IR 05000424/1985010
| ML20127G233 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/11/1985 |
| From: | Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127G222 | List: |
| References | |
| 50-424-85-10, 50-425-85-10, NUDOCS 8505210011 | |
| Download: ML20127G233 (7) | |
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NUCLEAR REGULATORY COMMISSION
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REGION 11 j
101 MARIETTA STREET,N.W.
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- r ATLANTA, GEORGIA 30323
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Report Nos.: 50-424/85-10 and 50-425/85-10
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Licensee: GeorgiaLPower Company
P. O. Box 4545
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Atlanta, GA 30302
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Docket Nos.: 50-424 and 50-425 License Nos.:
CPPR-108 and CPPR-109'
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Facility,Name: 'Vogtle 1 and 2
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Inspect' ion ~ Conducted: March-12-15, 1985
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M. D. Hunt Eate 61gned
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.fApproved by:
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T. E. Conlon, Section Chief Date Signed
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Engineering Branch
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Division of Reactor Safety SUMMARY-Scope:
This special, unannounced inspection involved 26 inspector-hours on site in the areas of worker's concern with regard to cable pulling procedures, electrical Quality Control (QC) inspector training, procedure revisions, inspection documentation signoffs, and inspector overall experience.
Results: No violations.or deviations were identified.
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8505210011 850416 gDR ADOCK 05000424 PDR
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REPORT DETAILS
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Persons Contacted Licensee' Employees
- E. Groover, Quality _ Assurance (QA) Site Manager
'*B.-C.--Harbin, Manager Quality Control M. H. Googe, Project Construction Manager-
-R. Page, QC Electrical Supervisor NRC Resident Inspector
- W. Sanders Other licensee employees contacted included construction craftsmen,
-engineers technicians, operators, mechanics, security force members, and office personnel.
-* Attended Exit interview 2.
Exit Interview The inspection scope and findings were summarized on March 15, 1985, with those persons indicated in paragraph 1 above'.
The inspector described the-areas inspected and discussed in' detail the inspection findings listed
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below.- _ No dissenting comments were received from the licensee.
Unresolved Item 50-424, 425/85-10-01, Review the Approval Requirements for ' Cable Pulling Calculations, paragraph 6.g..
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Unresolved' Item 50-424, 425/85-10-02,. Review the Overall Nonconformance Control Program, paragraph 6.e.
. Inspector Followup Item 50-424,425/85-10-03, Review Inspection Records that may be incomplete-due to DR closecuts, paragraph 6.a.
Inspector Followup-Item 50-424, 425/85-10-04, Review Staff Engineering
~ Qualifications, paragraph 6.d.
The -licensee'did not identify as proprietary any of the materials provided to.or reviewed by the inspector during this inspection.
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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio m
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Unresolved Items
~ Unresolved items are' matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
Two new unresolved items identified during this inspection are discussed in paragraphs 6.e. and 6.g.
5.
Employee Concerns
- On : November 24 and -25, 1984, an anonymous person called the Nuclear Regulatory Commission Headquarters Duty Officer to express concerns
- regarding certain electrical construction quality control. activities at plant Vogtle. -The caller was advised that the concerns would be entered
'into the formal Nuclear Regulatory Commission allegation tracking system for followup.
Additionally, the caller was advised.that this information would be provided to Georgia Power Company's (GPC) Quality Assurance Department because that'was where responsibility for actual changes stemming from these allegations would rest. The caller agreed, provided the requested anonymity
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During1this-inspection, the inspector was informed that a quality concern
. committee has been organized to review the quality concerns of the employees.
The connittee will accept concerns from individuals and provide
' answers to that -person on an individual basis. - If the ' employee desires to remain anonymous, the answer is then posted for general information. This
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committee also interviews 'all employees who are terminating employment at the site.
At the time of this inspection, the committee had developed a list of ~ concerns that had been presented by the employees.
Each concern will~be addressed and corrective action'taken as necessary. The GPC list of.
concerns,i reviewed by the inspector, overlap portions of the concerns
submitted by the anonymous caller. The concerns expressed by the caller are L
as follows:
e a.
When -inspecting Class IE items, QC inspectors ' will sometimes.not proceed with an inspection if many non-conformances or a large non-conformance (known at plant Vogtle as a " deficiency report") is found.
When later action is taken to resolve the DR.- the entire i.
inspection procedure is recorded as closed out, despite the. fact that the original inspection may not have been completed.
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There are no procedure checklists for cable pull cards or cable termination cards (see procedure ED-T-08, Rev. 4).
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Electrical QC inspectors are being qualified without any on-the-job training -- the caller does not believe'that adequate training is being provided.
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Inspection procedures are being changed too often and inspectors can
not keep up. ' Examples are EE580, Rev. 4, and X3AR01E-9, Rev. 8.
The procedures are haphazardly put together and do not cover areas which
'should be inspected.
The lack of quality engineers on site in the electrical area is contributing to these shortcoming o
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e.
Deviation. Report :(DR) numbers are centrally controlled and only
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assigned after supervisory review.
The problem is that a QC inspector
.can be " talked-out"~of a formal-DR. Consequently, non-conformances do not' become. permanent vault records with. formal requirements --for -
resolution.
A better system would allow a QC inspector to get a DR number-whenever asked for.. An improved method for non-conformance control should be established, f.
Many of_ the original plant Vogtle QC inspectors were inexperienced in nuclear' work and missed many things.
A recent influx of job shoppers-has turned up-a number of items.
There is a need to re-examine what has been done to date, as well.as things from now on.
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QC inspectors and supervisors are-initialing rather than signing cable termination record cards (EE 580).
The result.is that the person performing the inspection cannot later. be identified if problems occur.
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Discussion of Concerns a.-
This concern will require additional, information in order to determine the cause and the corrective actions required.
At the present time, there are no cross references between inspection records and DRs' that.
. permit an immediate access to these~ types of records.
Findings:
This. item will be reviewed.during a subsequent inspection and is identified as'an Inspector Followup Item 50-424, 425/85-10-03,
- Review' Inspection Records That May Be Incomplete Due to DR Closeouts.
b.
The inspector reviewed Construction Procedure ED-T-08, Rev. 4. Cable Termination. The Revision 4 did not contain a checklist as reported by the concerned employee. The lack of-a checklist for the. performance of lthe inspection acitvity covered by this procedure had been identified
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in a September QA audit. - The Audit Finding Report No. ED-04-84/54
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identified this finding as a Category II audit finding.
This finding
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.resulted in several Field Procedure Change Notices being issued as well as a complete revision being issued.
The - inspector reviewed Revision 5, dated December 28, 1984, of Construction Procedure. No. ED-T-08 Cable Termination.
A Field Procedure Change' Notice No.- 29, dated January 11, 1985, had been made part of the procedure.
This-Field Change Notice contained a checklist for terminations to ensure that the terminations meet the requirements
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-of specification X3AR01-E9 and is intended as an aid to the performance of. inspection activities, but is not intended to be all inclusive.
Findings:
This employee concern was substantiated.
At the time the
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employee. reported the concern he did 'not know that the licensee was
, taking corrective action as a result of the September QA audit finding.
i Through the issuance of Field Procedure Change Notices and a complete procedure revision a checklist is now part of the procedure.
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,c.
The ' inspector ' interviewed ten QC inspectors during.this inspection.
- The persons were-asked about the training prog (ram and its effective-ness.
The - licensee - was -issued a violation Report No. 50-424, 425/84-10-01, Training and Indoctrination of Electrical Contract QC Personnel) for certifying inspectors without the proper indoctrination and formal training. The NRC inspector was advised that there is now a training program which covers this issue.
Findings:
This concern is similar to others that have been submitted to the Nuclear Regulatory Commission and the licensee's Quality Concerns Committee.
The concern was valid approximately nine months ago, but_according to persons interviewed, has now improved with the
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upgrading of the training program.
- d.
The document EE 580 is the controlling program that generates the cable pulling and cable termination cards used for documenting QC inspections.
The document X3AR01E-9 is the construction specification for installing and terminating cables. The procedures used to document the QC inspector and acceptance are ED-T-07 (Cable Pulling) and ED-T-08-(Cable Termination).
The inspector was informed that the general practice is to revise a ' procedure when there are five Field Procedure
" Change Notices written against it.
The inspector reviewed procedures ED-T-07 and ED-T-08 but did not examine EE 580 and X3AR01-E9.
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'During interviews with the QC personnel a few mentioned that they were
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not'always in total agreement with the engineering staff's resolution to various problems and DRs. No members of the engineering staff were interviewed during this inspection.
Findings: The documents EE 580 and X3AR01-E9 are identified as program control and specifications rather than procedures.- The applicable procedures ED-T-07 (Rev. 7) and ED-T-08 (Rev. 8) were found adequate for the quality control activities.
This portion of the concern was not
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substantiated ' during this inspection.
The qualifications of the l
engineering staff will be examined during a subsequent inspection.
l This is identified as an Inspector Followup Item 50-424,425/85-10-04, L
Review Staff Engineering Qualifications.
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e.
During interviews with the quality control inspection personnel,' the
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NRC inspector. asked if any individual had ever had a nonconformance
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DR rejected.
Most of the' personnel advised that they had not had a DR rejected.
Several indicated that the deviation is discussed with
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other inspection personnel and their supervisor before the DR is written.
Several supervisors stated that they review the DR to ensure
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that they are properly prepared before submitting them for introduction
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into the numbering system.
The Construction Procedure GD-T-01, i
requires the supervisor to " review the report for completeness,
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acceptability and Hold Tag requirements before assigning it a control
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number."
However, during the review of the nonconforming program
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several closed DRs'were found to have several changes made by crossing out words:and statements to the point that it was difficult to determine the final disposition.
One DR was closed by stating that future actions will' be taken.- Another DR had a disposition that did not address the condition described.
Findings:
This concern could not be substantiated through interviews and because.of the fact that the procedure requires the supervisor to review all DRs prior to assigning control numbers.
The closed procedure review did result in identifying the following Unresolved Item 50-424, 425/85-10-02, Review the Overall Nonconformance Program.
f.
During the interviews with the quality control inspection. personnel, the inspector.was advised that the early training program was not as comprehensive as the existing training program.
Additionally, during
- early 1984 Violation 50-424, 425/84-10-01 Training and Indoctrination of Electrical Contract QC Personnel. was identified. As a result of this violation. revisions were made to the training program.
This violation was closed in IE Report Nos. 50-424, 425/84-35 after the corrective action was found acceptable. The persons interviewed stated that the training program was informative and provided the necessary instructions to perform their inspection activities.
On-the-job training is held as required.
Findings:
This concern could not be substantiated through personnel interviews.
Review of QC inspection records (DRs and completed cable pull cards) indicates that. the inspectors are cognizant of the -
inspection requirements.
g.
The inspector reviewed several. completed cable pull cards for completed
cable installations which were filed in the vault.
In accordance with Construction Procedure No. ED-T-07, Cable Installation, the attributes listed on the cable pull card are to be initialled by the quality
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control inspector if the activity is found acceptable in accordance I
with the inspection criteria.
When all the attributes are completed and initialled, the inspector then signs his name in the block designated as required by the procedure.
The supervisor or t.evel II inspector then affixes his signature to the card indicating acceptance -
of the inspection activity.-
The inspector reviewed the name/ initial logs stored in the vault which are used for identification purposes.
These logs consist of several volumes and contain many names.
However, it is possible to identify the inspector by name from initials.
Findings:
The use of initials for signoff of certain inspection acceptance activities is permitted by the controlling procedure.
Therefore, this concern could not be substantiated.
There was a possible problem identified during the review of the completed cable cards.
It was.noted that cable pulls requiring the use of tension-measuring devices contained calculation data sheets which contained no w
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l identification as to 'the source or preparer of the data sheets. This
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item will require further examination and is identified as an Unresolved Item, 50-424,425/85-10-01, Review the Approval Requirements for Cable Pulling Calculations.
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Conclusion As a result of this inspection-the following determinations regarding the employee conserns were made:
Employee Concern 6a.
Additional inspection will be required due to the difficulty in coordinating DRs with inspection records.
Employee Concern 6b.
This concern was substantiated.
The problem had been identified by a QA audit also.
The result is that checklists are now included in procedures ED-T-07 and ED-T-08.
Employee Concern 6c.
This concern was valid approximately nine months ago but corrections have been made in the training program.
Employee Concern 6d.
The portion of the concern relating -to procedures could not be substan-tiated.
The engineering staff qualifications will require further inspection.
Employee Concern 6e.
This concern was not substantiated in that the procedures were being followed.
Employee Concern 6f.
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This concern was not substantiated.
The inspectors are cognizant of the inspection requirements.
Employee Concern 6g.
This concern was not substantiated.
An unresolved item was identified relating to cable pulling tension calculations.
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