IR 05000424/1986066

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Insp Repts 50-424/86-66 & 50-425/86-31 on 860721-25.No Violations or Deviations Noted.Major Areas Inspected: Readiness Review Modules 6,20 & 21J & Employee Cable Splicing Concerns
ML20209F875
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 08/21/1986
From: Conlon T, Hunt M, Merriweather N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209F828 List:
References
50-424-86-66, 50-425-86-31, NUDOCS 8609120293
Download: ML20209F875 (6)


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i Report Nos.:- 50-424/86-66 and 50-425/86-31 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.:

50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name:

Vogtle 1 and 2 Inspection Conducted July 21-25, 1986 i

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Inspecto W

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M. D. Hunt

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Date Signed E ~ 2/ - ES N. Merriweather Date Signed

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Accompanying Personnel:

T. McElhinney Approved by @

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T. E. Conlon, Section Chief Date Signed Engineering Branch Division of Reactor Safety

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SUMMARY

Scope: This special announced inspection was conducted in the areas of Readiness Review Modules 6, 20, and 21J and employee concerns relating to cable splicing.

Results:

No violations or deviations were identified.

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8609120293 860322 PDR ADOCK 05000424 G

PDR

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • M. H. Googe, Project Construction Manager
  • E. D. Groover, QA Site Manager Construction
  • G. A. McCarley, Project Compliance Coordinator
  • C. E. Belflower, QA Site Manager, Nuclear Operations (NO)
  • C, Haynes Vogtle QA Manager
  • W. T. Nickerson, Assistant to Project Director
  • C. W. Janecke, Quality Concerns (QC) Investigator, Quality Concerns
  • R. E. Hollands, Compliance Supervisor
  • D. C. Borowski, Inspection Supervisor, Electrical QC
  • F. Page, Electrical QC Section Supervisor
  • B. C. Harbin, Manager, QC

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Other licensee employees contacted included construction craftsmen, engineers, technicians, QC inspectors, security force members, and office personnel.

Other Organizations

  • Fred B. Marsh, Project Engineering Manager, Bechtel Power Corp. (BCP)

NRC Resident Inspectors

  • J. F. Rogge, SRI
  • R. J. Schepens, RI
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on July 25,1986, with those persons indicated in the paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received from the licensee.

The following unresolved items were identified:

50-424/86-66-01 and 50/425/86-31-01, Review Acceptability For Use of Desk Top Procedures to Control Design Activities (QA Records), paragraph 6.

50-424/86-66-02 and 50/425/86-31-02, Review the Use of NA/NA FCRs in Lieu of Specification Changes, paragraph 6.

50-424/86-66-03 and 50-425/86-31-03, Review Application of Voided FCR No.

15409 Information into Raychem Technical Manual AX3AJ118-24, paragraph *

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50-424/86-66-04 and 50-425/06-31-04, Review Traceability of Raychem Splice Materials for NSWC Tower Power Cables, paragraph 6.

50-424/86-66-05 and 50-425/86-31-05, Review Inadequate Instructions for Raychem Splices, paragraph 6.

50-424/86-66-06 and 50-425/86-31-06, Review Licensee's Training Program for Construction and Operations Engineers, QC Inspectors and Craftsmen on Raychem Applications, paragraph 6.

50-424/66-07 and 50-425/86-31-07, Review Mathod of Controlling Copies of DRs, paragraph 6.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

3.

Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

4.

Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.

Fourteen new unresolved items identified during this inspection are discussed in paragraph 6.

5.

Readiness Review Modules 6, 20, and 21J During Inspection The examination and review of the following readiness review modules

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continued.

Module No.

Ti tle Report No.

Electrical Equipment 86-46

I&C 86-49 21J Equipment Qualifications 86-50 The records and documentation used in the development of these modules were reviewed.

The vendor certifications for various equipment and the QC records for receipt, storage and installation were reviewed.

Certain engineering docurents were examined as part of the review of these modules.

No violations or deviations were identified.

6.

Employee Concerns The NRC was contacted by an employee at the site who expressed concern regarding the application of Raychem splices and the use of splice materials.

Interviews were conducted with personnel in Georgia Power Company's (GPC) Field Engineering and Electrical Quality Concerns (QC)

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sections regarding various aspects of controlling the Raychem splicing methods and materials.

a.

Concerns As a result of these interviews, several concerns were identified and are listed as follows:

(1) QC inspectors are often required to indirectly direct the craft.

(2) Field Engineering instructions for Raychem splice kits are not adequate for anything other than a one-to-one splice.

The Electrical Contractor is using instructions from expended kits to select parts and assemble other kits.

(3) Field Change Requests (FCR) lack adequate instruction to build kits.

No provision for QC inspectors (QCI) to report discrepancies / errors in FCRs.

(4) No training given to the QC inspectors in Raychem Procedures.

(5) Procedure ED-T-08, FPCN 61 does not require parts from special kits to be recorded nor is in-line sleeving materials recorded.

(6) Maintenance work orders provide design criteria which violates cable installation and termination specifications.

b.

Discussion During interviews with QC inspectors, both GPC employees and contract personnel, the question was asked of each of them "Have you ever directed the crafts in the application of Raychem splice materials?"

The responses were similar in nature, first all knew they could not direct craft work activities during an inspection.

Secondly, most stated that they were frequently asked if they would accept a certain size of material if it were applied.

If the QC inspectors reply was negative then a different size material was substituted and the question restated.

This process often continues until the proper size materials, which are acceptable, are selected.

Further evaluation and examination of this concern will be required.

This is identified as Unresolved Items, 50-424/86-66-05 and 425/86-31-05, Review Inadequate Instructions for Raychem Splices.

Additionally, it appears that the Raychem Technical Manual AX3AJ11B24 incorporated in specification X3AR01-E-9 does not furnish adequate visual or written instructions for three-way and four-way splices. An attempt was made to revise the specification by FCR No.15409 to add additional information which would have added tables for designing various splices.

However, the FCR was voided and the table was to be

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incorporated as part of the Raychem Tech Manual. There is no record of such action having occurred to date.

This will be followed in a subsequent inspection and is identified a Unresolved Item 50-424/86-66-03 and 50-425/86-31-03, Review Application of Voided FCR No.15409 Information into Raychem Technical Manual AX3AJ118-24.

During a review of FCRs, it was noted that some FCRs had been identified as being non applicable (N/A) when applied as a Design Change Notice (DCN) and a Construction Specification Change Notice (CSCN) thus, becoming identified as an NA/NA FCR.

The NA/NA FCR is used as a one time (unique) correction for an activity not covered by a specification or drawing.

Several NA/NA FCRs were reviewed and in certain instances were found to be generic rather than unique.

Discussions with engineering personnel were held and there were differing opinions regarding the term generic and its application as used by the inspectors.

This item will be reviewed further but is identified -as Unresolved Item 50-424/86-66-02 and 50-425/86-31-02, Review the Use of NA/NA FCRs in Lieu of Specification Changes.

The licensee had the Raychem splice manufacturer conduct a training course for selected field engineering personnel in the engineering development of splice kits to provide a method for " building" splice kits from bulk parts. The training course certified only electrical field engineers.

No QC inspectors or craftsmen were included in this training.

The inspectors were advised that the crafts had been instructed previously.

This information will be verified during a subsequent inspection.

This situation is identified a Unresolved Item 50-424/86-66-06 and 50-425/86-31-06, Review Licensee's Training Program for Construction and Operations Engineers, QA Inspectors and Craftmen on Raychem Applications.

The licensee then developed a desk top procedure which was to be used to document the engineering activities for development of splices and the materials selected.

The desk top procedure did not appear to be a controlled document and may not be adequate for documenting these activities.

This item will be examined further and is identified as Unresolved Item 50-424/86-66-01 and 50-425/86-31-01, Review Acceptability for Use of Desk Top Procedures to Control Design Activities (QA records).

i The inspectors were advised that there were some splices located in the Nuclear Service Water Cooling (NSWC) Towers which had different materials for some splices but the splices were supposed to be the same. Due to hot functional testing being in progress, the termination boxes could not be opened for examination of the power cables.

This will be identified as an Unresolved Item 50-425/86-66-04 and 50-425/86-31-04, Review Traceability of Raychem Splice Materials for NSCW Tower Power Cable,

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Near the close of the inspection the inspectors were advised that f

frequently QC inspectors would take copies of Discrepancy Reports (DRs)

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to the field for inspection and closure of the DR only to find upon

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reviewing the original DR that a revision had been riade.

Often the revision does not affect the inspection but in some cases it alters the

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final resolution. This is identified a Unresolved Item 50-424/86-66-07

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and 50-425/86-31-07, Review Method of Controlling Copies of DRs.

The above listed items will require further examination before an accurate assessment can be made.

This examinaticn will involve discussion with various levels of personnel and exemination of procedures and design documents.

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