ML20010E993

Responds to NRC 810720 Ltr Re Violations Noted in IE Insp Repts 50-413/81-14 & 50-414/81-14.Corrective Actions:Revised QA Procedure Q-1 & Other Appropriate Procedures to Require Investigation of Causes of Conditions Adverse to Quality

ML20010E993
Person / Time
Site:	Catawba
Issue date:	08/19/1981
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20010E990	List: ML20010E993
References
NUDOCS 8109090242
Download: ML20010E993 (3)

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'* 3.' Pc pr. DUKE POWER COMPANY s,_

~f' " ' POWER DUILDING 422 Sourn Cut acu STREET, CRARWTTE, N. C.2ea-sa b I ' "r: 'df A 8 3' WILLI AM Q. PA,R M ER, J R.

Vier PnEseorw? TELE PMO N E: AREA 704 SrEau Pacouctiow 373 4083 August 19, 1981 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission

-Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII: PKV 50-413/81-14 50-414/81-14

Dear Mr. O'Reilly:

Please find attached a response to Infraction No. 413-414/81-14-01 as l

identified in the above referenced Inspection Report. Duke Power Company l~ does not consider any information contained in this inspection report to be proprietary.

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

V y truly yours, Q ._, .s ..

LO .. . (LL William O. Parker, Jr.

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-Attachment ec: NRC Resident Inspector Catawba Nuclear Station 0109090242 810903

PDR ADOCK 05000413

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DUKE POWER COMPANY

. CATAWBA NUCLEAR STATION RESPONSE TO VIOLATION USNRC IE REPORTS 50-413/81-14 and 50-414/81-14 VIOLATION As a result of the inspection conducted on May 26 - June 25,1981, and in accor-dance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified.

10CFR 50, Appendix B, Criterion V, as implemented by Topical Report Duke 1-A, Section 17, paragraph 17.1.16 requires that activities affecting quality sSall be prescribed by procedures of a type appropriate to the ci rcumstances. Construction QA procedure Q-1 describes actions to be taken to correct noncon-forming items, to determine the cause, and to prevent repetition.

Contrary to the above, on June 18, 1981, procedure Q-1 did not l

properly address determination of cause for significant conditions adverse to quality on June 18, 1981. This resulted in the inade-quate specification of corrective action for Nonconforming item Report No.11746 which identified root weld defects for Class C Weld Nos. INV343-1, INV344-1 and INV341-1. Corrective action

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specified was only to repair the three welds identified and did not address the cause of the condition r4cr corrective action to preclude repetition.

RESPONSE

1. We admit that procedure Q-1 was incomplete. However our personnel had j been trained and were aware of the need to address generic considerations and to take correctP e action to preclude repetition of significant conditions adverse to quality, p 2. The specific occurrence cited in the violation occurred because l corrective action had already been initiated for the condition identified on Nonconforming item Report (NCl) No. 'l1,746 in the form of revised inspection procedures. Since the corrective action had been initiated, repair of the welds in question was specified wi thout res ta ting the correct 6 ve action. Additionally, because the condition was Judged to be insignificant, generic research into the cause was not considered necessary at that time.

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3. . The. corrective steps already taken include: :3

-a.- 'The-personnel involved have been cautioned of the' need for proper i evaluation of significance and cause when -resolving nonconformances.'

b. Thefresolution of NCI 11,746 has been rearitten to require further evaluation of this type condition by Design Engineering.

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14. Corrective steps'which will be taken are to revise QA procedure Q-1

! and other appropriate procedures to require, for significant conditions ,

adverse to quality, the cause to be investigated and determined to the extent practical and consistent.with the occurrence and corrective action to be specified on the resolution to the nonconformance.

5. Full compliance will be achieved by October 1, 1981. -

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