ML20004E513

Forwards Response to NRC 810408 Ltr Re Violations Noted in IE Insp Repts 50-413/81-06 & 50-414/81-06.Corrective Actions:Design Nonconformance Procedure Implemented to Define Documentation & Reporting Requirements

ML20004E513
Person / Time
Site:	Catawba
Issue date:	05/01/1981
From:	Parker W DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20004E507	List: ML20004E511 ML20004E513
References
NUDOCS 8106120280
Download: ML20004E513 (4)

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ViCr PeCSooCNT IC((PMQNElAe(4 704 Straw Paooverion 373-4083 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II-101 Marietta Street, Auite 3100 Atlanta, Georgia 30303 Re: RII:

50-413/81-06 50-414/81-06

Dear.Mr. O'Reilly:

Please find attached a response to Infractions No. 413-414/81-06-03 and 413-414/81-06-04 which were identified in the above referenced Inspection Report. Duke Power Company does not consider any information contained in this inspection report to be proprietary.

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

Very truly yours,

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William O. Parker, Jr.

1 l RWO/mwk Attachment I cc: NRC - Catawba Resident Inspector i

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CATAWBA NUCLEAR STATION Notice of Violation 413/81-06-03 A. 10 CFR 50, Appendix B, Criterion XVI as implemented by Topical Report Duke 1-A, Section 17, paragraph 17.1.16 requires that the identification of any significant condition adverse to quality, the cause of the condi-tion, and the corrective action taken be documented and reported to appro-priate levels of management.

Contrary to the above, a significant condition adverse to qualify was

-not documented on March 12, 1981 in that inadequate design of Hanger No.

1-ANV-8255 was not documented and reported to appropriate levels of management.

Response

A significant condition adverse' to quality was not documented on March 12, 1981 in that the inadequate design of Hanger No. 1-ANV-8255 was not documented and reported to appropriate levels of management.

The design for Hanger No. 1-ANV-8255 was originally released April 11, 1980, after completion of analysis by " alternate analysis techniques" which required load restrsint in the vertical direction. Because of interferences inmediately above the pipe, a trapeze type support was designed. Trace heat insulation was accomodated by attaching a pipe clamp to the pipe with a box around the clamp to restrain the clamp in the direction of load; the box was then walded to the trapeze support. The support was installed on September 5, 1980.

In October, 1980, personnel from Duke's Design Engineering Iapartment who were in the vicinity of the hanger notice the possibility that the support configuration as installed could fail to function properly in the event some circumacance caused the pipe clamp to be positioned outside the surrounding box. Consequently, the hanger design was reviewed and a revised design was approved on December 29, 1980.

l Since the time that this condition was recognized, Duke has developed l

a procedure which defines the necessary documentation and reporting i

requirements for handling design nonconformances. The design non-l conformance procedures was knplemented on Novembar 7,1980, approxi-mately one month af ter the need for a review of the subject design was realized; therefore, this condition was not handled under the new pro-cedure. Any similar situation that may occur in the future would be handled as described in this new procedure.

Full compliance has been achieved.

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Violation 413/81-06-03 Page Two Item B. (2)

The Design Sketch 1-A-NI-4131, Revision 1, had the NF boundary drawn appropriately, bu e the number for the sway strut modification weld was omitted. According to our records, this was discovered during initial review of the sketch prior to release by site technical support.

A drawing revision was requested and subsequently received on April 8, 1981.

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CATAWBA' NUCLEAR STATION Notice of Violation 413/81-06-04 B. 10 CFR 50, Appendix B, Criterion V as implemented by Topical Report Duke 1-A, Sectica 17, paragraph 17.1.5 requires that activities af-facting quality be accomplished in accordance with established pro-cedures and also requires that drawings include appropriate quali-tative acceper. ace criteria for determining that important activities have been sccisfactorily accomplished. Duke Power Company procedure CP-385, Rev. 8, paragraph 2.11.2 requires hange s to be installed at an angular tolerance of i 4 . The Duke Power Company code of record for hanger installation (ASME Boiler and Pressure Vessel Code,Section III, Subsection NF, paragraph NF-1130) requires welds made to modify hangers to be performed in accordance with Subsection NF requirements.

Contrary to the above, activities affecting quality were not a;complish-ed in accordance with an established precedure and the drawing did not include appropriate qualitative acceptance criteria on March 18, 1981 in that:

(1) Hanger Nos. 1-R-NI-1487 and 1-R-NV-1764 were installed at an angle of 11 from the required angle.

(2) The drawing approved and issued for Hanger No. 1-A-NI-4136 did not specify the weld to shorten the sway strut assembly as an ASME weld.

Response

Duke Power acknowledges that:

(1) Hanger Nos. 1-R-NI-1487 and 1-R-NV-1764 were installed at an angle of 11 from the required angle.

i (2) The drawing approved and issued for Hanger No. 1-A-NI-4136 did not specify the weld to shorten the sway strut assembly as an ASME weld.

l Item B. (1)

Support Packages 1-R-NV-1764 and 1-R-NI-1487 were retrieved from our problem file which is a central storage location where the process control packages with identified problems are filed pending resolution.

Such problems can be identified during the document preparation, fabri-cation, installation, or inspection processes. A review of the process control forms for those supports shows that the inspections relevant to angular tolerance had not yet been perfor=ed. The out of tolerance con-dition observed by the inspector may have resulted from an installation error. Review of the process control forms will be complete by hot functional testing.

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