ML20207P916

Rev 3 to Insp - Insp Procedures, Element Rept

ML20207P916
Person / Time
Site:	Sequoyah
Issue date:	01/09/1987
From:	Akeley W, Halverson R, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207P893	List: ML20207P892 ML20207P895 ML20207P900 ML20207P903 ML20207P907 ML20207P910 ML20207P913 ML20207P916 ML20207P922 ML20207P926
References
80202-SQN, 80202-SQN-R03, 80202-SQN-R3, NUDOCS 8701200403
Download: ML20207P916 (23)

Text

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.t TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80202-SQN REPORT TYPE REVISION NUMBER:

~ Element Report 3 TITLE:. PAGE 1 0F 10 Inspection - Inspection Procedures REASON FOR REVISION: Rewritten to incorporate supplemental response to CATD 80202-SQN-2.

Note: Sequoyah Applicability Only PREPARATION PREP Y: R. HALVERSON/W. AKELEY

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REVIEWS PEER:

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CONCURRENCES

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L MK NM"7b /-7-1r7 SRP A = /? N l'7-F7 SIGNATURE DATE ' SIGNATURE

• DATE APPROVED BY-

[Yff)/ l~ V'07 N/A l ECSP 'MANA'CER DATE MANAGER OF NUCLEAR DATE I POWER CONCURRENCE (FINAL REPORT ONLY) l *SRP Secret ry's signature denotes SRP concurrences are in files. ,

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s-dh- r TVA EMPLOYEE CONCERNS REPORT : NUMBER:'

SPECIAL PROGRAM'- 80202-SQN '

- - REPORT, TYPE: - REVISION NUMBER:

Element Report 3. .

- -TITLE:' 'PAGE 2 0F 10

- Inspection-Inspection Procedures

'1.'Of CHARACTERIZATION OF' ISSUES l l

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-x 1il' Introduetion- Lj The issues - described in this Element Report were derived from employee

l a _

concerns generated as -- a result of: the : Watts .Bar - Employee Concern j

'Special' Program. - ' The issues were . determined to be applicable toi the '

L Sequoyah Nuclear Plant (SQN)i and twere ' investigated and evaluated on. '

that. basis.' l 1.2 ? Description of' Issues

~

, The conditionaireported by' Concerned Employees are:-

A. Unknow'ledgeable inspectors utilized procedures to . aid in the

' inspection process.. (00-85-005-002) l B. _

Un'a cceptable - . conduit bends and > threaded conduit . joints were accepted by inspectors.= (00-85-005-002)  ;

- C.- Surveillance Instructions (sis) and Maintenance Instructions

- (mis) are revised in an uncontrolled manner (pen and ink ' changes .

in the field). (SQP-86-009-X03) ,

D. - Notice of Indications . (NOIs) and . Maintenance Requests (MRs) do

. not .have a ' proper tracking system. (XX-85-102-008) e

'2 .' 0

SUMMARY

i 2.1. . Summary of Characterization of Issues Principal issues . disclosed by concerned employees are: whether inspectors are knowledgeable or do they get by with the help of procedures; - inspectors' accepted unevenly bent conduit. and conduit joints with too many exposed threads; uncontrolled pen and ink changes

-to sis and mis; and MRs and NOIs are not properly tracked.

$ 2.2 Sununary of Evaluation Process The - Quality Assurance Category Evaluation Group (QACEG) evaluation consisted of reviewing Specifications , Instructions, Procedures,

Inspection Reports, Survey Reports, and Correspondence. Discussions g

were held with Quality Control (QC) and Quality Assurance (QA) personnel to determine specific problem areas regarding electrical inspections, field pen and ink changes to sis and mis, and program controls for NOIs and MRs.

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• l' 1TVA EMPLOYEE CONCERNS: - REPORT NUMBER -

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SPECIAL PROGRAM ~ 8020 2-SQN 1 _

; .-- ' ; REPORT. TYPE

" REVISION NUMBER:

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m ' Element Report '3

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-TITLE:- PAGE 3 0F.10

. Inspection'-Inspection Procedures s, ,

2.3 . _ Sununary : of Findinas

- The -- conclusion : reached as a result of the L QACEG evaluation of .these :

issues are summarized below.-

~The , issue of :QC -Inspectors not. having adequate } knowledge was not

' sub s tantiate'd . - The concerned employee' stated 1 that - QC Inspectors used procedures in the performance of their. duties. Inspectors are trained in . ~ the use o f QC Inspection Procedures . and : utilization l of procedures - ,

'during inprocess inspections is'an accepted practice.

U' The issue of unacceptable conduit bends. and threaded cond it joints is partially substantiated.: While specifications contained specific installation criteria, QC inspectors -vere not required by procedure to -

inspect conduit bends or exposed conduit threads.

With . regards to . sis and mis being. revised. in an uncontrolled manner -

. (field. pen and- ink- changes), this issue was .found-I to be unsubstantiated.- The ~ concerned _ employee had not provided - specific '

information. However, QACEG investigation reveals ' adequate controls are 'in place to control revisions to- plant instructions.

O ' TVA - QA Surveillance Reports revealed no instances where Surveillance or Maintenance ' Instructions were revised in an uncontrolled manner. -

The: issue of NOIs . and MRs not having a proper tracking system _ is-partially substantiated. However, no upper or lower tier requirements have been violated. The program that controls MRs does not provide i feedback or status intormation to the initiating individual or

. organization.

2.4 Corrective Action Taken and the Results Achieved to Date 1 2.4.1 Issue -- Unacceptable conduit bends and threaded conduit 4 joints were accepted by inspectors.

4 Nuclear Safety Review Staff (NSRS) Report I-85-968-SQN (Attachment B) identified this problem and transmitted their reconsnendations to H. L. Abercrombie, Site Director of SQN, on February 24, 1986 requesting a response by April 20, 1986.

NSRS recoaunendation suggested an engineering evaluation of the

' ef fect of unevenly bent conduit and exposed threads at conduit joints should be made.

2.4.2 Issue -- NOIs and MRs do not have a proper tracking system.

4 QACEG issued CATD 80202-SQN-01 (Attachment C) identifying that Standard Practice SQM-2 does not provide Maintenance Request or Work Request (WR) status information to the initiating individual or organization.

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-TVA EMPLOYEE CONCERNS REPOR'" NUMBER: -

SPECIAL PROGRAM 80202-SQN

' UREPORT TYPE:: REVISION NUMBER:-

[ Element Report .3 ~

TITLE: PAGE 4'0F 10 Inspection-Inspec' tion Procedures

.3.0 LLIST OF EVALUATORS

- E 'M.-Akeley..

R. D. Halverson 4

,.4.0' EVALUATION PROCESS

'4.1 General Methods of Evaluation Upper-tier programs and- lower-tier - implementing . procedures 'were-reviewed to determine requirements 'and . specific - responsibilities.

Standards , . Specifications, Instructions,- Inspection Reports,' -- NSRS

~ Reports, Survey Reports, Surveillance Reports, and' Correspondence'were

. reviewed to ' determine the extent of - the issues and1 their overall

. . significance : to the the plant structure. ' Discussions were held with.

cognizant personnel pertaining to specific problem areas regarding electrical 1 inspections and the. program for controlling Maintenance

Instructions, Maintenance Requests,' and Notice of Indications.

4.2 Specifics of Evaluation 4.2.1 Issue -- Unknowledgeable inspectors utilize procedures to aid' in the inspection process.

4.2.2 . Issue -- Unacceptable conduit bends and threaded conduit l- joints were accepted by inspectors.

-Reviewed Employee- Concern File including Confidential File for

!- any additional intormation pertaining to these issues. . NSRS Report I-85-968-SQN was issued documenting the investigation and- findings of ' concern 00-85-005-002. This report was reviewed and - it contents-re-evaluated. Codes, Specifications, i

Instructions, and Standards reviewed during this evaluation are those ' included in the NSRS Report, " Documents Reviewed During This Investigation I-85-968-SQN and References".

. 4.2.3 Issue -- Surveillance Instructions and Maintenance Instructions are revised in an uncontrolled manner (pen and

- ink changes in the field).

[

A review of the Employee Concern File including Confidential

File did not provide specific details, therefore a review of the program that controls the review and issuance of new and revised Plant Instructions was conducted. The NQAM, Part III, Section 1.1, revision March 21, 1985 " Document Control" was

~

reviewed and discussions were held with two QA Engineers and j one Quality Control (QC) Supervisor knowledgeable of the issue

' of determine possible cause for revisions to sis or mis by field pen and ink changes.

.T ~

TVA EMPLOYEE CONCERNS . REPORT NUMBER:

SPECIAL PROGRAM REPORT TYPE: 80202-SQN Element . Report = REVISION NUMBER:

3 TITLE:

Inspec tion-Inspection Procedures PAGE 5 0F 10' A review was 'also conducted on the QA surveys associated with SI and MI activities. This included reviewing seven Survey Reports of SI activities performed during the period of April 1985 through October 1985 and twenty-one Survey Reports on MI activities during the period of January 1985 through _0ctober 1985. The survey reports are:

Surveys of SI Survey Period 13A-85-A-001 4/26 and 4/27/85 13A-85-P-002 6/28-7/17/85 13A-85-A-003 8/29 and 8/30/85 13A-85-A-004 10/4-10/7/85 13A-85-A-006 10/21/85-13A-85-A-007 10/28-10/30/85 13A-85-P-005 10/17-11/5/85 Surveys of MR Survey Period 4A-85-A-001 1/25-2/8/85 4A-85-A-002 2/27/85 4A-85-A-003 3/15/85 4A-85-A-004 4/18-4/23/85 4A-85-P-005 4/26 and 4/27/85 4C-85-A-006 5/5/-5/31/85 4A-85-A-007 6/4 and 6/5/85 4A-85-A-008 6/10/85 4C-85-P-009 6/11-6/26/85 4C-85-S-010 7/26-8/6/85 4A-85-A-011 8/8/85 4A-85-A-012 8/14-8/16/85 4A-85-A-013 8/16-8/23/85 4A-85-A-015 9/16 and 9/17/85 4C-85-S-016 9/27-10/23/85 4A-85-A-017 9/10/85 4A-85-A-018 9/13/85 4A-85-A-019 11/4-11/12/85 4A-85-A-020 12/4/85 4A-85-A-021 12/5/85 4A-85-P-023 11/18-12/5/85 4.2.4 Issue -- Notice of Indications and Maintenance Requests do not have a proper tracking system.

QACEG evaluation included reviewing TVA Topical Report TVA-TR75-1A, revis ion 8; NQAM, Part II, Section 2.1 " Plant Maintenance"; NQAM, Part III, Section 1.1 " Document Control";

Standard Practice SQM-2, revision 19 "Ma in tenance Management System"; and SI-114, Section 17.0, revison 4 "Inse rvic e Inspection Prog ram" . These documents we re reviewed to determine existing program controls for the issuance, tracking and closure of NOIs and MRs.

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.TVA EMPLOYEE CONCERNS ~ REPORT NUMBER:

SPECIAL PROGRAM' 80202- SQN REPORT TYPE: REVISION NUMBER:

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Element Report- 3 TITLE:- PAGE.6 0F 10

' Inspection-Inspection Procedures k,

5.0 FINDINGS'

- 5.1 - Findings on Issue - Unknowledgeable inspectors utilize procedures ' to aid;in the. inspection process.

. 5.1.1 Discussion

, NSRS Report I-85-968-SQN . was reviewed and ' QACEG concurs with their conclusion regarding this issue. The use of procedures in this manner is encouraged so that the inspector will be able to base the inspection on areas contained in a documented set of guidelines.

t 5.1.2 Conclusion The issue -of inspectors not having adequate knowledge was not substantiated. The concerned- employee stated that QC Inspectors used procedures in - the performance of their -job.

_ Inspectors are trained in the use of -QC Inspections - Procedures and utilization of . procedures during inprocess inspections is an accepted practice.

5.2 Findings on Issue -- Unacceptable conduit bends ' and' threaded conduit joints were accepted by inspectors.

5.2.1 Discussion

QACEG has reviewed and followed up NSRS Report I-85-968-SQN

[ . and ' the report was found . to be factual.

QACEG and NSRS evaluations reveal inspectors are trained in the use of the QC inspection procedures, such as SNP Inspection Instruction No.

26, " Exposed Conduit and Conduit Boxes Inspection". This-procedure was used by construction QC inspectors for conduit inspections. The procedure was issued and revised three times

! in 1977. ~

,_ However, none of the - revisions required that conduit bends be inspected. Interviews with past construction inspectors

• indicated that they never checked for conduit bend radiu s .

The procedure (SNP Inspection Instruction No. 26) has clear instructions for inspection of conduit identification, grounds, conduit fittings and lubricant , flexible conduit, burrs and sharp edges, physical separation, hangers, and termination. All of these attributes were part of an

[ inspection record the inspector filled out and signed.

i.

. Exact specifications for conduit bends are found in the Electrical Design Standard DS-E13.1.7. This standard gives minimum bend radius and minimum straight length required af ter I

-, - ~ , _ . _ . - - - __ _. .~. . _ _ . _ . _ _ _ _ _ _ . _ .. _ _ . _ _ _ .

TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80202-SQN REPORT TYPE: REVISION NUMBER:

Element Report 3 L' TITLE:' .PAGE 7 0F 10

. Inspection-Inspection Procedures the bend. ItLis.not known if this standard was actually used-by . craf tmen in the field at ' SQN. The = standard states -in section 1.0, "This standard gives the minimum bend radius requirements to be used in the design and installation of conduit systems."

TVA General ' Construction Specification G-40, " Installing.

Electrical Conduit Systems and Conduit Baxes", states in Section 3.2.4.1 (b), " Running threads on field threaded conduits shall not be used on metal conduits for connection at couplings." Running threads are extra threads. When they are used at'a coupling, the coupling or other connector will not-cover all of the threads. The National ' Electrical Code contains an ' almost identical statement about running threads.

TVA QC instructions did not require inspection for exposed threads. Adherence to the construction specification and the National Electrical Code was the responsibility of the cra f tsmen.

5.2.2 . Conclusion This issue of QC Inspectors accepting unevenly bent conduit and conduit joints with too many exposed threads is substantiated. However, QC Inspectors were not required to inspect conduit bends or exposed conduit threads. The elec trical craftsmen are required to properly- install the conduit.

Due- to the lack of inspections to verify specification installation requirements a review by the Department of Nuclear Engineering (DNE) is required to determine if conduit installations are acceptable.

5.3. Findings on Issue -- Surveillance Instructions (sis) and Maintenance Instructions (mis) are revised in an uncontrolled manner (pen and ink changes in the field).

7 5.3.1 Discussion The Nuclear Quality Assurance Manual (NQAM), Part III, Section 1.1, Revision March 31, 19ts5, provides for specific controls

! (ie preparation, handling, and onsite review) of Plant

! Instructions. The instruction is dra f ted within a plant section and under the general supervision of the section supe rv isor. When the instruction is satisfactory to the i supervisor of the originating section, it is submitted fo r independent review by the Plant Operational Review Corsnittee

( (PORC). As part of this independent review, representatives of the Site Quality Manager (SQM) are required to review the P

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'TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80202-SQN REPORT TYPE: REVISION NUMBER:

Element Report 3

' TITLE: PAGE 8 0F 10

-Inspection-In:pection Procedures instruction for adequacy of QC -hold points, required documentation, format, and content. Instructions required by Plant Technical Specifications are required to be ' approved for -

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issue by the Plant Manager and/or the Nuclear Service. Division of Westinghouse (NSD). NQAM, Part III, Section 1.1, paragraph 5.4.4.2.E, requires that, " changes which go beyond the intent of the original instruction shall be handled through the same tormal review process as the original issue before they can be-implemented."

The review of the (28) surveys performed by QA on SI and Maintenance Request (MR) activities revealed that checklist attributes . included verification that the latest revis ion - to applicable - instructions were being used. Survey reports reveal no instance where the latest revision to the applicable Instruction (SI or MI) was not used. Survey Reports made no mention of " pen and ink changes in the field" on either surveillance or maintenance instructions.

5.3.2 Conclusion Based on a review of existing program controls governing plant instructions, this concern is not substantiated. As addressed in this report, adequate controls are and have been in effect to control revisions to Plant Instructions. Quality Assurance Sarvey Reports revealed no instances whre Surveillance or Maintenance Instructions were revised by " pen and ink changes in the field."

5.4 Findings on Issue - Notice of Indications (NOIs) and Maintenance Requests (MRs) do not have a proper tracking system.

5.4.1 Discussion The concerned employee states that N0ls and MRs written by the Inspection Department are closed and placed in Plant Archives by another department. The department which wrote the MRs or NOIs would still be watting tor a disposition. The concerned employee concluded that the tracking system for N0ls and MRs is inadequate. NOIs are controlled by SI-114.1 "Inse rvice Inspection Program" which provides for the notification to the issuing organization of the disposition assigned. MRs however, are controlled by Standard Practice SQM 2,

" Maintenance Management System."

5.4.2 Conclusion Employee's concern regarding the proper tracking of NOIs and MRs is partially substantiated. Standard Practice SQM 2 does

3- ...

TVA EMPLOYEE CONCERNS REPORT NUMBER:'

SPECIAL PROGRAM 80202-SQN REPORT TYPE:' REVISION NUMBER:

.-Element Report' 3

-. TITLE: PAGE-9 0F 10 Inspection-Inspection Procedures not provide . feedback or status of MR information to the initiating individual or organization.

5.5 Attachment A, identified -the concerns as potentially safety-significiant and safety related. However, QACEG evaluation concludes that only- concern 00-85-005-002 is potentially safety-significant.

Concern 00-85-005-002 identifies the- lack of Quality Assurance Inspections for the bending of electrical conduit and exposed threads at ' conduit joints. . As addressed in Section 2.4, the Department ~ of ,

Nuclear Engineering' (DNE) is currently performing an engineering evaluation of this condition and any impact on safety will be determined as=a result of that evaluation.

5.6 Corrective Action 5.6.1 Issue - Unacceptable conduit bends and threaded conduit bends were accepted by inspectors.

NSRS Report I-85-968-SQN identified this problem and transmitted their reconumendations to H. L. Abercrombie, Site Director of SQN, on 2/24/86 requesting a response by April 20, 1986. NSRS reconunendations suggested an Engineering evaluation of the effect of unevenly bent conduit and exposed threads at conduit joints should be made. Contact with the Office of the Employee Concern Special Project Manager revealed that no response was submitted by H. L. Abercrombie to the NSRS. QACEG issued .a. Corrective Action Tracking Document (CATD) 80202-SQN-02 (Attachment D) requesting an engineering evaluation. The Site Director of SQN responded October 20, 1986. The response included a memorandum (S08

. 861009 821) dated October 9, 1986 to D. W. Wilson, Office of Nuclear Power (ONP), requesting the Department of Nuclear

. Engineering perform an Engineering evaluation. No engineering response has been received to date.

5.6.2 Issue - NOIs and MRs do not have a proper tracking system.

QACEG issued CATD 80202-SQN-01 identifying that Standard Practice SQM-2 does not provide Maintenance Request or Work Request status information to the initiating individual or organization. The SQN Site Director responded October 20, 1986 committing revision to SQM-2 to incorporate provisions

[. for notifying the originating section to rejected or cancelled WRs. To date, this revision has not been made.

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.:TVA EMPLOYEE CONCERNS . REPORT NUMBER:

SPECIAL PROCRAM' 80202-SQN iREPORT TYPE:- REVISION NUMBER:

Element Report' 3 TITLE: PAGE 10 OF.10 Inspection-In'spection Procedures

~6.0 ' ATTACHMENTS A.  ; Employee; Concern Progam System (ECPS) ' List of . Employee Concern Information

'B. NSRS Report I-85-968-SQN C. CATD 80202-SQN-01 D. _CATD 80202-SQN-02 4

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ATTACitMENT A EREllCE - ECPS120J-ECPS121C TENilESSEE VALLEY AUTHORITY PAGE -- 264 QUEllCY - REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 12:19:11

- ISSS - RitM EMPLOYEE CollCERif PROGRAM SYSTEM (ECPS) RUN DATE - 10/03/8(.

LIST OF EMPLOYEE C0!!CERil IllFORMATION GORY: QA QA/QC PROGRAMS SUBCATEGORY: 80202 INSPECTION PROCEDURES S GENERIC KEYHORD A H APPL QTC/HSRS P KEYHORD B 20tlCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYl10RD C tlUf1B ER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYl10RD D 005-002 QA 80202 N SQN N tl N N I-85-968-SQN SS SEQUOYAH - ELECTRICAL QC IllSPECTORS TRAINING T50224 K-FORM DO !!OT HAVE ADEQUATE Kl10HLEDGE OF HH QUALIFICATION AT THEY ARE IllSPECTING, AtID GET BY 0 ELECTRICAL HLY HITH HELP OF PROCEDURES. BECAUS IllSPECTORS

, E OF THEIR INEXPERIENCE. ELECTRICAL INSPECTORS SOMETIMES ACCEPTED UNEVEN LY BENT CONDUIT AllD CONDUIT JOINTS H ITH TOO MAllY EXPOSED THREADS. THIS.

OCCURRED IN 1977. CI HAS 110 SPECIFI CS OR FURTHER INFORl1ATION. CONSTRUC TION DEPARTMEllT C0!!CERil.

009-XO3 QA 80202 N SQN NNNN SS SURVEILLANCE IllSTRUCTIONS AND MAIllTE RECORD GEllERATION T50273 K-FORM tlANCE INSTRUCTIONS ARE REVISED IN All NONC0!1FORilAtlCE -

UNCONTROLLED MAllHER (PEN AND IllK CH GENERAL ANGES Ill THE FIELD), AND THESE REVIS GEllERAL IDHS ARE IMPLEMENTED PRIOR TO APPROP RIATE REVIEH AND APPROVAL, NUCLEAR POWER DEPARTMENT CONCERN. NO FURTHE R IllFORMATION AVAILABLE IN FILE.

-35 CG1 001 ^3 C0200 0 HON YYYY MS HATTS OAR TUC CENCRAL CONST. S:'EC.- HELDING HE 50705 REPORT G-29C, PROCESS SPEC. 0.C.l.1 IS IN PROCEDURES T50227 QUALITY

/ CONFLICT HITH THE TVA QUALITY ASSURA HCE COMMITHEllTS AS STATED BY THE TVA llELDS TOPICAL REPORT, TVA-TR75-1A, IN THA T PROCESS SPEC. 0.C.I.1, SECTION 6.0 ALLOHS UNCERTIFIED HELDER FOREMEN, HHO HAVE DIRECT RESPONSIBILITY FOR T HE INSTALLATI0tl, TO PERFORM PREHELD IllSPECTI0llS. HUCLEAR P0HER CONCERil.

(g g CI HAS NO FURTHER INFORMATION.

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102-008 QA 80202 N bFN NYYY  ! !! 0 '. 0 , G NS BROHHS FERRY, NOTICE OF INSPECTIONS RECORD GENERATION IS0208 K-FORM AND MAINTENANCE REQUESTS HERE HRITTE NotlCollFORMAllCE N FOR DISCREPAHCIES BY AN INSPECTI0tl QUALITY DEPT. AND All0THER DEPT. BOUGHT OFF REPORTS THESE MR'S CLOSED AND PLACED THEM IN THE PLAtlT ARCHIVES. THE. DEPT. NHIC H HROTE MR'S 8 fl0I'S HOULD BE STILL HAITING FOR DISPOSITION. THEY DON'T HAVE PROPER TRACKING SYSTEM. NUCLE AR P0HER CONCERN. CI HAS NO FUTHER INFORMATION.

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. UNITED STAk"ES GOVERNMENT ATTACHMENT B MCM076Md MM _ TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director Sequoyah Nuclear Plant 3 FROM: K. W. Whitt, Director of Nuclear Safety Review Staff E3A8 C-K I DATE: February 24, 1986 j

SUBJECT:

NUCLEARSAFETYREVIEWSTAFFIN[ESTIGATIONREPORTTRANSMITTAL Transmitted hereinis NSRS Report No. T-85-968-SON Subject Inadeounte Knowledge of Electrical OC Inspectors Concern No. 00-85-005-002' and associated prioritized recommendations for your action / disposition. ,

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It is requested that you respond.to this report and the attached one Priority 2 [P2] recommendation'by April 20, 1986 . Should you have any questions, please contact W. D. Stevens at telephone 6231-K Recommend Reportability Determination: Yes No _2C.

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ytfre M e, USRS/ Designee WDS:JTH Attachment

' cc (Attachment):

j' W. C. Bibb,,BFN -

l W. T. Cot *.le, WBN James P. Darling, BLN .

R. P. Denise, LP6N40A-C G. B. Kirk, SQN .

I D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C ,

{c, 6 4

J. H._Sullivan, SQN.,_ O a ,

V 531U N-dt{ d. ve e ...: . . . n . .r . n . ... r . . r.. . , t . n .. .. . o r c ...:_ .. n r .

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TENNESSEE' VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS JNVESTIGATION REPORT No. I-85-968-SQN -

EMPLOYEE CONCERN 00-85-005-002

SUBJECT:

' INADEQUATEKNOWLEDGEOFELECTRICALQCINSPECh0RS DATES OF INVESTIGATION: February 5-11, 1986'

\ -

INVESTIGATOR: - J / b a

C'. L , Breeding Date REVIEWED BY: 7 f S

, l.. E. Brock Date

, APPROVED BY: __

'N W. D. Stevens Date n ,

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.I. .BACKCROUND.

A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine' the validity of an expressed employee concern received by the t~ Quality Technology Company (QTC) Employee Response Team. The concern of record, as summarized'on the En@loyee Concern Assignment Request Form from QTC and identified as 00-85-005-002, stated:

Sequoyah: Electrical QC inspectors do not have adequate knowledge of what they are inspecting. And get by only with help of procedures. Because of their inexperience, electrical inspectors sometimes accepted unevenly bent

. conduit and conduit joints- with too many exposed threads.

This occurred in 1977. CI has no specifics or further information. ' Construction Department concern. ,

II.' SCOPE

\ The scope of this investigation was determined from the stated concern

of record to be two issues requiring investigation.

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A. Electrical Quality Control (QC) inspectors do not have adequate

- knowledge.

B. Inspectors accepted unevenly bent conduit and conduit joints with too many exposed threads.

The scope was confined to the construction period of work at Sequoyah Nuclear Plant (SQN) since the concern specifies 1977. There was very little work involving the operating and maintenance _ organization at that -

time. L

! III.

SUMMARY

OF FINDINCS -

A. Requirements and Commitments

, 1. 10CFR5'.0, " Domestic Licensing of Production and Utilization l Facilities"

2. TVA General Construction Specification G-40, " Installing Electrical Conduit Systems and Conduit Boxes," R1 dated Decembec 3, 1976 -

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3. TVA Division of Construction, SNP Inspection Instruction No. 26,

" Exposed Conduit and Conduit Boxes Inspection," RO dated May 26, 1977; R1 dated June 11, 1977; R2 dated September 13, 1977; R3 .

dated October 14, 1977 ,

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.g 4.- Electrical Design Standard DS-E13.1.7 " Dimensions of Rigid _and Flexible Metal Conduit Bends," issued September 30, 1976-  !

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B. Findings The' concern stated that the QC inspectors needed procedures to aid them in their job. The use of procedures-in this manner is encouraged so that the inspector will be_able to base the inspection  ;

on areas contained in a documented set of guidelines. The _ i

.. inspectors are trained in the use of the QC inspection procedures .

I i such as SNP Inspe*' c tion Instruction No.,26, " Exposed Conduit and .

Conduit Boxes Inspection." This procedure was~used by construction QC inspectors for conduit inspections. The procedure was issued and i

then revised three times in-1977. None of the revisions required-that conduit bends be inspected. Interviews with past' construction inspectors indicated that they never checked for proper conduit-bend

, ' radius.. The procedure has clear instructions for inspection.of '

< conduit identification, grounds, conduit fittings and lubricant,

{ flexible conduit, burrs and sharp edges, physical separation,

! t hangers, and teemination. All of these areas were part of an  ;

inspection record the inspector filled out and signed. Exact l specifications for conduit bends are found in the Electrical Design Standard DS-E13.1.7. This standard gives minimum bend radius and minimum straight length required af ter the bend. It is not known if

! this standard was actually used by craftsmen in the field at SQN.

The standard states in section 1.0: "This standard gives the minimum band' radius requirements to be used in the design and o installation of conduit systems." 0 i .

q TVA Ceneral' Construction Specification C-40, " Installing Electrical Conduit Systems and Conduit Boxes," states in section 3.2.4.1 (b), .  :,.

[ " Running tNreads on fleid threaded ccnduits shall not be used on LI l metal conduits for connection at couplings." Running threads are extra threads; and when'they are used at a coupling, the coupling or

'IO I

other connector will not cover all of the threads. The National..' .

Electrical Code contains an almost identical statement about running

• threads. TVA QC instructions did not require inspection for exposed

threads. Adherence to the construction procedure and the National

^

Electrical Co'pe was the responsibility of the craftsman. 1 o

o IV. CONCLUSIONS AND RECOMMENDATIONS ,

t c

. A. Conclusions. - ,

! i This concern is partially substantiated. QC inspectors were not required to inspect conduit bends or exposed conduit threads. The

- electrical craf tsmen were expected to properly install conduit and .

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, .; , . y '- w-then critical elements of the installation, such as identification and grounding, were inspected by QC inspectors. Conduit with exposed threads may-be subject to rust where the cutting of the threads has removed the protective coating from steel conduit.

The part of the concern which stated that.QC inspectors did not have adequate knowledge was not substantiated. The concerned individual stated that QC inspectors used procedures in the performance of their jobs. This is the proper and accepted method for QC inspectors to perform their duties. '-

B. ' Recommendations ,

I-85-968-SQN-01, Evaluation of Exposed Threads and Uneven 1v Bent Conduit .

' An engineering evaluation ,of the effect of unevenly bent conduit and exposed threads at conduit joints should be made. If this g evaluation determines that either of these conditions could have an adverse effect on the nuclear safety of SQN, then a search should be

- made to find such conduit and repair it. [P2]

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. W' W DOCUMENTS REVIEWED IN INVESTICATION I-85-968-SQN AND REFERE! ICES

1. 10CFR50, " Domestic Licensing of Production and Utilization Facilities"

2. TVA General Construction Specification C-40, " Installing Electrical Conduit Systems and Conduit Boxes," R0 dated December 3, 1976

3. TVA Division of Construction, SNP Inspection Instruction No. 26,

" Exposed Conduit and Conduit Boxes Inspection " RO dated ,

May 26, 19 7 7 * *

4. TVA Division of Construction, ,:He Inspection Instruction No. 26,

" Exposed Conduit and Conduit Boxes Inspection," R1 dated June 11, 1977

5. TVA Division of Construction, SNP Inspection Instruction No. 26,

" Exposed Conduit and Conduit Boxes Inspection," R2 dated September 13, 1977

}

6

6. TVA Division of Construction, SNP Inspection Instruction No. 26,

" Exposed Conduit and,, Conduit Boxes Inspection," R3 dated October 14, 1977 7.. Electrical Design Standard DS-E13.1.7, " Dimensions of Rigid and Flexible Metal Conduit Bends," issued September 30, 1976 B

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ATTACHMENT C s' . .' ,

1 ECSP CORPIC*IVE Action Trackine Document (CATD) ~

^:- 2

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INITI ATION_ ,_

X / No

/,X,

- 1. 1:enediate Corrective Action Required: /_/ Yes '

2. Stop Work Recommended: /~/ Yes /I/ No - - -'

3. CATD No. 80202-SON-1 4. INITIATION DATE 9/16/86 -

3. RESPONSIBt.E ORGANIEATION: Office of Nuclear Power

6. PROBI.EM DESCRIPTION: /X/ QR // NQR Standard Practice- SOM 2. Revision 19, " Maintenance Management System". and NOAM. Part II. Section 2.1 allows any olant emolovee to initiate an MR or WE for olant corrective. maintenance or-repair work and submit it to his suoervisor for further _s processing. Stsndard Practice SQM 2. however, does- not provide MR or WR status information to the initiating individual or organt:stion.

--i... / / ATTACHMENTS l

R. D. Halverson XiL4";#- DATE: f/4/r4

7. PREPARED BY: NAME , DATE: '9 46 / p C,

8. CONCURRENCE: CIG-11 W < / Vta /

1)ff' - Y f DATE: /8/M

9. APPROVAL: ECTG PROGRAM MGR: .

CORRECTIVE ACTION

• PROPOSED CORRECTIVE ACTION Pl.AN:

Standard Practice SOM-2 vill 1

' 10.

be revised to incorporate provisions for notifying the originating Current'1v the WR tracking section of reieeted or cancelled WRs.

evster is accessible from an online computer menu that allows

• the originatine section to view any MR/WR by I.D.

l 4

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l t / / /?d s / / N"""ACMMEN'S

'l. PROPOSED BY: DIRECTOR / MGR pf/f#///f//fn#_ DAIE: /c ht W 6 '

DATE!

12. CONCURRENCE: CEG-H

' ' SRP; DATE:

DATE:

ECTC PROGRAM MCR:

VERIFICATION AND C1,OSEOUT i

~

13. Approved corrective actions have been verified as satisfactorily implemented.

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TITLE DATE SIGNATURE b l

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b ATTACHMENT D j, '

. _ , . Pzga 1 of 5 --

ECSP CORRECTIVE Action Trackine Document -

. (CATD) ~

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. . .s INITIATION ~

" ~

1. Immediate Corrective Action Required: /X/ Yes // No.. - '

2.- Stop Work Recommended: /;/ Yes /I/ No -

3. CATD No. 80202-SON-2 4. , INITIATION DATE 9/16/86 -

5. RESPONSIBLE ORGANIZATION: Office of Nuclear Power .

6. PROBLEM DESCRIPTION: -/I_/ QR ./[/. NQR As described in Element Report 80202-SON. Concern 00-85-005-002.

no crocedure exists that mandates cuality control insoections of conduit bends and exuosed threads at conduit ioints that verify ,

specification recuirements have been meet.

~

/ /AITACHMENTS r 7. PREPARED BY: NAME R. D. Halverson /EgmV- DATE: 9//4//g

8. CONCURRENCE: CEG-H ^ M d //fA _- '- DATE: @//</ T6.- ,

9. APPROVAL: ECTG PROGRAM MGR: 2Y//dhmW eG. DATE: //f/Af CORRECTIVE ACTION .

10. PROPOSED CORRECT 7VN ACTION PLAN:A memorandum was issued .

, (SOS 861009 8211 i.e6uesuhi DNE se perterm an Angineering evaluation as recommended by ECTG (copy attacnec).

s i < /r# / / /ACACEMENTS

11. PROPOSED BY: DIRECTOR /MGR: ph//nN/////an@ DATE: /(>///i/fa '

12. CONCURREr E: CEG-H DATE:

SRP: DA*"E:

ECTG PROGRAM MGR: DATE: -

VERIFICATION AND CLOSEOUT

13. Approved corrective actions have been verified as satisfactorily implemented.

SIGNATURE TITLE DATE -

I. - .

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ATTACHMENT D Page 2 of 5 S08 861009 821 -

October 9, 1986 ,.

D. W. Wilson -

ONP, DSC-E, Seguoyah

Subject:

SEQUOYAH NUCLEAR PLANT (SQN) EMPLOYEE CONCERNS TASK GROUP (ECTG)

ELEMENT REPORT 802.02-SQN - CORRECTIVE ACTION TRACKING. DOCUMENT ,

(CAID) 80202-SQN-2 As lead coordinator of the Corrective Action Plan (CAP) for the subject report, I am requesting that DNE perform an engineering evaluation regarding

• the effect of unevenly bent conduit and exposed threads at conduit joints on nuclear safety at SQN. '

For additional information, attached is a copy of the'sutrject report an'd CATD. This evaluation is needed as a result of a recommendation made by the ECTG in the subject report in response to Employee Concern No. 00-85-005-002.

If this evaluation determines that either of these conditions could have an -

adverse affect on the nuclear safety of SQN, please provide design criteria that SQN can use to establish inspection and acceptance criteria. When you provide any needed design criteria, I will work with you and SQN Site plant management to develop and implement an inspection prograra if required.

All future correspondence on this subject should be sent to R. C. Denney, SQN Employee Concern Special Project (ECSP) Manager, and an information copy sent -

to me. 'Please call Mr. Denney (Ext. 7009) by Friday, October 10, 1986, with the estimated completion date of the requested engineering evaluation.

Any guestions-should be referred to Julio Nieri at Ext. 7335.

/ _f6 4V ". -

Sy d' W. E. Andrews

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ALV:JSN:RJZ glf r .

ttachments, b

g cc (Attachments): /b AV RIMS, MR AN 72A-C A H. L. Abercrombie, ONP, O&PS-4, SQN (Attn: R. C. Denney) 0291K

.y.. .. . . .

• '. .. Standard Pra'tica c Pcg2 8

• - ,e SQA166 Revision 8

~

Attachment A .

. Page 1 of 2 -- \, , ,.,

Corrective Action Plan of Employee Concern Investigation ' . .

Tracking Checklist . ' ~ , ',,

ECTG Report /CATD Number YO2,02 -6:PA> FD2D2 -f@U- /, 70202- 690-L Lead Organization Responsible for Corrective Action Plan % A.sfy'45 m c4 v e r ..

Initiation Date O c'T 2 ; / T f lo , .

CORRECTIVE ACTION PLAN (CAP)-

1. Does this report required corrective' action? Yes X No (If yes, describe corrective action to be taken,'if no, provide , justification)

See attached CATDs 80202-SQN-1 and 80202-SQN-2. .

2. Identify any similar item / instances and corrective action taken.

-3. Will corrective action preclude recurrence of findings? Yes X No 4.-Does this report contain findings that are conditions adverse to cuality (CAQ)

X as defined by AI-12 or NEP 9.17 YES _ . _ _ No

5. IF a CAQ condition exists, what CAQ document was initiated?

6. Which site section/ organization is responsible for corrective action? '

SQN Maintenance Scheduling (J. Ward) and DNE (Doug Wilson).

7. Is corrective action required for restart? Yes No X

- (This determination is to be made using Attachment C of SQA166.)

j 8. P2 :one number for restart' corrective action? Zone 77/48

9. Estimate completion ^date for correction action. Decemoer 12, 1986 ,

~

Completed By J S* Nierk Z A/

Date 10/10/86'

! hygroved By A/rF (14,nhuu Date /n//d/J'& ~

ECTG Concurrence Date '

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p 93 9

[_. . ,. Pcgs 4 of 5

, , SQA166 ,

,- Revision 8 -

Al"TACHMD.'T A Page 2 of 2

• L.

cap 6 @ c-10.'Was your corrective action initiated and completed in accordance with step 17 ' -

Yes No

11. If step 10 is no, describe the corrective action taken. ,

12. Is the corrective action implementation complete?' Yes No

13. Is the corrective action documentation closed? Yes -

No

.14. What documents were used to implement the corrective action?

Completed By: Date Verified By: Date -

ECTG Closure: Date

• y:1, - ,-

(Step No.) . Description .

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S03 8G1016 803 I' Memorandum .

TENNESSEE VALLEY AUTHORITY

-70  :

W.Nuclear R. Brown, Plant'-Program Manager, Employee Concerns. Task ONP, Group Watts Bar FROM  : 4 H. L. Abercromble, Site Director, ONP, O&PS-4, Sequoyah ant Nuclear Pl DATE- : October 20, 1986 i i-

SUBJECT:

SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE EMENT CO REPORT 802.02 SQN - QUALITY ASSURANCE

Reference:

CAP) CAT Your memorandum to me dated September Plant - Employee _ Concerns Task Group (ECTG) Element r Re 80202-SQN - Inspection Procedures (Sequoyah)" (T25 860924 8 I acknowledge s receipt of your element report and in accordance your with reque't (see applicable reference),

corrective action. Element Report 802.02 SQN has been r reviewed By this memorandum I an endorsing the site line organization CAP the CAP for your review and concurrence.

requirement. This CAP is not a restartand attaching If you agree with the proposed CAP, please sign the ECTG concurren below item checklist. 9 on the CAP tracking checklist and returncethe ng space CAP tracki 80202-SQN-2) are being returned to you by way of this m .

l./A4&2h H. L. Abercrombie RCD:JDS:JB:CS Attachment cc (Attachment):

RIMS, MR 4N 72A-C (S08 861014 873) RE0EIVED ]

A. G. Debbage, ONP, ECTG Building, WBN (Y,T 22 $3 0200T

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