IR 05000424/1986095

Insp Repts 50-424/86-95 & 50-425/86-45 on 860929-1003 & 1020-24.Violations Noted:Failure to Follow Procedures for Processing Field Change Requests & Incorporating Design Change Notices Into Drawings & Failure to Inspect Splices

ML20214P398
Person / Time
Site:	Vogtle
Issue date:	11/18/1986
From:	Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214P365	List: IR 05000424/1986095 ML20214P363 ML20214P382
References
50-424-86-95, 50-425-86-45, NUDOCS 8612040184
Download: ML20214P398 (10)

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- , mamee: UNITE) STATES A 'o NUCLEAR REGULATORY COMMISSi(.,N

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- Report.Nos.: 50-424/86-95 and 50-425/86-45 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA '30302 Decket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name: Vogtle~1 and 2 Inspections Cond cted: September 29 - October 3, 1986 and October 20-24, 1986 Inspector: -

A //Date//7!f4 Signed N. Merriwea'ther Approved b 7/ / / - / F- 94 T. E. Conlon, Chief Date Signed Plant Systems Section Division of Reactor Safety SUMMARY Scope: This routine, special unannounced inspection was conducted in the areas of employee concerns relating to the use of Raychem Products and followup of

previous identified unresolved item Results: Three violations were identified: . Project Field Engineering (PFE)

- failed to follow procedures for processing Field Change Requests (FCRs) and incorporating Design Change Notices '(DCNs) into, design drawings, paragraph 3.b;

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failure to provide training for Electrical Engineering and QC staff on the use of l

Raychem Products, paragraphs 6.c and 6.d; and inadequate inspection of Nuclear l Service Cooling Water (NSCW) Cable splices, paragraph 3.d.

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e REPORT DETAILS

- Persons Contacted-Licensee. Employees

• P. D. Rice, Vice' President, Vogtle Project Engineering

• C. Hayes,,Vogtle' Quality Assurance (QA) Manager

• E. D. Groover, QA Site Manage *R. McManus, Assistant Project Construction Manager

• A. Harrelson, Electrical Discipline Manager

• R. M. Bellamy, Plant Support Manager

• B. C. Harbin, QC Manager

-* E. Hollands, Compliance Superintendent

• C. W. Justice, Maintenance Foreman

• R. Frederick, Engineering Support-Supervisor - QA

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• G. 74. McCarley, Project Compliance Coordinator Other licensee employees contacted included construction craftsmen, engineers, technicians, security force members, and office personne Other Organization

• F. B.- Marsh, Project Engineering Manager, Bechtel

• S. Pietrzyk, Assistant Project Engineer, Bechtel

• D. W. Strohmman, Project QA Engineer, Bechtel NRC Resident Inspector

• H. Livermore, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection' scope and findings were summarized on October 20, 1986, with

- those persons indicated in paragraph 1 above. The' inspector described the areas inspected and . discussed -in detail the inspection finding No dissenting comments were received from the license The following new items were identified during this inspectio Violation 424/86-95-01 and 425/86-45-01, PFE Failed to Follow Proce-dures for processing FCRs and Incorporating DCNs into Design Drawings, paragraph 3.b. and 3 Violation 424/86-95-02 and 425/86-45-02, Failure to provide training for electrical engineering and QC staff on the use of Raychem products, paragraphs 6.c and j

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Violation 424/86-95-03 and 425/86-45-03, Inadequate Inspection of NSCW Cable 3plices, paragraph . Licensee Action on Previous Enforcement Matters (Closed) 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). The licensee developed desk top procedure DT-E-33, Rev. O dated July 16, 1986, to provide administrative uniformity within the Electrical Field Operations (EF0) in selecting Raychem products. The procedure allowed Field Engineers to design and approve Raychem splices. Since desk top procedures are not required to be audited by the licensee's QA program no safety-related work can be performed using Desk Top procedures. However, if the procedure becomes part of the Field Procedure Manual it is acceptable for safety-related work activities. The concern resulted because the cable termination inspection procedure ED-T-08, Revision 8 did not include references to desk top procedure DT-E-33. Subsequent inspection revealed that ED-T-08, Rev. 9 had been revised and was being reviewed for final sign-off prior to the inspection on July 20, 1986. The procedure had been reviewed by QA on July 17, 1986, submitted for signature on July 25, 1986, and approved for use on July 29, 1986. The procedure had been implemented only once on a non-safety splice in the turbine buildin Based on the above this item is considered close (Closed) Unresolved Item 50-424/86-66-02 and 50-425/86-31-02, Review the Use of NA/NA FCRs in Lieu of Specification Change During a review of FCRs issued against specification X3AR01-E9 it was noted that some FCRs had been identified as being non-applicable (NA) 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. Bechtel Project Reference Manual section C, paragraph 17.5.2.b required that

" changes involving configuration control may be approved for applica-bility to a unique component or installation onl Unincorporated (NA/NA) FCRs shall be listed in the "As-Built drawings" revision block at the time the "as-built" is issued". Contrary to the above, generic NA/NA FCRs (such as E-FCRB-14,517 E-FCRB-12,833 and E-FCRB-14,587) were approved by Design without the specific component identified. This item is considered one example of violation No. 50-424/86-95-01 and 50-425/86-45-01, PFE Failed to Follow Procedures for Processing FCRs and Incorporating DCNs into Design Drawing (Closed) 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 AX3AJ11b-2 The in-line splice guide, Vendor Instruction Manual, Sechtel Log AX3AJ118-24-2 did not contain adequate information

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for designing 3 and 4 way splices. An attempt was made to revise the manual by FCR-EFCRB-15409 to add additional information. This FCR was converted to a Design Change Notice (DCN-No. 4). The manual was revised to include DCNs Nos.1, 2, 3 and DCN No. 4 was identified on the cover sheet as being incorporated into the manual. However, when the inspector reviewed the revised manual on July 22, 1986, they found that DCN No. 4 had not been incorporated into the text, and a void had been stamped on FCR E-FCRB-1540 Vogtle Electric Generating Plant, Project Reference Manual (PRM),

Section C, paragraph 17.5.2.9 states in part that "when an FCR approved by project engineering requires a change to an engineering document, that change must be incorporated on the appropriate engineering document (drawing or specification)". Contrary to the above, the licensee failed to properly incorporate DCN No. 4 into Revision 3 of Vendor Manual AX3AJ118-24-3. This is considered another example of Violation 50-424/86-95-01 and 50-425/86-45-01 identified in paragraph (Closed) Unresolved Item 5'-424/86-66-04 and 50-425/86-31-04, Review Traceability of Raychem Splice Materials for NSCW Tower Power Cable The inspectors were advised that there were some different materials used on the splices in the Nuclear Service Water Cooling Tower which had different materials for some splices but the splices were supposed to be the same. The inspectors selected 16 cables (48 splices) in the A and B NSCW Cooling Towers for inspection to determine if the cables were installed using the proper Raychem materials as specified by procedure ED-T-08 and Specification X3AR01-E9. The results are as follows:

(1) Inspection of Cables 1AB1506HB/HA in Junction Box (JB)JB1ARJB0421

• Splices on cables IAB1506HB/HA in Junction box 1ARJB0421 utilized a WCSFN-650 overall sleeve. The effective inside diameter calculated in the field for the substrate was 1.76 inches. The use range for WCSFN-650 in non-accident environ-ments is specified by Raychem as 0.70 thru 1.75 inches. This installation was .01 inches outside the use rang * Shrink sleeve on red phase was not properly heated on one sid * Shrink sleeve on C phase installed over pain (2) Inspection of Cables IAB1508HB/HA in JB 1ARJB0423

Improper heating on one side of sleeve for all 3 phase *

Shrink on B phase installed over pain l

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(3) Inspection of Cable 1BB1608HB at Motor 1-1202-W4-002-M04

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• The end caps were bent and tywrapped on all 3 phase '(4) Inspection of Cable IBB1616HB at Motor 1-1202-W4-002-M03

• Bend radius of B phase cable repair exceeds Raychem minimum bend radius requirements of three inches (five times outside diameter).

(5) Inspection of Cable 18B1605 HB/HA in JB-1BRJB0424 i

• Overall WCSFN-650 sleeve is outside of allowable use rang Calculated effective diameter was 1.78 inches. The use range i

for WCSFN-650 in non-accident environments is specified by .

Raychem as 0.70 thru 1.75 inche (6) Inspection of Cable 1881608 HB/HA in JB-1BRJ B0427

• Overall WCSFN-650 sleeve is outside of allowable use rang Calculated effective diameter was 1.79 inches and the maximum allowable is 1.75 inc The above discrepancies are considered violation 50-424/86-95-03 and 50-425/86-45-03, Inadequate Inspection of NSCW Cable Splices. The other 10 cables inspected were found acceptabl (Closed) Unresolved Items 50-424/86-66-05 and 50-425/86-31-05, Review Ir: adequate Instructions for Raychem Splices. This item has been upgraded to a violation and is discussed in paragraph (Closed) Unresolved Items 50-424/86-66-06 and 50-425/86-31-06, Review Licensee's Training Program for Construction and Operations Engineer, QA Inspectors and Craftmen on Raychem Applications. This item has been upgraded to a violation and is discussed in paragraphs 6.c and . Background I.

! The NRC was contacted by an employee at the Vogtle Nuclear site who i expressed concerns regarding the -improper application of Raychem product In response to the employee concerns the NRC performed an inspection on

! July 21-25, 1986, to examine the licensee's program for handling Raychem l

Products. During this inspection, interviews were conducted with personnel in Electrical Field Engineering and Electrical Quality Control sections regarding various aspects of controlling Raychem splicing. As a result of these interviews, several concerns were identified and are listed as

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5 . QC inspectors are often required to indirectly direct the craf b. . ' 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 kit Field Change Requests (FCRs) lack adequate instructions to build kit No provision for QC inspectors (QCI) to report discrepancies / errors in FCR No training given to the QC inspector in Raychem procedure Procedure ED-T-08, Rev. 8 does not require parts from special kits to be recorded nor is in-line sleeving materials recorde Maintenance work orders provide design criteria which violates cable installation and termination specification The above inspection concluded with seven unresolved items being identified regarding the licensee's handling of Raychem product A special meeting was held with the licensee in the Regional office where the licensee discussed their program for handling Raychem products. In this meeting the itcensee informed NRC of a potentially reportable condition under the requirements of 10 CFR 50.55(e) concerning site designed cable splices using Raychem heat shrinkable insulatio Subsequently, two additional inspections were conductad on September 29 -

October 3, 1986 and October 20-24, 1986, to followup on the employee concerns and unresolved items. The inspections covered design, procurement, installation, and training for Rayche The results indicate that some weaknesses did exists in the licensee's program for Raychem products during the 1985 and early 1986 time frames. Most, if not all, of the weaknesses have been corrected by the licensee. Further enhancements are also planned to improve work on Unit Some, but not all, of the concerns were substantiate Contained in paragraph 6 below is a description of the concerns and a brief over-view of the NRC finding . Employee Concerns (Inspection Modules 510618, 510638, 510658 and Temporary Instruction 2500/17) Concern No. 1 QC inspectors are often required to indirectly direct the craf NRC Findings 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?"

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, . 6 The results show that 55 percent of the inspectors questioned had indirectly ~ directed the craft .in the selection of Raychem splice material. _ The responses were similar in nature. First, all knew they could not direct craft work activities during an -inspection and secondly, most stated they were frequently asked if they would accept a certain . size of material if it were applie If.the QC inspectors reply was negative then a different size material was substituted and the question was restated. This process often continues until the proper size materials, which are acceptable are selected. Based on the above, the inspectors concluded that the concern was substantiate The significance of this concern was evaluated in conjunction with the followup of unresolved - items 424/86-66-05 and 425/86-31-05, Review Inadequate Instructions for Raychem Spifces. The results are discussed in paragraphs 3.e. and Concern No. 2 Field Engineering instructions for Raychem splices 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 kit NRC Findings Inspection revealed that FCRs had been approved which allowed construc-tion to remove parts from kits to assemble site engineered splice kit The parts required and the splice configurations would be detailed by FCR. It was therefore substantiated that once the part is removed from the kit traceability was not always maintained because procedure ED-T-08 did not require recording part, kit and/or lot numbers for Raychem parts until revision No. 7 was issued on July 18, 198 Concern No. 3 FCRs lack adequate instructions for building kits. There were no provisions for QC inspectors to report discrepancies and errors in FCR NRC Findings The inspector reviewed several FCRs that had been issued against Specification X3AR01-E9 to provide 3 and 4-way splice details. All FCRs did provide a list of Raychem parts, hardware dimensions and a sketch of the splice configuration. However, deficiencies identified in the FCRs consisted of a failure to identify shim dimensions and overlap for outer sleeve and a failure to provide detailed step-by-step instructions on how the splice should be assembled. The instructions J

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were required because the in-line splice manual referenced in Specifi-cation X3AR01-E9 only provides inspection requirements for in-line one-to-one splices. Failure to incorporate this information into the-FCRs is considered as part of violation 50-424/86-95-02 and 50-425/86-45-0 A review of the licensee's procedure fer nonconformance control,-

GD-T-01, Rev.14 revealed that the procedure does not specifically address initiating a Deviation Report (nonconformance) for errors found in design FCRs; however, it does not prohibit deficiencies in design being identified by GPC QC. Although, errors in design should normally be identified by the design entity considering they maintain the design base document However, in the area of Raychem splices it was determined that several 3 and 4-way splice designs were in error because of a misinterpretation of the Raychem "use range" design criteria. The licensee reported this concern to NRC pursuant to the requirements of 10 CFR 50.55(e) on August 12, 1986. The errors resulted from misapplication of the use ranges criteria by both field construction, who generated the FCRs, and by Project Field Engineering, who dispositioned and approved the FCR Review of the incorrect FCRs revealed that a majority of the FCRs were

. approved by two people in PFE that had not received training on the use of Raychem products. (Examples of the FCRs are E-FCRB-10,867, E-FCRB-12, 694, E-FCRB-12, 513, E-FCRB-11, 941, E-FCRB-11, 295, E-FCRB-11, 212 and E-FCRB-12, 204.)

The above two concerns are considered one example of Violation 50-424/86-95-02 and 50-425/86-45-02, Failure to Provide Training for Electrical Engineering and QC Staff on the Use of Raychem Products, Concern No. 4 QC inspectors have had no certified Raychem training. The training that they have received came from On-the-Job-Training (DJT) with another inspector. This raises the question as to the ability of QC inspectors to perform inspections on Raychem splice .

NRC Findings The inspector interviewed persor.nel in both Cleveland Electric and Georgia Power Company (GPC) trair.ing departments to discuss past and present training of craft and QC inspectors, respectively. Discussions revealed that Cleveland electricians have been trained and tested on the use of low voltage and high voltage Raychem products. The program requires that they are recertified every six months through refresher trainin Records of this training were observed in GPC QA records vaul .

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GPC Electrical QC (EQC) inspectors certified in Electrical . Cable Terminations prior to August 20, 1986, were certified in accordance with procedure QC-A-01 using one of the twa methods below:

(1) The first method required:

(a) Completion of formal classroom training (b) Successfully passing a certification examination-(c) Satisfactory completion of DJT (2) The second method required:

(a) Three years of equivalent related inspection experience with approximately one year in cable termination inspection (b) Successfully passing a certification examination (c) -Satisfactory completion of 0]T The licensee conducted a survey of EQC training to determine whe ner inspectors had received Raychem training. The survey divided the EQC inspectors into two groups - contract and GPC inspectors. The survey results show that there were a total of 54 inspection personnel certified in cable terminations. Twenty were GPC personnel and 34 were contract staff (Butler Services and Continental Technical Services).

The majority of GPC inspectors were certified using method number 1 and had received some general Raychem training throuah the Cable Termina-tion Course. However, only four contract inspectors had attended the cours The remaining 30 contract inspectors were certified using method two and had not received any formal classroom training on Raychem but had only received DJ (This OJT may not have involved inspections of Raychem splices).

The licensee also questioned inspectors regarding training they may have received at other sites on Raychem product All but one EQC inspector had received training on Raychem. The one exception had only received DJT at Vogtl Based on the above, the NRC inspector concluded the concern was substantiate This is considered the second example of violation, 50-424/86-95-02 and 50-425/86-45-02, Failure to Provide Training for Electrical Engineering and QC Staff on the Use of Raychem Product e. Concern No. 5 Procedure ED-T-08, FPCN-61 does not require parts from special engineered kits to be recorded nor is in-line sleeving material recorde NRC Findings This item is addressed in paragraph (b) abov J

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f. Concern No.'6 Maintenance work orders -(MW0) provide design criteria which violates cable _ installation and termination specification NRC Findings Interviews with personnel .from nuclear operations indicated that-Raychem splices performed by operations were in accordance with a engineered kit'or the work was assigned to construction via a MWO to be worked in accordance with. construction specs and procedures. The inspector did not confirm or deny this concern but considered the findings made regarding the licensee's program for construction applicable to work performed for Nuclear Operations by way of MW ,