and CPPR-117
Inspection at Catawba site near Rock Hill, South Carolina and Duke Power Company
(DPC) Corporate Offices, Charlotte, North Carolina
Inspectors:
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[J/J. Blake
Date Signed
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C. R. McFarland
Date Signed
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Approved by:
//C. 8'ryagf,' Sect 1on Chief, Division of
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Resident and Reactor Project Inspection
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SUMMARY
Inspection on January 26 - February 6,1981
Areas Inspected
This so-cial, announced inspection involved 345 inspector-hours on site and 15
hours at the Corporate office in the areas of quality assurance, on site design
cc .: trol s ,
site management,
site procurement,
construction controls and
activities, handling of nonconformances and reportable item evaluation.
Con-
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struction activities inspected included electrical components and systems,
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instrumentation, safety-related pipe support and restraint system, and mechanical
equipment installation.
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Results
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Of the areas inspected, two violations were found concerning evaluation and
reporting of Part 21 and 50.55(e) items (Inadequate evaluation
paragraph 8.c
and inadequate training
paragraph 13.d); two violations were found in the area
of nonconforming items processir; (Inadequate evaluation for generic issues -
paragraph 12.b and 12.c and Inadequate documentation
paragraph 12.c); one
violation was found in mechanical installation (Inadequate procedures
paragraph
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11.e.(2), (3)).
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DETAILS
1.
Persons Contacted
Licensee Employees
- R. S. Alexander, Personnel Manager
- L. R. Barnes, Manager, Supports / Restraints
- D. G. Beam, Project Manager, Catawba
L. R. Davison, QA Manager, Construction
- S. W. Dressler, Senior Construction Engineer
- W. J. Foley, Principal Engineer, Electrical Division
- D. L. Freeze, Manager, Construction Services
- G. W. Grier, Planning Manager
- W. O. Henry, QA Manager, Technical Services
- R. A. Morgan, Project QA Engineer
- E. C. Wall, General Superint endent
J. R. Wells, Corporate QA Manager
Other licensee employees contacted included 25 engineers and construction
supervisors and foremen, 47 construction craftsmen, 38 technicians, and 16
office personnel.
Other Organizations
T. Davis, Project Manager, MCC Powers
W. Rochester, QA Engineer, MCC Powers
NRC Resident Inspector
- P. K. VanDoorn
- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on February 6, 1981, with
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those persons indicated in Paragraph 1 above. The violations were discussed
in detail.
On February 26, 1981, L. C. Dail, DPC Vice President Design Engineering and
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J. R. Wells, Corporate QA Manager met with the Region II staff in the Region
II office to discuss inspection findings.
3.
Licensee Action on Previous Inspection Findings
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Not inspected.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve noncompliance or
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deviations.
New unresolved items identified during this inspection are
discussed in paragraph 7.d.
5.
Site QA and Construction QA Program Implementation
a.
General
The purpose of this portion of the inspection was to complete an
overall review of implementation of the DPC program for control of site
QA and construction activities.
DPC Topical Report - Quality Assurance, Duke 1-A, Rev. 4, was accepted
by the Quality. Assurance Branch, Division of Project Management, NRR,
by letter dated June 29, 1978.
The Duke QA program commits to
applicable regulatory requirements such as 10 CFR 50, Appendix B and to
approved industry standards such as ANSI N45.2-1971 and corresponding
daughter standards, or to equivalent alternatives.
The QA program
commits to the regulatory position of the NRC Regulatory Guides listed
in table 17.0-1 of Duke-1-A with the exception of the clarifications,
modifications and alternatives stated in the table.
b.
Documents Examined
(1) DPC Topical Report on Quality Assurance, Duke 1-A, Amendment 4
(2) Corporate QA Manual
(3) Design Department QA Manual
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(5) Construction Department QA Manual
(6) Catawba Nuclear Station Construction Procedures Manual
(7) Catawba Nuclear Station Organization Chart
c.
QA Program Review
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The inspector reviewed the documents listed in paragraph 5.b and held
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discussions with responsible corporate and site management, QA, QC,
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technical support and craft personnel, and concluded that the DPC QA
program and supporting manuals contain the following:
(1) A policy statement from upper management supporting the QA program
and objectives.
(2) Adequate definition in the program for control of contractor and
subcontractor activities.
(3)
Provisions in departmental QA manuals for interface control
between Engineering Design, QA, Construction, Consultants, Con-
tractors, and Procurement.
(4) A listing of commitments to regulatory requirements.
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(5) Provision for management audits to determine QA effectiveness.
(6) Clear cut organization charts and responsibility matrices.
(7)
Independence of the QA organization from design and construction.
(8) QA Department direct access to management.
(9) Complete departmental QA manuals with proceduros to implement the
scope of work and provide interface control with other depart-
ments.
(10) Departmental QA manuals which are controlled documents and which
contain procedures for change control.
(11) Stop work requirements established in the Topical Report and
implemented by departmental procedures.
d.
Program Implementation
By observation of ongoing activities, review of reports and discussions
with personnel at all levels, the inspector concluded that the DPC QA
program, supporting manuals and organizational / functional alignment are
consistent with project status and adequate to monitor project
activities in an effective manner. Personnel were knowledgeable of the
QA program and procedural requirements. The inspector identified one
area, lack of knowledge and understanding of NRC evaluation and
reporting requirements, for which a violation was issued.
This is
discussed in paragraph 13.d.
e.
Audits
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There is a comprehensive system of audit and surveillance activities
which spans corporate, departmental and site activities. DPC belongs
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to a joint Utility Management Organization which includes seven
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utilities. This organization performs the corporate audit on an annual
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basis.
The inspector reviewed the corporate audit report for the
October 6-10,1980 audit.
Departmental audits are performed by the QA Department Internal Audits
Group.
The inspector reviewed C-80-7,
Catawba Nuclear Station
(10/13-20/80), and C-80-8, McGuire Nuclear Station (11/3-7/80) audits.
Site surveillance activities are performed by site QA personnel.
The inspector found that the audit system provides effective inter-
facing. Audit plans are tailored to a function and are not superficial
checklists.
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f.
Reorganization
On February 1,1981, all Quality Control personnel were transferred
from the Construction Department to the QA Department.
The Topical
Report does not reflect this organization. The inspector discussed the
change with NRR QA Branch, and with the DPC Corporate QA Manager. It
was agreed that DPC will submit a letter immediately to NRR describing
the new organization and will revise the Topical Report by March 31,
1981.
Neither NRR nor IE abjects to the reorganization and the
inspectors have no further questions on the subject.
As a result of this inspection, the inspector finds that the interface
activities between Design, QA and Construction is adequate.
Management
involvement at the work site is quite good.
It appears that management
supports the program.
6.
Project Management - Site
Portions of this inspection were directed toward methods used by site
management to determine that a quality product is produced and toward
participation of management and supervisory staff in handling of site
problems.
Also, it was directed toward craftsmen ond inspectors to
determine their competence and their perception of the following: work
quality; availability of technical assistance; accessibility of management;
freedom to express opinions; and protection from harassment.
a.
Organization
(1) There are no major contractors at the Catawba site other than the
Except for a few small contractors, all
personnel on site, from the project manager through craftsmen and
laborers, are employees of Duke Power Company (Duke).
Many
employees are second or third generation Duke employees and many
are working on their third Duke nuclear power site.
Probably as a result of this Duke " family" relationship, the
organization is less formally structured than at some other
utility sites.
Organization charts are of current date; however, they do not
reflect exactly how the organization is functioning in some minor
aspects. This presented no problem, since everyone involved knew
the actual functions. Also, there is a major change of function
in progress to Corporate Quality Assurance rather than to the site
project manager.
This change is discussed in greater detail in
paragraph 5.f of this report.
(2) Position Descriptions
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The site has Position Analyses for most jobs in the top two or
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three levels, project manager excluded. These analyses are
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generic to the company and are not totally accurate relative to
Catawba. They do not match the organization chart completely.
Theca analyses give the broad scope of authority and responsi-
. ties of the positions. However, QA procedures place specific
iesponsibilities on positions in handling safety-related matters.
Position descriptions do not provide for assumption of authority
in the absence of superiors. Assignments to acting positions are
made, if needed, by superiors. There are certain signoffs which
are not delegated but are designated to be signed by a specific
rank.
(3) Communications
The program specifies only three types of reports to go to the
project manager.
These are site stop work orders, variation
notices (departure from design), and nonconforming
items
reportable to the Nuclear Regulatory Commission.
Internally,
numerous other reports are sent to him, such as trending reports,
personnel actions and others.
Communications within the organization are not formally structured
but are handled by managers as they see fit with only the most
serious requiring notification of receipt back to the originator.
On safety matters, the QA Manual describes required communications
in each procedure. These appear to be clearly understood.
(4) Change Controls
Change controls are mastly originated in corporate offices and
notices are disseminated from there. Design changes originated on
site are handled by variation notices which receive corporate
approval before implementation.
In summary, site organization interface and communications is relatively
informal. Written memos are not used when direct contact will serve, except
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as required in the QA manual.
Due to the nature of the Duke " family"
organization, this system appears to be working.
No noncompliances or
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safety concerns were found that could be attributed to the organization.
b.
Trending: Nonconformances and Rework
(1) Nonconformances
Site personnel reported that trends of Nonconforming Items (NCI)
reports are prepared annually in corporate offices. These were
not examined by the inspectors. Unofficial trends of NCI's are
developed quarterly on site by the senicr QA engineer. NCI's are
placed in the computer and trends are developed.
At least
quarterly, these are reported to the site manager and actions are
taken as indicated.
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This system, while it apparently is of value in some respects, is
quite limited in other respects.
Items are entered in the
computer by a non-technical person and are assigned a key
designation based on wording of the NCI's.
NCI's of identical
items and failures were found by the inspectors to have received
different key designations, thus they would not appear on the
printout as repeat items.
Also, trending is based on changes in relatively large numbers (50
or more) and thus would not detect five failures, for example, of
a critical item.
(2) Rework
Extensive trending is done of all rework.
Trending reports are
developed for time periods throughout site history, by discipline,
by system, by crew, and by cause. Cause is generally defined as
repair or design, with a very low percentage due to repair.
Design may mean any change from original intent, from a regulatory
change to rerouting due to interference found in layout provided
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in the field.
These trending reports are prepared for the planning manager and
are received by the site manager and others monthly.
They are
used extensively in planning and evaluation.
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The NCI trending described above is not a requirement by NRC or Duke,
but is provided for information.
Though weaknesses are described in
the system, no noncompliance with regulation was found. Weaknesses in
the NCI system are described elsewhere in this report.
c.
Management Accessibility to Employees
(1) Availability of Technical Assistance
Discussions were held with craftsman, inspectors and engineers by
all of the NRC inspectors during condact of this inspection. As
described in other sections of this report, the site engineering
staff works very closely with construction forces. Problems are
approached together in the field and resolutions determined.
Construction personnel and inspectors stated that assistance was
always available.
(2)
Freedom to Express Opinions
Duke procedure Q-1 states that all employees are required to
report conditions adverse to quality.
There was evidence that
employees are encouraged to take any problem to their supervision
and to higher supervision, if they feel the need. Employee
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Relations has documented 255 cases in 1980 of employees going to
higher supervision and believes there may be many cases undocu-
mented.
(3) Employee Relations
There is an employee relations office on site located in the work
area.
Employees are encouraged to use these services for any
problem.
On all terminations for cause, Employees . Relations
conducts an investigation independent of other company investi-
gations.
(4) Grievance Procedure
The site has a Construction Department Employee Recourse Procedure
which expresses the belief that employee concerns should be
addressed promptly and should receive thorough consideration
without recrimination. The procedure directs Employee Relations
to assist in preparation of grievances as desired by employees; it
also details steps and required response times.
An informal procedure is described which provides for oral
discussions through four steps to the project manager. A formal
written procedure is described with steps up through the president
of Duke Power Company.
(5) Harassment
The company has a procedure which is posted on site forbidding
harassment of any employee for any reason by anyone and describing
penalties up through termination.
NRC inspectors discussed with QC inspectors and craftsmen the
possibility that they might be pressured or harassed about
rejecting work or into performing poor quality work.
Some of
those interviewed were amused at the thought of such pressure.
None of those talked to felt that such a situation might develop.
(6) Management Contact
In January 1981, the company instituted an Employee Forum program.
This provides for meetings with 20-30 employees, without their
supervision, by management.
The first meetings were held in
January and were attended by craftsmen and the project manager,
the general superintendent, and the personnel manager. Meetings
were described as totally open to any subject, completely confi-
dential, and followed up by answers, if the answer could not be
provided at the time.
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The Employee Forum announcement is posted in the general work
area.
The project manager stated that he hopes to reach 2000
employees in 1981. The personnel manager described the meetings
as very open.
The inspector has observed the project manager in the work areas
and noted that he was well known by the workers.
He was
frequently greeted by his first name.
In summary, it is the inspectors' opinion from interviews, observa-
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tions, and review of site and c6mpany policies that top management and
supervision are available to employees at a very low threshold. It is
unlikely that harrassment detrimental to quality work could develop
under these conditions.
7.
Site Procurement, Receiving and Storage
a.
General
The bulk of equipment or materials received at the site are either NSSS
supplied or DPC Engineer procured.
Site requisitioned items are
primarily consumables, standard stock items and transfers,
b.
Documents Exanine.1
(1) Requisition 8337-00578S
P. O. No. F 6216-13
(2) Requisition 8337-00607S
P.O. No. E-98052-13
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(3) Requisition 8337-00957S
P.O. No. F-33825
(4) Requisition 8337-02195D-3
P.O. No. F-34676
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(5) Design Engineering Department QA Program -
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Section 300 - Procurement
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(6) Construction Department QA Program - Procedure E-3,
Field Procurement of Items and Construction Services
(7) QA Manual for ASME Code Work - Section E
c.
Program Implementation
The inspector examined the above noted requisitions, purchase orders,
and controlling procedures; held discussions with site QA personnel,
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Technical Support personnel, Warehouse QC personnel, and Warehouse
personnel; and performed an inspection of warehouse and storage
facilities.
The inspector concluded that:
(1) The procurement documents examined included the applicable
technical, QA, Codes, standards and Part 21 requirements.
(2) The materials were ordered from suppliers which are on the
approved vendors list.
(3) The procurement documents specify packaging, handling storage and
documentation requirements.
(4) The receiving QC technicians have access to the procurement
documents at the warehouse.
(5) Site personnel were knowledgeable of site procurement, receiving
and storage policies, procedures and activ'ities.
(6) The site receiving, inspection, nonconforming, tagging, storage,
records and transfer activities are being handled in a controlled
manner.
(7) Class A, B, C and D storage facilities have been established.
d.
Weld Filler Material
During a review of purchasing / receiving records on Febr':ary 4,1981,
the inspectors noted that Purchase Order No. E93052-13 for type E110-18
electrodes ordered to ASME B&PV Code requirements only required typical
certifications rather than the actual certifications by heat and lot
required for ASME B&PV work. The inspectors were informed that the
material was ordered for a specific Non-ASME application and was not
used in ASME applications even though the material appears on the site
list of approved ASME materials. The inspectors informed the licensee
that this would be considered to be an unresolved item (50-413/414/
81-02-01 "Contrui of Weld Filler Material"), while the licensee
attempts to verify the following:
(1) The material was not used in any ASME application.
(2) No other material has been purchased in the same manner and used
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in ASME applications.
(3) The system for control of filler material assures that material
with only typical certifications does not get used in ASME appli-
cations.
In the areas inspected, no violations were identified.
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8.
Electrical (Components and Systems I) - Observation of Work and Work
Activities
a.
Emergency Diesel Generators Auxiliary Equipment
The inspector examined the inplace storage conditions of Diesel
Generators IA and IB and associated local control panels. Each diesel
engine and generator is enclosed in temporary enclosures to reduce the
accumulation of dust and dirt resulting from construction activities in
the immediate area.
Heaters are installed at the base of the
generators for protection from moisture. Weekly inspections are made
to insure that the heaters are functioning properly and recorded on
inspection Form 41-B.
Megger readings are taken every 3 months to
ensure that the protection is adequate for the generator windings.
The control panels and sequdncing panels are covered with wooden doors
to prevent damage to the control switches and meters. These panels are
inspected periodically for cleanliness and damage.
b.
4160 Volt Switchgear
The inspector reviewed the installed 4160V switchgear 2 ETA with the QC
inspectors to ascertain the depth of the QC installation inspection.
Records and discussions revealed that verifications of proper handling
methods, of correct location, and of proper orientation of the base and
equipment were made during the installation of the switchgear.
Inspection for damage is made at this time.
The electrical QC inspectors verify the correct torque values when
anchor bolts are used, but welding inspectors inspect and approve
welded equipment to base installations. The inspection is conducted in
accordance with Supplemental Inspection Instruction, Serial No.
4,
Electrical Equipment Installation.
c.
600V Switchgear and Motor Control Centers
During this inspection, it was found that thirteen 600V circuit
breakers had been nonconformed for broken contact blocks.
These
breakers had been found defective during calibration and adjustment by
the Transmisston Department and nonconformed in accordance with
Procedure Q-1, Control of Nonconforming Items, on Nonconforming Item
Report Nos. 9755,10665,10684,10721,10745,10752,10818 and 10852.
As of the beginning of the inspection, no request had been made for an
evaluation to determine the reportability of the breaker deficiencies.
The fact that breakers had been found defective during 6 successive
working days did not trigger any administrative mechanism that required
further evaluation for reportability.
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Approximately 3 days into the inspection, a request for evaluation of
the breaker def Liencies was made by site personnel to corporate
offices. Shortly before the end of the inspection, the inspectors were
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advised that evaluation had determined that the breaker deficiencies
were not reportable.
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The inspector, however, identified the compartments in which the
breakers were to be used and found that 4 of the breakers served wither
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as the normal feeder or alternate feeder breaker for the 600V Essential
Auxiliary Power System 600V Load Centers 2ELXB and 2ELXD.
Failure of these breakers would result in the loss of one train of 600V
motor control centers, which supply power for letdown heat exchanger
cooling water supply and suction valves; auxiliary feedwater to steam
generator 2B isolation valve; auxiliary feedwater pump 2B suction valve
from nuclear service water; and the pressurizer power operated relief
valve isolation valve.
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It was further determined that one of the breakers identified as
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deficient was to be installed as a feeder breaker in 600V Essential
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Auxiliary Power System 2ELXA which is identified as the redundant power
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train.
It would appear that were these breakers, as designated by
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approved engineering drawings CN-2703-01.01 and CN-2703-01.01, to fail,
the capability to obtain and maintain safe shutdown conditions would be
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greatly decreased.
Since the same model breakers are used throughout the other power
train, the possibility exists that the same deficiency exists in them.
The failure to adequately evaluate the breaker deficiencies appears to
be a violation and is identified as 414/81-02-02, Inadequate Evaluation
of Generic Deficiencies for Reportability.
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Electrical Penetration Installation
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The inspector observed partial installation of electrical penetration,
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Serial No. 2629F, internals. Cleanliness during the installation was
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closely controlled. All seals were installed and the torquing sequence
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was in accordance with Procedure CNS-1390.01-00-0073, Mechanical
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Installation Procedure for Electrical Penetration Types B, C, D, F, G,
H, J, K, L, & M.
Discussions with the cr-ftsmen and QC inspector
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revealed that these personnel were knowledgeable of the installation
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procedures as well as the requirements of installation of equipment
which required periodic calibration.
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Transmission Department
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This department performs all circuit breaker tests, calibration and
inspections for the construction and operating departments.
In
addition, all adjustable relay calibrations are accomplished by this
department. The Transmission Department also performs the high
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potential testing of high voltage cables after installation by the
construction forces.
All work is performed in accordance with the construction QA program or
the operating plant QA program.
During construction activities,
surveillance activities are performed and documented by the electr cal
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QC group.
Discussion with transmission department supervision revealed that the
existing department QA manual is being revised to define more clearly
the responsibilities of the department.
f.
Cable Installation and Terminations
No safety-related cable installations were made during this inspection.
Cable terminations were in progress in several areas but verification
by the QC inspectors is performed just prior to system turnover.
Discussions with the QC inspectors performing this task indicated that
they have an understanding of the procedure requirements. They further
advised the inspector that there was no difficulty in getting
corrections made when required.
g.
Electrical Motor Storage
Examination was made of electrical motor storage conditions while in
the warehouse or after being set in place.
Inspections are made and
documentrM in accordance with approved QA/QC procedures. The motors
are manually rotated quarterly and meggered monthly. Motors requiring
heat when not in operation have temporary power applied to the heaters
until thespermanent power wiring is installed. When this is completed,
the permanent breaker is closed and tagged so that power is applied to
the motor heaters.
h.
Electrical Equipment Qualification
The inspectors met with a Duke Power Company task force tnat had been
assigned the duty of quali fying electrical and instrumentation
equipment to meet the conditions of IEB 79-01B.
The group had just
been organized and had not had time to develop a complete program.
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Discussions with the inspectors indicated that the group was well
informed and understood the task before them.
1.
Personnel Interviews
The inspector conducted interviews with several craftsmen, rt0
inspectors, engineering technical support and supervisory personnci.
All discussions indicated that safety concerns could be carried to the
highest level necessary to obtain satisfactory answers or resolutions.
No resentment was observed between the craftsmen and the inspection
personnel. The craftsmen were aware of the requirements to do the work
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properly. Most were aware of the separation criteria and power train
requirements for separation. All had access to procedures and drawings
and indicated that they used them frequently.
The QC inspectors appeared to be well versed in the inspection
procedure to which they were inspecting.
Throughout the organization, no problems appeared that would indicate
that there was not cooperation between all parties involved.
9.
Instrumentation and Control
a.
General
DPC, being its own AE/ Constructor, is responsible for final design and
layout of plant; plant systems; purchasing of balance of plant equip-
ment; site receiving, storage issue installation and associated QA/QC
activitie;.
supplied equipment is received on site, stored and
installed by DPC Construction Department.
The only contractor on site that has responsibility for installation
and checkout of safety-related instrumentation is for HVAC, Bahnsen
Service Co. (Bahnsen) contractor. Bahnsen has subcontracted to MCC
Powers (Powers) the instrumentation and control portion of the
contract. Powers does application engineering only.
Contractor work packages for system installation, which include
description of work, applicable drawing, equipment to be purchased,
etc. are submitted to DPC Design Engineering Department for review and
approval prior to start of work or purchase of equipment.
DPC has
reviewed and accepted Bahnson's QA/QC program.
Bahnsen has reviewed
and accepted Powers QA/QC program. DPC performs vendor audits and site
surveillance checks on Bahnsen and Powers activities.
b.
Documents Examined
(1) Catawba Oraanizational Chart
(2) Equipment location drawing CN-1499.01.11
(3) Equipment location drawing CN-1499.01.10
(4) Instrumentatici Surveillance Checklist, dated 1/28/81
(5) DPC Specification No. CNS-1210.04-00-0011, June 27, 1978, Rev. 1,
December 5,1978
(6)
Instrument Standards Installation Field Practices, Drawing Nos.
ICS-A-20, 20.1, 20.2, 20.3, 20.3, 20.4, 20.5, 20.6, 20.7, 20.8,
20.9 and 20.10.
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(7) Instrument Field Installation Detailed Drawings CN-1499-KC-30,
KC29, KC24.
(8) Specification No. CNS-1354.02.00.0001,10/19/77, Multi Conductor
Control Cable
(9) Specification No. CNS-1354-03-00-0001, 11/18/77, Shield Pair
Instrument Cable
c.
Systems Installation
To verify systems installations, the inspector performed the following:
(1) Held discussions with DPC Design Engineering engineers, site
technical support personnel, warehouse receiving and inspector
personnel, site QA/QC personnel, craft personnel and craft
foremen, and Bahnsen and MCC Powers Contractor personnel.
(2) ..eviewed the documents identified in paragraph 9.b above.
'
(3) Examined the field installation of the following instruments to
verify that installation is in accordance with the plans and
specifications:
1KCFT 5990
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IKCFS 5990
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IKCFS 5950
--
IKCFT 5950
--
IKCFS 6060
--
IFCFT 6060
--
IKCFS 5963
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IKCFT 5960
--
1KCPG 5660
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1RNPT 5020
2KCFE 6520
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(4) Verified thnt selected drawings and variation notices were current
and at the proper locations.
(5) Witnessed QC personnel performing acceptance inspections.
(6) Witnessed QA personnel performing Surveillance Checklists on QC
personnel performing acceptance inspections.
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d.
Findings
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The inspector concluded the following:
(1) There appears to be good interface between Design Engineering and
site Instrument Technical Support personnel.
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(P.j Site Instrument Technical Support personnel are providing the
needed guidance to the crafts,QA and QC.
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(3)
Electrical / Instrumentation QC personnel are knowledgeable of QA
program and engineering document requirements.
(4) Craft foremen and craft personnel interviewed were knowledgeable
of engineering and QA requirements.
,
(5) The inspector could detect no cases where hostilities or
harrassment existed between craft, QC, technical support and
Design Engineering personnel.
(6)
Instrumentation and control equipment that was being received,
inspected, stored, installed and inspected for installation was
being handled in accordance with program requirements.
No violations or deviations were identified.
10.
Safety-Related Pipe support and Restraint Systems (Unit 1)
a.
Program
The applicable code for safety-related support and. restraint
installations is the ASME B&PV Code, 1974 Edition with Summer 1975
Addenda.
The inspectors reviewed selected procedures; interviewed technical,
quality control and craft supervisors; observed work activities; and
inspected installed supports and restraints to determine if the
,
licensee's program was adequate to ensure that installed supports and
restraints met the design requirements imposed by the applicable code.
Procedures reviewed included the following:
(1) CP-115 Installation of Concrete Expansion Anchors
!
(2) CP-385 Support / Restraint Erection Tolerances
(3) CP-432 Welding of Hangers, Supports and Seismic Controls
b.
Personnel
1
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The supervisors were interviewed to determine the working relationship
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between tne various groups involved with fabrication and installation
,
of the supports and restraints.
It was noted that the technical and
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craft organizations have personnel assigned to specific areas of
support and restraint work (i.e., Reactor Building, Auxiliary Building
and Turbine Building) and that the tec.:nical people in a specific area
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work closely with the craft personnel assigned to the same area.
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The licensee's hanger group also includes a design liaison team
assigneJ to the site for the purpose of solving minor problems with
hanger and support installation and also to perform verification
inspections when a problem is of the type that requires reanalysis of
the support systems.
This design group appears to have established a good working relation-
ship with the construction technical and craft personnel and the design
response to problems is obviously facilitated by the problems being
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translated into design terminology at the site level.
!
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The inspectors noted that there appeared to be an obvious cooperative
attitude in the interaction between the construction technical, craft
and design liaison personnel.
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c.
Work Observation
Work observed included the following activities:
(1) Observation of a pre-check team (one technical representative and
one _ craft representative) sighting locations of proposed hangers
and supports to see if they could be installed as designed.
The pre-check included verification by actual measurement and
establishing the location site with appropriate markings to
provide guidance to the installation crew. The completion of the
pre-check exercise was either a release for fabrication or a
design deviation or change request initiated by the technical
member of the team.
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(2) Observation of support and restraint fabrication welding and
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inspection activities in the Auxiliary Building.
(3) Observation of support and restraint installation activities in
the Auxiliary and Reactor Buildings.
DJr_ing the observation of work activities, the inspector
questioned the personnel involved to determine their knowledge of
job requirements. The personnel contacted during this inspection
appeared to be well trained in that welders, fitters, and QC
inspectors all seemed to understand the welding symbols used on
the design drawings, and installation mechanics all seemed to be
aware that if the drawing being worked did not provide tolerances
that CP-385 would provide the necessary information.
The installed supports and restraint systems inspected included
the following:
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1RKC- 392
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The inspector also examined the following mechanical type snubbers
which were a part of restraints being assembled in the Auxiliary
Building:
1500# Snubber
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1500# Snubber
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6000# Snubber
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650# Snubber
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--
1500# Snubber
1RCA- 079
1500# Snubber
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1500# Snubber
--
650# Snubber
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These snubbers were inspected for evidence of damage or mis-
handling.
The result of this inspection was that the inspector gained the
impression that licensee management is endeavoring to establish a
team environment in the area of hanger fabrication and
installation.
There were no violations or deviations in this srea of the
inspection.
11. Mechanical Equipment
a.
Scope
This portion of the inspection concerned on site design work and
installation relative to mechanical equipment. The inspector examined
completed work and work in progress relative to heat exchangers, tanks
and fuel racks.
!
b.
Organization
The mechanical equipment for the nuclear steam supply system (NSSS)
procured from Westinghouse Electric Corporation (Westinghouse) is
installed under the supervision of the mechanical construction
engineers. Mechanical equipment for the balance of plant is installed
under sapervision of the civil engineers.
The only documentation of
the civil engineers' evaluations is QA/QC documentation of acceptance
or rejection of work. Power house mechanics (millwrights) perform the
work of installation of all safety-related mechanical equipment.
QC engineers and technicians inspect work performance while QA
engineers and technicians perform surveillance of QC and craft work and
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documentation of the work.
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The inspector held discussions with personnel from each of the groups
listed above. All of those contacted demonstrated sufficient knowledge
of their assignments, the interface with the other groups and of the
QA/QC requirements to perform the work satisfactorily,
c.
Design Functions
The applicable specifications and drawings are prepared by the
corporate design engineering department and are readily Tvailable on
site as controlled documents.
Variation Notices (VN's) are processed for design changes deemed
necessary by on site construction engineers and on site design, and
result in revisions to design drawings. Minor changes may be worked
out by telephone between the two design groups but these are followed
up by drawing changes from corporate. The design groups meet regularly
either in the field or in corporate, usually weekly, to assure proper
understanding of problems.
d.
Document Review
The inspector reviewed the following VN's as representative of work in
progress and work completed: 1844, 1882, 6045, 7622, 7970, 8468, 10287,
12243, and 12992.
VN's are controlled by the requirements of QA
procedure R-3, Design Drawing and Specification Variation, documented
on Form R-3A and the status of VN's is logged on Form R-3B.
The inspector found that the task for each organization on site is
clearly planned, implemented and documented.
Complete work packages
were prepared for each task by the engineering section.
Prior to and during the inspection the inspector reviewed the PSAR and
QA procedures relative to mechanical design engineering and construc-
tion.
No violations were found in this area.
e.
Safety-Related Components - Observation of Work and Work Areas
(1) Upper and Lower Lateral Restraints, Steam Generators and
Pressurizers, Units 1 and 2.
The inspector reviewed specifi-
cations for the support framing of the pressurizer, steam
generators and reactor coolant pumps, CNS-114.05-3, and upper
lateral restraints of the steam generators, CNS-1144.05-00-0012.
He also reviewed drawings CN1070-11, CN1070-14 and CN1070-30 and
related details and construction procedures CP399 and 475. The
inspector also reviewed QA procedures L-80, M-4, 9,15,18,19, 21
and 51; QA procedures Q1 and R3; the QA surveillance checklist for
mechanical equipment installation and alignment, MWN-2; and the
monthly QA surveillance reports for inspection of installation of
mechanical equipment for June 1980 through January 1981.
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Discussions with construction engineers and craft foremen revealed
a reasonable knowledge of the above documents and related work.
The lower laterals are installed for the Units 1 & 2 steam
!
generators (SG). Upper laterals for Unit 1 SG's are about 25
t
percent complete. No field work has begun on upper laterals for
Unit 2 SG's. Upper and lower supports are installed for the Unit
1 pressurizer. The Unit 2 pressurizer lower supports erection is
about 75% complete; the upper supports are on site, but no field
work has been initiated.
- The inspector examined the completed work. No field erection was
in progress.
- (2) Pressurizer Relief Tanks - Units 1 and 2
Pressurizer relief tanks for Units 1 and 2 were inspected for
proper installation. The inspector reviewed drawings CNM1201.-
4-100, CP360A and QA procedure for reference.
The tanks. are
stored in place. The sliding supports for each tank are set on
embeds with two inch bolts. The elongated bolt holes in the base
of the sliding supports are designed to be 2.75 inches
long to
allow for thermal expansion of the tank and movement of the
,
sliding supports. Embeds for the sliding supports are not grouted;
the work is not complete.
Inspection of the elongated bolt holes is limited by washers and
nuts. By reaching under the sliding support plates, the inspector
was able to determine that the support plates apparently are
improperly positioned relative to the embed bolts. There was
clearance for about
inch of expansion on the Unit 1 tank and
inch on the Unit 2 tank; whereas, the design provides 3/4 inch.
Neither the equipment specification nor the installation procedure
,
(
provide acceptance criteria for this dimension.
Acceptance
criteria are related only to tank nozzles and piping.
i
Failure to provide acceptance criteria is contrary to Criterion V
of Appendix B as implemented by Duke Topical Report paragraph
!
17.1.5.2.
This is a violation identified as 413/414/81-02-03,
Inadequate Procedure.
i
(3) Containment Spray Heat Exchangers Supports - Units 1 and 2
Supports for the. containment spray heat exchangers are being
fabricated by welding I beams and cross braces in the site metal
fab shop and are being installed according to CP360A.
Approximately 4 of the required thickness of eaph weld
(approximately 200 welds per support) is being applied in the fab
shop. The supports are then transported to the Auxiliary Building
and are completed in place with the weight of the heat exchangers
on them.
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Welds are not completed in the fab shop and existing procedures,
drawings and instructions fail to define the status of work
completed in the fab shop. Thus, in the field, the supports must
be examined according to drawings and each of the
inch welds
increased to 3/8 to h inch.
Also, the welds are completed with
the weight of the heat exchangers on them; whereas, design intent
apparently was to ha.ve them welded in the shop without this load.
Failure to define the status of work completed prior to releasing
the equipment to another area is contrary to Criterion V of
Appendix B, as implemented by Duke Topical Report paragraph
17.1.5.2.
This is considered to be another example of the
violation identified as 413/414/81-02-03, Inadequate Procedures.
(4) Spent Fuel Racks - Units 1 and 2
The inspector reviewed the following drawings related to the spent
fuel racks:
CN1210-5, CN1210-13, CN1210-14, CN1210-20 and
Westinghouse drawing 875-7051, sheet 20. He also reviewed draft
procedure CP384 for the drag load test of fuel storage and fuel
handling equipment, and Westinghouse fuel assembly interface
specification, F-8, relative to new and spent fuel racks.
The inspector examined welding related work and inspected spent
fuel racks in the spent fuel pools for alignment and configura-
tion. Discussions with engineers, welders and inspectors revealed
that they were adequately knowledgeable of requirements and their
duties.
Except as noted in paragraphs 11.e(2),(3) above, no violations were
identified.
12.
Nonconforming Item Report Evaluation
a.
Scope
The licensee's handling of the broken circuit breaker contact problem
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(discussed in paragraph 8.c.) as a series of isolated nonconformances,
without any apparent consideration of generic implications raised
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questions about the =aconformance review and evaluation process at the
site.
The inspectors reviewed the licensee's procedure for reporting and
evaluating nonconforming items.
This procedure, QAP Procedure Q-1,
,
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Control of Nonconforming Items, provides step-by-step instructions for
j
the initiation and processing of nonconforming items on NCI Report Form
Q-1A.
j
The inspectors next conducted a two part review of NCI Reports.
The
!
first part involved the review of r ecently initiated NCI's (those
listed in the past 3 to 4 months) to see if any trends or generic type
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of nonconformances could be identified.
The second part involved a
review of completed NCI Reports in the QA records vault to determine if
corrective actions and documentation appeared to be appropriate for the
nonconformances described.
b.
Active NCI's
The first nart of the review started with a review of the NCI Log Book,
followed by a review of the record copy of the NCI Reports for those
that were still being worked.
The inspectors immediately noted the
apparently large volume of NCI's being generated at the site - (The Log
indicated that NCI Number 9000 had been issued in July 1980 and number
10900 was issued during early February 1981 - This is nearly 300 NCI
Reports per month).
The subjects covered by these NCI's ranged from
relatively minor documentation problems through major problems with
safety-related hardware. This large volume of all types of problems
being handled in the same manner was pointed out to licensee management
as a possible contributor to the reason why generic items and/or trends
were apparently going unnoticed.
During the review of the active NCI's, the inspectors noted one NCI
(Number 10479 which described a linear indication the full length of
the outside surface of a piece of stainless steel pipe) on which the
originator had added a note to the effect that this was the same heat
of material as was reported on NCI 10311. The inspector found that NCI
10311 had been closed after the corrective action "These sections of
pipe shall be replaced and discarded" was accomplished, but that when
the pipe; identified in NCI 10479 was inspected in the pipe fabrication
shop, two other piping assemblies with the same problem were noted.
These assemplies had also been nonconformed (NCI's 10637 and 10638)
with the NCI containing a note to the effect that this was the same
heat of material as reported on NCI 10311 and 10479.
The only acknowledgement of generic implications was that NCI's 10311
and 10479 were assigned to construct'on for evaluation while 10637 and
10638 had been assigned to design.
The inspector's evaluation of the incications reported by these NCI's
was that they were a lack of fusion indication caused by improper
welding of this seamed stainless steel pipe.
NCI's 10637 and 10638
were initiated on January 3,
1981, and forwarded ta design for
evaluation on January 13, 1981.
At the time of the exit interview for this inspection on February 6,
1981, an evaluation from design had not been received and there had
been no hold put on the remaining material of the same heat which
remained in stock in the licensee's pipe storage area.
.
The handling of these NCI's was cited as one example of violation No.
414/81-02-04, Apparent Generic Items cr Trends Not Recognized nor
Forwarded to Management.
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During this review of NCI's, the inspectors noted a number of NCI's
which reported that-the inside surface or roct face of a weld or welds
did not meet ASME B&PV Code acceptance criteria even though the weld
had already been accepted by QC. These %'I's included one (NCI 9902)
which reported unacceptable root condition on a weld joint which the
weld history records showed had been repaired as the correction to NCI
9295, which reported unacceptable root condition on a previously
accepted weld.
Another significant NCI was number 10786 listing a number of welds,
accessible for internal visual inspection, which did not meet
acceptance criteria even though the welds had been accepted by QC
visual inspection.
This NCI also referenced the Authorized Nuclear
Inspectors Report of January 30, 1981, which listed other welds with
the same unacceptable root conditions.
All of the NCI's which reported these weld ID surface problems had
three things in common: Disposition was to repair as necessary; Report
to management was checked "N0"; and not one of the NCI's reviewed by
the inspectors questioned how the inspection of the root surface was
missed originally and what action would prevent recurrence.
This situation was particularly surprising for NCI No.10786 which was
. initiated by the QA group because of the apparent significance of the
problem, but when construction decided not to report to management, QA
approved this decision.
This problem with the apparent inadt:quate visual inspection of the
internal surfaces of piping welds was cited as another example of
Apparent Generic Items or Trends Not Recognized nor Forwarded to
- Management (Violation No. 413/81-02-02)
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c.
Completed f;CI's
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During the second part of the NCI review, the inspector selected NCI's
numbered 9900 through 10000 which had been completed and filed in the
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QA record vault.
During this review, the following i!CI's were
identified as problems to the licensee's QA personnel
,
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NCI 9926 reported that a wear collar ring for a penetration was
5/16-inch thick and the plan required a thickness of 0.5312 to
.
0.5938-inch.
The NCI was dispositioned by the same person that
l
originated it with the statement that the material was right and the
plan was right.
l
Discussion with the originator showed that the plan required dimensions
were obtained by subtracting diameters and should have been divided by
two to find the actual requirement, therefore, there was no need for
the NCI.
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NCI 9933 reported that a piping flow section did not meet smoothness
requirements. This NCI had been dispositioned on November 17, 1980, as
unacceptable, requiring refabrication. This disposition had been lined
out on December 17, 1980, and a new disposition " Acceptable as is"
added.
This change in disposition was done without any recorded
justification.
These two NCI's were cited as examples of violation No. 413/81-02-04,
Incomplete QA Documentation.
In this same group of NCI's, NCI 9959 was written concerning the fact
that an 8" class A weld (Weld No. INI-32-1) was welded with excessive
weld weave. The disposition required removal of improperly welded
material and reinstruction of the welder (s).
The inspector noted that the disposition did not require verification
of metal removal nor did it specify how much to remove. The question
of what other welds had been done by the welder (s) was not sked. A
review of the weld history record for this weld shows that the NCI
number was written on the weld joint record but there is no record of
any metal removal.
NCI 9984 was also noteworthy: it reported that an RHR pump unit had
apparently been fabricated improperly because when the seal water
flanges were unbolted, the piping moved out of alignment indicating
that when the unit was fabricated by Ingersoll-Rand for Westinghouse,
the piping was assembled with residual stresses caused by cold spring.
The documentation for this case showed that the corrective action was
to bend the piping to the proper configuration under the guidance of
'
' the Westinghouse site representative.
The NCI documentation did not
report how much movement was involved nor was there any provision for
control and documentation of the bending operation. As a result, there
was no evaluation to determine what effect, if any, the uncorrected
cold spring could have had on safe plant operation.
These two NCI's were considered to be additional examples of the
licensee's apparent lack of comprehensive evaluation of potentially
serious nonconformance situations. These will be considered a part of
Violation 413/81-02-02, Apparent Generic Items or Trends Not Recognized
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nor Forwarded to Management.
13.
Reporting of Deficiencies, Defects and Noncompliances (10 CFR 50.55(e) and
a.
General
The purpose of this inspection was to ascertain whether DPC, and
appropriate
responsible
officers,
established
and
implemented
procedures and other instructions as required to ensure compliance with
10 CFR Part 21, and 10 CFR 50.55(e) requirements relative to the
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evaluation and reporting of deficiencies, defects and noncompliances.
Inspector determinations are based on the requirements of 10 CFR Part 21 as c'.assified by staff positions in NUREG-302, Revision 1 and
additional IE guidance relative to 10 CFR 50.55(e).
b.
Documents Examined
(1) Procedure Q4-121, Rev. 2, June 1980, Nuclear Regulatory Commission
~
Reporting Requirements
(2) Procedure PR-202, Rev. O, November 1980, Design Nonconformance
(3) Procedure PR-220, Rev. 7, August 1980, Nonconforming Item Reports
,
(4) Procedure PR-290, Rev. 4, June 1980, Nuclear Regulatory Commission
Reporting Requirements
(5) Procedure Q-1, Rev.13, May 1980, Control of Nonconforming Items
(6) Procedure R-5, Rev. 2, June 1980, Nuclear Regulatory Commission
Reporting Requirements
c.
Program Review
The inspector reviewed the above controlling: procedures and verified
that procedures have been established to assure that the following
.
requirements of 10 CFR 21 will be met; the posting (21.6), evaluating
deviations (21.21(a)(1)), informing the director (21.21(b)), and to
assure that procurement documents specify that provisions of 10 CFR Part 21 will apply when apolicable (21.31), maintenance of records
(21.51(a)), and disposition of records (21.51(b)). The inspector also
verified that procedures have been established to assure that 10 CFR 50.55(e) identification, evaluation, and reporting requirements will be
met.
The inspector concluded that the procedures, if implemented by properly
trained personnel, could provide the necessary controls to implement
the evaluation and reporting requirements of 10 CFR 50.55(e) and 10 CFR
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Part 21.
l
The lack of properly trained personnel is discussed below.
d.
Program Implementation
The inspector. held discussions with management, QA technical support,
QC and craft personnel relative to NRC requirements, NRC guidance, and
DPC controlling procedures for the evaluation and reporting of
deficiencies, defects and nonconformances.
The inspector concluded
that the personnel did not have sufficient knowledge and understanding
of NRC evaluation and reporting reqirements.and NRC guidance.
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Therefnre, the procedures were not being properly implemented. This
lack of knowledge and understanding of the requirements is evidenced by
the following:
(1) Personnel do not understand when a basic component is considered
to be deli /ered.
(2) Personnel do not understand when Duke becomes the responsible
evaluating agent.
(3) Personnel do not know how responsible individuals are informed of
possibly reportable matters when the concerned individual is not
assigned as the evaluator.
f
(4) Review of site training records and discussions with site
personnel reflect that training sessions, 10 CFR 50.55(e)
given
by site QA to site QA on 10/22/79, and 10 CFR 50.55(e) and Part 21
- given by DPC management to site QA and Construction on 11/27/79,
consisted of presentations of only the direct words of regulations
with no reference to NUREG 0302. There was no handout guidance.
No 4dditional training was in evidence at the site even though a
complete revision of procedures, as noted in paragraph "b"
above
was completed in mid 1980.
It was evident that evaluating personnel were not questioning, if
a basic componenet was involved; where the component was used, if
the component performed a safety-related function, what were the
consequences, and if the items were generic.
10 CFR 50, Appendix B, Criterion II requires that the program
shall provide for training of personnel performing activities
affecting quality as necessary to a:sure that suitable proficiency
is achieved and maintained.
The lack of adequate ~ training
relative to NRC evaluation and reporting requirements for
deficiencies, defects and nonconformances is idcntified as a
violation (413/81-02-05 and 414/81-02-05).
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