ML20009D943

Forwards Response to NRC 810410 Ltr Re Violations Noted in IE Insp Repts 50-413/81-02 & 50-414/81-02.Corrective Actions:New Block Installed on Volt Switchgear Breaker. Review Conducted of Sliding Base Support Requirements

ML20009D943
Person / Time
Site:	Catawba
Issue date:	06/25/1981
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20009D936	List: ML20009D943
References
NUDOCS 8107240518
Download: ML20009D943 (8)

Text

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DUKE POWER COFIPANY Powen BUILDING 422 SouTu CnuncIt STazar. CILARI.OTTE, N. C. 28242

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WILLIAM O. PA R K ER. .J R.

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"''$"3_js s7-$ E'o'o' c*rYo June 25, 1981 Mr. James P. O'Reilly, Director

b. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Ret RII:JCB 50-413/81-02 50-414/81-02

Dear Mr. O'Reilly:

Please find attached an amended response to Infraction Nos. 414/81-02-02 and 413-414/81-02-03 as identified in the above referenced Inspection Report.

D"ke Power Company does not consider any information contained in this inspec-tion report to be proprietary.

I declare under penalty of perjury, that the statements setforth herein are >

true and correct to the best of my knowledge.

Very truly yours, AL 0.

William O. Parker, Jr.

W RWO/php Attachment.

cc: NRC Resident Inspector Catawba Nuclear Station 8107240518 810701 PDR ACOCK 05000 ,

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

As a result of the inspection conducted on January 26 - February 6, 1961, and in accordance with the Intczim Enforcement Policy, 45 FR 66754 (Octobat 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 cond'tions adverse to quality. Design Engineer-ing Department Procedure DP-220, Nonconforming Item Reports, Section 2.2, requires the responsible Engineer to evaluate the nonconformance to ascer-tain 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 evalueted 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, '.0665, 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 Sevcrity Level IV Violation (Supplement II.D.2) applicable to Unit 2 only.

RESPONSE

1) Duke admits the violation.

2) This problem occurred because of unclear procedures and inconsistencies in training by persons responsible fer training. (See Response to Violation B in William O. Parker, Jr. letter of May 13, 1981.)

3) 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 comments are also included on Non-conforming Item Report 10727.

a) Non-conforming Item 9755 on a 4160 volt switchgear breaker serial number (50465E-1-10226) for 2ETAl2 was found in the switchgear cubicle by the Transmission Department to have a broken control contact block.

The breakage was considered to be isolated field damage based on dis-cussions between the responsible equipment engineee and site technical support engineer. A new block was purchased and installed on the breaker.

_2-DUKE POWER COMPANY CATAWBA NUCLEAR STATION NOTICE OF VIOLATION (Paragraph A)

RESPONSE

3) a) - continued The reportability was again reviewed and verified on 10/28/80 with final technical approval and verification of non-reportability on 10/29/80.

b) Non-Conforming Items 10665, 10684, 10721, 10727, 10745, and 10818 issued on six 600 volts laadcenter breakers with cracked arcing contacts were received by Design Engineering 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 an 2/3/81. The final determination of reportability was made on 2/10/81 and reported to NRC Region II on the sane day.

Non-Conforming Item 10752 issued on one 600 volt loadcenter breaker with cracked are chute retainer nolding was incorrectly included with the Non-Conforming 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 term 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 contact 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 cp reportable item and an evaluation was included in Report Number SD-50-413-414/81-02. The cracked are chute was evaluated and deter-mined not reportable. The control block and are chute breakage was evaluated to be due to breaker handling during long term storage and a general weakness of the breaker packaging.

c) It should be noted that the NRC Inspector reviewed these Non-Conforming 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 he alleged viola-tfon being made by the NRC. See Table 1 for detail 3.

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TABLE 1

'Cattwba-Switchgear and Loadcenter Breaker Nonconformance Reports Catawba Originated' Received Potential Reported 30 Day Note NCI! Senior Engr Review By Pwr Reportable To Report Number- QA Review Equip Group Item NRC Issued To SRAL Division 9755 10-10 10-10-80 10-14-80 10-22-80 N/A N/A N/A 1 10665 01-13-81 01-15-81 01-20-81 01-29-81 02-03-81 02-10-81 03-02-81 2 10684 01-15-81 01-15-81 01-20-81 01-29-81 02-03-81 02-10-81 03-02-81 2 10721 01-16-81 01-16-81 01-20-81 01-29-81 02-03-81 02-10-81 03-02-81 2

<10727 01-19-81 01-19-81 01-22-81 01-29-81 02-03-81 02-10-81 03-02-81 2 10745 01-20-81 01-20-81 01-22-81 01-29-81 02-03-81 02-10-81 03-02-81 2 10752 01-21-81 01-21-81 01-22-81 01-29-81 02-03-81 02-10-81 N/A 4 10818 01-26-81 .

01-26-81 01-26-81 02-02-81 02-03-81 02-10-81 03-02-81 2 10852'- 01-28-81 01-29-31 01-29-81 02-06-81 N/A 02-10-81 03-02-81 2,3

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TABLE 1 Catawba Switchgear and Loadcenter Breaker Nonconformance Reports Page 2

.Scepe of Nonconformance Reports C tawba Number

-NCI of Number Breakers 4160 Volt Switchgear 97.55 1 1 Switchgear breaker with broken control contact block.

600 Volt Loadcenter Breakers Arcing Contact Arc Con *. acts Blccks Chute Serial Nurber 10665 1 X (S) 50583-K1-13-02078 106d4 1 X (M) 50583-K1-12-04078 10721 1 X (M) 58583H3-11-01224 10727 1 X (lu) 50583H3-11-02224 10745 1 X (M) 50583111-12-01224 30752' 1 X 50583K3-11-01078 10818 'l X (M) 50583H1-12-02224 10852 8 X (M) 50583H1-12-03224 X 50583H1-11-01224 X (M) X 50583H1-11-02224 X (M) X 50583KJ-13-01073 E (M) X 50583H1-12-05224 X 50583193-12-01078 X 50583K3-11-02078 X (M) 50583H3-11-01224 M - Movable arcing contact.

S - Stationary arcing contact

TABLE 1 Catrvba Switchgear and Loadcenter Nonconformance Reports Prgu 3 Notes on Nonconformance Reports

1. NCI 9755 issued on a 4160 volt switchgear breaker Serial Number 50465E l-10226 with a cracked control contact block. Breakage was considered to be isolated field damage and not reportable.

2. NCI's 10684, 10721, 10727, 10745, and 10818 were issued on cracked moving arcing contacts for 600 volt loadcenter breakers. NCI 10665 was issued on a cracked stationary arcing contact for 600 volt loadcenter breaker.

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 loadcentar breakers with cracked arcing contacts, broken control contact blocks,9and 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 determined that these control blocks 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 are chute was evaluated and determined not reportable.

4. NCI-10752 issued on one 600 vol_ loadcenter bresker with cracked are 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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DUKE POWER' COMPANY CATAWBA NUCLEAR STATION NOTICE OF VIOLATION (Paragraph A)

RESPONSE - continued

4) 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 steps were completed on April 27, 1981.

5) Full compliance has now been ach'ieved.

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 Quality Assurance, Paragraph 17.1.5.2, requires that the acceptance criteria established by Design Engineering are incorporated in the instruc-tions, 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 thit all criteria have been met.

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

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1) Duke. admits the violation.

2) Erection and inspection personnel failed to comply with drawings during installation.

3) Details and Corrective Action:

Pressurizer Relief Tank Drawings CN-1050-6, R18 and CN-1050-7, R20 provide adequate instructions for installation of the special sliding support including a minimum accept-ance criteria of 3/4 iach clearance between the anchor bolt and support slot. Drawing CN-1050-6 shows the building location af the concrete support pad and anchor bolts. Section S-S is clearly noted. Drawing CN-1050-7 m _

s DUKE POWER COMPANY

. CATAWBA NUCLEAR STATION NOTICE OF VIOLATION (Paragraph C)

RESPONSE

3) - Continued 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 pressur-izer 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. A review of Design Engineering requirements for sliding base supports was conducted.

Partially Completed Work 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 lA, 1B, 2A, and 2B as stated. The fab-rication shop failed to install the correct size weld as required by the drawings and procedures, and inspectors failed to verify correct weld size before allowing the partially completed work to be transferred from the shop.

A re-inspection of all mechanical equipmer.t supports to the requirements of QAP M-18 (Inspection of Structure Steel Erection) has been completed by structural and welding inspectors to assure conformance with design drawings. The re-inspection did identify undersized welds on Containment Spray Heat Exchangers LA, 1B, 2A, and 2B. Non-conforming Item Report 9725 addresses this problem. The resolution for NCI 9725 failed to address the possibility of over-stressed welds due to loading by setting the equipment in place prior to weld completion. Non-conforming Item Report 11513 addresses the possibility of over-stressing the welds due to loading.

4) A. Pressurizer Relief Tank Erection and Inspection personnel will be trained in requirements of complying with Design documents.

B. Partially Completed Work To preclude any future problems a hold point will be placed in the equipment setting package per Procedure M-9 that will require structural inspection prior to equipment setting.

5) Full compliance will be achieved by September 1, 1981.

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