ML20138Q731

SALP Repts 50-413/85-42 & 50-414/85-44 for Mar 1984 - Sept 1985

ML20138Q731
Person / Time
Site:	Catawba
Issue date:	12/19/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138Q729	List: ML20138Q728 ML20138Q731
References
50-413-85-42, 50-414-85-44, NUDOCS 8512270438
Download: ML20138Q731 (40)

See also: IR 05000413/1985042

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NC 191985

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SALP BOARD REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION II

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT NUMBERS

50-413/85-42 AND 50-414/85-44

DUKE POWER COMPANY

CATAWBA NUCLEAR STATION UNITS 1 AND 2 ,

MARCH 1, 1984 THROUGH SEPTEMBER 30, 1985

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0512270438 851219

PDR ADOCK 05000413

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5$D 191985

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I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and to evaluate licensee performance based upon this

information. SALP is supplemental to normal regulatory processes used to

ensure compliance with NRC rules and regulations. SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to the licensee's management to

promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of the staff members listed below, met on

November 19, 1985, to review the collection of performance observations and

data to assess the licensee performance in accordance with the guidance in

NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A

summary of the guidance and evaluation criteria is provided in Section II of

this report.

This report is the SALP Board's assessment of the licensee's safety perform-

ance at Catawba for the period March 1, 1984 through September 30, 1985.

SALP Board for Catawba:

R. D. Walker, Director, Division of Reactor Projects (DRP), Region II

(RII) (Chairman)

J. P. Stohr, Director, Division of Radiation Safety and Safeguards

(DRSS), RII

A. F. Gibson, Director, Division of Reactor Safety (DRS), RII

T. M. Novak, Assistant Director, Division of Licensing, Office of Nuclear

Reactor Regulation (NRR)

V. L. Brownlee, Chief, Projects Branch 2, DRP, RII

Attendees at SALP Board Meeting:

D. M. Collins, Chief, Emergency Preparedness and Radiological Protection

Branch, DRSS, RII

K. P. Barr, Chief, Nuclear, Material Safety and Safeguards Branch, DRSS, RII

C. A. Julian, Acting Chief, Operations Branch, DRS, RII

H. C. Dance, Chief, Projects Section 2A, DRP, RII

K. D. Landis, Chief, Technical Support Staff, (TSS), DRP, RII ,

, G. A. Belisle, Acting Chief, Quality Assurance Program Section, DRS, RII

D. R. McGuire, Chief, Physical Security Section, DRSS, RII

F. Jape, Chief, Test Program Section, DRS, RII

T. E. Conlon, Chief, Plant Systems Section, DRS, RII

J. J. Blake, Chief, Materials and Processes Section, DRS, RII

C. M. Hoscy, Chief, Facilities Radiation Protection Section, DRSS, RII

P. H. Skinner, Senior Resident Inspector (Operations), Catawba, DRP, RII

P. K. Van Doorn, Senior Resident Inspector (Construction), Catawba, DRP, RII

K. N. Jabbour, Project Manager, Operating Reactors Branch 4, Division of

Licensing, NRR

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D. B. Gruber, Technical Support Inspector, TSS, DRP, RII

G. A. Pick,' Technical Support Inspector, TSS, DRP, RII

T. S..MacArthur, Radiation Specialist, TSS, DRP, RII j

L. it. Jackson, Reactor Inspector, Quality Assurance Programs Section,

DRS,-RII

F. R. McCoy, Reactor Engineer, Operational Programs Section, DRS, RII

II. CRITERIA l

Licensee performance is assessed in selected functional areas, depend % l

upon whether the facility is in a construction, preoperational, or operating

. phase. Each functional area normally represents areas which are significant l

to nuclear safety and the environment, and which are normal programmatic

areas.. Some functional areas may not be assessed because of little or no

licensee activities or lack of meaningful observations. Special areas may

be'added to highlight significant observations.

One or more of the following evaluation criteria was used to assess each

functional area.

A. Management involvement and control in assuring quality

B. Approach to resolution of technical issues from a safety standpoint

C. Responsiveness to NRC initiatives

D. Enforcement history

E. . Reporting and analysis of reportable events

F. Staffing (including management)

G. Training effectiveness and qualification

However, the SALP Board is not limited to these criteria and others may have

l been used where appropriate,

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Based upon the SALP Board assessment, each functional area evaluated is

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i classified into one of three performance categories. The definitions of

these performance categories are:

Category 1: Reduced NRC attention may be appropriate. Licensee management

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attention and involvement are aggressive and oriented toward nuclear safety;

l licensee resources are ample and effectively used so that a high level of

j performance with respect to operational safety or construction is being

achieved.

Category 2: NRC attention should be maintained at normal level. Licensee

management attention and involvement are evident and are concerned with

nuclear safety; licensee resources are adequate and are reasonably effective

so that satisfactory performance with respect to operational safety or

construction is being achieved.

Category 3: Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear

safety, but weaknesses are evident; licensee resources appear to be strained

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4 OEC 191985

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or not ef fectively used so that minimally satisfactory performance with

respect to operational safety or construction is being achieved.

The SALP Board has also categorized the performance trend over the course of

the SALP assessment period. The trend is meant to describe the general or

prevailing tendency (the performance gradient) during the SALP period. This >

. categorization is not a comparison between the current and previous SALP

rating; rather the categorization process involved a review of performance

during the current SALP period and categorization of the trend of perform-

ance during the period.only. The performance trends are defined as follows:

Improving: Licensee performance has generally improved over the course of  ;

the SALP assessment period.

Constant: Licensee performance has remained essentially constant over the <

course of the SALP assessment period.

Declining: Licensee performance has generally declined over the course of

the SALP assessment period.

'III.-SUMMARY OF RESULTS

Overall Facility Evaluation

Management' attention and involvement in both the remaining construction and

operating activities were evident as reflected by satisfactory performance l

.during this. review period. A continuing major strength in the construction

area as noted in the last SALP report was the dedication, at all levels,

toward producing quality work. Coordination of plant completion, checkout

of systems, and turnover of systems from construction to operations was well

organized and well managed. Management dedication had also been noted in

the operations area as well, as evidenced by their intimate involvement in

incident evaluations, frequent in plant visits, attendance at coordination

and status meetings, and regular overtime hours spent on site.

LThe licensee exhibited technical competence in understanding complex issues

and developing sound and thorough , resolutions. The licensee's approach to

ti.e resolution of technical issues was generally conservative and the

licensee was usually responsive to NRC initiatives. Weaknesses existed in

the operational Quality Assurance (QA) programs although some improvement

had been noted. This weakness was primarily identified in the area of the

corrective action program which was in the developmental process.

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No major deficiencies affecting licensing activities became apparent during

the evaluation faciod; however, Duke Power Company should focus on improving  ;

the quality and timeliness of submittals to the NRC.

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5/1/83- 3/1/84- Trend During

Functional Areas 2/28/84 9/30/85 This period

Operating Phase

~ Plant Operations Not Rated 2 Constant .

Radiological Controls Not Rated 2 Improving

Maintenance Not Rated 2 Constant

Surveillance Not Rated 2 Constant

. Fire Protection 2 1 Improving

Emergency Preparedness 2 2 Constant

' Security Not Rated 1 Constant

Quality Programs and

Administrative Controls

Affecting Quality (Operations) 3 2 Improving

' Licensing Activities 2 2 Constant

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Training (Units 1 and 2) Not Rated 2 Constant

Operator Licensing 3 Not Rated * -

Preoperational and

Startup Testing (Units.I and 2) 2 2 Improving

Construction Phase

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Soils and Foundations Not Rated Not Rated Not Rated

l Containment, Safety-

l Related Structures,

and Major Steel. Supports 2 1 Constant

Piping Systems and Supports '2 1 Improving

Safety-Related Components- 3

Mechanical Not Rated- 2 Constant

-Electrical Equipment and

l Cables 2 2 Constant

Instrumentation 2 2 Constant

Quality Programs and

Administrative Controls

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Affecting Quality

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(Construction) 1 2 Constant

• 0perator Licensing was included in Training for the current SALP

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IV. PERFORMANCE ANALYSIS

. Functional Areas For Operating Phase-

'A. Plant Operations

1. Analysis

During the evaluation period, routine inspections were performed

by the resident and regional based inspectors. Facility operation

reflected' consistent evidence of prior planning of activities and

assignment of priorities. Operational decisions were consistently

made at a level that ensures adequate management review.

Procedures and policies were rarely violated with most being

adequately written for the education and training required by the

user. A few inadequate procedures were identified, but this was

not considered excessive for a plant that had just begun opera-

tion.

The major accomplishment during this assessment period that

required the coordination of the total plant staff vis the

. preparation for plant operation including the satisfactory

completion - of the startup test program as discussed in another

section of this report. Significant operational events that

occurred - prior to initial criticality included a leak in the

reactor vessel head area due to an installation error while

assembling incore thermocouples and a manufacturing deficiency ,

associated with a potential loosening of control rod drive

mechanism set screws. Both of these events wer2 attrit utable to

vendor errors. Each required a short outage to correct the

conditions. Management took strong effective actions for these

probl en.s .

Following initial criticality, there were a total of 14 planned

and unplanned reactor trips ~during this period. Five of these

trips were performed as required by various test procedures during

the power ascension program. Three reactor trips were caused by

component malfunctions. One manual reactor trip was attributed to

a design deficiency in the main feedwater pump circuit. One

reactor trip was due to an unknown cause. The remaining four

trips were due to personnel errors, two attributable to instru-

mentation technician errors and two attributable to operator

errors. This was not considered excessive for initial startup and

power ascension testing.

Another significant operating event occurred in March 1985. A

xenon transient occurred due to extended operation with a control

rod being at the bottom of the core for a test, and subsequent

withdrawal of that rod at an undesired time. This caused flux

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tilting to occur with diverging nuclear instrumentation readings.

The utility considered readjustment of the instrumentation which

would have caused erroneous readings. Discussions with NRC

personnel and Westinghouse convinced the utility that readjustment

was not advisable. In addition to the events above, 23 of 24 of

the ice condenser doors were found in early January to be blocked

in a closed condition and in early February both trains of safety

injection were found to be inoperable for a short period of time.

Licensee inplant investigations were performed to assess and

provide recommended corrective actions for both reportable and

non-reportable events. During this reporting period, a total of

89 licensee event reports (LER) were reported. Of these LERs,19

were cttributed to operating personnel errors. This is not

abnormally high for a new plant. The LERs provided adequate

descriptions of an occurrence enabling other readers to understand

the activity. Corrective actions were generally thorough. Events

were generally reported in a timely manner. Licensee's responses

to NRC initiatives in this area were well received and acted upon

where required. An NRC evaluation of the quality of Catawba LERs

determined them to be above average.

Watchstanders in the control room were generally knowledgeable of

plant and system conditions. They were attentive to the require-

ments of their positions, assured complete turnover of information

prior to assuming the watch and, in general, performed in a

professional manner.

Unit 2 is currently preparing for operation. Significant discre-

pancies have not been identified. System turnovers have prog-

ressed satisfactorily with few exceptions existing at the

turnover. Staffing activities have already established sufficient

qualified personnel to support dual unit operation.

The violations identified below were not indicative of a pro-

gramatic breakdown but do indicate a need for constant management

awareness and review of activities that require detailed coordina-

tion,

a. Severity Level IV violation for failing to assure that the

lower ice condenser inlet doors were operable prior to

entering the mode for which they were required. (413/84-106)

b. Severity Level IV violation for failing to follow the procedure

which required verification that the ice condenser inlet door

blocks had been removed. (413/84-106)

c. Severity Level IV violation of Technical Specification (TS)

3.0.4 in which the plant was placed in mode 5 without meeting

the requirement to have both trains of the residual heat

removal system operable. (413/85-14)

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d. Severity Level IV violation for failure to fc ~ low procedures

l associated with the inoperability of diesel generator IB.

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e. Severity Level IV violation for failure to follow procedures

associated with control of keys. (413/84-87)

j 2._ Conclusion

j Category: 2

1 Trend During This Period: Constant

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-3. Board Recommendations

Performance in this area was not evaluated during the previous

SALP assessment. No change in the NRC inspection activity is

j . recommended.

l B. Radiological Controls

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1. Analysis-

During the evaluation period, inspections were conducted by the

resident and regional inspection staffs. NRC inspection effort in

t- this area was primarily directed towards startup procedures,

l startup shield surveys, and personnel qualifications and training.

' However, routine inspections were conducted in all phases of' the

radiation protection program. The licensee was responsive to the

inspection findings. No major weaknesses were -identified in the

!. radiation protection program.

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l The reduced operations including initial fuel load and startup

testing resulted in relatively low radiation levels in the plant.

l . Dose control as indicated by thermoluminescent' dosimetry measure-

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ment was adequate with a facility collective dose for the evalua-

tion period of 32.49 man rem. This low value was expected for a-

plant with little operating history.

The licensee had instituted a program to maintain radiation

exposure as low as reasonably achievable (ALARA) and was imple-

i menting the program for work performed during normal operations.

There have been no-major outages since the plant began initial

operation. Therefore, the ability to minimize exposures during

extensive radiological work had not been demonstrated.

i The qualifications of the plant health physics staff were accep-

table and met regulatory requirements. The licensee's health

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physics staffing level was adequate and compared favorably to

other utilities having a facility of similar size. An adequate

number of ANSI qualified licensee and ' contract health physics

technicians were available to support routine plant operations.

Early problems with reactor coolant leaks led to the contamination

of a number of plant areas. However, the licensee had implemented

an effective program to reduce the number of contaminated areas in

the facility. Contaminated areas previously identified were

reduced by approximately 30 percent.

Audits performed by the corporate health physics staff were

generally of sufficient scope and depth to identify problems and

adverse trends. Appropriate corrective actions were taken and

documented. The plant internal audit organization performs

reviews of the plant's health physics program. Although, these

audits are beyond regulatory requirements, the licensee is taking

action to improve the health physics expertise of the audit' staff

to insure technically adequate evaluations of the health physics

area.

During this evaluation period, the licensee had not disposed of

any solid radioactive waste. This can be attributed in part to

the implementation of an effective waste volume reduction program,

which included special training and waste segregation and sorting

areas. In addition, the licensee had only generated approximately

14,000 cubic feet of dry radioactive waste since plant startup and

had not solidified any spent resin to date.

In the area of radiological environmental monitoring, inspection

of the preoperational program disclosed that the program as

defined by the Final Safety Analysis Report (FSAR), the Environ-

mental Report-0perating License Stage, and the NRC Final Jnviron-

mental Statement had been adequately implemented. In conjunction

with an inspection of Duke Power Company's Oconee facility in

September 1984, Duke Power's Environmental Radiological Laboratory

(ERL), which also analyzes environmental samples from Catawba, was

inspected. During this inspection,,inadenuacles in the operation

of the ERL were identified. These included large sample backlog,

problems with personnel qualification .and staffing, large

quantities of solids in the water samples, and instrument

abnormalities caused by environmental conditions within the ERL.

Corporate management was usually involved with ERL activities and

the licensee was improving this area by involving corporate

specialists knowledgeable in radioanalytical techniques during

audits or " program assessments" cf ERL activities. Records were

generally complete, maintained, and available. Internal proce-

cures rarely were violated. Although key positions were identi-

fied with authorities and responsibilitjes defined, overall ERL

staffing was minimal as indicated by sample backlog problems and

substantial overtime. The laboratory staff was minimally

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acceptable in that only three out of six technicians had suffi-

cient experience to work independently in the radioanalytical lab.

Although, the licensee had developed a training and qualification

program to train the inexperienced technicians, prompt action had

not taken place until highlighted in an NRC inspection. In May

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1985, the ERL was again inspected. Actions taken by the licensee

to correct the inadequacies in the ERL were adequate; however,

licensee efforts were still ongoing to upgrade staff qualifica-

tions.

During the evaluation period, confirmatory measurement inspections

were conducted to evaluate the licensee's capability to conduct

analytical measurements of radionuclides in reactor coolant and

effluent process streams. The quality control program for these

radiological measurements met the guidance of Regulatory

Guide 4.15. The overall structure and procedures for quality

control were adequate; however, a need for closer management

review and timely resolution of technical problems was identified.

Inconsistencies of licensee results for gamma spectroscopy

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measurements of samples provided by the NRC reflected a need for

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improvement in the areas of counting room instrumentation and

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analytical techniques. Licensee results for strontium-89 and

strontium-90 were satisfactory; whereas, results for tritium and

iron 55 were inaccurate. A low systematic bias for tritium

results demonstrated the need for a more thorough review of

quality control data, subsequent identification of deficiencies,

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and implementation of adequate corrective actions by cognizant

individuals. The iron-55 analyses were performed by a vendor

laboratory, and the inaccurate results demonstrated the need for

improved review of the vendor laboratory's quality control program

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to ensure the validity of measurements.

, ,, Two inspections of the plant chemistry program occurred before

Unit 1 achieved criticality and were assessments of the measures

that had been taken to minimize steam generator corrosion. A

third inspection was an assessment of the effectiveness of these

measures during plant startup and during initial operation at 100

percent power.

Although some potential problem areas were identified in plant

design (especially the condensate polishers) and material

compatibility (copper moisture separator reheater tubes), the

secondary water system had been constructed in accordance with the

FSAR and appeared to be capable of minimizing ingress and trans-

port of corrosive material in the secondary coolant. The

licensee's program for surveillance and control of water chemistry

had boon developed to be consistent with the guidelines and

recommendations of the Steam Generator Owners' Group and was

acceptable. The licensee had not completed construction of all

chemistry laboratories and had not become fully qualified in the

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operation of some state-of-the-art analytical instrumentation when

the plant went commercial'; however, both endeavors were uo4 way

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in an acceptable manner.

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Abnormal chemistry conditions were encountered during the first

month of commercial operation. These events tested the design of

the plant, the licensee's monitoring system, and the licensee's

reactive procedures. Although deficiencies were identified,

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/ serious corrosion of the steam generator was prevented and several

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valuable lessons were learned. Positive measures were being taken

to upgrade the condensate ::leanup system and to train both

chemistrg and operations personnel in meeting the protective

criteria recommended by the Steam Generators Ownces Group.

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, Inspections were con' ducted for Unit 1 in the areas of preopera-

tional testing of . the radioactive waste systems, the ALARA

program, preoperational testing, process and effluent monitors,

and solid radioactive waste. The inspection program for liquid

and gaseous radioactive waste man:.gement involved both units. The

licensee's radioactive waste mansgement program was adequate.

No violations or deviations were identified.

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2. Conclusion

Category: 2

Trer.d During This Period: Improving

3. Board Recommendations

Performance in this area was not evaluated during the previous

SALP assessment. No change in the NRC inspection activity is

recommended.

C. Maintenance

1. Analysis

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During the evaluation period, routine inspections were performed

by the resident and regional inspection staffs. The maintenance

program appeared to be well organized with a well trained and

qualified staff. Maintenance training is addressed in Section J.

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Maintenance related decisions made at management levels were

q usually adequate to assure appropriate supervisory involvement.

Licensee resolutions to maintenance related technical issues

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generally showed clear and thorough understanding of the issues

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and were usually conservative and viable. Maintenance activities

generally exhibited evidence of adequate preplanning and assign-

ment of priorities.

An inspection of maintenance activities in March 1985, revealed a

somewhat high backlog of approximately 3,000 work requests, the

majority of which were low priority (type 3 and 4) work requests,

however, management appeared to have control of this backlog.

Procedures were generally adequate with a continuing effort to

locate and eliminate weaknesses. The licensee had a detailed

process for . completed maintenance record review, which generally

was very thorough and identified and corrected deficiencies

contained in their records. The process was adversely affected by

resource limitations which caused delays in performing record

reviews. It was noted that additional guidance and signature

requirements were required for instrument and electrical trouble-

shooting procedures and that the licensee had previously initiated

action to revise the procedures accordingly. Independent

verification was implemented in maintenance procedures in accord-

ance with Catawba Nuclear Station administrative requirements.

The use of procedures in accomplishing maintenance activities was

adequcte and procedures were detailed enough to allow proper

performance of the specified tasks.

The licensee's program for removal and restoration of equipment

was adequate.- Maintenance and operational personnel were suffi-

ciently knowledgeable of program requirements to allow for proper

implementation. Implementation of an equipment failure analysis

program was in developmental stages.

The violations listed below were identified and were not con-

sidered indicative of a programmatic breakdown but this area

should be monitored closely to assure procedure adherence.

a. Severity Level IV violation for a failure to follow proce-

dures associated with maintenance on a diesel generator

centrol panel component. (413/84-35)

b. Severity Level IV violation for failure to follow procedures

associated with torque switch settings on specific Rotork

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Electric Motor operated valves. (413/84-91)

c. Severity Level IV violation for a failure to assure adequate

testing was identified and performed following system

modification or maintenance. (413/84-95)

d. Severity Level IV violation for failure to follow procedure

to maintain cleanliness in a diesel generator room.

(413/85-20)

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2. Conclusion

Category: 2

Trend During This Period: Constant

3. Board Recommendations

Performance in -this area was not evaluated in the previous SALP

assessment. No change in the NRC inspection activity is recom-

s- mended. Continued licensee management attention to reduce the

maintenance backlog is recommended.

D. Surveillance

1. Analysis

During the evaluation . period, routine inspections were performed

by the resident and regional inspection staffs. The licensee

appeared to have an excellent program for scheduling surveillance

testing which identified surveillance requirements by due dates

and issued a weekly schedule. This program is computerized and

controlled by the integrated scheduling personnel. Tests were

normally completed on time in lieu of using extension periods,

although there were several instances where the component was

declared inoperable and appropriate corrective action taken until

the surveillance was completed.

Surveillance activities reflected adequate ~ preplanning and

assignment of priorities. Facility surveillance procedures were

usually adequate with few examples of deficiencies identified.

Surveillance activities were, in general, thorough and proper with

exceptions identified below. As with the maintenance records, the

surveillance records were given thorough reviews which sometimes

created a time lag in the document control effort.

In addition to the regularly performed surveillance activities

inspected, specific surveillance activities inspected were the

plant snubber program, core performance, and safety related cranes

and rigging. Procedures to implement the plant snubber testing

and operability checks were reviewed and found well stated in

establishing the testing requirements and acceptance criteria.

The review of scheduling and planning of snubber surveillance

indicate adequate management involvement and control. The

surveillance procedures for monitoring core performance were

reviewed and found acceptable. The surveillance procedures of

safety related cranes and rigging were acceptable to adequately

implement the ANSI requirements.

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Licensee resolution of surveillance related technical issues

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_ generally showed a clear and thorough understanding of the issuer.

-and was usually conservative and viable.

The violations and deviation listed below were identified and were

not considered indicative of a programmatic breakdown:

a. Severity Level IV violation for failure to follow the '

procedure while performing a surveillance on a residual heat

removal pump. (413/84-87)

b. Severity Level V violation for failure to adequately review

the results of a safety related battery surveillance test.

(413/85-14)

c. Severity Level V violation for failure to establish all

required measures to _ control measuring and test equipment.

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d. A deviation for. failure to test the diesel generators oat a

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peak load of 4100 kW. (413/84-87)

2. Conclusion

Category: 2

Trend During This. Period: Constant

3. Board Recommendations-

Performance in this. area was not evaluated in the previous SALP

assessment. No' change in the NRC inspection activity is recom-

mended.

E. Fire Protection

1. Analysis ,

During the evaluation period, inspections were performed by the

resident _ and regional inspection staffs. The fire protection

inspection history for Unit 1 consists of a regional pre-license

Appendix R fire protection team appraisal conducted in April 1984,

six routine followup inspections, and a second regional post-

license fire protection team inspection conducted in April 1985.

These inspections were conducted in the areas of fire prevention

and protection and the licensee's implementation of their commit-

ments reaarding the safe plant shutdown requirements and guide-

lines of 10 CFR 50 Appendix R and Standard Review Plan 9.5.1.

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The April 1984 Appendix R fire protection inspection identified

one deviation involving seismic supports for hydrogen gas piping

in the auxiliary building, a number of discrepancies associated

with the Standby Shutdown System, and. inadequacies of fire

detection and . suppression systems within a specific fire area.

The discrepancies were not identified as fire protection viola-

tions .since, at the time of the inspections, Unit I was not an

operating plant. To correct these discrepancies, the licensee

initiated prompt corrective actions and performed reevaluations of

several fire areas, revised and implemented numerous operational

procedures, completed required operator training, made several

plant modifications, and provided supplemental fire protection

submittals in support of the plant licensing effort. All of these

discrepant items have been' corrected.

These actions indicate an aggressive licensee program toward

achieving completion of work required to close out open fire

protection issues. Based on the results of followup inspections,

the licensee's present fire protection program for Unit 1 appeared

to be thorough and had adequately addressed those Appendix R

concerns identified in the initial inspections.

Considering the completeness of the licensee's fire protection

program and the prompt implementation of the corrective actions,

it was evident that the licensee assigned the appropriate

personnel at the site to assure the features met design require-

ments and commitments made to the NRC. In addition, the

licensee's corporate design staff conducted frequent site visits

to verify proper implementation of required features.

The operational fire protection and prevention. program for Unit 1

generally adhered to NRC guidelines. The administrative proce-

dures for control of. the program met NRC requirements. Adherence

to these procedures was satisfactory. The fire brigade was

. adequately organized and trained. Adequate fire brigade equipment

was available and appeared to be properly maintained. The fixed

fire detection and protection systems were being properly

maintained, inspected, and tested in accordance with technical

specifications.

In general, the licensee's performance in this area had improved

considerably over the assessment period. Upper management

provided the necessary support for implementation of the permanent

plant fire protection program and appeared to be aware of its

importance. The licensee's' response to NRC initiatives had been

timely. Fire protection events were promptly reported and

properly analyzed. Staffing of the fire protection organization

was adequate.

s.

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16 DEC 101985

The violation and deviation listed below were identified:

a. Severity Level V violation for failure to maintain a watch

and log of an impaired fire barrier. (413/85-04)

b. Deviation for failure to provide a seismically supported

hydrogen gas piping system to the reactor coolant pump drain

tank in the auxiliary and reactor buildings. (413/84-36)

2. Conclusion

Category: 1

Trend During This Period: Improving

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. Decreased NRC inspection activity in

this area is recommended.

F. Emergency Preparedness

1. Analysis

During the evaluation period, special and routine inspections were

conducted by the resident and regional inspection staff. An

evaluation of a small-scale exercise was conducted. Two Emergency

Plan revisions were reviewed by the regional staff.

Two post-appraisal inspections evaluated the licensee's responses

and corrective actions related to deficiencies, improvement items,

and incomplete areas identified during the emergency preparedness

appraisal conducted in November 1983. The licensee was responsive

to the appraisal findings. Their approach to the resolution of

the technical issues relating to the appraisal findings was

generally sound and thorough. The post-appraisal inspections also

disclosed improvements made in communications and coordination #

among the various groups comprising the onsite emergency response

organization.

The routine inspections and small scale exercise disclosed no

major deficiencies in emergency preparedness organization or

staffing. The corporate emergency planning organization was

adequately staffed and provided support to the station. Key

positions in the station emergency planning organization were

filled and personnel assigned to the emergency response organiza-

tion were, for the most part, adequately trained for their roles.

However, a review of training records for five newly assigned key

members of the emergency organization revealed that three had not

, ._.

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17 EC 191985

received appropriate training as required by the Emergency Plan.

This failure to follow the requirements of the Emergency Plan was

identified as a violation, as listed below. Training records of

shift supervisors indicated that required emergency training was

given in accordance with the Emergency Plan and its implementing

procedures, although the documentation of this training was of

.

marginal quality in terms of auditability. Individuals were

-

cognizant of their responsibilities and authorities and demon-

strated understanding of their assigned duties and functions

during simulated radiological emergency conditions.

The following elements of the emergency preparedness program were

inspected and determined to be adequate except as cited below:

Emergency Classification, Communications, Emergency Response

Training, Shift Staffing and Augmentation, Dose Projection and

Assessment, Changes to the Emergency Preparedness Program,

Coordination with Offsite Support Agencies, Annual Quality

Assurance Audits of Corporate and Plant Emergency Planning

Programs, and Emergency Preparedness Exercises and Drills. The

exercise demonstrated that the plan and required procedures could

be effectively implemented by the licensee's staff, although

several areas for improvement were noted by the NRC and the

licensee.

The violations listed below were not indicative of a programmatic

breakdown,

a. Severity Level -IV violation for failure to consistently

provide specialized training to individuals prior to assign-

ment to the onsite emergency organization (413/85-29).

b. Severity Level V violation for failure to implement a

procedure requirement to properly document emergency drill

findings (413/85-29).

2. Conclusion

Category: 2

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

W

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um

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18

DEC 191985

G. _ Security

1. Analysis ~

During the evaluation period, inspections were performed by the

resident and regional inspection staffs.

'

The licensee exhibited evidence of prior planning and assignment

of priorities both at the site and the corporate level. Manage-

- ment of the security program at both of these levels appeared

sound and _ well structured. This has resulted in a security

organization which appeared to be a professional, well supervised,

and appropriately staffed security force. In addition, because of

the site and corporate involvement, the licensee could quickly

take effective corrective actions on its own or NRC initiatives.

The licensee's Security Plan revisions reflected coordination

among various departments and a clear understanding of NRC

criteria and. implementing guidance.

A strong and independent corporate audit program was demonstrated

during this rating period. The most recent security audit was

thorough in that it covered a wide range of security responsibi-

lities including screening programs, contractor access authoriza-

tions, and offsite support from local 'aw enforcement agencies, in

addition to duties associated with the routine onsite security

program.

The onsite security force had been trained and appeared experi-

enced and confident in the conduct of its duties. The onsite

security force was supported by an extensive set of implementing

procedures. During this rating period, considerable inspection

effort was directed towards the performance of the security

personnel m backshift. They were found to be well managed and

effective. It was noted that compensatory measures (security

posts), in effect due to degraded barriers or alarms, needed to be

reduced. The licensee ' instituted a viable solution to this

problem which included allowing more nuclear station modifications

to be submitted by the security organization and setting a higher

priority on those modifications which would alleviate the need for

a security officer as a compensatory measure.

The violation listed below was identified by the licensee's

security force and was reported to the Region in a timely and

informative manner. It was not considered a major breakdown of

the licensee's overall security program. In correcting this

violation the licensee discovered an additional example of

unprotected vital equipment at this site and at another of its

facilities. The violation was considered indicative of a need for

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.

.

DEC 191985

39

a thorough and exhaustive review of all vital area barriers.

Another example of the same violation was disclosed in a later

report (413/85-33) during the assessment period. 'We note that the

licensee applied comprehensive corrective action to all three of

its licensed facilities instead of only to the site where the

problem was found demonstrating good corporate and site

coordination.

Severity Level IV violation concerning the failure to

maintain a vital area barrier (413/85-27).

2. Conclusion

Category: 1

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was not evaluated during the previous

SALP assessment. Decreased NRC inspection activity is recam-

mended.

H. Quality Programs and Administrative Controls Affecting Quality

(Operations)

.1. Analysis

During this evaluation period, inspections were performed by the

resident and regional inspection staffs. Areas inspected curing

this evaluation - period included the offsite support staff;

procurement; receipt, storage, and handling; surveillance testing

and calibration control; measuring and test equipment; audits;

Quality Assurance / Quality Control (QA/QC) administration; records;

document control; design control; and tests and experiments. The

primary emphasis of the above inspections was to verify imple-

mentation of the individual QA programs which were inspected

programmatically during the previous evaluation period.

Management involvcment and control in assuring quality was evident

by the use of adequately stated and understood policies. Reviews

were thorough and technically sound, but the process did not

appear to be timely due to the backlog of material that was being

reviewed. Procedures and policies were occasionally violated as

demonstrated by the violations identified. Procurement was

generally well controlled; however, there had been weaknesses

identified by the inspectors.

Responsiveness to NRC initiatives in this . area was generally

timely, but one specific longstanding issue involved implementa-

tion of a modified corrective action program. The NRC had

,

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.

20 DEC 191985

identified that the licensee's program for evaluation of problems,

documentation' of problems, and reportability reviews was margin-

ally acceptable. The licensee has conducted an extensive task

force review of this area and has developed a Problem Investiga-

tion . Report System to address the weaknesses identified, This

program a'ppeared to be an excellent proposal; however, it had yet

to be . implemented approximately one year after the weaknesses

. described above had been identified.

Strong management support for the Operations Quality Assurance

Department was exemplified by a significant increase in personnel

in the QA' Surveillance group, including a plan for extensive

training for these personnel, and special initiatives such as QA

Forum and QA Circles meetings.

The offsite support staff appeared adequately trained and staffed.

Training was primarily on-the-job. An effort was being made to

increase the amount of formal training.

. In the area of procurement, there was a positive feedback system

between those who specify technical ordering data on purchase -

requisitions and the Corporate Procurement Department. Li kewi se,

the licensee's receipt, storage, and handling of safety-related

materials was viewed as above average. Procedures were well

written, detailed, and striccly followed.

The licensee's records and document control programs appeared

adequate. Management had dedicated appropriate resources in the

records area. For the most part, controlled :opies of drawings

and procedures were kept up-to-date. However, in one area

inspected, clerks were allowing one month of drawing revisions to

accumulate before entering them in their controlled files.

The areas of design control and tests and experiments were being

managed in a technically sound manner. The design change program

had apparent improvement in all areas. Test data associated with

the licensee's test and experiments program were thorough and

technically sound.

Although only one violation and deviation was assigned to this

area, other violations in the areas of maintenance, components,

and piping systems were also indicative of QA problems in the

broad sense of the term.

The violation and deviation listed below were identified:

Severity Level IV violation for failure to prevent use of

teflon tape in radiation areas (413/84-104, 414/84-46).

A deviation from a commitment to remove all teflon tape from

the auxiliary building (413/85-20).

5

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,

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.

21 dEC 191985

2. Conclusion:

- Category: 2

Trend During This Period: Improving

3. Board Recommendations

, Performance in this area was evaluated as Category 3 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

I. Licensing Activities

-

1. Analysis

a. Management Involvement in Assuring Quality

There was evidence 'of prior planning and assignment of

priorities and decisien making was at a level that ensured

management review. Well stated, controlled, and explicit

procedures were in place for control of activities. The

licensee's resources were generally ample and used in such a

manner that a high level of attention was brcught to bear on

design and engineering issues needing expedited resolution.

Reviews were timely, thorough, and technically sound.

Mar,agement involvement was evident in the environmental and

seismic equipment qualification, diesel generator, fire

protection, hydrogen, and main steam line break reviews.

Management participation and involvement were evident in

various meetings with the staff and during several site

visits by NRC management.

One area where management attention appeared inadequate was

in the " Justification for No Significant Hazards Determina-

tion" submitted with proposed technical specification

amendments. Additional technical basis would be appropriate.

.

b. Approach to Resolution of Technical Issues from a Safety

Standpoint

,

The licensee demonstrated understanding of the technical

issues and their responses were generally sound and thorough.

The licensee carefully studied each NRC question or position

for impact on the plant prior to taking action. Conservatism

was generally exhibited, and approaches were generally sound

and thorough. This was demonstrated clearly in the resolu-

tion of issues related to fire protection, diesel generator,

equipment qualification, hydrogen and main steam line break

submittals,

s.

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__

.

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.

22

DEC 19 1985

DPC seemed to follow closely the regulatory environment and

took an active role from safety standpoints. DPC has

. consistently taken the lead for the nuclear industry to help

resolve . matters of generic concern. For example, DPC has

participated in the Westinghouse Owners Group for the -steam

generator tube rupture and small-break LOCA methods.

One area needing improvement was the amount of detail in the 1

discussion of safety consequences in submittals related to

technical specification changes.

During a Unit 1 blackout event caused by operator error, the

licensee personnel uncovered design interface problems

between the electrical systems of both units. In addition,

the event showed interface inadequacies between the operators

of both units. DPC moved aggressively to resolve these

problems,

c. Responsiveness to NRC Initiatives

In a majority of cases, the licensee provided timely responses

to NRC positions and requests for information. Responses to

technical issues were generally complete and timely. The

licensee had been efficient in responding to follow-on

questions. Acceptable resolutions were initially proposed in

most cases. This was evident in the control room design

review site audit, equipment qualification, diesel generator,

hydrogen, and main steam line break submittals.

The licensee was always ready to meet with the staff when

such a meeting would assist in resolving issues and explaining

designs or positions. On a number of occasions the licensee,

on its own initiative, met with the staff to discuss their

. proposed submittals to assure that the submittals would be

completely responsive to staff's positions prior to transmitt-

ing them to the NRC. In addition, the licensee was responsive

to staff surveys and investigations, such as the surveys on

operator training.

DPC attempts to meet deadlines and notifies NRC when they

cannot be met. However, it appeared that the licensee was

more responsive to those issues that DPC considered as having

higher priority (those issues affecting plant operation).

Issues to which DPC assigned lower priority frequently

required schedule extensions.

2. Conclusion

l

Category: 2

~ Trend During This Period: Constant

i

i

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.

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23 DEC 191985

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

J. Training (Unit I and 2)

1. Analysis

During the assessment period, routine inspections of plant

' training programs were performed by the regional and resident

inspection staffs. A special team asse:sment of the Catawba

training program was conducted to determine the effectiveness of

the licensee's overall training program in supporting the safe

operation of the plant. Although several weaknesses were identi-

fied in various areas of training, the training of plant personnel

was determined to be acceptable.

Management continued to be responsive to NRC initiatives and

concerns and had aggressively sought improvements to plant

training programs. A review of licensee actions on previous

enforcement matters related to training reflected that actions

taken were complete and adequate.

During this SALP period, it was noted that past Nuclear Equipment

Operator Qualification Checklist had a large number of sign-offs

on a single day. The licensee has taken action to revise the task

list completion to preclude this type of record keeping process

through management control and review of task training documenta-

tion.

Seven site visits were made to Catawba for licensing examinations

of operators and senior operators on Unit 1. A total of 52 Senior

Reactor Operator (SRO) examinations and 36 Reactor Operator (RO)-

examinations were administered. The pass rates were 77 percent

and 80.5 percent respectively for R0 and SR0 examinations. These

pass rates compare favorably with the industry average.

During this reporting period, one of two scheduled site visits was

made to administer examinations of Unit 1 operators for eligi-

bility to operate Unit 2. Examinations were administered consistent

with 10 CFR 55.24 which allowed for waiver of all portions of the '

examination except for orals limited to plant differences.

Subsequent results of the two examinations demonstrated satisfactory

training program administration and thus amendment of licenses for

dual unit operation.

The licensee's general employee training, Shift Technical Advisor

training, engineer / professional development training, management

training, and management technical training were considered

• .

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. ',

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DEC 191985

24

adequate. Maintenance training was effective, with the exception

of a lack of .a defined requalification or retraining program and

the establishment of a formal program for feedback of operating

experience. The licensee's development of the Employee Training

~

Qualification System was satisfactory as a means of formalizing a

technician's qualifications.

The licensee continued to maintain a. training program for the

plant health physics technicians and had established a qualifica-

tion testing and acceptance program for contract health physics

technicians. These programs were instrumental in upgrading the

technical competence of the health physics staff.

Recognizing that training is . applicable to all SALP functional

areas, comments are also provided in Functional Areas for

Operating Phase, Section F, Emergency Preparedness; Section H,

Quality Programs and Administrative Controls Affecting Quality;

and Section K, Preoperational and Startup Testing. Additional

comments are aise to be found under Functional Areas for Construc-

tion Phase, Section D, Safety Related Components - Mechanical;

Section E, Electrical Equip. ment and Cables; and Section F,

Instrumentation.

The violations and deviation listed below were identified and were

not considered indicative of a programmatic breakdown.

a. Severity Level 'IV violation for not establishing specific

plant procedures or instructions governing Cold License

Certifi:ation Observation training. (413/84-45)

b. Severity Level V violation for failing to provide training to

fuel handling personnel as described in the license.

(413/84-33)

c. Deviation, in two instances where the Cold Certification

Observation Check Li st was incorrectly documented as

complete. (413/84-45)

2. Conclusion

Category: 2

Trend During This Period: Constant '

3. Board Recommendations

Performance in this area was not evaluated during the previous

SALP assessment. Performance for Operator Licensing was evaluated

as Category 3 during the previous SALP assessment and was included

in Training for the current SALP assessment. No change in the NRC

inspection activity is recommended.

l

.

.

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DEC 1o 1995

25

K. Preoperational and Startup Testing (Units 1 and 2)

1. Analysis

During the review period, routine inspections were performed by

the resident and regional inspection staffs. Routine inspections

of test procedures, test witnessing, and evaluation of the

licensee's administrative controls which govern the conduct of the

preoperational test program were performed. A general improvement

from the last evaluation period was noted in the areas of document-

ing test results and providing more precise quantitative and

qualitative acceptance criteria in preoperational test procedures.

Major Unit 1 testing accomplished included Engineered Safeguards

Tests and Reactor Protection System Tests. The conduct of this

integrated testing was well coordinated between operating, engineer-

ing, and test personnel indicating prior planning and management

control. The Engineered Safeguards Test revealed problems with

several system valves not obtaining their emergency position,

valve response times were not met in all cases, and diesel

generator 1A tripped after emergency equipment was sequenced onto

the diesel generator. Maintenance was performed on the above

equipment and retesting was satisfactorily completed. The

licensee was responsive to NRC concerns in this area and took

prompt corrective actions.

Unit 1 thermal expansion and vibration tests were also performed

during the evaluation period. One violation was identified in

that licensee engineers did not follow the procedure to establish

test prerequisites which required final piping system hangers to

be installed and temporary hangers to be removed. In addition,

the ~ test records were incorrect as the test data sheets did not

reflect actual test conditions. The above problems were a repeat

of a similar occurrence that had been brought to the licensee's

attention during an inspectior, in November 1983. The licensee's

corrective action program was not effective since this problem

should have been identified by the licensee and corrected prior to

the inspection in September 1984. The licensee repeated the

vibration test to correct this problem. This action to resolve

the violation was technically sound and thorough.

The licensee continued with the performance of the preoperational

test program for Unit 2 with a scheduled completion date of early

January 1986. Major Unit 2 precperational tests completed during

the evaluation period included the reactor coolant system cold

hydrostatic test and containment integrated leak rate test. There

were problems with systems preparation for the cold hydrostatic

test and a lack of coordination and management control among the

groups in charge of the test. These problems, as indicated by two

violations described below, were contributing factors when portions

of the residual heat removal system were overpressurized and again

i

be

- -- - _ _ . . _ - _ _ . -

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.

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26 DEC 191985

when the volume control tank and portions of the chemical and

volume control system were also overpressurized. A lack of

conservatism was also demonstrated when, after the first over-

pressure incident, the decision was made to continue with the

hydrostatic test without thoroughly reviewing all systems and

components within the test boundary to ensure that adequate

overpressure protection had been provided. After the second over-

pressure incident, the licensee reviewed the problems which led to

the two incidents and took appropriate corrective actions. The

test was then successfully completed without further problems.

With the exceptien of problems identified during the reactor

coolant system cold hydrostatic test, the training and qualifica-

tion of test personnel appeared to be effective. This was

indicated by the absence of personnel errors during test perform-

ances and demonstrated understanding of the administrative controls

and requirements as they relate to the preoperational test program.

During this period, the Unit 2 integrated hot functional testing

was started and currently is in its final stages. Integrated hot

functional testing had experienced minor instrument calibration

and equipment problems. These problems were resolved in a timely

manner and only minor delays in the hot functional test schedule

were ancountered. Management involvement and control in assuring

quality was evident by well stated and defined procedures.

Records were complete, legible, and well maintained. Staffing and

training of the licensee's inspection, operations, test, and

maintenance personnel were adequate. The effectiveness of the

corrective actions taken to resolve the management control and

coordination problems present during the cold hydrostatic test

were evident during hot functional testing. The interface,

coordination, and communication among the various groups involved

in the hot functional testing were very good. This has resulted

in test and maintenance activities being completed with minimal

schedule delays. The effectiveness of the licensee's corrective

action program was also demonstrated in the thermal expansion and

vibration testing program in that considerable effort was expended

to avoid problems encountered during Unit I hot functional testing.

The corrective actions were technically sound, thorough, and

conservative.

Management involvement and control in assuring quality was

generally adequate in the Unit 2 integrated leak rate test. Prior

planning and assignment of priorities were observed in review of

test preparations and test procedures. Resolution of technical

issues and responsiveness to NRC issues were adequate in that

certain criteria and statements in the test procedure which were

unacceptable to the NRC were readily resolved. Further, the

licensee committed to upgrading the data acquisition system to

eliminate continuing computer and instrumentation problems which

make the analysis of the test more difficult. Although Duke has

'. .

DEC 19 1985

27

-continued its practice of assigning a new engineer as test

director for each integrated leak rate test, continuity and

experience were provided through the involvement of corporate

engineers who have participated in multiple leak rate tests.

The fuel handling and startup testing procedures were generally

acceptable at the time of first review. In the few cases where

procedural improvement was required, the corrective action was

prompt and effective. Initial fuel loading was accomplished in a

safe efficient manner with strict adherence to procedures. The

fueling crews included the proper number of licensed individuals.

All equipment generally functioned properly. There were few

problems due primarily to management controls and adequate pre-

planning. Startup tests were performed in strict adherence to

-procedures. Coordination of test activities between different

groups, for example, reactor engineering and operations, was

adequate and effective. The analyses of test results were

performed promptly and generally adequately. In the few cases

where additional analysis was requested, the additional work was

performed thoroughly and with dispatch.

The violations and deviations listed below were identified and

were not_ indicative of a programmatic breakdown.

a. Severity Level IV violation for failure to follow test

procedure prerequisites requiring final piping system hangers

be installed and temporary hangers removed prior to conduc-

ting pipe vibration tests. (413/84-92)

.b. Severity Level IV violation for inadequate procedure and

failure to follow the procedure which resulted in over-

pressurization of portions of the residual heat removal

system during cold hydrostatic testing. (414/85-12)

c. Severity Level IV violation for inadequate procedure which

resulted in overpressurization of the volume control tank and

portions of the chemical and volume control system during

cold hydrostatic testing. (414/85-12)

d. Deviation for failure to provide a component cooling water

system vent path as committed to in LER 413/84-14.

(413/84-102)

e. Deviation in that the reactor vessel level indicating system

was not fully operational by initial criticality as committed

to in the FSAR. (413/85-05)

i

s.

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28 DEC 191985

2. Conclusion

Category: 2

Trend During This Period: Improving

3. Board Recommendations

Performance in this area (Preoperational Testing) was evaluated as

Category 2 during -the previous SALP assessment. No change in the

NRC inspection activity is recommended.

Functional Areas For Construction Phase

A. Soils and Foundations

1. Analysis

Construction activity in this area was complete. No NRC inspec-

tions ner: parfnemad during this evaluation period.

2. Conclusion

The lack of inspection activity in this area precludes an assess-

ment of licensee performance.

B. Containment, Safety-Related Structures, and Major Steel Supports

1. Analysis

During the evaluation period, inspections were performed in this

area by the regional inspection staff. The inspections involved

the review of weld fabrication records of selected supports for

the pressurizer, steam generators A and D, the reactor vessel,

feedwater piping, polar bridge crane, main steam lines, and

containment spray heat exchanger. Also covered was examination of

the concrete laboratory, a walkdown inspection of concrete repairs

made on all structures in the Unit 1 power block and the annulus

of the Unit 2 Containment building, preparation for a concrete

placement around the Unit 2 pressurizer, followup of a concrete

honeycomb matter, and review of a licensee identified item concern-

ing repair material in abandoned drill holes in concrete having an

adverse affect on the capacity of anchors in or near the abandoned

drill hole. Review of the latter determined that the licensee -

performed a thorough investigation of the problem and that proper

,

'

measures were taken to correct and prevent recurrence of the

problem. Observations showed that the concrete laboratory was

being controlled in accordance with procedure requirements and

that concrete placements and repairs were being made in accordance

with procedure and specification requirements.

, t

- -

- - - - ,- - . . _ . - - - .- ,. -- . _ - . - .

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,

.

DEC 191985

29

'The inspectors found that audits were complete and thorough, audit

findings were reviewed. and their resolution technically sound,

quality records were complete and retrievable, procedures were

technically sound, and procurement appeared to be well controlled

and documented. The licensee's approach to the resolution of

-technical issue. was generally conservative and timely. Events

were reported in a timely manner and the corrective action was

generally satisfactory. Key positions were generally staffed with

well trained and qualified personnel.

Follevap of the unresolved item concerning identification of

concrete honeycomb disclosed a violation of procedure requirements

listed below:

Severity Level IV violation for failure to identify concrete

honeycomb in a timely manner. (413/84-49 and 414/84-23)

2. Conclusion

Category: 1

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended. -

C. Piping Systems and Supports

-1. Analysis

During this evaluation period, inspections were performed by the

l resident and regional inspection staffs. The majority of the

. piping and pipe support installation work had been completed prior

to the start of this evaluation period, thus the inspection

activities were directed toward the as-built verification program

required by IE Bulletin 79-14.

Understanding of technical issues was generally apparent.

Resolutions were timely, viable, usually technically sound, and

demonstrated a conservative approach. This is evidenced by

licensee reviews of several Construction Deficiency Reports (CDRs)

in this area cnd generic evaluations of hanger discrepancies which

had been identified by the licensee and NRC.

• .

. _.

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30 DEC 191983

The completion of hanger installation and system turnovers has

progressed exceptionally well for Unit 2. Systems have been

turned over with relatively few exceptions. The milestone

management concept developed by the licensee to better coordinate

plant completion has apparently come to full fruition for Unit 2.

The violation listed below was identified and involved minor

hanger discrepancies.

Severity Level IV violation for failure to install hangers in

accordance with applicable drawings ar.d procedures.

(413/84-100)

2. Conclusion

Category: 1

Trend During This Period: Improving

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

D. Safety-Related Components - Mechanical

1. Analysis

During this evaluation period, routine inspections were performed

by the resident and regional inspection staffs. Since little

installation activity occurred during this SALP period, primary

inspection effort was directed at storage, protection, and

maintenance of components. Regular observations of components

were conducted during routine plant tours with no problems being

identified.

Licensee management- involvement in safety-related component

activities appeared satisfactory and decision making was at the

level that assured adequate management review. Corporate manage-

ment was involved in site activities; for example, replacement of

the volume control tank and repair of safety injection system

accumulator tank 2.D. Reviews were timely and technically sound.

Records were complete, well maintained, and easily retrievable.

Field work procedures and QA program policies were generally

adhered to.

• .

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DEC 19 Igg 5

Corrective action systems recognized and addressed concerns.

Understanding of technical issues was apparent as evidenced by

actions taken on the above-mentioned components. Their resolu-

tions were generally timely, viable, and technically sound. Key

positions were identified ' with lines. of authority and related

responsibilities well defined.

The licensee's training and qualification program in this area was

responsive to regulatory and code requirements. It was imple-

mented by personnel who were properly- trained and certified to

specific disciplines. This helped to assure adherence to pro-

cedures and minimize personnel errors.

The violation listed below identified failure to implement storage

inspection requirements for component cooling pumps. It was

determined that the lack of inspections were not detrimental to

the pumps.

Severity Level IV violation for failure to implement adequate

storage inspections for component cooling pumps. (413/84-44,

414/84-21)

2. Conclusion-

Category: 2

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was not evaluated during the previous

SALP assessment. No change in the NRC inspection activity is

recommended.

E. Electrical Equipment and Cables

1. Analysis

During the evaluation period, inspections were performed by the

resident and regional inspection staffs.

The resolution of technical issues from licensee's nonconformance

reports and-10 CFR 50.55(e) reports were reviewed. The licensee's

performance in this area generally demonstrated that events were

properly identified, analyzed, evaluated, and that corrective

actions were considered appropriate for the circumstances. During

this evaluation period, the licensee's corrective action for _ two

previous violations, (1) cable installation-instructions not being

followed and (2) procedural adequacy for protective relay adjust-

ment activities, that remained open from the previous evaluation

.

. .

.

-

.

32 EU 1 9 1985

period were inspected and closed satisfactorily. The licensee's

-sitie management was actively involved with resolution of these

technical issues.

The licensee's quality assurance and quality control personnel in

this functional area were well qualified for their jobs and

knowledgeable in procedural requirements. Staffing in this area

was adequate for the level of construction activity.

The deviation listed below involved diesel generator drive hubs

which had not been corrected as committed to by the licensee.

This oversight was brought to the licensees attention by the

resident inspector. The deviation was not indicative of a

programmatic breakdown in this area. It was considered to be the

result of personnel not paying sufficient attention to detail,

failure to- prepare adequate procedures, or a lapse in training

which should have kept personnel aware of requirements.

Deviation for failure to perform corrective action committed

to in CDR 414/84-03. (414/84-47)

2. Conclusion

Category: 2

Trend During This Period: Constant

3. Paard Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection activity

attention is recommended.

F. Instrumentation

1. Analysis

During this evaluation period, inspections were performed by the

resident and regional inspection staffs.

The licensee issued procedures which control the instrumentation

program. These procedures had been reviewed and were adequate.

The licensee's resolution of technical issues identified by the

NRC and construction deficiency reports were handled in a timely

manner, with full consideration given to the issues and satis-

factory corrective actions. The licensee's staff, both QA and

craft, were trained for their specific work area. Craft training

was conducted by the craft foremen. The craft were trained to the

site procedures and specifications including the latest revisions.

s.

. . . _ _ _ _ ._- . _ - - -

.

<

.

,

-

.

DEC 191985

33

The QA staff was qualified and training was conducted to maintain

the qualification current. The licensee staffing appeared more

than adequate for the status of work in progress.

The violations listed below were identified. A violation involving

, isolation valves in the instrument air lines indicated a continuing

[ problem relative to the adequacy of instrument installation

'

instructions provided by design engineering. Similar problems

were observed in the past, but a general improvement was noted.

The violations are not indicative of a programmatic failure.

I a. Severity Level IV violation for installing non-safety related

isolation valves in instrument air lines for safety related

valves. (413/84-33 and 414/84-19)

b. Severity Level V violation for failure to maintain records of

protection and maintenance of instruments after installation.

(414/85-28)

l 2. Conclusion

Category: 2

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was evaluated as Category 2 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

G. Quality Programs and Administrative Controls Affecting Quality

(Construction)

1. Analysis

During this evaluation period, inspections were performed by the

resident and re'gional inspection staffs. Corporate and site

inspections were performed.

Management involvement in assuring quality appeared evident.

Quality assurance reviews relative to system turnovers appeared to

be extensive and .well coordinated. The QA Improvement Programs,

QA Forum Programs and QA Circles Program, previously implemented

continued during this period. Transition from construction QA to

operations QA relative to program and personnel was well coordi-

nated.

.

1

[.

-

.

-

.

34 DEC 191935

The licensee submitted two quality assurance program updates as

required by 10 CFR 50.55(f) describing changes to the Duke Power

Company Topical Report, Quality Assurance Program, DUKE-1-A.

Region II's letter dated July 30, 1985, accepted Amendment 9 of

DUKE-1-A.

The former Senior QA Supervisor, Audit Division, had his title

changed to "QA Manager" to coincide with the other four managers

in the QA Department. The former QA Manager.of Technical Services

was appointed to supervise a new Management and Technical Services

(MATS) group. The QA Manager, Vendors, assumed responsibility for

review, approval, and control of vendor and procurement quality

assurance records. The control of vendor documents was formerly

the responsibility of Technical Services. This should strengthen

the control of vendor documents.

In general, management resolution of issues identified by NRC and

licensee CDRs was thorough and timely. One deviation was issued

for failure to submit an updated CDR. Although violations were

'--

issued in this area, programmatic breakdowns were not evident and

most issues involved were relatively minor. One violation resulted

in reclassification of an unresolved item from a previous SALP

period. One violation involving adequacy of interface between

welder supervision and craft personnel involved extensive

evaluation by the licensee and was associated with a supplemental

hearing issue. called " Foreman Ove ride." An inspection at the

corporate' office identified a violation involving failure to audit

vendors triennially. This did not appear to be a programmatic

breakdown.

The violations and deviation listed below were identified:

a. Severity Level IV violation for failure to assure purchased

equipment met procurement documents. (413/84-28 and

414/84-16)

b. Severity Level IV violation for failure to adequately. control

interface between supervision and craft resulting in an

environment in which some welding crews perceived that QA

requirements could be suspended to meet schedule require-

ments. (413/84-88 and 414/84-39)

c. Severity Level IV violation for failure to perform triennial

audits of vendors. (414/85-08)

d. Severity Level V Violation for failure to establish measures

to ensure purchased structures meet specifications and

drawing requirements. (413/84-56 and 414/84-26)

l

1

L ]

_

.

.

DEC 191S85

35

,

e. Severity Level V violation for failure ta maintain records

for fuel pool cleanliness as required. (413/84-33)

f .' Deviation for failure to submit an updated CDR. (414/84-38)

'2. Conclusion

Category: 2

Trend During This Period: Constant

3. Board Recommendations

Performance in this area was evaluated as Category 1 during the

previous SALP assessment. No change in the NRC inspection

activity is recommended.

V. SUPPORTING DATA AND. SUMMARIES

A. Licensee Activities

Major activities for Catawba 1 included the satisfactory completion of

construction, preoperational testing, ini tial fuel load and crit-

icality, startup test program, and commencement of commercial opera-

tion. Each of these activities are milestones that involved the

coordination of the plant and corporato staffs.

Construction activities at Catawba 2 continued teward 99% completion

throughout the review period along with preoperational testing which

included hot functional testing. Primary construction activities

involved piping systems and supports, support systems, electrical power

supply and distribution, and instrumentation and control systems. In

addition, most of the new fuel for Unit 2 was received during this

period with licensing scheduled for early 1986.

During preparation for primary system cold hydrostatic testing of

Unit 2, the volume control tank catastrophically failed and the

residual heat removal, boron recycle, nuclear sampling, and chemical

volume control systems were overpressurized. The volume control tank

was replaced and an engineering analysis was performed to determine

acceptability for service for the other systems.

B. Inspection Activities

During the assessment period, routine inspections were performed at the

facility by the resident and regional inspection staffs. In addition,

a number of special team assessments and inspections were conducted

during this period:

_

.

,

.

-

36 DEC 191985

50 percent power operational readiness

technical specification review

training assessment

• procedure review

fire protection team inspection

• ~

emergency preparedness

quality assurance

C. Licensing Activisies

The NRC licensing ~ activities during the evaluation period included the

following actions:

Unit 1 Fuel Loading and Precriticality Testing License, July 18,

1984-

Amendment 1 to the above License, Technical Specification Change,

September 24, 1984

Unit 1 Low Power License, December 6,1984

Unit 1 Full Power License, January 17, 1985

.

In support of these actions, the staff issued three supplements to the

Catawba SER. They are:

SSER 2 - June 1984

SSER 3 - July 1984

-SSER 4 - December 1984

The assessment on licensing activities was based on the following

licensing actions:

Instrumentation and Controls

ICCI

Technical Specifications

Equipment Qualification

SALEM ATWS

_ Control Room Design Review

Fire Protection

Containment Systems

Shift Staffing

Inservice Inspection and Testing

Startup Test Program

Emergency Preparedness

TDI Diesel Generators

Hydrogen

s.

.

,

'.

37 0$0101985

Main Steam Line Break

SPDS

Leak-Before-Break Exemption s

Emergency Operating Procedures

Standby Shutdown System

License Amendments for Technical Specifications Changes

Preoperational Testing

D. Investigation and Allegation Review

Fourteen allegations were reviewed during the assessment period. Five

of the allegations were concerned with personnel problems, four dealt

with welding matters, three were brought forward at the Atomic Safety

and Licensing Board hearings during in-camera sessions. The remaining

two allegations were not within the purview of the NRC. At the end of

the evaluation period, no allegations were outstanding. -

E. Escalated Enforcement Actions

1. Civil Penalties

A Severity Level II violation civil penalty in the amount of

$64,000 was issued on August 13, 1985, for employee discrimina-

tion. The violation was denied. IE/ ELD is presently evaluating

DPC response.

2. Orders '

.

None.

F. Management Conferences Held During Appraisal Period

A management meeting was held in the Region II office on March 13,

1984, to discuss Duke Power Company's evaluation of the foreman

override issue.

A management meeting was held in the Region II office on August 15,

1984, to discuss the design and operation of the Standby Shutdown

Facility for the Catawba, McGuire, and Oconee plants.

A management neeting was held at the site or October 26, 1984, to brief

the NRC Chairman and Region II Administrator on the current and planned

activities for the Catawba facility.

A management meeting was held at the site on June 4,1984, to permit

NRC management a first-hand review of the operational readiness of

Unit 1.

A management meeting was held at the site on June 20, 1984, to provide

the NRC Region II Administrator the opportunity to visit Catawba and

.

meet with corporate and plant management.

5

rr -

.

.

,

..

DEC 191985

38

-

.An enforcement conference - was held in the Region II office on

" . February 8,1985, to discuss the physical blocking of the ice condenser

>'

..

inlet doors.

.

An enforcement conference was held in the Region II office on July 3. .

s 1985; to discuss the breach of a vital area barrier.

G. Review of~ Licensee Event Reports

,

bl. Construction Deficiency Reports

There were 17 Construction Deficiency Reports (CDRs) reported for

Unit l' and 30 CDRs reported for Unit 2 during this evaluation

period. These items involved piping systems and components,

structures, electrical equipment, instrumentation, support systems

and several vendor problems associated with the diesel generators.

Generally, reports were submitted in a timely manner and were

generally complete, accurate, and specified effective corrective

'

, actions. Three exceptions from the conditions described

-

involved: one case of incomplete information, one case of not

submitting a supplemental report as committed, and one case of not

-

~ completing a committed corrective action.

.

2. Licensee Event Reports

s, During the assessment period, there were 89 Licensee Event Reports

i;  :(LERs) reported for Unit 1. Of these 89 LERs, 67 were analyzed

for event cause by the NRC staff. The results of this analysis

1

q . are as follows:

s1 ,

'

..1 ~ Cause Unit 1

, .

'-

$l' -

Component Failure 13

.

Design 6

ti Construction, Fabrication, 5

'

, or Installation

+4 '

Personnel

'

,- Operating Activity 12

-

Maintenance Activity 11

s- -

Test / Calibration 13

<

-

Other 3

,

Out of Calibration 1

! Other 3

TOTAL 67

'

3. 10 CFR Part 21 Reports

, ,

j

y None,

j

r- .

I (

'

>

e m.

- - . __ _ . - _ - _ .

_ . _ _ _ . _ _ . . _ . . . _ _ - _ . _ _ _ _ _ _ _ _ _ - - _ .. _ ._ _ _ _ _____.

l[: '1-'

,

L ,

.

p! 39

l DEC 19 1985

_

"

,

H. Enforcement Activity

!.

"

-

Catawba 1

1

E

V: ..

'

I' '

Number of Violati.ons

, in Each Severity Level

Functional .

Area. l V l IV lIII l II l I l Deviations {

F l I i l i I i

Plant Operations- l l 5 l- l l l

l l l l l I

L Radiological Controls l l l l l l

[ l l I I I l

Maintenance l l 4l l l l

[-

=

,

1 I I l- 1 I

i_

'

-Surveillance l2 1 1l l l l 1

'

I i l l I I

Fire Protection l1 l l l l l 1

I I I I I I

.

Emergency Preparedness l1 1 1l l l l

l 1 I i l l

Security- l l 1l l l l

'

'

l I l i I l

Quality Programs and l l l l l l

Administrative Controls

'

l l l l l l

Affecting Quality l2 l 3l l l l 1

l 1 l i l I

Licensing Activities l l l l l l

'

I I I I I I

-Training l1 l 1l l l l 1

i I I I I I I

Praoperational and Startup l l 1l l l l 2

Testing l l l l l l

l l i I I I

Soils and Foundations l l l l l l

1 l l l l l

Containment, S/R Structures and l l l l l l

Major Steel Supports l l 1l l l l

1 I I I I i

' Piping Systems and Supports l l 1l l l l

l l l 1 I i

Safety Related Components - l l 1l l l l

Mechanical l l l l l l

l 1 1 I I I

Electrical Equipment-and Cables l l l l l l

1 I I l 1 I

. Instrumentation l l 1-[ l l l

l 1 I I I I

TOTAL l7 l 21 l 0l 0l 0l 6

i,

_ . . . _ _ - _ . _ - _ -

_

_ _ _ - -

____

, . OTC'19 1985

,-- . 40

k

h

h ;-- Catawba 2

w

Number of Violations

in Each Severity Level

Functional

Area lV l IV lIII l II I I l Deviations

I' I I I I I I

,

Soils and Foundations l l l l l l

l l l l l l I

! -

Containment, S/R Structures, I l 1-l l l l

I. and Major Steel Supports l l l- l l l

l' I I I I I i

b- Piping Systems and Supports l ;l l l l l

I I l l I l l

k Safety-Related Components - l l 1l l l l

i

f Mechanical l l l l l l

l l~ l l I l

,

_ Electrical Equipment _ l l l l l l 1

L and Cables l l l l l l

l l 1 'l i I I

Instrumentation i1 l 1l l l l-

I I I I I I

i

1

-

-Qualtty Programs and

-

l l [ l l l

!

Admiriistrative Controls l l l l l l

j Affecting Quality - Construction l 1 l 4l l l l 1

r i i I I I I

l Preoperational and Startup Tc M ng l l 2l l l l

L. I i l l I l

! 2

TOTAL. l2 l 9l 0l 0l 0l

l

_ .-