ML20235B721
| ML20235B721 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/24/1987 |
| From: | Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 19100, 19100-V01-R04, 19100-V1-R4, NUDOCS 8902140352 | |
| Download: ML20235B721 (39) | |
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l EMPLOYEE i
CONCERNS SPECIAL PROGRAM 1
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VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 19100 ELECTRICAL EQUIPMENT UPDATED TVA NUCLEAR POWER
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 l
SPECIAL PROGRAM REPORT TYPE: Subcategory - Construction REVISION NUMBER: A TITLE: Electrical Equipment PAGE 1 0F 24 REASON FOR REVISION:
Incorporate SRP coments Revision 1 Incorporate SRP coments, Executive Sumary.
Revision 2 and additional evaluation resulting from NRC coments l
Incorporate SRP coments and Finalize Report Revision 3 Incorporate Engineering Category references and Revision 4 Finalize Report I
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- SRP Secretary's signature donotes SRP concurrences are in files.
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i Preface, Glossary, and List of Acronyms for ECTG Subcategory Reports-HISTORY OF REVISION.
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REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3
i To clarify that one or more attachments will help the reader find where a particular concern J
is evaluated k
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TVA EMP1.0YEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM
)NT MATTER REY: 3 I
PAGE i 0F vill Preface This. subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986. ' Concerns filed after that date are handled by the ongeing ONP Employee Concerns Program (ECP).-
The ECSP addressed over 5800 employee concerns.
Each of the concerns was a formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate. The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results of these investigations are communicated
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by four levels of ECSP reports: element, subcategory, category, and final.
f Element reports, the lowest reporting level, wili be published.only for those concerns directly affecting the restart'of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of'one or more closely related l
issues. An issue is a potential problem identified by'ECTG during'the evaluation process as having'been raised in one or more concerns. For efficient handling, what appeared to.be similar concerns were-grouped into j
elements early in the program, but issue definitions. emerged from the evaluation process itself. Consequently, some elements did include only one issue, but often the ECTG evaluation found more'than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossar
't the terminology unique to ECSP reports, and a list of acronymt.
Additionally, at the end of each subcate6ory report will be a Subcategory l
Summary Table that includes the concern numbers;. identifies other subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the. concern is evaluated.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM 4
FRONT MATTER REY:
2 PAGE 11 0F viii The subcategories are themselves summarized in a series of eight category reports. Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations 1
industrial safety l
construction l
material control operations quality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of l
intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.-
Just as the' subcategory reports integrate the information collected at the element level, the category reports integrate.the information' assembled in
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all the subcategory reports within the category, addressing particularly q
l the underlyinr, causes of those problems that run across more than one i
subcategory.
I A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP,~ including the Inspector.
General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual. The Manual spells o'at'the program's.
objectives, scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and l
closeout of the issues raised by employee concerns.
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TVA EMPLOYEE CONCERNS-REPORT NUMBER:
19100 SPECIAL PROGRAM FRONT MATTER REV:
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ECSP GLOSSARY OF REPORT TERMS
- classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A: Issue cannot be verified as factual I
Class B: Issue is factually accurate, but what is described is not a
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problem (i.e., not a condition requiring corrective action)
Class C: Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG l
evaluation of an issue raised by an employee concern.
1 collective significance an analysis which determines the importance and consequences of the findings in a particular.ECSP report by putting those findings in the proper perspective.
concern (see " employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies i
revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion (plural: criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement"),
element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
l employee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a X-form or a form equivalent to the T-form.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE iv 0F vill evaluator (s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns.
findings includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective r
action.
l issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.
K-form (see " employee concern")
j requirement a standard of performance, behavior, or quality on which an 1
evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
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- Terms essential to the program but which require detailed definition have been.
defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-related, unreviewed safety-significant question).
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM l
FRONT MATTER REY: 2 PAGE v 0F viii Acronyms AI Administrative Instruction AISC American Institute of Steel Construction ALARA As Low As Reasonably Achievable ANS American Nuclear Society
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ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant l
BLN Bellefonte Nuclear Plant 1
CAQ Condition Adverse t) Quality l
CAR Corrective Action Repore 1
CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulaticas CI Concerned Individual CMTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division ef Nuclear Construction (see also NU CON) l l
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
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I DNE Division of Nuclear Engineering
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DNQA Division of Nuclear Quality Assurance j
DNT Division of Nuclear Training i
DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative i
ECSP Employee Concerns Special Program ECTG Employee Concerns Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team EN DES Engineering Design ERT Employee Response Team or Emergency 2esponse Team FCR Field Change Request FSAR Final Safety Analysis Report
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FY Fiscal Year GET (ieneral Employee Training HCI Hazard Control Instruction HVAC Heating. Ventilating, Air Conditioning II Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE vii 0F viii 1
L/R Labor Relations Staff M&AI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board NT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NOAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch NSRS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management e.nd Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetract Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction 1
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM FRONT MATTER REY: 2 PAGE vili 0F vill i
QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction in Force RT Radiographic Testing SQN Sequoyah Nuclear Plant SI Surveillance Instruction l
SOP Standard Operating Procedure SRP Senior Review Panel l
l SWEC Stone and Webster Engineering Corporation j
l TAS Technical Assistance Staff l
l T&L Trades and Labor l
TVA Tennessee Valley Authority TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing I
i VT Visual Testing l
WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant WR Work Request or Work Rules WP Workplans l
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TVA EMPLOYEE CONCEFNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 2 0F 24 OUTLINE OF CONTENTS EXECUTIVE
SUMMARY
1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction 1.2 Description of Issues 1.2.1 Panels 1.2.2 Junction Boxes 1.2.3 Hand Switches 2.0
SUMMARY
2.1 Summary of Issues 2.2 Summary of the Evaluation Process 2.3 Summary of Findings 2.4 Summary of Collective Significance 2.5 Summary of Causes 2.6 Summary of Corrective Action 3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation 3.2 Requirements or Criteria Established for Individual Issues 3.2.1 Panels 3.2.2 Junction Boxes 3.2.3 Hand Switches l
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SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 3 0F 24 4.0 FINDINGS 4.1 Findings on Panels 4.1.1 Generic 1
l 4.1.2 Site Specific l
l 4.2 Findings on Junction Boxes 4.2.1 Generic 4.2.2 Site Specific-4.3 Findings on Hand Switches 4.3.1 Generic i
4.3.2 Site Specific 5.0 COLLECTIVE SIGNIFICANCE 5.1 Significance of Each Issue 5.1.1 Panels 5.1.2 Junction Boxes
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5.1.3 Hand Switches 1
l 5.2 Collective Significance of the Subcategory l
5.2.1 Generic 5.2.2 Site Specific 6.0 CAUSE 6.1 Panels 6.2 Junction Boxes 6.3 Hand Switches 9
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TVA EMPLOYEE CONCERNS REPORT NUMB"R: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 4 0F 24 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken 7.2 Corrective Action from CATDs 8.0 ATTACHMENTS Attachment A. Subcategory Summary Table and List of Concerns" Attachment B. " List of Evaluators" Attachment C, " List of Concerns by Issue
w EXECUTIVE
SUMMARY
Electrical Equipment Report Number: 19100 ISSUE ASSESSMENT This subcategory report addresses four safety related employee concerns pertaining to the adequacy of material substitution, electrical equipment installation practices and the perceived existence of obsolete hand switches in the main control room panels. One issue noted that'the as constructed configuration of the vendor drawings for the 480V Shutdown Board panels did not reflect the as-designed TVA issued configuration' drawings. This issue was WBN specific and was not' evaluated at any other site. One issue questioned the acceptability of using galvanized steel as a junction box material at I
WBN. This issue pointed to an implied definition of acceptable materials as shown in the WBN QCP-3.03.- One issue was raised by individuals who perceived that TVA was using obsolete hand switches in the main control room panels.
MAJOR FINDINGS The configuration discrepancies documented by WBN NCR U-205-P showed that terminal block strip labeling and wire labeling did not conform to the existing as-constructed configuration vendor drawings available at that point in time. Prior to initiating the NCR, there were no inspection criteria available to require or control labeling on vendor supplied equipment wiring.
The discrepancies were factual but all funccional tests had been completed on.
the control panels. No Conditions Adverse to Quality had been identified and the equipment operated as designed. The issue was deemed to be factual, but the condition had been identified and addressed before the concern was registered. Site procedures for WBN are being revised to incorporate inspection requirements for interface terminal labelling and updating vendor drawings.
The junction box material substitution issue was considered to be not factual. Had the concerned employee referenced G-40 for a lis.t of acceptable junction box materials, he would have found that galvanized steel is an acceptable material. The issue was evaluated at all four nuclear sites.
Procedural clarification was undertaken at WBN, but no corrective action was required at any of the other sites. The perceived obsolete hand switches questioned at WBN were of the Westinghouse Type W-2 configuration.
In 1980, NRC issued bulletin No. IE 80-20.
This bulletin identified a shortcoming in the design of the switches which left some uncertainty as to the position of the switch during operation of its controlled equipment. NRC gave each utility utilizing the switches an option to either repisce or modify the switches.
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Page 1 of 2
e TVA implemented the modification option by issuing ECN 3306 and added a position indication circuit to 69 unit one and 33 unit two switches which met the intent and requirements of the NRC 80-20 bulletin. The incorpor.ation of the position indication circuit introduced the potential for a sneak circuit problem which was documented by Post Modification Test Deficiency No. PT-301.
The problem had also been identified by NRC bulletin IE 82-01.
ECNs 4591 and 4592 were issued to modify the circuit for the 28 (total for Unit 1 & Unit 2) switches which were identified to be potentially affected by the sneak circuit problem.~ SQN took the same option and modified their W-2 handswitches. The issue was deemed to be not factual.
COLLECTIVE SIGNIFICANCE The major idsue identified during evaluation of the concerns was the lack of General Construction Specification control for vendor supplied equipment.
Existing policy limited DNC's inspection requirements to TVA wiring connections at the' termination points at the vendor supplied component.
Configuration control mandates that vendor drawings.and TVA drawings shall I
reflect the same configuration, and inspection procedures should incorporate this requirement. DNE, DNC, and ONP management effectiveness in ensuring configuration control, as-constructed drawing control, work scope control, group responsibility assignment coordination, and ECN accountability has been proven to be short sighted considering the findings and resultant rework documented by this subcategory report and the data packs'e associated with NCR I
WBN W-205-P.
The technical adequacy of the equipment
..L never compromised.
I The operability of the safety-related equipment an'd the adequacy of the documentation was found to be acceptable.
CATDs issued by Operations in their 30804 report and by Construction in their 11200 report and the revisions to WBN-QCP-3.06-2 and QCP-3.06-3 as a result of NCR 7225. Revision 1, will assure that the procedural controls necessary to implement the inspection requirements for vendor supplied equipment interfaces will be in place.
Updating of vendor supplied drawings necessary to maintain the as-designed configuration control necessary for effective plant operation I
and maintenance of plant systems and equipment will be controlled with the Administrative Instructions AI-4.3 and 4.4 l
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4 PAGE 5 0F 24 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction This subcategory report for Electrical Equipment.in the Construction Category addresses four safety-related employee concerns.
The concerns were site specific to Watts Bar Nuclear Plant (WBN) and pertain to the adequacy of material substitution, installation of l
electrical equipment, and electrical hand switches. These problems l
were perceived to exist in electrical panels, junction boxes and handswitches, and the concerns were categorized for evaluation into three issues as follows:
l Panels Hand Switches l
HI-85-045-001 WBP-85-016-003 HI-85-093-N02 Junction Boxes IN-85-913-001 1.2 Description of Issues 1.2.1 Panels l
One concern reported the 480V shutdown board panels have a potential nonconformance that has not been documented and, therefore, not in accordance with as-constructed and as-designed drawings.
1.2.2 Junction Boxes One concern questioned the acceptability of material substitution for electrical junction boxes. The junction boxes were not manuf actured froni _ sheet metal and painted as required by General Construction Specification G-40 and appilcable electrical standard drawings. The boxes were constructed of galvanized steel, and may have been installed throughout the plant.
1.2.3 Hand Switches The concerns in this issue stated that hand switches in the main control room were declared obsolete and, rather than change the switches, nameplates and labels were changed.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM j
REVISION NUMBER:
4 PAGE 6 0F 24 2.0
SUMMARY
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2.1 Summary of Issues Perceived issues addressed by this subcategory consisted of concerns addressing the configuration control of the 4807 shutdown board panels, the use of " obsolete" hand switches in the main control room L
panels and the acceptability of material substitution for electrical junction boxes. The concerns addressed were site-specific to WBN, but the junction box issue was evaluated at all four nuclear plant sites.
2.2 Summary of the Evaluation Process i
The evaluation methodology consisted of a thorough review of the applicable procedures, documents, and standards to determine If the issues raised were adequately addressed.
Listings of nonconformance reports (NCRs) were checked to determine if previous documentation existed on the subjects.
Quality Technology Company (QTC) files were reviewed for any additional information that would assist in identifying specific items related to the concerns.
Walkdowns were performed to determine compliance with plant l
procedures.
Interviews were conducted with cognizant personnel to obtain information leading to a conclusion for the concerns.
l 2.3 Summary of Findings Of the three issues addressed, only one was determined to be 7
factual. The configuration control discrepancies for the 480V 4
shutdown board panels were substanti
'.ed, but the concerns addressing the substitute junction bor material and the " obsolete" hand switches proved to be not factual. Procedural clarification has been implemented to specifically authorize galvanized material usage. The W-2 hand switches had been modified prior to the issuance of the two concerns independent from the concern evaluation. The concerned individuals were misinformed about the hand switch requirements.
The summary of the individual issues follows:
v TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 7 0F 24 Panels Configuration discrepancies for the 480V shutdown board panels were identified and addressed by NCR W-205-P.
Of the 3675 discrepancies identified, over 3,400 were terminal block and wire labeling discrepancies.
Preoperational functional testing verified the installed configuration as being correct.
The documentation and operability of the equipment was never questioned and no nuclear safety problem l
was ever identified.
Junction Boxes The concern that galvanized steel junction boxes were not acceptable i
per DNE General Construction Specification G-40 is not valid.
Though G-40 did not specify galvanized steel was an acceptable junction box material, it implied, by way of referencing a nationally recognized standard, that the material was acceptable.
l The National Electric Code does recognize galvanized steel as an acceptable corrosion resistant material. The controlling site procedure VBN QCP-3.03, has been clarified to reflect galvanized steel's acceptability.
Hand Switches Discussions with cognizant Modifications Engineering personnel revealed that NRC IE Bulletin Number 80-20 required certain hand I
I switches in the main control room to be replaced or modified. TVA l
DNE issued Engineering Change Notice (ECN) 3306 in April of 1982 to IR4 modify the applicable hand switenes by rewiring them. This work was l
l completed in 1984 ECNs 4591 and 4592 were issued to address NRC l
bulletin IE 82-01 which covered the potential for the introduction l
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of a sneak circuit into the hand switch position indication circuit.
1 The concern was voiced in 1985. Memorandums were issued scoping the changes required as a result of human factor concerns, NRC regulations, and control panel nameplate and label changes. Some of the label and nameplate changes were for the modified hand switches.
2.4 Summary of Collective Sir.nificance j
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l Collectively, inadequacies were pinpointed in the upper-tier General Construction Specifications and site-implemented installation and inspection procedures. There were no controlling j
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 8 0F 24 documents addressing configuration control requirements for vendor supplied equipment. The coordination effort between design groups responsible for modifications to vendor supplied equipment needs to be strengthened to preclude the issue of scope of work documents (Impact and Justification sheets for ECNs) that are labled " documentation only" but actually require physical work on equipment. Misinformation also significantly affected the perception of employees who voiced concerns about the Westinghouse W-2 hand switches in WBN's main control room and the material acceptability for junction boxes.
2.5 Summary _of Causes The causes identified for configuration discrepancies for the WBN 480V shutdown board panels are:
l (1) No DNE or DNC procedures governing installation configuration control for terminal wiring labeling.
(2) Lack of coordination between design groups before issuance of scope of work documents for ECNs.
(3)
Inadequate site Project Control review for scope of work on ECNs designated as "for documentation only."
The concerns addressing the perceived " obsolete" hand switches were I
deemed to be an indication of a lack of communication about the status IRA l
of the W-2 switches.
l The concern related to the acceptability of galvanized steel electrical junction boxes resulted from the site procedure's f ailure to list acceptable junction box materials or at least reference the applicable G-40 section addressing junction boxes.
2.6 Summary of Corrective Action Corrective action had already been taken relating to the employee concern which dealt with the 480V electrical panels in unit 1 at WBN.
Vendor wiring for the unit 2 main control room panels at WBN is scheduled to be inspected. Corrective action is not required for i
the employee concern associated with hand switches. Additional corrective action is not required for the concern on electrical junction boxes, since the WBN site procedure has been revised to l
preclude any future misinterpretation of the material acceptability.
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TVA EMPLOYE. CONCERNS REPORT NUMBER:
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4 PAGE 9 0F 24 3.0 EVALUATION PROCESS 3.1 General Methods of Evaluation The evaluation methodology at each nuclear plant site consisted of a review of applicable design standards and specifications and site implemented installation and inspection procedures related to the issues. ECNs, NCRs, QTC files, and other related documents were reviewed for issue appilcability.
Walkdowns were performed with cognizant personnel to verify procedural compliance of issue-related components.
Interviews were conducted with personnel directly involved with each issue to obtain additional information.
These included discussions about previously accepted practices and standards associated with the issues addressed by the concerns.
3.2 Requirements or Criteria Established for Individual Issues 3.2.1 Panels The requirements for the 480V shutdown electrical panel installation, and the associated problems, were summarized in the nonconforming report NCR W-205-P, revision 1.
This NCR documented the violation of the requirements, evaluated the condition, and proposed corrective action. The corrective action has been completed for WBN unit one.
Because of the extensive nature of this NCR, (3675 documented deficiencies),
documentation of the as-constructed and as-designed condition was available. Further investigation was unnecessary to evaluate if any other potential installation violations existed, since the employee concern was determined to be factual as established by NCR W-205-P.
3.2.2 Junction Boxes TVA Construction Specification G-40 and Electrical Standard Drawing SD-E13.6.3 established TVA requirements for junction boxes. WBN Site Procedure WBN QCP-3.03, revision 18, established current requirements for material acceptance criteria for junction boxes.
The requirements of these documents were used to evaluate the acceptability of the material used in the final installation, as questioned by the concerned employee. These documents were also compared to accepted practices established at the site, as related by EEU l
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personnel during interviews. TVA Nuclear Safety Review Staff l
Report No. I-85-524-WBN was evaluated to compare its conclusions and the consistency of the findings with this report. A draft of the revision to VBN QCP-3.03 was reviewed to evaluate the effectiveness of clarifying the materials acceptable for use in junction boxes.
Reviewed conduit and grounding drawing 45N810-7 Revision 35, entitled " Conduit and Grounding. Floor Elevation 669.0, Ceiling Plan", and the Master Bill of Material for electrical equipment to determine the numbering scheme used by DNE to identify and describe those junction boxes specified for installation at SQN.
l SQN Workplan number 12292 related to the implementation of ECN 6823 was reviewed to determine the control method utilizeu i
to ensure the proper installation of junction (spilce) boxes.
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l SQN Electrical Maintenance Planning personnel were contacted to discuss the controls established or utilized during the I
maintenance request (MR) or work-release (WR) process related to junction box replacement.
SQN Procurement personnel were contacted to ascertain the
. documentation / certification requirements for procuring and receiving electrical junction boxes and a review of the affected documents was performed.
3.2.3
, Hand Switches Discussions with selected DNE EEB, EEU, and Modifications personnel and a subsequent document review established the criteria for evaluation of the perceived problem with hand switches. The evaluation was supported by scoping review of I
the work plans associated with modification of the main i
control room switches including replacement of the labels and l
l nameplates. Documents showed modification of hand switches I
was required by DNE ECNs 3306, 4591 and 4592. This l
modification was required as a result of the NRC IE Bulletin I
i numbers 80-20 and 82-01, which established criteria l
l requiring either replacement or modification of Westinghouse lR4 f
W-2 hand switches. The option was given to all utilities l
utilizing the W-2 hand switches to replace or modify the I
switches. ECN 3306 revealed TVA elected to modify the hand l
l switcher. Workplan review showed the modification work was a l
l result cf the ECN and the NRC 80-20 bulletin.
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ECNs 45L1 and 4592 implemented the requirements necessary to I
satisfy NRC bulletin 82-01.
Wort plan review and Post l
Modification test review showed the required circuit l
modifications were complete and functional.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
A PAGE 11 0F 24 A document review produced evidence that nameplates and labels were changed on the hand switches in the main control room. This work was a result of Human Engineering Related Changes and NRC regulations.
It was concluded through interviews that no obsolete hand switches had ever been installed in the main control room.
4.0 FINDINGS
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4.1 Findings on Panols 4.1.1 Generic Discussion Not applicable.
Conclusion The issue raised by the concern on Electrical Panels was determined to be WBN site-specific and, therefore, not generic to any other TVA site.
4.1.2 Site Specific - WBN Discussion The review of previously documented NCRs on the 480V shutdown panels revealed that 3675 discrepancies were documented on NCR W-205-P, Revision 1, initiated on November 20, 1984. NCR W-205-P was initiated independent of the employee concern. The NCR grew out of what was originally intended to be an ONP configuration walkdown covering Browns Ferry, Sequoyah, and Watts Bar. The closure requirement of the NCR consisted of completing a large scale configuration verification walkdown for electrical panels in the Main and Auxiliary Control rooms at WBN. These discrepancies had been evaluated, corrective action established, verified complete, and the NCR closed on April 22, 1985. For a complete discussion on NCR W-205-P, see Subcategory Construction Report 11200. Terminal block and wire labeling accounted for 92.8 percent of the problems.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
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PAGE 12 0F 24 Inspection procedures now require label verification for vendor supplied electrical equipment. Previously, no procedure addressed the inspection requirements necessary to confirm the labeling of terminal blocks and internal wiring for vendor supplied equipment. Vendor wiring in unit 2 main control room panels at WBN is scheduled to be inspected. Also, the electrical engineer now in charge of the main control room unit 2, reviews all ECNs, regardless of category, for change requirements including labeling changes.
The following is a summary of factors contributing to configuration control discrepancies:
1.
Inspection requirements for labeling of terminal block strips were nonexistent when the panels were installed.
In the early phase of construction, an agreement was made between Construction and ONP that Construction would wait until just before system transfer to install or update terminal block identification strips. This was an accepted practice free of any procedural control. The-electrical inspectors were required only to verify that each wire was attached to the appropriate terminal (e.g.,
one through 12).
4 NCR 7225 Revision 1 documents the fact that the existing procedures WBN-QCP-3.06-2 and QCP-3.06-3 are inadequate for suffielently establishing acceptance criteria for inspection of vendor and TVA interface terminal blocks.
2.
The majority of the wire labeling discrepancies were on vendor wiring (commonly referred to as internal wiring).
Most fleid wiring is color coded and not labeled with tags.
In the early construction phase of the project, a policy was established stating that DNC would not inspect vendor wiring since each vendor had a certified QA program.
Thus, TVA never inspected vendor wire labeling before this walkdown.
The TVA wiring diagrams reflected the as-designed con-figuration of the terminal interfaces, but the vendor l
drawings had not been revised to reflect the as-designed terminal configurations. The Corrective Action Plans for CATD 11200-WBN-06 and 30804-WBN-02 provide assurance that vendor drawings will be configuration veriflod prior to being used for any maintenance or repair work. WBN Administrative Instruction AI-4.3 details vendor drawing configuration verification requirements.
l l
1 l
m TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 13 0F 24 3.
DNC has had, and continues to have a problem with Engineering Change Notices (ECNs) that are categorized "for documentation only." To fit this category, the ECNs must not require physical changes to plant features.
After the 480-volt control panels were installed, we received many ECNs with terminal block strip label changes mistakenly categorized (by DNE) "for documentation only."
These changes were not scoped for work requirements by the WBN Project Control Unit because of the "for documentation only" designation.
Preoperational Test TVA-13A results provided assurance i
that functional tests were complete for unit 1 480V shutdown l
boards.
Several problems were identified as test deficiencies, but were resolved during the test.
Conclusion The concern that a potential nonconformance existed on the 480V shutdown panels was factual. The completed corrective action on NCR W-205-P provided adequate documentation of the as-constructed, as-designed status of the unit 1 panels.
This finding confirmed the employee's concern that the panels were potentially nonconforming. The extensiveness of the documentation and evaluation of the NCR, and the l
independently verified completed corrective action provided l
assurance the problem has been adequately addressed. Unit 2 l
panels will be subjected to similar configuration control l
walkdowns.
Revisions to WBN-QCP-3.06-2 and QCP-3,06-3 and adherence to AI-4.3 requirements will preclude any future configuration l
l control problems with TVA/ vendor interfaces on electrical l
l equipment.
l l
4.2 Findinr.s on Junction Boxes 4.2.1 Generic Discussion The upper-tier DNE specification did not specifically address junction box material, but only stated the material must meet the requirements of an approved recognized national s.tandard. The National Electric Code 3 Article 370-20 (an approved recognized standard), stated that the use of galvanized steel is an acceptable practice as a corrosion resistant material for metal junction boxes. The WBN site procedure did not specifically list galvanized steel as an acceptable material along with the listing of other l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 14 0F 24 1
materials.
Review of Electrical Standard Drawing SD-E13.6.3 revealed the boxes shall be constructed of sheet steel.
No 1
specific mention was given for a corrosion resistant material. However, a requirement was given for painting surface mounted field fabricated boxes.
Conclusion Because of a possible need for clarification in the DNE specifications, this issue was generic to all other TVA nuclear sites.
Evaluations at other sites revealed that they were utilizing galvanized steel.
Site procedures were determined to be adequate as were the DNE upper-tier i
procedure and drawings. The revision for clarification of the WBN site procedure should preclude future misinterpretation of the intent.
l 4.2.2 Site Specific
)
VEN Discussion The concern that junction boxes were not manufactured according to G-40 or standard drawings was not factual I
because the intent was not to exclude galvanized steel, but l
to address painted steel since some method of corrosion l
protection was required. A review of the DNE Electrical Construction Specification G-40 and Standard Drawing SD-E13.6.3 revealed junction box material was not specifically j
addressed but stated the material must meet the requirements of an approved recognized national standard.
Review of the t
National Electric Cods reve led galvanized steel, among other i
materials, was an acceptable corrosion resistant material for i
electrical junction boxes. A review of the WBN site procedure I
WBN QCP-3.03, revision 18, revealed that galvanized steel was i
not previously listed as an acceptable material. Discussions with DNC electrical engineers. Modification Unit engineers, and
)
an electrical craft foreman confirmed that galvanized boxes i
could be found throughout the plant. Galvanized boxes were also used at other sites, but no other instances of questioning the galvanzied steel acceptability were voiced.
i The WBN DNC Procedures and Training Unit was in the process of I
clarifying the acceptability of galvanized steel in the site i
procedure. The investigation completed by the NSRS l
(Report Number I-85-524-WBN) was consistent with the findings and conclusion of this report confirming that galvanized l
steel was an acceptable material for junction boxes. The NSRS report findings stated that the intent of G-40 and the l
electrical standard drawings was not to exclude galvanized steel, but to address painting because some method of corrosion protection is required.
i
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 15 0F 24
-l The investigation also concluded that the intent of the General Construction Specification G-40 was not to exclude galvanized steel from the list of acceptable materials for junction boxes.
Conclusion Galvanized steel is an acceptable material for use in electrical junction boxes and the employee concern is determined to be not factual.
SON Discussion i
)
I A cognizant Modifications engineer was contacted to determine I
if clarification was required in regard to material requirements for junction box construction.
SQN ModifD;ation i
and Addition Instruction (MLAI)-6 " Installation of Conduit and Junction Boxes" Revision 6, was. reviewed to determine if-clarification was required pertaining to a definition of corrosive resistant material.
The Modifications engineer interviewed indicated junction boxes were either specific and' procured by DNE or fabricated I
on site using DNE standard drawings. Notes on the drawings specify the material type as sheet metal and the corrosion
)
protection used is paint.
Problems or confusion had not bown
)
identified for the material requirements related to junction i
box construction.
A review of MLAI-6 revealed that junction box material was required to meet an approved recognized standard. No i
specific material requirements were given as examples to i
introduce error or confusion related to the material requirements for junction box construction, i
Review of conduit and grounding drawing 45N810-7, Revision 35 revealed that junction boxes were given unique identification l
numbers with the appropriate mark number assigned by the Division of Nuclear Engineering (DNE). Each mark number was j
to be utilized by the constructor during the installation.
j process in conjunction with "The Master Bill of Material for Electrical Equipment," to describe the type of junction box required at the specified location.
Review of the Bill of Material for various mark numbers revealed a general description of the affected junction box and included its size, type or NEMA rating, and other pertinent data such as contract and item number, etc.
(Reference 45BM826 R4 SHT 16 of 45, and 45BM828 R3 SHT 14 of 45).
l
1 TVA EMPLOYEE CONCERN 3 REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 16 0F 24 Reference to the " type" of junction box was DNE's method to specify which TVA standard drawing was to be utilized during fabrication and assembly.
j i
conclusion The site procedure is adequate as written and consistent with the requirements of G-40 and the National Electric Code.
Program enhancement could be accomplished by DNE should a list of acceptable materials be complied and injected into the governing design out-put document (G.C.S-G40).
BFN Discussion Modifications personnel were contacted to determine if clarification was required in regard to material requirements for junction box construction. MLAI-27, dated July 16, 1986, was reviewed to determine if clarification was required pertaining to a definition of corrosive r641stant material.
Conclusion Modifications personnel indicated junction box types were specified by DNE.
Fabrication was performed per the design specification which included provisions / requirements for painting to prevent corrosion. No deficiency was noted related to junction box material requirements.
MLAI-27
" Installation of Electrical Conduit and System Junction Boxes," stated that materials used for junction box construction shall meet the requirements of an approved national standard. An attachment to the procedure provided material specifications consistent with the National Electric Code and lists painted steel, galvanized steel, aluminum or stainless steel as being acceptable.
Independent verification is required and no deficiencies were noted.
BLN Discussion A review of site procedures BNP-QCP-3.2, revision 12, BNP-QCP-3.26, revision 6, BNP-QCP-10.5, revision 6, and BNP-QCP-3.13, Rovision 13 " Equipment Installation," provided the acceptance criteria for corrosion protection of electrical junction boxes.
A walk-through of the plant was performed to determine if a hardware problem existed as a result of inadequate material selection for electrical junction boxes.
3 TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 j
SPECIAL PROGRAM l
REVISION NUMBER:
4 P/GE 17 0F 24 0
Discussions were held with Electrical Engineers at the site.
I conclusion The site procedures did not list specific materials acceptable for electrical junction boxes. The BLN procedures provide assurance through unique number verification and shop inspections that the boxes installed meet DNE requirements.
All boxes observed during a walk-through of the plant were in good condition and free of corrosion.
l Discussions with Electrical Engineering personnel revealed the only galvanized electrical junction boxes used are those supplied with vendor equipment.
No hardware problem exists in the plant and no confusion existed as to the acceptability of the galvanized steel junction boxes used. The site procedures are fully adequate as written and l
ensure the boxes installed meet DNE requirements.
Note: Since galvanized junction boxes are constructed of a l
reactive metal similar to aluminum, and react with borated water to form hydrogen, the design basis calculations for hydrogen build-up inside containment should include these and other similar items in the inventory process. The control of such reactive metals within the confines of the containment !3 discussed in the WBN ECTG Construction Category, Subcategory Report 19200, " Conduit and Cable Tray."
DNE provides the methods which will ensure that these materials are included in the design basis calculation for hydrogen build-up and that future updates to the calculation package will include these and other similar materials.
4.3 Findinr.s on Hand Switches 4.3.1 Generic Discussion l
Not Applicable l
l 1
l e
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 I
PAGE 18 0F 24 Conclusion The issue raised by the two concerns for hand switches was VBN site specific.
4.3.2 Site Specific l
Discussion l
Discussion with a Modifications supervisor and cognizant l
Modifications Electrical Engineering personnel revealed that Westinghouse Type W-2 hand switches were required to be l
replaced or modified as a result of NRC Bulletin No. IE 80-20, issued July 31, 1980. In response to this bulletin, l
l l
TVA DNE issued ECN 3306 on April 7, 1982. This change IRA required modification of 69 Unit one and 33 Unit two W-2 hand l
l switches in lieu of replacement. This work consisted of i
rewiring the hand switches to incorporate a return to neutral position indicator circuit and was considered complete on i
March 3, 1983.
l In January of 1982 NRC issued IE bulletin 82-01 which l
l identified the potential for introducing a sneat circuit in l
l the course of implementing modifications required by IE lR4 bulletin 80-20.
l In October of 1982 the sneak circuit proLlem was identified I
in the Black and Veatch findings report for Watts Bar which l
indicated that the switches modified as a result of.ECN 3306 lR4 requirements did not satisfy licensing requirements.
l The Electrical Engineering Branch identified 28 valve control l
switches which had the sneak circuit problem and issued ECNs l
4591 and 4592 to correct the problem for Unit one and Unit IR4 two respectively.
I Six additional valve switches were identified to require I
modification and were noted on SCR WBNEEB 8526.
ECN 5840 was I
issued to modify the switch circuits and to finally bring all IRA the required W-2 switches into compliance with the IE l
bulletins 80-20 and 82-01.
I Reference findings section in the Engineering Category I
reports 235.11(A) for WBN and 235.11(B) for SQN design basis IR4 evaluation of the W-2 handswitch issue.
I l
l l
l l
l s
TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
'4 PAGE 19 0F 24 Discussions also produced documents revealing labels.and nameplates were required to be changed in the main control room. This change resulted from human engineering related concerns and NRC regulations. This work included changing labels and nameplates on hand switches, which was accomplished in 1984.
Conclusion The concern that " hand switches in the room control room were declared obsolete, but rather.than change the switches, only' labels and nameplates were changed" is not factual.
Modifications of the Main Control Room hand switches were properly evaluated and completed as verified through I
discussions with cognizant personnel and a review of inspection documentation. This work consisted of rewiring the existing switches to comply with IE bulletins 80-20 and 1
82-01.
All the modifications. required by ECNs 3306, 4591 and l
4592 are complete and all Post Modification test requirements.
l have been documented. Modifications required for tho' six IR4 1
valve control switches covered by ECN 5840 are scheduled to l
l be completed under work plan E5840-1 revision three by the l
WBN Modifications Unit. Work was also scoped and completed on the changing of hand switch labels and nameplates in the main control room. There was no association between'these work-related items since the requirements for the work originated from completely different. considerations.
Note: A review of the G.C.T.F. preliminary evaluation at SQN i
on this concern, SQN Report No. HI-85-045-001 concluded I
similar findings. Since SQN'and WBN have nearly identical main control. room designs, the NRC' Bulletins IE 80-20 and 82-01 were.also' applicable to switches at SQN. DNE issued ECN L5591 to' modify type W-2 switches at SQN. The. conclusions of the SQN report stating that no installed switches had been declared obsolete provides additional credence to the conclusions of this report.
5.0 COLLECTIVE SIGNIFICANCE 5.1 Stanificance of Each Issue 5.1.1 Panels l
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 l
SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 20 0F 24 The significance of the issue concerning electrical panel configuration occurred because inspection requirements for i
labeling of terminal strips was not procedurally addressed at any level when the panels were installed.
Such inspections would verify label discrepancies with vendor wiring and design changes not scoped by the site Project Controls Unit for ECNs that are categorized "for information only." The findings concluded the concern was factual, but the perceived problems with configuration control had been documented and corrected for VBN unit 1 and inspections were planned for unit 2.
It is also significant to note that the requirements to main-tain the as-designed status of vendor drawings existed in the Quality Assurance Program Description for Design, Construction, and Operation--Topical Report-TVA-TR75-1 part 17.2.6 and in WBN AI-4.3 but was not followed for the 460V shutdown board panels drawings.
5.1.2 Junction Bores This concern was determined to be not factual because the intent of G-40 was not to exclude galvanized stoel and was inadequately interpreted by the WBN site procedures. Site procedures were being revised before this ovaluation took place to emphasize the fact that galvanized steel was an acceptable jnnetion box material.
5.1.3 Hand Switches This concern was determined to be not factual with regard to the perceived problem that installed hand switches were obsolete and rather than replace the switches, only nameplates were changed. The findings concluded that replacement or modification of W-2 hand switches was required, and TVA chose to modify the switches. This modification consisted of rewiring the switches to add a return to neutral indicator circuit, which may have gone unnoticed by the concerned employees. The employees were apparently aware of the need to address a problem with the switches but were not informed of the required corrective action.
When a later effort was initiated to correct human factor concerns which included the replacement of nameplates and labels on hand switches, the employees may have incorrectly perceived this work was related to the " obsolete" hand switch problem.
m TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 21 0F 24 5.2 Collective Significance of the Subcategory 5.2.1 Generie l
The major issue identified during evaluation of the concerns for this subcategory wa,s the lack of General Construction Specification control for vendor supplied equipment as identi-fled in the 480V panel configuration control issue. Site l
procedures derived from G-specs depend on the adequacy of the l
G-specs to maintain design basis, control the quality, assure the operability and maintain the as constructed configuration l
l of all system components.
Existing policy limited DNC's l
l inspection requirements to TVA wiring connections at the i
termination interface points at the vendor supplied l
component. Configuration control mandates that vendor drawings and TVA drawings shall reflect the same configuration, and inspection procedures should incorporate i
this requirement.
l l
The requirement to verify the vendor drawings' as-designed l
l status prior to installation, repair, or maintenance of vendor l
supplied equipment has been emphasized in the Topical Report TVA-TR75-1 Part 17.2.6 " Quality Assurance Program Description for Design, Construction, and Operation" and in Site l
Administrative Instructions for Drawing Control of Unlicensed Units.
l Site implemented procedures at WBN are being revised to incorporate interface inspection requirements as a result of CATDs issued by the Operations Category Report and the Work Control Subcategory Report evaluations.
5.2.2 Site Specific - WBN DNE, DNC, and ONp management effectiveness in ensuring configuration control, as-constructed drawing control, work scope control, group responsibility assignment coordination, and ECN accountability has been proven to be short sighted considering the findings and resultant rework documented by this subcategory report and the data package associated with NCR W-205-P.
Employees (Engineering, QA, and Craft) have been consistent in their application of installation / documentation criteria as supplied by the governing procedures. When considering vendor supplied l
equipment, employees did not question the lack of label l
identification on the terminal blocks.
It is just another case of "It's always been done this way."
Responsibility for documentation, inspection, and configuration control for I
vendor-supplied equipment must be addressed procedurally to
i l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 22 0F 24 1
prevent recurring inconsistencies in the configuration control process. The technical adequacy of the equipment was never compromised. The operability of the.
safety-related equipment and the adequacy of the documentation was never in question.
6.0 CAUSE 6.1 Panels The causes identified for configuration discrepancies for the WBN 480-volt shutdow board panels are as follows:
1.
No DNE or DNC procedures governing vendor supplied equipment relating to the installed configuration / issued drawing configuration for terminal wiring labeling.
2.
Lack of coordination between design groups when issuing scope of work documents for ECNs.
3.
Inadequate Project Control review for scope of work on ECNs designated as " documentation only."
)
Note:
Detailed evaluation of panel configuration discrepancy control is reported in the Construction Category, Subcategory report number 11200, " Work Plan / Work Control."
Operations Report 30804 also details findings proving that vendor drawings which are not as-designed are being used to make repales to CSSC plant equipment.
Discussion The identifed cause for the 480-volt panel termination configuration discrepancies was traced to the initiating design organization's identification of work required in the field before issuing the scope of work documents (I&J-sheets for ECNs) and their lack of providing updated vendor drawings to reflect the scope of design changes as part of the ECN process.
For example, when a circuit is modified to perform a different function than what it was originally designed to perform, the design group responsibic for that portion of the specific circuit issues a scope of work document.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 23 0F 24
)
The design group responsible for the termination end of the circuit (different from the group responsible for the function end of the circuit) reviews the scope of wort document and revises the labeling portion of the drawing to agree with the new function of the circuit and issues their scope of work document showing that there is no construction work required. When.the ECN cover sheet is prepared, I
the catagory designation is controlled by the details shown on the I&J-sheets from each group involved in the change.
If the cover I
sheet is prepared using the information on the I&J-sheet from the group assigning a " documentation only" category for their area of l
responsibility, then the ECN gets designated as " documentation only" upon issuance to DNC. When the site Project Controls group receives an ECN designated as " documentation only," their representative files the ECN away without doing a required work scoping. When the l
drawing showing the physical work required arrives onsite, the responsible EE scopes the work and writes a workplan to do the work. Labeling changes on vendor supplied terminal blocks do not fall within the scope of any site or design procedures presently in effect. Therefore, if the physical work is performed on the TVA wiring and is documented as being complete, the circuit is considered
~
(by all groups involved) as being complete as shown the newest issued drawings and is documented as such. The configuration shown on the TVA issued drawings at this point in time is different than t. hat shown on the vendor drawings.
I i
The labeling is also shown on vendor supplied drawings and does not l
require any DNC inspections to verify labeling or j
drawing / installation configuration control.
I 1
Of the 3675 discrepancies documented by NCR W-205-P, 3412 were identified to be associated with labeling of vendor wiring.
Though the labeling discrepancies were pervasive throughout the control panels, no quality or safety concerns were identified during the evaluation. All circuits were functionally tested and documented and would operate as designed.
If the vendor drawings had been updated to show the as-designed configuration as part of the design change process, the labeling discrepancies would not have existed.
6.2 Junction Boxes The concern related to the acceptability of galvanized stoel junction boxes resulted from a misinterpretation of the procedural requirements.
The CI interpreted that material not specifically mentioned was intended l
to be excluded for use, Although the intent of WBN was not to exclude this material, the misinterpretation was due, in part, to the site procedure. The procedure' contained only a partial listing of approved materials, not intending to exclude galvanized steel, but to address some method of corrosion protection.
4 TVA EMPLOYEE CONCERNS REPORT NUMBER:
19100 SPECIAL PROGRAM REVISION NUMBER:
A PAGE 24 0F 24 This could possibly have caused the employee's concern. The potential for other sites to misinterpret the acceptability of galvanized steel caused this issue to be deemed potentially generic. Further investigation proved this not to be the case and the DNE upper-tier procedure was determined to be adequate.
6.3 Hand Switches l
The concerns addressing the Westinghouse W-2 hand switches displayed the CI's lack of knowledge concerning the NRC 80-20 &
lR4 82-01 bulletins and the switch modification work which had already I
taken place. The information was readily available to the employee which would have explained the perceived problem away.
i 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken or Planned In regards to configuration discrepancies for electrical panel labeling, site implementing inspection procedures now address labeling of electrical items as a result of NCR 7225 Revision 1.
Vendor wiring in the unit 2 main control room panels at WBN is scheduled to be inspected. The Electrical Engineer in charge of the unit 2 main control room now t'. views all ECNs. regardless of category, for any changes that may require physical work.
Reference Construction Category Subcategory Report number 11200, "WorkPlan/ Work Control" for CATDs which require DNE to update and issue ver. dor drawings as part of the design change process.
Corrective action has already been taken to clarify the junction box material requirements in WBN QCP-3.03 by the Procedures and Training Section, WBN, DNC.
No corrective actions were required as a result of the hand switch concerns.
7.2 Corrective Action from CATD's Non-applicable.
8.0 ATTACHMENTS 8.1 Attachment A. Subcater.ory Summary. Table and List of Concerns 8.2 Attachment B. List of Evaluators 8.3 Attachment C. List of Concerns by Issue l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 1 0F 1 l
1 ATTACHMENT B List of Evaluators John Campbell - BLN Henry Loftis - SQN. BFN, and BLN Gary Lyles - BLN Rob Brown - WBN l
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100 l
SPECIAL PROGRAM
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REVISION NUMBER:
4 j
PAGE 1 0F 1 ATTACHMENT C List nf Concerns by Issue I
Issue Concerns 1.2.1 Panels WBP-85-016-003 1.2.2 Junction Boxes IN-85-913-001 1.2.3 Hand Switches HI-85-045 -001 HI-85-093-N02 l
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