ML20091C270

Responds to NRC Re Violations Noted in IE Insp Repts 50-413/83-56 & 50-414/83-42.Corrective Actions:Cable Radii Will Be Inspected During Final Insp for Each Electric Sys & All Criterion Xvi Evaluations Will Be Reviewed

ML20091C270
Person / Time
Site:	Catawba
Issue date:	04/06/1984
From:	Tucker H DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20091B745	List: ML20091B779 ML20091C270
References
NUDOCS 8405300517
Download: ML20091C270 (4)

Text

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DUKE POWEh GOMPAhT P.O. BOX 30180 CHARLOTTE, N.C. 28242

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April 6, 1984 4/0: 26 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303 Re: RII:PKV/PHS 50-413/83-56 50-414/83-42

Dear Mr. O'Reilly:

Please find attached a response to Violation No. 413/83-56-03, as identified in the above referenced inspection report. -Duke Power Company does not consider any information contained in this inspection report to be proprietary.

Very truly yours, Ma 8 7kwer Hal B. Tucker /

LTP/php Attachment cc: NRC Resident Inspector Catawba Nuclear Station Mr. Robert Guild, Esq.

Attorney-at-Law P. O. Box 12097 Charleston, South Carolina 29412 Palmetto Alliance 21351 Devine Street Columbia, South Carolina 29205 8405300517 840514 PDRADOCK05000g Q

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W DUKE POWER COMPANY CATAWBA NUCLEAR STATION Item 413/03-56-03 Violation 10 CFR 50, Appendix B, Criterion V as implemented by Duke Power Company QA Topical Report Duke-1-A (Amendment 6), Section 17.1.5, requires that activities affecting quality be accomplished in accordance with procedures and instructions. Duke Construction QA Procedure R6, Rev. 1, Significant Corrective Action, requires evaluations to include a determination of the root cause of problems and a determination of generic implications.

Duke Construction QA Procedure Ql, Rev. 15, requires evaluations of non-conforming items to be complete and to address the problem identified.

Contrary to the above, nonconformance item reports were inadequately evalu-ated as indicated in the instances cited below:

A. On January 13, 1984, the inspector determined that the evaluation of electrical cable radius bend problems identified on R6A No. 352 f ailed to identify the actual root cause of the problem and stated that the problem was not generic and was non-repetitive when in fact, the problem was both generic and repetitive.

B. The evaluation of NCI No.13,522 was found to be incomplete on January 4, 1984, in that it did not address previous work performed by a craft person who had f alsified material traceability for a hanger.

Response

A. 1. We admit Part A of the violation.

2. The cause of the violation was failure to perform the Criterion XVI evaluation of the cable radius violation in the generic sense.

Instead, the evaluation only considered the problem stated on the NCIR: " Violation of cable bend radius specifications over motor control centers." Review of the evaluation by the Construc-tion Department Criterion XVI Coordinator failed to detect this error. The evaluation was then approved.

3. A subsequent re-evaluation of the cable bend radii throughout the plant has found violation of the radius criteria to be a ge-neric problem. To correct this problem the following steps have been implemented.

a. All cable radii will be inspected during our final walk inspec-tion procedure for each electrical system,

b. Violations noted during this inspection will documented, corrected, or reanalyzed for acceptance.

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c. All craft personnel involved in the installation of cable will be instructed in the requirements of the installation specification (CNS-1390.01-00-0022).

4. To ensure proper evaluations of all significant discrepancies requiring Criterion XVI evaluation, the following actions have been taken.

a. Selected experienced personnel have been designated to perform these evaluations. These individuals, normally at engineer or higher levels, are responsible for conducting an investi-gation of the problem and writing the formal report.

b. A review panel has been established at the Catawba site to review all newly evaluated Criterion XVI discrepancies. This panel, which meets weekly, consists of Construction Engineers from all disciplines, QA, and Craft representatives (optional).

The panels purpose is to ensure a generic review of all evalua-tions and to exchange knowledge of discrepancies across disci-plinary lines.

c. The previously mentioned steps along with the continuing pre-sence of the department Criterion XVI Coordinator enhances our abilities to perform the Criterion XVI evaluation.

d. All Criterion XVI Evaluations generated prior to February 1, 1984 will be reviewed for adequate consideration of generic implications.

5. a. Reinspection of all cable bend radii will be completed as systems are turned over to Nuclear Production.

b. Training of all craft personnel involved in cable installation is complete.

c. The Criterion XVI Evaluation review panel will begin meeting on March 2, 1984 and continue meeting until the Construction Department is assured that Criterion XVI evaluation process is properly understood and implemented by site personnel.

d. Review of all Criterion XVI evaluations completed prior to February 1, 1984 will be complete by June 1, 1984.

B. 1. We admit- Part (B) of the violation. NCI 13522 was resolved without investigating the responsible individual's past practices.

2. The cause of this violation was failure to perform a generic evalu-ation of this-individual's past work.

3. The disposition of NCI 13522 was reopened to address the indivi-dual's past practice. A specific sample of this employee's work cannot be defined for the following reason: Craft sign-off of

. . V process control for support / restraint erection is usually performed by hanger foremen, welding foremen, and crew lead craft person (s).

Since we could not sample his work, a series of interviews were conducted with fellow workers and inspectors responsible for in-specting his work. Of the individuals interviewed, no one had reason to suspect that the individual made a practice of this.

4. The review that an NCI receives now (QA Procedure Q-1) is designed to prevent reoccurrence of these type situations. No further corrective steps are required.

5. NCI 13522 has been reevaluated and closed out. Full compliance has been achieved.

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