ML20076L666

Petition Per 10CFR2.206 to Modify CP to Require Independent Contractor Review of as-built Conditions,Design Deficiencies & Qa/Qc Program & to Require Mgt Audit.Certificate of Svc Encl

ML20076L666
Person / Time
Site:	Catawba
Issue date:	09/14/1983
From:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
To:	Asselstine J, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
NUDOCS 8309190025
Download: ML20076L666 (528)

Text

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. 00cgET t,1~"UMBER cp Sj GOVERNMENT ACCOUNTABILITY PROJECT -

Institute for PolicyStudies 00CNETED

1901 Que Street N.W., Washington, D.C. 20009 USMC (202)234-9382 September 14, 1 SEP 16 A!0:58 Honorable Nunzio Palladino, Chairman OFFICE OF SECRETARY Honorable Victor Gilinsky CCCKE'TmG A SEHvici, BRANCH Honorable James Asselstine Honorable Thomas Roberts Honorable Frederick Bernthal United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Commissioners:

On behalf of the Palmetto Alliance, the Government Accounta-bility Project (" GAP") of the Institute for Policy Studies ("IPS")

through its Citizens' Clinic requests that the Nuclear Regulatory Commission ("NRC") take immediate action to protect the future health and safety of the public in and around the Charlotte, North Carolina area through the following actions:

(1) Modify the construction permit (Catawba Units 1 and 2) to include a mandatory review by an independent contractor of the following:1/

(a) The actual "as-built" condition of the Catawba facility, done through a 100% reinspection of the safety-related areas of the plant; (b) the design deficiencies and the breakdown in the design change control systems which render the design, as approved in the Final Safety Analysis Report, inaccurate and incomplete, and (c) the quality assurance / quality control program which has existed with major weaknesses at the Catawba facility since the beginning of construction.

(2) A management audit of the Catawba upper and mid-level managers responsible for both design and implementation of the Catawba quality control / quality assurance program.

b! GAP requests, that the review be conducted by an independent contractor

! using criteria set forth in the 1981 letter from Chairman Palladino to Congressmen Dingell and Ottinger. Specifically, this criteria sets forth i the independence and competence criteria as follows: (1) technical competence of the company and the individual companies and assurance that (2) the contractor had no previous activities at the plant, (3) that the

contractor had no previous cmployment with the licensee, (4) that no I individual employee had been employed previously by the licensee, (5) that neither the company nor employees owned or controlled licensee stock, and (6) that members of the present households of the employees 1 l

were not employed by the licensee.

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NRC Commissioners s Page Two Further, GAP requests that the Commissioners direct the Office of Investigations (OI) to conduct a complete and thorough investiga-tion into the deliberate mishandling by Duke Power Company (DPC) ,

management of certain serious complaints by Catawba welding inspectors (infra, 41 ) to determine possible violations of 10 C.F.R. Part 21, 10 C.F.R. . Part 19, and the Department of Labor provisions 29 C.F.R. Part 24 S 210 which prohibits licensees from harassing, intimidating, or in any other way discriminating against

- nuclear employees for revealing construction problems which they believe may lead to safety concerns.

. Finally, GAP requests that the Commission review the on-going internal investigation by the Office of Inspector and Auditor (OIA) to insure that the scope of that investigation includes conduct by Regional officials, including the Region II administrator, which

$s directly contrary to NRC rules and regulations.

Background

The Government Accountability Project is a project of the Institute for Policy Studies, Washington, D.C. The purpose of the program is to broaden the understanding of the vital role of the public employee, private citizen, and nuclear worker in preventing health and safety dangers, corruption, fraud, waste and other abuses.

GAP of fers legal and strategic counsel to whistleblowers, provides a unique legal education for law student interns, brings meaningful and significant reform to the government workplace, and exposes government actions that are repressive, wasteful or illegal, or that pose a threat to the health and safety of the American public.

Presently, tJun Project provides a program of multi-level assistance for government employees, citizens and corporate employees who report illegal, improper, or wasteful actions. GAP also regularly monitors governmental reforms, offers expertise to Executive Branch offices and agencies and state and local government bodies, and responds to requests by Congress and state legislatures for analysis of legisla-tion to make government more accountable. The Citizens Clinic for Accountable Government of GAP responds directly to requests for assistance from community groups, local government bodies, and individuals who are facing difficult struggles against the federal government, large corporations, or other entities that seek to

. repress or intimidate the individual struggles for fairness and equity.

The Project is not an " anti-nuclear" organization. Our involve-ment with nuclear power plants began at the William H. Zimmer Power Sta-tion in Ohio. At Zimmer the information provided to GAP, and through GAP to the NRC, led in part to a stop-work order being issued by the Commission on November 12, 1982. This information was compiled over a period of two years by GAP investigators from dozens of workers within the utility and within the contractor.

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-NRC Commissioners e Page Three Other - cases that GAP has been ~ involved in within the nuclear industry include the Midland Nuclear Power Plant in Midland, Michigan; the LaSalle Nuclear Generating Station in Illinois; and more recently. '

the ~ crippled reactor at Three Mile Island. Other requests for our

, assistance have come .from whistleblowers across the nation and ,

- citizens ' concerned about the safety of the nuclear plants being built in their communities.

In March 1983 the Palmotto Alliance, Mr. Robert Guild, Esq. ,

and Mr. Ron McAffee, a former Catawba worker whose experiences.with the ' applicant and the NRC staff is well-known to the Catawba Licensing Board,. brought the apparent problens Eat Catawba- to our attention.

They. had questions about "whistleblowing," . quality assurance issues, the lessons GAP had learned at the Zimmer plant, and our other nuclear industry experiences. Mr. Guild detailed the status of the inter-vention proceeding in the Catawba case. At our request he provided us with background information about Catawba. Two staff attorneys and the Citizens' Clinic Director and staff associates initially reviewed the case information.

Based on the information that we had already reviewed as well as1 documents that surf aced late in discovery to Mr. Guild, we deter- .

! mined that (1) there had been. a significant breakdown in the quality assurance / quality control' ("QA/QC") program implementat, ion at the Catawba plant, and'(2) the Nuclear Regulatory Commission Regional Inspection and Enforcement ("I&E") staff failed to take appropriate action to determine the extent of- the quality assurance breakdown at

- the Catawba facility.

On April 21, 1983 our organization requested that the Office of Investigations ("OI") - conduct an investigation into the handling of the complaints . of -harassment and intimidation of welding QC inspectors at the Catawba site. The complaints were brought to our attention through the~ information provided to the Palmetto Alliance during discove ry . We also announced publicly that we were conducting an independent investigation of the Catawba f acility.

4 GAP has now concluded a preliminary - review of the Catawba plant.

The analysis included a review of the documents on the- public record,

- a review 'of testimony presented in discovery depositions of NRC and DPC personnel 1(including a DPC former corporate quality assurance manager, on temporary assignment to the Institute for Nuclear Power Operations (INPO) ) , and information received from DPC Catawba employees.. ~

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NRC Commissioners Page Four e

GAP will continue its indep'endent investigation, concentrating on the concerns of DPC workers about quality control / quality assurance procedural breakdowns; as well as continue to monitor NRC staff

• efforts at resolving the issues we have raised. .

II. LEGAL BASIS A. Legal Requirements '

The law gives the Commission broad discretion to revoke, suspend, or modify the construction permit of an NRC licensee. 42 U.S.C. S 2236

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states that:

A license or construction permit may be revoked, suspended or modified in whole or in part, for any material false statement in the application for license or in the supplemental or other statement of f act required by the applicant; or because of conditions revealed by the application for license or statement of fact or any report, record, inspection, or other means which would warrant the Commission to refuse to grant a license on an original application; or for failure to construct or operate a facility in accordance with the terms of the construction permit of license or the technical specifications in the application;, or for ' the violation of or f ailure to observe any of che terms and provisions of this chapter or of any regulation of the Commission.

Part 50. 100 of Title 10 of the Code of Federal Regulations states the same criteria for the revocation, suspension or modification of a construction permit.

The NRC has a mandatory duty to exercise this authority when necessary. According to the decision in Natural Resources Defense Council vs. U.S. Nuclear Regulatory Commission, 528 F.2d 166 (2d Cir.

1978), under the Atomic Energy Act of 1954, the NRC is required to determine that there will be adequate protection of the health and safety of the public. The issue of safety must be resolved before the Commission.. issues a construction permit. (Porter City Ch. of Izaak Walton Le' ague-vs. Atomic Energy Commission, 515 F.2d 513, 524 (7th Cir. 1975).)

B. Criteria to Exercise Discretion According to 10 C.F.R. S 2.202, the NRC "may institute a pro-ceeding to modify, suspend or revoke a license or for such other action as may be_ proper by serving of the licensee an order to show cc se which will: (1)- allege the violations with which the licensee is charged, or the potentially hazardous-conditions or other facts

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NRC Commissioners i Page Five deemed to be sufficient grounds for the proposed action. " As interpreted by the Proposed General Statement of Policy and Procedure for Enforcement Action, published in the Federal Register, ,

44 Fed. Reg. 66754, Oct. 7, 1980 (10 C.F.R. S 2.202, 2.204), sus-penHfng orders can be used to remove a threat to the public health and safety to the common defense and to the securitv of the environment.

More specif,ically, suspension orders can be issued to stop facility construction when further work would preclude or significantly hinder the identification and correction of an improperly constructed safety-related system or component; or if the licensee's quality assurance program implementation is not adequate and effective to provide confidence that construction activities are being properly carried out. Moreover, orders can be issued when the licensee has not responded adequately to other enforcement action or when the licensee interferes with the conduct of an inspection or investigation or for any reason not mentioned above for which the license revocation is legally authorized. In order to help determino the significance of violations within this list, the Consdssion established " severity categories" ranging from the most serious structural flaws (Severity I) ,

to minor technicalities (Severity VI). 44 Fed. Reg. at 66758-59.

III. SPECIFIC BASIS FOR SUSPENSION - QUALITY CONTROL BREAKDOWN The Commission clearly has both the duty and the discretion to modify the Catawba Construction Permit. or to take whatever other actions are deemed necessary to insure that Catawba is constructed in accordance with 10 C.F.R. requirements.

As discussed below the results of our preliminary analysis reveal that the current regulatory program does not conf ront the causes, the extent, or the continuing nature of the QA breakdown at Catawba.2/

A. Failure to Ensure that the As-Built Condition of the Plant Refle s the Final Version of an Acceptable Design Criterion III - Design Control A basic requirement of 10 C.F.R. 50, Appendix B, Crittrivn III --

Design Control, is that construction must reflect the final, approved design. Measures shall be established to: (1) assure that appropriate regulatory quality standards are specified in design documents and deviations from such standards are controlled; (2) select and review, for suitability of application, essential (safety-related) materials, parts, equipment and processes, (3) identify and control design inter-faces and coordinate among participating design organizations; (4) verify or check the adequacy of design.

2/ The evidence presented in the petition is illustrative, not comprehensive.  !

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NRC Commiccicnero Pcg3 Six e

Design changes, including field changes, . shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates '.

another responsible organization.

Catawba design documentation does not reflect the plant as designed, and it is unclear whether it reflects the plant as-built.

Substantial documentation from Duke Power itself, and confirmation from workers leaves no doubt that . Catawba's design and field engineers built this plant "by the seat of their pants," not by the book.

An audit, or a "self-initiated" evaluation using INPO methodology, was conducted from September to October 1982. It is attached and incorporated in its entirety as Attachment # 1.

The following recommendations emerge from Section B, " Improvements Were- Recommended in a Number of Areas: The Following are the Most Importan t: "

(DC.1) 1. Procedure for th'e responsibility, issuance, and control of Design input needs to be formalized. (supra, p. 2a)

(DC.2) 2. Coordination on Design changes between the design disciplines should be improved.- (p. 2a)

(DC.4) }. Formal program is needed to review design documents to assure constructability, maintainability, and operability.(p.2a)

These recommendations result from the following findings:

(DC.1-1) No requirement exists for . identifying, tracking, and assuring that commitments identified in the PSAR are met. Design information should be clearly defined and controlled.

.- (supra, p. 7)

(DC.1-2) No control program for defining responsibility for providi.ng Design input-could be found. Input is usually provided on a request basis. (p. 7)

(DC.1-3) Design input information is not always provided in a controlled manner. Memoranda serve as the primary vehicle for documenting Design input. (p. 7)

(DC.1-4) System descriptions and flow diagrams do not always L agree as to the current requirements. Several system descriptions

! were observed to' lag revisions of system ilow diagrams. (p.7)

(DC. 1-5) No documented program was found for assuring correct application of seismic response spectra. (p . 7)

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NRC Commissioners Page Seven o

According to the methodology, the findings above are based on observations. The INPO report devotes 18 pages of observations on design control deficiencies to sqpport the findings. Although these observations do not provide sufficient detail for either the .

NRC or GAP to determine the full extent of the problems in design input and control, there can be no question that work at Catawba has largely proceeded on the basis of informal drawings and procedures instead of design changes approved by the project engineers. The INPO report underscores that conclusion:

1. From interviews, literature searches, and document reviews . . .

no requirement could be determined to exist for identifying and tracking PSAR commitments. (supra, p. 8)

2. ... no control program for defining, responsibility for providing design input could be determined to exist. (supra, p. 8) 4 Interviews, literature searches, and document revisions in the Civil Environmental Division showed design input is provided through memoranda, specifications, intra and intar-disciplinary discussions and meetings._ ,(emphasis added) (supra, ,

p. 8)

7. . . . no program requirenent for conducting constructability, maintainability, or operability reviews was found to exist, . . . . ,

(supra, p. 8)

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13. .. ._ no program for providing and controlling design input exists. (supra, p. 9)

As a result of construction personnel and field engineers making modifications on an undocumented, informal and ad-hoc basis,it- is not surprising that further investigation by the INPO team discovered

, that system descriptions and diagrams did not agree for the following

! systems:

1.

- -(l) Mechanical / Nuclear Division

! (2) Mechanical / Electrical System '(RHR)

(3) . Electrical Division (AFW and RHR) (supra, p. 8)

(4). AFW electrical system in disagreement with the p

elementary electrical diagrams and the mechanical syst'em description.

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(5) Review of the RHR system description and flow diagram I

revealed _ discrepancy between the requirements of the two documents concerning emergency power train assign-ments for the isolation valves between the RCS and the RHR-system. (p. 16)

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-NRC Commissioners e Page Eight Design interfaces were also found to be lacking in that "the process for controlling design input documents does not require timely. updating of system descriptions." (supra, p. 11) ,

Design process weaknesses detailed records not being filed in a timely manner, changes to design drawings receiving inadequate review, and calculations not being maintained in a controlled enough manner to support issued design documents. (supra, p. 15)

These are not theoretical problems. Findings DC. 3-3 plainly states )

- l Design documents relating to the design of the RHR l System are in disagreement creating a potential for  ;

error in the design. This is also true for the AFW l system. (supra, p. 15)

On.page 21 of this section the following related observation is made:

The Auxillary Feedwater Electrical system description was last revised on October 10, 1980. There have been several revisions of the Electrical elemer.tary diagrams and a complete revision of the Auxillary Feedwater Mechanical system 6cacription since the last revision of the Electrical system dcccription.

However, -the most telling comment about the exten't of design control problems is " tucked" into this section on page '19. Unfor .

, tunately the credibility of the report is brought up seriously short by the lack of attention given to the following observation:

Finding 4-3.. System descriptions are used to provide system control information. They do not reflec't (emphasis added)

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current system design.

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Further evidence from the INPO report that is merely cumulative l The evidence that follows is sufficient, ,however, to is excluded.

illustrate a comprehensive breakdown that requires an extraordinary NRC monitored review program.

DPC has had. ample opportunity to respond appropriately to findings and observations in this evaluation. Clearly this "self-initiated evaluation" and DPC's lack of an appropriate ' response 11s the best argument in support of GAP's request for an. independent design and construction verification program (IDCVP) .

The following statements by DPC construction management are particularly illustrative of our doubts about' DPC's ability to heal ,

'itself:

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NRC Commissioners Page Nine Responsible engineers and first-line supervisors j do not feel keeping system descriptions current

! with design drawings is important. (item 15, p. 17) ,

and, Interviews with personnel of the Electrical Division I

showed a lack of concern for the system description not being current with design drawings. (item 11, p. 9) f Even more revealing than the ' statements of the Catawba employees above is the denial, rationalization and insufficient response of the INPO Findings by DPC Management. Pages 100-121 of the INPO report detail those responses. Although DPC has committe'd itself in the future to some procedural modifications, the licensee has responded by explaining away the problem. None of the responses to areas of weakness in design includes a " backward look" to determine the extent of the problems. Only a few new programs or alleged program reviews are -promised for the spring of 19 83, and a few specific changes are ,

promised in response to specific findings. This is entirely inade-quate for the generic implications of the INPO findings. ,

DPC and Catawba management should not have been surprised by the INPO report. Conscientious Catawba employees have been raising complaints about problems in design control for years.

Former Quality Control Inspector Ron McAfee, for exan:ple, .a known critic of construction weaknesses on the sitg recently was deposed by DPC attorneys in connection with the ASLB operating licensing proceedings. (Selected pagen of his deposition are included as Attchmt.2) . Mr. McAfee's sworn deposition confirms that the INPO findings were not isolated discoveries. As Mr.-McAfee explains:

Okay, one thing I did fail to mention was the fact that blueprints were changed to reflect' construction errors. (pg. 37, 9-10)

On certain occasions we would go to inspect the cable tray supports, cable tray hangers, on all the cable supports or I should say most of them, were seismically braced. We found several instances in which seismic bracing was not run in the direction the print called for it to be run. (ld., Ln.'14-17).

We would, usually on this, our procedure was to talk to the technical support engineers, and generally the resolution would revise the blue print to reflect the change in the direction of the seismic bracing.

(Id., Ln 19- 21) .

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NRC Commissioners 4 Page Ten Mr. McAfee describes his concerns about this backward procedure on page 41:

Well, I wasn't fully satisfied. In other words, I was not comfortable with the fact that a print was being changed because a craft worker made a mistake and braced something the wrong way. (P. 41, Ln. 1-4).

I was still concerned about the fact that it was changed to reflect a construction foul up. (Ln . 18-19).

.Mr. McAfce's fears were well founded. His experiences with a totally backward approach to design control gives only one small glance at the " quick and dirty approTch" used by DPC management to build Catawba.

A review of all the Design Drawing and Specification Variation Procedures used for design control affirms the worst fears of Catawba's critics.

Variation Notices (VN) have been used from the beginning of con-struction as the method of controlling field variations from Design Engineering drawings and specifications. Although initially controlled by Project Engineering, that function was transferred to Project Manager in September 1976. (Attachment 3. ) -

Prior to that transfer, no meaningful QA/QC review of design changes evidently occurred until May 1, 1974 when the Project Senior Quality Assurance Engineer became responsible for approving the QA aspects of variation notices and for specifying inspection if needed.

(Attachment 4.)

Design control procedures remained inadequate throughout the decade. In Revision 7, June 27, 1975 the Project Engineer was restricted from using even the variation notice unless it became necessary. (Attachment 5.)

Prior to' approval the (Project Engineer) must verify that the use of the variation notice is essential to maintain work in progress or to maintain work which will soon begin. (p.l.)

In the November 1973 Revision the Variation Notice became not a record of engineer approved design /specificatien changes, but the equivalent of a memo of understanding between design engineers and construction . (Attachment 6.)

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NRC Commiccionoro Pcg3 Elsv;n~

l Variation Notices (Form R-3A) are not to be used to report work that already has been scoomplishe'd or to authorize the use of an_ unapproved or pre- .

liminary design but rather to document an agreement with Design Engineering to conduct work in variance with an- approved Design Engineering drawing or specification. (emphasis added)

According to revision 8 that agreement could be transmitted "to the field verbally by telephone, in person or in writing." l All the paperwork from engineering to QA could be done in the

.conve,nience of office -- as revision 8 further explains: .

The Project Quality Assurance Staff shall then review the Variation Notice. _If inspection is needed, the r words ' Inspection Required' shall be written' in the

' Action to be Taken' section. If inspection'is not needed, the ' Waived' block shall be checke'd. EItems ,

which ,will receive adequate inspection and documenta-tion through the normal function.of the Quality. Assur-

, ance PrcJram need not have their _ inspection ~ documented on the R-3A, and the waived block should be ' marked.

Quality Assurance approval shall'then'be signed and dated. If required, the Project QA Staff shall mark the R-3A to indicate inspection assignment.

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When' Mr. McAfee raised concerns about the quality of: nuclear

, construction design changes by telephone he was informed not to worry ,

i about it, that it wasn't his concern. (Deposition of Ron' McAfee,

p. 40).

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Yet it was not .until Revision 13, January ll, .1982,. ,that the i use of variation notices even began to come into compliance with 10 C.F.R. 50 Appendix B Criterion III. (Attachment 7). Significantly,

-this revision includes'DPC's first attempt at addressing 10 C.F.R.

50 Appendix B requirements by the inclusion of Paragraph ~4.8 l . requiring that design non-conformances be evaluated for reportability

, und6r 10 C.F.R. 21 and/or 50/55 (e), and 4.10 which 'gives Des,ign l Engineering the' responsibility for performing trend analyses on

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~ Variation Notices "to assure that any unnecessary trends are not developing."

Unfortunately, the commitment to 10 C.F.R. was short-lived.

p By the time that Revision 17 was implemented, the reportability review l only applied to a small percentage of the Variation Notices; excluded i

from review were VN's selector Interference," " Implementation l

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NRC Commiccion9ra Page Twelve Option," or " Missing Information. " 3/ (Attachment 8) .

Construction at Catawba is currently using Rev. 19, dated July 1, 1983. Unfortunately the weaknesses of the Variation Notice .

(Form R-3A) . have only increased. There can be.no reasonable -

assurance after a _ review of the design procedureg the INPO Findings, and the experiences of Catawba workers who have talked to GAP that the plant is built as designed, and that design changes have been accomplished according to NRC requirements under 10 C.F.R. 50, Appendix B Criterion III.

GhP's previous experiences at .zimmer and Midland ha,ve revealed frightening construction flaws at . sites near completion. The Region III Director has often commented that the "real sin" at Zimmer was that it was in the ground, . 974. complete, yet in an indeterminate state. A review of the procedures used to build Catawba reveal marked similarity in the lack of attention to quality assurance and quality control requirements. Hopefully the Commission will recognize the critical importance of taking a comprehensive.look at Catawba now.

B. Failure to Maintain an Adequate Quality Assurance Program to Identify and Correct Construction Deficiencies Criteria I and II -- Organization and Quality Assurance Program Most of the criteria of _10 C.F.R. Part 50, Appendix B, stem from Criterion I - Organization, and Criteria II - Quality Assurance Program. The criteria require a carefully controlled and documented quality assurance program with necessary staffing and craining.

Criterion I also describes the premise that provides.Aegitimacy-to :a licensee's OA program:- "Such persons and organizations (performing quality assurance functions) shall have sufficient authority _ and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify imple-

. mentation of solutions." At Catawba DPC policies dominated these premises, and in the process -took the rest of the quality assurance

.. program step-by-step.

2/ Interference - The inability of Construction to perform the work as shown on design documents because of physical obstruction.

Implementation Option - Alternate methods. to install items which simplifies the construction.

Missina Information - The inability of Construction to perform the work required by design documents because of insufficient information.

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I NRC Commissioners Page Thirteen

- The - premise for quality assurance at Catawba was simple:

if a problem is discovered - fix it first, fill in the paperwork .

later. 'The entirety of this petition ' demonstrates that violations of regulatory requirements were common. Moreover, the situation .

i was accepted by even the quality assurance management as "the way l things were done" at Catawba. Even in the . face of continued low quality assurance / quality . control ratings by the NRC. 4/and a i

series of critical . reports by consultants, DPC continued to maintain

.that the . Catawba facility had been constructed in accordance with

[ 10 C.F.R. Part 50 Appendix B.

Mr. William Lee, Chairman of the Board of Duke Power in his ,

deposition of July 12, 1983 maintained that there is nothing that caused him to question whether or not the Catawba station was safely built. (Deposition of William Lee, p. 75.)

Regardless of Mr. Lee's view there is a fatal flaw in the nuclear construction quality assurance program: it is not, and never has been, independent of construction. 5/

j4 a. NUREG-0834, NRC Licensee Assessments, August 1981 rated Catawba

1. and 2 below average for the period 9/1/79-8/31/80. Specifically, NUREG-0834 states: " Catawba received a relatively large number of items of non-compliance when compared with other power reactor facili-ties under construction. Most of these items of non-compliance were F . attributed to weakness in the licensee's quality assurance and manage-ment overview process."

b. Systematic Assessment of Licensee Performance (SALP) Duke Power Company - Catawba Nuclear Station, Units 1 and 2, May 18, 1983, Draft of the NRC. input,-rates Catawba "2" in Quality Assurance. -(Attachment 9. )

. 5,/ This issue was the subject of an Atomic Safety and Licensing Appeals Board (ALAB) order in the McGuire ' proceedings. The matters raised by. the McGuire case are equally relevant to Catawba. In that case the question. of adequate QA independence was raised by intervenors South Carolina Study Group,. in both the ASLB proceeding and on appeal to the JUWu3 The ALAB remanded the question back to the Board for clarification, directing the staff and DPC to furnish the following information:

(i) An unequivocal response as to whether the applicant's quality assurance organization conforms to Appendix B to 40 C.F.R. Part 50. ' Quality Assurance Criteria for Nuclear Power Plants.'

(ii) If the answer is in the affirmative, an explanation of the basis for its assurance that the quality assurance respon-sibilities assigned to the applicant's engineers in the areas

=of construction, testing and operation meet the independence i objective of- criterion I in Appendix B.

(Footnote 5 continued on page 14) - -

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NRC Commiccionsrs Page Fourteen The record of the lack of independent quality control developed through the history of construction of Catawba lends significant .

weight to the original fears of the South Carolina Study Group in .

1973 and the Palmetto Alliance in 1983.

The intervenors recognized that the intent, indeed the entire purpose, for requiring QA/QC to be independent from. construction was to allow inspectors an unfettered ability to determine the quality of construction and to implement approved QA procedures.

Mr. Lee, current Chairman of the ~ Board, who was then Senior Vice President of both Quality Assurance Program,and Vice President for Engineering and Construction, saw the. regulatory request as something much less than a realistic requirement.

The PNlmetto. Alliance, in its deposition of Mr. Lee in July 19 83, questioned the development of the first " topical" QA program.

Mr. Leo responded, (Footnotc 5/ continued from previous pa'q[)

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(iii) If the answer is in the negative (or anything other than an unqualified affirmative), an. explanation of the basis and

. authority for its conclusion as to the acceptability of the applicant's quality assurance organization.

b. The applicant is directed to respond to the following question _s; , , ,

(1) Do any of the applicant's' engineers who have been assigned quality assurance responsibilities in the areas of construction testing and operation also-have other responsibilities which could adversely affect the performance of their quality assurance responsibilities from any standpoint, including independence as well as available time.

(ii) What is the precise nature of the responsibilities of the company officials, up to and including the Vice-President for Construction, who supervise the Principal Field Engineer and the job Superintendent. The answer should reflect considerable detail, to clarify any implication of conflict between different responsibilities of a given individual.

(iii) Does..the quality assurance manual specify in writing that

-(l) the Pri'ncipal Field Engineer has been directed to communicato directly _with the Vice President for Construction on quality assurance matters; and (2) . that quality assurance inspectors

- have the authority to stop work.

. su spleacntal Decision ( ALAB-14 3) , Sept. 6,1973, in the matter of Duke _ Power Company, William B. McGuire Nuclear Station, Units 1 and 2, Docket Nos. 50-369, 50-370, p. 623-625.

.__. .. _ . . . ~ -. . - - . . . - - _ . - - . . _

l

< NRC Commihsioners

• Page Fifteen-i l

A. .

Well, we wanted to have not only inside our company but in all different boards and organizations that were -

reviewing. Quality Assurance, NRC, AEC, Staff Hearing Boards, Operating License Hearings going on, Construction

. Permit Hearings going on; and we wanted to have a uniform, throughout the company, nuclear program, a Quality Assur-ance Program and procedures that everyone understood. . . .

-(A) t Oconee and McGuire we were getting different reactions l i and different requests; and so we filed the document saying l this is the way we are going to march, and we got the NRC

< . to review that-in its entirety and to approve it; and we said now apply that to Docket Number so and so and so and so; and that is all the nuclear plants, and that resolved such questions as you have cited here, lack.of documentation as

{

to'where somebody reports. (See Attachment 9A for this and L other selected passages of Mr. Lee's depositione) s This topical approach may have eased the regulatory difficulties

. for DPC in .the early 1970's, but it has made public acceptance of the safety of Catawba much more difficult in 1983.

Obviously, Mr. Lee neither respected nor implemented the NRC instructions to his company in 1974 to split up the QA/QC function from construction and engineering. In a blatant disregard for the laws established by Congress to govern commercial nuclear operation, ,

4 Mr. Lee decided that the administrative inconvenience of scheduling employees' vacations took priority over complying with the law or the  !

court, as demonstrated by the following remarks:

, A. As we formed the Quality Assurance- Department as

( a separate and independent entity, remember I was l

wearing two hats, Vice President of Engineering and l Construction and the Corporate Quality Assurance guy.

l In order to get the technical aspects of Quality Assurance under way, I did not want at the outset to set up a' separate payroll, separate vacation records

, and separate lines of administrative reporting and l personnel record keeping and time sheets and whatnot, l but I wanted functional authority, that is the proce-j dures, the technical aspects, what was acceptable

-and not acceptable, came under my authority; but I

!'. wanted these people to stay for a time on zthe- payroll

! . of the line departments - that were doing the work.

l l

l l - -

. _ _ . _ _ -e - - ,___ _ ..

NRC Commission 3ra Page Sixteen l

l 1 1 This was 'a management technique in order to get the independent route started, and it was after we had entWblished the functional or technical or procedural aspects consistent -

with the topical . report 'in Appendix B, .that then I selected -

a Quality Assurance Manager and moved all the people under a

new department and therefore both administrative and functional authority were. vested in the Corporate Quality Assurance Manager, who reported for all purposes, to me.

But you have to. start somewhere, and I elected the  ;

management technique of leaving administrative. control and .

management under the existing line departments for starting -

l out with functional control, so that my time was not spent 1

' deciding who could take vacations when, so much as here are  !

the technical criteria we are going to put in place. See Attachment 9a.  ;

Mr. Lee's plans for .getting a separate QA program started are interes ting. As Corporate QA Manager and Vice President of Construc-tion / Engineering, he chose administrative convenience over regulatory requirements for nine years or nearly the entire construction period for McGuire and Catawba! The original organizational structure of DPC ~

- continued without accountability until 1981 when the welding inspectors finally "put their foot down" 'and refused to buckle to construction .-

cost and scheduling pressure. (See infra,. pp.42-45 of this petition. )

The DPC policy inherently defeated the key premise of Criterion i I - . organizational independence and quthority for QA personnel to '

, do their jobs. i i The welding inspectors who submitted documented complaints to DPC management (and eventually to the NRC) unilaterally complained of pressure from construction. Some of those ' complaints have been ,

provided as attachments to this report as Attachment 10. (For a more comprehensive list of available documented complaints from the welding l

. quality control inspectors, the Appendix to FOIA 83-200 is attached as Attachment 11. )

Concerns such as those below dominate the statements of over

[ two dozen welders:

The biggest concern that I have as far as not being supported in implementing the QA program is the fact' that at times resolutions and general gray areas have been watered down in order for craft to meet scheduling deadlines. '

A lot of these occasions have been exactly opposite of procedure requirements, yet the problems being brought up were to be ' ignored,- because at this point quality didn't L . matter -- only deadlines. (Statement of. John R. McCoy, Attachment 10.)

l i - -. _ _ . . , . _ . . . ~ . . , _ _ _ - - . _ . _ _ _ _ . . _ _ . . _ . _ _ , . _ . . . , _ _ . , _ . , _ . , _ _ . , . _ _ , _ _ _ , _ _ _ _ . _ _ _ _ _ , , . , _ . _ _ - . . ,

f NRC Commissioners Page Seventeen L John Bryant, another welding inspector:

i-

~

L.R.D. and C.R.B. have stated 'that it is part of their jobs = to -make decisions and judgments, ... when ,

they do give verbal directions they do not always want to accept the responsibility for them:

L.R.D. notified the QC welding inspectors, at one time, that they were over-inspecting misc. steel welds, because they were holding the craft too close to _ design and QA' procedures. If the welds were close to _ the requirements, they should be accepted. But,

'when the NRC _ came and found discrepancies, such as weld

lengths too short _(approx. 1/4") and weld sizes slightly under (approx. 1/32") , . L.R.D. tried to place the full responsibility upon the inspectors and issue "A" violations to them. (Attachment 10.)~

The subordination of QA to construction, in fact, has permeated l the program from the beginning of construction.

Even outside consultants failed to convince DPC Management of the failure of its QA program. The Management Analysis Corporation (MAC), hired to handle the welding inspectors " problem" creatively

• divided the welding inspectors complaints into " technical and non-technical" areas. In this way the MAC task force ' resolved the specific technical complaints-weld by weld, but it failed to address the "non-technical" programmatic flaws that left the welders no choice but filing their massive complaints.

~

i Essentially because the welders documented the'ir specific concerns it is only their work that the public can be assured has been performed according to procedures and sp~ e cifications.

l I

Ironically, the Licensing Board 'seems to ha've misse d that point and has narrowed the scope of the claims to allow intervenors to

-litigate only the welding concerns. Yet, it is just these welds,

~

reviewed by those welding inspectors who " revolted" against the status quo, which are most likely to be adequate. Unfortunately -

for the public the procedural quality assurance breakdown revealed '

by the welding inspectors is site-wide and the programmatic weakness permeates the project. ,

The welding inspectorW information is now two years. old. But L

other workers GAP has talked to confirm that the pressure continues.

i l

i L

R

.I

NRC Commiccionsrs

, q Page Eighteen A recent letter from a Catawba worker describes the current situation: l i

I l ~We have been under pressure for all this time to -

do what is/was necessary to make our work look good on ,

paper. However, it is not the fault of .the majority of the employees. We are constantly threatened with -

violations (A, B, or C) which can mean our jobs if

~

we f ail to do what we are told, whether it be right l

? or wrong.. (Attachment 26.)

Other QC inspectors have . confirmed that procedures may have ,

changed on paper recently, but in reality the construction force is given'" carte blanche" to finish Catawba.

I The INPO report also addresses the lack of independence under

'Section C, Pages 3 - 97, and Section D. 3. (The INPO report should be reviewed by the Commission in its entirety, not simply the ~

examples referenced for illustrative purposes.)

! C. Failure to, Maintain Adequate Controls to Process and Respond to Non-Conforming Conditions ,

i Violation of - 10 C.F.R. Appendix B, Criterion X and XVI i.

Nonconforming item reports (" NCI 's " ) are ths Jay safe award to assure routine . identification and correction of QALviolations. It does not matter if procedures are violated or .if hardware is defi-cient. Nor does it matter if the violation involves 10 C.F.R.,

3 Appendix B, 'or DPC's .own QA Manual. NCI's are sent to the NRC.

Both NRC and utility officials study - the reports to learn trends in particular QA deficiencies. The breakdown of the NCI reporting

system at Catawba illustrates. the breakdown of the entire QA program.

I It is significant to' no_te that the overwhelming majority of QA Lviolations discussed throughout the .INPO audit by QA/QC personnel, <

'and by workers that GAP investigators have spoken with were identified on more informal substitute forms such as R-2As, M-43, M-51s, V N 's and frequently mere inter-of fice memoranda.6/ The -

permanent non-conforming item.(NCI) reporting system at Catawba has only identified a shadow of the QA violations. As a result, l

t it circumvents normal oversight for the vast majority of necessary l corrective action.

'l. DPC Policy to Circumvent Non-Confirming Items (NCI_)

l l- In a May 1, 1974 revision to the Control of Non-Conforming Items , Procedure Q-1, the lines of construction authority over Quality 1

1/ M-4's detail. procedures for visual and non . destructive inspection of fieldwelds and M-51's for components supports, see page 74 of INPO audit.

i

NRC Commission 3rs

,Page Nineteen Assurance were explained. (Attachment 12) .

The Plann!.nq and Facilities Engineering (cost and scheduling) not QA/QC began the NCI process"oy numbering the report, distributing, appropriate copies, and retaining the original ~in the of fice pending file." (1 4. 2, Rev. 5) .

Although QA was given limited input into the resolution of NCI's, the QA

• hold point" was neither required nor binding. In fact as Para. 4.4 explains, the QA/QC inspector was only a glorified file clerk for the engineering staff: -

- After the resolution has been approved, the Non-conforming Item Report shall be returned to the Planning and Facilities Engineering Staff for processing. The Planning and Facilities Engineering Staff shall assign responsibility for corrective action to the appropriate personnel by checking the appropriate action assignment section on Form Q-1A. The Senior Quality Control Engineer or. an engineer or inspector working for him.shall verify the corrective action taken by completing the " action taken per resolution" section on the Q-1A report. The Project Quality Assurance Staff shall then file the completed form.

If QA/QC had even been given authority over-the construction NCI files there might be a possibility that documentation could be retrieved, but that is not the case. As Paragraph 4.5 of Rev. 5 demonstrates there was no overall QA responsibility for maintaining the status on NCI's.

The Planning and Facilities Engineering Staff shall maintain a log of the status of all Nonconforming Item Report sheets. The status may be logged on Form Q-lC or a computer printout. If a printout-is used, it should at least document the Nonconforming Item Report sheet serial number, a description of the nonconformance and the status of the resolution.. Monthly, the Planning and Facilities

. Engineering Staff shall send a list to Design Engineering of unresolved nonconforming items for which they are respons-ible. He shall also distribute to the Construction Engineers a list of unresolved or incomplete nonconforming items for '

which they are responsible.

4 bi" u ' - -

NRC Commissioners

, Page Twenty The last sentence of Paragraph 4.5 gives a particularly chilling insight into what DPC management considered the purpose of.NCI trending lists: .,

These lists shall be used by Design Engineering and the Construction Engineers to expedite the completion of their responsibilities for resolving the nonconformance.

( (emphasis added) 2.- In Process Inspections

, In October 19 82 NRC Region III inspectors / investigators con-ducted a comprehensive inspection of the Midland Nuclear Plant's diesel generator building. Among other things the inspectors discove. red a procedural QA deficiency.

~

That violation (excerpted below) is described in a February 8,1983 letter from James G.

Keppler, Regional Administrator,.for Mr. James Cook, Vice-President of Consumers' Power Company.

QC Supervisors instructed QC inspectors to suspend an inspection if an excessive number of deficiencies was observed. Consequently, there was no assurance that a complete inspection was being performed after the reported deficiencies were ~ corrected and we have found several instances in which final QC inspections were based on only the limited deficiencies reported during the initial inspection. In addition,,this failure to report all identified deficiencies resulted in inccrrect data being fed into your Trend Analysis Program, inhibiting your ability to determine the root cause of deficiencies and prevent their recurrence. (Attachment 13) .

(Consumers Power was fined $60,000 for this Severity Level III violation.)

The Nonconformance Procedure for Catawba, Revision 9, dated June 11, 1976, bears striking similarity to the ' situation discovered at Midland.

If a nonconformance is identified on material equipment, or activi. ties in the course of installation or construction, the noncon' forming -activities or activities which affect the resolution of the nonconformance shall be stopped and not

-resumed until the resolution of the nonconformance is identi-fied. Activities involving the material, . equipment, or_ item

-which do not affect the resolution of the nonconformance may continue. The ' Project QA Staff shall be responsible for determining which activities may proceed. Where necessary, these activities shall be described in the statement of the nonconformance. (Attachment 14) .

~ . . - . _ - = . - - - - -- - -

NRC. Commissioners

-, Page Twenty-One This procedure, a clear violation of Criterion X of 10 C.F.R.

i Appendix B remained in effect from 1976 through 1978. Then the violations of Criterion X and )NI increased. ,

By Revision 12, June 22, 1978, QC/QA inspectors were completely shackled to the Senior Engineer. They no longer had any authority to write NCI's without first setting approval. As 5.1(13) explained:

The Senior Engineer shall review the information 4

recorded for clarity, completeness, and validity; have i needed corrections or additions made by the originator; and sign and date to indicate his acceptance. If a report

'is determined to be nonvalid, this shall be explained in space 10. (Attachment 15)

Shortly, thereafter, Document Control began to issue sequential serial numbers only for approved NCI's.

It was approximately this same time period that the welding quality control inspectors on the Catawba site began to balk at the controls put on their quality judgment. For at least two quality control inspectors the '78 procedures represented a serious professional compromise.

Diaries, or logs, from the welding inspectors produced last May in the Catawba licensing proceedings reveal that some of the welding inspectors began keeping logs within months of the implementation of revision 12. . (See Attachment 10 'for welding inspectors concerns.)

Revision 14, pgs. 20 and 21, January 7, 1981 includes DPC's solution to " recurring" NCI's and QA/QC criticisms. by both of the NRC and internal critics.

s

! Welding inspectors have explained to us that this Revision 14 l procedural change became the " turning point" for many welding inspectors.

DPC put the " screws on" Catawba management to eliminate the NCI problems -- so Catawba management put the problem back on the quality control ~ inspectors -- instructing them via Revision 14 to (1) get construction on design engineer management review before writing

. up the NCI and (2) explore all other alternatives to 'take care of

' the problem' by preventing recurrences. According to both documents and interviews, - the " hoops" that quality control inspectors --

particularly welding inspectors -- were having to jump through to l do their job became unbearable.

l l

l 1

a

'r*" r1 e ew-*-*- *

• • -v-- -

-*--+=e -m *r +ww - ---,--*--e - * - - - * - - - - - - - - - - - - ----------=-------n-- -- ---- -----

I NRC Commiccicnoro Page Twenty-Two As .the welding inspectors handwritten notes describe:

I do not feel that this direction is in accordance.with

• the intent of QA procedure - Q-1, pg. 2, rev. B, para. 5-B.

Procedure Q-1 requires that all Q-1As, initiated, to receive

• a serial number, although they still may be voided. L.R.D.

and C.R.B. have not been following these QA requirements, for.after reviewing a Q-1A, and .they do not feel it should have been initiated, ' they discard the Q-1A without a serial number. Q-1, pg. 3, rev. 8, para. 5.1.4. (Attch 10)

Q-1A discarded without a serial number: A Q-1A was

, presented to L.R.D. for review and processing, involving welding with paint and foreign contaminants'in the weld zone and the visual appearance of the root pass. Q-1A was not serialized or processed. L.R.D.'s explanation was that only a partial pene. weld is required and since a full pene-tration has been acquired, there is no problem. (Attch 10)

NCI was written because of piping material having two heat numbers on it.- When called to taks the'NCI tags off of the pipe QC Welding found that there were three heat numbers on the pipe. When brought to ths attention of Larry Davison I was informed that the resolutions on NCI's were of This clearly no concern of mine and to remove the Ol-B tags.

violates 'M-4 and H4 and it is of my concern as a Duke Power employee and a resident of one of the~ surrounding towns. (Attch 10)

The technical review described above was procedurally ration-alized with 5.1.2 (b) , Revision 15:

b. Review ths information recorded for clarity, completeness, .and validity, have needed corrections or '

additions made by the originator; and sign and date for

' Technical Review. ' If a report is determined to be nonvalid, ,this shall be explained in the ' description of item space. If the nonconformance is such. that some activities concerning the item may proceed, the' activities which may proceed shall be stated. If no activities are stated, then no activities concerning the' item are allowed.

The report shall.be forwarded to the' Projec't QA Engineer for review. (Attachment 16)

The latest procedure available, Revision 17, still contains excessive weaknesses, but curiously it also contains the first requirement for- a 10 C.F.R. 50, Appendix B Criteria XVI evaluation of each-NCI.. (Attachment 17)

' '~ - _ . . _ _ _ _ . _ _ _ _ _ _ _ , . _ _ _

_ --.7 _

~

NRC Commissioners Page Twenty-Three The inclusion of 5.1.19 is far too little too late to provide l meaningful answers to Criterion XVI_ questions about Catawba.7/

i The procedural problems traced through a. decade of Quality  ;

control problens is not simply a paperwork breakdown. The INPO audit ( Attachment .1) documents the results of a decade long nuclear construction. program that had virtually no QA/QC check or balance.

The INPO findings should have come as no surprise to DPC/

Catawba management officials, the welding inspectors have been warning them for years. Unfortunately .the vindication of the welding inspectors comes too late to make much difference in the quality'of the plant. A quality assurance program cannot be "retrofitted" into the plant.

INFERIOR SUBSTITUTES FOR NONCONFORMING ITEM REPORTS

, There are a number of inferior substitutes to the NCI form being used to report nonconforming conditions. In particular, the R-2A (inspection discrepancy reports) governed by the R-2 procedures, is used on the bulk of nonconforming items. (See generally depositions of L. Davidson and C. Baldwin, June 29, 1983).

The R-2A is deficient- from NCI's in at least seven respects:

(1) NCI's identify the cause of the problem.

(2) NCI's cannot be closed with an informal undocumented.

design change.

(3) NCI's give inspectors the ability to stop work on a e nonconforming item that needs to be isolated.

(4) NCI's are sent to the NCI for review.

(5) NCI's are trended in QA.

l 1/ An individual assigned in writing by the Project Manager or QA Manager shall perform a 10CFR50, . Appendix B, Criteria XVI evaluation of the NCI. The following items shall be considered, as a minimum, in this evaluation: a) Are there possible Duke or industry generic implications? b) What ~is the root cause of the problem? c) What corrective action is required to prevent recurrence? d) Is this .

. condition repetitive in nature to the extent corrective action should be implemented? c) Should thin condition be investigated at other Duke sites? f)' Is this condition significant?

i

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

NRC Commissioners Page Twenty-Four )

-(6) NCI's have centrol numbers (once issued) .  !

(7) NCI's require written resolution..

The INPO reports the following about the R-2A's:

The performance of Construction corrective actions was reviewed. Responsibility for trend analysis of R-2A's (inspection discrepancy reports) recently was changed from QA to Construction. This review indicated the following areas of weakness: .

A. No trend analysis has been performed during the period 6-1-82 through 8-23-82.

B. Construction has not performed. any trend analysis of QA surveillance reports.

C. Construction has not performed any trend analysis of nonconforming item reports.

D. Statement of action on R-2A #5677 does not address all areas of concern. Piping system was pressurized prior to release by hydro groap. R-2A did not address procedure violation nor safety implications.

E. Action required on R-2A 4M5350, although cleared by QA, has not been completed. (INPO Report, at 43).

The INPO report further observes the following in the section of corrective action: <

1. Deficiencies were noted in Forms R-2A (Inspection Discrepancies) .where the Quality Assurance group.

A. accepted the statement of action required when the action did not address the root cause of the problem or B. approved clearance of the R-2A when corrective action had not,yet been taken.

Specifics of the examples are discussed in Performance Evaluation Details for Objectives No. CC-6, Items 1.D and E.

In'short, R-2A's have provided Catawba management with a paper-l

' work resolution to hardware problems. In the past Catawba was The solution criticized for having "too many NCI's" by the NRC. 8/ . -

or has been to write . R-2A's, or some other substitute like M-4's, M-51's instead.9/

8/

SALP Report I, supra p. 4.

~

1[ -Procedure M-51 requires the inspector to fill out an M-51CThe Form to identify discrepancies noted during hanger inspections. Management is I forms. are then returned to the craf t -for correction.

not made aware of problems noted, and no trending of these discre-pancies is developed and analyzed to evaluate basic causes and

address generic problems.

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

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NRC Commiccionero Page Twenty-Five Charles Baldwin testified that there used to be twenty-five NCI's per week, now there are only two. (Charles Baldwin deposition, June 29,19 83, at p. 53. )

The legitimacy of the R-2A as a substitute for NCI's depends not so much on its procedural flaws, but on its implementation.

Workers report to d:- that R-2A's are used liberally by both QA and construction to legitimize construction that pushes ahead of UK7QC' inspections.

VOIDING THE NONCONFORMING ITEM REPORT

- A particularly ominous method of cutting down NCI's at Catawba has been " voiding" or " verbally overriding" the NCI by management.

- It is as if it never existed. There is no record of it, nor any ,

- written record of the subject. Charles Baldwin describes the process in his July deposition as follows:

Q. Is there any form or documentation which you would document those instructions if your instructions were to.the effect that the NCI was not a valid NCI, not valid to handle as an NCI?

A. No, I did not docunent that. .

Q. Wat was the Inspector supposed to do with it, as you tmderstood?

A. Arrything he would like. '1here wasn't any procedure requirement at that time. He could destroy it if he liked, keep it on file for his personal records if he likes.

Q. ~ Was there anyone other than the Ir.getur enployed by Duke Power Capany t who was responsible for maintaining a file of those NCI's that were not' pursued beyond that point? i

A. Ones that weren't approved?

i Q. Yes.

A. No, not that I'm aware of.

Q. Were copies of those unapproved NCI's filed with the Nuclear Regulatory

, Counission?

A. No.

Q. Did you maintain any records of circtmetances where you determined that the

proposed NCI was not a valid NCI?

! A. No.

(Deposition of Charles Baldwin, June 29, 1983,

, pp. 82-83.)

\

There can be no way to ever determine the number of NCI's that have been forgotten, discarded, voided, or destroyed. According to -

- Mr. Baldwin there were ". . . numerous occasions" when the inspector-did not write up an NCI report'after talking to his supervisor. (Deposition i p. 84.):

i f

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MRC C mmicaioncro'

• Page Twenty-Six D. ' Failure- to Maintain Adequate Material Traceability to Identify and Document the History of All Material, "

Parts, Components and Special Processes.

Criterion VIII -- Identifications and Control of Materials, Parts and Components 10 C.F.R. 50, Appendix B, criterion VIII requires that identi-fication and ' control measures be established to assure that each material, part or component " item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation and use of the item." These measures "shall be designed to prevent the use of incorrect of defective materials, parts, and components". Similarily, criterion IX requires control of special processes, including welding.

T'o illustrate, the weld must be traceable back to a properly qualified welder using the proper procedure with the right filler material.

The full extent of material traceability deficiencies is un-known. But all indications are that the breakdown has occurred on a massive scale.

To illustrate, the INPO report concludes on page 32s Finding (CC.3-1) Site receipt inspection does not ensure that material and equipment received on site are evaluated against the requirements of the procurement specifications.

Examples of the problems identified may potentially result in delays, waste of materials, additional time spent on disposition of deviations from procured materials and work stoppage.

Finding (CC. 3-2) A consistent method for material identi-fication was not in effect in the warehouse. Several instances were noted where I.D. tags had fallen off, equipment was marked with ink, and when material was being sectionalized to start fabrication, a means for maintaining the identification was not being done.

Finding (CC.3-3) Proper protective measures were not taking place for environmentally sensitive equipment that was " robbed" for space parts. Some parts were being stored in an open door instrument cabinet.

Finding (CC.3-4) Procedure QFP-8.002 CNS, Rev 1A, does not indicate the disposition of unused filler material. Confusion appears to exist regarding handling of unused filler material and adherence to AWS code requirements could not .be determined.

Finding (CC. 3-5) Materials are not being maintained or stored effectively at work site locations. Several examples were ,

noted which reflected imporper control.

l NRC Commiccicncro Page Twenty-Seven Finding (CC.3-6) Scheduled preventive maintenance activi-ties on installed equipment are 'not always assured throughout the entire period of construction Department control. Equip-ment was identified for which preventive maintenance had .

been canceled up to 21 months ago, and there was no evidence -

that compensatory requirements had been established.

There is also the question of the' acceptance af material from other Duke sites for use at Catawba.

During a review of No. 10 cadweld operation in the Auxiliary Building, it was learned that the cadweld sleeves and powder had not been received by QC Receiving. These

' items were received from another site as non-quality items, and the QC inspector was not aware of the 16 51144 sleeves until notified by his supervisor. The work was stopped.(supra, )

E. Failure to Maintain an Adequate Quality Assurance Program for Vendors.

Criterion VII: Control of Purchased Material, Equipment and Services 10 C.F.R. Part 50, Appendix B, Criterion VII requires the appli-cant to establish measures that assure that purchased products

" conform to the procurement documents" and provide "for source evaluation and selection,. objective evidence of quality furnished by the contractor or subcontractor, inspection at the . . . source, i and examination of products on delivery". Documentary avidence of l

conformance to procurement requirements -- sufficiently identifying the specific codes, standards or specifications met by the purchased products -- must be available at the plant prior to installation or use, and retained at the plant afterwards. The applicant or its designee is also required to periodically assess the effectiveness j of the control of quality by the source.

During the history of the Catawba construction, DPC has relied l

almost exclusively on itself for material, equipment and services.

L As a result DPC has not been plagued by the numerous problens that l GAP has discovered at other facilities that relied exclusively on vendors for products and services. This autonomy has led to an l impression that DPC has adequately controlled the products and services used in Catawba's construction. This impression however is not accurate.

The examples below illustrate that serious weaknesces exist in I

the vendor program.

i

NRC Ccamiccicnero Pcga Twanty-Eight i

l .

To illustrate, The. following weaknesses were ' observed in control of HVAC contractor's welding program. .

A. No welder knew the weld procedure under which .

he was working.

B. All welders knew required weld size 'and location, but did not know how they acquired that information.

No process control was av&ilable to specify the 1C.

welding procedure for plenum erection (from ' Drawing CN-1684-VA-OOOH, Rev 0).

D. Welder was making welds without removing, galvanizing material.

E. HVAC support 2-H-VC-4999 had undercut in excess L of that allowed by AWS Dl.1 code.

. F. Welder / supervisor picks welding procedure from all available welding procedures. Supervisor indicates welding procedure (s) used on a support af ter the' support is complete.

and, A review of the vendor audits of the' HVAC contractor did not disclose any weaknesses in the' ' program. Observations of HVAC support installation indicates the following weaknesses:

A. There is no traceability of weld procedures to the finished weld.

B. Procedures did not meet Code requirements.

IV. REQUEST FOR MONITORING OF OFFICE OF INSPECTOR AND AUDITOR (OIA) INVESTIGATION BY THE COMMISSION -

In April- 1983 GAP requested an investigation' by the Commission's

-Office of Investigations (OI). Our request,. by' letter dated April 21, .

1983 was for an NRC investigation into unprecedented worker resist-ence to DPC violation of quality' assurance ' criteria and professional

-code requirements. (Attachment 18). Subsequent to our request the investigation request was forwarded to the' Office"cf Inspector and Auditor (OIA). In May 1983 OIA investigators. began'an investigation into the issues raised by our request. In May 1983 'OIA investigators met with GAP of ficials to allegedly " review". documen'tation to es-tablish the concerns our organization had about NRC Regional actions in connection with the " welding inspectors incident"'. (Infra, .at 42.)

To date the NRC has not released any results reg'arding OIA's efforts. .Our previous experiences with OIA howeverf,, leave little room for optimism for either comprehensive or timely results.

NRC Commiccien3r0 Pcge Tw0nty-Nina Unfortunately OIA's history has produced a dismal record of agency excuses for the misconduct of its employees. 10/

Since the misconduct of regional NRC employees in this case ,

was'such a serious breach of NRC policy regarding protection of "

workers' confidentiality, as well as other violations enumerated below, GAP is requesting the Commission to .(1) monitor the ongoing OIA investigation for scope, comprehensiveness, and thoroughness, (2) review the implementation of internal NRC operation policies of the Regional Administrator, and (3) probe by the Executive Officer for Operations Support into the inconsistency of enforcement policies of Region II with the rest of the Regions.

,A. Violation of NRC Policy and Regulations by NRC Personnel Regarding Pr'otection of Witnesses and the Release of Draft -

Information to Utility -

NRC policy regarding confidentiality of nuclear workers who give information to the NPC is, ironically,. best explained in a speech given by Mr. James P. O'Reilly, Region II Administrator, to the Atomic Industrial Forum's 19 83 Conference entitled. "NRC's Response to Whistleblowers" (attached and incorporated as Attachment I 19). 11/ That policy is reiterated in a June 27, 1983 letter from Mr. O TReilly to GAP:

I reiterata that NRC policy is to grant confiden-tiality to the extent possible under law, .to any alleger who requests confidentiality with respect to allegations which are considered by the alleger to be safety-related.

Mr. O'Reilly further explains his personal view of the success-ful implementation of this policy in Region II in his letter.

(Attachment 20).

It is to be noted that I have scrupulously adhered to the policy in the past and will scrupulously adhere to it in the future.

dSI For a detailed account of GAP's direct experiences with OIA see testimony of Billie Garde and Thomas Devine presented to the Oversight and Investigation Subcommittee of the Committee on Energy and the Environment, June 20, 1983.

SAI The text of the speech was provided to Palnetto Alliance in j May 1983 as a response to its request for NRC policy regarding protection of whistleblowers, and also to GAP in a June 27, 1983 letter from Mr. O'Reilly on the same subject.

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i NRC Commissioners

.Page Thirty Unfortunately for the over two dozen welder inspectors at the Catawba construction site Mr. O'Reilly's view of reality is, at best, j fanciful. ,

To illustrate, in October 1980 two lead welding inspectors finally gave up on DPC to resolve their technical concerns or take care of the harassment and intimidation to which the inspectors were subjected. They went to see the resident inspector, at that time, a Mr. G. F. Maxwell. Mr. Maxwell'unfortunately was obviously not aware of any NRC policy or of Mr. O'Reilly's policy regarding con-fidentiality of workers. His breach of their confidence is outrageous.

The details of this breach are best described in the deposition of Mr. -Larry Davidson, Manager of Quality _ Assurance at Catawba.

(Mr. Davidson' has consistently been the prime target of workers '

complaints-regarding harassment,. intimidation, falsification of re cords, and violations of QA/QC procedures. (Attachment.20) 12/

Mr. Davidson first described his NRC " notice" of the complaints of his workers in an _ interview with Lew Zwissler, a consultant-hired by DPC. (The notes of that meeting are included as Attachment 21). The following excerpt from Mr.- Zwissler's note confirms that Mr. O'Reilly's " scrupulous adherance" to workers confidentiality i

excluded the Catawba welding inspectors.

!- In October 1980 -- NRC Inspector (Maxwell) informed Davidson that WI's are bringing problems to him . . .

inspectors keep books -- are encouraged to do.

f Mr. Davidson further describes this meeting on pages 16-29 of his July 13 deposition. Of particular concern to us is Mr.

Maxwell's apparent disclosure of the identities of those inspectors who came to him (pp. 21, 22) as well as his revelation to Mr. Davidson

^ that the welding inspectors were keeping "a black book list of items they were not happy with ...". (Deposition pg. 20).

Of course, if the workers had not requested confidentiality perhaps Mr. Maxwell's disclosure could be explained, though not t

excused. However it is the Regional Administrator's position that j the contacts were under the request of confidentiality. In fact in an August 12, 1983 NRC Response to a Freedom of Information Request (FOIA) for "all agency records and information related to and/or generated in connection with an investigation at the 33/ The deposition .was taken July 12, 13, and 14, 19 83 in the Matter of Duke Power Company, Docket 50-413, 50-414.

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NRC Commiecionarc Page Thirty-One

' Catawba' Nuclear Power Plant in South Carolina in " Concerns of

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Wel' ding Inspectors" Mr. .O'Reilly details the confidentiality of informants as the bases for withholding groups of records responsive -

to our request. (Exhibit 11) Throughout the letter -- Mr. J. M.

• Felton, . Director Division of Rules and Records of the Of fice of Administration reiterates his statement:

The detailed names are of individuals who were confidential informants who provided information during an agency investigative effort.  ;

Mr. Maxwell lef t the Catawba facility as NRC resident inspector in late summer 1980. He was replaced later by a Mr. P. K. VanDoorn was obviously not familiar with the " scrupulous" confidentiality policies of Mr. O'Reilly either.

Unfortunately for.the workers, Mr. P. K. Van Doorn not only failed to acknowledge? the seriousness of the Catawba problems that he . inherited, he compounded them. He learned of the'se concerns upon his arrival in February 1981 on the site. (See deposition of P.K. Van Doorn, pp. 98, 99, May 19, 19 8 3) .

Not until a year later, in February 1982, did he react.to the warnings from the welding inspectors of major QA problens , pressure from

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construction. Their allegations this time included falsification of documents, harassment, intimidation, and a systematic historical breakdown of the OA program. (See Memo to File, P. K. Van Doorn, March'15,.1982 (Attachment 21) .

Surprisingly Mr. Van Doorn's reaction to the above allegationr.

was entirely inconsistent with the hypothetical response to just such a situation described in Mr. O'Reilly's speech to the Atomic l Industrial Forum. (Attachment 19).

I Now,.in accordance with your request, I will describe 'for you, .with an example, the process by which, the NRC responds to all allegations relating to nuclear j activities. Please note that almost all allegations are j unique. They involve different locations, different cir-cumstances, and different individuals. Let's presume, for my example case, however, that an alleger informs an NRC Regional Office that certain specific welds at a nuclear l power plant do not meet regulatory requirements.

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NRC Commissioners

. -Page Thirty-Two

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The allegation may have been received by telephone, personal contact with NRC personnel, notes - either signed or anonymous, or from news media representatives. A prompt .

preliminary evaluation of the allegation by the NRC, what- .

ever its source, will determine the initial NRC response and the Regional Of fice group assigned to. address the issue.

In this example on welding, a technical issue is involved ,

which would be assigned to one of our technical inspection groups. ,

Other possible NRC reactions would be determined by whether or not the allegation involved misconduct or wrong-doing. In such a situatien, the NRC Of fice of Investigations

.would become directly involved. The Office of Investigations is a staff office reporting directly to the Chairman of the NRC. It is staff 6d by professional in'vestigators residing in both headquarters and regional offices. This group investigates allegations involving potential or alleged misconduct or wrongdoing and is available to support the Regional Office's technical inspectors' pursuit of issues which require significant interviewing of individuals.

Similarly, should an investigation of alleged misconduct or wrongdoing involve issues where technical assistance is necessary to conduct the investigation, the technical staff would provide support to the Office of Investigations.

An example of how the. Office of Investigation would become involved can be demonstrated in the welding example.

> Let us assume that the initial inspection of the defective welds reveals that certain records may have been falsified.

At this. point, the purely technical issue has expanded to include the possibility of wrongdoing. The Office of Investi-gations would .then be called in for the specific purpose of investigating the issue of falsified records. In general, i

falsification of records required by the NRC, could constitute a material false statement and in certain cases, a criminal offenso. ,

Yet, even in 'the light of the policy instructions which were presumably given to Mr. Van Doorn by Mr. O'Reilly no referral of the concerns of the welding inspectors was given to the Regional personnel responsible .for investigating deliberate utility wrong-doing.

Instead, key' Region II personnel reviewed and confirmed their previous decision of January 29, 1982 to allow a DPC Task Force to address the issues raised by the welding inspectors. (See R.C.

Lewis' memo May 18, 1982, incorporated and attached as Attachment 22.) This' action reveals a mentality that is equiva-

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lent to allowing the fox to inspect the fence around the chicken coop.

NRC Commissioners Page Thirty-Three Finally, as the welding inspectors "were left slowly twisting in the wind" 1}/ the NRC inspector they had turned to for help was busy insuring that DPC had all the information available. In a December 20, 1982 memo to file George Grier, DPC Corporate Manager, .

describes notes given to him that date by P. K. Van Doorn. " Attached are notes from Kim Van Doorn...Kim will be recommending that no further interviewing is necessary in regards to his matter."

The resident inspector gave this memo to the utility on December 20, 1982. (Attachment 23) . By doing so Mr. Van Doorn not only violated the confidence of workers who came to the NRC in good faith but he also violated the NRC's policy regarding re-lease of draft information. 14/

A January 7, 1983 IE Report (50-413/82-32 and 50-414/82-30) confirms that the inspection was ongoing. The report, included as Attachment 24, reveals that, as of January 7, 1983, the investi-gation/ inspection was ongoing. An undated memo from P. K. Van Doorn to J.Y. Yo rse , Chief Investigator in Region II (Attachment 25) removes any doubt that the Resident Inspector did not understand the seriousness of the welding inspectors allegations.

B. Violation of 10 C.F.R. S 1.64, Duties of -

the Inspection and Enforcement - Regional Directors 10 C.F.R. S 1.64 states that:

The Office of Inspection and Enforcement develops policies and administers programs for: Inspecting liccasees to ascertain whether they are complying with NRC regulations, rules, orders, and license provisions, and to determine whether theec licensees are taking appropriate actions to protect nuclear materials and facilitates, the environment, and the health and safety of the public; inspecting applicants for licenses, as a basis for recommending issuance or denial of a limited work authorization, construction permit,.or an bSI This description was used by one of the welding inspectors to describe how they viewed the lack of NRC support.

14/ NRC policy regarding r? lease of draf t inspection and/or investi-gation reports is stated in the NRC Inspection and Enforcement Manual, S 1005 , and clarified in a March 8, 1983 letter from C. Nunzio Palladino to Congressman Edward S. Markey in response to a question regarding the policies regarding the release of draft inspection reports. The letter states, " current NRC policy prohibits the release of draf t inspection reports iwithout the express permission of the Executive Director for Operations".

NRC Commissioners Page Thirty-Four operating license; inspecting suppliers of safety-related services, components, and equipment to determine whether they have established quality assurance programs that '.

meet NRC criteria; investigating incidents, accidents, allegations, and unusual circumstances including those involving loss, theft, or diversion of special nuclear material; enforcing commission orders, regulations, rules, and license provisions; recommending changes in licenses and standards, based on the results of inspections, investi-gations, and enforcenent actions; and notifying licensees regarding generic problems so as to achieve appropriate precautionary or corrective action .. . NRC's five Regional offices are responsible for carrying out inspections and investigations.

Problems at the Catawba facility cannot be blamed entirely on the licensee. The Congress of the United States was very clear in its mandate to the early Atomic Energy Commission ("AEC") that monitoring civilian nuclear power projects was to be a major part of its-task. At least part of the responsiblity for the problems at Diablo Canyon, Zimmer, Midland, and Three Mile Island have rested with the regulators who " looked the other way" at utility misfeasance or lethargic imp 3 mentation of regulatory requirements.

In this case, the Regional Administrator responsible to the Commission, and ultimately to the public for the safe construction and operation of Catawba has failed to detect generic problems with the QA/QC program, the design control deficiencies, and the subse-quent hardware problens.

As pointed out in this report (supra, p.16 ) it was not until 1982 that DPC implemented its 1974 commitment to split the QA/QC f unction from Construction and Engineering. In this case DPC management has not just dragged its feet about bringing the Catawba construction project into compliance with 10 C.F.R. requirements

-- it has refused to do so. The Commission must ask Mr. O'Reilly why he never requested even an explanation of that situation.

Further explanations are needed to explain why the Regional Administrator did not respond to the serious allegations of harass-ment, intimidation and falsification of records brought to his attention by the resident inspector in January 1981.

Finally, in light of the generic deficiencies revealed in the INPO report (Attachment 1) , we request that OIA audit the regulatory program at Catawba in an attempt to determine or explain why DPC was allowed to build this plant according to the undocumented intuition of management, instead of to 10 C.F.R.

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L NRC Commissioners

_, Page Thirty-Five C. Violation of 10 C.F.R. S 1.64 (b) , Duties of the Executive Officer for Operations Support

' 10 - C.F.R. . $ 1. 64 (b) states that the Executive Officer for TOperations Support is responsible for, among other things,

" developing requirements. for enforcement and investigations; and

" assuring consistency of the enforcement program among the various offices."

Af ter a review of the documents on the public record it is clear that the implementation of the Commission's enforcement program has specific inconsistencies in relation to findings, violations, and programmatic deficiencies at the Catawba facility.15/

We ' list four examples as illustrative of our observations. These examples are not intended to be comprehensive.

1. In Process Inspection Notices ("IPIN ")

In Section-II,I, C of this petition (supra, p. 18) we describe this practice, first as -identified _ and acknowledged by consumer Power Company (CPC) .at its Midland Nuclear Power Plant (Units 1 and

2) ?in IE . Inspection Report 83-01 (Docket Number 50-329/330) and then as described in Catawba's . Quality Control procedure, Revision 9, " Control of Nonconforming Items."

We will exclude a detailed restatement of. the evidence available to the Commission. . A -full ' record of despocition testimony as well as workers statements confirms that _ the practice of either construction or Technical supervisors halting QC inspections "in progress," and subsequently requiring either rework, reevaluation, or " voiding" of NCI's has been common practice at Catawba since at least _ late

-1977.

The trending and documentation-issues raised by this practice are the subject of another portion of this pet 1 tion (supra , at 23)

-yet Region II's acceptance of this practice without recognition, violation notice, or enforcement action is unexplainable.

Consumers Power Company (CPC) was fined $60,000 ' for the IPIN practice. Regional Administrator Keppler ordered a technical resolution which requires 100% reinspection of all inspections affected by this practice.

! Catawba is the first ' and 'only Region II nuclear plant under construction that we have had experience with. We have worked with Region I,1I1, IV and V on problems at othe:. plants.

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1 NRC Ccmmiacioners Page Thirty-Six I

At' Catawba the NRC is silent.

, 2. Quality Assurance Breakdown  !

Section III, Specific ' Ba81s for Suspension, details th.

examples of violations of 10 C.F.R. Appendix B that we have selected for inclusion is this petition. We excluded the cumulative infor-ration from .NRC. Inspection and Er.forcensnt (IE) records available

.to.the Commission.

{

A review of the regional inspection and enforcement history

~

at Catawba reveals a reactive and " rubber stamp" regulatory program.

Alongside a review of Duke internal audits.and procedures the IE

' record is an almost useless source; of information about the history of the plant. In other words tha lack of enforcement action, and large numbers of low severity level notices of violations historically at Catawba does not serve as a measuring stick of the severity of the problems at the plant. g/

' At Zimmer' Cincinnati Gas and Electric (CG&E) was fined $100,000 for a' quality assurance breakdown in November 19 81. The fine came i ~ as a shock to CG&E because it was 97% complete and virtually enforce-j ment free..

However, as the November 13, 1981 letter to Cincinnati Gas and Electric Company (CG&E) states:

The._results of the continuing investigation reveal a widespread breakdown of your quality assurance program as evidenced by numerous examples of noncompliance with twelve of the eighteen different ~ criteria for a quality assurance. program as-set forth in 10 CFR 50, Appendix B.

The cause of the breakdown was. your f ailure to exercise adequate Loversight and control of Lyour principa1' contractors to whom'you had delegated the work.of establishing and execut-ing quality assurance programs. You thereby f ailed to ful-fill your vital responsibility as described in Criterion I of.10 CFR 50, Appendix B, to assure the execution of a quality assurance program.

• The i:mpact of the identified quality assurance defi-ciencies on the actual construction has yet to be determined. >

LLimited' independent' measurements were performed by the NRC in selected areas of concern in an attempt to characterize the actual safety significance of these deficiencies.

6/ A review.of the regional enforcement statistics reveals a high number of low' level violations in ' Region II with a small number of high'~ enforcement fines. (NUREG ).

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NRC Commiccionsro

- Paga Thirty-Ssvan Although a few problems requiring corrective action were identified (i.e. , four. unacceptably installed pipe hangers), the majority of the NRC independent measurements did not disclose hardware problems. ... recognizing that

• significant construction deficiencies could have resulted

• from the quality assurance problems identified during this investigation, the NRC has required the establishment of a comprehensive quality confirmation program to determine the quality of plant systems important to nuclear safety.

The NRC will confirm the adequacy of the program and may make additional independent verifications. Deficiencies identified by these programs will require resolution prior to issuance of an Operating License.

The results of this investigation and our review of your 10 CFR 50, Appendix B, noncompliance history reveal an additional matter which is of significant concern to us.

This matter - concerns inadequate corrective actions. The results of our normal inspection program for the construction and testing of Zimmer indicate you were found in noncompliance forty-four times since December 1979 with thirteen of the

~

eighteen different criteria of Appendix B to 10 CFR 50.

During our Systematic Assessment of Licensee Performance review on December _16, 1980, we expressed concern with your relatively poor performance -in this area. This poor history of compliance with 10 CFR 50, Appendix B, .when echsidered with the recent finding's of the investigation indicates Chat your corrective actions only addressed individual' problems and not underlying programmatic causal factors. Consequently we request that you review your history of noncompliance with 10 CFR 50, Appendix B, for the past two years and in your

. response- to this letter provide those steps you have taken to address and correct the underlying programmatic causal factors ~ related to the noncompliance.

Two years later at Midland a $120,000 civil penalty was imposed following the discovery of a quality assurance breakdown. Midland was 87% complete. The February 8, 1983 states:

The results of the inspection indicate a breakdown

_ in the implementation of your quality assurance program as evidenced by numerous examples of noncompliance with nine of the elghteen different criteria as set forth in 10

.CFR 50, Appendix B. The breakdown was caused by personnel ,

who f ailed .to follow procedures, drawings, and specifica-tions; by first line supervisors - and field engineers who~

failed to identify and correct unacceptable work; by construction management who failed to call for quality control inspections in a timely manner, allowing a backlog of almost 16,000 inspections to develop; and by quality assurance personnel who failed to identify the problems and ensure that corrective actions were taken. As a result,

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i NRC Commiocientra Page Thirty-Eight I

you failed to fulfill your primary responsibility under Criterion 1 of Appendix B to 10 CFR 50 to assure the ,

execution of a qcality assurance program. In addition, of particular concern to the NRC is the fact that quality .

ccatrol (OC) supervisors instructed QC inspectors to suspend inspections if excessive deficiencies were found during the ,

performance of inspections. Consequently, not all observed deficiencies were reported, and complete inspections were not performed by all QC inspectors af ter the reported defi-ciencies were corrected.

The evidence that has been available to Region II about a quality assurance breakdown at Catawba is more comprehensive, better documented, and virtually undeniable. Yet Catawba has reached 84%

complete with a clean bill of health.

10 CFR S 1.64 (b) requires reasonable " consistency" among the regions. It is unreasonable that the public living near Catawba should accept a lesser standard of quality and safety than the public in Ohio or central Michigan.

We urge the Executive Of fice for Operations Support to compare the QA/QC record of Midland, Zimmer and Catawba. 17/

3. Control of Contract Welders and Welding Procedures The October 1982 INPO report makes the following observations <

about welding and welding procedures of the HVAC contractor at Catawba:

No welder knew the weld procedure under which he was working.

Welder /rupervisor picks welding procedure from all avaliable welding procedures. Supervisor indicates weld-l~

i ing procedure (s) used on a support af ter the support is complete. (Attachment 1, p 36)

The response promised by DPC was A review with Bahnson personnel confirmed that the sign sof fs on the weld procedures constituted verifi-cation that the procedure meets the requirements of AWS D-1.1. A letter is forthcoming to verify this.

(INPO, p. 147.)

11! Of particular interest to us on this subject would be the analysis of Ms. Elinor Adamson Unit 4 Branch Chief of the Office of Nuclear Reactor Regulations (NRR) . Mr. Adamson is Branch Chief over Unit 4 which includes both Midland and Catawba.

NRC Ccmmis sicnnrs Page Thirty-Nine-Similiar situations at other plants have led to enforcement fines, ordered reinspections and rework for wel' ding performed by unqualified or uncertified welders and/or welding done to unapproved .

procedures. .

At Catawba.no violation notices were ' issued for the welding deficiencies, no NRC review was conducted of the work of the un-qualified / unverified welders, and no other en~forcement action was taken by RegionII.There has been no serious attempt made to determine the extent, or the cause of the HVAC welding. problems. No questions have been raised to DPC and no explanation has been provided from them about (1) how many welders were unqualified, (2) what procedures were flawed, .(3) what action has been taken' to identify all the

- welding of those unqualified welders, (4) when was the last audit DPC performed on the ' HVAC contractor, .(5) how long have the procedures -been non-conforming, and (6) what changes have been made to prevent this from recurring.

4. Harassment and Intimidation This petition (infra, p. 41 to 45 ) has requested the Commission direct the Office of-Investigations (OI)_to perform an investigation into the-improper handling of the welding inspectors'-harassment and intimidation complaints by DPC management.

We also request under S 1.64 (b) that the Commissica's Operations Support Office review the entire. record available on the welding

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inipectors charges of harassment and intimidation 18 / and compare -

the evidence with that used to support the $50,0.00 liarassment/

intimidation civil penalty fine at Zimmer in 1981.

In that case the NRC found that contrary to both 10 CFR 50 and CG&E policies OC Inspectors did- not have sufficient freedom to identify problems and were not sufficiently independent from cost and schedule. The'results of interviews indicate that some QC Inspectors were: (a) harassed by construction I workers and supervisors; (b) not always supported by QC management; and (c) intimidated.

[8,/ This information can be obtained by a review of the documents listed in Attachment 11, Freedom of Information Act (FOIA)83-200, and other relevant documents produced under discovery of " Contention Six - Quality Assurance" in the ASLB ' licensing proceedings. Docket 50-413, 50-414.

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NRC Commiccionsrs L Page Forty l

Examples of " insufficient freedom of QC inspectors, including insufficient freedom from cost and schedules: were listed as:

1. Five QC Inspectors interviewed executed signed sworn ,

t statements wherein they claimed they were~ doused with water (while engaged in the performance of inspection duties) by construction personnel. Two other QC-Inspectors made similar statements .-

2. A QC ' Inspection supervisor claimed that over his objections qualified QC Inspectors who were doing thorough jobs were reassigned by QC management because of complaints by con-struction personnel.

3. . Two QC' Inspectors executed signed sworn statements wherein they claimed they had been harassed by being searched for -alcohol by security personnel at the request of con-struction supervisory personnel. One other QC Inspector made a similar statement.

4. A QC Inspector executed a signed sworn statement wherein he claimed the QA Manager had threatened to fire him after con-struction personnel complained he had used a magnifying glass to visually inspect a weld when in fact he was using a mirror and either device was an acceptable tool.

5. A QC Inspector executed a signed sworn statement wherein he claimed he was struck by a stream of water from a fire extin-guisher while performing an inspection.

6. A QC Inspector executed a signed sworn statement wherein he claimed he was threatened with bodily harm by a construction

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person if he did not pass a weld.

7. A Lead QC Inspector executed a signed sworn statement wherein he claimed:

a. He was accused by the QA Manager for holding up a concrete pour when in fact the delay was caused by the concrete trucks being late.

b. Construction management frequently. approached QC Inspectors and challenged their inspection findings and questioned their judgment.

c. The QA Manager said things like, 'our job here is to accept, not reject, and we are here to get this plant built.'

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NRC Commissionara Page Forty-One

8. A Lead QC Inspector executed a signed sworn statement wherein he claimed he was relieved of his inspection duties because he continued to submit legitimate nonconformance reports over construction management objections for deficient -

- welds on pipe support hangers.- He also stated that QA: manage- -

. ment had previously told QC Inspectors to not write anything to make Kaiser look bad.

l 9. A QC Inspector executed a signed sworn statement wherein he claimed he was told by QA management to accept inspected itens that were unacceptable.

We know of no other case except Catawba where so many inspectors (over two dozen) provided so much concrete evidence to support their

, claims lof harassment, intimidation mui lack of independence from .

! cost and scheduling. (see documents listed in Attachment 11) .

The ' actions of a mid-level manager who threatens "to throw someone of f scaffolding" -if an -inspector writes another NCI or the

. brandishing of a shotgun to a QC inspector constitute the deliberate violations of 10 CFR-Part 19,.and 24 CFR Part 24, S210.

DPC has a duty.to enforce those laws. The absence of DPC's willingness to confront the harassment and intimidation complaints of its employees, dismissing them as "non-technical concerns" are the equivalent of condoning these activities.

Information' available' on the public record does not explain.why Region II did not take any enforcement action to insure that Duke's Catawba Management understood that 10 CFR -Part 19 was applicable to them as.well-as all the other utilities.

Just as the public is entitled _to equal protection from health and safety hazards that could result from poor nuclear construction, nuclear construction workers ~ are entitled to equal protection under

"- the Atomic Energy Reorganization Act.

V.- Request for a directed OI investigation F By letter dated April 21, 1983 GAP requested the. Office of Investi-

, gations (OI) to open an investigation ~into certain serious allega- ,

tions -- including harassment, intimidation, falsification of records, and approval of non-conforming items -- brought to the attention of both Duke Power Company Management and the NRC throughout 1980, 19 81, and .19 82.

To date, no OI investigation has begun. It is our understanding i

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. NRC Commissioners Page Forty-Two

-that our request was forwarded to the Office of Inspector and Auditor - (OIA) in May of this year, and that the investigation is .

still ongoing. However, even a closed OIA report, regardless of. -

the outcome, will not deal effectively with the question of delib-erate utility violations of the Atomic Energy Reorganization Act.

We- believe that it is critical that OI begin their investiga-tion immediately, therefore we request that the Commission exercise its authority and request the investigation.

. Our own review of the voluminot.s amount of information. regarding the entire episode, referred to as the " welding inspectors incident" indicates that both' the NRC staff and the utility ndsjudged and mishandled the warnings of QA/QC inspectors.19/ Only a complete, thorough investigation by the appropriate branches of the agency can resolve whether the mishandling and misjudgment was deliberate.

The chronology of events presented below clearly indicate the need for an investigation.. Catawba workers that GAP investigators have talked to confirm our own findings and conclusions. More important', . they confirm that QA/QC procedural flaws, hara.ssment/

intimidation ofE quality control inspectors and hardware problens continue en the site. (See Attachment 26 , affidavit of Billie Garde)

Unfortunately, the workers have nowhere to go with their problems

-- all roads lead back to Duke. Even our organization has determined that there is inadequate independence of ' the Regional NRC office from . Duke Power Company. In the current regulatory-vacuum we cannot, in good faith, provide the NRC with workers' affidavits -- we have no confidence that the workers' confidentiality'or information (thus their identity). will be protected (see Attachment 19, 7une 27, 19 83 letter from Mr. James P. O'Reilly to B. Garde regarding con-fidentiality) , and we have no confidence that the workers' infor-

. mation we would provide will be adequately addressed.

Summary of Welding Inspector Incident In late 1977 ' and early 1978 procedural changes in the Q-1, Non-conforming Item System, were implemented at the Catawba construction site. These changes took authority from the Quality Control Inspectors and placed~it with technical supervisors.

The Technical supervisors worked directlylunder and closely with

. construction / engineering.

19/ See Attachment 27 , " Groups Voice Catawba Plant Safety Questions,"

CEarlotte Observer, June 26, 1983.

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NRC Commission 2rs Page Forty-Three In 1978 Mr. G.E. " Beau" Ross began to document problems that he, as lead welding inspector, had identified as in non-compliance

' with the approved procedures. Soon af ter, other welding inspectors .

' aleo-began to write down, in logs or diaries, items which they

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were told to "not write up" as a non-compliance ("NCI") or incidents in which they were told to " sign off" on items which they1did not

-approve. In most of these incidents the welding-inspectors objected to the instructions, and documented their objection and

. any resulting arguments. This continued throughout 1978 and 1979.

Relations between the welding inspectors and the technical supervisors

.nnd QA/QC management continued to deteriorate.

In -the summer of 1980 two of the welding inspectors decided that the situation of construction and QA/QC supervision overriding NCI's ~

had gotten out of hand. They went to talk to the resident NRC inspector. Within days, the resident inspector had reported the complaints of the inspectors back to the main target of their complaints, he alsG informed DPC of the fact that the welding inspectors were ' keeping logs of the changed NCI's. The resident inspector left Catawba in late summer 1980.

t In January 1981 DPC management and the NRC met to discuss the

' welding inspectors concerns." In February 1981 the new resident Anspector arrived, Mr. P.K. VanDoorn. During this same time period . the Systematic Assessment of Licensing Performance (SALP) was released and a _special team inspection was conducted at Catawba -- both revealed quality assurance / quality control problems. During the same time period a large number of specific quality assurance-related deficiencies, violations, and discrepancies appeared in -IE reports. '

(See IE reports 1977 through 1981.)

In June / July 19 81 Lake Power Company decided to " downgrade the. pay" of the welding inspectors. The inspectors complained that the downgrading was a direct result of their continued implementation of _ QA/QC procedures on the site. They began the official complaint procedure through Duke. Power Company's employee recourse orocess.

In December 1981' their complaints were reviewed by the Chairman of the Board, William Lee. He rejected their complaints. However, he initiated a task force to deal with their concerns.

Three weeks later the task force finished its report, dismissing

'the problems. This was reported at a meeting with the NRC in January

-1982. The welding inspectors, however, againawent to the NRC and reported that the task force was a " whitewash." These complaints were. transmitted back to Duke Power Company. Duke - then initiated a second task _ force and hired the Management Analysis Corporation

_(MAC) to conduct a review of the problem with " skilled interviewers."

MAC's contract with DPC included a provision that MAC be prepared to testify-for DPC in the operating license hearings, if necessary.

NRC Commicsion:rs -

Page Forty-Four On March 24, 1982 W.J. Tobin, Regional Investigator provided C.E. Alderson the Director of EIS with the initial summary of Case No. 2G022. He attached two memos from VanDoorn which " Jack Bryant suggests we date as March 15, 1982."

The memo stated among other things:

I am impressed with the magnitude and specificity of these concerns, as I am with the fact that we are dealing with employees, versus an isolated former employee, who are apparently- presenting their concerns to the Duke task force reviewing welding problems at the Catawba site. (Attachment 28)

In May 1982 the Duke Power Company management made a presentation' to Region II personnel t including the Regional Administrator.

Their conclusions are included in a two-volume report available in the Public Document Room, entitled, Welding Inspectors Task Force.

Essentially the MAC task force and subsequent corrective action dealt with the problems by (1) talking to all the welding inspectors, (2) identifting all of their concerns, (3) dividing up their concerns into " technical and non-technical" (4) having all of the technical complaints either repaired, re-evaluated, or re-worked until the complaining inspectors were convinced that all of their specific problems were solved, (5) recommending to Duke a strengthened communication program between the inspectors and construction personnel. The task force did not address the question of harassment, intimidation, or procedural QA/QC flaws.

In late August 1982 another meeting took place between the NRC and DPC about the welding inspector concerns, Soon after, the resident. inspector went to see DPC e phyee Bradley to " scan" the files of the information contained in the MAC report, and to notify DPC that he was about to begin his investigation of the welding inspectors' concerns,and would notify them of his findings.

i On December 22, 19 82 P.K. Van Doorn met with George Grier to discuss his findings during his investigation. He also gave Mr. Grier, DPC QA Manager, a copy of his notes--which included a summary of the concerns of Catawba welding inspectors. On January 7, 1983 an IE report was issued which contained a partial resolution on.the case, but which held open NRC review of the corrective action ,

In February 1983 the " case chronology records" of Region II report that the case was closed. In March 1983 the case is reported closed in an IE report.

In March 1983 the Palmetto Alliance was granted discovery of Contention Six and Seven regarding Quality Control / Quality Assurance issues in the ASLB operating lic aing proceedings. In response to interrogatories about " disputes between management and workers" the information about the wieding inspector complaints was revealed by Duke Power Company.

NRC Commisioners Page Forty-Five In June 1983 Mr. Ross filed a second employee recourse complaint to protest the low ( a "2" on a scale of "5")

performance rating-that he received. It was the first rating he had * -

ever received that was not outstanding. He protested that1the ilow rating was

'a direct. result of the complaints he had raised about QA/QC violations and harassment. He also complained that'the new supervisor, Mr.

~ Art Allum had been brought in to build a negative record on his performance.

By July 1, 1983 Mr. Allum had been removed as his

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supervisor. , and Mr..Ross had been couns&lled about the fact.that the Intervenors would be putting the

" worst face possible" on words like " harassment, intimidation, and falsification of records."

In August 1983 welding inspectors continued to file

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employee recourse complaints about harassment and intimidation by their supervisors.

(All of the documentation detailing the above record is available by a review of the documentation provided in discovery in the Catawba licensing proceeding. In the event that the Commission would like GAP to present a detailed documented

' chronology of the well ag inspectors experience at Catawba, we '

will do so.)

- Conclusion-The' laws governing the construction of nuclear power plants were not written'to be applied differently in five areas of the country.

Nor was Criterion B of 10 C.F.R Part 50 written- as a guide for the utilities to implement at their leisure. Yet Duke Power Company management decided that QA/QC independence was an option at Catawba, n6t a requirement.

It was not an accident that Catawba was rated below average in the -first SALP report. It deserved that rating. Unfortunately for the residents . that surround the Catawba plant and for the l

municipalities that have purchased the plants' power Catawba is still below average.

l l All the othbr plants in the original "below average" category have since undergone major reinspections. These reinspections c have discovered major hardware problems that have required years i to identify, repair, and rework. It is an illusion to think that

! Catawba does not also need to be scrutinized because it was built by Duke Power Company. There is no footnote in the law that j excludes' Duke from it, and there are no inspection standards which i exempt a plant -f rom ' the stringent quality control requirements j that Congress he.s placed in the law.

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NRC Commissioners

. Page Forty-Six  !

l It has taken, as it always seems to take, a group of quality control inspectors who were willing to risk their jobs and their careers with Duke Power to demand that QC be implemented ,.

at the Catawba site. They were successful.

If the Commission fails to intervene on behalf of the QC inspectors, however, they will have all raised their complaints in vain. The Regional Director has decided that this was Duke's problemy and he let Duke handle it in their own way. But just as the utilities are not exempted from the consequences of isolated incidents which come to the attention of the NRC, the Regional Administrator cannot be exempted from establishing a regulatory atmosphere that does not tolerate any harassment or intimidation of nuclear workers.

Mr. O'Reilly has placed the burden of standing up to licensee management squarely on the back of the workers to insure that Catawba is built according to 10 C.F.R. That is the responsibility of this Commission.

We look forward to your response to this Petition in the near future.

Sincerely, ,

A Billie Pirner Garde Director Citizens Clinic ccfw enclosures Service List, ASLB H. Denton, NRR D. Eisenhut, NRR T. Rehm, EDO V. Stello, IE B. Hayes, OI J. Cummings, OIA W. Dircks, EDO J. O'Reilly, IE, RII cc/wo enclosures P. McKenna, OIA E. Adamson, NRR m -

4 LIST OF ATTACHMENTS 1

Attachment j Number Name of Document 1- Construction Project' Evaluation for Catawba Nuclear Station . (INPO ' Report) 2 Deposition of William.R. McAfee 3 Quality Assurance Procedure R-3, Design l . Drawing and Specification Variation, Revision 9 4 Quality Assurance Procedure R-3,. Design Drawing and Specification Variation, Revision 5 5 Quality Assurance Procedure R-3, Design Drawing and Spe:.:ification Variation, Revision 7 6 Quality Assurance Procedure R-3, Design Drawing and Specification Variation, Revision 8

.7 Quality Assurance Procedure R-3, Design-Drawing and Specification Variation, Revision 13 8 Quality Assurance Procedure R-3, Design Drawing and Specification Variation, Revision 17 9 Systematic Assessment of Licensee Performance, August 1981-9a 10 Deposition Report: Lack of William Lee, Ju[ld1%

of-Support 1983QC Welding or the Inspectors and for the QA Program 11 FOIA-83-200 response letter from NRC, 5/19/83 12 Quality Assurance Procedure Q-1, Control of Nonconforming Items, Revision 5 13 Letter from James Keppler to James Cook (Consumer Power Co.), 2/8/83 14 Quality Assurance Procedure Q-1, Control of Nonconforming Items, Revision 11, p.2 15 Quality Assurance Procedure Q-1, Control of Nonconforming Items, Revision 12, p.2 16 Quality Assurance Procedure Q-1, Control of Nonconforming Items, Revision 15, p. 3 17 Quality Assurance Procedure Q-1, Control of Nonconforming Items, Revision 17, p.5

.18 Letter from GAP to NRC Office of Investigation, 4/21/83 19 Letter from James P. O'Reilly to B. Garde, 6/27/83' copy of speech attached 20 Memorandum from K. Karriker to B. Morgan, 1/14/82 21 Deposition of Larry Davidson, notes of meeting between'L. Davidson and L. Zwissler, 2/5/82 22 U.S. NRC Memorandum for Jack Bryant from C.L. Alderson, 5/18/82 23 George Grier, Memo to File, 12/20/82 24 IE Report #50-413/82-32 and 50-414/82-30 25 Undated memo from P.K. VanDoorn to J.Y. Yorse 26 Affidavit of Billie Garde 27 Charlotte Observer article, June 26, 1983 28 U.S. NRC Memorandum for C.L'. Alderson from W.J. Tobin, 3/15/83 1

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- Attachment #1

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Duke Power Company' Construction Project Evaluation for Catawba Nuclear ~ Station m

Dl!KE POWER ,

October,1982

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CONSTRUCTION PROJECT EVALUATION FOR

_ CATAWBA NUCLEAR STATION UNITS 1-2

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September 27 - October 14, 1982 7'

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'i c DUKE POWER COMPANY

, CHARLOTTE, NORTH CAROLINA

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P TABLE OF CONTENTS SECTION TITLE PAGE A. Scope 1 B. Sunnary ~ 2 C. Performance Evaluation 3 Sunnary D. Response Summary 97

1. Design Engineering 98

2. Construction 122

3. Quality Assurance 142 E. Appendix A 156

1. Observation Sheets 157 O

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Scope The evaluation was a "self-initiated" review of work being done by i

the Design, Construction, and Quality Assurance Departments on the Catawba Nuclear Station. Personnel conducting the evaluation were employed by Duke Power Company and the Tennessee Valley Authority (see the resumes that follow). Evaluation team members were selected on the basis of their experience in design, construction, and quality assurance. Duke team members had little direct responsibilities for

( activities at the Catawba site and none in the areas they reviewed.

To prepare the team members for the evaluation, INPO trained key

- team members in the methodology of the "self-initiated" review. These Individuals then trained the other team members.

The evaluation consisted of fleid observations, interviews, and review of supporting documentation.

NOTE: This evaluation did not include a review and assessment of vendors supplying permanent plant materials and equipment in areas other k than HVAC. In addition the evaluation did not include any preoperational 4 testing beyond the testing performed by Duke's Construction Department.

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SELF INITIATED EVALUATION TEAM-MEMBER RESUMES

>.' BELLEFONTE NUCLEAR PLANT - TENNESSEE VALLEY AUTHORITY CATAWBA NUCLEAR PLANT - DUKE POWER COMPANY r-L

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(1) Paul A. Evans, Principal Mechanical Engineer, TVA - Manager of the Catawba Nucles,r Plant Evaluation M3 and BS in Mechanical Engineering and registered engineer in the State of Tennessee with 12 years of experience in design and construction of nuclear power plants. From 1970 to 1973 he served C various assignments in the Mechanical Engineering Design Branch with responsibility for developing mechanical piping and equipment design criteria for assuring structural adequacy of design and

,. prepared input for safety analysis reports. Responsible for the management of mechanical engineering sections having technical responsibility for the development of design criteria, conducting design reviews, performing specialized technical analyses, and performing evaluations of equipment and structures for seismic and r

accident loading effects. In addition, he has managed construction L control evaluation teams for the Institute of Nuclear Power Operations at three nuclear plants.

, (2) H. L. Huggett, Coordinator, Special Projects, Duke Power Company -

2 Manager of the Bellefonte Nuclear Plant Evaluation

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, BS in Mechanical Engineering and 12 years of nuclear power plant I

design experience. Responsible for developing power piping design and equipment design. Supervisor of cost estimating and integrated schedules of nuclear plants under construction. Additional duties f

[ included the scheduling and estimating of nuclear capital improvements on existing plants. Present duties include Special Project assignments concerning nuclear engineering and project control.

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{ (3) Roy D. Anderson, Assistant Electrical Engineering Supervisor, TVA y BS in Electrical Engineering with 9 years of experience in

, construction of nuclear power plants. He was employed with Alabama Power Company from June 1974 to June 1975. He served as lead engineer at TVA's Watts Bar Euclear Plant responsible for safety u

> systems from June 1975 to November 1980. He worked on a task force to establish requirements manual and adjust procedures from November 1980 to September 1981, and currently serves as assistant supervisor electrical engineering at Watts Bar.

(4) Marvin R. Belew, Senior Electrical Engineer, TVA BS in Electrical Engineering with 16 years of nuclear power plant design and construction experience. This experience includes 5 years of responsibility for design modifications and maintenance of I the Oak Ridge Research. Reactor, 1 year of responsibility for writing test procedures and performing preoperational tests for i

commercial nuclear plants, 4 years of responsibility performing electrical engineering design for boiling water reactors (BWR), 5 years supervising of a BWR instrument and control design section, I

and 1 year as staff engineer with responsibility for the technical review and correctness of all instrument and control design work on TVA nuclear plants.

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(5) D. T. Clift, Senior Nuclear Engineer TVA BS degree in Mechanical Engineering with 12 years experience in the design of nuclear plaats principally in the mechanical and nuclear I engineering disciplines. This exp rience includes 2 years responsibility for mechanical design of intake pumping station, 6 I

years responsiblity for the technical administration of the nuclear

.g steam supply system contracts, and 4 years responsibility for i

safety systems analysis, preoperational test support, and providing engineering support for operating nuclear plants.

(6) Douglas M. Franks, QA Surveillance Supervisor, Duke Power Company

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BA degree in Economics with 12 years of experience in the nuclear L.-

power field. Five years experience were gained in the nuclear navy in operation and maintenance of the nuclear power plant on a nuclear submarine. Two of his seven years experience in the power industry as been directly involved in inspection, supervision, and technical quality assurance matters. The remaining five years

, involved directing audit and surveillance activities during the operating and construction phases of nuclear' sites, including development of audit and surveillance programs and technical interface with project management.

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!c (7) D. L. Freeze, Manager - Oconee Station Support Division, Duke Power Company ES in Civil Engineering and a registered engineer in North Carolina i

.. and South Carolina with 16 years of experience in construction of h ,

nuclear power plants. From 1967 to 1974 he participated in various assignments in the construction of Oconee Nuclear Station. The ._

last 3 years of that assignment included responsiblity at the site 4

for construction engineering, planning and scheduling, and quality control. From 1974 to 1981 he served as a Project Engineer at the-i Catawba Nuclear Station responsible for. construction engineering, planning and scheduling, and quality control. In 1981 he served as Manager of Construction Services Organization, coordinating department scheduling, budgeting, materials control, and work methods L.

activities. Presently he is assigned as manager of a construction division responsible for capital improvements and modifications at Oconee Nuclear Station. The two largest of these additions being a L

standby shutdown facility and a radwaste facility.

I (8) Clancy Glidewell, Principal Civil Engineer, TVA BS in Civil Engineering with 23 years of experience in design and construction of power plants. His experience includes 6 years

( design of concrete structures for fossil and hydroelectric i'

facilities, 2 years design of concrete structures for nuclear generating facilities, 6 years supervisor of design unit involved in design of nuclear generating facilities civil structures, and 8 1

years as a structural engineering specialist involved in licensing and design of nuclear generating facilities. Experience includes preparation and/or review of specifications, criteria, procedures, scope documents, scheduling, research and development, resource allocations, reports, and cost.

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(9) J. R. Hendricks, Jr., Principal Engineer, Duke Power Company BS in Civil Engineering and MS in Water Resources Engineering, a P'

Registered Profes:!onal Engineer in North and South Carolina, with 11 years experience in nuclear power plant design. This experience lF includes responsiblity for supervising the development of overall nuclear plant layout and geometry, specification of coatings for g nuclear plants, development of hazards analyses, fire protection

!1 il programs for nuclear plants, and development of environmental requirements for nuclear plants applicable to new and operating facilities.

W (10) A. R. Rollins, Jr., Manager of Construction Services, Duke Power Company BS in Mechanical Engineering with 12 years of experience in L

construction of nucient power plants, performed welding engineering function for Duke Power Construction at the Oconee Nuclear Station from 1970 to 1974. Supervised the Duke Power Construction welding engineering section at the Catawba Nuclear Station from 1974 to 1977. Senior Quality Control Engineer for Duke Power Construction at the Cherokee Nuclear Station from 1978 to 1980. Supervisor of the Duke Power Construction Engineering Support / Restraint Group from 1980 to'1982'. Manager of Construction Services for Duke Power Construction 1982 to present.

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(11) B. M. Rice, Senior Engineer, Duke Power Company 3

BS in Electrical Engineering with 18 years of experience in design and construction of nuclear power plants. He-possesses management and supervisor experience in the' design of instrumentation, control, and power systems design and equipment specificatio'n, and

( has extensive experience in licensing, regulatory requirements,

.r i and industry codes and standards.

(12)

Glenn Robinson, QA Mechanical Engineer, Duke Power Company BS in Mechanical Engineering with approximately 14 years experience in construction of nuclear power plants. He served 3

. years in a mechanical technical s6pport function at Surry for Stone and Webster. He then was employed by the Duke Power Company where he served approximately 3 years in a mechanical technical support role at the Oconee and McGuire sites, and for 8 years in i.

mechanical construction quality assurance at the McGuire Nuclear Station.

(13) M. N. Sawyer, Mechanical Engineer, TVA BS in Mechanical Engineering'with 15 years of experience in L

construction of nuclear power plants. In 1968 he was assigned various responsibilities in the Browns Ferry Nuclear Plant,

. Construction Division as a mechanical engineer. In 1969 he was

I, transfered to a new section to write procedures addressing appendix B where he served through 1971. He was then promoted to 1

a supervisor with responsibility for performing preoperational 4

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tests on Browns Terry. In 1977 he was transfered to the 1" Hartsville Nuclear Plant as a supervisor of the Engineering Services Group where he served through 1979. He was then transfered to the Construction DiYision to form a new organization to handle modifications and additions to operating nuclear plants

'l and is currently serving in that capacity, l

I (14) P. A. Schrandt, QA Engineer, TVA BS degree in Mathematics with 6 years experience as a quality assurance engineer. This experience consists of four years as the 1 Design QA Engineer for Yellow Creek and Bellefonte' Nuclear Plants,

, one year experience as a materials engineer, and one year on special projects. Experience in QA includes developeent of QA

[ procedures, responses to 50.55e items, review and approval of engineering procedures'and specifications, special quality i

l assurance investigations, and numerous committees on 10CFR50, L

ASME, AWS, and ANSI interpretations.:

Previous experience consists of three years as an engineering supervisor in nuclear submarine overhaul, seven years as a senior test engineer in cryogenics on the Saturn V Program, and 10 years in construction as a senior resident engineer .in the aero space field.

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. g (15) H.,S. Sh'e'ppird.LAssistant Construction Engineer, TVA e:.

j BS in Building' Conbruction with 25 years of experience in power

, plant construction. From 1958 to 1963 he served as an of fice engineer with various assignments"in the Office Engineering Unit i

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.- ( on a coal-fired steam plant. From 1963 through 1966 he served

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s s vailous assignments in the Concrete,and Soils Unit. In January

- y 1967 he was promoted to Group Leader for the. Concrete and Soils Unit a7d Browns Ferry Nuclear Plant and served in that position through November 1972. He was then promoted to Supervisor, Civil

, Engineering Unit at Watts Bar Nuclear Plant where he served L through March 1977. In March he was then transfered and promoted to Assistant Construction Engineer, Quality Control Section with

' responsibility for all inspections at the Hartsville Nuclear

[ Plant.

L (16) Stephen P. Stagnolia, Welding ngineer, TVA BS in Mechanical Engineering with 15 years of nuclear construction i

experience. This experience consists of 5 years with various responsibilities for performin; mechanical engineering functions associated with piping installation, condenser erection, equipment startup and test, material receipt inspection, and as Welding Engineer and Inspector. The succeeding 9 years he filled various assignments working as a Welding Engineer and Inspection Lead Engineer and as Welding and Inspection Unit Supervisor in charge of all welding and inspectien. He currently serves as Staff Supervisor Construction Welding Engineering Staf f responsible lor the overall program in the Division of Construction and providing welding engineering services and consultation for the Construction Division.

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(17) 7. F. Vyke, Principal Engineer, Duke Power Company p HS in Nuclear Engineering with 21 years of experience in design of nuclear systems and power plants. He worked for 5 years for Westinghouse Electric Corpo/ation, Atomic Power Division, responsible for various assignments in nuclear fuel engineering

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i and performing reactor performance testing. He has 16 years of experience in the Design Engineering Department of Duke Power Company. This experience includes performance of and/or responsibility for work in the areas of radiation shielding and nuclear fuel analyses; mechanical equipment application and fluid system engineering; piping material application; station service system engineering and design, pipe support design, and layout of power piping, l (18) Carey F. York, Manager, Mt. Holly Station Support Duke Power

, Company MS in Civil Engineering and Registered PrJfessional Engineer in North Carolina with 16 years experience in construction of power plants. From 1967 to 1974 he was involved in various assignments during the construction phase for the Keowee and Jocassee Hydro Stations. From 1974 to 1980 he served in a staff position in the s

, construction department, responsible for developing department wide policies and procedures scandards applying to nuclear construction related to materials, planning and scheduling,

, welding, earthwork, and budgeting areas. In 1980 he served at Hanger Manager in the Construction Department at the Catawba i

{ Nuclear Plant. From 1981 to present he serves as Division Manager

, for the Station Support Division in the Construction Department.

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SUMMARY

Introduc'lon t l An evaluation was conducted of design and construction activities l

at Duke Power Company's Catawba Nuclear Plant Units No. 1 & 2 during the period from September 27 through October 14, 1982. The evaluation was initiated by Duke Power Company and was conducted by an evaluation

- team compri:ed of senior technical and management personnel from Duke Power Company and Tennessee Valley Authority. The evaluation team utilized performance objectives and criteria developed by the Institute of Nuclear Power Operations specifically to support the institute's sponsoring utilities in this type of evaluation. . The plant, which is located in Clover, South Carolina will be two 1145 MWe (Westinghouse)

PWR Units. Unit I is about 90% complete and is scheduled to begin comnercial operation in 1985.

Statement of Purpose o The purpose of this self-initiated evaluation was to facilitate the general upgrading of this plant, and the nuclear industry as a whole, to a higher level of excellence in the design and construction of new facilities. A true appreciation of this effort can best be achieved by a review of the performance objectives, the results, and the corrective actions specific to this evaluation as contained in the body of this report.

Overall Assessment Within the scope Gf this evaluation, the team determined that the plant was being designed and constructed by well-qualified personnel. Once the facility is completed, we are confident that the plant will perform its intended functions and operate safely.

Certain Strengths were noted as follows:

1. A strong corporate committment to design and construct a safe facility.

2. Construction facilities and equipment are planned for, acquired, installed, and maintained in a manner consistent with projects needs to support quality construction.

3 Project scheduling and work planning were in order and are making effective and efficient use of project resources.

4. The procurement of equipment, materials and services was_ adequate to meet project requirements.

5. The management of project documentation was reviewed and found to provide 2

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. a strong base for the plant's operational stage.

7 (6) Management has shown support of training by hiring an outside consultant to review.the Inplace training techniques and performing a "needs analysis".

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7. Quality Assurance and Quality Control functions were performed adequately and Independently to support and controf the quality of the facility.

P Improvements Were Recommended in a Number of Areas: The Following are Considered the Most important:

(DC.1) 1. Procedure for the responsibility, Issuance, and control of Design input needs to formalized.

(DC.2) 2. Coordination on Design changes between the design disciplines should be improved.

(DC.4) 3. Formal program is needed to review design documents to assure constructability,

4. maintainability, and operability.

3 (QA.3) 4. Managers and supervisors need to be reminded to enforce adherence to all plant policies and procedures.

a (CC.3) 5 A Construction program should be implemented for site material control.

(CC.4) 6. Closer control and monitoring of activities conducted by the W/AC contractor (QP.1) is necessary. ,

(CC.5) 7. Inspection procedures need to be clearer in their definition of requirements.

((p 8f Assessing generic Impilcations of construction protilems need to be considered more often.

, (QP.3) 9. Independent assessment of quality related activities should be incorporated into a progrcm.

(TC.1) 10. Methods and procedures used to perform system testing needs to be reveiwed and Individual responsibilities need to be more clearly defined.

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r PERFORMANCE EVALUATION

SUMMARY

Construction Project e <

Parformance Area Organizatieonal Structure Objective No. OA-1 Evaluator (s)

I. Performance Obf.ective The owner's corporate organization and all other project organizations responsible for the design, engineering, planning, scheduling, licen-F sing, constrnetion, quality assurance, and testing of a nuclear plant should provide an organi:ational structure that ensures effective project management con *.rol.

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II, scoce of Ivaluation 6

l The scope of evaluation covered in this area was mainly the Chief Enginee.s and i= the Vice President of Design Engineering, the Project Manager and Vice President

' of Construction, and the Corporate quality Assurance Manager's office. A total of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> by two evaluators were utilized to accomplish the evaluation which consisted of interviews, review of documentation delineating organizational structure, and attending meetings where Managers were involved.

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III. Conclusien The activities evaluated under this performance objective were found to be j satisfactory.

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PERFORMANCE EVALUATION SUMMIM Construction Project Catawba Nuclear Station

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MANAGEMENT INVOLVEMENT AND Porformance Area __couvTmvr'2? a'n niis'.TPv Obj ective No . ,,g3,__2, Evaluator (s) , , _

I. Performancs Obiective Senior and middle managers in the owner's corporate office, desigt.er's office, and at the construction site who are assigned functional responsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness, and knowledge, a direct involvement in significant decisions that could affect their responsi-bilitie..

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II. Scoce of Evaluation The scope of evaluation included the Project Manager and his imediate staff of the Construction organization, the division Chief Engineers and their immediate staff of the Design organization, and the Corporate Quality Assurance Manager and his immediate staff. The evaluation consisted of interviews, document revlee of examples of management involvement,and walk-through activities that enabled demen-stration of involvement either before or during the walk-through. Approximately 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> were utilized by the total team for this evaluatice..

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III. Conclusien All managers demonstrated, in general, a good understanding of the activities for which they were personally responsible and maintain an action tracking system for followup. One area for which a weakness was expressed by some managers was the

..relatively low visibility experienced at the Construction site. In some instances,

-l. Managers stated they spend less than 5 percent of their time in the Construction l l area. No finding was developed for tnis case. With this one exception, the acti-t e

vities covered under this performance objective were considered satisfactory. i

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PERFORMANCE EVALUATION

SUMMARY

Construction Praject Catawba Nuclear Station

.l THE ROLE OF FIRST LINE SUPERVISORS POrformance Area ANO MIDDLE MANAGERS Objective No. CA-3 V

i Evaluator (s) -

I. Performance Objective l The project first line supervisors and middle managers should be l goalified by' verified background and experience and have the necessary 1 authority to carry out their functional area responsibilities.

-1 .

II. Scoce of Evaluatien 1

The scope of evaluation covered by this objective included craf t foremen and supervisors of the Construction Manager's staff and group supervisors in the Engineering divisions and the Quality Assurance Department. The evaluation con- 1 i

sisted of interviews, walk-through of areas of responsibility where appropriate, I

.i and documentation review. Approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> were utilized by all members of the evaluation team. .

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t III. Cenclusien First-line managers, in general, were very knowledgeable of their responsibilities and demonstrated strong commitment to the program. Uncertainty was expressed in areas where the matrix form of management was being implemented but was felt to be no more than expected at the stage of imolementation that existed during the evalua-tion. Therefore, it is concluded that activities related to this performance j cbjective are being conducted in a satisfactory manner.

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. - + . - . . . . , . , , - - - , --.--,---.~,.--+-,n .

r- PERFORMANCE EVALUATION

SUMMARY

ConStructicn Projcct i

CcttwSc Nuclocr Station

~

The Role of First Line Supervisors P rformance: Are.s , and Middle Manaoer Objective No. 0A.3 Evaluator (s) P Evans /H Huacett IV. Areas of weakness and corrective action: Good Practices Finding ,

(OA.3-1) Managers a,nd Supervisors do not always enforce adherence to

g. plant policies and procedures.

(Factual information CC.I, CC.4, CC.5 and PS.1) 1 .

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PERFORMANCE EVALUATION S W.ARY Construction Project Catawba Nuclear Station

',. Performance Area Desien.Ineuts Objective No. ne 1 Evaluater(s) C Glidewell I. Performance Obiective Inputs to the design process should be defined and controlled to achieve complete and quality designs.

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II. Sceee of Ivaluation

[' The evaluation of this area involved essentially three members of the team. Approxi-a mately 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> were expended in Interviews, document review and research at various locations within the Design office.

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III. Conclusion 4

! 4 The v::st majority of activity evaluated under this performance ot 'tetive was

! generally satisfactory. However, there were a number of weakness s identified

, that Indicated a need to strengthen certain aspects of the organization.

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e PERFORMANCE EVALUATICH SU0'.ARY Construction Project Catawba Nuclear Station Perfor:tance Area 5sion Inout Objective No. DC-1 i

Evalpator(s) C 31idewell i

IV. Areas of weakness and corrective actient Good Practices Finding No requirement exists for identifying, tracking and assuring commitments i (DC.1-1) Identified in the PSAR are met. Design information should be clearly OE defined and controlled.

F Finding No control program for defining respon:Ibility for providing Design input (DC.1-2) could be found. Input is usually provided on a request basis.

Finding Design input information is not always provided in a controlled manner.

(DC.1-3) Memorandums serve as the primary vehicle for documenting Design input.

1, Finding $ystem descriptior.s and flow diagrams do not always agree as to the c (DC.1-4) current requi rements. Several system descriptions were observed to lag revisions of system flow diagrams. .

No documented program was found for assuring correct epplication of

~

, Finding (DC.1-5) seismic response spectra.

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PERTORMANCE EVALUATION DETAILS Construction Project i'

Catawba Nuclear Station I ,

e.

1. Perfor: nance Areat Desien Inout Objective No. DC-1 (title)

{ . 2.. Provide factual information that suecorts the Performance Evaluation su= unary

- 1. From interviews, literature searches, and document reviews within he Civil /

Environmental Division, the Project Management Division, and the Safety Review Analysis and Licensing Division, no requirement could be determined to exist for Identifying and tracking PSAR commitments. The Safety Review Analysis and Licen-I sing Division does compile a IIst of commitments of which they are aware and track them to completion.

- 2. From interviews, IIterature searches and document reviews in the Civil /Environmenta

, Division, no control program for defining responsibility for providing Design input could be determined to exist.

[ J.

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Personnel interviews within the Civil / Environmental Division showed a very good

l, understanding of existing procedures and in carrying out the requirements of the procedures.

g

4. Interviews, literature searches, and document revisions in the Civil / Environmental Division showed Design input is provided through memorandums,* specifications, w-intra-and inter-disci,plinary discussions and meetings.

5 A review of Specification CNS-1108.00-00-0002, Volumes I and ll and interviews within the Civil / Environmental Division showed no Ir.structions on the use of the i ,

spectra contained in the specification existing.

6. Review of Specification CNS-1108.00-00-0002, Volume ! and 11, a controlled docu-ment, showed the manuals contained no name, number or unique identifier to assure control of the eunuals is being maintained.

7 From personnel interviews and document reviews in the area of support restraint design, no program requirement for conducting constructability, maintainability, or operability reviews was found to exist; however, these areas are considered in the modeling and review of support restraints.

8. Personnel Interviews and document reviews within the Mechanical / Nuclear Division showed system descriptions / flow diagrams, both controlled documents, are in disagreement.

9 Review of issued Mechanical and Electrical system descriptions showed the two system descriptions did not agree (RHR System).

10. Interviews and document reviews in the Electrical Division showed the Auxiliary Feedwater and the Residual Heat Removal system descriptions for Electrical systems and Mechanical systems do not agree.

8

F PERFORMANCE EVALUATION DETAILS Construction Project (

Catawba Nuclear Station l

l

1. Performance Area: Design input Objective No. DC-1 (title).

2. Provide factual information that succorts the Performance Evaluation '

Summarv - .._..

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11. Interviews with personnel of the Electrical Division showed a lack of concern for j the system descriptions not being current with Design drawings.

12. The Auxiliary Feei:lwater Electrical System description does not agree with the '

-1 elementary electrical diagrams and the Mechanical System description.

i 13 Interviews with Electrical Division personnel revealed no program for providing and controlling DerIgn input exists.

14. The individual Instrument accuracy infertr.ation supplied by the Mechanical instrument and Control Group to the Electrical Equipment Qualification Group for the NUREG 0588 Electrical Equipment Environmental Qualification Report for instrument loops con-talning both mechanical and electrical components are not based on the total loop accuracy. They are based on the system requirements supplied by the mechanical process engineers.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station F*

.Parfo_ryuLnce Area DESIGN INTERFACES Objective No. DC-2 .

g-D T Clift Evaluator (s) , ,,

I, Perfor:sance ob$ective , ,, _

Design organization external and internal interfaces should.be identified an'd coordinated to ensure a final design that satisfies all input require:sents.

F -

II. Scoce of Evaluation _

The evaluation of the performance objective involved several members of the team.

. The evaluation included discussions with responsible engineers, designers and supervisors in the Mechanical, Electrical and C1vil Design organizations. Interface p.

documents were reviewed and compared with Design input data for the RHR and AFW ,,_ ,_

Systems. Appr9ximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> were expended in the evaluation of this objective.

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q III. Conclusion The majority of the activities evaluated under this performance objective was sa*isfactory. However, several weaknesses are identified that indicate a need to strengthen certain aspects of the centrol of Design interfaces and Design input

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1

lr- PERFORMANCE EVALUATION

SUMMARY

Construction Project j' Catawba Nuclear St, tion r

Perfor: nance Area Deslor. Interfaces ,

. Objective No. DC-2 Zvaluator (s) l IV. Areas of weakness and corrective action: C-cod Practices I

ding The process for controlling Design input documents does not require timely

,, ~

[(DC.2-1)updating of system descriptions. The RHR and AFW System descriptions are n'ot ;nalntained current with system designs.

4 ,

( Fi ndir.g Several Instances were identified where Design and Design change information 4 (DC.2-2) were not effectively coordinated between the affected organizations.

Several problems were observed involving the exchange of information and

,, control of interfaces between the electrical and mechanical I & C groups I

and between support / restraint and piping layout sections.

t j Finding The following good practice was noted: The Duke data base program

[ (DC.2-3) provides s11 design organizations an efficient and effective means to .,

Identify and locate design Information.

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PERFORMANCE EVALUATION DETAILS Ccnotruction Projcet Catawba Nuclear Station

,e Design interfaces Objective No. DC1 2

1. Perfor: nance . Area:

(title) .,

2. Provide factual information that sucrorts the Perfor=ance Evaluation Summarv _ _,

1. Review of system design input documents used to provide interface criteria  :

P revealed the,following:

I A. The Mechanical System description and the system flow diagram are Identified as the primary Design input documents; however, only the flow diagrams are revised in a timely manner. Most Mechanical Systems personnel Interviewed did not feel that the Mechanical System description needed to be revised prior to or in conjunction with the flow diagram.

B. Design changes required by DCA(s), VN(s), NPR(s), etc are incorporated into the Design input process mainly through revision of the system flow diagram arid direct communication with organizations having a Design interface.

h The Mechanical and Electrical System descriptions for the RHR System were found to disagree as to system requirements. The applicable QA Fi procedures (EPR 101 and the Mechanical Systems Group Handbook, Section 6.0) which govern preparation of system descriptions do not provide guidance for the case of conflicts between Design input documents.

2. A review of the interface between the Mechanical I & C group and the E',ectrical Equipment Qualification group for the preparation .of the NUREG 0588 Electrical Equipment Environmental Qualification Report identified the following: G A. The Ilectrical ! & C Group requested information on transmitter required accuracy; whereas, the Mechanical I & C Group provided instrunient accuracy based upon system requirements (supplied by the process engineer).

B. The Instrument total loop accuracy was not considered or addressed due

• to a breakdown in communications between the groups involved.

3 Interviews and document reviews in the Civil / Environment 21 Division show the

' responsibility for Design interface coordination is not clearly defined. However, most of the division personnel interviewed exhibited a very good understanding of who they interfaced with and coordination is conducted through this understanding.

G From Interviews, literature searches and document reviews within the C1v11/

Environmental Division, the Project Management Division and the Safety Review Analysis and Licerising Division: no requirement could be determined to exist for identifying and tracking SAP commitments. The Safety Peview Analysis and 1.icensing Olvision does compile a list of commitments of which they are aware and track these to completion.

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,. PERFORMANCI IVALUATION CETAII.S COnctruction Projcet 1

Catawba Nuclear Station

!c I'

l. Performance Areat Design Interfaces Objective No. DC-2 (title) .,

g

2. Provide factual information that succorts the Performance Evaluation Snearv - .

L .

5 A weakness was noted in the communication between ths Analysis and Support /

I Restraint Section and the Station Services group in the area of. diesel generator I, isometrics and piping, layout drawing review and coordination. Specifically, the isometrics used for hanger design are not reviewed.by the group responsible for

, the piping layout.

6. The Duke data base program provides all organizations an efficient and effective means to identify and locate design information.

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l1~ PEREORMANCE EVALUATION

SUMMARY

Ccnctruction Projcet Catawba Nuclear Station

e .

L Jarfor: nance Arma- DESIGN PROCESS Objective No. DC-3 i- .,

Iv31uator (s) C E.lidewell

< I. Performance Objective

, The management of the design process should result in designs that are safe, reIlable, verifiable, and in compliance with the design

, requirements.

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II. Scope of Evaluation The evaluation of this area involved essentially three members of the team.

i

,' Approximately 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br /> were expended in personnel Interviews, document reviews and~research at various_,lorations with the Design office. - --

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1 III. Conclusion The majority of activity evaluated under this performance objective was generally satisfactory. However, there were a number of weaknesses identified that indicated a need to strengthen certain aspects of the organization.

1

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u o- PERFORMANCE EVAI,UATION

SUMMARY

Construction ProjGet l s

Catawba Nuclear Station P0rfor: nance Area Design Process Objective No. DC-3 Evaluator (s) C Glidewell '

IV. Areas of weakness and corrective action Good Practices Finding Design records are not always being flied in a timely manner. Valver y (DC.3-1) form originals on flie in a manual had not been transmitted to General Services for Corporate filing.

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4 Finding Changes'to Design drawings do not rece~ve the same degree of documented l (DC.3-2) review as the original issue. Originals are documented by designer, drawer, checker and approver. Revisions are documented by checker and l approver. ,

I s

I, Finding Design documents relating to the design of the RHR System are in disagree-(DC.3-3) ment creating a potential for error in the design. This is also true for the AFW System.

I Finding Calculations are not being maintained in a contro11ef manner that support L (DC.3-4) Issued Design documents.

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J PERFORMANCE EVALUATION DETAILS Ccnctructicn Projcet 1'

Cetawbn Hucicar Steticn L

1. Perfor: nance Area: Design Process Objective No. DC-3 (title)

2. Provide factual information that succorts the Performance Evaluation e .

surnmarv ,

1. From interview's and document reviews within the Civil / Environmental Division, the Project Management Division, and the Safety Review Analysis and Licensing Division, no requirement could be determined to exist for Identifying and tracking PSAR commitments. The. Safety Review Analysis and Licensing Division does compIIe a list of commitments of which they are aware and track these to completion.

2. From review of Issued drawings in the Civil / Environmental Division, drawing

' revisions do not receive the same degree of documented review as the original Issue of the drawings; i.e. , original sign-out shows designer, drawn, checked, I, and approved; whereas, revisions show only checked and approved.

L 3 A review of the Specification CNS-1108.00-00-0002, Volumes I and li, and interviews r; within the Civil / Environmental Division identified no documented program for assuring correct use of the spectra contained in the specification exit.

4. Review of Specification CNS-1108.00-00-0002 Volumes I and ll, a controlled

-f document, showed the manuals contained no name, number, or uniq'ue identifier to

, assure control of the, manuals is being maintained. -

p 5 In:erviews and document reviews in the Civil / Environmental Division show a good understanding of how the design process works.

6. Review of the manual containing coordination waiver forms completed and on file in the Civil / Environmental Division showed several of the completed waivers had 3 not been transmitted to the General Services Division for filing.

7 Thirty to forty percent of olpe hangers being installed in the Reactor Building are I

temporary hangers requiring replacement when Design information on permanent hangars become available. ..

J 8. Interviews and document revisions in the area of support restraint design showed

( criteria is being met.

9 Review of the RHR System description and flow diagram revealed discrepancy between the requirements of the two documents concerning emergency power train assignment for the isolation valves between the RCS and the RHP. System.

10. Review of the Mechanical and Electrical System d6scriptions for the RHR System showed the two documents do not agree as to the current system requirements.

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L r PERFORMANCE EVALUATION DETAILS Ccnctructicn Projcet L Catawba Nuclear Station

,e i

1. Performance' Area: Objective No. DC-3

. (title) .,

2. Provide factual information that suecorts the Performance Evaluation d' Summarv _ _,

l

11. A review of the Systems Group Document Storage File did not reveal any documented t

[

• calculation (per QA Procedure MPR 101) to support data sheets information used to purchase safety related equipment for the AFW System.

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.c 12. A review of the docume.nt file .(Systems Group) did not contain any documented calcula- l tion to support flow diagram Information for the AFU System.

s 13 Information provided by Duke to Westinghouse Corporation to be used in the s&fety

.I analysis to evaluate the effects of the secondary system (AFW) on the NSSS following g various postulated accidents was not based on calculations verified, approved, and documented in accordance with Procedure MPR 101 or PR 101.

14. There is no procedure in the Electrical Division which identifies the Mechanical or L Electrical System description for the RHR or AFW Systems as being the controlling document for Design.

1, .

$ Responsible engineers and first-line supervisors do not feel keeping systera descriptions current with Design drawings is important.

.1

16. The AFV Electrical System description, the elementary diagrams and the Mechanical System description do not agree.

17. From Interviews with Electrical Division personnel, no program could be identified which defined responsibility for providing and controlling Design input information.

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l PEPEOFFM CI EVALUATION

SUMMARY

Construction Project

, Catawba Nuclear Station g -

I Perfo::mance Area DESIGN OUTPUT Objective No. DC-4 i Evaluator (s) Belew Cilft, Glidewell. Herdricks

I. Perfor ::ance Obiective h Project desig'n documents should specify constructable designs in terms of complete, accurate, and understandable design requirements.

i

< l II. Secee of Evaluation )

i i

The evaluati on of this performance objective was performed by Interviewing respon-( sible Design engineers and their supervisors; comparing Design input documents with

, Design output documents; reviewing procedures which control Design documents; and K

,r reviewing Design output documents. Approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> were spent on these acti-vities.

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III. Conclusien The majority of the activities evaluated under this perforrmace objective was satisfactory. However, there were some weaknesses identified that Indicated a need for improvement in areas by the findings.

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PERFORMANCE EVALUATION

SUMMARY

Construction PrJjcet Catawba Nuclear Statioc.

I l Perfor: nance Area Design Output DC.4 Objective No.

I Evaluator (s) s.t.w_ c1If. . c1Id.w.11 HendeIe1cs ,

i -

, IV. Areas of weakness and corrective action: Good Practices ,

1 Finding The 10P transmitter accuracy Information required for the NUREG 0588 (DC.4-1) Electrical Equipment Environmental Qualification Report is not being properly determined. The overall Instrument loop accuracy is not considered.

r-Finding No documented program was identified for determining and assuring (DC.4-2) review for constructability, maintainability and operabi!!ty it conducted. Reviews are performed where a need is identified.

Finding System descriptions are used to provide system control irformation.

I '. 7 (DC.4-3) They do not reflect current system design.

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PERFORMANCE EVALUATION DE* AILS Construction Project

~

Catawba Nuclear Staticn

1. Performa.nce Areat Design Output Chjective No. DC.4

. L. . (title)

I

2. Provide factual information that succorts the Pe- fo-mance Evaluation ,

st2mmarv -

1. The BOP transmitters required accuracy Information supplied by the Mechanical F lt-C Group for the NUREG 0588 Electrical Equipment Environmental Qualification 4 Report does not consider overall Instrument loop accuracy. The required accuracy for these transmitters is not coordinated with the Electrical Centrol System

'g Engineering Group for consideration of overall loop accuracy. The entire system requirements are'being used for the transmitter.

" 2. During interviews with responsible engineers and their supervisors, it was deter-mined that constructability, operability, maintainability and personnel movement were considered during the design phase, but no documented program was identified which requires these evaluations with the exception of the piping design criteria.

(

L Some examples of weakness in the review of constructability are.as follows:

A. Transition pieces are being added to the "A" frames of the steam generator ,

upper lateral supports. Thase transition pieces were necessary due to the-I[ fact that the required post weld heat treatment of the welds joining the "

'( upper lateral supports and the embedment could not be performed.

( B. The sealing surfaces of the KF heat exchangers are being weld built-up and L machined to eliminate leakage at the sealing surfaces. A welded reinforcing collar was identified and added near the sealleg surface that caused distortion i of the sealing surface.

@ The area in Unit 1 Auxiliary Building Pecetration Room at Elevation 577 where hangers are being installed is extremely congested, making quality installation difficult.

@ In the above defined area, Design changes on items already installed provide potential for extensive rework and/or modifications. Such rework and/or modifications may alter the quality of installed items previously accepted.

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- PEP.FORMANCE EVALUATION DI* AILS Constructicn Projc=t Catawba Nuclear Station

,f

1. Perfor: nance Area: Design Output Objective No. DC.4 (title) p.

.I

2. Provide factual infor=ation that sucecr's the Performance Evaluation

!e Summan _ ,

II .

i 3 The Residual Heat Removal (RHR) System flow diagram and system description have ig a discrepancy between the requirements of the two documents concerning emergency i power train assignments for the isolation valves between the Reactor Coolant System and the RHR Systems.

I

• 4. The Auxiliary Feedwater and itesidual Heat Removal Mechanical System descriptions are not in agreement with the Electrical system descriptions. There are no set requirements for revising these documents and no procedure which identifies which of thes,e is the controlling document.

5 The Auxiliary Feedwater Electrical system description was lart revised on October 10, 1980. There has been several revisions of the Electrical elementary

. diagrams and a complete revision of the Auxiliary Feedwater Mechanical System description since the last revision of the Electrical system description.

6. Personnel interviewed within the Civil / Environmental Division showed a very goo [

understanding cf existing Design procedures and in carrying out their requirements.

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1 PERFORMANCE EVALUA"' ION

SUMMARY

' Construction Project Catawba Nuclear Station l

Parformance Area DrsTGN cvANGES Objective No. oc-M I

Evaluator (s) m,t.m rtir. rits.m.it u. s .;,c, I. Performance objective f Changes to released project design documents should be controlled to i,

ensure that constructed designs comply with the most recent design requirements.

P II. Scoce of Evaluation

. The evaluation of this performance objective was performed by interviewing responsible Design engineers and their supervi, sors; reviewing documents which control Design changes; and reviewing revised documents. Approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> were spent on these activities.

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III. Conclusion .

1 '

The majority of the activities evaluated under this performance objective was satisfactory. However, there were some weaknesscs identified that indicated a need for improvement in areas identified by the findingr.

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v PERTORMANCE EVALUATION 3UMMARY Csnstruction ProjGct

?

Catawba Nuclear Station 1

i PGrformance Area Desten Chances Objective No. DC-5 n

Evaluator (s) Belew. Clift. Clldewell. Hendricks I  :

c IV. Areas of weakness and corrective action: Good Practices _

Finding Conflicts between system design documents exist for extended periods (DC.5-1) of time, because system descriptions are not revised in a timely manner.

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PERFORMANCE EVALUATION DETAIIS Construction Project Catawba Nuclear Station lF Design Changes Objective No. Oc-5 i ',. 1. Perfor: nance Areat (title) i, l' 2. Provide factual info =ation that sueeerts the Perfor.ance Evaluation Su:n: .arv ,,,,,,

1. From review of issued drawings, drawing revisions do not receive the same degree of documented review as the original issue of the drawings. Original sign-out shows designer, drawn, checked and approved; whereas, revisions show checked and approved.

2. The Auxiliary Feedwater Electrical System description was last revised October 10,

. 1980. There has been several revisions of the elementary diagrams and a complete i

revision of the Auxiliary Feedt.ater Mechanicel System description since the last l

e revision of the Electrical system description.

3 The Residual Heat Removal (RHR) Systenn flow diagram and system description have

,' a discrepancy between the requirements of the two documents concerning emergency power train assignments for the isolation va7ves between the Reactor Coolant System and the RHR Systc.m.

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I' PERFOPS.ANCE EVALUATION SU."E.ARY Construction Project F Catawba Nuclear Station E Perfor=ance Area CONSTRUCTION ENGINEERING Objective No. CC-1 Evaluator (s) T F Wyke, R D Anderson I. Performance Obiectire ,

Engineering and design performed under the authority of the construc-tion organization should be controlled as to consistency with the basic design critoria to ensure ec=pliance with applicable codes, standards, and regulatory commitmente.

II. Scoce of Evaluation g

The evaluation of this area involved several members of the team. Approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> were expended in reviewing work practices in the various disciplinc areas. This evaluation included review of procedure, review of examples of work, and discussion with various levels of personnel.

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III. Conclusion Tha lar5,e majority of activity evaluated under this performance objective was satisfactory. However, several weaknesses were identified which Indicated a need to strengthen certain aspects of the organization.

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PERFORMANCE EVALUATION

SUMMARY

Conct:uction ProjGet F

q Catawba Nuclear Station w.

< -r Performance Area Construction EnoineerIno Objective No. CC.1

~

Evaluator (s)

Areas of weakness a::d corrective action: Good Practices IV.

Mana~gers and supervisors do not always enforce adherence to plant Finding)

(CC.1-1 policies and procedures. Several areas were noted where personnel

' did not adhere to established work procedures.

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I PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station f 1. Performance Area: Construction Engineering Objective No. ~

CC.1 4- (title)

2. Provide factual information that suco_ orts the Performance Evaluation summarv _

1. A controlled copy of CP-461 was revised by hand, contrary to QA Procedure G-1.

2. The actubl practice interface between the pipe erection craft and the Pipe Fab

- Shop for preassembled sections is at variance with CP-42, omitting preparation of sketches by the Construction Engineer-hechanical, r

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'3. k'ork on instrumentatica guide funnels on Unit 2 reactor vessel head was observed at variar.ce to appreved drawings, based on verbal authorization.

4. Instructions to pipe erection craft on installation of Unit 2 instrument root valves are provided by a memo to file, rather than by a controlled document.

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l~ PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station r

i Construction Facilities 7erformaned Area and Ecui ment Objective No. CC-2 Evaluator (s) R Anderson '

[  :;. Performancechective t Construction facilities and equipment should be planned for, acquired, instelled, and maintainad consistent with project needs to support quality construction.

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II. Sccce of Evaluation The evaluation of this area was a result of input from several of the team -

r. embers, and approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was expended in this effort. A meeting r.

was held with the Facility Engineer to discuss methods and responsibilities

.. for recognizing need, planning, implementing and maintelning Construction facilities and equipment. The evaluation was limite'd to the plant site.

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III. Conclusicn Construction facilities and equipment are planned for, acquired, installed and ma*ntained in a manner consistent with project needs to support quality construction.

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PERFORMANCE EVALUACION

SUMMARY

Constructica Project Catawba Nuclear Station 4 r -

- Perfor::iance Area Material Control Objective No. CC-3 Evaluator (s)

I, ?erformance obiective ._

Material and equipment should be inspected, controlled, and raintained to ensure the final as-built condition meets design and operational requirements.

S II. Scoce of Evaluation

- The evaluation of this performance area ir.volved nine of the twelve team members at the project site. Approximately 16 houri were expended in observing work

f. practices at several locations such as warehouse, fabrication shops, powerhouse --- -

[ and storage ys-d areas. A review was made of the written procedures, instructic.,ns, manuals and standarc's on material control . Valk-throughs, observations and reviews '

revealed most of the evaluation details.

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I I. Conclusien Some of the activities evaluated under this performance objective were satisfactory.

! However, weakness was identified in a couple of areas where there is a need to l strengthen certain aspects of the project's policies.

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- PERFORMANCE EVA5UATION SUMMA 3W Construction Project Catawba Nuclear Station Perfor: nance Area Material Control Objective No. CC-3 Evaluator (s) $ Sheppard IV. Areas of weakness and corrective actient Good Practices Finding Site' receipt inspection does not ensure that material and equipment (CC.3-1) received on s7te are evaluated against the requirements of the pro-curement specifications. Examples of the problems identified may I. potentially result in delays, waste of materiala, additional time spent on disposition of deviations from procured materials and work stoppage.

Finding A cansistent method for material Identification was not in effect in (CC.3-2) the warehouse. Several instances were noted where I.D. tages had fallen

• off, equipment was marked with ink; and when material was being sectional-ized to start fabrication, a means for maintaining the identification was not being done.

m Finding Proper protective measures were not taking place for, environmentally (CC.3-3) sensitive equipment that was " robbed" for spare parts. Some parts were

' being stored in an open door instrument cabinet. ,

Finding Procedure QFP-8.002 CNS, Rev 1A, does not indicate the disposition of (CC.3-4) unused filler material. Confusion appears to exist regarding handling of unused filler material and adherence to AWS code requirements could not be determiend.

)

Finding Materials are not being maintaineo or stored effectively at work site (CC.3-5) locations. Several examples were noted which reflected improper control.

Finding Scheduled preventive maintenance activities on installed equipment are m (CC.3-6) not always assured'throughout the entire period of Construction Depart-ment control. Equipment was identified for which preventive maintenance haJ been. canceled up to 21 cenths ago, and there was no evidence that compensatory requirements had been established.

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PEPSOMANCE EVALUATION DETAILS Conctruction Project Cartwba Nuclear Station L

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MateHal Control Objective No. CS~3

1. Performance Area:

(trtle)

2. Pravide fac-tual information that sumoortis the Perfor: anca Ivaluation Surcnarv

1. During a walk-through in the HVAC, Pipe Fab nd Welding Equipment Shops, several weaknesses were observed: ,

A. In the Pipe Feb Shop:

1. Carbon steel pipe was heavily pitted on the inside diameter, which was only slightly above minimum wall thickrass, thus not allc. wing much for

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clean-up, fitting and grinding.

2. Orifice flar.ges are being purchased oversized (next hight r schedule) so that sufficient material is available for clean-up of the flow section.

B. In the Velding Equipment Shop:

1. A large supply (several boxes) of g'lue which is used for we' ding purge dams was being stored in one of the welding shops. The craft indicated they needed to keep a large supply because the warehousp would let them

, run out if they did not store up.

- C. In the HVAC Fab Shop:

1. A safety related galvanized steel angle used by the HVAC contractor is color coded on the ends when received at the site, but when fabrication begins (sectionalizing), no attempt is made to maintain this identification.

2. Procedure QFP-8.002 CNE, Rev 1A, (Control of Velding Filler Material)

- requires the return of unused filler material at the end of each shift.

The procedure does not indicate what is the disposition of the unused filler material. The supervisor indicated tha+. the coated electrodes *'

are placed back into the holding oven and are subject to reissue to the next shift. The QA engineer indicated that the returned coated electrodes

- are placed in a separate holding oven and are returned to Duke Powe- Company, who is responsible for the reconditioning of 'the electrodes. There is con-firmation from Duke Power Corapany welding material issue station employee i - that the contractor does occasionally return coated electrodes. The effective Code, AWS D1.1, requires reconditioning of coated electrodes after exposure to the atmosphere.

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2. In a walk-through of warehouse and storage yard area, the following weaknesses were. observed:

A. Stick-on paper I.D. tags were used for electrical equipment identification.

Most of these tags were falling off the equipment in two warehouses. No 31 6.w".w.we wyermr.-msg.2pmmerstf Gis:" dMR.4ERh ;r.2

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PER70RMANCE M'ALUATION DETA55 Cens duction Projcc m

Catawba Nuclear Station L

1. . Performance Area: Material Control Objective No. CC-3

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(title)

2. Provide factual infor: nation that succorts the Performance Evaluation Summarv -

consistent' method of correcting the problem was being employed. Onc ware-house was using ink to mark i.tems. The other one was stapling paper tags

. on equipment when possible.

f E. Spare generator circuit breaker had been robbed of parts for use with other circuit breakers without protection of disconnected parts. Some parts wert stored in an Instrument cabinet with the door open.

' Access to warehouse area where safety-related equipment was stored was C.

not secured in two warehouses. Entranu area was open for access by both maintenance personnel and electrical termination and panel fabrication crew.

D. A 4-inch stainless steel pipe was on a rusty set of carbon steel rollers

~ used to move pipe into the pipe cutting building. The stainless pipe had rust streaks on the surface.

E. Cable reels were stored with cable ends not taped as required in the storage yard. ,

3 At a review of a repressure test in the Auxiliary Building on 10-4-82 for

" Shutdown 201B 7626, water was leaking from a temporary hose connection and was he!ng allowed to soak a carton of filters. The carton was identified "AHU-3 1131-CHS." The situation was pointed out to the test director, but was not corrected.

' 4. During a walk-through of Unit 1 Turbine Building, it was noticed that while pipe f abrications on spool piece CT-SM-73 had end caps missing, there was no fit-up being done in this area. Other fabrications in the main steam chest area were also uncapped. ..

5 During a review of No. 10 cadweld operation in the Auxiliary Building, it was 1 earned that the cadweld sleeves and powder had r.ot been receive.1 by QC Receiving.

[. - These items were received from another site as non-quality items, and the QC Inspector was not aware of the .16 51144 sleeves -until notified by his supervisor.

The work was stopped.

6. A review of the welding filler control center did not identify any weakness. It Is well-equipped and designed to handle the flow of work in a smooth, efficient manner.

7 The program for preventive maintenance of project equipment was oLserved. The details are presented in Observation of P.eventive Maintenance Program. It was noted that preventive maintenance activities do not continue through the entire period of construction control.

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I PERFORMANCI IVAI.UATION

SUMMARY

Construction Project Catawba Nuclear Station

.. Parfor: nance Area Control of Construction Processes Objective No. CC-4 Ivaluator (s) T F Wyke, H S Sheppard I, Perfor=ance Ob-iective The construct. ion organization should :nonitor and control all construc-

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tion processes to ensure the project is completed to design requirements and that a high level of quality is achieved.

II . . 'Secce of Evaluation The evaluation of this area involved many members of the team. An estimated 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> were expended in observing work practices at various locations on the project.

As a Teltc7-up 'to these observations, an estimated 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> were devoted to--dis-

.cussions with varicus levels of supervision and management and review of selected records.

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m III. Conclusion The majority of activity evaluated under this performance objective was satisfactory.

However, there were several weaknesses identified that indicated a need to strengthen certain aspects of the organization.

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PERFORMANCE EVALUATION

SUMMARY

Conctruction Projcet Cattwba hucisar Station 1 1

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Parfar: nance Area Control of. Construction Processes Objective No. CC.4 Evaluator (s) T F Wyke & H $ Shecoard

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IV. Areas of weakness and corrective action: Good Practices P

Finding Manag'ers and supervisors do not always enforce adherence to plant (CC.4-1) policies and procedures. A number of areas were noted where personnel

, did not adhere to established work procedures.

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Finding Weaknesses were observed in control of HVAC contractor's welding

.(CC.4-2) . program. Several instances were noted where contractor personnel

, were not famillary with program reeuirements.

Finding Weaknesses were observed in the training of craft personnel in selected (CC.4-3) areas. Several examples were noted which reflected insufficient familiarity with work procedures. c L

Finding The following good practice was noted: A Quality Awareness Team selects (CC.4-4) a " Quality Crew of the Month," promotino a competitive attitude toward improving quality.

Finding One. example of restrictive procedure (CP-601) was observed. Use of this (CC.4-5) procedure precludes Judgenent by experienced personnel and results in concrete mix which will not meet acceptance criteria.

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PERFCF14ANCE I;7ALUATION DE':' AILS Construction Projset Catawba Huclear Station

1. Perfor: nance Area: Control of Construction Processes Objective No. CC.4 (title)

2. Provide factual infor nation that suenorts the Perfor=ance _ Evaluation Suz=narv ,

1. Review of documentation ard physical installation of kHR Pumps 2A and ?.B (Unit 2) Identified the folicwing weaknesses:

A. Several required forms were not in the process control package; e.g. ,

g Forms M-5A '(Pumps 2A and 25), Form M-18A (2A) and i~orms M-9C (2A and 2B).

, B. Several forms not completely signed; e.g. , Form M-SD (layout for 2A and 2B and QA approval for 2B) and Form M-9A (shlia and grout for 2B).

C. Verification of anchor bolt material not clear on Form M-10A(2B).

D. Form "VDF Inspection Before Velding to Piping" shows Section A measure-ments out of tolerance (Pumps 2A and 2B) and readings which Indicate r that internals will not mate with casing (Pump 28)! No action taken on latter problem even though it was identified 5-22-81, and no R-2A initiated. -

E. No requirement for inspection of torquing of casing studs specified on -

Forms M-9D (2A and 2B). -

Special cover for Purnp 2B casing was lef t off.

F.

6 G. Installation of casing hold down studs was signed off on Form M-10A. The nut on the st,ud opposite the discharge of Pump 2B was not fully threaded.

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2. During plant walk through, several pipe caps were observed to be missing; e.g.,

- In main steam linc at turbine stop valves in Unit 1 Turbine Building contrary to CP- 116. -

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, 3 At Pipe Cutting and Beveling Shop, a section of stainless steel pipe was observed on a set of rusty carbon steel rollers, with visible rust pickup -

- on stainless steel piping, contrary to CP-170.

4. The following weaknesses were o!: served during preparation for and conduct of concrete pours:

g A. Wall section for Unit 2 pressurizer cavity

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-rebar was not installed in accordance with Design drawings

-area engineer did not docuraent Design information provided to craft I '

-placing crew had not planned their activities 35 b i' T- -

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(~ PERFORMANCE EVALUATION DETAILS Construction Project l Catawba'Nu-lear Station Control of Construction Processes Objective No. CC.4

1. Perfor: nance Area:

(title)

2. Provide f actual infomation that su=corts the Perfomance Evaluation su:marv _ ,

B. Wall section for Unit 2 steam generator compartment, Pour 4958 l -p1' acing crew had difficulty placing concrete in congested form 5 The following weaknesses were observed in control of HVAC contractor's welding

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program.

I A. No welder knew the weld procedure under which he was working.

B. All welders knew required weld size and location, but did not know how they acquired that information.

C. No process control was available to specify the welding procedure for plenum erection (from Drawing CN-1684-VA-000H, Rev 0).

c D. Welder was making welds without removing galvanizing mater,la1.

E. HVAC support 2-H-yC-4999 had undercut in excess of that allowed by AWS DI.i code.,

F. Welder / supervisor picks welding procedure from all available welding procedures.

Supervisor Indicates welding procedure (s) used on a support after the support is complete.

6. Work en instrumentation guide funnels on Unit 2 reactor vessel head at variance to approved drawings, based on verbal authorization.

m 7 During discussion with electrical craft personnel, the following weaknesses were observed:

A. Different understandings among personnel with respect to requirements for electrical lugging tool 'recalibration.

B. Differe.nt understandings among personnel with respect to procedure for checking sliding link terminal block connections.

C. Electrical lugging tool not adequately marked for easy identification in o - some Instances.

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l p PERFORMANCE EVALUATION DETAII.S Construction Projset L'

Catawba uclear Station 1 _

Perfortuasce Jerea: Control of Construction Processes objective yo, CC.4 1.

e (title) f

, 2. Provide factual infor.ation that sueco-ts the Perfor: nance Evaluation i summarv _,

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8. A Quality Awareness Team selects a " Quality Crew of the Month" each month, promoting a competitive attittde toward improving quality.

9 Personnel in the Pipe Fab Shop are not familiar with all the markings .on pipe.

No person could explain certain markings etched into the material on pipe bend I. 2N5-139-AA. Personnel did know which numbers were required to be transferred.

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10. CP-601 requires the addition of a specific amount (88 ounces / cubic yard) of

- Helment L10-A to first truck of concrete at the discharge point. This require-

, . ment precludes judgment by experienced personnel to determine variations in the amount of this additive appropriate for different weather conditions. Implemen-tation of this requirement in Pour No 4958 resulted in wasting 24 cubic yards of concrete before concrete mix passed test criteria, b

11. Review of terminations in electrical cabinets revealed the following weaknesses:

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A. Form H-9B was not present in cabinets in the Unit I cable spreading area.

B. Talked with an electrician foreman and an electrician craftsman who did not I

know what Forms H-9A, H-98 and H-9Ca're.

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12. Design Engineering Specification CNS-1390.01-00-0011 provides information required

- for setting switches en Limitorque and Rotork electric valve operators. However, neither this specification nor Construction procedures provide details and pre-cautions for properly adjusting and operating these electric valve operators.

Craf t personnel ttstad that vendor manuals containing this information are not available to them.

13 CP-458, Section 4.1, requires the hanger material sent to the Coatings Shop to 7 be tagged. A box of unmarked materials was observed during the review of the Coatings Shop, contrary to CP-458. Coatings 3 hop personnel indicated that this

' L- occurred on several occasions. Warehouse personnel indicated that not tagging the material is acceptable.

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.( PERFOPMCE IVALUATION

SUMMARY

Construction Project

[

Catawba Ny lear Station

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Parfc_: lance Area Construction Quality Inseections Objective No. CC-5 Evaluator (s) D L Freeze I. Performance Obiective ,

Construction. inspections should verify and document that the final

, product meets the design and quality requirements.

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II. Score of Evaluation The evaluation of this area involved essentially all team members working at the

' construction site. Approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> were e.xpended in observing work practices at various locations on the project. As a followup to these observations, 5 approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> were devoted to discussions with various levels of supervision and management. Some records were reviewed as reflected in the section entitled Performance Evaluation Details. .

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III. Conclision The majority of activi ty evaluated under this performance objecti ve was generally satisfactory. However, there were a number of weaknesses identified that indicated a need to strengthen certain aspects of the organization.

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6 PERFORMANCE EVALUATION

SUMMARY

Construction Project

{

i Catawba Nuclear Station 2

Parfor:.ance Area Construction, quality Assurance Objective No. CC.5 Evaluator (s)

IV. Areas of weakness and corrective actions :", cod Practices f

Finding Inspection procedures are not always clear in their definition of (CC.5-1) Inspection requirements, resulting in installed items being accepted when requirements have not been met and vice versa.

Finding inspection documents are sometimes completed in an illegible manner, (CC.5-2) making any required future follow-up difficult, if not impossible.

Finding inspection requirements established by HVAC contractor do not verify

, (CC.5-3) that Code requirements are met.

Finding QC inspectors sometime perform production functions.

(CC.5-4) .

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PERFORMANCE EVALUATION DETAILS Construction Projcet Catawba Nuclear Station

1. Performance Area: Construction Quality inspections Objective No. CC.5

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(title)

, 2. Provide facrual information that succorts the Performance Evaluation Summarv _

l> 1. The performance of concrete placement and inspection was observed to evaluate the quality of concrete insta11aticn. The details are presented in Observation of Concrete Operation. Weaknesses were noted in the use of procedures. Overall

, work and end results were satisfactory.

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2. A review of piping system flushing and hydrostatic testing procedures and documents was performed. The details are presented in Observation of Test Procedures and Documents. Although the overall work and end results were satisfactory, several weaknesses were identified. These included:

. A. QA management has provided procedural requirements in memos and letters which should have been detailed in inspection procedures.

B. Preparation of documents which define piping system flush boundaries and also hydrostatic testieg limits is not defined in inspectfun procedures.

3 The performance of hanger inspections was observed to evaluate the quality of hanger installation. ' The details are presented in Observation of Hanger inspection. Overall work and end results were satisfactory. A weakness was

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observed in an inspection requirement (full thread engagement) not being adequately defined. An additional weakness was observed in that QC inspectors r sometimes torque concrete expansion anchors to correct values af ter their inspections reveal insufficient torque rather than notifying the craft organization of the deficiency.

4. The performance of the HVAC contractor was observed to evaluate the Ct.ality of the HVAC installation and inspection. A weakness was identified in the prepara-c tion of visual weld inspection procedures. Details are presented in the Observa-tion of HVAC Contractor.

5. An Inspection of the setting of Residual Heat Removal pump casings was made.

Areas of weakness were identI~fied as listed below:

A. Inspection initials and signatures on inspection forms are illegible.

8. Prerequisite Inspection items were not initialled prior to equipment's being set and grounded.

C. Completed records had blank inspection steps. All inspection steps should be 6 addressed.

D. Layout (surveying) verification was not obtained prior to setting Pump 2A.

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m f PERFORMAb?CE EVALUATION

SUMMARY

Const.tuction ProjGct Catawba Nuclear Station r

parformance Area const uctien Corrictive Actions Objective No. CC-6 L Evaluator (s) D L freeze C

I, Performance Obiective The construction organization should evaluate audits, inspections, and surveillances; process replies and follow-up; and take corrective action to prevent recurrence of similar problems.

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II. Scoce of Evaluation The evaluation of this area involved six members of the team working at the constructien site. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended in discussions with various levels of supervision and management. Some ecords were reviewed as reflected in the section entitled Performance Evaluatica Details.

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f 4-3 1 III. Conclusion L,'

The majority of activity evaluated under :his performance objective was generally

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satis f actory.

No program is in place to satisfy the requirements of this performance objective in regard to generic implications of problems and actions to preclude recurrence.

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e-J PERFORMANCE EVALUATION SUMM uY Construction.Projcet Catawba Nuclear Station

. Parfor:nar.ca Area Construction Corrective Actions Objective No. CC.6 r-Evaluator (s)

.i, IV. _ Areas of weakness and corrective action: Good Practices Finding Certgtn trend analyses have not been performed as required in the three (CC.6-1) months that followed change of responsibility for such trends from QA to Construction.

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e Finding No program requirements exist for trend an;slyses of surveillance and

(CC.6-2) Inspection documents other than R-2A inspection Discrepancy Reports.

Finding Replies to deficiencies do not always address all areas of con ern l I. (CC.6-3) regarding such deficiencies. Technical resolutions are addres.ed; however, procedural violations and safety implications sometimes are not addressed.

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I PEPJORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station l

1. Performance Area: Construction Corrective Actions Objective No. CC.6 (title) i 4 2. Previde factual infomation that sueco.-ts the Performance Evaluation

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r 1. The performance of Construction corrective actions was reviewed. Responsibility

, for trend analysis of R-2A's (inspection discrepancy reports) recently was changed from QA to Construction. This review Indicated the following areas of weakness:

i A. No trend analysis has been performed during the period 6-1-82 through 8-23-82 i . for R-2A's.

B. Constructl~on has not performed any trend analysis of QA surveillance reports.

I C. Construction has not performed any trend analysis of nonconforming item reports.

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D. Statement of action on rt-2A #H5677 does not address all areas of concern.

Piping system was pressurized prior to release by hydro group. R-2A did not address procedure violation nor safety implications.

c Action required on R-2A #M5350, although cleared by QA, ha's not been complete-d.

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2. An inspection of the setting of Residual Heat Removal pump casings was made. Areas of weakness identified are listed below:

A. An inspection before welding to piping Indicated one area to be out of tolerance and that the internals will not mate with casing. This information was obtained 5-22-81, and no action h s been taken since then.

B. No R-2A, inspection Discrepancy, has been generated to address situation in A., above.

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( c- . PERFORMANCE IVALUATION SDIMARY Construction, Project Catawba Nuclear Station-i Parformance A*:ea Test Ecuiement Control Objective No. CC-7 I

[ Evaluator (s} C F York

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i I. Performance chieetive Measuring and test equipment should be controlled to support construction' testing effectively.

e II. Sccce of Evaluation

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The evaluation of this area involved several me.nbers on the team. Approximately

( 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> were spent in evaluating the testing equipment in the civil and mechanical laboratories at the site. Discussions were held with several inspectors and super-visors on the testing program and their understanding of it. A review was made on the appropriate QA and Construction procedures.

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III. Conclusien

.l- The majority of activities evaluated under this performance objective was generally sa ti s f acto ry. However, there were a number of weaknesses identified that Indicated a need to strengthen certain aspects of the civil test control area.

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i PERFORMANCE EVALUATION

SUMMARY

Construction Projeet

.f Catawba Nuclear Station

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I Parfor: nance Area Test Ecutement Control Objective No. CC.7 Evaluator (s) C F York Areas of weakness and corrective action: Good Practices

[ .IV.

n Finding Supervisors in the quality Control organization do not always enforce I.

(CC.7-1) adherence to required Quality Assurance or Construction Procedures.

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F Finding filegible unique numbers on some electrical lug crimping tools were (CC.7-2) noted in the electrical area.

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P PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station f ._

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1. Perfo. w ce Area: Test Equipment Control Objective No. CC.7  !

(t:.tle) I I

g 2. Provide factual information that succorts the Performance Evaluation Summarv _ ,

1. A' review of the applicable procedures and the testing and measuring equipment Iccated in the soils laboratory identified the following weaknesses:

A. Scale CKSC TB.-2 stored in a cabinet in the Soils / Concrete Lab with a valid I

sticker having a calibration due date of 10/23/82. Supervision stated this scale was not being used. This item could not be located on the computer 1 calibration printout sheets; therefore, no recalibration could be made on this scale by QC area. Calibration sticker on this item implied this was under the' program and subject to controls of Procedure 0-1, Rev 15. This b

procedure required an item to be entered on Form 0-1A and listed on Form 0-1B; each M and TE Item to be controlled. This was not done.

B. Triple Scale 2157 and several soli sieves located in :he Soils / Concrete Labora-

' tory with stickers showing calibration dates nad expired. QC supervisor stated these items were not in use. Procedure 0-1, Revision 15. Section 3 8, Discrecancies -- if the calibration check interval is excepded for a M & TE f

item, but the item is not used af ter the due date, an explanatory note shalP~

be entered on Forrp 0-1 A or card 0-1D. Supervisor had failed to meet either of these requirements.

i- .

C. A 200 mesh sieve (CKQUA-19707) was observed in the Soils / Concrete Laboratory with a tear in the mesh screen. CP-620 requires any damage sieve to be imme-diately (1) removed from the test area; (2) removed from the calibration recall program (not in program); (3) calibration sticker removed (valid sticker-sieve

,L due date not exceeded yet); (4) disposed of immediately (sieve still in foils /

l Concrete Laboratory). Item was removed from the program.

l!

!1 ' 2. Two scr.eduled concrete placements were observed. The details are presented in Observations of Concrete Placement. The overall work and end results were satis-factory; however, it was observe : that the device used in measuring the slump had a 1" movement in the vertic'l direction which could result in an inaccurate k reading.

3 During plant walk-through, several electrical lug crimping tools (each requires

i a unique identification number and requires. bi-weekly calibration verification) unique numbers were very difficult to decipher.

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_ 4. Construction Procecure 9, Section 5, requires the calibration of the dry flim

>L thickness gage at the beginning of each day. The dry film thickness gege used during the review of the coatings facility was calibrated September 13, 1982,

.F with a two-month interval before the next calibration.

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PERFORMANCE EVALUATION

SUMMARY

Construction Projact Catawba Nuclear Station 1~

POrformance Area Industrial Safetv Objective No. PS-1 f Evaluator (s) B Rice ,

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g I, Performance Objective The construction site industrial safety program should achieve a high degre'e of personnel safety.

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II. . Scoce of Evaluation The evaluation of this area involved essentially the entire team while performing 0 evaluations of activities associated with other performance objectives. Approxi-mately 16.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> were expended in observing safety. As.a follow-up to these observations, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> were devoted to discussions with various levels of supervision and management. Some records were reviewed as a follow-up to interviews and obser-vations.

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e The majority of activity evaluated under this performance objective was generally sat i sf acto ry. However, there were a number of weaknesses identified that indi-cated a need to strengthen certain aspects of the organization.

1

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I PERFORMANCE EVALUATION SUML~tRY Construction Project f,

Catawba Nuclear Station g-Industrial Safety PS-1 Parformance Area Objective No.

Evaluator (s) B Rice '

i f IV. Areas of weakness and corrective action: Good Practices m

Finding Managers and supervisors do not always enforce adherence to plant (PS-1) safety procedures. A number of areas were noted where personnel did

~ not adhere to established safety procedures.

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l PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station I

1. Perfor=ance Area: Industrial Safety Objective No. _PC-1 ,

(title)

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2. Provide factual information that succorts the Performance E>aluation p Summarv _

1. The performance of the various disciplines' work was observed and reviewed, and the following items were noted which appeared to be in violation of safe practices for the si te work areas.

A. A ladder providing access to a concrete pour (Elevation 642 in Reactor Building c #2) cid r.ct 'have a cage or protective enclosure around the top part of ladder.

The ladder was approximately 50 feet from the ground elevation.

,- B. During observation of concrete pour No. 4957, builders were observed working around a floor opening (1C' x 12' x 10' depth) that contained no guard rails, L and the builders were not using attached safety belts. In addi-ion, other workers were at the bottom of the opening.

C. Scaffolding in Reactor Suilding 1 which was inside the crcne wall underneath the reactor and steam generator level had no handrails or toe boards,and personnel were not using safety belts. .

' D. Hasdrails on the, walkway on top of Reactor Building 1 are old and are coming loose at their anchor points.

E. Personnel working in Reactor Suilding 1 come area were not using safety belts at all times.

F. Velders for HVAC Contractor Bahnson were making welds without removing the galvanizing from the metal. This could result in the welder inhaling fumes that would be hazardous to his beslth.

l .

L G. In Unit 1 Auxiliary Building Penetration Area, a worker was standing on a platform which had no handrails and was not secured by a safety ianyard.

The plctform was greater than 20 feet above the floor.

H. In three separate interviews, the control of welding was reported as inadequate for protection of personnel from eye flash burns and from splatter.

l. A powerhouse mechanic was observed climbing on pipe in the pipe rack with no provisions to prevent pipe from shifting, i

J. Scaffolding in Unit 1 Reactor Building in the area of the "ND" System piping was found in need of repair.

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PERFORMANCE EVALUATION DETAILS Construction Projset Catawb'a Nuclear Station r

Industr[a1 Safety Objective No. PS-1

1. Performance Area:

(title)

2. Provide factual information that suceerts the Perfermance Evaluation g Summag _

K. During concrete pour No 4958 for Unit 2 Reactor Building steam generator

. enclosure walls, contractor's personnel (Rock Hill Concrete Company truck driver) was observed not wearing side shields on eye glasses.

L. In the Paint-Sandblask Shop, steel grit was present on floor around reclaim I equipment, causing slick surface to exist. There were no warning signs.

t.

M. In cooling tower area, no handrails or handrungs were available to assist in climbing through floor opening to second elev? tion from ladder.

h N. In Unit 2 Reactor Building, material pulley was inaccurately and inadequately attached to cables supporting personnel work pietforms.

O. Three separate instances were observed where electricians were standing on the top step of the stepladders. In one instance, the supervising electricicn i

was ho! ding the ladder; and when questioned, he revealed he was aware of .

[ safety procedure requirements prohibiting this practice.

. P. During concrete pour No 4957 on Waste Solidification Building, a builder stepped'to a screid board from a stabla footing, lost his balance and fell

- into freshly poured concrete in which rebar was sticking up.

Q. Corrective Action Notice (R-2A) indicated craf t performed pressure testing on fire protection line before work was properly inspected and released. The

, systems engineer when questioned did not censider this a problem. The Safety Department was not copied on corrective action notice.

L R. On the roof of Unit 2 Auxillary Building, the cadweld power is stored in a map bor. The box was not locked and nad no warning signs or markings.

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. S. Protective personnel barriers were not placed in front of energized boards to keep people from coming in contact with the boards behind the control room panels.

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T. Protective shields around a welding activity on piping in the containment penetration region of the Unit 2 Auxiliary Building were not being used which could result in eye flash burns of personnel in the area.

4. Curing a repressure test for Shutdown 201B, water was allowed to run through sleeves to the elevation below creating an unsafe slippery floor surface. The testing pecole received comolaints about the conditions from two dif#erent workers in the working area below.

50 i

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PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station Industrial Safety

1. Performance Area: .o3.jective No. PS-1 (title)

r. .

2. Provide factual information that succorts the Performance Evaluati,o_[},

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V. During Interview with warehouse personnel, a need was expressed for more ,

training in handling and storage of hazardous materials.

b W. Electrical supervisor stated that safety information wat sometimes watsred down by the time it reached his crew.

,~ X. Records indicate that eye injuries account for aporoximately 40 percent of all injuries, averaging approximately 160 per month. It was estimated that

[. flash-burns accounted for 30 percent of this number with foreign particles accounting for the remaining percentage.

Y. The general housekeeping practices resulted in an exceptionally clean work area for the employees.

Z. During a response to a crane accident, the site safety personnel were quite p effective in responding to the event by prompt removal of the injured per-

6 sonnel, control of access and control of spill of hazardous material. '~ '

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PERFORMANCE E*TALUATION SITm".ARY Constr.:ction Project l~

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. Perforniance Area P-eieet Plannine Objective No. 75-2 Evaluator (s) _ B M Rice I .

I. Performance Objective

- Project plans.should ensure completion of the project to the highest industry standardi- by indentifying, interrelating, and sequencing the tasks of the project organizations..

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- II. Sconc of Evaluation 1

- The evaluation of this area involved observation, plan review and discussions with various levels of supervision and management. Approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> were spent I in this evaluation.

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The findings were minor in nature and are not considered significant.

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PERFORMANCE EVALUATION SUM &HY Construction Project Catawba Nuclear Station I"

Perfor:::ance Area Project Planning Objective No. PS-2

.j Evaluator (s) B Rice t

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IV. Areas of weakness and correcti*:e action: Good Practices Finding input into schedule and planning from Quality Assurance and Control (pS-1) did not appear to be covered in sufficient detail compared with other activities.

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$ERFORMANCI EVALU?. TION DETAILS Constructicn Project i

Catawba Nuclear Station la Perfor: nance Area: Project Planning Objective No'. PS-2 (title)

2. Previde factual infor: nation that succorts the Perfor::ance Evaluation Sur::narv _

1. An assessment of the project planning activities, scheduling and interfacing

(

{ of project tasks was made with the following items of interest n'oted:

i A. A new concept'of area work package is being evaluated for implementation I on Unit 2; however, personnel are not yet available to implement due to concentration of work on Unit I and hiring freeze.

B. Project construction schedules and planning appear to lack proper consideration of input from the Quality Assurance and Control groups to enable a complete definition and sequencing of tasks of the project organization.

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PERFORMANCE EVALUATION SU.T1ARY Construction Project Catawba Nuclear Station f Performance Area Project Control Objective No. PS-3 Evaluator (s) D E Hatley

' ' I, Performance Ob-iective Project scheduling and work planning and coordination should ensure that the objectives of the project plan are cet through effective and efficient use of project resources.

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o II. Scoce of Evaluation The evaluation of this area involves primarily one evaluator plus input from the remainder of the team. The evaluations use interviews as the main source of data and a review of Project Control Documents and Reports. Approximately 8

- hours were expended on this evaluation.

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- The activities and criteria evaluated under this crea were all satisfactory.

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PERFORMANCE IVAI,UATION

SUMMARY

Construction Project Catawba Nuclear Station 7srformance Area Proiect Procurement Process Objective No. pc-4 D T Clift Draluator (s) r .

I. Performance Obiective The project procurement process'should ensure that equipment, materials, and services furnished by suppliers or contractors meet project requirements.

II. Scoce of Evaluation The evaluation of this area involved several members of the team. Approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> were spent in the evaluation of the procurement process. The evaluation included discussions-with Mechanical, Electrical and Civil procurement personnel; review of procurement procedures; procurement records; and review of work in process to determine compliance with procurement procedures.

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PERFORMANCE EVALUA"' ION

SUMMARY

Construction Project Performance Area . Contract Administration Objective No. PS-5 Evaluator (s) Hollins/Hendricks I. Performance obiective Methods for administering and controlling contractors and suppliers r and for managing changes to their contracts should ensure effective y control of performance.

II. Scoce of Evaluation The evaluation of this area involved two members of the team. Approximately five hours were expended in reviewing this item with individuals responsible for administration of on-site contracts. This included review of control of corrective

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action and review of schedule control. Quality of the performance is covered under other performance objectives.

L lt should be noted that this is a small segment of the overall construction effort.

The two major contractors are Bahnson which has the HVAC scope and Covil which has the insulation scope.

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1 III. Conclusion The activity evaluated under this performance objective was found to be satisfactory.

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PERFORMANCE EVALUATION SU.v_v.ARY Construction Project Catawba Nuclear Station r

Perfur: nance Area Contract Administration Objective No. PS-5 Ivaluator (s) Hol1 Ins /Hendricks y

IV. Areas of weakness and corrective action: Good Practices No areas of weakness were found. Quality of performance is covered under other performance objectives.

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-[ Catawba Nuclear Station I l  !

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1. Performance Area: Contract Administration Objective No. PS-5 (title)

2. P'rovide factual information that succorts the Performance Evaluation Summarv _

1. Changes are reviewed and approved appropriately.

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2. Changes-in schedule are reviewed by management.

3 Changes are approved by Construction Engineering.

4. Performance is monitored through schedule reviews and appropriate audits.

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SUMMARY

Constructi'on Project

. Catawba Nuc1' ear Project r-Performance Area Documentation Manacer.:ent Objective No. PS-6 Evaluator (s) c F vnek

2. Perfor=ance Ob-iective ..

The management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /information requirements of the plant's operational phase.

n. Scoce of Evaluation The evaluation of this area involved several members of the team. A program for

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the receipt, review of acceptability, resolution of deficiencies and control of

- documents during construction were reviewed. The Quality Assurance program was examined to determine what, when, how, to whom, by when and in what format records

- will be turned over to the plant's operational staff. Several controlled documents were traced through the entire cycle on the construction site. Discussions were held with various levels of supervision and management in the Construction and QA areas. Approximately 30 work-hours were expended in this objective.

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III. Conclusion l .

The activities evaluated under tris performance objective were satisfactory.

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F PERFORMANCE EVALUA* ION

SUMMARY

Construction Project

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Catawba Nuclear Station Perfomance Area "rainine Manacement Suecort objective No. TN-1 ,

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Evaluator (s) A R Hollins I. Performance Objective Management should ensure that an effective program exists for indoctri-

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nation, training, and qualification of personnel involved in the project. .

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II. Scoce of Ivaluation The evaluation of this area involved interviews with various levels in the training organization and user organization at the construction site. Approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> were expended in the training area.

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l I- III. Conclusien Generally, managernent gives adequate support to insure effective programs exist.

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- PERFORMANCE EVAI,UATION

SUMMARY

Construction Project Catawba Nuclear Station

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Perfor: nance Area Training Management Support Objective No. TN.1 g

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• A R Hollins Evaluator (s) e IV. Areas of weakness and corrective action: Good Practices

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Finding Management has shown its support by performing a "needs analysis" (TN.1-1) to determine the direction that training should follow and has hired an outside censultant to determine training organizational needs.

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PEPJORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station

l. Performance Area: Training Management Support Objective No. Dl (title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

1. Management has recently hired an outside consultant to evaluate the training organization.

2. A task force has recently performed a "needs analysis," and.the findings have been reported to management.

3 Management has used existing feedback (reaction questionnaires, verbal feedback and post testing) to modify programs and instructors.

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f PERFORF.ANCI IVALUATION S M.ARY Construction Project Catawba Nuclear Station

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i Training organization

• Perfomance Arar. and Ad- inist- atien Cbjective No. M- 2 Evalua*.or (s ) A R Hollins I. Performance obiective

- The training". organization and administration should ensure effective control and implementation of training activities.

r II. Scoce of Evaluation The evaluation of tnis area involved interviews with various levels of supervison in the training organization and user organizations at the construction site.

,/ Approximately 1P hourr were expended in the training area.

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l l-III. Conclusien . . .

Generally, the training orgenization cnd administration ensures effective control l

and implementation of training activities. However, the role of the training lr organization appears to be not clearly defined and no feedback system for measuring l

i the effectiveness was determined to be in place.

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-' i PERFORMANCE EVALUATION

SUMMARY

Construction Project  :

Catawba Nuclear Station I

Terforr.ance Area Training Oreanization and Administration Objective No. TN-2 Evaluator (s) A R Hollins IV. Areas of weakness and corrective action: Good Practices l

Finding Some. managers in the Construction area appeared to not understand the (TN.2-1) responsibilities of the training organization. Confusion as to who is responsible for the development of the employees and who determines the employees' need for training was evi. dent.

t Finding No active program could be identified to acquire feedback to determine (TN.2-2) the effect on productivity or quality brought about by training.

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PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station r 1. Performance Area: Training Organization and Administration Objective No. TN-2 (title)

2. Provide factual information that supports the Performance Evaluation Summarv _

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1. There were no procedures identified that outline the responsibilities of ~ the training organization.

,. 2. A program is in place called " Training the Trainer" to enhance the performance of instructors.

3 Managers and supervisors indicated that they were not clear who determines training needs and how Individuals are selected to receive training.

4 The following programs exist to acquire feedback at the completion of training for the purpose of developing, modifying and improving the training program:

A. Training reaction questionnaires 8

[ B. Verbal feedback C. Post-testing 5 QA procedure training for individuals Is'the only area where training require-ments are defined clearly .nd documented. ,

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l PERFORMANCE EVAI.UATION

SUMMARY

Construction Project Catawba Nuclear Station  !

1 r Perfo:.:tance Area Quality Procrams Objective No. OP-1 t Evaluator (s) P Schrandt 5 I. Performance Obiective

1 The quality assurance program scope, content, and applicability should be appropriatie, defined clearly, and understood.

f Scoce of Evaluation II.

The evaluation of this performance objective involved one member of the team. The i.o evaluation consisted of approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of discussion with Quality Assurance management, supervision and various employees. Procedure reviews and numerous record checks required approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

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4 The comitments of the quality program in general are satisfactory as evaluated under this performance objective. Identified weaknesses indicate a need for i

increased emphasis in certain elements.

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SUMMARY

Construction Project Catawba Nuclear Station

'r Parformance Area quality Programs Objective No. QP-1 Evaluator (s) P Schrandt -

i I IV. Areas of weakness and corrective action: Good Practices

(

• Finding Cor>tracted vendor QA and QC program audits are not being performed 3^

(QP.1-1) in sufficient depth to ensure program effectiveness. Several weaknesses exist in the welding program of the HVAC contracter.

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I PERF0FFJdiCE EVALUATION DETAI!S Construction ProjectJ

, Catawba Nuclear Station 1

1. Perfo=r.ance Area: Quality Programs Objective No. QP-1 y

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2. Provide factual information that su=corts the Perfer: nance Evaluation S t==na rv - _

1. A review of the vendor audits of the HVAC contractor did not disclose any weaknesses in the program. Observations of HVAC support installation indicates the following weaknesses: ,

A. There is no " traceability of weld procedures to the finished weld.

B. Procedures did not meet Code requirements.

I 2 ., er is no roc ura evid4 e n yb y i h the# c rrect"

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Objective No. QP-2 Evaluator (s } P Schrandt

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I. Performance Obiective j Quality assurance and quality centrol functions should be performed

' . in a manner t'o support and control tihe quality of the project activities.

II. Scoce of Evaluation The evaluation of this area consisted of discussion with various levels of personnel outside of the Quality Assurance Department as well as management, supervision and

'1 auditors within the QA Department. Procedures were checked and numerous records

'- were reviewed. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended in discussion and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in review of records, procedures and certification of auditors.

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1, The areas evaluated under this performance objective are well programmed and

i implemented. There are no findings under this performance objective; however, an area of concern in vendor QA program implementation has been identified

. under QP-1, Quality Programs.

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PERFOP.%NCE EVALUATION

SUMMARY

Const:uction Project Catawba Nuclear Station f

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Perfo:cance Area Indeoendnet Assessments Objective No. OP-3 D Franks, P Schrandt, d Robinson Ivaluator (s) _

I. Performance Obiective ,

Management sh.ould provide an effective, independent assessment of

• project activities affecting the quality of the project.

I e II. Scoce of Evaluation q

The evaluation in this area involved approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and included direct observation of activities, discussions with various levels of supervision and with technicians and review of records, organization charts and procedures.

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I III. Conclusion .

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The criteria under this ,nrformance objective was generally satisfactory. However, there were some weaknesses i.ated in the site surveillance area which need attention.

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1, I PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station

( '

Parfor: nance Ared Independent Assessments Objective No. __QP-3 Evaluator (s) D Franks. G Robinson, P Schrandt c . IV. Areas of weakness and corrective action: Good Practices

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Finding Independent assessments.of some quality-related activities have not (QP.3-1) been performed by the QA Department at Catawba for the last two years.

Lack of independent assessments were noted for two special processes.

Finding The surveillance program does not always assure a comprehensive assess-

'(qP. 3-2) ment of addressed areas. An area was noted where an audit found several deficiencies but surveillances performed in the same area had not been i effective in identifying problems.

- (.

Finding Surve811ance personnel do not adequately pursue full completion of (QP.3-3) assigned checklists in some cases. An area was noted where a checklist item had not been performed for 13 months when activity in the area has

,t, been regular.

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1 PERFORMANCE EVALUATION DETAI'S Construction Project 1

1

1. Performance Area: Independent Assessments Objective No. QP-3 (title)

I 2. - Provice factual information that su== orts the Performance Evaluation i Summarv . _

I

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1. Independent as'sessments have not been performed for at least the last two years by the QA Department (either the Audit Division or the site surveillance group) in the following areas:

A. Post weld heat treatment (Note: site surveillance was performed in this area through February, 1981, but the assessments were superficial).

I B. Pipe Bending i

! 2. The QA technical group does not do a log!c check / review of pressure test procedures. The Project QA Manager, in a memo dated 7-8-82, stated that QA review shall not normally include a " testing logic" check--that this check would be accomplished on a surveillance basis. To date, the surveillance.

program has not done a complete pressure test procedure review. As a result, f at a time when 75 percent of the Unit 1 test procedures are written, an i

effective independent assessment of the test procedures has not been done by site QA. . .

3 The site surveillance program has noted one finding in the last six months on the test program in six surveillances. Departmental Audi t CD-82-10(CN),

conducted July 21 through 27, found four deficient items. A review of the surveillance checklist covering testing (MWN-1) revealed that it did not g provide guidance in sufficierit detail for a comprehensive assessment of the area.

4. Survelliance CEl-4 completed checklists habitually fail to cover item 13 L

(Monitor the electrical checkout of one electrical elementary diagram.)

l The programmatic requirement for CEl-4 completion is quarterly, although the checklist itself requires monthly completion. The last time item 13 was performed was during October 1981. The reasons noted in the completed

' surveillance checklists for not performing item 13 were either failure of the craft to notify the technicial that the activity was going on or that no work was going on. The Electrical Support Group stated that checkout of lt l

' electrical elementaries has been performed regularly. There are completed j reporting forms, CP-466A, on file for this activity covering the period i

May through September 1882. Other items of the same checklist have not

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been performed for several months.

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PERFORMANCE EVALUATION SUMLiRY Construction Project Catawba Nuclear Station i l

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u Parfor=ance Area Corrective Actions Objective No. OP-4 j "P

Evaluator (s) D Franks, G Robinson, P Schrandt I I. Performance Obiective ,

I Conditions recuiring corrections or improvements should be resolved in an effective and timely =anner.

II. Scoce of Evaluation The evaltation in this area involved approximately 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> and included record E review, discussions with various levels of supervision and procedure review.

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L The criteria under this performance objective were generally satisfied. However, d, there were weaknesses noted which need attention.

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,,P S-j PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station i

f i

Parfor.mance Area Corrective Action Objective No. QP.4 Evol,lator (s) D Franks, P Schrandt, G. Robinson 1

r IV. Areas of weakness and corrective action: Good Practices i

Finding in some cases, QA approval of Inspection' Discrepancies (Forms R-2A)

~

(qP.4-1) was not sufficiently critical. Cases were noted where QA had approved R-2A Forms where the statement of required action did not address the root csuses and where corrective action had not yet been taken.

Finding Some conditions adverse to quality found during inspection are (QP.4-2) reported in a manner that is not subjected to trend analysis. As a result, related generic problems are not addressed; and basic

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- causes of degraded quality are not evaluated.

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PERFORMANCE EVALUATION DETAII.S Construction Project Catawba Nuclear Station I

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1. Performance Area: Corrective Action Objective No. O_p . h (title) i

2. Provide factual information that succorts the Performance Evaluation Su=marv - ..

1. Deficiencies were noted in Forms R-2A (Inspection Discrepancies) where the Quality Assurance group A. accepted the. statement of action required when the ac:fon did not address the root cause of the problem or B. approved clearance of the R-2A when corrective action had not yet been taken.

i

• Specifics of the examples are discussed in Performance Evaluation Details fo-Objectives No. CC-6, items 1.D and E.

2. For seven of nine 10CFR50.55e folders reviewed, senior management was not informed of the reportability status within the procedcre guidelines. Procedure PR-290, c Paragraph 2.2.2, states that the Vice President Design Engineering, Responsible j-Division Head, and the Corporate QA Manager should be notified of the reportability "

status of a potentially reportable item within five days.

3 Procedure M-51 requires the inspector to fill out an M-51C Form to identify dis-

'l crepancies noted during hanger inspections. The forms are then returned to the craft for correction. Management is not made aware of problems noted, and no trending of these discrepancies is developed and analyzed to evaluate basic causes and address generic problems.

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1 PERFORMANCE EVALUATION

SUMMARY

Construction Project g_

Catawba Nuclear Station I

p Perfor: nance Area Test Program Objective No. TC-1 Evaluator (s) M N Sawyer

g. 33 for: nance ob iective The test program should verify the plant's full capability to operate

, as intended by testing the plant's systems functionally.

1 II. Scope of Evaluation L The scope of the evaluation of this area was restricted to hydrostatic and pneumatic testing of piping systems. Functional testing of systems is the responsibility of Nuclear Power 7rbduction, rather than Design and Construc-

__ _ . tion. Specifications and procedures were reviewed along with a typical test procedure containing test data. Discussions were conducted with the appro-priate supervision during the evaluation and as a followup after performance

'- details viere obtained. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended on, review of L specifications, procedures and interviews.

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1 III. Conclusion ,

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,t The majority of activity evaluated under this performance objective was satisfactory.

i However, there were indications of weaknesses identified that point to a need to i further examine and strengthen certain aspects of the program.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station i

Perfor: nance Area Test Program Objective No. TC-1

{

~( M N Sawyer Evaluator (s)

IV.- Areas of weakness and corrective action: Good Practices f Finding There is no clear policy document from management that defines the (TC.1-1) Systems group or the organization's mission and responsibilities for testing systems.

- Finding The controlling Quali ty Assurance and Design documents do not contain

-(TC.1-2) all of the information required and used to perform system tests.

I Finding There is no program for identifying and tracking discrepancies in test (TC.1-3) documents to cause appropriate resolutions or corrections in a timely manner.

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I PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station

(

Test Program TC.!

1. Perfo::mance Area: Objective No.

(trtle)

Provide factual info:-nation that succorts the Perfor=ance Evaluation

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2.

Su==arv _

p An inspection was made of the Systems Group. The Systems Group is r.esponsible for conducting hydro and pneumatic tests of piping systems. The supervisor of the Systems Group reports to the Construction Engineer-Mechanical. Weaknesses were observed in specifications and procedures.

1. The supervisor had no overall policy direction on paper, such as a letter from management describing the group's mission and responsibilities.

2. The controlling design document is Specification CNS 1206.00-02-1002. This specification covers testing with water. There is nothing in this document that specifies how to handle pneumatic testing. Pneumatic testing is done on such systems as instrument, air and oil.

3 The controlling Quality Assurance procedure is Procedure N-1, Pressure Testing.

p This procedure does not address Form L-71A. There is nothing in N-1 on how to pr'epare or how to use L-71 A. This form is the flow diagram that describes the I

systems and furnishes Design information. It also gives boundarles for partial system tests and is a principle planning document. The evaluator was told that a new revision of N-1*is being distributed that mentions Form L-71A.

4. The Form L-7.A for hydro testing the Unit 1 CA System in the Feedwater Pump Room shows mislocated instrument lines. Corrective Action Notice form R-2A No 5350 was-issued. The R-2A cleared with a statement that the flow diagram would be k revised. The R-2A did not address the testing document (L-71A). The flow diagram has not been corrected. The L-71 A was addended to reference.the R-2A af ter the 1 evaluator expressed concern.

C 5 A part of Design aad QA information being used to perform tests is not in the controlling Specification CNS-1206.00-02-1002, nor in the QA Procedure N-1. This..

Information is contained in various letters that are not controlled documents.

L Examples of these letters are:

A. Letter dated 9-22-82, Davison to Dressler, regarding Catawba 1-2, Hydro of Flanged and Screwed Connections.

B. Letter dated 12-14-78, Coggins to Dick, regarding Catawba 1-2, Hydrostatic Test Pressure, Reference Point, File CN-1206.03-1.1.

C. Letter dated 9-1-82, Davison to Dressler, regarding Catawba 1-2, QA Review of i Hydro Prior to Turnover.

D. Letter dated 7-8-82, Davison to Morgan and Willis, regarding Hydrostatic Testing, i

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.I PERFORMANCE EVALUATION DETAII.S Construction Project Catawba Nuclear Station

(

'i Test Program Objective No. TC.1

!I 1. Performance Area: .

d (title) 2, Provide factual information that su== orts the Performance Evaluation Su:mnarv _

f E. Letter dated 10-12-81, Blackley to Rogers, regarding Catawba 1-2, Safety, L Relief and Safety-Rellef Valves.

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F. Letter dated 9-21-82, hvison to Willis and' Dressler, Catawba 1-2, Verification

q of Valve Pos!, tion on L-710.

6. The QA Procedure H-1, Press ure Testing, and accompanying forms do not provide instructions nor a place for verification signature that gauges have been properly L- calibrated per Procedure 0-1, Control of Measuring and Test Equipment.

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j PERFORMANCE EVAI,UATION

SUMMARY

Construction Project

.. Cata@a Nuclear Station Test Group organization

.' i Performance A,rea and Staffing objective No. TC-2 ,,

M N Sawyer Evaluator (s) e r i" I. Performance Objective

-f The test group organization and staffing should ensure effective implementation of the test program.

II. Seces of Evaluation

. l.

The scope of the evaluation of this area was restricted to hydrostatic and pneumatic testing of piping systems. Functional testing of systems is the t responsibility of Nuclear Power Production, rather than Design and Construction.

The test organization, test staffing end records were reviewed. A hydrostatic c test was evaluated while the test was in progress. Discussions were held with test group supervision during the evaluation and as a follow-up after perform-j ance details were obtained. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended on review and discussions.

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III. Cenelusion _ ,,,

The majority of activity evaluated under this performance objective was satis-

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-factory. However, there were Indications of weaknesses identified that point to a need to further examine and strengthen certain parts of the program.

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PERTOPy.ANCE EVAI.UATION SU.v>JW Construction Project

, i Catawba Nuclear Station Test Group Organization and Staffing Objective No. TC.2

< Performance Area M N Sawyer Evaluator (s) .

4 Areas of weakness and corrective action Good Practices IV.

Finding Th'e Systems Group functional organizational relationships to (TC.2-1) Interfacing organizations are not clearly defined.

L Finding The key management, supervisory and professional positions and (TC.2-2) responsibilities are not discribed in writing.

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Finding The personnel who are assigned to perform testing do not meet the (TC.2-3) sxperience and qualification requirements in all aspects.

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i i PERFORMANCE EVALUATION DETAILS Construction Project f Catawba Nuclear Station

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1. Perfor: nance Area: Test Group Organizational Staffin9 Objective No. TC.2 (title)

2. Provide factual infor: nation that succorts the Perfor nance Evaluation Summarv _ , , , ,

The Systems grou;f reporting to the Construction Engineer-Mechanical is responsible for hydrostatic and pneumatic testing. This organization was reviewed, and interviews were held with appropriate' supervisors. A hydrostatic test was observed for RN retest for Form CP-2018, No. 7626.

1. There is no procedure that clearly describes the organizational structure and organizational relationship to Interfacing organizations.

2. There is no document that describes the reporting priorities and relationships between the Systems group supervisor and three separate superiors. The three superiors are the Construction Engineer-Mechanical, the Completion Engineer and the General Superintendent for Unit 2.

'i 3 .' The size of the Systems group appeared to be adequate for the assigned tasks.

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4 There are no written descriptions of the positions of key management, supervisory

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and professional personnel. The evaluator was informed that job descriptions have

been written, out not yet approved and issued.

5 Personnel who are assigned to perform are trained on procedures. The qualifications y of personnel are maintained by training on revisions to procedures. A record is made of training received by each Individual.

6. The Hydrostatic Test Procedure CP-283 for the RHR (ND) Systein was reviewed. The

'L hydrostatic test record for Section 7A shows that the test pressure was held for five minutes, rather than the ten minutes specified. The same individual that recorded this data conducted the RN retest for Form CP-2018, No. 7626. The hydro-

.q static test record Form NI A for this test was examined. The test record and observation revaaled that this test director had the following problems:

A. The N-1 A listed the pining section low point as Elevation 578. The actual low I

point was approxirrately Elevation 602. The N-1A was not corrected before the test was attempted.

B. The N-1A requires the test relief valve set point to be in the range 234-236 psig.

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The relief valve furnished by the test director was set to 238 psig. The maximum test pressure was 233 psig. This could have over pressured the system. The test director removed and reset the valve.

C. The tost director had marked the minimum test pressure space on the calculation "

sheet as not applicable. After this was pointed out by the QC Inspector, the test director calculated the minimum test pressure as 219 8 psig. The calculation sheet was then corrected.

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PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station L -

Test Group Organizational Staffin9 Objective No. TC.2

1. Perfor: nance Area:

(tstle)

2. Provide factual information that succorts the ?erfor:::ance Evaluation Su:=narv -

D. The temporary hose connected to the test equipment was leaking. The water was saturating a carton of air filters and leaking to the floor below. A complaint was madq by two craftsmen from the floor below.

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8 PI;RFCPANCI IVALUATICN SW. MARY Construction Prcject Catawba Nuclear Station 1,

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Perfor=ance Area Test Plan Objective No. TC-3 Ivaluator(s) M N Sawyer I. Perfor=ance Obiective The test organization should prepare a plan and a schedule that.

. describe the' sequence of system or component testing to succort' major schedule milestones.

II. Scoce of Ivaluation The scope of the evaluation of this area was restricted to hydrostatic and pneumatic

- testing of piping systems. Functional testing of systems is the responsibility of Nuclear Power Production, rather than, Design and Construction. Discussions were

- - - - - held with appropriate supervision during the evaluation and as a follow-up af ter performance details were obtained. Test schedules and logic diagrams were reviewed and a hydrostatic retest was observed. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended on g

review and discussions. -

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I III. Conclusion The activity evaluated under this performance objective was generally satisfactory.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station

1 Perfor::ance Area Test Plan Objective No. TC-3 Evaluator (s) M N Sawyer IV. Areas of weakness and corrective action: Good Practices Finding There are indications that a growing amount of rework after systems (TC.3-1) are turned over to the test group could; adversely affect the scheduled system completion dates.

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PERFOPS.ANCE IVALUATION DETAILS Construction Project Catawba Nuclear Station Test Plan Objective No. TC.3

1. Performance Area:

(title)

( 2, Pro' vide factual information that succorts the Performance Evaluation

( Summarv An interview was held with the supervisor of th Systems group. The test logic diagram and test' schedule were reviewed. A visual observation of a test was made.

1. The Systems group has adequate input to the overall site schedule.

2. The systems required to be completed in the near term are coordinated with Nuclear Power Production.

3 Experienced personnel developed and are following the test schedule.

4. The system boundaries of piping sections scheduled to be tested are clearly defined on Form L- 71A. The valve lineups are carefully planned for each test.

Controls are in effect to insure prerequisites are met prior to beginning a test.

5 The needed interface people were present at the scheduled test. The numbers of craf t and QC inspectors were adequate to complete the test in a timely manner.

However, changes to the pressure test Form H-1 A were necessary af ter the group was assembled at the test location. This caused a delay in starting the test.

I 6. There have been approximately 7,740 Request for Shutdown Forms CP-201B and approximately 1,100 Shutdown Forms F-13A written to date. These forms list rework L

af ter the time systems are turned over to the Systems group for testing.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station Parfo::=iance Area System Turnover for Test Cbjective No. TC-4r -

Evaluator (s) G Robinson I, Performance Objective _.

The construction testing and turnover process should be controlled effectively t'e ensure that program objectives are met.

II. Scoce of Evaluation The evaluation of this area involved two team members. Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> were expended observing a QC walk-down. Approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> were expended review!ng and discussing turnover documentation with involved personnel.

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III. Conclusion _ _ . . .

The majority of activity evaluated under this performance objective was generally satisfactory. Two items of weakness were noted.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station Parfor: nance Area System Turnover for Test Objective No. TC-4 Evaluator (s) G B Robinson IV. Areas of weakness and corrective action; Good Practices Finding Not all items that identify Construction deficiencies or items that (TC.4-1) ould have an effect on maintenance are identified. Examples are reliance on craf t for the required list of outstanding variation notices'and craft's leaving valves uncapped and QC mechanical inspector stating he has no responsibilities for keeping valves capped.

Finding Although turnover procedures identify responsibilities of various (TC.4-2) organizations, not all groups adhere to their responsibilities. An example is craft applying test pressure to an unreleased portion of a system without direction from Construction Engineering.

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PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station-System Turnover for Test TC-4

1. Performance Area: Objective No.

(title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

1. Without direction from the Systems group, craft applied 200 psig to a portion of RF/RY. This occurred prior to the system being properly released for testing.

Reference R-2A (corrective action notice), Serial No. M5677 2 During a walk-down performed on a section of System NI, three valves were welded out on one side and left uncapped on the other. (Valves 1N1328, 1NI329 and 1N1330) When questioned,.the inspector stated they were not in his area of

, . responsibility. The items had passed the craft pre-inspection.

3 Electrical Construction Engineering is relying on the craft for the list of outstanding variation notices (5-2J) at the time of turnover.

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i PERFORMANCE EVALUATION

SUMMARY

Construction Prcject Catawba Nuclear Station Test Procedures and Ps for::ance Area Test Documents Objective No. TC-5 ,

Evaluator (s) G Roblnson I. Perfor:iance Objective _.

Test procedur.es and test documents should provide appropriate direction and should be used effectively to verify operational and design features of respective systems.

II. Scoce of Evaluation

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The evaluation involved two team members. Approximately seven hours were expended observing work practices. As a follow-up to the observation, twelve hours were devoted to discussions with various personnel involved in testing. Review of records involved another twelve hours.

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The majority of activity evaluated was generally satisfactory. However, there were weaknesses identified.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Catawba Nuclear Station P3rformance Area Test Pro _c_edure and Test Documents Objective No. Tc-5 Evaluator (s)

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, IV. Areas of weakness and corrective action; Good Practices Finding / Appiopriate preparation of Corstruction testing teams prior to conducting (TC.5-1) tests is not always being accomplished. Several problems were observed to occur resulting from poor planning practices.

". Finding Tt.chnical data, inspection criteria, documentation handling, and (TC.5-2) procedure review criteria are being obtained from uncontrolled

,<. documents and verbal Instructions. This could potentially result in rework, a

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c PERFORMANCE EVALUATION DETAILS Construction Project

<* Catawba Nuclear Station-

'~ Test Procedures and Test Documents TC-5

1. Performance Area: Objective No..

1 (title)

{

2. Provide factual information that-succorts the Performance Evaluation Summarv _

1. During observations of testing in progress, the-following weaknesses were noted, t (A through C -- approximately 300 feet of 1" pipe on CP-566)

A. More than one-half hour each for four craftsmen and the technician were spent trying to locate radios for cormunications during testing.

B. For approximately one and one-half hours the test crew tried to pump one section to test pressure. There was a boundary valve leak-through problem that prevented bringing the system to pressure. It was not determined where the leak was.

C. Approximately six hours were spent from the time the test technician and k craf t started out to do a relatively simple test until it was completed and the pipe inspected.

(D through J -- test for 201B 7626, RN System approximately 100 feet of

• 3" pipe)

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D. The N-1A (hydro test form) listed th'e section low point as Elevation 578.

- The actual low point was approximately 602. The N-1A was not corrected.

E. The N-1A InJicated a relief valve set to 234-236 psig was required. The t t relief valve supplied by the test director was set at 238 psig. The l maximum test pressure was 233 psis.

F. The QC Inspector pointed out to the test director that he had marked l' minimum test pressure as not applicable. The minimum test pressure was then calculated by the director to be 219.8 psig, and the form corrected.

G. The temporary hoses being used to supply water to the system were leaking.

The water was soaking a carton of filters identified as "AHU-3 1131-CNS."

This was pointed out to the test director, but the situation was not corrected.

E H. Water from a hose leak was running through an air duct sleeve to the elsvation below, creating a slick floor. During the observation, two l< different people came to the test director to complain. A utility person was stationed on the floor below to clean up the water. The hose connection was tightened to slow down the leak.

i 1. The test director left the test area to have the relief valve reset to 232 psig, and the range corrected on the N-1A. Two craft personnel and two inspectors waited in the area for him to return. The wait was approximately 20 to 25 minutes.

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c-L PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station

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1. Performance Area: - Test Procedures and Test Documents Objective No. TC-5 .

(title) r' a

2. Provide factual information that succorts the Performance Evaluation Summarv _

I J. Further checking cencerning proper system low point revealed direction had L been given the systems people in a letter dated 12-14-78. The letter stated the provisions would be added to the specification. A review of the r specification revealed that it has not been incorporated to date. This was verified with the systems engineer.

2. A review of testing documents, procedures, audits and records revealed the following ,

i

. A. CP-283, a recently completed ND System pressure test, was obtained from j Systems (prior to their final approval) and reviewed in general. The

r. following items were noted:

b 1. Section 7A was on a Class E line which is ANSI B31.1, but ASME li t was the referenced Code on the N-1A. This discrepancy had not been I caught by Construction and/or QA on initial review.

I 2. The test of Section 7A was held only 5 minutes; 10 minutes is required.

g by 831.1.

3 Section 7A had attached an F-10A (ASME repair form) for Valve 1FW56.

i(- The valve was actually in Section 7B and was not shown on the L-71A.

4. Step 7.65 had a valve number added with no Initials and dates contrary J to procedure.

I, 5 The test engineer did not approve some of the CP-249A Forms (fill source analysis). CP-249 does not explain the approval process.

'a

. 6. R-2A 5478 was referenced on Section 6 as a problem. The test was signed acceptable by the test engineer on 9-17-82. The R-2A wcs not

, ,.- cleared until 9-28-82. There appears to be procedural guidance given L concerning clearing problems discovered on testing as they relate to i accepting the tests.

B. CP-566 (NI Pressure Test) was recently finished. A review noted the following problems:

1. Several Class E N-1A's (hydro forms) did not have the test data on the form. The technician stated he had the data in his notes and just had

! not completed the form. Some of the tests were accomplished as much as

'I one month earIIer.

L.

l, 94 Ii

o. . . .-

m PERFORMANCE EVALUATION DETAILS Construction Project Catawba Nuclear Station

1. Performance Area: Test Procedure and Test Documents Objective No. _TC-5

~

(title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

r

2. Section 8 contained Class B and Class C piping. This section was completed on either 8-31-82 or 9-1-82, but no data was placed on the y

N-1A by the inspector. The test director stated that a particular QC Inspector had witnessed the test. Checking revealed a different

'E Inspector had witnessed the test, and the test data was on a small, loose, piece of paper in the inspector's table drawer. The inspector had to study for a moment before he could relate to the data. QA Procedure N-1, Paragraph 4.3, requires recording the data properly during the test.

I 3 QC stated that within the last two weeks they have started completing i ,.

the test data portion of N-1A and withholding their signatures until the test gauge is calibrated. There is not a procedure that addresses

p this practice.

l- C. Several letters which are not controlled documents are being used by systems and QA/QC for determining requirements and performing inspections. Examples are:

'i ,. .

1. Letter dated 12-14-78 concerning system low points

2. Letter dated 10-12-81 concerning flanged relief valves 3 Letter dated 9-1-82 concerning testing records i

4. Letter dated 7-8-82 concerning procedure review 4

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'l PERFORMANCE EVALUATIC?T

SUMMARY

Construction Project l

'~

Catawba Nuclear Station l F .

Parformance Area Svstem Status Controls Objective No. TC-6 4

Evaluator (s) G Robinson I, Performance obiective *e 4

/ A method should. exist to identify the status of each system or component and the organization holding control or jurisdiction over that system or compenent to prevent interference and ensure equipment <

r and personnel safety.

II. Scoce of Evaluation The evaluation of.this objective involved in the preoperational testing accomplished

- by Nuclear Production. No observations were made in this area, since it does not 4

apply to work accomolished by Duke Design or Construction.

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i III. Conclusion __

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i Response Summary -

r The information that follows addresses each of the Evaluation Team i . findings. Several of the corrective actions resulting from ther findings have already been initiated. _We will track the remaining

, -corrective actions until completely implemented, i s e

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DESIGN ENGINEERING -

f Perfor: nance Area Reviewed Finding #

. [ Design inputs (DC-1) DC.1-1

I DC.1-2 DC.1-3

- . DC .'l-4

]r DC.1-5 Design Interface (DC-2) 'DC.2-1 E DC.2-2 DC.2-3 r Design Process (DC-3) DC.3-1 DC.3-2

- DC.3-3 DC.3-4 Design Output (DC-4) DC.4-1 DC.4-2

,  ; DC.4-3 I. Design Changes (DC-5) DC.5-1 e

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f INP0 EVALUATION

. GENERIC WEAKNESS: Lack of-Documented Requirement for Implementing l, PSAR & FSAR Design Commitments APPLICABLE INP0 FINDING (s):

, DC 1-1

<u APPLICABLE SUPPORTING FACT NUMBER

c L. 1-1 2-4 3-1

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I INP0 PERr0Rl1A!!Cf. EVAL 9ATI0fl C0flSTRUCT10fl PROJECT RESP 0llSE SilEET CATAWBA flVCLEAR ST.

.- Performance Area Desian Inout Evalua tor (s) C. Glidewell IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC.1-1 No requirement exists for identifying, tracking', and assuring commitments identified in the PSAR are met. Design information should be clearly defined and controlled.

I o Corrective Action Plan l- Duke Power Company's past method for control of SAR commitments has been as follows:

- 1. Listings of commitments maintained by SRAL Division have been used to identify, track, and control: ,

a. PSAR commitments, outside those embodied in normal engineering practice,

b. Commitments sent to the NRC after PSAR approval and prior to submittal of FSAR.

i

c. Commitments identified prior to preparation of the FSAR to be included in the FSAR.

i d. Deviation from PSAR commitments.

e. Deviations from FSAR commitments. These deviations included in licensing documents via normal SAR and license amendments.

2. Commitment and deviation listings have been distributed to Design Engineering Sections Heads and updated on no less than a quarterly basis.

3. All SAR and Regulatory Commitments are reviewed by appropriate levels of i- Duke management prior to submittal to'NRC. Quality Assurance procedures require the consideration of SAR and other regulatory commitments in the l preparation of calculations, design specifications, and related documents.

Duke Power Company feels that this finding has merit in that a number of SAR

.j and Regulatory Commitments were considered a part of normal engineering practice and were not controlled by any o.f the above methods. An effort

'- will be initiated to develop a program for more direct commitment tracking.

Program development will be complete by March 1, 1983.

L 100

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INPO EVALUATION  ;

m GENERIC WEAKNESS: Lack of Formal Program Defining Responsibility for Provision of Design Input

, ,e APPLICABLE INP0 FINDING (s):

DC 1-2.

APPLICABLE SUPPORTING FACT NUMBER

, 1-2 3-5 1-3 3-8 l- 1-13 3-14 2-3 3 2-6 4-6 I

i I.

l 1 _ _

l 101

I PERFORiiANCE EVALUATION CONSTRUCTI0tl PROJECT INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

i Performance Area DESIGN INPU1 Evaluator (s) C. Glidewell IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC 1-2 No control program for defining responsibility for providing Design input

'i. could be found. Input is usually provided on a request basis.

D y _ Corrective Action Plan g The organizational respor.sibilities in the Design Engineering Department ar'e 1"

formally documented in responsibility statements. In addition, significant commitments to provide design input are included in the integrated schedule

.. or ' punch list by responsibile group. At the supervisory level within Design Engineering, the design process is well understood; however, due to speciali-zation in some functional groups, individual engineers may not be familiar with the overall process.

q" The INP0 finding identifies some Design Engineering activities where formal procedures could be of value to Duke's overall design program. The INP0 observations will be used as a basis for continued review of this area through i

May 31, 1983,to determine if specific problems indicate a need for a more stringent control program. Corrective action regarding specific problems identified concerning system descriptions is addressed under the discussion L of findings DC 1-4, 2-1, 3-3, 4-3 and 5-1. Corrective action regarding specific

' problems identified concerning instrumentation design is addressed under the discussion of findings DC 2-2 and DC 4-1.

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.I INPO EVALUATION

GENERIC WEAKNESS: Lack of Formal Program for Assuring Control of Design Input Documentation I APPLICABLE INPO FINDING (s) u DC 1-3

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APPLICABLE SUPPORTING FACT NUMBER 1-4.

2-1B W

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT

, INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Desian Inout Evaluator (s) C Glidewell-

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'i IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC.1-3

. Design input information is not always provided in a controlled manner.

Memorandums serve as the primary vehicle for documenting. design input.

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Corrective Action Plan _

(1 Duke agrees additional review is in order to determine if procedure changes or additions would be beneficial. This review and any needed procedure development will be completed by March 1,1983.

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d. 104

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INP0 EVALUATION n

GENERIC WEAKNESS: System Descriptions not Current and/or Disagree

-l: with Other Design Documents (Flow Efagrams/ Design L. Drawings / Elect. System Descriptions, etc.)

i APPLICABLE INPO FINDING (s)i f DC 1-4'

'i. DC 2-1 DC 3-3 C DC 4-3 DC 5-1 L

l APPLICABLE' SUPPORTING FACT NUMBER 1-8 1-12 3-1D 4-4 1-9 2-1A 3-15 4-5 4, 1-10, '2-1C 3-16 5-2 1-11 3-9 4-3 5-3 4

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! PKga 1 of 2 INIO PERFORMANCE EVALUATION CONSTRUCTION PROJECT i o RESPONSE SHEET CATAWBA NUCLEAR ST.

Design ' Inputs, Design interfaces, Design Process,. Design Output, Performance Area and Deslan Changes P

f

. L Evaluator (s) ~C. G11dewell. D. T. Clift. Belew, and Hendricks

. i j' IV. Areas of Weakness -and Corrective Action; Good Practices Finding # DC.1-4,-DC.2-1, DC.3-3, DC.4-3, and DC.5-1

[ #DC.1-4 System descriptions and flow diagrams do not always agree

' as to the current requirements. Several system descriptions were observed to lag revisions of system flow diagrams.

.i

1. DC.2-1 The process for controlling Design input documents does not require timely updating of system descriptions. The RHR and

~

AFW System descriptions are not maintained current with system-designs.

1. DC.3-3 Design documents relating to .the design of the RHR System are

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In disagreement creating a. potential for error in the design. e This is also true' for the VFW System. "

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1. DC.4-3 System descriptions are used to provide system control informa-4 tion. They do not reflect current system design.

1. DC.5-1 Confilets between system design documents exist for extended periods of time, because system descriptions.are not revised in a timely manner.

L Corrective Action Plan All of the above INPO findings evolve from Design Engineering Depart-ment 's philosophy pertaining to system descriptions. System descriptions as utilized in Duke's design process are considered general supporting documents to flow diagrams and electrical elementary drawings. Also,

system descriptions are important for initiating system design and for

+ documenting the final design.

The present method of handling system descriptions requires a close working' and approval process between Mechanical and Electrical. Although 4

the process has worked well in the past, there is potential for improve-

men' and the 7f ollowing corrective measures will be considered and pursued

'by Design Engineering:

1) ~ Provide more timely update for,both mechanical and electrical i

systems descriptions on a continuous basis with completion by 4

. Reactor Fuel Load date for Catawba Unit 1.

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Ptga 2 of 2 Finding #'s DC.1-4, DC.2-1, DC.3-3, DC.4-3, and DC.5-1 Corrective Action Plan (Continued)

- 2) Document future changes in instrumentation and controls on instru-mentation data sheets. Instrumentation data sheets currently

~ have a three level signoff (prepared, checked, approved); addi-

.- tionally, in the future these documents will be issued via a

' controlled distribution. This approach will provide downstream

'L work groups'a document to work from until the Mechanical System Description is revised.

3) On' future plant designs, consider using logic drawings to transmit design information now found in the Mechanical System Description

r. In a more graphic and controlled manner. With this change, the Mechanical System Description would then become a general i n fo rma-tion document only.

4) Establish a time interval governing . revisions to the Electrical

. System Description. Afterwards, monitor Electrical system descrip-t ton release schedules to insure they reflect current system designs.

Areas 1), 2), and 3) stated above for improvement of Duke Power

, Company's Design program will be evaluated, appropriate procedures revised or developed for implementation within Design Engincering by

'L March 1, 1983 Item 4) will be implemented by December 15, 1982.

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r INFO EVALUATION >~, t ,

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'r 7, a GENERIC WEAKNESS; LackofFormal-ProgramtoAssure.jCorrectjApplication

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and/or Control of. Seismic . Response _ Spectra

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APPLICABLE SUPPORTING FACT NUMBER'

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1-5 3-3. .

1-6 >.3-4 -

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT 4" ,l INP0 RESPONSE SHEET CATAWBA NUCLEAR ST.

Ll-Performance Area Desian Input i Evaluator (s)- -

C. Glidewell i I I, IV. Areas of Weakness and Corrective Action; Good Practices

. Finding # DC.1-5 L .

No documented program was found for assuring correct application of seismic response. spectra.

of i

L Corrective Action Plan

[t. s a result of an earlier internal review by Desgin Ennineering, revised procedures are being implemented to improve control of seismic design l requirements. Responsibilities have been reviewed and the Civil / Environmental

l. Division will' review all specifications and procedures containing seismic design or qualification requirements to assure seismic requirements are adequately and correctly specified. In addition, the Civil / Environmental i.

Division is preparing structural design specifications for each plant that include the seismic analysis and design requirements for major structures.

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It is' Duke's position that adequate procedures are in p' ace or being implemented to control the use of response spectra and assure seismic design requirements .are being satisfied.

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I INP0 EVALUATION t

I GENERIC WEAKNESS: Lack of Formal Program for Determining and Assuring L. Constructability, Maintainability and Operability 1

APPLICABLE INP0 FINDING (s):

DC 4 '

APPLICABLE SUPPORTING FACT NUMBER 1

1-I' 1-7

'3-7 4-2 l- I e

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f INP0 PERFORMAMCE EVALUATION-RESPONSE SHEET

. CONSTRUCTION PROJECT CATAWBA NUCLEAR ST.

I Design Output Performance Area Evaluator (s) Pelew, Clift, Glidewell, Hendricks IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC 4-2 No documented program was identified for determining and assuring review for constructability, maintainability and operability is conducted. Reviews are performed where a need is identified.

Corrective Action Plan Reviews for constructability, maintainability, and operability.have been conducted during the design and construction phases of Catawba Nuclear Station.

, There are three primary programs for review as follows:

.i 1) ' Scale Model Reviews - Each area 'of the plant has been reviewed several times utilizing our scale model (3/8 inch = 1 foot). Also, special enlarged models of small congested areas are constructed where potential problems are known to exi'st.

2) . Composite Drawing Reviews - This series of orthographic drawings illustrates the design of all engineering disciplines within each area of the plant.

As design drawings are released, the composite drawings are updated and the design is reviewed for constructability and maintainability.

3) Piping Design Criteria - There are 24 Piping Design Criteria. Construct-ability, maintainability and operability were considered in the development of the criteria. Since the Piping Design Criteria is a recent development, it has only been utilized on new designs and recent design revisions.

Each of the above programs is documented and solicits appropriate inputs by affected groups within the company.

' o further improve or supplement the above programs, Duke Power organized a task T

force to investigate methods for improving Construction and Nuclear Production input into the design process during the fall of 1981. This study especially i

addressed reviews for constructability, maintainability and operability. The L study and resulting recommendations have been completed and approved for imple-mentation beginning with the design of the Cherokee Nuclear Station. Recommend-

! ations included the formation of review groups from the Construction and Nuclear Prod 0ction Departments which review considerations for constructability, main-tainability and operability.

In summary, our Design Engineering Department's design process includes

, formal reviews for constructability, maintainability and operability which are considered adegu, ate; therefore, no change to existing or approved future Duke practices are p'lanned as a result of this finding.

111

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t INP0 EVALUATION GENERIC WEAKNESS: Inadequate Interfacing of Design Changes /Information Relative to Instrumentation Design APPLICABLE INP0 FINDING (S)-

DC 2-2 DC 4-1:

CORRESPONDING INP0 FACTS:

2-2A, '2-28, 4-1 & 1-14 he i .

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l 111P0 PERFORMA!!CE EVALUATION CONSTRUCTION PROJECT I RESP 0!!SE SHEET '

CATAWBA ftUCLEAR ST.

Performance Area Design Input / Design Interfaces / Design Output Evaluator (s) Below, Clif t, Glidewell, Hendricks

-IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC.2-2. DC.4-1 Finding Several instances were identified where Design and Design change (DC.2-2) information were not effectively coordinated between the affected organizations. Several problems were observed involving the exchange of information and control of interfaces between the electrical and mechanical I & C groups and between support /

restraint and piping layout sections.

Finding The B0P transmitter accuracy information required for the NUREG 0588 (DC.4-1) Electrical Equipment Environmental Qualification Report is not being properly determined. The overall instrument loop accuracy is not considered.

I L

Corrective Action Plan The above findings all relate to the specific weakness identified in Finding

- DC.4-1 with respect to the ' interface between Mechanical Instrumentation and Control (MPIC) and the Electrical Division. The weakness is a lack of an established and documented program and responsibility assignments for determining required accuracy'for Catawba safety related instruments located in potentially harsh plant environments as required by NUREG 0538.

To correct this specific problem, an appropriate documented resolution will

. be developed and implemented with affected groups by December 15, 1982.

In addition, existing methods of accounting for instrumentation accuracies in overall system design, both safety and non-safety, consist of unwritten understandings and agreements. To improve Design Engineering interfaces, responsibilities and methods, a more formal program will be developed and implemented by March 1, 1983.

113

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INP0 EVALUATION

- GENERIC WEAKNESS: Inadequate Interfacing of. Design Changes /Information Relative to Piping and Support / Restraint Design c

APPLICABLE INP0 FINDING (s):

DC 2-2 APPLICABLE SUPPORTING FACT NUMBER

- 2-5 I.

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RESPONSE SHEET CATAWBA flVCLEAR ST.

Performance Area Design Interfaces Evaluator (s) D. T. Clift IV. Areas of Weakness and Corrective Action: Good Practices ,

~

Finding # DC 2-2 Several instances were identified where Design and Design change information were not effectively coordinated between the affected organizations. Several

- problems were observed involving the exchange of information and' control of interfaces between the Electrical and Mechanical I & C Groups and between Support / Restraint and Piping Layout sections.

Corrective Action Plan

- Current practices have an inherent weakness to the extent that Support / Restraint generated isometrics have potential for being in disagreement with the drawings produced by the Station Services Group. Discrepancies between the two can exist for the following reasons:

1. Discrepancy between erected pipe and Station Services Drawings;

2. Incorrect field measurement;

3. Translation error in the isometric process;

4. Time lag in revision process, i.e., the two documents temporarily may not be in agreement with latest revisions.

In order to ensure that disagreements between the Support / Restraint isometrics and the Station Services drawings are discovered and resolved in a timely fashion, the- following future action plan will be implemented by the Mechanical. and Nuclear Division:

1. Support / Restraint Group will review their isometric drawings against Station Services Group drawings and identify and resolve cases where there is a disa-greement.

2. Future isometric drawings will require an inspection sign-off by the Station Services Group. Station Services Group will review the isometrics for con-

, figuration and inclusion of the latest revisions.

,, Implementation ,of steps 1 and 2 will begin December 1,1982.

In conclusion, Duke agrees with the INPO Finding- and appropriate procedures will be revised and/or developed formally documenting the above interface improvements.

within Design Engineering by January 4, 1983.

115

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m INP0 EVALUATION GENERIC WEAKNESS: Lack of Formal Program to Assure Timely and Proper

'~ Filing of Design Records APPLICABLE INP0 FINDING (s):

DC 3-1 1.

APPLICABLE SUPPORTING FACT NUMBER 3-6 O

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f PERFORiiANCE EVALUATION CONSTRUCTION PROJECT INP0 RESPONSE SHEET CATAWBA NUCLEAR ST.

f Performance Area DESIGN PROCESS Evaluator (s) C.-Glidewell IV._ Areas of Weakness and Corrective Action; Good Practices Finding # DC 3-1

~

Design records are not always being filed in a timely manner. Waiver form

-- originals on file in a manual have not been transmitted to General Services for corporate filing.

Corrective Action Plan INP0's finding is valid for the specific instance identified. A thorough and encompassing review of Civil / Environmental, Mechanical & Nuclear, and Electrical Divisions for the generic implications of the finding indicated that there is

' not a significant deficiency or weakness in this area. The isolated deficiency identified in the audit finding has been further investigated and corrective action initiated. A revision to the procedure (PR-130) will be proposed by November 30, 1982 to clarify the filing requirements of the original form 4

c (Form 130.1).

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INPO EVALUATION GENERIC WEAKNESS: Original Issue and Revisions to Design Documents Differ in Sign-Off Documentatien APPLICABLE INP0 FINDING (s):

DC 3-2 l

APPLICABLE SUPPORTING FACT NUMBER 3-2 5 >

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., RESPONSE SHEET CATAWBA NUCLEAR ST.

c.

Performance Area DESIGN PROCESS i . Evaluator (s). C. Glidewell

- IV. Areas of Weakness and Corrective Action; Good Practices Finding # DC 3-2 Changes to design drawings do not receive the same degree of documented review as the original issue. -Originals are documented by designer, drawer, checker and approver. Revisions.are documented by checker and approver.

Corrective Action Plan Drawings are processed in accordance with the Design Engineering Quality Assurance program. This program distinguishes between original drawing issue and revision issue insofar as the degree of sign-off required. Even though ,

there is a difference in the amount of documented information concerning those l individuals working on a drawing, the overall program maintains the same integrity for revisions as for original issue. Both original issue drawings

, and revisions to those drawings are prepared by a qualified individual. The

!~ information which is prepared by the qualified individual is then checked by another individual, other than the supervisor, who is equally qualified. This  ;

, check is documented in the case of original issue.and revision issue. If there are interfacing considerations with other divisions, appropriate. .

j inspection signatures are obtained for both original issue and revision issue drawings. Finally, the original issue or revision issue of the drawing is approved by an individual authorized in writing by the division head of the sponsoring division. In all instances, work on design drawings is done by a qualified preparer, checked by another qualified individual, and approved by a designated supervisor who is in responsible charge of the work. Documentation of who actually prepared a revision to an original drawing has no bearing on the quality or integrity of the design.

. Although INP0's finding is correct,it does not represent a design deficiency or weakness. The finding and supporting facts describe what is documented in the Design Engineering Quality Assurance program as Duke procedure. This ,

program has met the test of time for adequacy and has been reviewed and accepted by the Nuclear Regulatory Commission. No change to existing Duke practices are planned as a result of this finding.

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INPO EVALUATION n: GENERIC. WEAKNESS: Design Calculations not Current, Complete and/or do not Support Other Design Documents

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-APPLICABLE INP0 FINDING (s):

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APPLICABLE SUPPORTING FACT NUMBER i

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I INP0 PERFORMANCE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAWBA NUCLEAR ST.

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Performance Area Deslan Process

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Evaluator (s) C. Glidewell IV. Areas of Weakness and Corrective Action; Good Practices i Finding # oc.3-4 Calculations are not being maintained in a controlled manner that support issued Design documents.

Corrective Action Plan T

The INPO finding relative to this matter is unique to the Mechanical Systems Grouo of Duke Design Engineering and requires two corrective

, actions as follows.

1) Documentation Deficiencies - As a result of this INPO finding, Design Engineering conducted a review of the Mechanical Systems Group calculational file which' revealed that a small percentage

(<5%) of the Catawba calculations were not in the required docu-mentation format. All calculations not in the required documenta-tion format will be upgraded to proper format by March 1, 1983

2) Mechanical System Verification - As a system reaches an advanced stage of crection (system as-built to QA procedure MPR-140), design

" data, parameters, and functional design requirements that are important to nuclear safety are verified in a final system verifica-tion calculation prior to reactor fuel load as required by ANSI J N45.2-11. Although the Design Engineering Department's system verification process is acceptable, it has two weaknesses; the-requirement for system verification is not documented in writing nor is the work scheduled. In order to formalize and assure the requirement for system v'e rification is met, a Mechanical Systems Group work place procedure will be written and implemented by 1-15-83 to define design parameters to be verified and how the

-( verification can be accomplished. A schedule for system verifica-L tion will be developed based on as-built and reactor fuel load dates. Appropriate entries will be added to the Design Engineering acti vities punchlist by 12-15-82 to assure system verification calculations are completed prior to reactor fuel load.

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CONSTRUCTION c l Performance Area Reviewed Finding #

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ConstructionEngineering(CC-1) CC.1-1 Material Control (CC-3) CC.3-1 i CC.3-2 CC.3-3 CC.3-5

.. CC.3-6 Control of Construction (CC-4) CC.4-1 Processes CC.4-3 CC.4-5 Construction Corrective (CC-6) CC.6-1 Actions CC.6-2 CC.6-3 Test Equipment (CC-7) CC.7-2

Control Industrial Safety (PS-1) PS.1 Project Planning (PS-2) PS.2-1 Test Program (TC-1) TC.1-1 TC.1-2 TC.1-3 Test Group Organization and (TC-2) TC.2-1 Staffing TC.2-2 TC.2-3 f TC 3-1 Test Plan (TC-3)

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System Turnover for Test (TC-4) TC.4-1

'J TC.4-2 Test Procedures and Test (TC-5) TC.5-1 Documents TC.5-2 Training Management Support (TN-1) TN.1 -1 Training Organization and (TN-2) TN.2-1 Administration TN.2-2 i

i 122

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.I PERFORMANCE EVALUATION CONSTRUCTION PROJECT INP0

- RESPONSE SHEET CATAWBA NUCLEAR ST.

1 Performance Area Construction Engineering r

i T F Wyke, R D Anderson

. g. Evaluator (s)

\

c IV. Areas of Weakness and Corrective Action; Good Practices L , Finding # CC 1-1 q

" Managers and supervisors do not always enforce adherence to plant poIIcies and procedures. Several areas were noted where personnel did not' adhere to established work procedures.

s Corrective Action Plan Currently, Construction procedures are reviewed annually. By July 31, 1983, this review will be expanded, actual work practices will also be reviewed.

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT

. -INP0 RESPONSE SHEET CATAWBA NUCLEAR ST.

4 1 '

Performance Area Material control c- Evaluator (s) s sheooard

J 'IV. Areas of Weakness and Corrective Action; Good Practices Finding # cc.3-1 O Site receipt inspection does not ensure that material and equipment received on site are evaluated against the requirerents of the procurement specifications. Examples of the problems identi fied may potentially result in delays, waste of materials, additional time spent on disposition of deviations from procured materials and work stoppage.

Corrective Action Plan

- Response I-- The method .for transferring non-safety-related materials between-sites will be examined. Any changes needed will be completed by May, 1983 -

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. INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

• t Performance Area Material control Eval 6ator(s) s. sheooard I

F IV. Areas of Weakness and Corrective Action; G3od Practices Finding # cc.3-2

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l A consistent method for material identification was not in effect in the warehouse. Several instances were noted where 1. D. tags had fallen off, equipment was marked with ink; and when material was being sectionalized to start fabrication, a means for maintaining the identification was not being done, a

Corrective Action Plan c Response A uniform marking system will be developed by January and implemented by AprII,1983. - Also, beginning in April,1983, in-house audits will be made to ensure compliance with the marking system.

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

I t

Performance Area Materlat control - ,

I S Sheppard

. Evaluator (s)

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IV. Areas of-Weakness and Corrective Action; Good Practices t Finding # cc.1-2 1"

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Proper protective measures were not taking place for envi ronmentally sensitive equipment that was " robbed" for spare parts. Some parts were being stored in an open instrument cabinet, w/

Corrective Action Plan

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Response

The Equipment Maintenance Section had reported this situation to the site manager of equiprent and materials in a memo date/ !?otember 28, 1982. By

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January 1,1983, a procedure will be implemented to cor... .1 removal of parts.

It should be noted that the Transmission Department is responsible for the

'l items cited in 2B.

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PERFORf%NCE EVALUATION CdNSTRUCTIONPROJECT INPO CATAWBA NUCLEAR ST.

RESPONSE SHEET

\ .

7 Perfonnance Area Material cor. trol i

s vieppard

.. Evaluator (s)

L.

- IV. Areas of Weakness and Corrective Action; Good Practices

- Finding # cc.3-5

p Materials are not being maintained or stored ef fectively at

-l work site locations. Several examples were noted which reflected imprope r cont rol .

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Corrective Action Plan

Response

i A program to hold supervisors accountable for Material Control and housekeeping will be implemented by April 1, 1983 4

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- IV. Areas of Weakness and Corrective Action; Good Practices

(< Finding # CC.3-6

,. Scheduled preventative maintenance activities on !nstalled equipnent

_I are not always assured throughout the entire perlov on Construction

- Department control. Equipment was identi fied for v:hich preventative maintenance had been cancelled up to 21 months ago, and there was c no evidence that compensatory requirements had been established.

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l Corrective Action Plan ll

Response

F By March 1,1983, the preventive maintenance program will be revised.

This will ensure that plant equipnent is maintained until it is turned over to the Nuclear Production Department.

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- RESPONSE SHEET CATAWBA NUCLEAR ST.

c' Performance Area C ntrol of Construction Processes i

Evaluator (s) T F Vyke. H S Sheooard g

( IV. Areas of Weakness and Corrective Action; Good Practices

<- Finding # cc.4-1 -

f Managers and supervisors do not always enforce adherence to plant policies

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and procedures. A number of areas were noted where personnel did not adhere to established work procedures.

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Corrective Action Plan f An evaluation and action plan will be completed by February 28, 1983

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RESPONSE SHEET - CATAWBA NUCLEAR ST.

> T Performance Area Control of Construction Processes

g. Evaluator (s) T F Wyke & H S Sheppard l

i IV. Areas of Weakness and Corrective Action; Good Practices

'- Finding # cc.4-3 I

Weaknesses were observed in the training of craft personnel in selected areas. Several examples were noted which reflected insufficient familiarity

.. with work procedures.

Corrective Action Plan in-house and consultant training studies have been completed. Recommended I

changes will begin January 1,1983 I

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=c- IV. Areas of Weakness and Corrective Action; Good Practices

< Finding # CC.4-5

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One example of restrictive procedure (CP-601) was observed. Use of this procedure precludes judgment by experienced personnel and results in concrete mix which will not meet acceptance criteria.

C Corrective Action Plan Construction procedures are reviewed annually. These reviews will include

<l" checks for overly restrictive requi rements.

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i IV. Areas of Weakness and Corrective Action; Good Practices Finding # CC.6-1 Certain trend analyses have not been performed as required in the three months that followed change of responsibility for such trends from QA to

- Construction.

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- Corrective Action Plan The Construction Department will review QA Procedure A-1. The procedure

( will be revised to ensure changes in departmental responsibilities are communicated and implemented promptly. The revision will be completed

., by January 31, 1983 L

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INPO PERFORMANCE EVALUATION l RESPONSE SHEET CONSTRUCTION PROJECT CATAWBA NUCLEAR ST.

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Performance . Area Construction Corrective Action Evaluator (s)

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IV. Areas of Weakness and Corrective Action; Good Practices Finding # CC.6-2

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No program requirements exist for trend analyses of surveillance i~ and inspection documents other than R-2A Inspection Discrepancy Reports.

Corrective Action Plan Managemen t recognizes the importance of identifying adverse trends and implementing timely corrective action. Construction has designated

-p a supervisor responsible for trend analyses. Management will determine items to be trended by February 1, 1983 Procedures for trending these items will be developed and implemented by April 1,1983

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT INP0 RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Construction Corrective Action D 'm Freeze

- Eva16ator(s)

I IV. Areas of Weakness and Corrective Action; Good Practices Id- Finding # CC.6-3

'I Replies to deficiencies do not always address all areas of concern regarding such deficiencies. Technical resolutions arc addressed; however, procedural violations and safety implications sometimes are not addressed.

Corrective Action Plan

. Deficiencies involving procedural and safety implication must be I reported as Non-Conforming items (NCI's). Presently, all Catawba NCl's are reviewed by an offsite evaluation team. Items that warrant further investigation are returned to the site. This is an ongoing e f fo r t .

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- IV. Areas of Weakness and Corrective Action; Good Practices '

4 i Finding # CC.7-2

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'L lilegible unique numbers on some electrical lug crimping tools were noted in the electrical area.

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I Corrective Action Plan

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Quality Control inspects lug-crimping tools on a random basis. Tools

(' needing repair or calibration are documented for corrective action.

These tools are identified by the company number of the employee that has been assigned the particular tool. When the number has been in

, question, it has been easy to trace the tool to the employee to which it 1

has been assigned. '

L By November 1, 1982, all responsible employees will be instructed to p monitor tool identification numbers to make sure they are legible.

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,- RESPONSE SkED CATAWBA NUCLEAR ST.

Performance Area industrial Safety .'

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IV. AreasbfWeaknessandCorrectiveAction;GoodPractices f Finding # ps 1 _ '

Managers an:1 sepervisors do not elways enforce adherence to plant safety procedures. A number of areas were noted where personnel did not adhere to established safety procedures.

Corrective Action Plan The individual items identified have been reviewed and appropriate corrective action initiated on each observation. In order to assure that Managers and Supervisors promote and enforce adherence to safety criteria and procedures, we initiated in September 1082, a Management training series. This ongoing series concentrates on criteria, supervisor responsibility, constant involvement, and the consequences of violations.

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r INPO PERFOR!iANCE EVALUATION i RESPONSE SHEET CONSTRUCTION PROJECT CATAWBA NUCLEAR ST.

E Performance Afea Project Planning Evaluator (s) B Rice IV. Areas of Weakness and Cnrrective Action: Good Practices Finding _#, t s.2-1 ,

Input into schedule and planning from Quality Assurance and Control did not appear to be covered in sufficient detall compared with other o activities.

, Corrective Action Plan 1 .

L On August 20, 1982, G W Grier, Corporate QA Manager, formally requested by letter to R L Dick, Vice President, Construction, that planning of QA p activities be conducted by the Catawba Construction Planning Organization.

In response, planners have been assigned to QA/QC planning for Units 1 and

2. These planners are beginning to provide long-range QA/QC plans, covering

. work schedules and staffing needs. Quality Assurance has assigned an ex-pediter to work with these planners. The expediter is responsible for communicating short-range schedules and changes in priority to QA management.

D I .

137

P INPO PERFORMANCE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area System Testing (includes All Test Areas TC-1 thru TC-5)

Eval $ator(s) H N Sawver, G Robinson I V. Areas of Weakness and Corrective Action: Gcod Practices Findinc # TC-1 thru TC-5 '

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TC-1-1 There is no clear policy document from management that defines the System

- Group or the organization's mission and responsibilities for testing systems.

TC-1-2 The controlling Quality Assurance and design documents do not contain all of the information required and used to perform system tests.

TC-1-3 There is no program for identifying and tracking discrepancies in test L. documents to cause appropriate resolutions or corrections in a timely manner.

TC-2-1 The Systems Group functional organizational relationships to interfacing organizations are not clearly defined.

TC-2-2 The key management, supervisory, and professional positions and responsibilities are not described in writing.

TC-2-3 The personnel who are assigned to perform testing do not meet the experience and qualification requirements in all aspects.

TC-3-1 There are no indications that a growing amount of rework after systems are turned over to the test group could adversely affect the scheduled system completion dates.

TC-4-1 Not all items that identify construction deficiencies or items that could have an effect on maintenance are identified.

TC-4-2 Although turnover procedures identify responsibilities of various organization, not all groups adhere to thei r responsibilities.

TC-5-1 Appropriate preparation of construction testing teams prior to conducting tests is not always being accomplished.

TC-5-2 Technical data, inspection criteria, documentation handling, and pro-cedure review criteria are .being obtained from uncontrolled documents and verbal instructions.

Corrective Action Plan 1

An in-depth review of practices and policics in the system testing area will be performed. An action plar. to identify and address weaknesses will be developed by March 1, 1983 Meanwhile, test personnel have been di rected to comply with established procedures and to pay close attention to details.

6 t

130

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'" i PERFORMANCE EVALUATION CONSTRUCTION PROJECT INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

s-

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r Performance Area Training Management support Evaluator (s) A R Hollins

.f IV. Areas of Weakness and Corrective Action; Good Practices Finding # TN.1-1 Management has shown its support by performing a "needs analysis" to determine ,

- the direction that training should follow and has hired an outside consultant to determine training organization needs.

Corrective Action Plan An outside consultant was hired to determine training needs and develop an organizational structure for the training area. In addition, an "in-house" needs analysis was conducted to further define and detere.ine the direction that training should follow.

implementation of recommendations made in the studies is scheduled to begin January 1, 1983 s

11 139

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PERFORfiANCE EVALUATION CONSTRUCTION PROJECT INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

I i

Perfomance Area Traininn ornanization_anif#inis t rat inn A R Hollins Eva15ator(s) ..

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- IV. Areas of Weakness and Corrective Action: Good Practieel Finding # TN-2-1 1

Some managers in the Construction area appeared not to understand the ,

- responsibilities of the training organization. Confusion as to who is responsible for the development of the employees and who determines the employees' need for training was evident.

I Corrective Action Plan Responsibility for training will be clearly identified to management.

Implementation is scheduled to begin January 1, 1983 r

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Training Organization and Administration Perforsance Area

{- A R Hollins

. Eva16ator(s) i' IV. Areas of Weakness _and Corrective Action; Good Practices

'- Finding # TN.2-2 No active program could be identified to acquire feedback to determine the effect on product i vity or quality brought about by training.

Corrective Action Plan The ef fects of training on quality and productivity is very difficult to

-I me as u re . One responsibility of the new training organization will be

- to evaluate the effects of training. This will begin in January, 1983 O

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I QUALITY ASSURANCE l e

Performance Area Reviewed Finding #

Material Control (CC-3) CC.3-4 Control of Construction (CC-4) CC.4-2

-Processes

[ ' Construction quality inspections (CC-5) CC.5-1 TC.5-2 f tc.5-3

[, CC.5-4 n Test Equipment Control (CC-7) CC.7-1 Quality Program (QP-1) QP.1-1

'j' Independent Assessment (QP-3) QP.3-1

[. QP.3-2 QP.3-3 5 Corrective Actions (QP-4) QP.4-1 QP.4-2 4

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PERFORMANCE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAW3A NUCLEAR ST.

Performance Area Material Control Evaluator (s) S Sheppard _ . - . .

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y IV. ' Areas of Weakness and Corrective Action: Good Practices Finding # CC.3-4 Procedure QFP-8.002 CNS, Rev. lA, does not Indicate the disposition of unused filler material. Confusion appears to exist regarding handling

' of unused filler material and adherence to AUS code requirements could not be determined.

=

e Corrective Action Plan s

Procecure applies to Sahnson fliier metal issue station and does not apply to Bahnson field welders. Procedure does not cover the handling of filler material after being returned to Bahnson issue station after exoosure. The steps not covered are segregation of filler material and the return to Duke for rebake. However, thi s i s bei ng done properly.

The orocedure is to be revised to include the segregation and return of unused filler metal to Duke Power for rebake. This procedure is to be completed and implemented prior to November 21, 1082. With this orocedure

- change and adequate instruction of personnel, it should eliminate any confusion concerning adherence to AWS Code requirements in this area.

PERFORMANCE EVALUATION CONSTRUCTION PROJECT INP0

- RESPONSE SHEET CATAWBA NUCLEAR ST.

Control of Construction Processes

~

Performance Area .

Evaluator (s) T F Wyke, H S Sheppard IV. Areas of Weakness and Corrective Action; Good Practices Finding 1 CC.4-2 r

Weckr.csses were observed in control of liVAC contractor's welding program. Several instances were noted where contractor personnel were not familiar with program requirements.

n Corrective Action Plan A meeting was held on 10/28/82 between Bahnson management and Duke QA to determine the best method of transmitting the weld procedure assign-ment (in writing) to the welder. Alternate methods of making the weld

- procedure assignments were discussed at. great lengths. Bahnson is making a study to ascertain the most efficient method that would be acceptable to Duke Power Company. The new method will be determined, reviewed by Duke QA and implemented prior to December 15, 1982.

p 144

b- PERFORMANCE EVALUATION CONSTRUCTION PROJECT INP0 CATAWBA NUCLEAP, ST.

RESPONSE SHEET

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Performance Area Construction quality inspections

. . Evaluator (s) D L Freeze IV. Areas of Weakness and Corrective Action: Good Practices Finding # CC.5-1 inspection procedures are not always clear ir. their definition of inspection requirements, resulting in installed items being accepted

. when requirements have not been met and vice versa.

Corrective Action Plan A procedures group has been established and will be reviewing and correcting any unclear situations identified. All the items observed will be corrected. The QA procedure for installation and inspection-of concrete anchors will be revised to define " Full Thread Engagement".

Site QC personnel will be instructed on Construction Procedure 601.

These corrective actions will be completed by January, 1983 e

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f f INP0 PERFORfiANCE E'/ALUATION CONSTRUCTION PROJECT

- RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Construction Quality Inspections CC-5 Evaluator (s) D L Freeze IV, Areas of Weakness and Corrective Action;_ Good Practices, Finding y CC.5-2 4nspection documents are sometime, completed in an illegible manner making any required fucure follow-up difficult if not impossible.

Corrective Action Plan For comparison purposes, we will have on file an example of each inspector's signature and initials with the name printed beside them. In addition, all inspectors will be reminded of the importance of a legible signature or initial on documents. These actions to be completed by 1 Dec. 82.

146

'I PERFORfWlCE EVALUATION CONSTRUCTION PROJECT

- INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Construction Quality Inspections ,

Evaluator (s) D L Freeze IV. Arcas of_ Weakness and Corrective Action; Good Practices Findina i CC.543 Im;pection requirements otablished by HVAC contractor ds not verify that Code recuirements are met.

c Corrective Action Plan A review with Bahnson personnel confirmed that the sign offs on the weld procedures constituted verification that the procedure meets the require-ments of AWS D-1.1. A letter is forthcoming to verify this.

Based upon this audit, questions have been raised as to the compliance of Bahnson Weld Inspection Procedure, QCI-9.001 CNS, to the AWS Code Dl.1 as it relates to undercut.

When Bahnson procedure QCI-9.001 CNS was formulated, a conversation was held between Bahnson and Duke's Catawba Analysis and Support Restraints section concerning the 1/32" undercut being in compliance with the Code.

Duke's support restraint section felt that the 1/32" undercut was acceptable due to the loading on these welds but this was not documented or followed up by a letter.

I Duke Design Analysis Section has stated that concern for undercut is b primarily related to fatigue considerations. The requirement for less allowable undercut when its direction is transverse to primary tensile stress is specifically aimed at high stress fatigue considerations.

Fatigue is not a concern in HVAC duct support systems and stresses for all loading conditions other than seismic are relatively low. For this reason the criteria used by Bahnson is considered acceptable.

Duke Specification CNS 1211.00-05 will be revised stating that fatigue is not a concern for HVAC duct support systems and stresses for all loading conditions other than seismic are relatively low; therefore undercut up to 1/32 inch is acceptable regardless of direction of primary tensile stress.

This revision will be completed by Feburary 1, 1983.

147

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f INP0 PERFORIM!!CE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAWBA flUCLEAR ST.

Performance rea Construction Quality Assurance Evaluator (s) D 1. Freeze _

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'IV. A,_reas of Weakness and Corrective Action; Goed Practices Finding # CC.5-4

m QC inspectors sometimes perform producticn fonctions.

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Corrective Action Plan This finding is based on observation of an inspector tightening a loose nut on a concrete expansion anchor. While this did occur we do not feel, based on interviews with individua~. inspectors, that this is a comon practice; however, all inspectors who inspect torque on concrete expansion anchors will be cautioned to report obviously loose nuts on appropriate process control documents (R-2A, M-51C, etc.). This action will be completed by November 15, 1982.

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PERFORitANCE EVALUATION CONSTRUCTION PROJE'CT INPO RESPONSE SHEET CATAWSA NUCLEAR ST.

s l Test Equipment Control Performance Area C F York Evaluator (s) t f

IV. Arcas of Weakness and Corrective Action; Good Practices g.

Finding # CC.7-1 Supervisors in the Quality Control organization do not always enforce adherence to required Quality Assurance or Construction Procedures.

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I Corrective Action Plan The factual information provided represents a minor violation of Procedure requirements although no work was done using the M&TE items in question and the intent of the procedure was met. A nonconforming item, NCl 15749, has been originated,' calibration stickers removed where applicable and'the damaged sieve destroyed. Supervisor will be cautioned to adhere to procedures in future. This action will be completed by Nov 15, 1982.

149

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1 PERFORMANCE EVALUATION CONSTRUCTION PROJECT IN 0 i- RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Ouality Procrams Evaluator (s) P Schrandt

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IV. Areas of Weakness and Corrective Action: Good Practices Findir.g # QP.1-1 Contracted vendor QA and QC prngram audits are not being performed in

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sufficient depth to ensure program effectiveness. Several weaknesses exist in the welding program of the HVAC contractor.

t Corrective Action Plan Plans are to review Bahnson audits and Duke Vendor surveillance reports for sufficient depth.

Depending on our findings, surveillance will be expanded in order to further assure that Bahnson's QA Program is functioning properly. The review and first surveillance is to be completed by December 15, 1932.

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• RESPONSE SHEET CATAWBA NUCLEAR ST.

Independent Assessments Perforrence Area

- D Franks, G Robinson, P Schrandt Evaluator (s) ,

IV.-AreasofWeaknessandCorrectiveAction;GoodPfacticts Findinc s- QP 3-1 independent assessments of some quality related activities have not been performed by the QA Department at Catawba for the last two years. Lack of independent assessments were noted for two special processes.

c.

5 Corrective Action Plan

[ The Surveillance Checklists at Catawba will be reviewed and revised as necessary to assure that significant activities are adequately covered. This review and the necessary revisions will be completed by 2-15-83. Surveillance will be performed in the two areas noted by 3-1-83 Note that an independent assessment

[. of one of the processess was performed by the NRC Resident inspector in August 1982. No deficiencies were noted.

(.-

_ An evaluation by the Audit Division to assure all quality-related activities were either assessed or planned to be assessed before the end of 1982 was ongoing during the INPO evaluation. As a' result of our efforts, the two special processes noted in Finding QP3-1, along with others, were identified as needing action; and plans have been made to complete this action. The two specific areas of QP3-1 are to be addressed during an audit beginning 10/25/82. The other areas will be addressed in subsequent audits.

The evaluation for assuring coverage of quality-related activities will be incorporated into our Audit Planning System.

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e- PERFORf',A"CE EVALUATION CONSTRUCTION PROJECT INPO RESPONSE bhEET CATAWBA NUCLEAR ST.

Performance Area independent Assessments D Franks, G Robinson, P Schrandt Evaluator (s)

IV. Areas of Weakness and Corrective Action; Good PPactices Finding n Q P 3-2 Tne surveillance program does net always assure a comprehensive assessment of addressed areas. An area was r.oted where an audit found several deficiencies but surveillance perforred in the same area had not been effective in identifying problems.

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l Corrective Action Plan The position of Surveillance Supervisor was established at Catawba on September 1, 1982. The Surveillance Supervisor is reviewing surveillance activity to 'N assure that it is effective. The area noted by this finding Sad been recognized as needing attention and surveillance had been planned. The planned, comprehensive surveillance was performed October 11-15, 1982.

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E PERFORMANCE. EVALUATION CONSTRUCTION PROJECT INPO RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Independent Assessments D Franks, G Fobinson, P Schrandt Evaluator (s)

IV. Areas of Weakness and Corrective Action; Good Practices Findino # QP 3-3 l

- Surve!!!anco personne! do not adequately pursue full completirn of assigned checklists in some cases. An area was noted where a checklist item had not been performed for 13 months when activity in the area has been regular.

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1$ Corrective Action Plan The Surveillance Supervisor reviews all surveillances conducted. Effective

- immediately his review will include an evaluation of any checklist item not performed to determine the validity of the reason for not performing _

the item. If his evaluation Indicates an invalid reason he will have the item scheduled and completed. Surveillance on the item noted as deficient will be completed by 3-15-83 l

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INPO PERFOR"ANCE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAaTA NUCLEAR ST.

Performance Area Corrective Action D Franks, P Schrandt, G Robinson Evaluator (s)

F IV. AreasJof Weakness and Corrective Action; Good Practices Finding , QP 4-1 In some cases, QA approvais of inspection discrepancies (Form R-2A) was not sufficiently critical. Cases were noted where QA had approved R-2A Forms where the statement of required action dId not ad:iress the root causes and whers corrective action had not yet ocen taken.

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J Corrective Action Plan Procedure R-2 which governs the Initiation and resolution of R-2As is presently under revision to clarify the initiation and resolution of inspection discre-pancies (Form R-2A). This revision will address the review of the R-2A by QA prior to QA approval. This revision will be completed by 1-1-83 1

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I INP0 PERFORMANCE EVALUATION CONSTRUCTION PROJECT RESPONSE SHEET CATAWBA NUCLEAR ST.

Performance Area Corrective Action Evaluator (s) D Franks, P Schrandt, G Robinson IV. Areas of Veakness and Corrective Action;* Good Practices Finding # QP.4-2 Sove conditions adverse to quality found during inspection are reported in a manner that is not subjected to trend analysis. As p a result, related generic probler,is are not addressed; and basic causes of degraded quality are not evaluated.

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L Corrective Action Plan We agree with the finding. Quality Assurance Procedure M-51 will be

, revised to require the trending of the M-51C fcrms by the Construction Department. This revision will be -completed by January, 1983 1

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{ l APPENDIX A v

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I-OBSERVATION SHEETS t

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. OBSERVATION OF

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SYSTEM WALK-DOWN 1

1. Scoce Observed a partial walk-down of System NI.

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ll. Observations

.A. The information supplied the inspector appeared to be well-organized.

B. The Inspector signed the walk-downs acceptable on the drawings q prior to doing the work. ,

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C. Valves IN1328, IN1329 and IN1330 were welded up on one side and left uncapped on the other. The inspector stated that was out of his area of responsibility. No corrective action was taken.

F lli. Conc!usiens A. Inspections may be signed off before they are performed.

B. Protective covers on valves are not always being maintained.

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. - CBSERVATION

' 0F COSMETIC CONCRETE REPAIR f

- 1. Scooe Observed two Concrete Finisher!.. and one QC Inspector performing cosmetic

~ concrete repair of spalled concrete around a 12" pipe penetrating the cencrete containment wall--Unit 1 Reactor Building. The repair was on the outside facs af the wall at Elevation 560 in the Auxiliary Building l ,,,

penetration room area.

P

11. Observations

. A. The repair area had been previously cleaned of all loose particles.

The workers did clean area of any loose dust, etc, with compressed g-j.

air before beginning work.

F B. The inspector measured depth of spalling and assured the repair I

area met requirements for cosmetic repair.

C. The repair material, Sikatop 123, was already mixed. The o.C inspector said they had mixed one' complete bag since-several large areas were going to be repaired.

The workers applied the components properly and blended the repair D.

with the originally-placed concrete such that a smooth interface resulted.

E. The QC Inspector observed the work in progress. He had a current copy of CP-430 in his possession which addressed cosmetic repair.

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He also had a release log of Sikatop materials approved by QA 9-24-82, Revision 33, Document Number 337 1F .

In the area was a fire extinguisher which had been inspected 9-8-82.

ISC

G. Two workers near the area were on an unguarded platform greater than 20 feet above the floor drilling and installing expansion anchors. One worker was tied off by safety lanyard; the other was not.

Ill. Conclusions

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A. Some craft personnel tend to ignore safety practices.

f B. Cosmetic concrete repairs are being perfcrmed and inspected in accordance with proper procedures.

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OBSERVATION OF CONCRETE OPERATION

l. Secpe Observed the batching, sampling, testing and placing operations for concrete assigned to Pour No. 4960 in the No. 2 Reactor Building from 8:45 am till 12:15 pm on 10-1-82.

II. Observations

' A. One Level I civil-structural inspector and one operator were present at the batch plant.

- B. The first truck load (4 c.y.) was batched out--had the required y

mix-actual weights on a printed-out ticket, signed by the inspector releasing the truck for delivery. This load of concrete was rejected because of unacceptable amount of Melment was added to the concrete.

C. Reviewed records on storage of material--Form P-3C, Revision 1, dated 6-12-80, inspection of Stored Material and Equipment. Aggregate and admixtures met the level and storage conditions required. It was signed by Level I structural inspector and dated 10-1-82.

D. The second truck load (4 c.y.) was batched out--meeting all require-ments of Procedure M-2. This load of concrete was rejected--exceeded slump before addition of Melment, even though the batched out water was 858 pounds, and the maximum Design called for was 960 pounds.

Note: There was a long telephone conversation between the plant 2

Inspector and his supervisor about the amount of water and Melment to be batched out on the second load.

E. The third truck load (4 c.y.) was batched out--met all requirements of the procedure. This load was accepted before and after the addition of Melment.

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w F. It was noted during tha slump test measurcment that tha h:ndio attached to baseplate had a 1/4" movement in the vertical direction.

This device is not under the calibration program. Remaining slump tests were performed by the inverted cone method. Both methods are accehtable.

G. A QA technician was performing a surveillance of this concrete pour.

These are required quarterly. No problems were noted.

P H. First concrete reached the form at approximately 10:45 am. At the form were four utility personnel and their supervisor to place the

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concrete, two builders and their supervisor to monitor the form, one crane flagman and one QC inspector to monitor the placing of the concrete.

The concrete was being transported in a two cubic yard bucket. A

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tremie chute was used to drop concrete to bottom of form.

The Melment admixture caused the concrete to flow readily. Good J.

vibration of the concrete in the form was performed.

K. Placing of the concrete progressed well. No clogging of tremie chute occurred.

L. The two crafts were assisting each other when the need arose indicating good cooperation.

M. Good safety practices were observed. Safety belts and lanyards were being used where needed.

N. The approach path of the concrete to the form traveled over the refueling canal. The canal had been covered with polyethylene to protect against dripping concrete laitance.

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lit. Conclusion te personnel are not properly trained in the use of the additive, Melment to the concrete mix.

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OBSERVATION ,

0F f MATERIAL CONTROL l f _ t

l. Scope Review warehouse and storeyard storage activities relating to electrical equipment.

- II. Observation A. Identification of material and equipment, both safety and non-safety, within warehouses was by paper stick-on tag with non-permanent adhes *ve. Tags on numerous items were either loose -

or had fallen off. Varehouseman stated there was no standard procedure for tagging or identifying equipment in the warehouse.

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' B. A non-safety transformer that was damaged was stored in middle of the aisle without any identification tag. The warehouseman was able to find the receiving paper by leafing through the record book. There was no damage notation on record. .

C. Safety and ncn-safety equipment was stored together. There is potential for issuing wrong equipment.

D. Access to warehouse is not secure from adjacent termination fabrication shop. Material on second and third shelves on

- bin separating the shop and warehouse is directly accessible to shop personnel.

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E. Access to warehouse is not secure from adjacent maintenance office area. Double doors were unlocked and open allowing

! direct access to storage areas.

F. Warehouseman responsible for receiving equipment in one warehouse stated he did not know of any procedures relating to his work.

l Quality Assurance Procedures P-1 and P-2 are directly applicable I

to receiving and storage activities.

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f~ G. Same warehouseman Indicated he had been in,his job three years and had not received any formal training in that Job. Absence i.. of knowledge of procedures indicates need for training.

_ H.

Cable reels were stored.In storage yard with cable ends open and unprotected. Open cable ends allow moisture to enter causing cable deterioration and possible failure in service.

f I. Spare generator circuit breaker stored in yard had its control cabinet open where parts had been robbed. Olsconnected tubing connections and loose parts were, therefore, exposed to the open f envirorment. This indicated lack of storage control, maintenance and surveillance and could lead to deterioration of equipment.

L.

J. Virehouse supervisor indicated he needed training and informa-tion on handling hazardous materials.

111. Conclusions A. The procedures for storage of material are not always followed.

i S. Procedures for identification of equipment in storage are ".ot available.

C. Knowledge of storage procedures appear to be lacking.

D. Training of personnel does not appear adequate. f

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E. Procedures for identification of damaged equipment within the' warehouse do not appear te exist.

Control of access to warehouse app. ears to be weak.

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E OBSERVATION OF HVAC SUPPORT INSTALLATION

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1. Scoce An observation was made of Bahnson Service Company's Installation of duct supports and plenum work in the Unit 2 Auxiliary Building.

Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> were spent on this observation, ll. Observations A. Viewed Support 2-H-VC-4999 There appeared to be excessive undercut on some of the welds.

B. Looked at a plenum that was shown on Drawing CN-1684-VA-000H, I Rev 0. This drawing had two sheets. There were differences between the drawing and what was erected.

Reviewed Design Change Request A-0073N523, Rev 15, which had 20 pages of revised details attached. Due to the volume of changes, the required configuration was difficult to understand.

DCR Procedure QFP3.004CHS, Rev 2, does not specify a time frame to incorporate changes. No apparent discrepancies between the assembly and the drawing as modified by the DCR were found.

C. The " process control" package for this plenum contained only ttie I drawing and the DCR. The Senior QA Engineer indicated that it should contain a sheet specifying the welding procedure, although there is no written requirement.

D. When asked how the welder knew what welding procedure to use on the plenum, the supervisor said that the welder walks up and either knows what procedure to use, or he doesn't. If he knows what to use, he uses it. If he doesn't know, he asks his supervisor.

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l E. Each support package has a Sheet BSC-62-81, Rev 1, in it. This sheet lists all procedures qualified for Catawba. Each welding procedure on the list has such things as base material type, base material thickness, welding process, joint type, etc shown. The welder (s) selects the welding procedure (s) to be used. After the l support is completed, the supervisor checks off on the sheet the welding procedure (s) that was used.

t F. The welders did not stencil their work. The HVAC contractor's I procedure requires that work be stenciled in those areas designated by the Project Welding Supervisor. No areas have been designated.

There is no Code requirement (AWS D1.1) to stencil welds. Either

[ the supervisor or the welder (s) list the welder (s) on "Ductwork Hanger Log Sheet." This log sheet is kept by the supervisor. The supervisor indicated that the log sheet, even though it is a part of a formal procedure, is not a permanent QC/QA record, and he has never turned any in to the office. This log sheet is required by Procedure AFP-CNS 5.003, Rev 1. The procedure does not indicate the disposition of the log, and the Senior QA Engineer confirmei that it was not a part of the permanent record. He also confirmed that there is no permanent record showing which welders or procedures were used on a support.

G. The supervisor indicated that QC checked each welder's " rods" about once each week. The Senior QA Engineer said that filler material was checked on a surveillance basis, and there is no written requirement. There is a form (QC/QA 116, Rev 1) used to document the inspection.

H. Procedure QCl 9.001 CNS, Rev 0, (Visual Inspection of Welds) was reviewed and determined that this procedure allows 1/32" undercut on material greater than 5/32" thick. This does not meet the AWS 01.1 Code requirement.

1. The QC inspector's copy of QCl-10.002 CNS, Rev 0, (Seismic Hanger installation) was reviewed, and no apparent problems were found.

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[ J. The QC inspector was asked that since the welders don't mark their work and the welding procedure is not specified or recorded by l l'ndividual welds, how did he know that the proper procedure was used on the weld and that the welder making that weld was f qualified. He indicated that it was not a problem, that he just knew. The Senior QA Engineer indicated that this inspection was done on a surveillance basis.

K. Procedure CNS-007, Rev 0, (Welder Qualification Log) was reviewed.

This procedure is designed to meet the 90-day requalification require-n%nt of ASME IX and appeared adequate.

L. A log is published monthly to show which welders are qualified As on which procedures. This log is not a controlled document.

this log is not controlled, it is used to assign qualified welders to production welds and is subject to change; the distinct possibility f exists to assign an unqualified welder to a job.

I lil. Conclusions A. Welding procedures and welders are qualified, but the program to control thei r use in the field needs modification.

B. There are necessary functions that need to be performed; and these functions are being performed, but are not formalized in a procedure.

C. Procedures need to be reviewed for technical adequacy (i .e. , do they meet the Code 7).

I D. Training should be performed so that welders know to which procedures they are working and where to find the requi rements.

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I f 1 OBSERVATION ,

0F BASEPLATE GROUTING

l. Scoce f Conducted a brief review of quality and,non quality baseplate grouting.

II. Ob._ vations A. The first two plates were quality related, and quality control was present.

B. The mixing water was measured by a painted line on the inside of a I bucket.

C. The grout was Gifford-Hill Supreme, a non-shrink grout, of which a full sack was used in each batch.

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D. An electric hand mixer was timed for 5 minutes. (The mixing time required was 4 to 5 minutes).

E. The inspector took the mixed grout temperature and recorded 78 F.

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F. The area to be grouted had been wet and covered in burlap.

l t G. The area was inspected and released for grouting by the inspector.

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t H. The grout was placed from one corner, and the entrapped air was removed.

I. The placed grout was dressed, and the crew moved on to the second baseplate.

J. The last two baseplates were non-quality.

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K. The difference between quality and non quality grouting was the inspection; craft action was the same.

Ill. Conclusion f The baseplate grouting operation for both quality and non-quality activities is meeting the program established and the effected performance objectives.

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T OBSERVATION 1 0F

- HANGER INSPECTION f 1. Scoce Observed the final QC inspection of Hangers 1-R-FW-87 and 2-A-YC-3163 T II. Observations A. The hanger document packages had all the required Information needed

[ to perfor,m the final inspection, including applicable variation notices, nonconforming item reports, supplementing typical drawings,

- and baseplate epoxy report.

B. The inspector cited correctly the applicable procedure as M-51.

C. The inspector verifed that he had the correct drawing revisions by comparing them wi th those identifled on Form M-518.

L 0. The inspector verified all the dimensions shown on the hanger sketches and the correct material and size. The inspector was I generally familiar with allowed tolerances but sometimes checked with a QA process control technician (our escort) for specifics.

For example, on Hanger 2-A-YC-3163, the inspector did not recall "the latest thing they told us" on the tolerances for the "W" and "C-C" dimens ions. The QA technician provided the information, and the inspector stated that anything in doubt would be verified correct

. by checking the procedure, specification, or information from his supervisor.

1 1 E. Sufficient thread engagement was questionable on one of the nuts on Hanger 1-R-FW-87 The inspector stated that he could barely E get a fingernail in part of a thread, so it wat ok. He stated that no one said you had to be able to feel a thread the entire circum-ference of the anchor bolt. CP-115, Section 1F, ststes, "the anchor il 1

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to be torqued has at least a full nut engagement after torquing."

Subsequent evaluation by the QA hanger group determined that the engagement was marginal but acceptable.

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.3 F. While attempting to verify that the welds were in the correct posi tion on Hange r 1-R-FW-87, the inspector became confused wi th the weld symbols on the hanger sketch and stated, "I don't know.

I'm not much of a weld inspector." He stated that the only reason they verified weld locations was to be sure that bench fabricated f hangers were installed in the correct orientation. The inspector and the QA technician (escort) subsequently agreed that the welds were in the correct locations. Further checking with the QA hanger group verified the welds were positioned correctly.

Bearing surfaces of expansion anchor washer surfaces were visually G.

inspected.

H. The inspector veri fied minimum torque on Hanger 2- A-YC-3163 anchor nuts. He stated that torquing was not checked at installation but at final inspection. This agrees with Procedure M-52.

L 1. Torque was checked at 20 ft-lb with a torque wrench set correctly with an attached sticker indicating calibration was current. The QA hanger group verified that this was the correct torque.

2. The torque inspection resulted in three of four plate nuts tightening further during inspection, torque being applied at minimum torque (20 ft-lb). One of these three moved significantly (more than 1/2 turn).

s 3 The inspector tightened all the loose nuts to minimum torque while explaining that when they found loose nuts, they were instructed to stop, allowing the craft to correct the discrepancy.

He further stated that he believed it was the common practice for I the inspector to go ahead and tighten the nuts. )

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4. When asked how he knew how much torque to apply, the inspector d stated that he did this so much that he Just knew (the "12" in the expansion anchor identification HH1240 identified the amount of J torque). Subsequent checking with the QA h..nger group verified that 20 ft-lb was the correct torque.

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~# The welds on item 3 (plate) of 2-A-YC-3163 were incorrectly positioned.

l j d The inspector noted this and noted the discrepancy on Form M-51C for Correction.

t J. Several of the tolerances which the inspector cited without consulting the procedure were recorded and later verified with the QA hanger group.

Ill. Conclusions inspectors sometimes perform torquing on expansion anchor nuts which are found insufficiently torqued at the time of inspection rather than having the craf t correct the discrepancy for subsequent reinspection.

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OBSERVATION 0F CONCRETE EXPANSION ANCHOR INSTALLATION

1. Scoce f Observed two powerhouse mechanics (hangers) installing two sleeve-type concrete expansion anchors in Unit 1 Auxiliary Building Penetration Room at Elevation 577 The general foreman and foreman for this area were present during the observation. Approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was used for

{ observation.

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11. Observations The A. The initial anchor instaliation to be observed did not occur.

The hanger could not be installed to meet Design requirements.

problem was communicated to the Hanger Construction Engineering 9roup. The hanger had previously been pre-checked and ok'd for installation.

B. The next anchor installation was for a two-anchor plate to be mounted to the ceiling. The plate had a strut attached to it.

C. The workers had located the anchors per the hanger sketch t: sing the piping as the reference. _

1 i D. Due to small size and spacing of these anchors, no ultrasonic check for embedded rebar was deemed necessary.

The holes were drilled to an approximate depth of 3 1/h" inches.

l E.

The workers used the length of the drill bit to gage the depth and did not measure. Minimum depth required was 2".

II F. With the holes in an overhead position, no specific action was taken to clean the holes.

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l G. Anchors were installed by threading nut onto bolt and tapping on nut with a hammer to set the anchor into the drilled hole.

H. ' Nuts were tightened snug against plate. QC inspector was not present. Calibrated torquing will be done when the QC Inspector is present for documentation.

I. While in the area, an anchor hanger was observed. This particular hanger was installed as a QA-2 hanger which did not require visual welding inspection. The hanger has been re-classified as a QA-4 hanger which requires visual weld inspection; however, some of the welds are now inaccessible. The workers did not know whether or not the hanger could be accepted as installed or if the hanger would have to be removed and re-installed.

[ Checked records and verified the two workers were trained to J.

install anchors.

K. Returned to area later and installation had been completed.

Epoxy had been applied, and anchors torqued. Wrench used to torque was identified as CA-160. Follow-up with QA/QC showed the wrench to be currently in its calibration.

l. Area where expansion anchors were being installed was extremely L.

congested with piping, valves and other hangers and restraints.

The congestion appears to make quality installation difficult to do.

l ii1. Conclusions l

A. Workers and supervisors installing concrete expansion anchors l are trained and knowledgeable of installation requirements.

1 Areas where hangers are being installed are extremely congested, lI B.

making quality installations difficult.

C. Changing Design criteria provides potential for extensive craft rework.

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g OBSERVATION OF PRESSURE TEST

l. Scoce Observed a pressure test performed for shutdown 2018 7626. (RN f System 100 + feet of 3" pipe.)

11. Observations A. The N-1A (hydro test form) listed the section low point as Elevation 578. The actual low point was approximately 602.

The N-1A was not corrected.

B. The N-1A indicated a relief valve set to 234-236 psig was required. The relief valve supplied by the test director was f set at 238 psig. The maximum test pressure was 233 psig.

C. The QC inspector pointed out to the test director that he had marked minimum test pressure as not applicable. The minimum test pressure was then calculated by the director to be 219.8 psig, and the form corrected.

D. The temporary hos'es being used to supply water to the system were leaking. The water was soaking a carton of filters identified as " AHU-3 1131-CNS." This was pointed out to the test director, but the si tuation was not corrected.

l E. Water from the hose leak was also running through an air duct sleeve to the elevation below creating a slick floor. During l the observation two different people came to the test director to complain. A utility person was stationed on the floor below to clean up the water.

The hose connection was tightened to slow l

> down the leak.

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l F. The test director left the test area to have the relief valve reset to 232 psig, and the range corrected on the N-1A. Two craft personnel and two inspectors waited in the area for him f -to return. The wait was approximately 20 to 25 minutes.

G. Further checking concerning proper system low point revealed direction had been given the systems people in a letter dated 12-14-78. The letter stated the provisions would be added to the specification. Nothing could be located in the spec by this observer, nor by the systems engineer.

Ill. Conclusions A. Appropriate preparation for testing operations is not being performed prior to going to the field.

B. Direction is being taken from Design in letters which are not controlled.

C. Appropriate attention is not being given to stored materials and surrounding areas affected by leaking water.

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f REVIEW 0F 1

PREVENTIVE MAINTENANCE PROGRAM

1. Scoce I Reviewed the program for identification and performance of preventive maintenance during the construction process. The preventive maintenance program (PM) is implemented by Procedure P-3, and PM tasks and frequencies are identified by the Construction Engineering group on Form P-3A. Forms P-3A are initiated when a component arrives for storage and are reviewed as necessary when the component is installed.

l II. Observations A. A review of selected P-3A records maintained by QA revealed that all identified PM tasks on QA condition equipment are performed at the identified frequencies.

B. A reviewlon to P-3A # M-94 (Reactor Cavity Manipulator Bridge Crane) changed the classification from " Nuclear Safety Related" to "Non QA Condition." The QA records reflected cancellation of the PM item.

1. QA reflected the status as cancelled because inspection of the PM cctivity is not required for non-QA condition equipment; thus, QA had no responsibility to assure PM compliance once the classification was downgraded.

L 2. A check of the Safety Related Structures, Systems and Comoonents Manual confirmed a non-safety related (QA Condition 1) status.

3 Additional examination of non-QA condition records reflected that PM M-44 has been accomplished at the prescribed frequency. Checks l

of additional non-qA condition PM tasks revealed accomplishment at the specified frequencies.

C. QA records reflected that P-3A #E-125 (KC Pump Motor 1B1) was can-celled by Construction Engineering on 5-19-82.

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1. The stated reason by Construction Engineering for the cancella-tion was that once the power to the motor is terminated and the j pump is coupled, it is turned over to the Construction " Systems" group for flush and hydro, and then it is turned over in short order to the Nuclear Production Department (NPD), who assumes I

.f PM responsibility. The cancellation Form P-3B stated the reason was that the pump and motor are coupled.

2. The KC System has not been turned over to NPD, and NPD performs I no PM tasks on the equipment.

3 The Systems group runs the pumps periodically, as requested by NPD, for chemical mixing, but performs no PM tasks on the equip-ment.

4. No scheduled maintenance activities have been performed on 1B1 KC Pump Motor since cancellation of the P-3A Form.

I 5 QA reviewed the cancellation of the PM tasks. Asked why the PM was cancelled, the reviewer stated that " Construction Engi-

.g E neering determines the requirements--they can do anything they want to."

D. QA records reflected that P-3A #E-133 (Centrifugal Charging Pump 1B Motor) was cancelled by Construction Engineering on 1-9-81. Previously identified PM tasks included rotating the shaft, checking the space heaters energized, periodic resistance checks and checking the oil level.

1. The same reason as stated in C.1 above was given for cancellation.

2. The NV System has not been turned over to NPD, and NPD performs no PM tasks on the equipment.

I 3 The Systems group performs no PM tasks on the equipment.

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4. No scheduled maintenance activities have been performed on the equipment since cancellation of the P-3A Form.

5 QA reviewed the cancellation as in D.5, above.

E. The testing engineer stated that he is supposed to get copies of P-3A Forms when the systems are turned over to his group so that he can designate any PM items which are to continue. He stated that he has seen very few of the forms.

I F. The wording of CP-411, Section 4.2.4 ('Vhen a P-3A appears no longer appropriate because of T/0 to Systems...") implies preventive main-tenance ends at that point.

Ill. Conclusions Scheduled preventive maintenance activities on installed equipment does not always continue through the entire period of Construction Department control.

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I E .

OBSERVATION Q OF CONCRETE OPERATION

1. Scoce Observed the batching, sampling, testing and placing operations for concrete assigned to the steam generator enclosure wall, Pour No.

4958 in the No. 2 Reactor Building from 8 i.n till 11: 30 am on 9/28/82. A visit was made to the civil section of site construction f engineering, also.

II. Observations A. One Level I civil-structural inspector and one operator were present at the batch plant.

[

B. One truck had been loaded out before observation started.

C. Three consecutive loads were batched out--each had the required mix--actual weights on a printed-out ticket, signed by the QC inspector releasing the trucks for delivery.

D.

. Three of the four truck loads (8 c.y. per load) were rejected at the test point after the addition of Melment changed the batch-out Design mix from an allowable slump of under 4" to an unacceptable slump of more than 8".

.I E. The QC inspector was questioned about inspection and Testing, He Part 4.3 of Procedure M-2, inspection of Design Concrete.

said that a mixer performance was performed on both the batch plant mixer and on truck No. 37 Upon cl.ecking on records at the concrete lab, they showed the main batch plant mixer passed the test, but truck No. 37 failed.

I . .

180

l I F. One QC supervisor, one Level I and one Level 11 Inspector (civil-structural) were present at the discharge point (sampling and

' testing).

G. When the first truck load of concrete (8 c.y.) arrived, Melment L10-A was placed in the truck at the discharge point in accordance with the procedure (88 OZ/cy). Concreteemet the Construction procedure before Melment was added to mix (less than 4" slump, f 4-8 percent air content allowable), but failed criteria af ter Melment.was added (greater than B" slump) .

l H. QC supervisor produced Construction Procedure 461 as the control procedure for this concrete pour. CP-461 relates to repair of I- honeycomb areas. Pour No. 4958 was a first-time pour. Procedure 601 was the correct Construction procedure for this concrete peur.

I. The ladder allowing access to the area where concrete pours were being made had no cage or railing around the top portion of the ladder. The top of the ladder was 50 plus or minus feet from the ground floor of Reactor Building Unit 2.

J. Procedure 461 (a controlled document) in the civil section of i Construction Engineering had been altered by marking through parts of the typed materials. Also, additional comments had been l

! written in ink at several places in this procedure. Altered controlled documents could cause confusion when referenced by individuals in the civil section.

K. At the pour location, there were six utili ty personnel plus utility supervisor, two builders plus builder supervisor, two concrete finishers and one QC inspector during concrete placement at the form.

L. The rebar placement inside the form was somewhat irregular.

The bullaer supervisor stated that rebar previously embedded

I ial .

I was not precisely where it should have been. As a result, rebar was pulled in'to alignment to meet configuration of the form. The

- QC inspector stated this section of wall was actually better from this standpoint than some below it. A few isolated rebars were f within 1/2" of the form.

M. Drawings used by the builder supervisor to install the rebar and embedments were verified with Document Control that all were of the current revision.

N. In talking with the concrete finisher, he expressed concerns about

- productivity in grouting work being hampered by lack of paperwork to release hangers for grouting. He stated he often went into areas that looked like they had many (40 to 50) hangers ready to grout, but would only have paperwork for a few (2 to 3) . He was f concerned about inaccessibility--difficulty in transporting grout materials to areas of work. A general comment was made that there were too many people on site in the craft organization.

O. The concrete pour was scheduled to begin at 8 am. Concrete arrived at approximately 10:25. A tremic chute (elephant trunk) was used to tremie concrete to bottom of form; however, concrete backed up and chute became lodged. Af ter pulling, prying, etc j for approximately 20 minutes, the builder supervisor told the utility supervisor he would remove the forms, which he did. The

! chute was then freed. The vibration of the concrete was adequate, and the QC inspector was actively involved in visual observation that placement and vibration were adequate. The tremie chute was lodged again with the next bucket of concrete.

l P. A Rock Hill Concrete Company truck driver left his truck to watch a slump test, and he did not have side shields on his glasses.

Q. The uppermost personnel scaffold around the inside perimeter of the crane wall in Unit 2 Reactor Building is supported by cables I

i 1

102 l

. .. . ~ . . . - . . . .

I I

f rom brackets attached to the wall . Scaffolds are required to bd Inspected at regular intervals by craft foremen. An inspection tag indicated last inspection was in March 1982.

R. Two powerhouse mechanics were installing Instrumentation guide funnels to the underside of the Unit 2 reactor vessel head. They were having difficulty installing two of these funnels due to interference with the funnel and weld reinforcement on the instru-I mentation tube penetrating the head. They were waiting for the Westinghouse site representative to observe the situation and recom-mend action. No process control documentation had been generated to control the work.

Ill. Conclusions A. Site personnel are not properly trained in the use of the additive Melment to the concrete mix.

I B. Some site workers tend to disregard basic safety rules.

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.I l 133

I .

OBSERVATION OF i l

UNIT 2 PRESSURlZER CAVITY ENCLOSURE WALL l

l. Scoce Observed three utility personnel plus foreman, two builders, one area engineer and one QC inspector making final adjustments to release bottom lift of pressurizer cavity enclosure wall for concrete placement. Work was identified by Placement No. 4960.

ii. Observations A. The previous day, the evaluation team was advised this pour would begin the morning of 9-30-82. When we arrived at the form at I 9 am, the pre-pour inspection sheet had not been signed by QC.

B., Several areas had rebar too close to the form.

C. Final cleaning of the form was in progress.

D. QC was questioning the correctness of spIIce lengths on horizontal rebar. The builders had installed the rebar per verbal Information from the area engineer who had checked with Design. No criteria i

was specified on the rebar drawings,and no variation notice was written to authorize the splice lengths used. The area engineer l

was measuring the splice lengths on the horizontal bars to give l E.

l Information to Design such that a decision could be made by Design l

as to adequacy of installation. The area engineer did initiate a VN to verify splice lengths,and QC signed pre pour.

I E. No pour grade was marked on the form, and the utility foreman did not know where the top of concrete would be. He stated he would get the information from the builder foreman.

I 184 i .

- . . . . . . . - . . - - - . . . - . . . . . . . . . ~ . .

?

s F. The utility foremen had not identified access points for placing concrete in the more heavily congested areas.

o-Ill. Conclusions A. The concrete pour was not ready for placement. l

8. The builders had Installed rebar without knowing splice length criteria.

C. The builders had installed rebar not in accordance with clearance criteria.

D. The utility personnel had not planned their placement activities.

a E. The area engineer was providing Design criteria information

- without documenting the Information.

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185

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, l CBSERVATION OF MATERIAL CONTROL I. Scope Review warehouse and storeyard storage activities relating to electrical equipment.

11. Observation A. Identification of material and equipment, both safety and non-safety, within warehouses was by paper stick-on tag with non permanent adhe-sive. Tags on numerous items were either loose or had fallen off.

Warehouseman stated there was no standard procedure for tagging or identifying ~ equipment in the warehouse.

7 B. A non-safety transformer that was damaged was stored in middle of the aisle without any identification tag. The warehouseman was able to find the receiving paper by leafing through the record book. There was no damage notation on record.

C. Safety and non-safety equipment was stored together. There is poten-tial for issuing wrong equipment.

D. Access to warehouse is not secure from adjacent termination fabrication shop. Material on second and third shelves on bin separating the shop and warehouse is directly accessible to shop personnel.

E. Access to warehouse is not secure from adjacent maintenance office area.

Double doors were unlocked and open allowing direct access to storage areas.

F. ' Warehouseman responsible for receiving equipment in one warehouse

. stated he did not know of any procedures relating to his work.

L quality Assurance Procedures P-1 and P-2 are directly applicable to receiving and storage activities.

186 k

G. Same warehouseman Indicated ha hrd bean in his Jcb three ysers and had not received any formal training in that job. Absence of knowledge of procedures indicates need for training.

N. Cable reels were stored in storage yard with cable ends open and unprotected. Open cable ends allow moisture to enter. causing cable deterioration and possible failure in service.

l. Spare generator circuit breaker stored in yard had its control cabinet open where parts had been robbed. Disconnected tubing connections and loose parts were, therefore, exposed to the open environment. This Indicated lack of storage control, maintenance and surveillance and could lead to deterioration of equipment.

J. Warehouse supervisor indicated he needed training and information on handling hazardous materials.

- Ill. Conclusions A. The procedures for storage of material are not always followed.

B. Procedures for identification of equipnent in storage are not available.

C. Knowledge of storage procedures appear to be lacking.

D. Training of personnel does not appear adequate.

i E. Procedures for identification of damaged equipment within the ware-I. house do not appear to exist.

F. Control of access to warehouse appears to be weak.

187 1

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- -., .q Attachmsnt #2 -

833559 40 0) $. tT M

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.kT UNITED STATES OF AMERICA

-NUCLEAR REGULATORY COMMISSION -  %

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -

- . .; s .._ .

IN RE: -

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)

DUKE POWER COMPANY, et al. ) Docket Numbers (Catawba Nuclear Statfo E ). ...

Units 1 and 2)

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50-414 3

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l MAY 19, 1983 6:00 P.M.

4 DEPOSITION OF:

WILLIAM RONALD McAFEE

. Evelyn Berger Associates STENOTYPE REPORTING SERVICE P. O. 90X 19444 CHARLOTTE. NORTM CAROLINA 30119

M5AFEE . Direct 37 q,s 1 4 I have a copy (indicating). few is this response 2 correct to the best of your knowledge?

3 A Yes, sir. -

14 4 As I see it there are six al*sgations and Ibelieve 5 you have made reference to each one of : hose allegations alread r; 6 is that correct? '

7 A No, that is not correct.

8- 4 All right, will you correct !T understanding? '

9 A Okay, .orie thing I did fail tc mention was the fact 10 that blueprints _ 'were changed to refleci construction errors.

11 And if you would like me to elaborate i s that I will. .-

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12 4 Yes, wotiid you? .

.n.

13 A On certain occasions we wouis go to inspect the cable 14 tray supports, cable tray hangers and 411 the cable tray supports, t

15 or I should say most of them, were sei: nically br' ace'd. We found 16 several instances in which seismic bra ing was not run in the 17 direction the print called for it to be run.

18 l We would, usually on this ou- procedure was to talk 19 to the Technical Support engineers, an- generally the resolution 20 to this was that Design Engineering wo Id revise the blueprint 21

to reflect the change in dir'ection of the seismic bracing.

22 l And I will add,that it was m: understanding that i

23 seismic bracing ran pretty much a cont.nuous system. In other-

- (- 24 words,' you didn't brace all of them in one direction. You would l

25 l alternate the direction bfr. bracing and so forth.

[

Ev8 LYN Sgmega ASSOC 8ATES. STENOTYPE REPONTI888 SENWCE *MA ALOTTE. NOstfu CAmoussa

• McAFEE - Direct '

38 I

4 Let's just explore that one for a moment: As I .

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2 understand it, you ould go out in the field to conduct your

~

3 inspections, and you look at the blueprints to determine if 4 the work was performed pursuant to the blueprint; Is that

~

5 correct? _.-

6 A Yes.

7 4 And in some instances you. determine that the work was 8 inconsistent with the blueprints?

8 A Yes.

10 Q And then the matter went to .the Technical Support 11 engineers. Who'were they? .

12 A They were in the construction department, they were 13 engineers.

14 4 What does that mean; What are they supposed to do 13 when you bring this to their attention? Are they supposed to l

16 determine if this is improper or if it is acceptable?

II A My understanding of their job when I was out there 18 is that they were to determine or help us to determine if it 18 was a.significant non-conformance. That was my understanding 20 of their job.

21 Q Stop there. Did tou receive training as to what thetr 22 job was? How did you come to understand that was their job? .

23 A Basically from -- we didn't receive any formal train-24 ing that was their job -- but that was the way we were told to 25 use, if you will, these people.

g EvsLTm gemoan ASSOCIATES. STENOTTPS asPORTING S$RWICE. CNARLOTTE. NORTM CAROUMA

~

McAFEE - Direct 39 I

4 Did it bother you that you had to bring this matter

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2 to the Technical Support engineers? Did you have problems with l

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3 tliat concept? -- -

~~4 -

A At that time I didn't at all because it wasn't just

.5 with th' ese seismic bracings that we went to Technical Support 6 This was on the matter of, well, other minor things.

with.

7 I'm just 4 I understand,that they look at many things.

8 trying to look at, right now, do you have any problems with the

~ 8 fact that they* lock at a wide-range of construction analysis?

10 A No'. '

il 4 And noV we are talking about a specific instance of 12 this seismically braced - What was seismically braced?

7 I3 A Cable i; ray hangers, Cable tray supports.

I4 Where were they located?

I 4 .

i 15 A Well, the vast majority of the ones I was responsible l

I8 ']ne, Pipe Chase for inspecting were'in the Reactor Building II again, and the auxiliary building.

18 4 And what crews were involved?

I8 '

A Cecil Cox. .

20 4 And as I understand it, the matter was taken to 21 Technical Support, and what'did Technical Support do with the 22 matter?

23

. A They would contact Design Engineering.

% 24 4 Do you know if they contacted Design Engineering in 25 this instance?

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McAFEE - Direct -

40 1 'A' Well, the're were several in' stances.

- 2 '4 'Do you laiow 5.f they contacted Design Engineering 3 in.each of these instances? .

4 A. I didn't hear the phone calls. We were told that 5 they'did. -

6 4 What is the function of Design Engineering in thir 7 process to the best of'your knowledge? -

8 A It is my understanding that Design Engineers design 9

the plant, and if the blueprint or design needs tu be chan.?ed,

~

10 then it is their responsibility.

11 4 They were centacted to 'see if they wanted to change 12 the prints'or non-conform the item; and help me out with this:

DI 13 If they can change the prints do they have to make some deter-14 mination that it is proper.to change the prints to the best of

~

15 your knowledge?

16 A They have to make a determination based on whatever 17 criteria they use.

18 4 You don't know what that criteria is?

19 A No, I am not an engineer. ,

20 4 And these instances involving seismically braced l

21 l cable. tray supports and hangers, did Design Engineering make l

22 l the judgement that the blueprints should be changed?

l l 23 A In most instances, yes, that I brought to their atten-l '

- 24

• tion.

25 l 4 And were you satisfied with the resolution of the matter'

. . . . . . . - . . . . . . . . . . . . . . . - . . . - . . . - . . . . ~ . , , . . ~ . -

M$AFEE-Direct 41 (t .

I A Welli I wasn't fully satisfied.

In other words,. I

• was not comfortable with the fact that a print was being change i .

because a craft' worker made a mistake an'd braced something the wrong wayI s '

I had t'o be satisfied because they reviewed'the print 6

and that was the new print I had to inspect by. Do you under-7 stand?

4 I understand. Let me again just explore it for a 9

moment: Am I correct in understanding you were not totally 10 satisfied because this was reflective of inefficiency or not doing the job rig'hii the first time; but 'once the engineers (g;

tho'se people I assume who have a technical background, made a 13 ' c.etermination it was ' appropriate to change the design, those 14 were then your marching orders; and i~nasmuch as thei: seism'ibkhy

15 .

braced cable trays and hangers were now running in a direction 16 consistent with a revised blueprint, you no lenger had a pro-

.17 .

blem with the work?

18 A. I was still concerned about the fact that it was 19 changed to reflect a construction foul-up. I had no choice but 20 te inspect by the blueprint.

21 4 Were you concerned that the seismically. braced cable, 22 trays or cabh 2 angers would not perform the function they were 23 g' supposed to perform?

\

24  :

A I considered that a possibility.

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Attachment #3 m a.,e envision e PROCEDURE R-3 PAGE C5-1 l REVISION 9 k Dunt POWER COMPANY DESIGN' DRAWING AND SPECIFICAT;0N VARIATION CONSTRUCTION DEPARTMENT QUAllTY ASSURANCE '

PROGRAM A9)dd4 9AW% WA N kn..b .. CqVER SHEET

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LIST OF PAGES, FOR$IS, & ATT ACHMENTS V AllD FOR THIS REVISION:

Revision

• Page CS-1 9

• Page 1 6

• Page 2 8

• Page 3 Deleted

• Form R-3A 7 Form R-38 0

(

Note: Form R-3A, Revision 7 will be used for all Variation Notices issued after implementation date of this procedure.

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l neem a.ic enveen , l PROCEDURE R-3 l PAGE 1 l REVl540N 6 l eme mates e,

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ears Y

co'E N EeN a N e nen, QUALITY ASSURANCE PROGRAM 1

1. EllLPDSE

This procedure establishes the method of controlling the fleid verlation from Design Engineering drawings ,and specifications as approved by the Design Engineering Department. ,

2. Sfa,P,g, No variations from design drawings and specifications are permitted without prior approval by the Design Engineering Department. This procedure l ,

' estabitshes the method for assuring that these variations era approved and t that they appear as revisions to the design drawing or speelfication if necessary. Variation Notices (Form R-3A) are not to be used to report ww that already has been accomplished or to authorize the use of an unapproved or preliminary design but rather to document an agreement with Design

- Engirieering to conduct work in variance with an approved Design Engineering drawing or specification. Procedure Q-1 shall be followed to report work which is being performed or has'been completed in violation of the approved 1

revision of the design drawing or speelfication effective at the time the work is accomplished. Previously completed work which varies from later revisions to design drawing or specification may be reported on a Variation Notice (Form R-3A) In accordance with this procedure. .

). RES PC.isl81 LITY The Project Manager or his designee in writing is responsible for approving [

the variation for field use. Prior to approval he must verify that the use e

of the variation notice is essential to maintain work In progress or to '

maintain terk which will soon begin. The Construction Engineer, In diose area of responsibility the variation lies, Is responsible for the Initiation of the Variation Notice (Form R-3A). The Senior Planning and Facilities l

Engineer is responsible for the distributton and logging of variation notices. Design Engineering is responsible for properly making all required revisions to specifications, drawings, or calculations. ,

4. PROCEDURE 4.1 The responsible Construction Engineer or an employee designated by him who discovers the need for a variation from a design drawing or specificatt'en shall Inf tlate a Verlation Notice (Form R-3A). He shall get approval for the variation action to be taken from the Design Engineering Department and shall include on the form the name of the Individual giving this approval. This approval may be l

transmitted to the field verbally by telephone, in person, or in l

, writing. He shall then complete the "by Construction" section of Form R-3A including the distribution section. The Variation Notice must then be approved by the Project Manager or his designee in writing. l

. . , )

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iees 4.ic eevisso , l PROCEDURE R-3 l PAGE 2 l REVl510N 8 Mm D%

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co'7,'eE M E I 7 , QUALITY ASSURANCE PROGRAM eare 4.2 After this, the Planning and Facilities Engineering Staff 'shall -

number, log on Form R-3s or a computer printout, and distribute the Verlation Notice as Indicated in the distribution section. ,

He shall retain the original copy In the Field Office. If a computer printout is used, It shall at least document the Variation Notice serial number, and the completion status In regard to Design Engineering revising the drawing. l 4.3 Inspection and documentation of work performed in accordance I with a Variation Notice shall be accomplished in the same manner as would have been accomplished using the design doctanent which has been varied. The Variation Notice shall be considered the

, design document. ,

4.4 The Vice-President, Engineering or his designes shall be sent a copy of each Variation Notice and he shall see that the "by Engineering" section of each Variation Not!ce is completed in accordance with Design Engineering's Qua1Ity Assurance procedures pertalning to Variation Notices. After this section is complete, a copy shall be returned to the Construction Field Office to be flied with the original copy of the Variation Notices. The Planning and Facilities Engineering Staff shall VN record the receipt of the copy on Form R-3B or the computer print-out. The Senior Construction Engineer will assure that any  ;

exceptions or alternatives proposed by Design Engineering are l acted upon and that the completed action and Inspections reflect i these exceptions and alternatives. The completed Variation Notices "

with Design Engineering signatures shall be forwarded to the Project Quality Assurance Staff for filing.

4.5 Each month the Planning and Facilities Engineering Staff shall check j the file of Variation Notices to see that they are being completed i in accordance with this Section. They shall then transmit to Design Engineering and Quality Assurance Engineering and Services Division a list of any uncleared notices w'nich are more than one (1) month .

old.

5 FORMS . ,

i .

The following forms are required by this Section:

Fonn R-3A Variation Notice Form R-35 Variation Notice Log or Computer Printout

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DUKE POWER COMPANY .

CONSTRUCTION DEPARTMENT -

PROJECT ff i G uits VARIATION NOTICE S., lei N. 24 3lo

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SMETCH m SYSTEM OR STRUCTURE

$4tTGrr Mh hinause NdAY SdtfCg/dL UNIT ggg,yg RESPONSly CONST. ENGINEER DWG. NOS. AFFECTED REY. Na Mc-141A.c4-1 2

-ND&P3 X] L. rf. J exoo DESIGN ENGINERING CONTACT I

P./Na/Ko 4)g g g.7.y I lit,iCRIPTION OF VARIATION '

h l 4WW l LJCDM 12 Au su vattfalues RA M A RTEUf TUR AL t* ni u 99A,1 AMb bDelat C A~utrA t tS or AW A U h ,% AT FLAssA';"Irus ')51*=R*IcesTsh M I- /.

• D ARTAf dF M AAJa 1 1 # " p a t r- osir 8 O i-E ACTION TO SE TAKEN 5: wat s w nia 2" go*rianus sessuu to SA 4o2 up xn 4. ca.ss 3 As R w nf IAI teni Te M. ?A nn scATitus ,tudirTcu A artvt cau ~r-not par =w A GL ALs b NDsuG h9 ^ ^ *1M L HWs 1" Rtr d vs j

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DISTRIBUTED TO OF piEg ,

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F This variation notice is R ', 7 kg' car ed to be necessory General Suoerintendent 5 Layout Suoerintendent Ta .m F for continuotion of w or k .

Const. Ener. Wad l V S A. Eagr. ***'t ^a I hYjjjpp: ~

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0.C. Engr. Sech. Appr oval Date Cesigr. Enging. M.M Dese _l l _

SOLUTION: W[Some es 'teken by construction AfMAM ( ) Esception taken to construction solution.Exploin below.

l RES PONSIBLE SUPERVISOR Const. Enaineer contocted M/A Defe YA EXCEPTION A i

l-I g Verletlen correctly stated by construction (bffes ( )No Revision merked se oppilcoble.documente (afYes()No 3 Safety reisted (69Yee ( )No Spec. Celculation or Dwg. issue required MYes( ) No 6 Sote. Calculations or Dwa. revision road (Wyes ( INo Spet. Calculation or Dwg. revised es listed below.

T Dwg. No. R ev. N o. Dwg No. Rev. N o. Dwg. N o. Rev. N o, i ~ W=I4ld.04-l Z e

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Date Y_ I7 -7b Wesponsible Eng. Svov. l Qu ality Assurance

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e FORM R-39 REVISION O 6XAm PtE ouxE POWER company

. CONSTRUCTION DEPARTMENT

[V PROJECT Mc 6usaf VARIATION NOTICE LOG '

Sheet Vorlation Date Date Cleared Action Description of Variotton Notice Orignoted No. By Eng. Inspected 997 l 1-14 6 ko n t-374 E re v to on eksnee on ole Mc-to+o 99 9 t-3-N s-s 9 M I- 4-74 Rehe ekas ne en has. Me . 449 / Ac- 44ta e+

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Ofs/& r+w gGPOR ATE G A MAN AGER ~M DA room a.ie nevmow o v PROCEDURE R-3 l PAGE CS-1 DESIGN DRAWING AND SPECIFICATION VARIATION CON RU ON DEP R NT

v. nE Pa.ED APPROVED 6 NO. av oan av y o^"

PROGRAM

/FA' s%lw l

~

COVER SHEET List of pages, forms, and attachments valid for this revision:

Revision

• Page CS-1 5

• Page 1 5

• Page 2 5

• Page 3 5

• Form R-3A 4 Form R-38 0 S 4 SL3ERS~:ED l

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PROCEDURE R-3 PAGE 1 DESIGN DRAWING AND SPECIFICATION VARI ATION CON RU ION DEP M NT rey, PRE PARED APPROVED QUAUTY ASSURANCE NO. SY DATE DATE

_ BYf PROGRAM S , Mz - '

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1. PURPOSE This section establishes the method of controlling the field variation from l Design Engineering drawings and specifications as approved by the Design l Engineering Department.

2. SCOPE No variations from the design drawings and specific ns are permitted without prior approval by the Design Engineering t. This Section

. establishes the method for assuring that thes a ons are approved and that they appear as revisions to the desi r ng or specification if necessary. Variation Notices (Form R-3 t to be used to report work that already has been accomplished t er to document an agreement with Design Engineering to conduct work .va nce with a Design Engi-neering drawing or specification. I the o r case, a Nonconforming.

Item Report Sheet (From Q-1A) shou ue.

3 RESPONSIBILITY The Project Engineer, Senior c lon Engineer, or someone of higher authority within. the projec a nt organization is responsible for approving the technical por f the variation for field use. The Con-struction Engineer, in whose of responsibility the variation lies, is responsible for the initiation of the Variation Notice (Form R-3A).

The Project Senior quality Assurance Engineer is responsible for approving

, the quality Assurance aspects of Variation Notices and for specifying l Inspection if needed. The Senior Quality Control Engineer is responsible l for assigning the applicable group to inspect the action if specified by quality Assurance. They may delegate in writing the authority to perform these actions to persons who work for them. The Senior Planning and Facilities Engineer is responsible for the distribution and logging of variation notices. Design Engineering is responsibis for properly making any required revisions to specifications, drawings, or calculations.

4. PROCEDURE l 4.1 The responsible Construction Engineer or an engineer designated by him who discovers the need for a variation from a design drawing or specification shall initiate a Variation Notice (Form R-3A). He I shall get approval for the variation action to be taken from the l Design Engineering Department and shall include on the form the name of the Individual giving this approval. This approval may be transmitted to the field verbally by telephone, in person, or in writing. He shall then complete the "by Construction" section of

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PROGRAM

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Form R-3A including the distribution section. The technical portion of the Variation Notice must then be approved by the Senior Construction Engineer, Project Engineer, or an Individual of higher authority within the project management organization.

The Project quality Assurance Staff shall then review the Variation Notice. If inspection is needed, the words " Inspection-Required" shall be written in the " Action to be Taken" section.

If Inspection is not needed, the " Waived" block shall be checked.

No item requiring inspection by other parts of the quality Assurance Program may be waived. Quality Assurance approval shall then be signed and dated. If required, the Senior quality Control Engineer shall assign to the applicable group of Quality Control Inspectors or layout crew the responsibillt r inspecting the completed action.

4.2 After this, the Planning and Facilities Engi ff shall number, log on Form R-3B or a computer pri t nr dis tribute the Variation Notice as indicated in the str lon section.

He shall retain the original copy in t F d fice, if a computer printout is used, it shall at cument the Variation Notice serial number, an c letion status in regard to Design Engineering revi i rawing and Construc-tion inspecting the variation. p 4.3 A member of the quality Co nsp ction group or layout crew that has the inspection a shall sign and date the "com-

. pleted action Inspectec y tion on the original or a copy of the Variation Notied signs a copy, he shall return the signed copy to the P1 Ing and Facilities Engineering Staff who shall file this copy w th the original of the Yartat[on Notice and record that the notice has been Inspected on Form R-3B, or the computer printout. ,

4.4 The Vice-President, Engineering or his designee shall be sent a copy of each Variation Notice and he shall see that the "by Engineering" section of each Variation Notice is completed in accordance' with Design Engineering's quality Assurance procedures pertaining to Variation Notices. After this section is complete, a copy shall be returned to the Construction Field Office to be flied with the original copy of the, Variation Notices. The Planning and Facilities Engineering Staff shall record the receipt of the copy on Form R-3B or the computer print-out. The completed Variation Notices with inspection and Design Engineering signatures shall be forwarded to the Project quality Assurance Staff- for filing.

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DUKE POWER COMPANY DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT REv.

rREPARED APPROVED QUALITY ASSURANCE NO. M DATE H. l DATL PROGRAM 5 M M ysp,y ,

4.5 Each morth the Planning and Facilities Engineering Staff shall check the flie of Variation Notices to see that they are being completed in accordance with this Section. He shall then transmit to Design Engineering and quality Assurance Engineering Division a IIst of any uncleared notices which are more than one (1) month old. He shall also distribute to the appropriate Construction Engineers, quality Control groups, Layout Supervisor, and Project quality Assurance Staff a IIst of any uninspected Variation Notices which require inspection and which are more than one (1) month old.

5 FORMS The following forms are required by this Section:

Form R-3A Variation Notice Form R-3B Variation Notice Log or Computer Printout

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To Design Engineering O Civil O Elect. dech. From Desi n Egineering From Project Monoger.

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(Date)

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1 Return to responsible engineer mben revisions hovo been comploted.

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DUKE *OWER COMPANY DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT

,, v. enEranEo arenOvEo @EN MWuME NO. SY DATE SYr i DATE PROGRAM 7 O lA) M 4/tll75 MA /r771f 1

l COVER SHEET List of pages, forms, and attachments valid for this revision:

REVISION

• Page CS-1 7

• Page 1 5 Page 2 6

• Page 3 6

• Form R-3A 5 Form R-3B 0 sOPERS 53 9 l

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(N DESIGN DRAWING AND SPECIFICATION VARIAT10i4 CONSTRUCTION DEPARTMENT

,Ev. PREPARED APPROVED .

NO. sY DATE bye DATE PROGRAM I 5 &NeaSM. N'W /lhb= ' & LMV

1. PURPOSE This Section establishes the method of controlling the field variation from Design Engineering drawings and specifications as approved by the Design Engineering Department.-

2. SCOPE No variations from the design drawings and specifications.are permitted without prior approval by the Design Engineering Department. This Section establishes the method for assuring that these variations are approved and that .they appear as revisions to the design drawing or specification if necessary. Variation Notices (Form R-3A) are not to be used to report work th.at already has been accomplished or to authorize the'use of an unapproved

~

or preliminary design but rather to document an agreement with Design Engi-neering to conduct work in variance with an approved Design Engineering drawing

'{se at n e rmer case, a Nonconforming item Report Sheet 3 ItESPONSIBILITY The Project Engineer, Senior Construction Engineer, or someone of higher authority within the project management organization Is-responsible for.

• approving the technical portion of the variation for field use. Prior to approval he must verify that the use ,of the variation notice is essential

.to maintain work in progress-or,to maintain work'which will soon begin. The Construction Engineer, in whose area' or responsib~111ty the variation lies,

.is responsible. for the initiation' of- the Variation Notice (Form R-3A). ,

The Project Senior Quality' Assurance Engineer is responsible for approving the qual.Ity Assurance aspects of Variation Notices' and for specifying

'Inspectio'n i f' nceded. The Senior quality Control Engineer is responsible ,

for assigning .the applicatste group to inspe'ct the action if specified by quality Assurance. They may delegate in writing the authority to perform these actions to persons who work for them. The Senior Planning and FacIIIties Engineer is responsible for the distribution and logging of

, variation notices. Design Engineering is responsible for properly making any required revisions to specifications, drawings. ,or calculations.

4. PROCEDURE 4.1 The responsible Construction Engineer or an employee designated by him who discovers the need for a ' variation from a design drawing or specification shall Initiate a Variation Notice (Form R-3A). He shall get approval.for the variation action to be taken.from the Design Engineering Department and shall include on the form the name.of the individual giving this approval. This approval may be transmitted to the field verbally by telephone, in person, or 'in writing. He shall then complete the "by Construction" section of 4

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• Y DUKE POWER COMPANv DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT

,, y. ,,,,,,,o A,,noveo QUAUTY ASSURANCE ,

NO. av oArE sv . DATE PROGRAM W

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Form R-3A including the distribuilon section. The technical

. portion of the Variation Notice must then be approved by the Senior Construction Engineer, Project Engineer, or an Individual

! of higher authority within the project management organization.

The Project Quality Assurance Staff shall then review the Variation Notice. if Inspection is needed, the words " Inspection Required" shall be written in the " Action to be Taken" section.

If inspection is not needed, the "Walved" block shall be checked.

Items which will receive adequate inspection and documentation through the normal function of the' Quality Assurance Program need not have' their inspection documented on the R-3A, and the waived g block should be marked. Quality Assurance approval shall then be signed and dated. If required, The Project QA Staff shall mark the R-3A to indicate inspection assignment.

4.2 After this, the Planning and Facilities Engineering Staff shall number, log on Form R-3B or a computer printout, and distribute the Variation Notice as indicated in the distribution section.

He shall retain the original copy in the Field Office. If a l computer printout is used, it shall at least document the l

- Variation Notice serial number, and the completion status in regard to Design Engineering revising the drawing and Construc-tion Inspecting'the variation.

4.3 A member of the quality Control Inspection Group or layout crew that has the inspection assignment shall sign and date the "com-pleted action inspected by" section on the original or a copy of the Variation Notice. If he signs a copy, he shall return the signed copy to the Plsnning and Facilities Engineering Staff who shall file this copy with the original of the Variation Notice and record that the notice has been inspected on Form R-3B, or the computer printout.

4.4 The Vice-President, Engineering or his designee shall be sent a copy of each Variation Notice and he shall see that the "by Engineering" section of each Variation Notice is completed in accordance with Design Engineering's Quality Assurance procedures pertaining to Variation Notices. After this section Is complete, a copy shall be returned to the Construction Field l ,

Office to be filed with the original copy of the Variation Notices. The Planning and Facilities Engineering Staff shall record the receipt of the copy on Form R-3B or the' computer print-out. The completed Variation Notices with inspection and Design Engineering signatures shall be forwarded to the Project quality Assurance Staff for filing.

9

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DUKE POWER COMPANY l!

DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT I APPROVED

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.Ev. PR E PARED .

NO. _ _ _ _ BY DATE BY DATE

- PROGRAM I 6 h @M 6ltS}lf M4 f.14 7f ,

l The Project Quality Assurance Staff will assure that any exceptions or alternatives proposed by Design Engineering i are acted upon and that the completed action and inspections [ ,

- reflect these exceptions and alternatives. ,l t !

4.5 Each montn the Planning and Facilities Engineering Staff shall l check the file of Variation Notices to see that they are being i i completed in accordance with this Section. He shall then transmit .

l to Design Engineering and quality Assurance Engineering and Services  :

Division a list of any uncleared notices which are more than one (1) i month old. He shall also distribute to the appropriate Construc _ _ i tion Engineers, Quality Control groups, Layout Supervisor, and Project quality Assurance Staff a list of any uninspected Variation Notices which require inspection and which are more than one (1) .

month old.

5 FORMS -

~~

The following forms are required by this Section:

Form R-3A Variation Notice Form R-38 Variation Notice Log or Computer Printout O

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FORM Ra3A REVISION 5  ;

DUKE POWER COMPANY CONSTRUCTig DJPARTMENT

! PROJECT u ut.ls ar VA'ilATION NOTICE S.rici No. 8 0 0 To Design Engineering Q Civil O Elect. O Mech. From D sign Engineering From Project Monoger.

This variation notice is forwarded for your action s To

• C. blESII

• artif' to be necessory for continvetion of worlt (Project Manager) end r, /k s$goJy hy7,/97g Design engineering.oction is complete end opproved cad'Is returned for our recorde.

(T Approvoil for gri tion no

. AkA]n. anft h(Dote)v?}9H 4. . We & udl,)fE (O A. 4 provel) (Dole) (Responsible l'ieslan Eno.6pervisor) (Def e )

SYSTEM OR STRUCTURE UNIT SKETCH ETCH W OsiDUAL YAY hbtOIM L. S sjm p ^

RE)P LNSIBLE CON %I ENGINEER DWG NOS. AFFECTED R E E V. NO.

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y o ( , DESCRIPTION OF VARIATION S*1 C AIKA g 8td 'If AAf IUT2 A TL ACK- Al

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fw na Lr ACTION TO BE TAKEN; Q g[gog g gg L/9 10 4 As S.w w In Ancus. Sn7c[PA%CA Tsaa wms Ms bf Elsu M As.// Ate MUST f[ A& Wis& A. LifMtitos.s SAOul20. __ 0 INSPECTION ASSIGNMENT: DISTRIBUTED TO hp ESl DISTRIBUTED TO $PfES ecA D Elect. Q Civil General Superintendent ,g O Welding / N OT Q Layout Layout Superintendent 0 0Md Const. Engr. MFCM l Completed action ins acted by.

0. A. Enge NfcAd l 0.C. Engr. NEm I hk, e  % 9 75 Signetfare Date Desion Engineering i SOLUTION * (dSome os taken by construction hd4

( ) Enception taken to construction solution. Explain below. *$ ( ) Alternative solution. Explain below. RESPONSIBLE 56ERVISOR EXCEPTION OR ALTERNATIVE NOME . 2 W Variation correctly stated by construction ( d fest )No Revision marked on applicable documents( (DTrest )No klies( )No ( MYes ( JNC Spsc.,Colculation or Dwg. lasue Reqd. y Safety related Spec., Calculation or Dwg. Revision Reed. ( GPre s ( )No Spec.,Colculation or Dwg. Revised as listed below. i g Ret No. Dwg. No. Rev. No. 2 Dwg.No. Rev. No. Dwg. No. l

• ltc 1614.64. I 3 -

G3 Return to responsible engineer when revisions have been completed.

                                                                                                                 . h V dI*IE N                                                  Date _                MLYEI; YII Variation Cleared: (M Yes Date

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l ( ) No By -

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           ,      .-                                                     FORM      R -38          REVISION     O m                    6XAm P46                               DUKE POWER COMPANY l ')                                                     . CONSTRUCTION DEPARTMENT PROJECT Mc Guant
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VARIATION NOTICE LOG Sheet Verfation Date Date D Cleared Action Description of Voriction Notice g9n , No By Eng Intpected 99 7 l 2-74 8 10-W 1- 3 74 E te g.tt ,n e h e.e on ,/we Me-/afo

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                                                                                  '                                                                                                             I DUKE POWEk COMPANY DESIGN DRAWING AND SPECIFICATION VARIATION                                                                               CONSTRUCTION DEPARTMENT ggy,                  PREPARED                                                                                      APPROVED           QUALITY ASSURANCE No.                  av                                         dan                                                ev.         D*"   -        PROGRAM 8        D W ,.ja d                                 ill9h5                                                                 h,;>.d COVER SHEE:

List of pages, forms, and attachments valid for this revision: Revision .

                     *Page CS-1                                                                                                             8 Page 1                                                                                                            5
                     *Page 2                                                                                                                7 Page 3                                                                                                            6

• Form R-3A 6 Form R-3B 0 Note: Form R-3A, Revision 6 will be used for all Variation Notices issued after implementation date of this procedure.

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                                   /bfRFORATfCK RANAGER     DATu PROCEDURE R-3   PAGE   1 V

DUKE POWER COMPANY DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT l REV. PREPARED APPROVED NO. BY DATE BY. DATE DWM PROGRAM 5 4-4-M /Mn " 4 t7 7f

1. PURPOSE This Section establishes the method of' controlling the field variation from Design Engineering drawings and specifications as approved by the Design Engineering Department.

2. SCOPE No variations from the design drawings and specifications are permitted without prior approval by the Design Engineering Department. This Section I establishes the method for assuring that these variations are approved and that they appear as revisions to the design drawing or specification if necessary. Variation Notices (Form R-3A) are not to be used to report work that already has been accomplished or to authorize the use of an unapproved or preliminary design but rather to document an agreement. with Design Engl-neering or to conduct work in variance with an approved Design Engineering drawing specification.

(Form Q-1A) should be used.)In the former case, a Nonconforming item Report Sheet 3 RESPONSIBILITY The Project Engineer, Senior Construction Engineer, or someone of higher authority within the project management organization is responsible for approving the technical portion of the variation for field use. Prior to approval he must verify that the use of the variation notice is essential to maintain work in progress or to maintain work which will soon begin. The Construction Engineer, in whose area or' responsibility the variation lies, is responsible for the Initiation of the Variation Notice (Form R-3A). The Project Senior Quality Assurance Engineer is responsible for approving the quality Assurance aspects of Variation Notices and for specifying inspection if needed. The Senior Quality Control Engineer is responsible for assigning the appIIcable group to inspect the action if specified by quality Assurance. They may delegate in writing the authority to perform these actions to persons who work for them. The Senior Planning and Facilities Engineer is responsible for the distribution and logging of variation notices. Design Engineering is responsible for properly makisig any required revisions to specifications, drawings, or calculations.

4. PROCEDURE 4.1 The responsible Construction Engineer or an employee designated by him who discovers the need for a variation from a design drawing or specification shall Initiate a Variation Notice (Form R-3A). He shall get approval for the variation action to be taken from the Design Engineering Department and shall include on the form the name of the individual giving this approval. This approval may be transmitted to the field verbally by telephone, in person, or in writing. He shall then complete the "by Construction" section of W

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rom 4.ie PROCEDURE R-3 l PAGE 2 DUKE POWER COMPANY l DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT l

          ,,,           ,,,,,,,o                      a,,nOvio        QUAUTY ASSURANG                    I' NO.         .,            one             u          oats   .

PROGRAM - 7 MM b Form R-3A Including the distribution section. The technical portion of the Varlation Notice must then be approved by the Senior Construction Engineer, Project Engineer, or an Individual of higher authority within the project management organization. Y The Project quality Assurance Staff shall then review the Variation Notice. If inspection is needed, the words " Inspection Required" shall be written in the " Action to be Taken" section. if inspection is not needed, the "Walved" block shall be checked. - Items which will receive adequate inspection and documentation through the normal function of the quality Assurance Program need not have their Inspection documented on the R-3A, and the waived

                       -block should be marked. Quality Assurance approval shall then be signed and dated. If required, The Project QA Staff shall mark the R-3A to Indicate inspection assignment.

4.2 After this, the Planning and Facilities Engineering Staff shall number, log on Form R-3B or a computer printout, and distribute the Variation Notice as indicated in the distribution section. He shall retain the original copy in the Field Office. If a computer printout is used, it shall at least document the Variation Notice serial number, and the completion status in I regard to Design Engineering revising the drawing and Construc- g tion quality Control inspecting the variation. I 4.3 A member of the quality Control Inspection Group or layout crew that has the inspection assignment shall sign and date the "com-pleted action inspected by" section on the original or a copy of the Varlation Notice. If he signs a copy, he shall return the signed copy to the Planning and Facilities Engineering Staff who shall file this copy with the original of the Variation Notice and record that the notice has been inspected on Form R-3B, or the computer printout. 4.4 The Vice-President, Engineering or his designee shall be sent a copy of each Variation Notice and he shall see that the "by Engineering" section of each Variation Notice is completed in accordance with Design Engineering's quality Assurance procedures pertaining to Variation Notices. After this section is complete, a copy shall be returned to the Construction Field Office to be flied with the original copy of the Variation Notices. The Planning and Facilities Engineering Staff shall record.the receipt of the copy on Form R-3B or the' computer print-out. The completed Variation Notices with inspection and Design Engineering signatures shall be forwarded to the Project Quality Assurance Staff for filing. l

   ~ ~ 71_ _ _ _ _ . _ r _
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DUKE POWER COMPANY DESIGN DRAWING AND SPECIFICATION VARIATION CONSTRUCTION DEPARTMENT nEv. easeAnno Arenoveo %EN MWMEE NO. SY DATe SY DATe

                                                                           '           PROGRAM                          l D@M                                      MA 6                           6l15}l5                       (,.14 7j The Project Quality Nssurance Staff will assure that any exceptions or alternatives proposed by Design Engineering are acted upon and that the completed action and inspections reflect these exceptions and alternatives.

4.5 Each month the Planning and FacIIItles Engineering Staff shall check the file of Variation Notices to see that they are being completed in accordance with this Section. He shall then t-,nsmit to Design Engineering and quality Assurance Engineering an services

       ~

Division a list of any uncleared notices which are more than one (1) month old. He shall also distribute to the appropriate Construc-tion Engineers, Quality Control groups, Layout Supervisor, and Project Quality Assurance Staff a list of any uninspected Variation Noticas which require inspection and which are more than one (1) month old. 5 FORMS The following forms are required by this Section: Form R-3A Variation Notice Form R-3B Variation Notice Log or Computer Printout

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CONSTRUCTION DEPARTMENT PROJECT b A ~%

                                                            -                                     VARIATION NOTICE -                                           Social No. 9 W
                                                      '                                  *,

• SYSTEM OR STRUCTURE UNIT SKETCH - 'i #- 'l.

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E Vorlotion correctly stated by. construction (%)Yes( )No Revision marked on opplicable documents (M )Yes ( )No { w Sofety related (g)Yes( )No Spec.,Colculation or Dwg. issue required (X)Yes( INo E Spec.,Colculations or Owg. revision read. (g)Yes( )No Spec.,Calculetion or Dag. revised as listed below. Dwg.No. Rev. No. Ret No. O wg. No. Rev. No.

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F08tM R-3B REVISION O DUKE POWER COMPANY h'XAh! P 4 E CONSTRUCTION DEPAfTTMENT-

' PROJECT Mc Gurnf VARIATION NOTICE LOG Sheet .

Verfellen Date Date Date Cleared Action Deectlption of Votieffon Notice Ongneted Inspected No. By Eng. 997 1 1-74 8 10 N b- 3'74 EseveToon e hsnee " on *Ian Me - 10 40

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p 4.se nw: Pnocsount R-3 PAGE l REVISION 8 E R QUALITY ASSURANCE PROGRAM

1. PURPOSE This procedure establishes the method of controlling field variations from Design Engineering drawings and specifications approved by the Design Engin-eering Department. -

2. SCOPE No variations from design drawings and specifications are pemitted without prior approval by the Design Engineering Department. This procedure es- -

tablishes the method for assuring that these variations are approved and that they appear as revisions to the design drawing or specification if necessary. Variation Notices (Form R-3A) are not to be used to report work that has been turned over to QA/QC for inspection or to authorize the use of an unapproved or preliminary design but rather to document an agreement with Design Engineering or conduct work in variance with an approved Design Engineering drawing or specification. (Previously completed work which

                           ' varies ,from later revisions to design drawing or specification may be re-ported on a Variation Notice (Fom R-3A) in accordance with this procedure.)

3. RESPONSIBILITY The Project Manager or his designee in writing is responsible for approving the variation for field use. Prior to approval, he must verify that the use of the variation notice is essential to maintain work in progress or to maintain work which will soon begin. The Construction Engineer, in whose area of responsibility the variation lies, is responsible for the initiation of the Variation Notice (Form R-3A). Construction is responsible for the distribution and logging of Variation Notices. Design Engineering.is Q responsible for properly making all required revisions to specification:;,

drawings, or calculations.

4. PROCEDURE 4.1 The responsible Construction Engineer or an employee designated by him who discovers the need for a variation from a design document, shall initiate a Variation Notice (Form R-3A). He/she shall complete the l

                                                  "By Construction" section of the R-3A fom and obtain approval for the variation from the Project Manager or his desigr.ne. When requests for variation involving changing or deleting Quality Assurance requirements (such as nondestructive examination, inspections, test requirements, documentation, etc.) are made, they shall be approved by an individual of the Quality Assurance Technical Services Divisien prior to imple-mentation. The Design Engineering contact is responsible for obtaining and documenting this approval. The employee initiating the Variation Notice shall include the name of the Quality Assurance contact on Fom R-3A. Variation Notices may be verbally approved by Design Engineering j                         under the folicwing cases:

a. When the action to be taken can be stated completely in writing on Form R-3A.

b. When the Variation Notice is supplementad by an attached sketch for clarification purposes only. A clarification sketch is defined as a marked up copy of an existing design drawing showing only those changes verbally approved by Design Engineering. Attachments must be uniquely identified to the Variatien Notice by use of the R-3A serial number.

Variation Notices supplemented by attached sketch (es) representing al-ternate designs, or changes so complex that clarification sketches will

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e 2 :.x p.,,,, A.ic n PROCEDURE R-3 PAGE 2 REVlSION 10 4 DUKE POWER COMPANY QUALITY ASSURANCE PROGRAM CONSTRUCTION DEPARTMENT not suffice, require Design Engineering approval of the sketch beftn allowing work in accordance with the Variation Notice to begin. 4.2 After this, Construction shall number, log on Fom R-38 or a con.puter ~ printout, distribute the Variation Notice as indicated in the dis-tribution section, and retain the' original copy in the Field Office. If a computeris used, it shall document, as a minimum, Variation Notice serial number and completion status in regard to Design Engineering re-vising and drawing. 4.3 Inspection and documentation of work performed in accordance with a Variation Notice shall be accomplished in the same manner as would have been accomplished using the design document which has been varied. The Variation Notice shall be considered the design document. 4.4 The Vice-President, Engineering, or his designee shall be sent a copy of each Variation Notice and who shall see that the "By Engineering" section of each Variation Notice is completed in accordance with Design Engineering's Quality Assurance procedures pertaining to Varia-tion Notices. He will assure that one of the two solution blocks is checked. After Design's portion of the form is complete, a copy shall be returned to the Construction Field Office to be filed with the original copy of the Variation Notices. 4.5 Construction shall record the receipt of the copy on Fem R-38 or the h computer printout. Any R-3A fom that has the "same as taken by Con-struction" block checked by Design, requires no further action. The Senior Construction Engineer will assure that any exceptions proposed by Design Engineering are acted upon and that the completed action and inspections reflect these exceptions. If actions or inspections can-not be performed in accordance with the exception, Quality Assurance Procedure Q-i shall be followed to report the work which has been com-pleted. Completed Variation Notices with Design Engineering signatures shall be forwarded to the Project Quality Assurance Staff for filing. 4.6 In the event it is necessary to void a Variation Notice, the individual associated with originating the R-3A will contact Design Engineering and fomard a copy of the R-3A to the Design Engineering coordinator with an explanation of the need te 3id the Variation Notice. 4.7 Obvious engineering er 3 h .'vered during construction which clearly would not preclude ac w @b .irkmanship, will be identified by the use of the R-3C form. ine :.c 4,e Construction Engineer or his designee shall complete the R-3C fom and obtain Quality Assurance approval. Periodically (weekly, etc.), he shall fomard this infomation to De-sign Engineering for incorporation into the design documents if Design sees a need to change these documents. 4.8 Design shall evaluate all Variation Notices except those checked "(a) Interference", "(b) Construction Option," or "(c) mssing Infomation" for Design nonconfomance in accordance with PR-202. All Design non-0 ( coaror aces ust thea be evaiu ted for report b$i4tr uader ioCFR2i and/or 50.55e. Entire Page Revised

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a.ic nma PROCEDURE R-3 PAGE 3 REVISION O j ,, p DUKE POWER COMPANY QUALITY ASSURANCE PROGRAM l h CONSTRUCTION DEPARTMENT l l 4.9 Each month Construction shall check the file of Variation Notices to see that they are being completed in accordance with this Procedure. * , A list of any uncleared notices which are more than one (1) month old I shall be forwarded to Design Engineering. g 4.10 Design Engineering is responsible for performing trend analyses on Varia-tion Notices to assure that any unnecessary trends are not developing.

5. FORMS The following forms are required by this procedure:

Form R-3A Variation Notice Form R-3B Variation Notice Log or Computer Printout Form R-3C Minor Discrepancy Log  ! O O O CARRYOVER

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                    .. ..                          .                           PROCEDURE R-3                                 PAGE C5- 1                                 REVISION 17 DUKE POWER COMPANY CONSTRUCTION DEPARTMENT DESIGN DRAWING AND SPECIFICATION VARIATION QUAUTY ASSURANCE                                                                              -

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                                                                                                        'h/s3 coygn ggggy ears LIST OF PAGES, FORMS, & ATTACHMENTS VALID FOR THIS REVISION:

REVISION

                                                              *Page CS-1                                                                             17
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w.- . . . . p 4.se n Pnocaount R-3 Pass 1 navision 12 QUALITY ASSURANCE PROGRAM i CONSTRUCTION DEPARTMENT

1. PURPOSE This procedure establishes the method of controlling field variations from Design Engineering drawings and specifications as approved by the Design Engineering Department.

2. SCOPE No variations from design drawings and specifications are permitted without prior approval by the Design Engineering Department. This procedure establishes the method for assuring that these variations are approved and that they appear as revisions to the design drawing or specification if necessary. Variation Notices (Forn R-3A) are not to be used to report work that has been turned over to QA/QC for inspection with the following exceptions: Catawba Support / Restraints may be accepted in the as-built condition by authorized on-site Design Engineering personnel in accordance with QA Procedure M-51 or M-58 and to report unclear / conflicting design

          ,c   documents provided no rework is necessary. Variation Notices are not to authorize the use of an unapproved or preliminary design but rather to document an agreement with Design Engineering or conduct work in variance with an approved Design Engineering drawing or specification. Previously completed work which varies from later revisions to design drawing or specification may be reported on a Variation Notice (Fom R-3A) in accordance with this procedure.                                          -

Ci 3. RESPONSIBIt.ITY The Project Manager or his designee in writing is responsible for approving the variation for field use. Prior to approval, he must verify that the use of the variation notice is essential to maintain work in progress or to maintain work which will soon begin. The Construction Engineer, in whose area of responsibility the variation lies, is responsible for the initiation of the Variation Notice (Form R-3A). Construction is responsible for the distribution and logging of Variation Notices. Design Engineering is responsible for properly making all required revisions to specifications, drawings, or calculations.

4. PROCEDURE 4.1 The responsible Construction Engineer oi an employee designated by him who discovers the need for a variation from a design document, shall initiate a Variation Notice (Form R-3A). He/she shall complete the "By Construction" section of the R-3A Form and obtain approval for the variation from the Project Manager or his designee. Variation Notices may be verbally approved by Design Engineering under the following cases:

a. When the action to be taken can be stated completely in writing on Form R-3A. The block provided on the R-3A form can be used to supplement the description of the variation.

b. When the Variation Notice is supplemented by an attached sketch for clarification purposes only. A clarification sketch is defined as a marked up copy of an existing design drawing showing only those changes verbally approved by Design Engineering. Attachmenfs must

 .b'                         be uniquely identified to the Variation Notice by use of the R-3A serial number.

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! o , l p uc nw Pnocsount R-3 PAos 2 navislON 12 . QUALITY ASSURANCE PROGRAM n- CONSTRUCTION DEPARTMENT (. . Variation Notices supplemented by attached sketch (es) representing - alternate designs, or changes so complex that clarification sketches will not suffice, require Design Engineering approval of the sketch before allowing work in accordance with the Variation Notice to begin. l l 4.2 After this, Construction shall number, log on Form R-38 or a computer i printout, distribute the Variation Notice as indicated in the 1 distribution section and retain the original copy in the Field Office, j If a computer printout is used, it shall document, as a minimum, l Variation Notice serial number and completion status in regard to Design Engineering revising the drawing. 4.3 Inspection and documentation of work performed in accordance with a Variation Notice shall be accomplished in the same manner as would have been accomplished using the design document which has been varied. The Variation Notice shall be considered the design document. 4.4 The Vice-President, Engineering, or his designee shall be sent a copy of each Variation Notice and he shall see that the "By Engineering" section of each Variation Notice is completed in accordance with Design Engineering's Quality Assurance procedures pertaining to Variation Notices. He will assure that one of the two solution blocks is checked. After Design's portion of the form is complete, a copy shall be returned to the Construction Field Office to be filed with the original copy of O- the Variation Notices. NOTE: For each pipe support / restraint, variation notices may be compiled until the support / restraint is completed by construction, and fomarded to Design Engineering for drawing incorporation. Clarifications or changes to previous R-3As may be accomplished by the origination of a new variation notice. Any exceptions taken by Design Engineering will be handled in accordance with section 4.5 of this procedure. 4.5 Construction shall record the receipt of the copy on Form R-38 or the computer printout. Any R-3A form that has the "same as taken by Construction" block checked by Design,. requires no further action. The Senior Construction Engineer will assure that any exceptions proposed by Design Engineering are acted upon and that the completed action and inspections reflect these exceptions. If actions or inspections cannot be performed. in accordance with the exception, Quality Assurance Procedure Q-1 shall be followed to report the work which has been completed. Completed Variation Notices with Design Engineering signatures shall be fomarded to the Project Quality Assurance Staff for filing. 4.6 In the event it is necessary to void a Variation Notice, the individual associated with originating the R-3A will contact Design Engineering and forward a copy of the R-3A to the Design Engineering coordinator with an explanation of the need to void the Variation Notice. 4.7 Obvious engineering errors discovered during construction which clearly would not preclude acceptable workmanship, will be identified by the use

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                                                                                          ' N~      PAGE                            REVISION DUKE POWER COMPANY -

CONSTRUCTION DEPARTMENT of the R-3C form. The Senior Construction Engineer or his designee shall - complete the R-3C form and obtain Quality Assurance approval. Periodically (weekly, etc.) he shall fomard this information to Design Engineering for incorporation into the design documents if Design sees a need to change these documents. 4.8 Variation notices checked " Interference", " Implementation Option", or

                                  " Missing Information" do not require PR-202 evaluation. Any variation notice checked "Other" shall be evaluated for reportability under 10CFR21 and/or 50.55e by Design Engineering.

4.9 Each month Construction shall check the file of Variation Notices to see that they are being completed in accordance with this Procedure. A list of any uncleared notices which are more than one (1) month old shall be forwarded to Design Engineering. 4.10 Design Engineering is responsible for performing trend analyses on Variation Notices to assure that any unnecessarf trends are not developing.

5. FORMS The To11owing foms are required by this Procedure:

Form R-3A Variation Notice Form R-38 Variation Notice Log or Computer Printout Form R-3C Minor Discrepancy Log l e O . L .- _ ___ _ -. _ _ - __ ___ _ __

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  - [ S.                                                                     PROJECT d.47'4v/mA qj                                                                                                                                               swiss No. 3 0, oc o VARIATION NOTICE SYSTEM OR STRUCTURE                                                           EnETCH ATTACNMENT                             UNIT VG - Annuws Vem rarra                                                                     Sysrrm                         Bi"e                                            L'                          l l

• RESPONSISLE CONST. ENGINEER j NEED POR VARIATIOf6 OOCUMENTS APPECTED REV.MO 2,.,,41/_ [ '

IdINTERPERENCE (PR 202 N/Al ~ s G ey g g C IMPLEMENTATION OPTION (PR-202 N/A) Z m rwi> a d2W OMesslNG INFORMATION IPR 202 N/A) Nyg OSSION ENGR. CONTACT QOTHER (PM.202 AseticatWtv Evehsedan Ree-reel RL  % xe DESCRIPTION OF VARIATION "P.sv n ar 1Eeuva o er CAM 2 ad, y g s=3g .z u odensa Te A t.Levt A n m'ss w A t d' tYAAV-

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GENER At SUPERINTENDENT LAvOuT SUPERINTENDENT & COnst. ENGR. 6/K4. / APPROVAL O. A. EnoR E / 6 f. . / g/4t /gz _ O. C. Enom. t / g 4. , / a,7, CESIGN ENGING. E / ( C, . / ONC (PR 202) Asesiesete C Yes @ee Sedution: ( vi Sense es unen tv Cenerveden. ( ) Enesenten tegen to Caneerussen eseution. Enessin beieus. g I DESIGNATED !NOlvtOUAL DATE Const. Eneinser Ceneesses Osse EXCEPTION i w i E E Verlesien correstfy stesses try Construction (t#[ Yes ( ) No Revoeien rnertsed en esaticante demarnens VT Yes ( ) Ne W , k Deshanent Rev6 den Reemired ( / Yes ( ) No Oesunient issue reewired ( Yes ( ) No (/ No Om- -- . rev6ses es tienet basess. Cornenente er docuanent noting attaened i 1 Yes DOCUMENT NO. Rev.No. DOCUMENT NO. Rev. No. DOCUMENT NO. Rev. No. VM. /- 3-o 2 . 0/ / CLEAREO SYt APPROVEO SY: Iof.b OATE: i l'!EE A A-- DATE: Y!/7 ML

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I FORM R-38 - REVISION O

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                    &:r, X A/St P & E CONSTRUCTION DEPARTMENT l

PROJECT Me G u e rt r l l VARIATION NOTICE LOG . Sheet O Verletten Dete Dete Date Cteored Action Description of Verletion Notice Orignoted No. By Eng. Inssected 99 7 1 2-74 1-10 74 J- 3 74 5meve1,,n e ha.a.e en e/w a A7e - /a 40 ' 9 c19 l-3-74 n - t 9-14 I-IV-74 Reh e cheene en dwgs. Me - 449 / Me 44 ta e ee. ,,

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DUKE POWER COMPANY CONSTRUCTION DEPARTMENT PROJECT 0 4f4ve84

      'n                                                                                         UNIT                       M O2 03 MINOR DISCREPANCY LOG Design Document No. 6M-M- /O4/O                                                                 /                  -

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              "EI'gipSWdR: Darrell G. Eisenhut, Director Division of Licensing Roger'Hattson, Director Division of Systens Integration Richard Vollner, uirector Division of Engineering Hugh Thompson, Director Division of !!urnan Facters Safety TitRH:                                     Elinor G. Adensaa Chief Licensing Branen No. 4 Division of Licensing Thor.1as N. Novak, Assistant director for Licensing Division of Licensing FR0!!:                                    Kahtan N. Jabbour, Project Manager Licensing Ho. 4 Division of Licensing S!J8 JECT:                                 SYSTENATiC 'SSESS!!EHT OF LICEhSEE PERFOR:W CE (SALP)

DUKE POUER COMPAf$Y - CATAWBA NUCLEAP. STATI0ti, UNITS 1 AND 2 -- I tta'ched is a draf t of the NRR input for the SALP for Duke Power Company. This draft reoort is based partly upon input solicited from selected statf personnel who have had substantial contact and involvenent with Duke Power Company's licensing naterial. Please review the draft evaluation and provide

any concents you feel aopropriate. All conrents receivec by May 23, 1983 will be considered in the final report.

I To assist you with.the review and corrent, the following persons were contactea for input: R. Pichumani and H. Chokshi, SGEB; J. Pulsipher, CSE; D. Terao, SER; rt. Hum, flTEB; H. Walker, EQ3; A. Singh, ASB; J. Lazevnich and R. Giardina, i PSB; F. Burrows, ICSG; E. Branagan, RAB; J. Boegli, HETB; J. Spraul, QuAB; 8305250211 830518 PDR ADOCK 05000413 G PDR l omer > ...................... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........................ ...................... . . . . . . . . . . . . . . . . . . . . . . . . . . . . IsuRuame> ........................ ...................... . . . . . . . . . . . . . . . . . . . . ...................... . . . . . . . . . . . . . . . . . . . . . . ........................ ...................... 1 l DATE ) ........................ ....................... ........................ ........................ . . . . . . . . . . . . . . . . . . . . . . ........................ ..................... 4RO FOT.M 318 (10-80) NRCM 0u0 0FFiClAL RECORD COPY usam ini-w.no

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T.. Deripsey and F. Akstulewicz, AEB; Y. Hsii, CP9; S. Diab, P.SB; - J. Buzy, LQB; F. Liederbach, PSRS; G. Sfoonds, EPLB; D. Kubicki. CbEis and C. Gaskin, MSS.

                                                                                                                                                                      .b Kahtan N. Jabbour, Project rianager Licensing Branch tjo. 4, DL                                               -

Enclosures:

1.- Catawba Evaluation ilatrix

         .        -2. kRR Input for SALP Report O                    DISTRIBUTION
                    -Docket File 50-413, 50-414-NRC PDR PRC System LBf4 r/f EAdensam                         CGaskin                                                                                                                                   .

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RGiardina l- FBurrows E8ranagan JBoegli l- JSpraul

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Attachment 9a l

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U NIT ED STATES OF A MERIC A NUCLEAR REGULATORY COMMISSION

                                                         .         ,;.                             n             u i.. . . ::                                 -
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BEFORE THE A T O MI'C S'A F E T Y AND LIC E N SIN G BOAR D y, ,

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In the M a tt e r ['ol - -

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i DUKE POWER, COMPANY, et al. ) Docket Nos. 50 413

                                                   '                                                                                               ~

4 1. 7. ., . ) 50-414 (Catawba Nuclear Stations, ) U ni t s .,1 a n d. 2) . .

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                                                                                                                                                     .                           JULY 12, 1983 3:15 P. M.
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n l ., l . .sc . . t DEPOSITION OF: WIL LI A M S. LEE hlh Evelyn Berger Associates STENOTYPE REPORTING, SERVICE P.O. BOY 19444

Loo . Direct , 12 1 C on st ruction at the time you became S e nio r Vice 2 Pr e sident ? 3 A There was an In s pe c tio n Program as we-4 have had at our othe r plants. 5 O Do you remember when you named it 6 Quality Assurance? 7 A We had, for example, test laboratories 8 to test the ma te rials that we us e d in c on s t ru c tion. 9 We had in s p e c to r s to test the slump of th e concrete 10 and placing of the concrete and that sort of thing 11 before a uclear came along. 12 We did that with our other plants. 13 Q All right, sir; I directed your attention to 14 the footnote, and at Page 165 of the report that I 15 have, a gain, Footnote 11, that r e fl e c t s this obser-16 vation: -- 17 The Staff's approval of the A p pli ca nt 's 18 current Quality A s su ranc e Program was with the 19 u n d e r s i:'a n d i n g ther e would be a separate Corporate 20 Assurance Manager, th at position being fill e d by the 21 A pplic a n t's Vice P ra s id e nt, E n gin e e rin g and "2 C on s t ru c tio n. 23 Who was acting in Du k e's c a pa cit y; that 24 would have been y o u r s e l f' ? 25 A Yes. I a s sume. EvtLYN $. BERGER

                                      @m0@im @GemT_ R3P8RTBO

l i Loo - Diroet 13 l I l 1 Q He will have the duty and r e spon sibility to 2 assure that the separace Corporate C u ali t y ussurance 3 Program be effected in a timely manne r; otherwise 4 the und e r s ta ndin g of the separate Quality Assurance 5 function will not be very meaningful. 6 We b e li e v e the Corporate Mana g e r of the 7 QA po sition should be fille d as quickly as possible, 8 to commence January, '73, as being the outside 9 li mit s for s uc h a ctio n. 10 In that connection, sir, let me ask you to 11 take a look at another document dated August 13, 1973; 12 and fi r s t as k you to take a look at t h a t- (in dic a tin g) . 13 Can you identify i t, sir? l 14 A Do you want me to read the whole thing ? 15 Q No, sir; I wanted you to exa mine it. Havo 16 you seen that befo re ? 17 A I don't r e call havin g seen it. 18 Q I want to dir e c t ' you r attention t o' a couple l 19 points. T hi s is i d e ntifi e d as titled, "Saf ety Evaluation 20 R e por t, C atawba Nuclear S t a tio n, Units 1and 2, 21 Qualit y A s sura nc e, " memorandum to R. C. DeYoung 22 f rom R obe rt L. T e d e s e o- at the then, I a s sume, A t o mi c l 23 Energy Co mmi s sio n. 24 I wanted to direct ~ your attention to what 25 has been indicated in the face of this report as p en di ng Evrtym S. Brnorm

                                   ".Yn5N.S((a$.".,'" _                                     )

l l Loo - Diroct 14 l I 1 qu e s tion s , what I will charac te riz e as pending , l 2 qu e s tion s , regarding the company's C ua li ty Assurance 3 P ro gr am. . l

                                                                                                        )

4 T he o b s e r va tion is the pro gram acc eptable 5 for D e sign and C o ns truc tion s u bj ec t to the following  ; 6 items: 7 First, clarification of the independence, 8 r e s po n s ibiliti e s , au tho ritie s , and s pe cific routine

        ?   duti e s of the Electrical,                   M e c ha ni c al. Vi e l di n g / N D E ,

10 and Civil Inspectors. 11 What is your understanding of the AEC or l 12 NR C 'S que s tion re garding your Quality Assurance 13 Program in that regard? 14 A My und e r s tandin g only comes from reading 15 the documents attached to the back.of that, which is 16 the Safety E valu ation R e po rt, it s elf; and in that docum . 17 ment they conclude that the o r g ani z a tio nal independence 18 of the ins pector s you cited was s atis f ac to ry, and 19 th e i r r e po rtin g and functioning were s a tis f a c to r y based 20 upon their o b s e r va tion s in the field of what was goint 21 on. 22 But what th e y wanted was documentation i 23 of what the situation was f rom the A p plic an t s . What 24 that is refe ria; to is documentation of what you 25 found. Evt LYN $ $[RGER orne;at couet atpontra

                                                               ~.

Loo - Direct 15 1 O What was the basis of your under standing I 1 l 2 of the que s tio n ? V, h y do they raise that que s ti on ? l 3 A At the t i m e- th e y Iwant e d do cum e nta tio n of l l 4 everything; it was also at a period in which we had ) three separate groups of NRC r e vi e win g three s eparat e 5 6 Projects; and all of a sudden we f ound that the three 7 separate NRC groups were ma kin g interpretations of 8 A P P e n dix B with respect to Qu a li t y assurance o r gani-9 z ation s s o mewha t diff e re ntly f rom one another. 10 Q Slow do wn a second. Three diff e rent pla nt s 11 all under cons truc tion at the same time ? 12 A Yes. 13 O So c o nflic tin g inte rpre tations among the 14 three plants based on who it was the Commis sion wa s ) l 15 looking at? l 16 A Yes, but there were details of where is the _ 17 d o c u m e n t a tio n of where those inspectors report and l i 18 someone might ask one que stion and another person 19 ask another diff erent type of que stion, and we were 20 getting rip s awed by requests for in f o r m a tio n from 21 three groups. 22 O Do you have an understanding of why the 23 qu e s tion regarding documentation of the r e s p o n s ibili t i e s 24 du tie s , et cetera of in spectors was raised at C a t a w b s. ? 25 A Because, as I understand it from the EVtWM $, B(RGER

                                      "*", * ?."L"E "'"

Loo - Diroct 16 1 e nc lo s ur e, it wa s not clear f ro m what was said in 2 the SAR, where they reported or what they did; so 3 the NRC made some fin din g s and found out where th e y 4 reported, and that was okay, but let's get a document .. 5 Q And is it your un de r s ta ndin g that that item 6 was s uc c e s s fully corrected? 7 A Yes, !t was, but it was decided to correct 8 it in a pion e e rin g sort of way. 8 Q How is that, Mr. Lee? 10 A We wrote a ge ne ric Quality Assurance 11 document. 12 Q How do you unders tand that and what did 13 you run into ? 14 A W ell, we wanted to h ave not only inside - 15 our company but in a ll diff er ent boards and organi-16 z a tion s that wer e r eviewin g Quality A s surance, NRC, -- 17 AEC, Staff H e a rin g Boards, O p e r atin e License Hear-18 C o n s t ruction Permit H e a ri ng s going on ; ings goin g on, 19 and we wanted to have a unif o r m, throughout the 20 c om pany, nuclear program, a Cuality Assurance l 21 Program and procedures that everyone und er s too d. 22 Q Is that in s om e way to address this ripsaw 23 expe rienc e ? 24 A Yeah, at Oconee and h: c G uir e we were l 25 getting dif f e r e nt reactions and diff e rent r eque s t s; an d i EmVN $ SERGER l OFFICIAL COURT REPORTER U. S. OtSTRICT COURT _ _ _

Loo - Diroct 17 1 so we file d the document saying this is the way we 2 are going to march, and we got the NRC to review 3 that in its entirety and to approve it; and we said ,

           ,   4   now apply that to Docket Number so and so and so 5   and so; and that is all the nuclear plants, and that 6   resolved such que s tion s as you have cited here,                      lack 7   of documentation as to where s omebo dy r e p o r t s ./ '

8 O Would this be g e n e r ally called your topical 9 report on Quality A s surance and the various amend-10 monts to that ? 11 A Y es. 12 O W ould that have been, was there a n yt hi n g 13 out of order r el a tiv e to the way other lic en s e e s 14 handled that que s tion ? 15 Do you know ? 16 A To my r e c oll e c tio n we were the fir s t - 17 A pplic ant to file a topic al re po rt. 18 C W ha t was the p ra c tic e of other c on s t ructio n s, 19 if you k no w ? l 20 A Just put it in a Chapter 17 and every PSAR l 21 l and FSAR, and the problem that we found there, for 22 some reason you were in the r a t c h e tin g process, you l 23 change one Chapter 17 f o r one piant at one stage and 24 try to change all the ather:. 25 W e found ourselves with inconsistent Evrtyn S. BERotR OFFICIAL COURT REPORTER U. S. DISTRICT COURT

• l Los - Diroet ,

18 1 Chapter 17's, and we decided to go to pic al. I b elie v e 2 it was Chapter 17, 3 Q It says Chapter 17 here. . 4 A W ha te ve r. l 5 Q A ll right, sir: th re is a reference to a ' 6 need for documentation of D u ke 's definition of the 7 terms " A dminis t ra tive R epo rtin g" and " F unc tion al 8 R e porting. " 9 How about giving me your und e r s tan ding of 10 what the s i g nifi c a n c e of those terms were as you 11 used them? 12 A As we f ormed the Quality Assurance D e pa rt. 13 ment as a separate and independent entity, re m embe r 14 I was wearin g two hats. Vice President of En gin e e rin g 15 and C on s t ru ctio n and the Corporate Quality Assuranco l 16 guy. .- 17 In order to get the technical aspects of 18 Quality Assurance under way. I did not want at the 19 outset to set up a separate p a y r o ll, separate va c a tio r. 20 records and se parate lines of ad mini s tr ative report-21 ing and personnel record keeping and tim e sheets a n c. 22 wha t n o t, but I wanted functional au tho rit y, that is 23 the procedures, th e technical asoects, what was 24 acc e ptable end not accaptable, enme under my aut ho ri ty: 25 but I wanted these p e o ple to stay for a time on the EvtLYN $ stRGER OFFICIAL COURT REPORTER

l l Loe - Diroct 20 l 1 bring the Quality Control Ins pector f u n c ti o n under the 2 Quality A s suranc e Department for both functional / 3 a dminis trative purposes until rathe r late in the g a yn e , 4 T ha t is for a slightly diff e r ent reason the: e. 5 The a dminis trative and functional c ontr ols are some- l 6 what dif f e r e nt than I described back in my ti m e . 7 O What I want to understand, sir, if yo u 8 kno w, were those, the terms as you u s e d them, used 9 in the same manne r to r e fl e c t the di s tinc tio n and 10 r e s ponsibility and supervision of inspectors later on? 11 A G enerally so, the in s pe c to r s later on who 12 were in the C o n s t ru c ti on Department inspected to the 13 c rit e ria and procedures e s tablished by the Quality

                                                                    ~

14 Assurance Department. 15 The a d mini s tr ativ e control of ins pector s in 16 the C on s truc tion Department also included s ch e dulin g 17 their wo rk. 18 T he C on s t ruction D e pa rtm ent knew be st l 19 what was going to be don e next. 20 Q And was that s ch e dulin g r e s p o n s ibili t y or 21 authority, that was in addition to the r e s po n s ib ility 22 that would have been included as you us ed the terms

23 "a d mini s tr a tiv e" and " functional" b e f o'r e ?

24 A R e ally, it would b'c embraced in a d mi ni- l 25 s tra tiv e r e s pon sibility in either c r. s e . EvtLYN $, BERGER l _ QFFICIAL COURT REPORTER l 11 1 Of t' Af rT Entf RT

Loo - Direct 21 1 Q And then I interrupted you. You s tarted 2 to tell me why you thought there was a sig nifi c a nt l 3 diff e r en c e in the r ea sons why the ins pector s were , 4 o r g aniz a tio n ally kept that way. 5 A W ell, the main dif f e re nc e in my r e c olle c ticin ' 6 was that with re spect to the Catawba inspectors who. 7 were on the C on s truc tion Department organization and 8 then mo ve d to the Quality assurance Department 8 o r g anis a tio n, th os e inspectors were under my super-10 vision f or all purpo s e s. 11 Back in the early days of the Q u ali t y 12 Assurance D e pa r tm ent, Mr. Parker had assigned me 13 as Quality Assurance Manager, and this gave me 14 f un c tio n al authority for Quality A s surance Mana ge r s 15 of the c om pany, but a d mini s t r a tiv e management of 16 those people was in some cases vested, the depart- - 17 ments that did not report to me, was ves ted in other 18 people who reported separately to Mr. Parker. 19 So in that way, there was a diff e re nc e in 20 my scope of f un c tio n al and a d minis tr a tive mana ge-1 ment authority. 22 Q A ll ri g h t , sir; Page T wo of the document 23 that was attached to the memo, we have ref erred to 24 the AEC c omm ent s from the draf t of the SER for 25 Quality Assurance at C a t awb a. l EVELYN S. stRGER I 0FFICIAL court REPORTER U. S. OtsTRICT COURT

Loo - Diroet 22 1 "At the present time the positions of 2 Corporate CA b aager and :le ni o r Vice President for

    . 3  Engineering and C o ns t r uc tion are filled by the same 4  individual. "

5 "The Staff que stioned the a c c e p ta bili t y of 6 this o r g aniz atio n al a r r an g e m en t, wherein the same 1 7 individual has multiple dutie s, to eff ec tively imple-8 ment the QA P ro gram. " 9 "Asa re sult of extensive discussion of 10 this m atte r, DPC has committe d to appoint a f ull- ti me 11 Corporate QA Manager by no la te r than July, 1974, 12 and has otherwis e clarified delineation of s t a f fi n g an d 13 a s signment s that appear to safeguard agains t dilution l 14 of QA eff ort during this int e rim period of organiza. 15 tio n. " 16 First, why wa s it de te rmin ed, how did you - 17 understand the d e t e r min a tion to vest you with the 18 dual r e s ponsibility of QA Manager, Corporate CA 19 Manager; as well as Senior Vice President for 20 Engineering and Con s truction ? 21 A I told Mr. Parker it was important, and 22 that either he did it or he would designate me or 23 A u s tin T hie s to do it; and I recommended be do it 24 to me. 25 Q A ll right, sir. You thought it was too EvtLYN $, BERGER OFFICIAL COURT REPORTER U. S. DISTRICT COURT

Loo - Diroet 23 1 important to assign to someone els e ? 2 A Yes, and I thought I was, because of m'y i 3 particular background I was more q u alifi e d to give,it 4 my attention than, frankly, was he. , 5 Q What wa s M r. T hie s ' area of responsi-6 bili ty ? 7 A His area of re s ponsibility was Op er atio n s. 8 T hi s was in '73/'74, when we had s even units in 9 various stages of c ons truction, of which one, then 10 two, then thre e, wer e operational; and we had six 11 more c o m mi tt e d , and mo s t of the effort wa s in D e sig n 12 and C on s t ru c ti on in terms of number s of people 13 involved in Quality A s suranc e. 14 Q And you, being the C o n s t ru ctio n Engineer-15 in g person more appropriate to handle that? 16 A T h at 's correct. .- 17 Q Did you say M r. Parker has a choice, eith.nr 18 he takes it or he d ele g a t e .it or assign it to one who 19 reported to him and tell all the others that report to 20 him this guy has it? 21 A Yes. 22 O A n d ' .V r . P a rk e r 's po sition at that tim e ? 23 A In 1971, he was made Executive Vic e 24 P re sident and General Manager. At some point the re - 25 af te r he was made P r e sid ent and Chief O p e r a tin g Evetyn s. erRa:R OFFICIAL COURT REPORTER U. S. DISTRICT COURT

Loo - Diroet 24 1 O f fi c e r ; I don't remember e xa c tly when. 2 Q A ll right. l l 3 A His scope did not change, his title c h a n g e c! . ' 4 O But in any event the scope of his responsi. 5 bili ti e s were beyond C on s t ru ction and Engineering 6 and O perations ? 7 It inc lu d e d all the a c tivitie s of the c o mp art y ? 8 A All the operational activitie s of the c o m p art y, 9 r e tail and whatever. 10 Q And what of tho s e areas was M r. P ar ke r's 11 background? 12 A Mr. Parker spent th e fir s t two dozen year 13 of this company with Mill Power Supply Company in 14 Purchasing; and he joined Duke Power in about I thin'c 15 1962. 1 16 Q His background wa s n't in C on s t ru ctio n ? 17 A No, he was a graduate Electrical En gine e r l , 18 but his professional career had lar gely been in 19 P ur ch a sin g and Sales. 20 Q Were you a pa rtici pa nt in th e extensive 21 dis cu s sion s that the AEC had reference to in this 22 document co nc er nin g the a s signment of this function; j 23 do you r e c all ? l 24 A I do n't recall, Ur. G uil d . 25 O A ll ri gh t, the point that I raise or appear EvtLYN $. BERGER I 0FFICIAL COURT REPORTER l u3 DrSorrC9 COURT

Loo - Diroet 25 4 1 to raise here is wh e th e r or not there was a Jil u tio n 2 of the QA effor:s, whe th e r or not a person's multiplc 3 duti e s , such as you had at the time, could e f f e c ti v,e ly 4 implement the QA P r o g ra m. 5 A Are you reading or interpreting their 6 words? 7 Q I' m doing a little bit o f both. I would be 8 happy to h a v.e you interpret it, you r s elf. I am try-9 ing to put it in a nutshell and get you to interpret i t. 10 you r s elf. 11 Do you r e c all it in a nu t s h ell if you don't 12 r e c all the actual dis cu s sio n ? 13 A I don't remember the dis cu s sions ; I 14 remember that to start up s o me thin g originally new 15 and e s tablis h the procedures and r equir e me nt s and 16 whatnot is a tough a s signment. . 17 I wanted to be p e r s o n ally involved in g e ttin g 18 that done, and in that I would have the opportunity to 19 in t e r f a c.e with my people to see how they contribute d 20 to the efforts and see what their levels of compet ency 21 were; so I elected to carry this more myself fo r a 22 ti m e and put it to g e the r. 23 And in that process. I was able to id e nti-24 fy certain oorsonc vhoso experience and c o mp e t e n c e 25 were demonstrated: and then we developed a depart- 1 EvtLYN $. BERGER

                            . OFFICIAL COURT REPORTER n t nttTatt f*nneT

Loo - Diroet 26 1 ment and named a full-time person. 2 Q All ri ght, sir; h a'd it been your plan from 3 the start to have s om e on e do this work, head the 4 Quality Assurance Department f ull t i m e, independent of 5 you? 6 A Yes. 7 Q Vi a s that m ade clear to the A EC; do you 8 know? 8 A I don't r e c all, I'm sure it was, that at 10 some point in time that w o uld be it, but I wanted to I 11 have p e r s o n al hands on involvement in putting it 12 to g e th e r. 13 One of the problems at that ti me was, and 14 it was f rom inside the company, this was i m p o r t a nt' 15 to interface with the NRC on all lic ensin g matter s, 16 For Oconee had been transferred to what was called - 17 the Steam Department, and NRC was a s kin g a lot of 18 qu e s ti o n s about Quality Assurance of the Eteam De-19 partment. 20 The M c G uir e project was in the cons truction 21 p e r mi t stage. The Catawba p r oj e c t was in an e a rlie r 22 phase of the c on s t ru c ti on p e r mit stage. 3 I was the Senior Vice P r e sident of En gi-24 neerin g and Co ns t ru c ti o n and a member of the noard 25 of Directors. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ . _ - MNE

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I I Attactuwnt k. Item 10 of-Attachment 1 to April 12, 1983, Duke Power Company Letter,

                   " Hand Uritten Notes from (JC and QA Inspectors which Set
                                              .Forth.

Their Specific Problems and Concerns." . A.- Dean Bentley B. January. 19, 1922 Notes of T. A. Gardner regarding N.C.I. Numbers 62S9 and 6247. C.- August 6 and 12 and September 3,1981 Notes of William H. Burr Concerning Cetauta NCI-Nos. 12682, 12420, and 12454 D. Memo from 8cyce Coffin. E. C.D. Crisp. F. B. Deaton. G. Harold Eubanks (regarding NCI 78SD). H. A.S. Gantt. I.. V.C. Godfrey (dated 1/20/62). J. Larry Jackson. K. Richard Jones. L. January 14, 1982 Remo from Kenneth E. Carriker to Bob Morgan l initiating the Employee Reccurse Procedure. I G. Ronald Kirkland. N. Notes of John McCoy. D. Notes referring to John Rockholt, author unknoun. P. Ransom Sims. Q. Mickey Standridge. R. .Lindsay Hovis. S. Beau Ross. T. J.R. Bryant.

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Page 1 of 1 The redlographs of this weld were reevaluated and the Internal surface was

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                                                                              - Att chm:nt # 11     ,
   .8,(peuq'o,,

o UNITED STATES NUCLEAR REGULATORY COMMISSION

                                                                         .                          l f
                 .. ,I                   WASHINGTON, D. C. 20$55
      % ,,,, #                             May 19,1983 Docket Nos. 50-413 50-414                                                                 .

Ms. Billie P. Garde. Director Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W. IN RESPONSE REFER Washington, DC 20009 TO F01A-83-200

Dear Ms. Garde:

This is in partial response to your letter dated April 21,1983, in which you requested, pursuant to the Freedom of Information Act, copies of any and all agency records and information related to and/or generated in connection with an investigation at the Catawba Nuclear Power Plant in South Carolina in " Concerns of Welding Inspectors (

Reference:

Case 2G022).'" You stated your rewest includes any and all records and information concerning the allegations by the site QC welding inspection personnel, including inspections or investigations by any and all regional or Washington divisions, offices or sections of the Nuclear Regulatory Comission. . In partial response to your request, copies of the documents listed on Appendix A are being placed in the NRC Public Document Room,1717 H

Street, N.W., Washington, DC where they will be available for public l inspection and copying. Copies of the documents released in response to this request are also being placed in the NRC's Catawba facility Local i

Public Document Room located at the York County Library,138 East Black ! Street, Rock Hill, SC 29730 Ms. Mary Mallaney, Assistant Reference Librarian.

 ,         Portions of documents one through eight of Appendix B have been deleted in order to withhold information which would directly or indirectly reveal the identity of confidential informants. Because disclosure of         ,

this information would disclose the identity of a confidential source, l it is being withheld from public disclosure ' pursuant to Exemption (7)(D) l of the Freedom.of Information Act (5 U.S.C. 552(b)(7)(D)) and 10 CFR 9.5(a)(7)(iv). I Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been determined that the information withheld is exempt from production or , disclosure, and that its production or disclosure is contrary to the i public interest. The persons responsible for this denial are the undersigned and Mr. James P. O'Reilly, Regional Administrator, RII, Atlanta, Georgia. [

Ms. Billie P. Garde , This denial may be appealed to the Comission's Executive Director for

   . Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the                      .

Executive Director for Operations, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial FOIA Decision." A few additional documents are under review and we will communicate with you again concerning their disposition. Sincerely,.

                                                       /
                                                     ;         '. , - f
                                                   ,           .u& 2

[b J. M. Felton, Director Division of Rules and Records Office of Administration .

Enclosures:

As stated S 8 I l l

UNITED STATES 8  % NUCLEAR REGULATORY COMMIS$10N - g wasumorow.o.c. nom ( rues ,e

    ~ Docket Nos. 50-413                                                          g g g g3 50-414 Ms. Billie P. Garde. Director                                                              '

Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W. IN RESPONSE REFER Washington, DC 20009 TO FOIA-83-200

Dear Ms. Garde:

This is in further response to your letter dated April 21,1983, in which you requested, pursuant to the Freedom of Infonnation Act, copies of any and all agency records and information related to and/or generated in connection with an investigation at the Catawba Nuclear Power Plant in South Carolina in " Concerns of Welding Inspectors (

Reference:

Case 2G022)." You stated your request includes any and all records and information concerning the allegations by the site QC welding inspection personnel, including inspections or investigations by any and all regional or Washington divisions, offices or sections of the Nuclear { Regulatory Comission. ' In further response to your request, copies of the documents listed on Appendix A (Continued), are being placed in the NRC Public Document Room (NRC PDR),1717 H Street, N.W., Washington, DC where they will be available for public inspection and copying. Copies of the documents released in response to this request are also being placed in the NRC's Catawba facility Local Public Document Room (LPDR) located at the York County Library,138 East Black Street, Rock Hill, SC 29730 Ms.-Mary Mall.aney, Assistant Reference Librarian. Any additional documents responsive to your request, other than those referred to below, are already in the PDR or LPDR in files for Docket Nos. 50-413 and 50-414. The names and personal identifiers of certain individuals have been deleted from documents 11, 12, 13, and 25 of Appendix B. The deleted names are of individuals who were confidential informants who provided information during an agency investigative effort. Because disclosure of this information would disclose the identity of the confidential sources, it is being withheld from public disclosure pursuant to Exemption (7)(D) of the Freedom of Information Act (5 U.S.C. 552(b)(7)(D)) and 10 CFR 9.5(a)(7)(iv). A copy of the remaining documents listed on Appendix A and the nonexempt portions of documents 11,12,13, and 25 of

j. Appendix B are being placed in the NRC PDR cnd LPDR.

7 _. Ms. Billie P. Garde f An additional group of documents is responsive to your request. The l group consists of nine attachments comprising 38 pages to an undated memorandum to Carl E. Anderson from P. K. VanDoorn. The memorandum was , addressed as document 1 of Appendix B in our May 19,1983 response. ) These attachments consist of handwritten notes of internal staff sumaries i of the interviews and concerns ~ expressed by confidential infonnants during an agency investigative effort and supporting documentation provided by the confidential informants. These documents are being withheld the Freedomin their entirety pursuant of Information to Exemption Act (5 U.S.C. 552(b) (6)6and and(7)7(C)(and c) and D))(D)(of and 10 CFR 9.5(a)(6) and (7)(iii) and (7)(iv) because it would not be in-the public interest since disclosure would constitute a clearly unwarranted l invasion of personal privacy, and would identify confidential sources. ' The bases for withholding this group of records are as follows: First, the names of the confidential informants, the names of the other persons involved in reported incidents such as supervisors or co-workers, and the numbers of reports containing the allegations and other identifying  ; information have been withheld. This has been done to protect the. ' identity of our confidential sources or to protect the privacy of co-workers or supervisors involved in reported incidents. Second, copies of handwritten notes and supporting documents provided by the infonnants have been withheld since both the handwriting itself and the description of incidents and individuals could be compared with information available ( to the public in Docket Files 50-413 and 50-414 at the NRC PDR ori these ! sarae incidents and reports leading to the identification of the confidential informants. . Third, internal staff summaries of the interviews and concerns have been withheld. .Since virtually all the incidents and i reports disclosed by the informants and referenced or described in these

summaries are also referenced or described in similar terms in the Duke .

Task Force Report relating to the welding inspectors' concerns, the descriptions, names, numbers, and the number of incidents discussed i could be used to identify the informants. Disclosure of the contents of the allegations and copies of related documents (which are in fact readily available to both Duke Power Company and Palmetto Alliance and in the NRC PDR) would not, therefore, be in the public interest because it would lead to disclosure of the infonnants' identities in a situation where assuranceiof confidentiality was given. In fact, all the relevant information, save the identity of the confidential informants, is publicly available. , Pursuant to 10 CFR 9.9 of the Commission's regulations, it has been determined that the information withheld is exempt from production or disclosure, and that itsl production or disclosure is contrary to the public interest. The persons responsible for this denial are the undersigned and Mr. James P. O'Reilly, Regional Administrator, RII, Atlanta, Georgia. l ( l

_ _ - - . - . = - - -_- ---- ---

            .                                                                                                                                                                   )

Ms. Billie P. Garde ( This denial may be appealed to the Commission's Executive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must,be in writing, addressed to the - Executive Director for Operations, U.S. Nuclear Regulatory Comission. - Washington, DC 20555,:and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial F0IA Decision." l

                                   .          s..       ,

Sincerely, s g J. M. Felton, Director Division of Rules and Records Office of Administration

Enclosures:

As stated

                                                                                  ,Mg epir-
                                                                                          '~

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Appendix A

       .g

• F01 A- 83-200

      .L ,

s ( 12/8/81 - Log, handwritten (1 page) 12/16/81

2. 5/18/82 - Notice of Significant Licensee Meeting (2 pages)

3. 5/25/82 Presentation for IE/ REGION II, Resolution of Inspector Concerns, Catawba Nuclear Station (15 pages)

4. 7/15/82 Memo to G. W. Grier from C. N. Alexander, Jr. re: Status of Welding Inspector Non-Technical Concerns w/ enclosures (19 pages)

5. 7/27/82 Memo to Dance from Bryant,

Subject:

Catawba Prehearing Contentions-Chronology (3 pages) _

6. 7/30/82 Memo to D. G. Eisenhut from R. C. Lewis,

Subject:

Contentions Expressed at the Catawba Prehearing in York, South Carolina, on January 11-12, 1982 (14'pages)

7. 9/30/82 Letter to H. B. Tucker from R. C. Lewis,

Subject:

Report Nos. 50-413/82-21 and 50-414/82-19 w/ enclosures (21 pages)

8. Undated Memo to J. Y. Vorse from P. K. Van Doorn,

Subject:

Allegations Concerning QC Welding Inspection at Catawba Nuclear Station (Case No. 2G022) (1 page) 2/14/83 Letter to H. B. Tucker from H. C. Dance

Subject:

Report Nos. 50-413/82-33

• and 50-414/82-31 (7 pages)

10. 2/23/83 Memo to G. E. Johnson from C. E. Alderson,

Subject:

Documentation of Allegations: Duke Power Company, Catawba Nucicar Station (1 page) l 11, 2/28/83 Memo to File, by G. W. Grier,

Subject:

Catawba Welding Inspector Concerns, Completion of (2 pages) 12, 3/4/83 IE Presentation to ACRS on March 4,1983 (5 pages)

13. 3/14/83 Letter to J. P. O'Reilly from H. B. Tucker, re: RII:PKV 50-413, 82-33; 50-414/82-31 (1 page) ,

l 14. 3/17/21 Memo to K. Van Doorn from J. M. McConaghy,

Subject:

Welding Inspector Concerns NCI 9092- Dome Pitting (92 pages) , 15. 4/20/83 Palmetto Alliance Press Release (1 page)

16. 4/21/83 List-Case Chronology, File Wmber 2G022 (1 page) ,

17. Undated News article by Jack Horan. Observer Staff Writer, titled: Group Alleges Duke Records falsified (1 page)

Undated Report -Final Report of Task Force Effort to Evaluate Technical Concerns of Catawba Welding Inspectors - Volume 1 - Task Force Program Summary - Prepared by L. M. Coggins, et al . (42 pages)

a 2

       ~

19. Undated Report-Final Report of Task Force Effort ~ to Evaluate Technical Concerns of Catawba Welding Inspectors - Volume II - Technical Evaluations

      .{ and Verifications-Individual Concerns (452 pages)                                                                                                                                                         ,

20. Undated Handwritten Statement by Dean Bentley - Things that concern me most about the present condition of the QA, QC Progpam (2 pages) .

21. 10/26/79 Handwritten notes (4 pages) to 8/19/80

'.72. Undated Report, handwritten, by JRB - Lack of Support for the QC Welding Inspectors and for the QA Program (12 pages)

23. 11/26/79 Nonconforming Item Report, Serial No. 6918 w/ attachments (7 pages)

E,4. 3/11/80 Nonconforming ' Item Report, Serial No. 7514 w/ attachment (2 pages) -

25. 7/25/80 Report - ANSI B31.1 Weld Inspection Report - Drawing CN-lWL-912 Weld Number lWL912-25 w/ attachment (2 pages)

26. 7/25/80 Report - ANSI B31.1 Weld Inspection Report - Drawing CN-lWL-912; Weld Number-lWL912-26 w/ attachment (2 pages) ,

27. 8/19/80 Nonconforming Item Report Serial No. 9258 (1 page) 28 8/20/80 Nonconforming. Item Report, Serial No. 9264 (1 page)

29. 8/20/80 Nonconforming Item Report Serial No. 9266 (1 page) a

30. -8/22/80 Nonconforming Item Report, Serial No. 9291 w/ attachments (5 pages)

31. 8/22/80 Nonconforming Item Report, Serial No. 9293 (1 page)

32. 11/6/80 Nonconforming Item Report, Serial' No.10013 ( l page) 33 12/7/81'Nonconfoming Item Report, Serial No. 13540 (1 page) ,

34. 11/19/81 Nonconforming Item Report, Serial No.13455 w/ attachments (6 pages) 35.

10/7/81 Nonconforming Item Report, Serial No.13053 w/ attachment ('2 pages) l-

36. .

12/12/80 Variation Nutice,. Serial No.14967 w/ attachment (2 pages)

37. 3/16/81 Nonconforming Item Report, Serial No. 11309 (1 page)

(18. 7/9/81 Nonconforming Item Report, Serial No. 12139 (1

             ' Weld Process Control Sheet, Weld.No. 2NC16-10 (1 page)page) w/ attachment:

19.

9/25/81 Weld Process Nonconforming Item Report, Control SerialSheet, No. 12139Weld No. 2NC16-15 (1 page) w/ attachment: (1 page) k

                        ,y., ,, - - .      ..- , - - ---. e   - - , .  ,

e-. - _ - . . . - . . , , , .- ,n, , . . -.,,-,- - - - - . - --. ,-,..,,- , . - - - , - - , ~ . - - - .

3

40. 4/8/81 Noncoriforming Item Report, Serial No. 11534 (1 paeal

[ 8/7/81 Duke Power Company Form - Exceptions or Alternatives to R-3A's, R-3A Serial No. 14052(1 page), w/ attachments, Variation Notice Serial No.14,052

         .(2 pages)

42. 7/6/81 Weld Process Control Sheet, Weld No. ICA67-ll w/ attachments (9 pages) -

43. 7/17/81 Nonconforming Item Report, Serial No. 12213 (1 page)

44. 7/21/81 Nonconforming Item Report, Serial No. 12239 (1 page) 4 5. -4/1/81 Weld Process Control Sheet, Weld No. 2NV373-3 (1 page) w/ attachment (1 page)

_46. 9/16/81 Nonconforming Item Report, Serial No. 12782 (1 page) w/ attachments (1 page)

 ' 47. 8/28/81 Weld Process Control Sheet, Weld No. ~1 nil 62-27 (1 page) w/ attachments. (4 pages)

48. 1/19/82 Handwritten statement by T. A. Baumgardner (2 pages)

49. 7/2/79 Nonconforming Item Report, Serial No. 6047 (1 page) 50 7/31/79 Nonconfirming Stem Report, Serial No. 6259 (1 page)

51. 8/6/81 Handwritten notes - unsigned (4 pages) 8/6/81-Nonconforming Item Report, Seiial No. 12420(2pages) 5{ *

53. 8/J2/81 Nonconforming Item Report, Serial No. 12454'(1 page) w/ attachment (1 page)

54. 9/3/81 Nonconforming Item Report, Serial No. 12682 (1 page) 55 Undated Handwritten Notes by Boyce Cauthen -- Lat.k of Support from QA (3 pages) 56 Undated Handwritten Notes by C. D. Crisp -- Concerns 1 through 6 (1 page)

   ,57. Undated Handwritten Notes by B. Deaton (1 page)

58. Undated Handwritten Notes by Harold Eubanks (1 page)

59. Undated Handwritten Notes Re: NCI 7850 by Harold Eubanks (1 page) a

60. 2/29/80 Nonconforming Item Report, Serial No. 7850 (4 panes)

61. 8/28/81 Handwritten Notes by A. S. Gantt (1 paDe)

62. Undated Blank Form (1 page) -

63. 2/13/79 Weld Process Control Sheet, Weld No. INV 309-1 w/attachnents (5 pages)

64. 2/12/82 Form QA-107A Revision 1 -- Personnel Exit Interview Documentation Form w/ handwritten report by V. C. Godfrey, Jr. (dated 1/20/82) (8 pages)

( I

4

     ~
       .,. 1/18/82' Handwritten Report by V. C. Godfrey, Jr. (1 page)

{ 7/30/80 Nonconforming Item Report, Serial No. 9085 (2 pages) .

67. 8/29/80 Nonconforming Item Report, Serial No. 9358 (2 pages)

     .68. 11/24/80 Nonconforming Item Report, Serial No. 10187(2pages)                                               *

69. 8/1/80 Nonconforming Item Report, Serial No. 9119 (1 page)  !

70. 2/29/80 Nonconforming Item Report, Serial No. 7850 (4 pages)

    '71. Undated Handwritten Report by Lindsey Harvey Hollis, Jr. -- To Whom It May Concern (3pages)

72. 1/18/82 Handwritten statement by R. W. Irby (1 page) '

73. 1/11/82 Memo to J. R: Wells & L. R. Davison from R. A. Morgan Re: Catawba 1-2, Management Procedure 8030-0003, Resolution of Technical Matters w/ attachments (5 pages)

74. 7/31/80 Nonconforming Item Report, Serial No. 9092, w/ attachments (8 pages)

75. 8/24/81 Nonconforming Item Report, Serial No.12549, w/ attachments (5 pages)

76. Undated Handwritten Statement by Larry D. Jackson (2 pages) -

( Undated Handwritten Statement by Richard Allen Jones (2 pages) 78 1/14/82 Memo to Bob Morgan from Kenneth W. Kerriker

Subject:

EMPLOYEE RECOURSE (1 Page) S ( - 79. 1/19/82 Handwritten Note to R. A. Morgan from Ronald Kirkland (1 page) ' 80.- Undated. Handwritten Statement by John R. McCoy (2 pages)

81. 11/30/81 Form 184 (5-76) Handwritten Notes re events on 2/27/81; 2/26/81; and 2/25/81 (2 pages - virtually identical)

82. 1/19/82 Handwritten Notes by G. E. Rose (18 pages)

83. '3/11/80 Nonconforming Item Report, Serial No. 7514 (2 pages)

84. 10/7/81 Nonconforming. Item Report, Serial No. 13053 (2 pages)

 < 85. 9/24/81 Form QA-107A Revision 1 -- Personnel Exit Interview Documentation Form w/ handwritten report Re: Weld No. IFW10-13 (3 pages)                                                              .

86. 4/1/81 Weld Process Control Sheet, Weld No. 2NV373-3 w/ attachment (2 pages)

87. Undated Handwritten Note by Ransom Sims (2 pages) 88(.~ ~ Undated Handwritten Note by Jerry Standridge (2 pages)

, 89. Undated Handwritten Note by unidentified author (2 pages)

                                                   '                                ~ ~
                                                           .i                             RE: FDIA-83-200      .

I APPENDIX A (Continued) ( 90. 12/20/82 Synopsis of Comments Concerning Welding Inspector Concerns (2pages)

     .              91. 1/7/83               Lette'r.to H. B. Tucker from H. C. Dance, 

Subject:

Report Nos. 50-413/82-32 and 50-414/82-30 (7pages)

 ~

92. 2/4/83 Letter to J. P. O'Reilly from H. B. Tucker, Re: RII:

PKV, 50-413/82-32, 50-414/82-30 (1 pag'e)

93. *4/8/83 Before the Atomic Safety and Licensing Board, Re:

                                            -Duke Power Company, et al, Catawba Nuclear Station
                                           - Units 1 and 2, Docket Nos. 50-413 and 50-414, NRC Staff Second Supplemental Response To Palmetto Alliance
     *.                                      First Interrogatories and Production Requests On Contentions 6 and 7 (Re: General Interrogations 4) W/ Attachments
          .-                                 (37 pages) Accession #8304110017 94.'     3/17/83         Note to Carl from G. E. Johnson re: Draft Discovery Response (1 page) 95.~     2/1/83         Memo to C. E. Alderson'from P. K. VanDoorn' 

Subject:

ALLEGATIONS CONCERNING QC WELDING INSPECTION AT CATAWBA NUCLEAR STATION (Case No. 2G022) w/ enclosure - List of Persons Interviewed (2 pages) '.

   .(

l l l f s 1 1

                         .                                                                                                            l
                   *THIS DOCUMENT CAN.BE LOCATED IN THE NRC PUBLIC DOCUMENT ROOM BY THE                                               l ACCESSION NUMBER
 .=m          - = =        .         __,ew.=,=-p     .-v=w a .   - . _ _ _ -   F F*****P'"*    -M*""?"**N--        . "'" - - -

R2: "F01A-83-200 APPENDIX B {,  ;. Undated . Memo to C. E. Anderson, from P. K. VanDoorn, subject: ALLEGATIONS CONCERNING QC WELDING INSP NUCLEAR STATION (1 page) 7 3/15/82 . Memo to C. E. Anderson, from P. K. VanDoorn,

Subject:

CONCERNS EXPRESSED BY A NUCLEAR STATION (1 page)QC WELDING INSPECTOR AT CATAWBA . 3 3/24/82 l.

SUMMARY

OF CASE NO. 2G022 INITIAL (2 pages) Mem

• 4' 5/18/82 Memo for Jack Bryant, from C. E. Alderson,

Subject:

CATAWBA - CONCERNS OF WELDING INSPECTORS (

REFERENCE:

CASE 2G022) (1 page)

5. _ Undated Handwritten Notes (2 pages) 6* 9/30/82 ,

Memo for Jack Bryant, from C. E. Alderson,

Subject:

l CONCERNS OF WELDING INSPECTORSCATAWBA (REF.- CASE 2G0 7* 2/22/83 Memo for G. E. Johnson, from P. K. VanDoorn CATAWBA NUCLEAR STATION (1 page) 8* 3/22/83 ,

 ;-(                        Alliance       First Interrogatories and Production R Contentions 6 and 7 (Re:

General Interrogatory 4) (8 pages) , e l l e I ( .

                                 -                -  <    .                  RE: FOIA-83-200 -

APPENDIX B (Continued)

              ~

9. Undated List: Questions.for Supervisors (1 page)

10. Undated List: Questions for Inspectors (1 page) , {

   ~                                                                                               '
                ** 11. U'ndated        Questions for Supervisors and Answers (by individuals)

(4pages)

                ** 12'. Undated        Questions for Supervisors and Answers (by individuals)

(10 pages)

                ** 13. Undated         Questio'ns forsInspectorr; and: Answers (by individuals)

(19pages)

14. 12/5/82 Note: File No. J-5, H-1, R-13 NCIR 7850 (1.page) e.

15. 12/5/82 Note: File No. R-64 (1 page) ,

16. 12/5/82 Note: File' No. R-20 (1 page) -

17. 12/5/82 Note: File No. R-32 (1 page),

18. 12/5/82 Note: File No. D-24, Weld 1KD 12-29 (1 page)

Note: ' File No. R-50, D-23 (1 page) ( 19. 12/5/82

20. 12/5/82 Note: File No. D-16 (1 page)

21. 12/5/82 Note: File No. R-62, D-15, NC1R 13053 (1 page)

22. 12/5/82 Note: File No. R-6, D-4 (1 page) l

23. 12/6/82 Note: File No. D-31, NC1R 13, 028 (3 pages)

24. 12/6/82~ Note: File No. D-30, Weld # INI 162-27 (1 pa'ge)

** 25. Undated Draft of Attachment A to document 93 on Appendix A l (3 pages) af

         ~

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                ** Names and personal identifiers deleted                                       ,

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                    ~'.
                                                                                                        ~        ~
    ,                                                                                             Attachment #12 u-       \
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COVER SHEET List of pages, forms, and attachments valid for this revision: REVISION

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1. PURPOSE This section establishes the method of controlling, reporting, marking, and resolving items found not to conform with Design or Quality Assurance requirements such as specifications, . design drawings, th}}