IR 05000424/1985042

Insp Rept 50-424/85-42 on 850903-06.Violation Identified: Failure to Evaluate or Incorporate Mfgs Recommendations Into Equipment,Maint & Storage List Program

ML20205F371
Person / Time
Site:	Vogtle
Issue date:	10/11/1985
From:	Belisle G, Jackson L, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205F365	List: IR 05000424/1985042 ML20205F361
References
50-424-85-42, NUDOCS 8511050337
Download: ML20205F371 (7)

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION yI 'n REGION ll

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Report No.: 50-424/85-42 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.- CPPR-108 Facility Name: Vogtle 1 Inspection Conducted: September 3-6, 1985 Inspectors: if - /6 /, 6 L. H. Jackson ~'V, / D&te 'Si gned f f,' /Ob/ $$

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Date Signed

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Approved by: / 2/ eF /0////d4

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G. A. ( Beli sle, 'AC' ting Sect ion Chief Da'te' Signed Division of Reactor Safety SUMMARY Scope: This special, unannounced inspection entailed 54 inspector-hours on site in the areas of employee concern Results: One violation was identified - Failure to evaluate or incorporate manufacturers recommendations into the Equipment, Maintenance, and Storage List (EMSL) Progra PDR ADOCK 05000424 G PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• D. Daniels, Assistant Quality Control (QC) Manager

• D. Fiquett, Unit 1 Field Construction Manager

• L. Glenn, Quality Concerns Manager

• E. Groover, Quality Assurance (QA) Site Manager (Construction)

• B. Harbin, Manager, QC

• C. Hayes, Vogtle QA Manager

• R. Hayes, Acting Mechanical Field Office Supervisor

• G. McCarley, Project Compliance Coordinator

• Nickerson, Deputy Project General Manager R. Osborne, Mechanical QC Supervisor

• A. Page, Electrical QC Supervisor A. Harrelson, Assistant to the Vice President & Project General Manager C. Brewer, Assistant QC Manager

.0ther licensee employees contacted included engineers, technicians, QC supervisors, QC inspectors, and office personne NRC Resident Inspectors

• J. F. Rogge, Senior Resident Inspector

• R. J. Schepens, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on September 6, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding The licensee acknowledged the inspection finding Vislation - Failure to evaluate or incorporate manufacturers recommended preventive maintenance measures for Control Building Engineering Safety Chillers in the Equipment, Maintenance, and Storage List-(EMSL) program, paragraph 4.b.

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.The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio _

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2 Employee Concerns The Nuclear Regulatory Commission (NRC) was contacted on May 1,1985, by an individual who expressed three concerns about the electrical quality control (EQC) program being implemented at Plant Vogtle. As a result of these concerns, NRC inspectors interviewed 21 randomly selected EQC inspectors (7 - Continental Technica! Services, 8 - Butler Services, 5 - Georgia Power Company, and 1 - Bechtel Power Company), 4 EQC Supervisors, and examined pertinent QC records and procedure Additionally, meetings were held with Vogtle Plant QA/QC Managers and the Quality Concerns Manager to determine if concerns expressed to the NRC were already identified in a licensee controlled system; if so, when documented; and what was the corrective action status of those concern The following are the specific concerns:

(1) CONCERN: QA inspectors are harassed and intim.idated by QC supervisors in that they are constantly told to stay out of the office and given limited time to prepare their inspection report QC . inspectors are hesitant to identify problems because they are not given sufficient time to document these problem '

DISCUSSION: The submitter of this concern is apparently referring to the Georgia Power Company (GPC) approved work policy (MQC-650, Plant Vogtle Units 1 and 2 Work Policy, dated October 31, 1984)

for QC inspectors. The following guidelines are established by this work policy:

The inspector needs to be in the field the majority of his work da Normally an inspector should be able to perform office paperwork (writing discrepancy reports, research, etc.) in 30 to 45 minutes during the beginning and end of his shif Inspection personnel who have completed their inspections and subsequent paperwork need to be in the field to perform in

, process inspections, not sitting in the office waiting for someone to call them to come inspect an ite Each supervisor is responsible to ensure the work is covered in the fiel QC management has two memorandums on file documenting two separate occasions where the concerned employee reportedly spent an excessive amount of time to complete routine paper work in the offic In his defense for this tardiness accusation, QC

.. management documented the.following employee statements:

The time he spent was not beyond the amount require :

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He should be allowed to remain in the office reading specifications, procedures, etc. until the craft called for an inspection.*

Requiring employees to be in the field, in an area that he can be reached when needed, constituted intimidation and harassment.*

He did not want to hear about how long it took him (to write paperwork).

He was busy the entire time, therefore there should be no

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discussio He did not think or write as fast as others so no comparison should be mad He was doing his job and would continue to do the job he was hired for, until the time he was terminate *The concerned employee's documented second and third statements are contrary to GPC's work policy for GC inspectors. In response to the concerned employee's statements above, management documented in a memo that the employee was shown a copy of MQC-650 and was informed that completing paperwork in a prompt and quality manner was part of an inspector's jo Furthermore, he was informed by QC management that if it required him twice the time to do his routine paperwork compared to other inspectors then QC management assumed he was performing at a level below what is reasonably expecte Intimidation and harassment is a perception that differs from person to perso However, i nte rvi ews-cwith the 21 randomly selected EQC inspectors revealed that even if they felt intimidation and harassment (real or imagined) existed by their supervisors, all 21 stated it did not and would not stop them from identifying and documenting deficiencies they found at Plant Vogtle. Any safety concern or problem they knew about had been documente .

The concerned employee submitted this concern to the Quality Concern Program (QCP) on May 9, 1985. This concern, Quality Concern No. 85V0207, was investigated and the concerned employee was notified by letter dated August 9,1985, that his claim of intimidation and harassment could not be substantiate FINDING: Contrary to the concerned employee's concern, company policy did not cause any of the 21 EQC inspectors interviewed to fail to document their finding Supervision was enforcing the

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GPC inspector work policy wnich dictates that an inspector's job is to be in the field the majority of his work day where he will be accessible to the crafts when needed for inspection purpose CONCLUSION: This concern was not substantiate (2) CONCERN: Supervisors do not permit inspectors to prepare Quality Concerns during normal working hour DISCUSSION: There are two types of concerns an employee may file at Plant Vogtle. A personnel employee concern (involving alleged unsatisfactory working conditions), or a quality concern issue that may effect the safe operation of the plant. Discussions with the concerned employee's two immediate supervisors identified that they unknowingly at first assumed he was filing a personnel empicyee concer Based on this assumption, the lower level supervisor erroneously thought that only quality concerns could be written up on company time and told the concerned employee he had to write his concern at home. Subsequent discussion by the lower level supervisor with his immediate supervisor identified he had made an error in judgement and that company policy permitted both personnel employee and quality concerns to be documented during working hours. The lower level supervisor stated he had the concerned employee contacted immediately that same day in the field (approximately 30 minutes later) and notified him that if he

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, had a concern.(employee or quality) he could write it in the field or at home whichever place he chos The Region II inspector discussions with 21 EQC inspectors did not identify any other inspector who was told by his supervisor that he could not document a quality concern during working hour Discussion with the QC Manager revealed that although he or any member of his supervisory staff would like the first chance to act on any_ quality concern, the employee has the right to file his quality concern at anytime with the Quality Concern Program. An EQC inspector's job is to be in the field accessible to crafts when needed for an inspectio Company policy dictates this in correspondence MQC-650 dated October 31, 198 Inspection of an item is on an as-needed basis; therefore, there is generally some slack time during an inspector's working day when a concern can be adequately documente This concern is documented in Vogtle's Quality Concern Program n (QCP) as part of Quality Concern No. 85V0207. A review of the Quality Concern Program resolution by the Region II inspector indicated that the concern wts adequately investigated and resolve The concerned employee was notified by the QCP Manager in a letter dated August 9, 1985, of the investigation result . . . . -.

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, -The - QCP Manager's conclusion was that Quality Concern 85V0207

could not be substantiated.

FINDING: This was an apparent communication problem between electrical QC supervisors and the concerned emp'ioyee that.was immediately corrected the same day.

CONCLUSION

This concern was not substantiate (3) CONCERN: There is a loss of traceability on construction items that are reworked because documentation for rework is a new set of

- documents which are not traceable to the documentation prepared

! for the original installation. An item could be reworked and a i

review of original installation documentation would not reflect rework or modificatio DISCUSSION: Discussions with the Manager of QC and the-

- Construction QA Site Manager identified that this inability to

, link or marry-up rework documentation with original documentation was a valid problem. However, both managers have had this rework ,

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problem identified in GPC controlled systems and corrective action is already in process to resolve the problem. Review of records

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t , (Reference: QCP Concern No. 85V0019, File X78G54, Log QQC-1310, L dated April 23,1985) identified that the subject rework concern was . identified as early as March 15, 1985, during reinspection of another problem concerning welds and related records. Coincident

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to this reinspection activity, the QA grcup conducted Electrical Assessment tudit CP01-85/21. during March 4 - April 12, 1985, in

which they also identified similar rework documentation problem .

The inspector conducted discussions with the Assistant to the Vice President and Project General Manager and examined Actic, Plan

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EQC-10 which was developed to track and resolve-this problem. The 4 inspector examined correspondence MQC-782 (File X7BG17) dated

July 15, 1985, which detailed planned corrective actions in this area and discussed the status of these actions with the Assistant

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QC Manage FINDING: The employee's concern is valid; -however, the subject concern appears to have been identified and placed in a licensee

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controlled deficiency system prior (approximately 1 1/2 months) to the concerned employee reporting this item to Reg ~ ion II. Adequate

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corrective action appears to be in process to rectify this rework documentation proble CONCLUSION: The concern'was found to be valid, A concerned employee reported to the NRC what he perceived to be a problem with engineering not fully complying 'with vendor and

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manufacturers requirements regarding inspection and maintenance of

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equipment in storage.

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CONCERN: Safety-related equipment, specifically chillers, have not been identified as having an inspection / maintenance requirement to rotate the compressor impeller of the chille DISCUSSION: NRC inspectors interviewed 15 GPC employees _on September 4, 1985. These employees were randomly selected from the QC organization. Supervisors as well as those QC personnel involved in verification of the Equipment, Maintenance, Storage List (EMSL) program were interviewed. Those persons interviewed have as much as 16 years with GPC and as little as 18 months. Pertinent procedures and records were also examined to evaluate the concern !

GPC procedure GD-T-09, Inspection and Maintenance of Items in Storage, Revision 6 and Revision 8, were reviewed by the inspector to confirm responsibility assignment for establishment of the EMSL progra Paragraph 6.0 of both procedures was consistent in assigning the responsible discipline engineer the responsibility to determine if an item is to be entered into the maintenance program. This assigned duty is to be performed within 30 days of receipt of the Permanent Plant Equipment Daily Receiving Report. If the decision is not to input an item into the program, er to delete an item from the program, the engineer initiates and transmits an exemption or deletion to mechanical QC personnel for reference filing. If the decision is to input an item into the program, engineering initiates the appropriate forms, and transmits them to mechanical QC personne GD-T-09, Paragraph 6.3.2.2, Revision 6 and 8 requires the responsible discipline engineer to refer to the best avail-able data for maintenance '

and/or storage requirements, when equipment is received at site, prior to arrival of the vendor installation / maintenance &nstruction manua The inspector selected EMSL cards for the Control Building Engineering Safety Features Chillers and verified that manufacturer requirements to rotate the compressors every two years had not been incorporated into the EMSL program. The licensee issued Deviation Report numbers MD-08008 and MD-08009 which documented the failure of the responsible discipline engineer to incorporate rotation recommendations into the EMSL program. The recommendations to rotate the compressors were dated May 17, 1982. However, as of September 5, 1985, these recommendations had not been included into the EMSL program. Rotation of Units 1 and 2 compressors was accomplished during February 1985 as documented on DRs MD-08008 and MD-0800 FINDING: This failure to evaluate or incorporate, vendors recommendations in accordance with established procedure GD-T-09 is Violation 50-424/85-42-0 CONCLUSION: This employee concern was substantiate .J