ML20195D405

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Forwards Draft Rept of Insp on 710412-14.Major Areas Inspected:Requirements of PI3800/2,Attachment H & I,Sections 5105.03,04 & 5205.03,04 Re Present Cont Activity
ML20195D405
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/28/1971
From: Fred Bower
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Andrea Johnson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20195C961 List:
References
FOIA-88-156 NUDOCS 8806230113
Download: ML20195D405 (15)
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UNITED STATES

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Y y&  %.h APR 281971 !
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  1. ,7 A. Johnson, Reactor Inspector - ,-

Region V, Division of Compliance U 'ly i[' W, /

THRU J. Long, Senior Reactor Inspector egion II, Division of Compliance INSPECTOR'S EVALUATION AND OPINION - PACIFIC CAS AND ELECTRIC COMPAhT (DIABLO CAh70N UNIT NO.1), LICENSE NO. CPPR-39, DOCKET NO. 50-275 This memorandum refers to the feeder report for the inspection conducted Ap ril 12-14 , 19 71.

From my review of the PG&E QA Manual, the PG&E inspection instructions, procedures and the contractor's QC Manual, I have concluded that a suitable QA/QC program has been developed for the E/I work scheduled for the present electrical contract.

I was favorably impressed by the large number of PG&E personnel onsite.

This group apoears to have implemented the program suitably to date.

I feel that G. Richards has identified the need for someone in his QE group with E/I experience due to our inspection. I believe that the addition of such a person would strengthen the QE group considerably; however, I do not feel that we should actively push for this since they l already have a larger onsite staf f in the general QA/QC area than most l licensees at the projects I have visited.

The short and really inconclusive period of time that I was able to discus =

the E/I QA activity with E. Barrido suggested that he was not yet fully j on top of his responsibilities. He has only been assigned to this site for some three months which may be his problem. In any event he aopears, at present , to be a weak point in this program that hopefully will improve over the near future.

As discussed in the report, there are several areas that apoear to need strengthening. In particular, I don't feel they have fully ar.alyzed the many problems associated with the cable installation. I feel that k'right's reference to the use of color coding is a plug factor but not the total answer he seemed to think it was. The real secret to success in this area would seem to be more related to close supervision and continued QC it.spection during installation than any other apnroach.

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A. Johnson APR 281971 I hope they continue to develop strong and detailed procedures particularly for cable traceability, seismic certifications, separations criteria, con-ductor termina tion , e tc. , that we discussed during the visit. The next inspection in this area should reveal the effectiveness of this inspection.

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~7 khh F. U. Bower 00:II:FUB Reactor Inspector

Enclosure:

Feeder Report (Bower) l I

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  • (- (' DRAFT NO. 1 BOWER:wb 4/21/71 FEEDER REPORT Pacific Gas and Electric Company Diablo Canyon Unit No. 1 Docket No. 50-2 75, License No. CPPR-39 Category A Location: San Luis Obispo, California Date of Inspection: April 12-15, 1971 S COPE The inspection activities during this visit were directed toward the requirements of PI 3800/2, Attachment H and I, Sections 5105.03, .04 and 5205.03, .04, as they relate to the present construction activity.

Additionally, the opportunity to discuss and review planning action for future construction activity in this area was taken as a means of orienting the individuals and organization involved to the interests and expectancies of the Division of Compliance in the control of quality of electrical /

instrumentation (E/I) installations. ,

S tdt'iARY

1. Procedures reviewed indicated an adequate program for the E/I installa-tion work in progress and as scheduled for the immediate future. (See Section C.2.)
2. Although Pacific Cas and Electric Comoany (PG6E) has a very large site staf f, there may be a weakness in the E/I area in the QC and QE groups. (See Sections C.2 and C.4.)

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3. E/1 construction activity, both completed and in progress, is so minor that an evaluation of workmanship and related inspection action could not be meaningfully made at this time. (See Section B.)
4. Several potential oroblem areas, involved in future work, were discussed with indications that the QA/QC planning effort was incom-plete. (See Section C.4.)

Management Interview - The inspector participated in the close out meeting with the princioal inspector and presented the results of his inspection.

The following items were presented in summary with questions and/or statements of clarification being the only response f rom the PG&E staf f members present.

1. Seismic requirements and the documentation of tests and/or analysis i.c the E/I class of equipment and its installation. (See Section D.2.)
2. Tr.,ceabilit? of cable manufacturers test data certification. (See Section C.4.)
3. Conductor termination and inspection program. (See Section D.l.)
4. Cable ins tallation adminis trative program. (See Section C.4.)
5. Program for inspecting installed safety-related cables to a given standard. (See Section C.4.)
6. Imoulse line location and installation 'or safeguards system instru-men t channels. (See Section D.3.)

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7. Control of conductor splicing. (See Section D.4.)
8. In the more positive view, the inspector discussed the several pro-cedures and construction drawings reviewed and found suitable for their intended purooses. These included the receiving inspection and warehousing of electrical goods, the riefi:ict tviation/ variation reporting and disposition program and the electrical penetration design and layout.

DETAILS A. Persons Contacted PG&E J. Carvin - Quality Engineering - Site R. Woods - Quality Engineering - Site B. Good - Quality Engineering - San Francisco E. Barredo - Quality Engineer - Site R. Wright - Resident Engineer (Electrical) - Site J. Price - Electrical Insoector - Site I. Mcdonald - Lead Electrical Insoector - Site C. Townsend - Lead Electrical Inspector - Site G. Richards - Director Quality Engineering - San Francisco Howard P. Foley Company - Electrical Contractor L. Bergstrom - Project Manager J. Moore - Chief - Quality Assurance B. Cons truction Procress -

With the exception of the station ground grid, eqst-in conduit and a minor amount of exposed conduit, little of the E/I installation has been started. Work is commencing in the spreading area under the 12-4.16 Kv distribution boards in the turbine building which are safety related, however, this work is not being oressed.

A total E/I work force of ten electrichns is indicative of the oriority nresently niaced on this activity.

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A review of planned events indicates that vigorous activity in the E/I areas is still some weeks in the future. From this review it was determined that the next insocetion could possibly be deferred until f all or early winter without deletertous ef fect on the Compliance inspection program.

When the f acility construction ef fort advances 'o the point where the several key . areas become available, electrical constructbn activity could mushroom rapidly because a very large portion of the electrical equipment has already been received and is in storage at the site.

As a result of this availability, the labor force may be expanded very rapidly and ef fectively which in turn could tax the QA/QC organization.

This is a point that should be monitored.

C. QA/QC Progran (3800/2, At tachments H and I)

1. *5105.03 - Implementation of QA Program A 0) orogram, as evidenced by the several documents, has been developed and implemented as required. The specific provisions of the QA program is set forth in a document entitled, "PG&E QA Manual, Diablo Canyon Unit No. 2." In answer to the question regarding ef fectiveness against Unit No. 1, the staff confirmed -

that the provisions of the document had been developed to meet the licensing requirements imoosed for Unit No. 2 and the 18 criteria of Appendix B to 10 CFR Part 50. Now the document is equally ef fective against both Unit Nos. 1 and 2 and, in fact, the QA program is a single ef fort with no distinction in require-ments between the two units.

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2. *5105.04 - Review of OC System
  • b.6 General instructions regarding handling and storage are contained in the QA Manual previously discussed. Any specific instructions, as detailed by the suoplier or implied by the physical characteristics of the equipment, will be inspection items identified and listed by the purchase specification. These instructions become inspection points required to be observed by the contractor QC organization and the PG&E QC organization.

The required QC actions are described by procedures contained in the Howard P. Foley Company "QA Manual" and the PG6E "Electrical and Instrumentation Instruction Book for QA."

  • b.7 E/I components identified as nonconforning are handled in the same manner as other components and the procedure utilized are Common.

In essence the comoonent found discreoar*. is tagged "Hold" and a "deviation report" prepared. b'hile the deficiency is being analyzed for ultimate disposition, the component is isolated in a segrated area if feasible. If not feasible to move the com-ponent, the hold tag is considered suitable to avoid installing or using the discrepant comoonent.

A nrocedure has been devised for review and disnosition of discrepancies that assures conformance with all requirements and nrovides docurentation of the action taken.

  • 3S00/2.

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Exhibit A, attached hereto, is a flow chart of the discrepancy disposition action that appears to indicate all milestones in this procedure.

  • c.1 All handling and installation requirements are imposed upon the E/I contractor by the construction specification which forms a part of the relevant contract documents.

By reviewing the construction specification (No. 8807) effective for the E/I work presently in progress, it is readily apparent that both general and specific requirements are set forth therein in a manner intended to be both effective and complete to assure that the work performed will meet quality standards. These quality standards consist of both industry standards and/or PG6E standards both of which have been referenced and made avail-able for use and are intended to provide an E/I installation in conformance with the commitments of their application.

  • c.2 The use of qualified electricians experienced in the trade is required by contract. Individuals sith special skills for work requiring special exoerience f or such purposes as terminations ,

stress cones , testing, etc. , will be identified as the job pro-gresses and such skills will be employed as required. Con fi rma-tion of ocrformance will be certified through QC action.

  • 3800/2.

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  • C.3
a. Inspection of the E/I installation is organizaed in a way to give a three tier approach. The electrical contractor is the first tier and is required by contract to establish and naintain an onsite QC unit of a semiautonomous character that inspects and documents in accordance with an approved plan.

The second tier of inspection in the PG6E onsite electrical organization (see Exhibit B) which also inspects installed hardware as well as audits the QC activity of this electrical contractor. This activity performed in accordance with a plan set forth in their "Electrical and Instrumentation Instruction Book for QA."

{ The staf f individual, responsible to the electrical resident O .

engineer for the QA function, is relatively new to the site

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(three months) and does not presently appear to have a full

~~~~ grasp of his responsibilities. Hopafully, future evaluations will reveal increased competence, assuring suitable performance in this important oost. -

The third tier is a periodic audit f unction performed in accordance with a credetermined plan by the onsite Quality Engineering (QE) unit o f PC&E.

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b. Testing will be performed by the onsite PG6E electrical organization. Although little has been accomplished in actual installation, the test unit and a mobile test laboratory are onsite performing preliminary calibrations and test of equipment received at the site. The electrical resident engineer discussed their plans for testing which will seemingly be a very comprehensive program that is designed to meet or exceed the requirements of the PG6E QA

?tanual.

3. *5205.03 - Imolementation of QA Program The general QA program discussed herein under item "1" above is equally effective across the board and is suitably implemented to make a positive finding for this inspection point as is indicated for item "1."
4. *S205.04 - Review of QC System
  • b.2 The soecification and purchase order for cables has not yet been released by Engineering; however, it is clear that the general policy for test is to require the manufacturer to perform such .

tests as set forth in the specification and orovide test results to PC6E by certified document.

Discussions with the QE and QC personnel indicated a lack of a specific program that would provide traceability and assurance

  • 3800/2.

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that cables as installed were certified as required by their

&t program. This inspection point th7GTd be reexamined at a later date when elements of their cable certification program have been detailed.

  • c.2 The procedure for receiving inspection and discrepancy reporting is equally ef fective against cables and is deemed suitable to assure that discrepant materials will be held segregated and will not be installed.
  • d.3 Storage areas and/or protective shelters have not yet been established for cables.

This inspection point $$ E(td be reexamined at an appropriate time in the future.

  • f.2 Wireway location and installation is a design function that has been performed by the engineering unit and is required by the general provisions of their PSAR in terms of separation and protection.

The PG&E QA/QC unit sees their obligation as one of confirming that tae construction drawings are converted accurately to installed hardware. They do not feel obligated to confirm that design has fulfilled all requirements of aonlicable criteria nor

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has such a docume t generally known as a "separation criteria" been written for the use of all groups with related responsibilities.

During the discussions it was pointed out to the site staff that the Compliance inspector would be inspecting f rom a standpoint of criteria, along with the cons truction drawings. When installed hardware is found to diverge from the criteria, a nonconformance is considered to exist, irrespective of construction drawings.

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This inspection point sheutt be reexamined at a later time when a more positive evaluation has been made based on performance of their progran as applied to a representative sample of installed materials and equipment.

  • f.4, f.5, and f.6 Cable routing, redundancy, separation and wireway loading is intended to be controlled, in the major sense, by a computerized program (EDP) developed and implemented by PG&E engineering.

The program, as developed, must wait until an appreciable amount of related work has been performed for e'raluation, however, it seemingly has elements that could give assurance that at least some of the many possible variables are controlled.

A specific pro? ram for inspection and documenting installed cables to a given standard has not yet been developed to the deRree expected. The discussion on this subject revealed that the QE group did not have a menber that was experienced in the E/l area. Although not a commitment, it uas indicated that a progran t.nd a suitably experienced person would be considered.

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W These inspection points SM be reexamined at a later ciate before a finding is reached.

  • f.9 Site NOT for installed cables will be eerformed by the PG6E test unit. Details of this nrogran have not been develoned since no urgency nresently exists in this area.

g d..e This inspection point sLehl be deferred for later visits.

D. Discussion Iten

1. The elements of a nrogram for conductor termination and insnection wtu.

was discussed.

They do not eresently have a formal nrogram for this function and ,/

it is not clear that one will be develooed M Se OE unit and  ;

others listened attentively to the inseect a e erarks on the merits of a tool cont rol program at.) the notentd al problem j

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associated with noorly made terminals.

2. The problem identified at other projects ** in secuting and main-taining suitable documentation confirming that the E/I equionent would nerform as required during and af ter the design seismic event was discussed by the inseector.

In resoonse, the PG6E staff stated that their nrocurement soecifica-tions required that the equipment meet these requirements, but it

  • 3E00/2.
    • Note: The nroblen was discussed without reference to the snecific nrojects, m ~ . . -_

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r was not clear that the vendor was required to provide a certified docunent that the equipment had been tested and/or analyzed and did meet the seismic requirements.

This item shesia remait/open for future discussion and evaluation.

3. The subject of impulse lines for safeguards instrument channels was discussed from the standpoint of their relative importance as a cart of a redundant system.

It was centioned that these lines are quite of ten located in areas whe.nchigh energy accident conditions could occur. Since these lines are usually the first element of a system sensing variables outside the set points , it was stressed that their imcortance should not be under estimated. The inspector stated that, although the IEEE 279 standard dealing with the single failure criteria was not snecifically df fective against these lines, it orovided an excellent guide for consideration in the routing and installation of such systems. They were urged to not let these lines be installed under the "field routed" conceot, traditional in regular industrial installation of such systecs, since the chances were good that such procedure would not produce an installation that was accentable.

Since the PG6E staff had not identified these installations as critical, they did not know what control would be orovided by Engineering.

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This item chcrid remain) onen for continued discussion and evaluation.

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4. The construction specification that will control the installation of safety-related cables has not yet been written. In response to the insnection question, the s taf f stated that it was PG&E policy to make all conductor solices in boxes or cabinets pro-vided for the ournose. Specifically, they stated that folices were not made in conduit, trap or wireways.

This item steu+4 remaint onen until the specification in question is released and the staf f connittent can be confirmed.

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