ML20003C755
| ML20003C755 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 02/19/1981 |
| From: | Parker W DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20003C748 | List: |
| References | |
| NUDOCS 8103180207 | |
| Download: ML20003C755 (6) | |
Text
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o DuxE. POWER COMPANY Powna Buturwo 422 SouTis Cacacia STszzr, CitAnwrTz, N. C. 28242 i,
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February 19, 1981 Vice Pogssorut TELCpao'et: AntA 7C4 SvzAm Paoowction 373-4083 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II l
101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re:
RII:ARH 50-369/80-38 50-370/80-20
Dear Mr. O'Reilly:
Please find attached a response to violation 369/80-38-04, 370/80-20-03 which was identified in the above referenced inspection report. Duke Power Company does not consider any information contained in this inspection report to be proprietary.
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'truly your,
a d, William O. Parker, Jr.
RWO:ses Attachment f
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Mr. Janes P. O'Reilly, Director February 19, 1981 Page Two WILLIAM O. PARKER, JR., being duly sworn, states that he is Vice President of Duke Power Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this response to IE' Inspection Report 50-369/80-38, 50-370/80-20 with respect to McGuire Nuclear Station; and that all statements and matters set forth therein are true nd correct to the best of his knowledge.
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d. ac William O. Parker, Jr.
e President Subscribed and sworn to before me this 19th day of February, 1981,
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1 PCGUIRS NUCLEAR STATICN UNITS 1 & 2 RESPOISE 'IO NOTICE OF VIOIATIOT USNRC INSPECTION REPORT NOS. 50-369/80-38, 50-370/80-20 DIS 054ICN OF VIOIATICN Me Notice of Violaticn cites inadequacies in identificatim and ccntrol of inter-fa s, coordinaticn amcng design organizaticos, and documentation of design inter-faces involving Duke Power Cmpany and EDS Nuclear, Inc. 'Ihe bases for the Viola-ticn are the following Significant Deficiency items:
lieport Nunber Report Date SD-369/80-20, 370/80-15 Novenber 26, 1980 SD-369/80-21, 370/80-16 Novenber 26, 1980 SD-369/80-21, 370/80-16 (supplement 1 of 1)
January 09, 1981 The deficiency itens and the subsequent Violaticn are cause for ccncern in both ccx:panies and have resulted in acticns by bcti to identify cause and take correc-tive acticns where required. 'Ihe following have been cmeluded frcm review actions whid are cmplete.
SD-369/80-20, 370/80-15 IfCATm m EDS review criteria were not reviewed and approved by Duke in advance. More direct ccntrol of EDS work nethods could have possibly prevented the prcblem.
Engineering review of affected support / restraint designs resulted in minor structural changes to a limited nunber of designs.
Sketch / Analysis Ioad Mismatch f
Duke verbal instructicns to EDS were not incorporated into Duke procedures and when EDS-originated support / restraint designs became Duke respmsibility, loads shcwn cn sketches were used for field revisicns. 'Ihis item represents failure of an individual to exercise followup within the Duke organization.
Adequate procedures existed for incorpora+.icn of the item if followup had I
been perfarned. Engineering review of.affected support / restraint designs resulted in minor structural changes to a limited nunber of designs.
RV Discharce Ioads An extraordinary effort, with face-to-fa neetings between Duke and EDS,was made to review the support / restraint load definition for the particular line which was the cnly cbject of this deficiency. An cbvious breakdmn in cmma-nicaticn resulted anyway, possibly because ccnclusicns were not docununted.
Engineering review of.affected support / restraint' designs resulted in minor structural changes to a limited nunber of designs.
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SD-369/80-21,370/80-16 IOCA pressure was not included in analysis due to failure of ELS and Duke to document the need to censider the load. Occurance of this prcblem is not directly related to interface or coordinaticn ccntrol between Duke aM EDS.
Engineering analysis and review of affected piping and support / restraints resulted in ecnfinnaticn of adequacy of existing piping and structural changes to a limited number of support / restraints.
SD-367/80-21,370/80-15 (Supolemnt 1)
Adequate procedures existed to protect against use of the criteria for dynamic loads other than seismic. A ccmuunicaticn breakdcun occurred in analyst inter-pretaticn of IICA effects, which-are not often encountered in criteria-analy::ed piping system. bbre direct, written instruction might ham prevented this prcblem. Engineering analysis and review of affected piping and support /
restraints resulted in ccnfirmation of adequacy of existing piping and struc-tural <:hanges to a limited ntmber of support / restraints.
Scre corrective acticns are indicated, however, it should be recognized that the resolution process for these items was largely documntaticn change. Ccrpared to
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the total secpe of support / restraint designs reviewed, only a limited ntmber required any structural change and most of these danges were minor.
CCFetLnVE iT1'ICNS:
Prcposed corrective acticns were discussed during the Inspection E::it Interview at Duke Offices cn Deceber 5,1980 and were again reviewed and sdaduled preliminarily at the Exit Interview at EDS Offices cn December 18, 1980. 'Ibese acticns and their ccmpleticn status are shown cn Attadaent A.
In additicn to items cn Attachment A, the following acticms have been ecmpleted:
1)
Duke QA Departnent ccmpleted an extensive audit at EDS-San Francisco Office (2/81).
2)
Duke Design Engineering c:Ipleted a technical audit of EDS-San Francisco piping analysis for FtGuire Unit 2 and identified no further concerns (12/80).
3)
EDS CA ccmpleted an audit of San Francisco Office as related to NBC con-cerns with design input tracking and the d.ecking process in analysis.
Corrective acticns have been identified and will be ccnpleted by 4/1/81.
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ATf10MNT A CORRECTIVE 1Cfl0NS - NCTriG OF VIOIATICN h ticn Calp/ Status EDS Acticns Date Duke Acticns
- 1) Write in-house design ncn-Ccmplete ~
- 1) : Define precise nethods for devel-Ccmplete ccnformanms cn each defi-cping and controlling in-house
(!CSRD 15.0) ciency item.
workplam procedures to cotply with existing On requirenents.
2; Ibview memos, correspcn-Carplete dence, and existing pro-2)
Ibview existing workplam proce-Ul-Ccrplete cedures and pla into dures, memos, etc. for conpli-U2-3/1/81 controlled proceddres.
an with results of Item #1; verify no problems with past work; 3)
Provide copy of existing Ccmplete '
revise prcmdures as necessary to procedures (inc1rding memos, ccmply with Itan i1; create new etc.) to Duke for review.
procedures ao nemssary.
4)
Ibview applicability of each Ccmplete 3)
Ibview and revise as nemssary Carplete
' deficiency item for all EDS specific technical procedures to clients.
prevent repeat of deficiency items.
5)
Ibvise existing procedures to Ul-Ccmplete 4)
Ibview EDS procedures (EDS Item Ccmplete incorporate Duke cuments U2-Ccmplete*
- 3); verify no prchlems with past (Duke Item #4); create new work; define changes required in procedures as necessary.
content and format.
6)
Inpletent results of Duke Ul-Nane Beguired 5)
Ibview and define, as necessary, Ccmplete Item #5.
U2-4/1/81 changes to nethods for ccntrolling (BCSRD 28.0)
EDS scope of work.
6)
Inplement results of Item #5.
U1-Ikne Beguired t
U2-4/1/81
- Scme acticus will be required when ecmpleting EDS Item 6) h=
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