ML20127L184
| 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: |
| References | |
| 50-424-85-16, 50-425-85-16, NUDOCS 8506270784 | |
| Download: ML20127L184 (8) | |
See also: IR 05000424/1985016
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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101 MARIETTA STREET,N.W.
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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:
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T. D. Gibbons
Date Signed
Approved b
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E. Conlon, Section Chief
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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
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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-
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and Part 21 Information in Three Operation Areas; Violation 424/85-16-05 and
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425/85-16-05,- Failure to Assemble Battery Racks in Accordance with Approved
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Instructions.
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8506270784 050528
ADOCK 05000424
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REPORT DETAILS
1.
Persons Contacted
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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
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determine if concerns expressed to the NRC were part of the ongoing Quality
Concerns Committee investigations.
While the concerns were similar in
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
the addition of supports not to exceed limitations of 300 pound weight
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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
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however, concurrence from the manufacturer (vendor) for the addition of
weight with a resultant moment limit of 300 ft-lbs.
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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
Procedure for the Installation and Inspection of Cable Supports in
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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
and ultimately stored in the records vault.
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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
corresponding Unit 2 breaker.
Further, no instructions were listed for
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the nonconforming tagging of the damaged breaker.
It was also noted
that one individual performed the evaluation, approved the disposition
and approved the inspection requirements for Georgia Power Company
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(GPC).
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Deviation Report No. ED-08440 reported the removal and apparent loss of
a 5 amp and a 10 amp class IE breaker from the Diesel Generator (D/G) A
motor control center (MCC).
The disposition was to remove breakers
from Unit 2 and install them in Unit 1.
However, the justification
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states that, "If the missing breakers are used elsewhere the quality
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standards will still be maintained because the missing breakers are
class IE."
The disposition does not address the unauthorized removal
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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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