IR 05000338/1987003
| ML20207T784 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/03/1987 |
| From: | Conlon T, Mcelhinney T, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207T767 | List: |
| References | |
| 50-338-87-03, 50-338-87-3, 50-339-87-03, 50-339-87-3, NUDOCS 8703240335 | |
| Download: ML20207T784 (7) | |
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unirsost:Tes NUCLEAR MEGULATOMY COMMIS$10N y'
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101 MAnttTT A :T MS ET, N W.
- ATL ANTA.GEOMOI A 30323 g
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Report Nos.:
50-338/87-03 and 50-339/87-03 Licensee:
Virginia Electric and Power Company P.O. Box 26666 Richmond, VA 23261 Docket Nos.:
50-338 and 50-339 License Nos.:
NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Conducted: february 9-13, 1987 Inspectors: CA 4G
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.d*4 6-V 97 A. B. R uT T ~ '
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AVi$bsvr?hi 33/S?
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T. McE1hinney f/
Date Signed Approved by: O
/W Y
8-98/
T. W ctnron, Section chier Date Signed Engineering Branch Division of Reactor Safety i
SUMMARY
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Scope:
This special, unannounced inspection was conducted in the areas of electrical discipline with regard to an employee concerns identified to the
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l Results:
No violations or deviations were identified.
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8703240335 870305 PDM ADOCK 05000338
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- E. W. Harrt11, Station Manager
- P. F. Driscoll, Manager Quality Assurance
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- G. Smith, Assistant Station Manager, Nuclear Safety and Licensing
- G. Harkness, Licensing Coordinator
L. Carter, Quality Specialist, QA Training Coordinator T. Abercrombie, Electrical Engineer D. Snudgrass, Startup Engineer M. Asburg, Startup Engineer Other licensee employees contacted included construction craf tsmen, i
engineers, technicians, mechanics, security force members, and of fice personnel.
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Other Organization
Engineering Personnel of Stone and Webster Co., Boston, MA by Telephone
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NRC Resident Inspectors J. Caldwell
- L.
King
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 13, 1987, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
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Licensee Action on Previous Enforcement Matters
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i Thissubjectwasnotaddressedintheinspection.
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Unresolved items
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Unresolved items were not identified during this inspection.
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5.
Employee Concerns Potential Problems:
A former electrical craftsman expressed his concerns early in 1985 to the NRC investigative staff in Atlanta, Georgia.
These concerns related to the electrical area and cover a span of approximately four years preceding the date contact was made with NRC investigative
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staff, l
The following information was given to the NRC investigative staff.
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i a.
Inadequate traceability records for electrical equipment installed and used in safety-related applications, b.
QC inspectors are not qualified for electrical inspections and QC inspector sign off work without actually inspecting the work, i
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The writing and issuance of nonconformance reports is discouraged by j
VEPC0 management.
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d.
Contractor electricians are not certified or qualified.
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Combustible material (wood veneer) in an electrical fire protection panel.
Observations and Resolutions
The NRC Inspectors interviewed approximately ten VEPC0 electrical QC inspectors, electrical, and instrumentation craf t maintenance personnel who worked at North Anna covering the period indicated above and who are
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still em)1oyed at the site.
Additional interviews and discussions were
held wit 1 VEPC0 personnel in Electrical Engineering area, QA Department, including training, skills and certification.
Procedures and reccrds were
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also examined in the inquiry of the above listed employee concerns.
It should also be noted, that many changes occurred during the concern to improve work, documentation and training practices. period of Major s
changes in 1981, 1982, 1985, 1987 were made in the Quality Assurance and l
Quality Control areas.
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Inadequate traceability records for electrical equipment Installed
and used in safety-related appilcations.
l 10 CFR 50, Appendix 0, Criterion Vill delineates the requirements for
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identification and control for materials, parts and components,
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i Measures must be established to assure that the Identification of an i
item is maintained by some unique manner in order to prevent the use of incorrect or defective materials, sorts and components.
A concern
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was made that certain electrical equ'pment was installed without the i
proper traceability tags, in that the Q.C. traceability tags were
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lost for some of this equipment and the Q.C. inspector wrote up another tag before the equipment was installed.
The NRC inspectors obtained approximately forty serial numbers from electrical equipment located in the process racks, protection channel racks and the panels located in the electrical equipment rooms, installed for the Safety Parameter Ofcplay System (SPDS).
This equipment includes multiplexers (muxes), submultiplexers (submuxes) and buffers manufactured by Validyne Engineering Corporation of Northbridge, California.
The serial numbers were traced back to purchase order number MPP 51434, which indicated that the equi) ment was purchased as Category 1 - Safety-Related.
In addition, t1e NRC inspectors interviewed electrical Q.C. inspectors and instrumentation and control craft personnel with regards to Q.C. inspectors writing traceability tags for equipment.
They indicated that they were not
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aware of any installed equipment that had questionable traceability, i
They also indicated that it is not uncommon for a Q.C. inspector to write up tags for equipment that has a missing QC acceptance tag as long as the material or equipment is traceable.
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The following equipment was included in the sample lot reviewed by
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PANEt NO.
INSTRUMENT NO.
SERIAL NO.
1 El CB 301A 1 Mux 11A 57205 I
IMux22A 57196 1 El CB-301C IBuffer14-15 57434 ISubmux1A1 57541 1 El-CD-23A 1 Mux 01A 57213 1Bufferl-5 57533
1 El-CB-238 1 Mux 02A 57225 1 Buffer 2-6 57525 i
1 El CB 23C 1 Mux-03A 57214
IBuffer3-7 57527
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1 El CB 230 1 Mux 04A 57226
IBuffer4-8 57530
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I 2 El-CB-3018 2 Mux 12A 57209 l
2 Mux 23A 57193 2 El CB 301A 2 Mux 05A 57221
l 2Buffor2A3 57526
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Based on the sample lot of muxes, submuxes, and buf fers, the NRC
inspectors conclude that electrical equipment installed onsite is traceable and NRC regulations and/or licensee's commitments for traceability have been met.
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l b.
QC inspector not qualified for electrical inspection and QC inspectors sign off work without actually inspecting the work.
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Virginia Electric and Power Company (VEPC0) Topical Report QA Program. VEP-1-4A, dated 1982, endorsed the Qualification of
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Inspection Examination and Testing Personnel for Nuclear Power
l Plants as specified in ANSI N45.2.6,1978.
For the time period of I
concern, qualification and training records were examined in detail
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for five VEPC0 QC electrical inspectors and several contractor
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electrical QC inspectors.
The records showed that these inspectors r
I were involved with on-the-job training or were quellfied as level 1
t or level !! inspectors.
The records for one or two of the electrical QC inspectors, before their qualification and certification,
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r indicated that they were under the proper supervision and that T
followup inspections were made of their work by qualified inspection personnel.
VEPC0 also had a Quality Control Enspector Development Program that covered a four year period. Records showed that many of the electrical inspectors were enrolled with this program and had
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successfully passed written examinations on the subject material, i
Some of the electrical inspectors, whose records were reviewed are
still employed at the site.
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l Otscussion and interviews were made, on an individual basis, with QC
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l electrical inspectors, and VEPC0 electrical, and instrumentation
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craf t personnel. The workers interviewed were at the site during the j
period of concern.
There was no indication that electrical QC i
inspectors were signing off work without actually inspecting the
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work.
Several workers did recall a problem of this type in another discipline. This was confirmed by VEPC0 management and is documented l
in NRC Inspection Report No. 50-338, 339/85 30, dated December 13, (
1985.
The workers concern with regard to the above subjects in the
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electrical area do not indicate that NRC regulations or licensee's
l commitments have been violated.
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c.
The writing and issuance of nonconformance' reports is discouraged by VEPC0 management
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The licensee's procedures establishes measures to comply with
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Parts or Component and Corrective Action).10 CFR 50 Appendix 8. Criteria 15 and 16 (Nonconfoming Material,)
l 0&M Instruction (1982 Section 15. Nonconformance Reporting states in part the following:
r The person discovering / identifying an apparent discrepancy shall
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report it to the QC Representative.
The QC Representative shall i
review for validity and classification of all reported
discrepancies prior to issuing the NCR.
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Olscrepancies which are not issued as NCR shall be returned to
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the originator with an explanation.
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The Station Manager or designee is responsible for disposition.
Discrepancies which will be corrected during normal process or within the scope of the controlling document need not be reported.
The above requirements are stellar in subsequent documents.
Also, the VEPC0 Inspection report is used to identify problems that require corrective action.
Discussion with electrical QC, and craf t personnel indicated that VEPC0 management only discouraged the writing of electrical NCRs when work was controlled by normal processes or when it was within the scope of the controlling document.
An example of this could involve a QC sign of f point.
The sign of f would not be made until the corrective action was completed.
The interviewees indicated that if the NCR fell outside of the above requirements and it was valid, they heard of no problems with management acceptance of an NCR.
The workers concern with regard to the above subject in the electrical area does not indicate that NRC regulations or licensee's commitments have been violated, d.
Contractor electricians are not certified or quallfled VEPCO's Topical Report, VEP-1-4A, dated 1982, endorsed, with slight modification ANS!/ANS 3.1 draf t December 1979.
This standard, entitled Qualification and Training of Personnel for Nuclear Power Plant, glves guidance on requirements for maintenance personnel.
One of the items in this section state that maintenance personnel shall have three (3) years work experience in'one or more craf ts and shall have demonstrated their ability to perform assigned tasks...
During the latter part of the period of concern, the contract supplier for craf t personnel was changed and on January 11, 1985 VEPC0 started a QA Audit into the Training and Qualifications of craf t personnel that were being supplied by the new contractor.
The Audit, N 85 01, showed that qualification and certification records for craf t personnel could not be found.
As a result of the audit, records were complied and obtained that showed craf t personnel,in includinr electrical, have a minimum of 42 months of experience their pr' mary or related craf t.
This experience is not necessarily nucIcar power plant experience, it does, however, satisfy the minimum three years of experiences as required by ANS!/ANS 3.1 draf t December 1979, in addition, as a result of the audit, qualification / certification craf t records have been established, the training program and records for the same have been estab11shed and improved.
The inspector reviewed several electrical craf t records for qualification and training and considered them to be satisfactory with regard to ANS!/ANS 3.1.
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In light of the above, it is considered that electricians were qualified.
However, the licensee's lack of records for this item indicates an apparent violation to 10 CFR 50 Appendix B, Criterion 17, QA records.
This criterion requires that records be maintained including data such as qualification of personnel.
This apparent violation was discussed with the resident inspectors, and
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regional personnel and the following were considered:
(1) The violation was identified by the Itcensee.
(2) The violation fits in Severity Level IV or V.
i (3) The violation was reported, if required (not required by 10 CFR 50.72 or 50.73),
(4) Adequate corrective measures were established and implemented.
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It was not a violation that could reasonably be expected to have
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been prevented by the licensee's correct 1/e action for a i
previous violation.
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Based upon the above considerations, it was concluded that the violation would not be cited based on 10 CFR 2 Appendix C, i
Section V.A.
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Combustible material in electrical fire protection panels
The Robert Shaw fire Alarm consoles located in panel 1 El-CB-97 in the control room were examined.
These consoles have a 1/16 inch wood veneer siding.
The total amount of this material, consisting of four pieces, is less than 250 square inches and is part of the unit when
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procured form the manufacturer.
An analysis performed by the
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Ilcensee (EWR 85147) shows that this small amount of combustibles is l
negligible when compared with other combustibles located in the control room.
These combustibles consist of items such as cables, carpetingIonalamountofcombustiblesaddedbytheveneerwoodsidin0 transient combustible procedures, drawings, records, etc.
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i The addit on the consoles does not appreciably affect the fire loading for the
issue.
This item control room and is not considered to be a safety 0 338, 339/85-03.
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i is also discussed in NRC's Inspection Report No. a
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