ML20214P382

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Notice of Violation from Insp on 860929-1003 & 1020-24
ML20214P382
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/21/1986
From: Walker R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214P365 List:
References
50-424-86-95, 50-425-86-45, NUDOCS 8612040179
Download: ML20214P382 (4)


Text

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ENCLOSURE 1 NOTICE OF VIOLATION Georgia Power Company Docket Nos. 50-424 and 50-425 Vogtle License Nos. CPPR-108 and CPPR-109 During the Nuclear Regulatory Commission (NRC) inspection conducted on September 29 - October 3 and October 20-24, 1986, violations of NRC requirements were identified. The violations involved failure to follow procedures for handling Field Change Requests (FCRs) and DCNs; failure to train Project Field Engineers and contract Quality Control _ (QC) staff on the use of Raychem Products; and improper use of heat shrink and bend radius violations on NSCW cable splices.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement-Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below: ,

A. 10 CFR 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

The Vogtle Electric Generating Plant (VEGP) Project Reference Manual (PRM) is the procedure used by Project Field Engineering (PFE) for processing FCRs. This procedure contains the following requirements in regard to handling FCRs:

Section C, paragraph 17.5.2.a states that "when an FCR approved by PFE requires a change to an engineering document, that change must be incorporated on the appropriate engineering document (drawing or specification)."

Section C, paragraph 17.5.2.b states that " changes involving configuration control may be approved for applicability to a unique component or installation only."

Contrary to the above, on July 22, 1986, the following examples of not following proceduros for processing FCRs and DCNs were identified:

1. FCR No. E-FCRB-15,409 (DCN #4) was not properly incorporated into Vendor Instruction Manual AX3AJ11B-24-3, although the transmittal sheet stated that it had been incorporated.
2. Generic unincorporated (NA/NA) FCRs (such as E-FCRB-14,517, E-FCRB-12,833 and E-FCRB-14,587) were approved by PFE without the specific component identified.

This is a Severity Level IV violation (Supplement II).

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Georgia Power Company Docket Nos. 50-424 and 50-425 Vogtle 2 License Nos. CPPR-108 and CPPR-109 1

1 E. 10 CFR_ 50, Appendix B, Criterion II requires that. the QA Program shall provide for indoctrination and training of personnel performing activities

4. affecting quality as 'necessary to assure that suitable proficiency is achieved and maintained.-

1 Contrary to the above, on October 20, 1986, the following examples of lack .

, of training were identified: l

,- 1. C'ontract Electrical QC personnel had not been trained on the use of Raychem Products. ,

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2. Project Field Engineers approving FCRs relating to Raychem splices had 4

not received training to become efficient in the use of Raychem Products. Consequently, FCRs for three-way and four-way splices were 4 approved which did not meet the Raychem design criteria. Additionally, t the FCRs did not provide adequate instructions to the craft and QC on such parameters as required shim length, overlap of outer sleeve and

! parts-assembly. Examples of the FCRs are as follows: E-FCRB-12,662,

.E-FCRB-10,867, E-FCRB-12,694, E-FCRB-12,513, E-FCRB-11,941, l E-FCRB-11,295, E-FCRB-11,212, and E-FCRB-12,204.

p This is a Severity Level IV violation (Supplement II),

i ~C. 10 CFR 50, Appendix B, Criterion V requires that activities affecting

) quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accom-plished in acccrdance with these instructions, procedures, or drawings.

Procedure ED-T-08, " Cable Termination" establishes the methods and practices

! for the installation of cable terminations, jumpers, cable splices, vendor-supplied pigtails, electrical conductor seal assemblies, and associated flex conduit. The procedure requires that Raychem Heat Shrink F shall be installed per the Vendor Manual AX3AJ11B-24 for in-line splices or special engineered kit instructions.

Contrary to the above, on October 22-23, 1986, deficiencies were identified with installations using Raychem' shrink materials which indicated that procedure ED-T-08 and Raychem vendor instructions were not being followed.

These deficiencies included:

1. Improperly sized heat shrink materials used on safety-related cables 1AB1506HB, IBB1605HB, and IBB1608HB located in junction boxes 1ARJB0421, IBRJB0424, and 1BRJB0427, respectively, in the Nuclear Service Cooling Water Towers. The overall outer shrink sleeves were WCSF-N-650, although, the reverse calculated effective inside diameters indicated that an overall sleeve size of WCSF-N-1000 should have been used.

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- Georgia Power Company Docket Nos. 50-424 and 50-425

- Vogtle 3 License Nos. CPPR-108 and CPPR-109

2. The molded ' end caps on all three phases of cable IBB1608HB were improperly bent and fastened with a tywrap. This configuration was not approved in the vendor manual.

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3. The shrink sleeve on the B phase motor lead for device 1-1202-W4-002-M03 was bent beyond the minimum allowable bending radius specified by the vendor manual.

This is a Severity Level IV violation (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby

- required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation -in reply including

- for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by Luis A. Reyes /for Roger D. Walker, Director Division of Reactor Projects Dated at Atlanta, Georgia this c255-L day of khmlu r 1986 2

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Georgia Power Company Docket Nos. 50-424 and 50-425 Vogtle 3 Licen,e Nos. CPPR-108 and CPPR-109

2. The molded end caps on all three phases of cable 1BB1608HB were improperly bent and fastened with a tywrap. This configuration was not approved in the vendor manual.
3. The shrink sleeve on the B phase motor lead for device 1-1202-W4-002-M03 was bent beyond the minimum allowable bending radius specified by the vendor manual.

This is a Severity Level IV violation (Supplement II).

Pursuant ^ to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit to this Office within 30 days of .the date of the letter transmitting this Notice a written statement or explanation in reply including for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR GULATORY COMMISSION b

Roger D. Wal e', Dire tor x Division of actor Projects Dated at Atlanta, Georgia this J.ll % day of Ak%br 1986 J