ML20127L184

Insp Repts 50-424/85-16 & 50-425/85-16 on 850415-19. Violations Noted:Inadequate Electrical Penetration Cable Support Installation & Insp Procedures,Inadequate Procedures Re Deviation Repts & Failure to Post Part 21 & Other Info

ML20127L184
Person / Time
Site:	Vogtle
Issue date:	05/22/1985
From:	Conlon T, Gibbons T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127L154	List: ML20127L149 ML20127L166 ML20127L184
References
50-424-85-16, 50-425-85-16, NUDOCS 8506270784
Download: ML20127L184 (8)

See also: IR 05000424/1985016

Text

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gp [th UNITED STATES

g q*o NUCLEAR REGULATORY COMMisslON

['i n REGION Il

g j 101 MARIETTA STREET,N.W.

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e ATLANTA, GEORGI A 30323

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Report Nos.: 50-424/85-16 and 50-425/85-16

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: April 15-19, 1985

Inspectors: //f//

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T. D. Gibbons Date Signed

Approved b Y #7t'fp1V Y2r AS

E. Conlon, Section Chief D&te 5'1gned

Engineering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection involved 72 inspector-hours on site

in the areas of employee concerns.

Results: Five violations were identified: Violation 424/85-16-01 and

425/85-16-01, Inadequate Procedure for the Installation and Inspection of Cable

Supports in Electrical Peitetrations; Violation 424/85-16-02 and 425/85-16-02, No

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. directions for Acceptance / Rejection of Deviation Reports; Violation 424/85-16-03 ,

and 425/85-16-02,. Failure to Disposition Deviation Reports in Accordance with

, Procedures; Violation 424/85-16-04 and 425/85-16-04, Failure to Post Form NRC-3-

! and Part 21 Information in Three Operation Areas; Violation 424/85-16-05 and

p 425/85-16-05,- Failure to Assemble Battery Racks in Accordance with Approved

L Instructions.

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PDR ADOCK 05000424

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REPORT DETAILS

1. Persons Contacted

I Licensee Employees

• D. O. Foster, Vice President and Project General Manager

• H. H. Gregory, General Manager, Vogtle Nuclear Construction

• M. A. Googe, Project Construction Manager

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• C. W. Hayes, Vogtle Quality Assurance Manager

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

• B. C. Harbin, Manager, Quality Control (QC)

• T. L. Weatherspoon, Assistant Manager, QC

• F.-Page, QC Section Supervisor

• L. Glenn, Quality Concerns Manager

Other licensee employees contacted included construction craftsmen,

engineers, technicians, operators, mechanics, security force members, and

office personnel.

Other Organization

• S. Pietrzyk , Assistant Project Engineer, Bechtel Power Corporation

NRC Resident Inspectors

• J. Rogge

• R. J. Schepens

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on April 19, 1985, with

those persons indicated in paragraph 1 above. The inspector. described the

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The following new

items were identified during this inspection.

Violation 424/85-16-01 and 425/85-16-01, Inadequate Procedure for the

Installation and Inspection of Cable Supports in Electrical Penetrations.

(paragraph 5.a.)

Violation 424/85-16-02 and 425/85-16-02, No Directions for Acceptance /

Rejection of Deviation Reports. (paragraph 5.b)

Violation 424/85-16-03 and 425/85-16-03, Failure to Disposition Deviation

Reports in Accordance with Procedures. (paragraph 5.c.)

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Violation 424/85-16-04 and 425/85-16-04, Failure to Post Form NRC-3 and

Part 21 Information in Three Operation Areas. (paragraph 5.d.)

Violation 424/85-16-05 and 425/85-16-05, Failure to Assemble Battery Racks

. in Accordance with Approved Instructions. (paragraph 5.g.)

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

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3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Employee Concerns

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The Nuclear Regulatory Commission has been contacted at various times by

individuals who expressed concerns relating to the construction quality

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control program at plant Vogtle. As a result of these concerns the NRC

inspectors interviewed various personnel, examined QC records, personnel

records and engineering specifications and details. Numerous safety-related

components related to the expressed concerns were examined during this

inspection.

Meetings were held with various management employees in an effort to

determine if concerns expressed to the NRC were part of the ongoing Quality

Concerns Committee investigations. While the concerns were similar in

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nature it was determined that a separate examination of the concerns was

warranted. The following is a list of the concerns examined during this

inspection, a discussion of the method of evaluation used by the inspectors

and the findings resulting from the examination of QA records, procedures,

specifications and discussions with various personnel.

a. Concern: They are adding cable supports internally to electrical

penetration (EP) enclosures without appropriate drawings, vendor

concurrences and in violation of their own specifications.

Discussion: The inspector examined a Stoo Work Notice (SWN) Control

No. SW-E-14 which was issued February 2,1985, to halt the cable pulling

including the cutting of holes for cable entry into the EP box

enclosures. The reason for the SWN was the lack of installation and

inspection requirements for the holes cut in EP enclosure boxes, the

installation of chase nipples and cable support assemblies, and the

coating of cut hole edges. The recommended action for restart was for

engineering to provide installation, inspection and documentation

requirements for the listed activities.

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The SWN was cleared and work resumed on February 22, 1985, when the

questions cited in the stop work order were addressed. However, the

answer regarding the addition of supports in the EP boxes did not-

clearly define the corrective measures in that the resolution permits

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the addition of supports not to exceed limitations of 300 pound weight

and did not define the inspection requirements. The manufacturer had

issued a letter dated February 8,1985, which advised that the load

limit is 300 foot-pounds rather than 300 pounds of weight. However, no

information was given as to how the total weight was to be distributed.

Additionally a Deviation Report (DR) No. 8106 dated March 18, 1985 was

written which again addressed the problem of acceptability and

inspection of the supports added without sufficient engineering

details. The portion of the DR which addressed the addition of

supports to the EP enclosure boxes was dispositioned as "N/A" and

justified on the basis of a drawing which contained various details,

but none that address the installation of these supports. The

inspector was unable to identify any definite details for the cable

support installation. The NRC inspector contacted the EP manufacturer

in regard to the installation of supports in the enclosure boxes and

was informed that the total moment must include the weight of the cable

as well as the support steel.

Findings

This concern is substantiated in part in that there are no

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appropriate drawings on details for the installation of cable supports

, in the EPs. In addition there is no inspection criteria. There was

however, concurrence from the manufacturer (vendor) for the addition of

4 weight with a resultant moment limit of 300 ft-lbs.

This condition is an example of an inadequate procedure and is

identified as a Violation 50-424/85-16-01, 425/85-16-01, Inadequate

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Procedure for the Installation and Inspection of Cable Supports in

Electrical Penetrations.

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b. Concern: Deviation Reports (DR) are not getting numbers. They are

being. rewritten by supervisors and for various reasons are not getting

numbers to be put into the system.

Discussion: Similar concerns have been expressed on three different

occasions. One of these concerns was addressed in Inspection Report

Nos. 50-424/85-10 and 50-425/85-10. During that inspection several QC

inspection personnel were interviewed. Most of those interviewed

advised that they had not had a DR rejected. They stated that DRs are

usually discussed with their peers and supervision before they are

written. The supervision is required to review the DR for

completeness, acceptability, and hold tag requirements before assigning

it a control number in accordance with Procedure GD-T-01, Nonconfor-

mance Control. During the review of this procedure the inspector noted

that by Field Procedure Change Notice (FPCN) No. 35 dated December 5,

1984, the following instructions were given to the appropriate

supervisor in QC," for DRs which you feel should not be assigned a

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number, write a justification as to why, on the DR and send the

original to the Assistant Manager of Quality Control." A QC Audit

Report dated April 16, 1985 identified instances where copies of DRs

that were not given control numbers were not being given to the

assistant manager of QC as directed. Additionally, a memo was issued

by the manager of QC on April 2,1985 which introduced a system that

directs that all DRs will be given an interim number before the

individual presents ' the DR to his supervisor. After review by the

supervisor, if acceptable, the DR is given a control number in the

nonconforming system. The rejected DRs are reviewed by QC supervision

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and ultimately stored in the records vault.

Findings: No site records were maintained or required for rejected DRs

prior to the issuance of FPCN No. 35. Later the QA Audit Report dated

April 16,1985, identified the fact that the procedure was not being

followed for proper handling of rejected DRs. In the present form the

procedure is not auditable for rejected DRs in that no tracking

mechanism is included in the procedure for voided DRs. There are no

provisions in the procedure for logging DRs prior to issuance of a

control number. This finding is partially substantiated in that the

procedure appears to be inadequate in directing the disposition of

voided DRs and there is no criteria for the QC supervisor to base his

rejection / acceptance of the DR submitted for evaluation and entry into

the nonconforming control numbering system. In addition GD-T-01 does

not require an independent review of rejected DRs as required by

paragraph 17.2 of the licensee's FSAR.

This is identified as Violation 50-424/85-16-02 and 50-425/85-16-02, No

Directions For Acceptance / Rejection of Deviation Reports.

c. Concern: Improper disposition of DRs dealing with equipment problems.

Discussion: Several closed DRs were reviewed to examine the

dispositions. Deviation Report ED-05471 concerns a Unit 1 circuit

breaker which was damaged during the installation of the wiring. The

disposition directed that the breaker be replaced with a Unit 2

breaker. It can only be assumed that the replacement breaker is the

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corresponding Unit 2 breaker. Further, no instructions were listed for i

the nonconforming tagging of the damaged breaker. It was also noted i

that one individual performed the evaluation, approved the disposition

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and approved the inspection requirements for Georgia Power Company

(GPC).  ;

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Deviation Report No. ED-08440 reported the removal and apparent loss of l

a 5 amp and a 10 amp class IE breaker from the Diesel Generator (D/G) A l

motor control center (MCC). The disposition was to remove breakers

from Unit 2 and install them in Unit 1. However, the justification

! states that, "If the missing breakers are used elsewhere the quality i

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standards will still be maintained because the missing breakers are l

class IE." The disposition does not address the unauthorized removal )

of the original equipment, but qualifies them as class IE even though  ;

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the location, condition or use of them was not known at the time the DR

was dispositioned. Deviation Report No. ED-06060 identified several

electrical cabinets with cable entries that violate the details of

design drawings and specifications. The disposition does not address

the problem but, instead promises that a sealant will be installed.

Here again the recomended disposition, the approval and work complete

was signed by the same individual.

Several DRs cited termination or . pulling of cables without QC

observation stating that the equipment was not affected, only a

procedure was violated. No justification was given for the procedure

violation.

Finding: This concern was substantiated. The DRs reviewed by the

inspectors confirm that the dispositioning of DRs is not clear, lack

sufficient instructions and do not require adequate corrective actions.

These conditions are identified as Violation 50-424/85-16-03 and

50-425/85-16-03, Failure to Disposition Deviation Reports in Accordance

with Procedures.

d. Concern: The worker claimed that craft / construction personnel do not

know how to contact the NRC resident inspector and that appropriate

telephone numbers should be posted at the site.

Discussion: The NRC inspector examined the telephone directories for the

site, Augusta and Waynesboro. The site directory has an NRC Resident

Inspector listing with the correct number listed. The Augusta

directory has a listing for the Region II Office in Atlanta and the

Waynesboro directory has a listing for both the resident inspectors

office and Region II.

The Form NRC-3 is posted in six places where workers can see it when

going to work or leaving work in the construction areas.

The NRC inspectors wear the NRC hardhats and blue jackets while in the

plant. The senior resident inspector for construction is known to the

crafts and construction personnel.

Findings: This concern is not substantiated. However, the NRC inspec-

tors did identify a violation while researching this concern. The

licensee has failed to post the Form-NRC 3 and Part 21 information

in the nuclear power administration building, service building and

maintenance building. This is a Violation of 10 CFR 50.7(e) and

10 CFR 21.6(a) posting requirements. This Violation is identified as

50-424/85-16-04 and 50-425/85-16-04, Failure to Post Form NRC-3 and

Part 21 Information in Three Operations Areas.

e. Concern: The worker claimed that his supervisor had told QC inspectors

to leave a job after they had issued a stop work order because a 1300KV

cable was stressed to over 1000 pounds during a pull.

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Discussion: The NRC ins?ector examined the plant power systems

drawings to ascertain wh 3re the 1300KV power was used. There is no

1300KV power system at tv plant. The worker must have meant 13.8KV

cable. The Final Safety Analysis Report (FSAR) paragraph 8.3.1.1.1

states that the 13.8KV system is a Non-Class IE system.

The licensee procedure ED-T-07, " Cable Installation" Revision 7 dated

December 21, 1984 states in paragraph 1.0, "QC department inspection is

required only for Class IE cables" and GPC Electrical Field Operations

personnel are responsible for maintaining quality standards for all

non-class IE cables. QC inspection is not required for the 13.8KV

cable.

Finding: The concern could not be substantiated. The QC inspectors

were not following these procedures in that the observation of non-class

IE cable installation is the responsiblity of GPC Electrical Field

Operations personnel. The QC supervisor was correct in directing his

employees.

f. Concern: The worker stated that there are no procedures dealing with

the pulling of non-class IE electrical cable over 600 volts.

Discussion: The NRC inspector examined procedure ED-T-07. The

procedure states in paragraph 1, "GPC Electrical Field Operations

personnel are responsible for maintaining quality standards for all

non-class IE cables." In paragraph 3.7 the field operations personnel

are directed to perform in process monitoring of non-class IE cable.

Paragraph 5.5 requires high potential testing to be witnessed by

electrical field operations personnel when testing non-class IE cables.

Findings: This concern is not substantiated by the facts that ED-T-07

does in fact cover the installation of non-class IE cable rated 600

volts and above.

g. Concern: Equipment turnovers are being accomplished without the

installation being complete and the appropriate documentation not being

on file.

Discussion: The inspector examined hatteries, IAD1B, ICD 1B and 18D1B,

which had been turned over for testiag. It was found that the racks

were not uniform in the spacing provided at the ends of the racks. The

rack ends are tight against the end cells on one row of battery cells

while anather row of cells in same battery has a gap of 7/8' (Battery

ICD 1B) and 3/4" (Battery 1AD1B). The racks for Battery 1BDIB have

three rows of cells which have gaps of 3/4" at each end, 1" at each end

and 7/8" at each end. One row of cells has the rack end in contact

with the cells. Records examined by the inspectors revealed that the

only inspection -performed by QC inspectors was torquing of rack

assembly bolts. For battery rack 1AD1B there were no rack bolt torqu-

Ing records, battery rack 1BD1B had 5/16" bolts torqued to 27

foot-pounds on a rework order. Battery rack 1CD1B record listed the

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tie bar torquing value at 12 foot-pounds and its rod brackets at 17

foot-pounds. No bolt size was listed.

It was also noted that the craft had used torque wrenches calibrated in

inch-pounds (in-lbs.) while the QC inspectors used torque wrenches

calibrated in ft-lbs. No conversion calculations were attached to the

records. It should be recognized that there are three sizes of

batteries. As a result the racks for each battery are of differing

dimensions.

Findings: It appears that the assembly drawings for these battery

racks were not followed during the erection and inspection in that the

racks are not uniform and QC inspections were not performed in the same

manner. This concern is substantiated. The assembly of these battery

racks appears to be a violation of procedures, drawings and

instructions in that the racks for the individual batteries are not

uniform in length. Further, the manufacturer advised the NRC

inspectors that the rack ends should be in contact with the end cell in

each row.

This is identified as Violation 50-424/85-16-05 and 50-425/85-16-05,

Failure to Assemble Battery Racks in Accordance With Approved

Instructions.

6. Inspector Followup Items

(Closed) 424/85-10-04,425/85-10-04, Review S?aff Engineering Qualifications.

The NRC inspector selected five licensee engineers and five engineers

employed by the licensee's electrical contractor. The NRC inspector

examined personnel records of the employees to verify that their training and

experience were adequate for their positions. The inspector found that each

individuals' record confirms that he is qualified for the position he fills.

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