IR 05000528/1989012
| ML20248G884 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/08/1989 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20248G883 | List: |
| References | |
| 50-528-89-12, 50-529-89-12, 50-530-89-12, NUDOCS 8910110072 | |
| Download: ML20248G884 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
R port-Nos. 50-528/89-12, 50-529/89-12, 50-530/89-12
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~ D'ocket Nos. 50-528, 50-529, 50-530 License Nos. NPF-41, NPF-51, NPF-74 S
Licensee:
Arizona' Nuclear Power Project J
P. O. Box 52034
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Phoenix, Arizona"'85072-2034
, Facility _Name: _Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and.3 Inspection at:
Palo Verde' Site, Wintersburg, Arizona
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Inspection Conducted:
January 30, 1989 through August-11, 1989
Inspector:
J. F. Burdoin, Reactor Inspector W. J. Wagner, Reactor Inspector F.
Gee, Fwastor nspector
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fM Approved by:
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F. R. - Huey, Chiir,' Engineering Sectio Date Signed Summary:
Inspection on January 30, 1989 - August 11 1989 (Report Nos. 50-528/89-12, 50-529/89-12, 50-53J1/89-12]
Areas Inspected: A special inspection by regional inspectors of various vital areas and equipment in the plant, commercial grado procurement and follow-up on two allegations.
Inspection Procedure Nos. 30703, 37700, 38703, 71707, and 92701 were uf.ed as gutdance for the insocction.
Results:
General Conclusions The licensee's actions taken to correct minor housekeeping findings, to clarify allegation items, and to correct deficiencies resulting from follow-up of allegation issues were thorough, timely, properly documented and adequate.
Significant Safety Matters:
None Summary of Violations or Deviations:
None Open Items Summary:
None GJ10110072 8909:O FDR ADOCK 050005.28
'd PDC
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DETAILS
1.
Persons Contacted The below listed technical supervisory personnel were among those contacted:
Arizona Nuclear Power Project (ANPP)
+R. Badsgard, Resident Engineering Supervisor
- B. Ballard, Sr. Director QA/QC J. Barrow, Electrical Engineering Supervisor W. Bauer, Materials Receiving
++T. Bradish, Compliance Supervisor E. Chan, Impell Lead Senior Engineer
++P. Coffin, Compliance Engineer R. Collins, Radiation Monitoring System Engineer C. Day, Electrical Standards Supervisor K. Donaldson, Electrical Engineer M. Dougherty, Supervisor Stores
+R. Fullmer, Manager, Quality Audits P. Gibbons, EE580 System Coordinator R. Guron, Electrical Engineer S. Grier, Lead Procurement Engineer
- D. Hackbert, Quality Audits Supervisor L. Henson, Electrical Systems Engineering Supervisor A. Howard, Supervisor of Contracts l
M. Hypse, Lead Electrical Engineer
- +S. Karimi, Compliance Engineer S. Kesler, Acting Electrical Supervisor
- J. Kirby, Director, Nuclear Production Support L. Lodolo, Diesel Generator System Engireer N. Lossing, Senior QA Engineer M. Mann, Quality Assurance Investigator J. Matteson, Quality Nonitoring Supervisor
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L. Hitchell, Emergency Lighting System Engineer l'
- +L. L. Papworth, Director, Site Services S. Fenick, Procurement Engineering Design Control
+R. Prabhakar, Manager, Quality Engineering 5. Schroeder, Electrical Engineer
- * T. Shriver, Compliance Manager
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N. Simko, Maintenance Manager, Unit 2
- L. Spiers, Inventory Control Supervisor C. Stewart, Quality Investigation Administration R. Stueven, I&C Foreman, Unit 3
- T. Thompson, Resident Electrical Engineer W. Wheelis, Control Wiring Diagram Coordinator D. Withers, Electrical Supervisor D. Young, Senior Procurement Quality Engineer J. Zalitis, QC Inspector
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'The inspectors also talked with other. lice.1see personnel during the H
. course of the' inspection.
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Attended the Exit Meeting on March 3, 1989.
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Attended the Exit Meeting on April 14, 1989.
+ ': Attended the~ Exit-Meeting on June 23, 1989.
- Attended the Exit Meeting on July 28, 1989.
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++ Attended the Exit Meeting on August 11, 1989.
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Incaddition, NRC Resident Inspectors attended the exit meetings.
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- 2.
Area Inspection (71707)
An independent inspection was conducted of the Units 1 and 2 Auxiliary Buildings.
The inspector examined areas and equipment for debris,
- potential hazards, oil and water leakage, and equipment condition, e.g.,
oil level, valve position, and electrical connection configuration and cleanliness.
The equipment and areas inspected included:
Units 1 and 2 A.
Two 4160/480V switchgear rooms (trains A and B).
B.
Four 125V battery rooms.
C.
Four battery equipment rooms.
D.
Two remote shutdown panel rooms.
E.
Two diesel generator rooms.
F.
Two diesel generator control rooms.
Housekeeping and equipment status appeared to be acceptable.
No violations or deviations were identified.
3.
Allegation Follow-up - ATS No. RV-89-A-0045 A.
Characterization u
Falsification of Work Orders for the Main Generator.
B.
Implied Safety Significance to Design, Construction or Operation None, because the Main Generator is not safety-related.
C.
A_ssessment of Scfety Significance The inspector, talked to the Hot Line representative about the ifcensee's actions with regard to an allegation that Work Orders were being falsified (Hot Line number 89-041).
The licensee had all the Work Orders in question impounded and found that the de-termination and re-termination verifications were highlighted instead of being initialed when completed.
That is, the contractor personnel were highlighting steps for actual buyoff.
Contractor personnel admitted to doing this.
The licensee determined this to
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be administrative 1y wrong and a bad work practice however, not l
falsification.
A final report on this allegation will be issued
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'withinthenextfewwedkswhichwilladdresscorrectiveactions,
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such as contractor training on acceptable work practice.
A copy of--
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this report will be'sent to the Senior-Resident Inspector.
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D.,
Conc 1'usion and Staff Position
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Actions taken by the licensee have been performed in a reasonable
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manner.to support their findings.
b No violations or deviations were identified.
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Allegation Followup.- ATS.NO.'RV-88-A-055 A.
Characterization-
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1)
Numerous electrical wiring configuration control problems ~ exist after turnover from startup.due to the EE-580 system and drawing issue process -- drawings for DCP's do not. reflect the as-built -- to illustrate.
(a) EE-580 cards have not been forwarded to the EE-580 Coordinator to allow the EE-580 As-Built Records to be maintained.
Work'or' ers go out to, the field without having the EE-580 (b)
d installation cards attached.
(c) There are many missing termination / routing cards, etc.
2)
Quality Assurance (QA) has not been adequately following up on Hot Line calls.
Example:
(a) A member of Engineering Evaluations Department (EED) saw somebody dumping radioactive liquid from Unit 1 into a drain.
The Hot Line call was not investigated because the call was made anonymously.
(b) A Hot Line call regarding non performance of whole body counts prior to leaving site has not been adequately addressed.
(c) A Hot Line call regarding excessive overtime of test technicians performing ASME Section.XI inservice testing has not been adequately addressed.
'(d) A Hot Line call in December 1988, regarding low morale in systems engineering (engi.neering evaluation department)
and the potential impact on plant safety has not been addressed.
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(e) Hot Line call (85-69) was not properly addressed.
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3)
Improper storage of electrical cable / wire, on the ground.
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4)
Quality Assurance is not following up on Corrective Action Requests (CARS).
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Procurement Engineering personnel are not qualified to determine the acceptability of substituted parts.
6)
The-connection wiring diagrams'for the emergency diesel generators, the radiation-monitors, and emergency lighting'are
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incorrect.
B.
Implied Significance to Design, Construction or Operation 1)
Configuration control problems could cause inaccuracies in design drawing records and can result in erroneous modifications to safety systems which could have adverse consequences on safe operation of the plant.
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liot Line. calls'not being properly addressed could result in inadequate correction of safety issues.
3)
Damaged or degraded electrical cable wire could impact the operability of safety-related equipment.
4)
Failure to verify the adequacy of corrective actions could challenge safe operation of the plant.
5)
Improper sttbstitution of parts could result in malfunction or failure of safety-related equipment.
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Incorrect connection wiring diagrams could cause inaccuracies in design drawing records resulting in erroneous modifications
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C.
Assessment of Safety Si(Lnificance
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1)
EE-683 System
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'Backhround
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The EE-580 program is a large (;nmputer program that maintains
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up-to-date records of cable routing and cable termination for
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the plant.
The EE+580 program, in conjunction with supporting
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procedures will identify, quantify, and statur, raceway
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L locations, cable, terminations, and jumper information.
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EE-580 program accepts input, edits, validates, and storcs this
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'information and automatically produces reports which identify I
the result of this information.
The information that is stored in the project data base can be independently accessed by engineering, construction, services, and procurement personnel as required.
The purpose of the EE-580 program, from an i
engineering point of view, is to provide field construction j
with timely and accurate information concerning raceway, cable l._
routing, and termination identification.
The program was
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instituted at the site by Bechtel during the station construction' period.
The EE-580 system maintains the as-built' configuration of the plant cable routings and terminations.
Design modifications are entered into the EE-580 system as a pending configuration change at the time a Design Change Package (DCP) is issued.
The pending configuration change is held in a special section of the'EE-580 system until such time as the Field Work Package (FWP) is prepared, when the pending configuration change is
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- transferred to the EE-580 data base, replacing the as-built configuration.
The installation cards (four types), which are generated at the time the FWP's are developed, are used in the field as instructions for the installation of equipment, raceways, cable, and terminations..These installation cards are the key to the control of the data base of the EE-580 system.
Following completica of work orders in the field, the installation cards,are returned to the EE-580 system, at which time the cards are' "STATU5ED" (construction completed and quality control field inspected) to the EE-580 system data base.
In order for the EE-580 system to function as intended, the installation cards must go out to the field with the work packages and be returned from the field following completion of the work to update the EE-580 data base.
The crux of the allegation is that the EE-580 system was not functioning as designed, in that control of the installation cards was sporadic and incomplete.
In some instances, the cards did not acco:npany the work orders to the field.
In other cases, following the completion of the work, the cards were not returned for entry into the system.
Other lesser infractions, contrary to the prescribed operation of the system resulted in an inaccurate EE-580 data base.
Chronology of Events (a) July 29, 1985.
The quality monitoring audit group prepared Corrective Action Report (CAR) CA85-126, on adverse conditions they found with the EE-580 system.
For example, the Palo Verde Maintenance / Operation / Engineering organizations have been performing activities which involve updating the data base for the EE-580 program without written policies / procedures which establish organizational responsibilities.
(b) August 14, 1985.
Quality Hot Line File 85-69 was filed initially with five items, of which three were associated with the EE-580 system.
Two of the additional three items added to this Hot Line File in September 1986, dealt with the EE-580 system.
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.(c) August 22, 1986.
The QA department prepared CAR
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CA-86-0156, which identi.fied additional procedural problems.
For example, Maintenance Department Directive MOD-05. Paragraph 3.2.3, did not contain statements making
itJ a mandatory requirement for maintenance personnel to-
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obtain cards from the EE-580 coordinator.
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(d). August 22, 1986.
The QA department prepared CAR CA86-0157
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and t'he' responsible work organi7ation for contract work
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orders have failed to generate the necessary procedures
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for EE-580 card control
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(e). August 25, 1987.
Allegation RV-87-A-047 was filed with
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NRC Region V identifying a lack of completeness of site
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modifications 1.i the scheduling of raceway installations
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.per the EE-580 program, lack of interdisciplinary review 3;
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of site modifications, and engineers lack sufficient-
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(f) September 18, 1987, QA Hot Line File 87-075 was initiated and basically identifies the same issues as the ebove allegation.
This action initiated a complete review of the entire EE-580 system program and resulted in a major program to resolve all the outstanding EE-580 system deficiencies and problems.
The inspector examined the above documents and numerous associated documents and came to the following conclusions:
The EE-580 system represents the plant electrical configuration along with the elementary / schematic diagrams, single line diagrams, and raceway layout drawings.
It was turned over to the licensee from Bechtel (construction) in January 1984 (Unit 1).
It was not completely up to date, and was missing some installation cards at that time.
It appears that, following the turnover, the controls for the system, mainly. the procedures for the control of the installation cards, were l
inadequate.
This' contributed appreciably to the. number of missing in ga11ation cards. These deficiencies went uncorrected until the filing of CAR CA85-126 in July / August L
1985, when corrective measures were first initiated.
Corrective Actions The corrective measures taken in response to CAR CA85-126 resulted in preparing a policy for EE-580 use, issuing and/or revising appropriate work control procedures, initiating training for Palo Verde employees who use the EE-580 system, and a review of the effects of deficiencies on the data base.
The corrective measures taken in response to CARS CA86-156 and CA86-157 further upgraded procedures for the operation and
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maintenance departments.for the three units, the outage
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' management department, and work organizations responsible for
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The licensee's corrective measures in response to the NRC's
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letter of September 25, 1987, in which the concerns of allegation RV-87-A-047 were communicated to ANPP, are contained
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in the licensee's letter to NRC dated October 12, 1987.
One of the corrective measures, developed to address the concerns of
' ' RV-87-A-047, was to completely verify the EE-580 system data i;
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The licensee's contracted with Bechtel in Decembec 198h to verify the installation configuration of the EE-580 Circuit and Raceway Tracking System for Units 1, 2, and 3.
The purpose of the verification was to address concerns regarding the status of outstanding EE-580 cards and the status of the safety related cards in the vault relative to the EE*580 program.
The inspector examined the Bechtel contract and the final reports dated May 1988 and the supplement to the final report dated October.1988, The EE-E80 verification program resulted in a total of 106,251 installation cards being reviewed.
A total of 6184 items were not found and require further action.
Of these, 5136 items are class IE installation cards which are associated with safety systems.
The licensee maintains that only 6184 outstanding items resulting from an invehtory'of 106,251 installation cards demonstrates an as-built accuracy of 94% for the plant electrical configuration.
Cable raceway fill / loading, which might appear to be impacted by the missing 6184 items, does not represent a serious concern since pending configuration changes are transferred to the data base at the time the field work package is prepared.
The licensee is presently in the' process of developing a plan and a tentative schedule for the activity of resolving the remaining 6184 items.
Preliminary plans call for further engineering evaluation of the 6184 items to establish actual
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as-built conditions.
For those items which cannot be resnived by this means, a field walkdown will be conducted of the item / system, as necessary. to resolve the concern.
It is V
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by field verification (walkdowns) will be.on systems located
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Lrefueling or prolonged outages. Therefore, the licensee
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T" 6184 items would not occur until the second refuelings for Unit
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2 (Fall 89) and Unit 3 (Fall 90), and the third refueling for e
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, Unit-1 (Late 90).
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To preclude changes or design modifications being made to
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systems which can be affected by the still outstanding 6184
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items, the EE-580 program includes a " star c" status
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(outstanding card in field) and "D.
R." Status (design change pending) which flags the status to the EE-580 system users.
The inspector also examined other aspects of licensee responses j
to the concerns outlined in'NRC's letter of September 25, 1987, and reviewed aspects of the licensee's plant construction
practices and startup testing programs as they related to cable installation / terminations.
These areas included:
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The training program / lesson plans and attendance records f.or training Palo Verde plant personnel in the use of the EE-580 system.
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Bechtel's method and controls for the installation and verification of electrical cable routing and termination during construction.
These methods required verification by field engineers and witnessing and signof f by quality control inspectors.
The licensee's cable identification program.
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related cabling is color coded to maintain separation of safety channels and to preclude intermixing and misrouting cables.
The color coding makes it more difficult to inadvertently violate separation criteria.
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The startup organization's testing programs, which
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included component tests, instrument system loop tests, integrated preoperational system test, and power ascension tests, all verify cable terminations and system completeness.
Power ascension tests confirm system design and operation.
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The new operations oriented cable and raceway tracking system (CARTS) presently being developed to replace, early next year, the construction oriented EE-580 system.
Both systems will be maintained in operation in parallel, until all " bugs" are ironed out of the new (CARTS) system.
Conclusion Examination of the EE-580 system with regard to electrical wiring configuration control problems., drawing issue process, and as-built drawirms revealed that the information provided by the alleger was substantially correct.
Although this part of the allegation was substantiated, once tha licensee bet,ame aware of the problems with the EE-S80 system (July / August 1985), a continuing effort has been expended to upgrade and correct the deficiencies in the EE-580 program / system.
The licensee has committed to resolve, by January 1990, all those 6184 items which can be dispositioned by analysis or walkdowns of systems, where accessible, such as the auxiliary and control buildings, including those in Unit 2 containment.
Only those items inside Units 1 and 3 containments will remain outstanding after January 1, 1990.
The licensee has committed to complete
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these items.by late 1990.. The inspector concluded, based on corrective actions /coinmitments, construction practices, and
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preoperat.15 91/ operational testing programs, that the EE-580
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resolve the systec deficiencies appears acceptable.
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l This item will remain open pending a review of more detailed action programs requested by the NRC, iconitoring of the progress of these programs, and a review of the safety signifi;.ance of the. results (0 pen Item 50-528/89-22-01).
2)
Hot Line Calls The Hot Line Supervisor we.s interviewed with reference to
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. examples the alleger supplied where it was contended there had been inadequate follow-up of the Hot Line concerns.
The Hot' Line Policy is to leg and record ta a computer all Hot
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Lire calls regardless of whether they are anonymous or the caller leaves his/her name.
All concerns are followed-up and
' investigated 4 In those cases where the caller has left his/her-
name, a letter.is sent to the caller describing the findings and dispositioning of the Hot'Line concern (s).
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(a) 'Regarding thE concern alleging dumping of radioactive fluid into a drain,' a conversation between the inspecter and the Hot Line caller clarified the drain as an area drain which collects rain and runoff drainage from a radioactive materials storage area on the (Sonth side) of Unit 1, which might/could become contaminated.
The Hot Line caller was told that a -similar concern had been received earlier on the Hot Line and assignid file No.86-136, a holding pond that is the receiver of water frc:a the area drain could be contaminated.
It was for this
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reason that the particular call was not logged or recorded.
The anonymous caller was told that if he/she would leave his/her name, a letter describing the dispositf oning of Hot Line File No.86-136 would be sent to him/her.
As an alternative to leaving a name, the caller was told to call back in a few days and the.
dispositioning of Hot Line File 86-136 would be read to him/her over the telephona.
The Hot Line calle'r did not leave a name and "hungup"; nor did the caller ever call back to determine the final dispositioning of this concern.
The technical review of Hot Line File No.86-136 has been addressed in Region V Inspection Report 50-528/89-15.
It is concluded for this concern, that a Hot Line call was not recorded or investigated because the caller remained anonymous, is substantiated, in part, with extenuating circumstances.
The Hot Line call was not recorded because an earlier call concerning a similar subject for the same
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crea had already been recefved and was on record as File
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B6-136.
(b) In reference to the concern of a Hot Line call regarding
" nonperformance of whole bcdy counts (WBCs)..." this concern has been addressed fn Region V Inspection Report 50-528/89-15. The aforementioned inspection report concluded that, "Although this portion of the allegation was substantiated, in part, as having occurred, the inspector concluded that the licensee's OA Hot Line response had adequately addressed the problem of termination WBCs not being performed."
(c) In reference to the concern of a Hot Line call regarding
" excessive overtime of test technicians performing ASME Section XI Incervice Testing...," this concern ~was clarified by the alleger when no Hot Line files cculd be identified es-dealing with a concern of overtime for these technicians. The Quality Investigation Supervisor identified eight Hot Line files concerning overtime dating back to 1984; but none dealing with Section XI test technicians. The alle@er contend; that the concern was generated during stroke time testing of vf.1ves during surveillance testing performed by Section XI Test Technicians. Hot Line File 87-078,." Surveillance Testing Periodicity of Valve Stroke Time" was the only file on record for this subject.
The inspector examined 'this documentation and there was nnthing in this Hot Line file to suggest it dealt with the overtime issues for Section XI Test Technicians. The concerns of Hot Line File 87-078 appear to have been aadressed and dispositioned.
The inspector, during discussions with the licensee in following up this item, became aware that a LLRT technician had filed a complaint with the supervisor during the 1988 Unit 2 refueling outage on excessive overtime. However, this issue was resolved within the department concerned and never became a Hot Line item.
The inspector could not conclude that a Hot Line concern regarding excessive overtime of test technicians performing ASME Section XI was filed, Therefore, the inspector concluded that this concern could not be substantiated.
(d) In the case of the Hot Line call regarding " low morale in Systems Engineering Department...." this item as such, was not called-in or filed in December 1988 with the 0A Hot Line Group. However, a concern on the sarne subject was received by the Quality Investig6 tion Department on June (
29,1988, " Low morale is resulting in more errors, more rules and low productivity" in the Engineering Evaluations
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Department (systems engineering).
This concern was assigned as QA Hot Line File No.88-059.
The inspector examined this file and concluded that the concern had been properly followed-up and dispositioned in accordance with QA Hot Line policies.' The Hot Line investigator brought this morale issue to the attention of the responsible Employee / Industrial Relations Representative (EIR), the hidnaeer of the Engineering Evaluations Department (EED) and the Executive Vice President.. The manager of the Engineering. Evaluation Department,'upon being made aware of the morale issues, implemented an "EED Employees Survey."_ The Engineering Evaluations Department Manager in conjunction with the Engineering Manager followed-up the EED Employees Survey by implementing a program in October 1988 to improve the morale of the EED Department and that program in presently in effect, A package of documents forming the bases for the
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allegation that a Hot Line' item concerning morale had been filed in December of 1988, but had not been properly addressed, had been put together by an engineering
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department supervispr.
The inspector contacted.the
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supervisor and was informed the package described above was not filed as a QA Hot Line concern; but was a
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compilation of his notes and conclut,ons from the results of the EED Employee Survey and management meetings on this subject.
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The inspector concluded that this concern was not (
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(e) With reference to the fifth allegation,"... Hot Line File 85-69 was not properly addressed", the inspector examined the.. file in detail.
This Hot Line issue (85-69) was received August 14, 1985 and initially included five items of concern identified by the caller.
Three more items
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were added to this Hot Line issue by the caller in
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September 1986, and an additional three items were included in October 1986 for a total of eleven items.
The investigation of these eleven items was quite involved and stretched over a long period of time.
The QA Hnt Line investigation group substantiated three of the eleven concerns of Hot Line File 85-69.
A letter dated March 16, 1987 was prepared and sent to the person who initially filed the Hot Line call.
Each of the eleven concerns of the Hot Line was adequately addressed in the letter.
As to the findings of the QA Hot Line Investigation Group, tha three item.s 2, substantiated by the QA Investigator were identified in the letter to the caller as confirming the caller's co~ncerns.
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I it is concluded that this concern was properly
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The inspector concluded, following his review and sampling cf QA Hot Line, records and files that the QA Hot Line Investigation Group performed their function in an accepteble
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manner,
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3)
Improper Storage of Electrical Cable / Wire During the inspection it.was determined that all cable and wire are issued from the controlled access Level B Warehouse C.
Warehouse C has been classified Level B per ANSI N45.2.2 (1972)
" Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants." Level B storage conditions are for items sensitive to environmental conditions and require-measures for protection,from the effects of temperature
extremes, humidity and vapors, acceleration forces, physical damage, and airborne contamination. The inspector toured Warehouse C and found cable reels stored on concrete or wooden shelves along with the necessary identification attesting to the acceptability for issuance.
Good housekeeping was observed by the inspector.
This', plus storing the cable wire in Warehouse C ensures protection from_ damage, hardening effects, and accountability for precise record keeping.
Prior to Warehouse C storage, cable was received, stored and issued from the Cable Reel Yard located on the North side of j
the plant by the Water Reclamation Facility.
All the cable j
stored in this area was purchased by Bechtel during the
construction phase.
Since the Operations phase, licensee purchases of these materials all went into Warehouse C.
However, during 1987 to 1989, engineering was evaluating the material located in the Cable Reel Yard to determine the
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quality and traceability of the cable; and if found acceptable,
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was placed in Warehouse C.
This effort was completed and the i
surplus cable inventoried.
A contract is in process of being
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prepared to send out to utilities, construction companies, and
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scrap dealers for a sealed bid to dispose of all of the excess j
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cable (approximately 700 reels).
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The inspector was informed by the licensee that during this transition period, ie: relocation from Cable Reel Yard to
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Warehouse C, cable was issued from the reel yard.
The
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inspector inquired into how a non quality or scrap cable /wiro issued from the Cable Reel Yard would be identified to prevent
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installation in a safety-related application.
For example, suppose 3 feet of scrap wire was tossed over the fence, would the program / procedures, if properly implemented, prevent its
installation.
The inspector concluded that the scrap cable
would not have been installed for the following reasons:
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Material Control Personnel are required to ensure that
'when quality related materials ~are staged in the Central Depot (Warehouse F) or field, a copy of the Quality Control' Inspection tag (green tag) shal!' accompany the
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l material and be placed in the. Work Order Package-following job completion (Reference Procedure 30 AC-9MC01
" Maintenance Material Control" Section 2.6.1, page 3 of 32).
If, however, this material (cable / wire) bypassed Material Control, then QC should be able to identify and
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J delay work until proper materials are supplied, as
described in the following reason.
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2.
QC hold points are required when cable / wire is installed
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in safety-related systems.
This is documented in
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procedure 63 AC-0QQ01 " Quality Control Inspections",
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.Section 4.3.6. 'This procedure requires QC inspection for
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installed.
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r In orded to determine cable traceability, from installation to
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the reel the cable was issued from, the inspcctor reviewed the
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.following randomly selected work order and applicable QC
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procedure:
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Work Order (WO) No. 00337582, was issued to install the
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AC/DC convertor outside the Diesel General panel per Plant
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Change Package (PCP) 85-01-DG-038.
The Work Order Package
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contained the Request on Stores (ROS) which identifies the quantity issued (250 feet) and for tracking purposes the
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Purchase Order (PO).No. and Material Receiving Report MRR
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The reel number is cRntained in the PO file.
The WO package contains the " Control and Tracking System Cable Installation Card" which also identifies the reel number.
In addition the WO package contains the green acceptance tag which identifies the reel number.
2.
Procedure 63 AC-0QQ01 " Quality Control Inspections."
Section 4.3.6 contains the requirement for identifying the reel number as one of the QC hold points attributes verified whenever cable / wire is installed in safety-related systems.
It is the inspector's conclusion that traceability from reel to installation, or from installation to reel, is well docunnted.
This is true, also, for the amount of cable issued.
Thus, an accountability system is satisfactorily defined.
4)
Quality Assurance is not following up on Corrective Action Requests (CARS).
ANPP Procedure 60GB-0QD1, " Corrective Action" establishes the QA measures required for evaluating the adequacy of proposed corrective actions, and for verifying that the corrections have been
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Some requirements of this procedure'which are
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applicable to this issue of QA involvement are as follows:
L Section 2.2 - The Quality Systems and Engineering Manager.is'
responsible for (a) preparation and issuance of a CAR Status ReportL on a quarterly basis, and (b) notifying the appropriate QA/QC Managers when follow-up action is required by their department.
Section 2.3 Corporate QA/QC Department Managers / Supervisors are responsible for ensuring timely corrective actioi by (a) following l
up on delinquent corrective action documents and (b) evaluating
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responses and establishing new (Jue dates if the response is unacceptable (as in the case sf CAR No. CA 87-0050).
Section 2.4 - Managers / Supervisors of site organizations are responsible for ensuring timely corrective action by (a) planing and scheduling corrective action, (b) responding to QA/QC on or before established due dates, and (c) providing a scheduled date for corrective action if unable to complete corrective action by the response due date.
-Essentially this procedure provides QA with the necessary responsibilities for remaining involved in ensuring that conditions adverse to quality are properly dispositioned by the CAR process.
To verity that QA was actively following-up when required by this
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procedure the following five CAR's were reviewed by the inspector of eleven CARS identified by the allcger.
CA85-0126 - This CAR, issued to Operations was opened on July 29, 1985 with an initial response due by September 1, 1985.
The CAR was initiated as a result of QA Monitoring activities which identified the existence of inadequate procedural guidance for control of EE-580 installation cards.
The initial response of August 21, 1985 was determined by QA to be incomplete and, therefore, unacceptable.
A new response date of September 30 was extended to November 15, 1985. The final response was submitted on November 14, 1985.
The corrective actions taken were determined to be satisfactory by QA on December 2, 1985.
CA86-0156 - This CAR, issued to Plant Maintenance, was opened on
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August 22, 1986 with an initial response due by September 22, 1986.
On September 12, 1986 QA sent a letter to the Manager of Plant Maintenance regarding the CAR and the possible need to extend the completion date..The CAR response was completed by October 31, 1986 and subsequently evaluated by QA as acceptable.
Corrective actions e
on some items were scheduled for completion by December 5, 1986.
QA closure of this CAR was on December 9, 1986.
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CA89-0050 - This CAR, issued to Noclear Engineering, was opened on
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April 10, 1987 and closed on June 28, 1989.
QA reviewed the corrective actions taken on April 30, 1987 and found them
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unacceptable. On December 10, 1987 the corrective actions taken
.g were determined to be unacceptable when additional problems were identified in the design configuration area.
These problems were
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l related to the plant configuration program and the need to revise procedures addressing plant _ changes, design :ontrol process,
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l Engineering Evaluation Requests (EER's) and the: change control process. Target completion dates for revising these procedures initially ranged from December, 1987 to July 15, 1988. 0A was involved with verification of the corrective actions taken on December 12, 1987 and January 29, 1988. On June 7, 1988, licensee letter 167-02422-ECS/FCP, changed the schedule for completion of the corrective actions as a result of reorganization, the Configuration Management Working Group Report, the subsequent NRC Safety System Functional Inspection, and associated licensee commitments; all which resulted in a major program revision.
This CAR was closed after the final corrective action was verified as being acceptable by 0A on July 28, 1989.
CA88-0063 - This CAR, issued to Radiation Protection and Chemistry, was opened on July 14, 1988, and responded to on August-25, 1988.
0A's evaluation on September.1, 1988 was for partial acceptance. A meeting was held with OA on September 26 to determine and clarify the issues on which OA based its rejections; the response date was extended.to October 17. The response date was met and 0A's evaluation of the corrective' actions taken was found satisfactory, and the CAR was closed on October 26, 1988.
CA88-0069 - This CAR, issued to fire Protection, was opened on August 3, 1988. A manifold was replaced by a fire pump off the circulating water canal without subsequently having updated the drawings to indicate that a temporary modification existed in that area. After reviewing the problem, the licensee considered this to be a non-significant deficiency which should not be addressed on a CAR. This conclusion was based on (a) being an isolated case, (b)
the group responsible was no. longer in existence, (c) it was agreed to remove the pump and restore the system back to the original configuration, and (d) the issue was not safety-significant.
Therefore. 0A voided the CAR on September 2, 1988 and issued Monitoring Report MA-88-0058 to track resolution of the problems identified.
It is concluded from the review of the above documentation that Quality Assurance's follow-up of corrective actions were adequate and timely to assure prompt and proper dispositioning of CARS.
Inspectors will review the other six CARS, identified by the alleger, during a future inspection.
5)
Procurement Engineering not aualified to determine acceptability of substituted parts.
The replacement of an item that differs in physical or performance characteristics from the item originally specified is considered to be a substitution. When a vendor cannot supply the original item specified in the procurement document, but can provide a substitute, an amendment to the original purchase order.is required to purchase the substitute. Administrative Procedure No.12AC-0PR04, " Purchase Request /0rder Amendments" defines the responsibilities and processes for amending the Purchase Request (PR) and Purchase Order (PO), to
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ensure the applicable technical and quality assurance reviews, concurrences, and authorizations are obtained. If the substitution represents a new item not previously evaluated, then Procurement Engineering processes a Material Engineering Evaluation (MEE) to assure the item is a qualified replacement. The inspector reviewed the qualifications of Procurement Engineering personnel who performed the evaluations described in MEE Nos. 000260 and 000264.
Both MEES involved substitution (replacement) of one specified grade of steel product for another. The procurement engineer who performed these MEES was adequately qualified based upon nuclear industry experience and education. Likewise, the responsible supervisor approving these evaluations was, also, adequately qualified.
In addition, the inspector reviewed the qualifications of four procurement engineers involved in similar evaluations and found them to be equally qualified to determine acceptability of substituted parts.
The inspector also determined that adequate measures are incorporated into the procurement program to assure that all substitutions are properly evaluated for intended service. For example, if procurement engineering authorized a substitution owing a telephone conversation with a vendor, without amending the P0 in
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accordance with 12AC-0PR04, the item shipped would not be accepted during receipt inspection. Receipt inspection is based on the P0 requirements; therefore, a substituted item procured in this~ manner would have a different part number'from that specified on the PO
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which would result in rejection and generation of an NCR at the time
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of receipt.
The inspector concludes based on education alid experience in the-nuclear industry, the procurement engineering personnel are qualified to evaluate the acceptability of substitute materials.
6)
The station connection wiring diagrams for the emergency diesel cenerators, radiation monitors, and emergency lighting are incorrect.
(a) The inspector assessed the extent, if any, of incorrect wiring diagrams for the emergency diesel generators by randomly selecting drawings from the safety related portions of the system and verifying a selected number of terminations on the drawings against the as-built condition.
The selected drawings were:
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Control Wiring Diagram, Diesel Generator System, Diesel Engine M-DGB-H01, Drawing Number 13-E-DGF-007, Revision 0, 13 Sheets.
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Control Wiring Diagram, Diesel Generator System, Diesel Generator "A", Lube Oil Circ Pump 3M-DGA-P04, Drawing Number 03-E-DGF-002, Revision 0, 3 Sheets.
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The. control wiring diagrams were initially prepared by the contractor (Sargent and Lundy) for consolidating Bechtel and
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equipment vendors, EE-580 (cable routing and termination schedule), and ANPP electrical drawings to facilitate operation u.
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and maintenance. -It was understood that the contr61 wiring diagrams were currently under the first review cycle and did g
not include any update of recently completed design change
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packages.
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- The inspector verified the first group of drawings against the Unit 1 emergency diesel generator equipment.
Out of 132 termination points, the inspector found that the cable number and wire number were correct for each of the termination
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points. :Four wires were recently installed per 1DCP DG 060 and were not'yet' incorporated into the drawings.
l The inspector verified the second group of drawings against the Unit 3 emergency diesel generator equipment.
Out of 46 termination points, the inspector found that the cable number and wire number were correct for each of the termination points. The inspector did find one terminal block number was labeled incorrectly on the drawing, but considered this to be of minimal significance.
The licensee took prompt action to correct the drawing.
The inspector, by random sampling of connection wiring diagrams, found no evidence to support the allegation.
(b) The inspector assessed the extent,-if any of incorrect wiring I
diagrams for the radiation monitors by randomly selecting l
drawings from the safety related portions of the system and verifying a selected number of terminations on the drawings against the as-built condition.
The selected drawings were 8 sheets of Control Wiring Diagram, Post Accident Monitor Unit, Radiation Monitor, 3J-SQN-C04, Drawing Number 03-E-SQF-004, Revision 0.
The inspector verified the drawings against the Unit 3 radiation monitoring equipment.
Out of 101 termination points, the inspector found tnat the cable number and wire number were correct for each of the termination points.
The system was composed of multiple units of area radiation monitors with a 1ccal alarm unit.
The wiring terminations were done in an orderly manner by color coded wires for each unit L
and repeated in the same order for all other units.
If any
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color-coded wires were terminated out of order, it would be obvious.
Most of the other wiring connections were by cable l
plugs.
The inspector verified that the plugs only engaged in one way by their orientations and/or by their sizes.
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The inspector, by random sampling of connection wiring diagrams, found no evidence to support the allegation.
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'(c) There'were no. connection wiring diagrams for emergency l
lighting. The cable runs were unscheduled.
The cables were J-field-ropted with no isometric drawings nor labels for the
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conduits.
A' plant walkdown was the only way to trace out the
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! cable routing.
Power to the emergency lighting unit was j
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Loss of
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. power to the. unit was observable by the energized lights of the l
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lighting unit from the local battery pack.
Receptacle plugs were available to deenergize the units locally before
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maintenance.
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However, there were distribution panel drawings to account for
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the power source, ZPL drawings to account for the location and
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the full tag' numbers of those lighting units providing lighting
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for safe shutdown of the plant, and plant layout drawings to account for the location of all emergency lighting units.
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The existing-distribution panels drawings cannot bc relied on l
to make accurate load calculations for each breaker and to-
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account for the lighting units on the breaker.
The licensee j
has committed to have a contractor walk down the emergency
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lighting system to verify and update the existing drawings, to establish the exact load on each individual breaker in the
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distribution panel, and to generate unitized drawings as part l
of a review covering all lightings.
The proposal was in the j
signature process, and the project is to be completed by July
1991.
The cnnduit routing for emergency lighting remains l
unscheduled.
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The electrical group in the nuclear engineering department was initiating design change packages to resolve the deficiencies found during a recent Appendix R walkdown of all three units by the engineering evaluation department.
The inspector found that the licensee was taking steps in updating the drawings to account for all installed plant em?rgency lighting units.
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The inspector found that the allegation was partially j
substantiated in that the emergency lighting electrical drawings did not account for all installed plant equipment.
D.
Conclusions and Staff Positions 1)
The licensee initiated acceptable actions to resolve the concerns identified and deficiencies in the EE-580 system.
The licensee analyzed the extent of the problem with the inventory of the installation cards in the vault and has initiated a program to resolve the outstanding items.
These actions presently appear acceptable.
2)
The licensee!s QA Investigation Department's operation of the QA Hot Line Section has been examined and found to be committed to be responsive to all Hot Line callers with early and
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thorough follow-up and communication of its findings back to the Hot Line caller.
The Hot line records were found to be.
accurate, complete and retrievable.
The Hot Line operation is considered to be acceptable.
3)
The licensee has a satisfactory program which is being implemented to assure that cable / wire is properly stored, and
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issued with traceability from installation to reel.
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4) : Review of documentation indicated that QA was in constant
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communications with the applicable organizations responsible
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for correcting adverse conditions.. From review of the CARS, it was evident that the QA organization was following up to essure that corrective actions were adequate and properly implemented in a timely manner consistent with the seriousness and complexity of the adverse condition.
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5)
Procurement' Engineering personnel are qualified, based upon education and nuclear work experience, to determine the acceptability of substituted parts.
6)
The inspector, by random sampling of connection wiring diagrams, found no evidence to support the allegation with regards to the emergency diesel generators and radiation monitors.
However, the inspector found that the allegation was partially substantiated for the emergency lighting electrical drawings, since they did not account for all installed plant emergency lighting units.
The staff concluded that the licensee's program to update the plant drawings to account for all installed emergency lighting units is acceptable as a corrective measure for this deficiency.
No violations or deviations were identified.
E.
Action Required None 5.
Exit Meeting The inspectors conducted exit meetings on March 3, April 14, June 23, July 28 and August 11, 1989, with license representatives denoted in Section 1.
During these meetings, the inspectors summarized the scope of the inspection activities and reviewed the inspection findings as described in this report.
The license acknowledged the concerns identified in the report.
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