ML20235B741
| ML20235B741 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/11/1987 |
| From: | Russell Gibbs TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 10500, 10500-V01-R03, 10500-V1-R3, NUDOCS 8902140388 | |
| Download: ML20235B741 (59) | |
Text
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EMPLOYEE CONCERNS SPECIAL PROGRAM i
l VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 10500 DETERIORATION OF PERMANENT FACILITIES UPDATED 1
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t TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REPORT TYPE: Subcategory - Construction REVISION NUMBER:
3 (Final) 1 TITLE: Deterioration of Permanent Faellities PAGE 1 0F 40 REASON FOR REVISION:
Revised to incorporate Executive Sumnary, SRP conunents. CAPS, and Finalize IR1 report.
I Revised to incorporate SRP conunents and TAS conunents and Finalize Report lR2 Revised to incorporate SRP conument.s and Refinalize Report IR3 PREPARATION PREPARED BY:
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Preface, Glossary, and List of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3
i Io clarify that one or more attachments will help the reader find where a particular concern is evaluated 4
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM FRONT MATTER REV:
3 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 Tennescee Valley Authority (TVA). The ECSP and the organization which catried out the program, the Employee Concerns Tast 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 ongoing 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 by four levels of ECSP reports: element, subcategory, category, and final.
Element reports, the lowest reporting level, will 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 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 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 mare 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 itwas have been placed at the front of each report: a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, at the end of each subcategory report will be a Subcategory 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 applicab!11ty; and briefly states each concern.
l 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.
(
e T7A EMPLOYEE CONCERNS REPORT NUMBF.R:
10500 SPECIAL PROGRAM FRONT !ATTER 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 industrial safety construction material control operations guality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of 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 all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
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 Tast Group Program Manual. The Manual spells out the program's objectives, scope, organization, and responsibilities. It also specifics the procedures that were followed in the investigation, reporting, and closecut of the issues raised by employee concerns.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE 111 0F viii ECSP GLOSSARY OF RSPORT TERMS
- classification Jf evaluated issues the evaluation of an issue leads to one of the folloC cf, determinations:
Class A: Issue cannot be verified as factual Class B: Issue is factually accurate, but what is described is not a probles (i.e.. not a condition requiring corrective action)
Class C: Issuc in 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 correctiw action, which was not identified j
by an employee concern, but was revealed during the ECTG evaluetion of an issue raised by an employee concern.
1 collective significance an analysis which determines the importance and l
consequences of the fiLdings in a particular ECSP report by putting those j
findings in the proper perspective.
i concern (see " employee concern")
corrective action Jteps taken to fix specific deficiencies or discrepancies j
revealed by a negative finding and, when necessary, to correct causes in i
order to prevent recurrence.
l criterion (plural: criteris) a basis for defining a performance, behavior, or quality which ONP imposes on its61f (see also " requirement").
l element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
f employee concern a formal, written description of a circumstance or circumstances that e.n employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
1 l
~, - - -
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM FRONT MATTER REY:
2 i
PAGE iv 0F vili evaluator (s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns.
findinas includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.
K-form (see " employee concern")
reautrement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.
root cause the underlying reason for a problem, i
l
- Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear i
safety-related, unreviewed safety-significant question).
1 i
l
e TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM FRONT MATTER REV: 2 PAGE v 0F viii Acronyms l
l l
AI Administrative Instruction AISC American Institute of Steel Construction l
ALARA As Low As Reasonably Achievable ANS American Nuclear Society l
l ANSI American National Standards Institute j
ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality I
l CAR Corrective Action Report l
CATD Corrective Action Tracting Document CCTS Corporate Commitment Tracting System l
CEG-H Category Evaluation Group Head l
CFR Code of Federal Regulations CI Concerned Individual CNTR Certified Material Test Report COC Certificate of Conformance/ Compliance DCR Design Change Roguest DNC Division of Nuclear Construction (see also NU CON)
i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM l
FRONT MATTER REV:
2 PAGE vi 0F viii DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training 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 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 Response Team FCR Field Change Request l
FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction HVAC Heating. Ventilating. Air Conditioning rI Installation Instruction INPO Institute of Nuclear Power Operations IRN Inspection Rejection Notice
v i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM i
FRONT MATTER REY:
2 l
1 PAGE vii 0F viii L/R Labor Relations Staff l
M&AI Modifications and Additions Instruction MI Maintenance Instruction 1
MSPB Merit Systems Protection Board MI Magnetic Particle Testing NCR Nonconforming Condition Report 1
NDE Nondestructive Rzamination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear Procedures System NQAM Nuclear Quality Assurance Manual l
WRC Nuclear Regulatory Commission NSB Nuclear Servlees Branch 4
NSRS Nuclear Safety Review Staff i
NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management and Resources Committee l
OSHA Occupational Safety and Health Administration (or Act)
ONP Office of Nuclear Power l
OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction
_______.___m__
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM FRONT MATTSR REV: 2 PAGE vill 0F viii QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction.in Force i
RT Radiographic Testing SQN Seguoyah Nuclear Plant i
SI Surveillance Instruction i
I SOP Standard Operating Procedure
]
SRP Senior Review Panel l
SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff T&L Trades and Labor TVA Tennessee Valley Authority TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Tosting VI Visual Testing
- WBECSP, Watts Bar Employee Concern Special Progras WBN Watts Bar Nuclear Plant WR Work Request or Work Ruins WP Workplans i
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I TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 l
PAGE 2 0F 40 l
i Outline of Contents PAGE
{
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Executive Summary J
.1 1.0 Characterization Of Issues 5
d j
1.1 Introduction 5
1.2 Description Of Issues 5
1.2.1 Caulking 1.2.2 Instruments 1.2.3 Rusted Instrument Air Lines 1.2.4 Rusted Conduit 1.2.5 Contaminated Electrical Control Cabinets l
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1.2.6 Water Stancing in Cable Trays 1.2.7 Debris in Cable Trays l
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3 ?.B Equipment installed in Underground Water Source l
2.0
SUMMARY
6 U
2.1 Sumary Or Issues 6
2.1.1 Caulking l
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2.1.2 Instruments 2.1. :3 Rusted Instrument Air Lines i
2.1.4 Rusted Conduit
- 1. 3. 5 Contaminated Electrical Centrol Cabinets 1
2.1.6 Water Stahding in Cable Trays l
l 2.1.7 Dabris in Cable Trays 2.1.8 Cguipment Installed in Underground Water Source 2.2 Summerir tir Evaluation Process 7
1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 3 0F 40 l
l PAGE l
2.3 Sunenary Of Findings 8
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2.4 Summary Of Collective Significance 10 2.5 Suarnary Of Causes 10 l
2.6 Summary Of Corrective Actions 12 l
1 l
3.0
SUMMARY
Of EVALUATION PROCESS 14 l
4.0 FINDINGS 14 4.1. Caulking 14 4.1.1. Watts Bar 4.1.2 Sequoyah 4.2 Instruments 16
~
4.3 Instrument Air Pipint 18 4.4 Conduit 19 l
4.4.1 Seguoyah 4.4.2 Watts Bar 4.4.3 Bellefonte 4.5 Electrical Control Cabinets 23 l
4.5.1 Sequoyah l
4.5.2 Watts Bar l
4.5.3 Bellefonte l
4.5.4 Browns Ferry l
l 4.6 Water Standing In Cable Trays 29 l
1 l
4.7 Debris In Cable Trays 30 4.8 Eculement Components Installed In An Underground Water Source 32 l
5.0 COLLECTIVE SIGNIFICANCE 32 i
IVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 40 PAGE 6.0 CAUSES 33 6.1 Caulking 33 6.2 Instruments 33 l
6.3 Instrument Air Pipint 34 l
6.4 Conduit 34 6.5 Electrical Control Cabinets 34 6.6 Water Standing In Cable Trays 35 6.7 Debris In Cable Trays 36 l
1 6.8 Eauipment Components Installed In An Underground Water Source 36 1
7.0 CORRECTIVE ACTIONS 36 7.1 Caulking 36 7.2 Instruments 38 7.3 Instrument Air Piping 38 7.4 Conduit 38 l
l 7.5 Electrical Control Cabinets 39 7.6 Water Standing In Cable Trays 39 7.7 Debris In Cable Trays 40 7.8 Eculpment Installed In An Underground Water,, Source 40 8.0 ATTACHMENTS 40 8.1 Attachment A Listing of Concerns indicating Safety 40 Relationship and Generic Applicability 8.2 Attachment B List of Evaluators 40 8.3 Attachment C List of Concerns by Issue 40 l
Datorioration of Parmanent Equipmint Report Number: 10500 Executive Summary Issue Assessment l
Eight issues concerning deterioration of permanent facilities were addressed l
in this subcategory report. The concerns addressing dust in vital control I
cabinets were evaluated at all four nuclear plant sites. Rusty conduit was evaluated at three sites. The concerns addressing instrumentation's i
indeterminate maintenance requirements and rusty instrument air lines were 1
evaluated at Watts Bar Nuclear Plant (WBN) only. The single concern addressing deteriorated caulking at the Additional Diesel Generator Building (ADGB) was evaluated at Sequoyah Nuclear Plant (SQN) and WBN. Two Bellefonte l
Nuclear Plant (BLN) specific concerns involving water in cable trays and l
debris in cable trays were evaluated at BLN only. One concern addressing equipment components installed in an underground water source could not be evaluated. This BLN specific concern'did not supply enough information on the K-form to initiate an investigation.
Major Findings The concerns for dust in control cabinets proved to be factual and modifications to eliminate dust in the DGB control cabinets at WBN are forthcoming independent of the concern evaluation. Rusty conduit was determined to be a minor cosmetic problem at three of the four sites and required no corrective action. The instruments addressed at WBN were determined to have no physical damage and were being maintained according to the controlling procedures developed by the preventive maintenance program.
The concern for the rusty instrument air line proved to be factual. The line
.in question had already been identified and replaced independent of the evaluation. The deteriorated caulking was verified but posed no safety-related problem at WBN and was not installed at SQN.
The concerns addressing water in cable trays and debris in cable trays at BLN could be substantiated for cable trays in manholes but not for cable trays in the powerhouse. Water and debris in manholes have also been identified at the other three sites.
Collective Significance Seven of the eight issues addressed are associated with permanent plant features that are susceptible to deterioration in an ongoing construction environment. The concerns addressing dust in control cabinets and water in cable trays have been shown to pose potential problems with safety-related equipment and systems. Construction Management has responded by expanding the Preventive Maintenance Program to identify and track damage and initiating corrective measures. The rusted air line problem was considered to be an insignificant issue since it had already been documented through the CAQ process and subsequently replaced through the ECN process before being voiced I
l as an employee concern.
Note: See Executive Summary Table #1 for Issue Evaluation.
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TVA EMPLOYE: CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 5 0F 40 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction Seven of the nine concerns addressed by this subcategory report are nuclear safety-related issues. Two concerns for the same issue were deemed generic to all four nuclear plant sites. One is generic to three sites. One is generic to Sequoyah Nuclear Plant (SQN) and Vatts Bar Nuclear Plant (WBN). The remainder are site specific.
The concerns categorized as deterioration of permanent facilities l
were evaluated in this subcategory. Three of these concerns evaluated were pertinent to SQN, six of these concerns were pertinent to WBN five of these concerns were pertinent to the Bellefonte Nuclear Plant (BLN), and one concern was evaluated for the Browns Ferry Nuclear Plant (BFN).
As used within this subcategory report the abbreviation (ONP) refers to the Office of Nuclear Power, exclusive of the Division of Nuclear Construction (DNC). This distinction is necessary since the majority of the employee concerns addressed by this subcategory report relate to requirements and criteria issued by the Office of Construction (Nuclear) (now DNC), and/or to requirements and criteria issued by ONP.
1.2 Description Of Issues 2.2.1 Concern IN-85-231-003 addressed caulking deterioration in the missile shields for the Additional Diesel Generat7r Building (ADGB) at WBN. This concern was considered to be generic for SQN.
1.2.2 Concern IN-85-962-002 stated that some unit 2 system 31 instruments had been installed in 1980 on Elevation 692 in the Auxiliary Building near the entrance to the unit 2 pipe chase and had never been documented. Lack of installation documentation provided indeterminate maintenance records for the instrumentation. This concern was determined to be site specific for WBN.
1.2.3 Concern IN-86-205-003 contended that two 4 inch embedded instrument air lines running from the Turbine Building to the Intake Pumping Station could possibly contain rust flakes 7
which would clog up instrument lines and cause false instrument readings. The lines were sandblasted in 1977 and then hydrotested before embedmont. This concern was determined to be site specific for WBN.
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 i
i PAGE 6 0F 40 1.0 CHARACTERIZATION OF ISSUES (continued) 1.2.4 The concerned individual who registered 00-85-005-010 perceived that a problem existed at SQN with exposed thread rust on 3/4" 8 all-thread nipples used to couple fittings i
for conduit located above the 710' elevation in the south part of the Auxiliary Building 12 inches to 30 inches below the ceiling penetrations. This problem was said to have existed before 1977 anG may still exist. This concern has been deemed generic for WBN and BLN.
1.2.5 Concerns OW-85-007-010 and IN-85-685-002 involves electrical control cabinets at WBN which have been contaminated by construction dirt and/or metal shavings. The contamination entered the cabinets through the cooling vents on top and front of the cabinets. The contamination could cause the contacts or other electrical components to deteriorate or become inoperative. This concern is generically applicable to SQN, BLN, and BFN.
1.2.6 Concern QCP 10.35-8-10 is BLN-specific and deals with water i
standing in cable trays.
1.2.7 Concern QCP 10.35-8-12 is BLN-specific and deals with debris in cable trays.
1.2.8 Concern XX-85-060-001 addresses equipment components that are installed in an underground water source that may be susceptible to rust damage. The employee emphasized that any additional information would compromise their 1
confidentiality. This concern is considered site specific for BLN only.
j 2.0
SUMMARY
2.1 Summary of Issues The basic perceived problem expressed by the employee concerns
]
within this subcategory is that equipment and plant features that are not routinely maintained through a preventive maintenance type i
program are visibly deteriorating and that no program exists to identify and control any further plant damage.
The issues raised by the various employee concerns contained within this subcategory report are summarized as follows:
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM RSVISION NUMBER: 3 PAGE 7 0F 40 l
2.0
SUMMARY
(continued) 2.1.1 Caulking in the lift eye bolts recesses for the missile shields at the Additional Diesel Generator Building is deteriorating because of improper installation and incorrect choice of materials for the job requirements caused by a lack of design criteria input before installation.
2.1.2 Some system 31 instrumentation has been installed in the l
Auxiliary Building for six years without benefit of I
documentation or routine preventive maintenance because of l
the transfer schedule slowdown and required calibration documentation sequence.
1 2.1.3 Rusted instrument air lines hydrotested and left in a wet l
layup condition.could lead to rust flakes clogging up
)
instruments thereby creating false readings, and/or equipment
)
failure.
2.1.4 Rusted exposed threads on 3/4-inch B conduit nipples in the Auxiliary Building at SQN are not being corrected and could have an adverse effect on plant operation.
2.1.5 Accumulations of dust and metal shavings inside electrical I
equipment cabinets could cause electrical components to deteriorate or become inoperable.
l 2.1.6 Water standing in cable trays is a condition potentially adverse to quality.
2.1.7 Debris in cable trays is a condition potentially adverse to quality.
2.1.8 Equipment components installed in underground water source I
l are susceptible to rust damage.
2.2
SUMMARY
OF EVALUATION PROCESS The nine employee concerns associated with this subcategory report were investigated in accordance with specific evaluation plans established for each project. Since each issue was investigated as an independent entity, the specific evaluation methodology utilized varied somewhat because of the nature of each issue.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 i
SPECIAL PROGRAM
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REVISION NUMBER: 3 s
PAGE 8 0F 40 l
2.3 Summary Of Findings Of the eight issues raised by the various employee concerns contained within this subcategory, as enumerated in section 1.2 l
above, four require corrective action and one concern remains unresolved because of lack of information required to respond.
2.3.1 Caulking The deteriorated caulking in the Additional Diesel Generator Building missile shield lifting eye recesses was determined to be factual. Civil features such as the missile shields do i
not receive routine preventive maintenance inspections. The caulk performs no safety function.
2.3.2 Instruments The specific instruments noted by the concern have been installed and documented. No maintenance or periodic calibration is required prior to system transfer to ONP. The Preventive Maintenance Group has responsibility for periodic inspections for damage and/or visible deterioration.
2.3.3 Instrument Air Piping 1
The perceived rusty 4-inch air lines turned out to be one i
1-inch air line. The problem with the air line had already l
been addressed by NCR 4386 and ECN 3740 was issued to provide a replacement air source.
2.3.4 Conduit Exposed thread rust was considered to be a generic problem at I
three TVA nuclear sites. Walkdowns in the Auxiliary, l
Turbine Control, and Reactor Buildings at each site revealed only minor surface conduit thread and fitting rust. There was no indication of damage or deterioration that would require corrective action.
2.3.5 Electrical Control Cabinets l
Airborne contamination was considered to be a generic concern for all TVA nuclear sites. Some dust was found in most of the cabinets inspected during the evaluation. The amount of dust observed was minor and not deemed to be detrimental to cabinet functions except at WBN's Diesel Generator Building.
I Temporary fiberglass air filters have been taped over the j
front air vents of the control cabinets in an attempt to keep out dust. The design of the control cabinets ventilation system forces room air into the interior of the cabinets.
Some relays have exposed contact surfaces and some
a TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 9 0F 40 time delay relays have pneumatic time contro'1 orifices which would be susceptible to damage from the airborne dust particles. Design changes to incorporate permanent filters on the control cabinets are forthcoming. All of the sites have preventive maintenance and housekeeping procedures in place to preclude any excessive buildups of dust in any of the control cabinets. There are procedures in place at each site addressing protective requirements for control cabinets when any construction activities are taking place in the areas surrounding the cabinets.
2.3.6 Water Standinr. In Cable Trays Water standing in catie trays was a site specific concern voiced at BLN. No evidence of water standing in cable trays could be found during the extensive walkdowns through the Reactor Building, Auxiliary Building, Control Building, and Turbine Building. Water standing in manholes has been identified as a problem at all TVA nuclear sites. Some of the manholes were observed to have had enough water in them I
to cover cable trays. Some of the manholes were equipped with sump pumps which would keep the water level below a level which would have the potential to damage cables and other equipment installed in the manholes. preventive j
maintenance and housekeeping programs at each site need to be
)
l expanded to include periodic inspections for all manholes to preclude any potential equipment damage.
2.3.7 Debris In Cable Trays j
Debris in cable trays was a site specific concern at BLN.
The visual survey of cable trays was done in conjunction with l
the evaluation for water standing in cable trays. The survey 1
produced no cable trays containing dirt or debris, i
Safeguards are in the housekeeping and cable tray l
l Installation procedures which monitors keeping employees, i
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tools, materials, and debris out of the cable trays and off
(
l of the cables.
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I 2.3.8 Equipment Components Installed In An Underground Water Source This concern was site specific for BLN and was the only concern voiced concerning rusted equipment components. It j
did not address a specific type, location, or any information j
that would establish a starting point for the investigation of the concern. The concerned individual emphasized that to
[
provide any more information about the specific equipment would compromise their confidentiality. Specific information l
1s required before an investigation and evaluation can be made.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 10 0F 40 2.4 Summary Of Collective Significance Seven of the nine concerns evaluated in this subcategory address the problems associated with permanent' plant features which are in place long before the plant is in an operational mode. Cables, cable trays, conduit, instruments, and control cabinets are all susceptible to deterioration in an ongoing construction environment. The findings in five of the seven concerns noted that l
there are existing procedures that govern the survelliance and maintenance requirements of the features. The two concerns addressing instruments and the deteriorated cault show in their findings that there is a period of time between installation and system transfer that no program is in place to guarantee their l
integrity and safety. No collective significance was assigned to the concerns addressing equipment installed in an underground water source or the rusted instrument air line.
2.5 Summary Of Causes 2.5.1 Caulkina l
The deteriorated caulking condition is a result of the use of an improper material for the application requirements and insufficient periodic inspections. Design review and coordination between the materials application group and the responsible CEB engineer was lacking.
2.5.2 Instruments No specific cause for the concern was determined from the l
evaluation. The concerned individual questioned TVA's l
installation and maintenance practices for instruments.
I 2.5.3 Instrument Air Pipina Hydrotesting the air line and leaving it in a wet layup configuration caused the rust problem.
I 1
2.5.4 Conduit No specific cause was assigned to the rusty condult. Minor thread rust was evident at all sites inside the environmentally controlled structures, and more noticeable rust deposits were evident in aress of continuous harsh environments.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 l
SPECIAL PROGRAM g
REVISION NUMBER:
3 PAGE 11 0F 40 2.5.5 Electrical Control Cabinets i
)
Airborne contaminants infiltrating into electrical control cabinets is caused by the ongoing construction activities, in conjunction with the ventilation system designed into the cabinets themselves. The room ventilation system at WBN's Diesel Generator Buildings actually forces airborne dust particles through the cabinet ventilation louvers.
2.5.6 Water Standina in cable Trays No evidence of any existing water standing in cable trays could be substantiated inside any deled in structures at B LN.
Water standing in manholes, which in some instances has risen above cable tray levels, has been identified at all TVA nuclear sites. Causes attributed to these problems were:
j A.
Having manholes covers installed at elevations that are lower than the surrounding grade levels.
B.
Underground conduit that fills with water at times and 1
empties into the manholes.
C.
Sump pumps that are installed In the manholes are inoperable for indeterminate reasons and for indeterminate lengths of time.
I D.
Inadequate design considerations for water removal from manholes.
E.
Poor housekeeping practices in conjunction with inadequate preventive maintenance programs for addressing recurring problems.
F.
Management inattentiveness to trends of having to pump water out of manholes before performing work.
Though no evidence could be found to prove water had been standing in cable trays inside dried in structures, the possibility that the concerned individual witnessed water standing in cable trays cannot be ignored. Instances when water could possibly have been noted in cable trays are as follows:
A.
Rain could have filtered down from one elevation to l
another before the roof of a building was in place.
1 B.
The CI could have observed an incident where water leaked into a cable tray from piping or tubing that was undergoing a hydrostatic test.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 13 PAGE 12 0F 40 2.0 Summary (continued) 2.5.7 Debris in Cable Trays No evidence was found to document any instance of debris existing.in cable trays at this point in time. The CI could possibly have witnessed debris in cable trays sometims in the past that could have been caused by one of the following:
IR3 A.
The CI observed an isolated instances where employees, tools, materials or debris were in a cable tray before the site QA organization and NRC cited construction for violating cleanliness requirements for cable trays in 1985.
B.
The CI observed an empty cable tray which had not been inspected, which contained dirt or debris. This situation has existed in the past.
j 2.5.8 Eauipment Components Installed In An Underground Water Source The K-form information is not specific enough to evaluate the concern and determine a cause. The CI indicated that any further information,would compromise their confidentiality.
2.6 Summary Of Corrective Action 2.6.1 Caulkint ECN 6798 will be issued for WBN to revise drawing 10W331-16 Rev. 2.
The note requiring caulk will be deleted.
Drain i
holes will be added to the recesses in the alssile blocks to prevent water collection. A protective coating will be applied to the lifting eyes to inhibit rust and deterioration.
The caulk is not installed in the missile shield blocks at SQN.
If lift eye deterioration appears, repairs will be initiated in accordance with the existing maintenance process.
2.6.2 Instruments No corrective actions are required for this concern.
2.6.3 Instrument Air Pipina Corrective actions have already been taken. No further corrective actions are required.
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4 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 40 2.0 Summary (continued) 2.6.4 Conduit Fanagement to encourage employee involvement and feedback in reporting plant feature deterioration to preclude any potential component failure. Conduit rust prevention and identification is achieved at all sites within the parameters of GCS G-40 sections 3.2.1.6 and 3.2.4.2 and by the applicablo site implemented procedures.
i 2.6.5 Electrical Control Cabinets Management needs to:
A.
Enhance employee awareness and encourage active participation to improve overall plant cleanliness.
1 B.
Identify problem cabinets and areas and provide preventive measures to preclude dust and/or metal particles from entering electrical control cabinets.
j Corporate Management provided the following as a corrective l
action response. The appropriate preventive and corrective procedures are in place at the affected sites to address dust and/or metal particles in electrical control cabinets.
C.
Design and install permanent filters for control cabinets at WBN's Diesel Generator Building, j
i 2.6.6 Water Standing In Cable Trays Manhole inspection requirements should be incorporated into I
the b)usekeeping and preventative maintenance programs.
lR3 The inspection requirement for visible moisture presence in i
solid bottom cable trays needs to be added to the housekeeping procedures for all sites. BLN-DNC has initiated a change to BNP-QCP-10.27 to require inspection for standing water in
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cable trays for areas and systems not transferred to plant operations. Transferred areas and systems will be surveyed and controlled by Bellefonte Standard Practice.BLS-4 lR3 attachment 2. "Housteeping Checklist."
l 2.6.7 Debris In Cable Trays l
No corrective action required.
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q TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 14 0F 40 2.0 Summary (continued) 2.6.8 Eguipment Components In Underground Water Source No corrective action can be assigned until enough information is obtained to enable ECTG to investigate and evaluate the-concern.
3.0 Evaluation Process In general, the evaluation methodology consisted of the following steps:
A.
The complication and review of all applicable DNC, ONP, SQN, WBN, BLN, BFN procedures, codes, requirements and practices.
B.
Plant walkdowns and component inspections.
C.
Interviews and discussions with individuals directly involved with implementing aforementioned requirements and practices.
D.
The complication and review of previous work, reports and interoffice memorandums concerning elements in this report.
4.0 FINDINGS The following is a summary of the findings and conclusion for each of the eight elements within this subcategory:
4.1 Caulking 4.1.1 Watts Bar Conversations with DNC Civil Engineer, DNE-WBP Civil Engineer and ONP Mechanical Maintenance Supervisor, a review of documentation, and a field inspection resulted in the following:
A.
The caulk in question was added to the Additional Diesel Generator Building missile shield lifting eye recesses by FCRs F-3183 and F-3427 on TVA drawing 10W331-16. R2, to aid in keeping water out of the recesses. The recesses were provided for the lift eye bolts to limit the height dimension due to the restricted clearance above the shields for lifting. Diesel Generator building misslie' shields one through four do not have caulk in the recesses. The caulk performs no saf ety function.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 15 OF 40 4.0 FINDINGS (continued)
B.
Currently the recess cault is 4 inches thick..The drawing calls for an approximate 8-inch thickness. This is a drawing requirement and an as-constructed configuration conflict, which requires correction. There are cracks and bubbles in the caulking and surf ace spalling of the concrete around the recesses.
C.
Neither Construction' nor ONP plant maintenance procedures specify routine periodic inspections of civil features such as missile shields and caulking. However, deterioration problems associated with nonnuclear safety-related features such as caulk are detected and l
corrected during architectural transfer walk downs.
I Also, the maintenance request process will initiate repair for problem areas when requested by concerned individuals.
D.
Division of Nuclear Construction (DNC), Division of l
Nuclear Engineering (DNE) and Office of Nuclear Power l
(ONP) Engineers were in agreement that'it would not matter if the cault was left as is.. removed, or replaced with regard to the missile shield in-place design function. However, accelerated lift eye bolt rust which is enhanced by these wet areas is a potential hazard associated with shield lifts. Caulk is not intended for use in applications as thick as this,and can be expected to deteriorate by bubbling, cracking, losing adhesive and flexible properties, etc., because of temperature fluctuations and expansion / contraction cycles. Moisture is retained in the recers within the cracks, crevices, bubbles, etc., resulting from caulk deterioration, which hampere normal evaporation and seepage through the concrete. The retained moisture will accelerate lift eye bolt rust. If water collecting in the recesses were to freeze, design experience indicates it would simply cause some loemlized spalling and cosmetic damage to the concrete surrounding the recesses.
Conclusion Deteriorated caulking on the missile shleid does exist. The situation has been determined to be insignificant in nature and not nuclear safety-related. Some correctivt actions are warranted as shown in section 7.0.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 16 0F 40 4.1.2 Sequoyah A.
Inspection of the Additional Diesel Generator Building revealed the building is still under construction and the lifting eye recesses in the missile shleide do not have caulking in them at this time. A review of TVA drawing 10W333-16. R2, showed that eight inches of polysulfide caulking was called for to fill the recesses, of the top shield only, to seal out water.
B.
The review of WBN ECTG Element Report, Caulking (C010501), revealed the concern was factual at WBN but was insignificant and not nuclear safety-related. This review also revealed that a Field Change Request (FCR) is to be initiated by WBN mechanical maintenance to modify the note on TVA drawing 10W331-16 to eliminate the requirement to " fill the recess with caulk."
Conclusion Caulk has not been placed in the misslie shield lif ting eye recesses at this time. SQN should follow the path of WBN by initiating an FCR to eliminate the requirement to fill the recesses with caulk and to specify the disposition which will address the " Bolt Rust" concern which precipitated the generation of FCRs F-3183 and F-3427.
4.2 Instruments Conversations with the DNC Instrumentation Engineering Unit Supervisor and the Instrumentation QC Supervisor, review of DNC and DNP procedures governing instrument installation / calibration, preventive maintenance, and physical inspection of the instruments in question revealed the following:
A.
The method of verifying installation completion for instruments is governed by QCP-3.06-7, " Inspection of Electrical and Instrumentation Egulpment Installation." This inspection is initiated, by request, from the responsible engineering group to the QC group. A separate unit within the Construction l
Engineering Organization (CEO) has been established and assigned the responsibility of ensuring a quality program through I
continued verification of requirements, correct frequency of inspection, proper documentation, and timely correction of deficiencies for permanent equipment during.the time between initial installation inspection and system transfer to ONP.
Procedure WBN-QCP-1.52, " Preventive Maintenance," was revised in October 1985 to incorporate any changes necessary to comply with new vendor specifications for equipment.
WBN-AI-6.6,
" Performance of Initial Testing, Calibration, and Maintenance of Permanent Plant Instrumentation Before Transfer." governs the
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 17 0F 40 4.0 FINDINGS (continued)
A. (continued) method of ONP initial instrument calibration and documentation upon DNC request before transfer. ONP performs instrumentation umintenance and tracks periodic recalibration requirements, in accordance with established procedures after system transfer.
B.
Inspection of the described area revealed that flow, pressure, and temperature instruments were installed on panels 2-L-544 and 2-L-545 for unit 2 system 31, incore instrument room chillers A and B.
These panols are in the suziliary building elevation 692 pipe chase. The instruments were covered with metal protective covers hung onto the panel frames.
C.
Unit 2 work including system 31 " Chilled Water," has been slowed by the current evaluation process underway for both units at WBN. Transfer of unit 2 systems, when resumed, will involve a complete walkdown inspection of systems by DNC responsible engineering units and subsequent joint transfer walkdown of systres ty DNC and DNP groups. This transfer pro:ess will include a verification of instrumentation installation and completed "25" test cards or a listing of open items requiring work. The initial and periodic calibration of instruments are a part of this process.
D.
Discussions with the Instrumentation Systems Engineer, the Preventive Maintenance Engineer, and the ONP Instrument Maintenance Engineer, indicated the current procedure controlling the installation, documentation, and maintenance of instruments are adequate to maintain the integrity and safety of the instruments.
E.
A review of the controlling procedures provided assurances that provisions were in place to maintain instrument integrit).
IR3 Conclusion The schedule stretch out for unit 2 may sometimes give the appearance that. some uncompleted work may not get done.
However, if existing procedures and documentation are followsd, unit 2 instruments will receive their required maintenance and calibration before and following placement in operation. Therefore, this concern is not factual and not a safety problem and no corrective action because of the concern is required.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 18 0F 40 4.3 Instrument Air pipinr.
Review of the Air Supply Drawings for the Intake Pumping Station, upper tier procedures governing installation methods & pressure test requirements, history of the air line presently in use. and discussions with engineers for DNC-IEU & MEU. DNE-Nuclear Engineering Branch (NEB). ONP-Preoperational Test Groups. Instrument Mainte' nance, and Operations Sections produced the following:
A.
The air supply piping addressed by this concern supplied air to I
the Intake Pumping Station ERCW traveling screen differential l
pressure switches and for air supervision of the reaction fire i
protection header at the Intake Pumping Station. In actuality.
the 2-to 4-inch lines in question are really just one 1-inch line.
l B.
This nonessential air supply line was hydrostatically tested I
rather than pneumatically tested as required by current procedures.
1 C.
Established testing procedures discovered that the rusted line could not pass flow and cleanliness requirements. Subsequently, a WBN Construction NCR 4386 and ECN 3740 were initiated to evaluate and correct this air line situation. The ECN removed I
from use and capped the' rusted air line and an alternate air 1
supply was established. The changes made were determined to bc acceptable and meet prescribed requirements.
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D.
The control air system design at WBN follows industry standards I
in the use of carbon steel piping.
In essential air systems stainless piping and tubing are used. Air dryers limit moisture in control air service and a local filter removes particulate.
Test procedures establish acceptable test mediums and system installation acceptance is accompanied by an air blow through a l
white cloth for cleanliness testing.
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Conclusion 1
Discussions of this concern with instrumentation engineers indicated l
this concern was factual. However, it was detected and corrected by i
established procedures and existing procedures would prevent recurrences; therefore, no corrective actions are required.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 19 0F 40 4.4 Conduit Exposed thread rust on conduit was considered to be a generic concern for three TVA nuclear plant sites. The general evaluation approach for addressing this concern was established at SQN, where the original concern was voiced, and was followed during the evaluation process at WBN and BLN. Reference section 3.0 above.
Each plant finding will be discussed below:
4.4.1 Sequoyah A.
The walkdown of the Auxiliary Building, elevations 669, 690, and 734, areas of the Turbine Building and yard areas revealed only minor surface conduit thread and fitting rust which required no corrective action. A great deal of outside and Turbine Building areas had aluminum conduit, as well as some areas of the Auxiliary Building. Aluminum conduit wonid not have the rusting problem.
i B.
The discussion with electrical personnel from Maintenance and Modification Groups did not reveal a problem with rust on conduit.
C.
The review of Standard Practice SQ-A66, " Plant Housekeeping," Revision 9. revealed the housekeeping checklist contained items to assist in the identification of rust on conduit. There is no indication of damage or deterioration of installed items due to improper housekeeping.
D.
A review of Standard practice SQM2, " Maintenance Management System," Revision 18, showed that any plant personnel may report the need for plant corrective maintenance or repair work by filling out a Maintenance Request (MR) form. This would include rusty condult.
E.
A review of Modification and Additions Instruction.
(MLAI)-6, Revision 6. " Installation of conduit and Junction Boxes", dated February 18, 1986, revealed in paragraph 3.2.4.2 that steel and IMC conduit joints and connections shall be made watertight and rustproof by means of application of a thread compound which will not insulate *.he joint. This shall be done on any conduit being installed by the Modifications Unit. An example of
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l TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 20 0F 40 4.0 FINDINGS (continued) this compound was given as "Kopr-Shield."
Paragraph 3.2.4.3 stated rigid aluminum conduit installed outdoors or in wet locations shall preferably be provided with aluminum fittings and supports. Galvanized fittings i
and supports may be used in special cases. Care must be taken to prevent the contact of aluminum conduit with corrosive materials in locations where moisture can accumulate.
conclusion The concern for conduit rust at SQN was found to be an insignificant problem with no corrective action required.
i There are effective programs in place at SQN to identify excessive conduit rust if it occurs and ways for anyone to get corrections made should they ever be needed.
I 4.4.2 Watts Bar A.
The surveys conducted in the Auxiliary Building, Reactor J
Building, and yard arpas of VBk revealed only minor conduit thread and fitting rust which required no equipment corrective action at this time. Only surface runt was found on some yard area conduit threads and fittings. These outside rusted areas were associated with temporary conditions involved with unit 2 construction activit.ss which will be removed from service as the construction work and transfers are finalized.
B.
The discussions with ONP Electrical Engineers revealed that conduit rust has not been a significant power plant problem and has been handled through the plant maintenance and housekeeping procedures. These procedures depend on employee detection and reporting by MR of deficient conditions, along with the formal tours for the Construction to Power system and feature transfers and housekeeping tours. Typically, rust forms on the surface then dramatically slows unless there is moisture present combined with exchanges of atmosphere to replenish the oxygen and/or flowing liquid conditions.
TVA EMPLOYEE CONCERNS REPORT NUM8ER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 21 0F 40 4.0 FINDINGS (continued)
C.
The review of the governing installation procedures revealed that construction specifications address use of rust preventative compounds on conduit threads. Also, transfer tours, plant housekeeping, maintenance, and employee involvement programs are in place which will correct deficient conditions in most plant areas when they are detected and reported. However, procedures do not exist to periodically inspect infrequently accessed areas for general deterioration such as rust.
Conclusion This SQN conduit rust concern was found to be an insignificant probJam at WBN which requires no corrective action at this time. However, the maintenance program at WBN depends on employee awareness, detection, and reporting of deteriorated conditions observed during day-to-day work activities in addition to the transfer and housekeeping tours. Since these tours focus on egulpment and overall areas, some detail items such as conduit rust in out-of-the-way areas right not be detected. Therefore, it was determined that a potential exists for conduit and other equipment / structure deterioration to go undetected for long periods in areas which are accessed very infrequently.. This is especially l
true in areas which,are damp and/or exposed to the elements.
Examples of these are yard areas, manholes, underground cable f
tunnels, pipe chases, confined spaces, and other j
out-of-the-way areas. Since existing minor conduit rus conditions could progress and eventually warrant corrective I
measures, espeelally in high potentisi, infrequently accessed areas, there are some procedural improvement (nd emphasis actions which are recommended and are listed as corrective action in section 7.0.
4.4.3 Bellefonte i
A.
The survey of comparable areas in.5* Auxiliary Building revealed no rust of any consequence. Za fact no rust at all was found on 3/4" e conduit threads. In the Auxiliary Building, areas which (from ground elevation) appeared to have rust on the conduit threads turned out to be the copper coating used on threads which had lost its sheen and to which dust had adhered giving the I
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L TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 22 0F 40 4.0 FINDINGS (continued) appearance of rust. Outside areas at the diesel fuel storage tanks and cooling towers were also surveyed for conduit threads in high element exposure environment which had visible rust.
B.
In discussions with DNC electrical engineers, it was revealed that conduit requires no structural strength requirements. Rust can form on conduit and conduit threads, but after a general oxidation period, rust dramatically slows down unless moisture is ever present in combination with oxygen. In discussion with the Electrician Craft Superintendent, it was revealed that the copper coating is used on all conduit threaded joints.
C.
Reviewing G40
" Installing Electrical Conduit Systems and Conduit Bores," revealed in section 3.2.4.2 that
" steel and intermediate metal conduit joints and connections shall be made water-tight and custproof by means of the application of a thread compound." Also BNP-QCP-10.27. R10 " Housekeeping," reveals in section 4.1,
" cleanness - A state of being clean in accordance with predetermined standards, and usually implies freedom from dirt, scale, heavy rust, oil or other contaminating impurities."
Conclusion The SQN conduit rust concern was found to be an' insignificant problem at BLN es no threads containing rust were observed in relevant areas of the Auxiliary Building. Threads were found which took on the appearance of rust; however, closer observation revealed it only to be the copper coatings used on all conduit fittings which had lost its sheen and, mixed with construction dust, had taken on the appearance of rust.
Outside areas of high element exposure revealed rust on conduit. threads at the cooling tower swite' gear ar.t t 4e1 n
storage tank pump motors conduit. The rust does not rose any problem because of the fact that any serious deterioration hasn't surfaced at this time. However, some procedural improvement and emphasis should be put on damp area inspection, as well as areas of high element exposure such as yard areas.
Powerhouse Building areas have installation specifications located in G-40, section 3.2.4.2 addressing water-tight and rustproofing ctoduit threads by installation
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 23 0F 40 4.0 FINDINGS (continued) of copper costings and supplemented by the housekeeping proced re BNP-QCP-10.27. RIO concerning cleanness in section 4.1 "which usually implies freedom from--heavy rust-." One procedure discrepancy was noted and that was the.t even though G-40 section 3.2.4.2 addresses the use of a thread compound to make joints and connections water-tight, rust proof and noninsulating, there is no inspection requirement in BNP-QCP-3.2, R12 concerning " Conduit Systems" which addresses the use of thread compound. The craft are made aware of the requirement for thread compound by way of their training module BN-TM-018. " Exposed Conduit."
4.5 Electrical Control Cabinets Dust and/or metal particles contoninating interiors of electrical control cabinets was considered to be a generic concern for all IVA nuclear plant Sites. The same general evaluation approach for addressing this concern was established at WBN where the original concern was voiced, and was followed during the evaluation process at SQN, BLN, and BFN. Reference section 3.0 above. Each plant
. finding will be discussad telow:
a.5.1 Sequoyah A.
The review of WBN Element Report. Electrical Control Cabinets (C010505), revealed WBN did not have a problem at present with dust or metal grindings building up in electrical cabinets except as noted at the Diesel Generator Building. The generic application to SQN was in regard to the need for employee involvement in reporting cleanliness condition violations.
B.
An inspection tour was taken to observe electrical control cabinets in the Turbine, Auxiliary, and Control Buildings. Some dust was found on some of the cabinets.
No metal grindings were observed. The amount of dust obserred was minor and was not enough to be detrimental to cabinet functions. Interiors of cabinets observed with surface dust were inspected for possible contamination. None was found.
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TVA EMPLOYEE CONCERNS REPORY NUMBER: 10500 SPECIAL PROGRAM I
REVISION NUMBER: 3 PAGE 24 0F 40 4.0 FINDINGS (continued)
I C.
Review of Standard Practice SQA66 " Plant Housekeeping "
Revision 9. revealed in paragraphs'4.0.6 and 4.0.7 that plant operations personnel will clean the front of i
electrical distribution boards, control boards, and i
control panels. In general, everyone engaged in a work activity is responsible for maintaining proper cleanliness during the activity and for cleanup followint completion of the activity.
Also, in paragraph 4.2, sections E and F, SQA66 states "special care shall be taken when opening or disassembling sensitive electrical equipment which may be i
damaged by dust or moisture. Such work shall be performed in an area which has been cleaned of excess i
litter, dirt, and dust. Barriers, screens, shields, I
restricted access, or other protection shall be provided
{
as necessary for isolation of areas where dust, inclement
]
weather, or other conditions exist that may affect the quality of work being performed." The housekeeping l
checklist also has roecific electrical chect items such as "there is no accumulation of foreign materials around the exterior of electrical boards and panels."
D.
Interviews with Electrical Maintenance personnel revealed i
l they do not believe dust and metal grindings in the electrical control cabinets to be a prot 2em. The interviews revealed the Electrical Mair *: nance personnel were very much aware of the need for cleanliness of these cabinets.
E.
Review of the MRs did not reveal any direct evidence that dust or metal grindings in control cabinets had caused any problems.
l Conclusion l
There is not a problem with dust and/or metal grindings
)
contaminating the control cabinets at SQN. There are i
procedures inplace at SQN to prevent this from becoming a problem.
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.n TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL FROGRAM REVISION NUMBER:
3 PAGE 25 0F 40 m.__
4.0 FINDINGS (continued) 4.5.2 Watts Bar A.
A plant survey of electrical control cabinets was conducted in the Diesel Generator, Turbine, Auxiliary, and Control Buildings on both unit: at WBN. Some dust was found in most cabinets. No metal grindings were observed. The amount of dust observed was minor and not deemed to be detrimental to cabinet functions except as noted at the Diesel Generator Building. The amount of dust observed did not appear unusual for the construction stage of WBN.
I B.
Dust and dirt problems in the Diesel Generator rooms continue to,be neglected. Temporary fiberglass air i
filters have been taped over the front air vents of the I
field flash and voltage regulator cabinets in an attempt l
to keep out dust. Some relays in the generator I
excitation cabinets are not enclosed. This exposes the contact surfaces to dust, grit, and other airborne contaminants. The same problem exists with the time delay relays with the pneumatic time control orifices in the adjacent control cabinets.
C.
The review of governing documents revealed that l
construction quality control procedures for electrical equipment includes inspections for cleanliness and 4
l provides for corrective action for deficiencies.
Modifications Administrative Instructions include l
requiring work provisions for protection of surrounding equipment during work activities and inspections for cleanliness, with followup corrective action. Before transfer of equipment to ONP, walkdown inspections examine electrical equipment for cleanliness.
Maintenance Instructions require periodic inspection and l
cleaning of major electrical control cabinets. The ONP l
MR instructions and DNC Employee Involvement programs I
will result in correction of deficient conditions when l
they are observed and reported by employees during their day-to-day work activities. The DNC Housekeeping and Employee Involvement procedures are relatively new and are an improvement over past programs.
D.
The discussions with cognizant engineers revealed that there have been times in the past when metal grindings and excessive dust were temporarily present inside l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 pAGE 26 0F 40 4.0 FINDINGS (continued) electrical control cabinets. This indicated that the appropriate protective procedures were not followed or the work was too extensive to allow adequate protection.
Excessive dust and metal grindings, if allowed to remain in electrical cabinets, could cause premature failures because of excessive heat, and in extreme cases, cause shorting of contacts and wiring. However, these conditions were cleaned up and are not present at this time. The cleanup of the excessive dust and grindings occurred through the normal inplace combined ONP and DNC inspections, transfer, housekeeping, and maintenance procedures.
i Conclusion The electrical control cabinet dust concern was not found to be a current problem of any consequence at WBN, except as noted at the DGB. However, discussions with cognizant individuals indleate excessive dust has been occasionally found in the electrical control cabinets in the past. This does not seem to be unusual for a plant with construction work still going on, as long as it is cleaned out before the equipment becomes operational. The cleanup of dust and the protection of electrical control cabinets from surrounding work, activities-is an on-going program which requires continued attention by all employees and supervisors, l
Therefore, there are some corrective actions warranted as
{
indicated in section 7.0.
4.5.3 Bellefonte A.
Random inspection of electrical control cabinets produced evidence of dust in most all cabinets. No metal grindings were found in any cabinets. The amount of dust found in the cabinets was not excessive.
B.
BNP-QCP-10.27 RIO " Housekeeping," section 6.3.1.5 addresses protecting installed equipment from adjacent I
construction activities to prevent permanent equipment damage. Section 6.3.1.6 addresses electrical cabinets and making provisions to shield cabinet openings during work activities while providing proper ventilation.
j BNP-QCP-1.3, R8 " Preventive Maintenance," section 6.2 adosesses corrective action for areas not found to meet maintenance requirements and documents proposed 1
corrective action and disposition of such.
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v 17A EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 27 0F 40 4.0 FINDINGS (continued)
BNP-QCP-9.2, RIO " Transfer of Permanent Plant Equipment, Systems or Structures," Attachment "E" sections 2.A.1 and 2.A.4 address interior cleanliness of control cabinets at j
time of transfer of permanent equipment, systems, or structures from DNC to ONP.
C.
Discussion with BLN-QC Preventive Maintenance Group l
Leader revealed that all of the safety-related electrical control cabinets are in the Preventive Maintenance Accountability Program; however requirements for cleanliness levels are supplied by different systems engineers. By different engineers controlling the l
requirements for the cabinets of their systems, there is no consistency in th6 periodic inspection requirements.
)
Discussion with a BLN Craft Coordinator revealed that of
)
the cabinets in the program which require being cleaned, J
very few have "E" sheets (requirement deficiencies) and 1
when the Construction Coordinator gets an "E" sheet the Electrical Craft Superintendent meets or betters the required turn around time on clearing up the deficiency.
D.
Discussion with the Electrical Craf t Superintendent revealed that airborne dust and metal grindings do get i
I into the Electrical Control Cabinets. However, craft I
employees on medical restrictions within the electrical department are utilized in continually cleaning these I
cabinets and components. The number of employees utilized will vary but cleaning of the components and cabinets is a continuous effort.
Conclusion l
l Dust and metal grindings exist inside electrical cabinets at j
BLN. Hnwever, engineering, quality control, and craft personnel, in conjunction with inplace procedures, adequately address the problem. As soon as electrical cabinets are received onsite, electrical engineers write the maintenance requirements. Anytime the location or environment of these cabinets change, the engineer is afforded the opportunity to i
update or change the requirements. Once the cabinet is l
installed in the field, engineering could eliminate the requirement of checking the cabinet for cleanliness. This would eliminate quality control inspections. However, the l
electricians are still cleaning cabinets constantly. During I
walk throughs and transfers, cleanliness is addressed by the inplace BNP-QCP-9.2, RIO requiring the cabinet and components to be clean before Operations Saction will accept the transfer of said equipment.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 28 0F 40 4.0 FINDINGS (continued) i 4.5.4 Browns Ferry A.
The review of WBN Element Report, Electrical Control Cabinets (C010505) revealed WBN did not have a problem at present with dust or metal grindings building up in electrical cabinets except at the DGB. The generic application to BFN was in regard to the need for employee involvement in reporting deterioration and any lack of cleanliness conditions.
B.
Electrical control cabinets were inspected in the Turbine, Reactor, and Control Buildings. Some dust was found in some cabinets. No metal grindings were observed. The amount of dust observed was minor and was not enough to be detrimental to cabinet functions.
C.
Review of Standard Practice BF-4.2, " Safety Inspections and Audits " Revision 2 revealed in paragraph 4.0 that "special care shall be taken when opening or disassembling sensitive electrical equipment which may be damaged by dust or moisture. Such work shall be performed in an area which has been cleaned of excess litter, dirt, and dust. Barriers, screens, shields, restricted access, or other protection shall be provided as necessary for isolation of areas where dust, inclement weather, or other conditions exists that may affect the quality of work being performed." The housekeeping checklist also has specific electrical check items such as "there is no accumulation of foreign materials around the exterior of electrical boards and panels."
l D.
Interviews with Electrical Maintenance Section personnel revealed they do not feel dust or metal grindings in the electrical control cabinets to be a problem. The interviews revealed the Maintenance and Modification personnel were very much aware of the need for maintaining cleanliness of these cabinets.
Conclusions BFN does not have a problem with dust or metal grindings contaminating the electrical control cabinets. There are procedures in place at BFN to prevent this from becoming a problem.
v-l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM i
REVISION NUMBER:
3 PAGE 29 0F 40 4.0 FINDINGS (continued) 4.6 Water Standina in Cable Trays Water standing in cable trays was considered to be a site-specific concern for Bellefonte Nuclear Plant (BLN). Reference section 3.0 above, for general evaluation approach.
A.
Visual inspection of surveyed areas produced no cable trays of either the ladder rung or solid bottom type with water standing in them. Visual inspection of an Essential Raw Cooling Water System (ERCW) hand-hole revealed that the cable l
was covered with a mud slurry and cable tray hangers were coated j
with areas of surface rust, but no evidence of rust or lR3 deterioration of the cable tray and/or cable tray hardware was l
apparent. Water standing in aanholes has been identified as a l
generic problem at all sites. This problem is being addressed by Operations in the Cable and Conduit Subcategory.
B.
Housekeeping procedure BNP-QCP-10.77. RIO - section 4.1 defines cleanliness and section 6.1.2.4 addresses the f act that during all housekeeping tours specific observations are made where cable trays are. involved by stating, " Ensures that during housekeeping tours specific observations are made where cable trays are installed that they do not contain tools, debris, or employees."
l l
Cable tray installation procedure BNP-QCP3.3, R13 -
l Section 6.1.2.1 states,"
..also is free of other structural defects that would effect the life or structural integrity of the tray."
C.
Electrical engineers and QC personnel stated that BLN class 1E cable is not designed to be submersible however, the sheathing is designed to repel moisture. The galvanized trays and related hardware are not rustproof but rust inhibitive. Solid bottom trays are presently installed only inside dried in structures and are not installed in areas of element exposure. Solid bottom trays are not designed to be watertight.
Conclusion l
Since the concerned individual (CI) stated water was standina in cable trays, the assumption can be made that the concern did not involve ladder rung type cable trays since they will not hold l
water. The solid bottom type trays are not designed to be I
watertight and are presently only installed in dried in buildings.
Taking into consideration that the CI specified no date or location.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 30 0F 40 Conclusion the tray in the concern could have been installed before the installation of building roofs was completed.
If it was during the timeframe before the roof was installed, water could have been found i
during cable installation. Although buildings are presently dried-in, there are ongoing construction activities such as flushing, and hydros, especially of the RF (fire protection) systems, which could potentially spray water into the cable trays.
This potential will continue to exist.
The cable sheathing of class 1E cable is not designed to be submersible but is moisture resistant. Water poses a hazard from an operational standpoint and could provide an industrial safety bazard should there be a tear and/or cut in the cable sheathing.
The fact that EQC inspects cable trays before the installation of cable, especially for structural defects and the galvanized finish, (see QCP 3.3, R13, section 6.1.2.1), ensures at one point the condition of the tray. The observation of one ERCW electrical hand-hole showed the cable to be covered with mud slurry and visible rust deterioration to the cable tray hangers, but there was no visible deterioration to the cable tray or installation hardware.
Water in manholes continues to be a problem where the water level
)
reaches the cable trays.
The inhouse procedures governing housekeeping and installation g
monitor continuously the installed trays for elements that could q
damage cable except in manholes. QC has the opportunity to identify any tray containing water and/or uncover any evidence indicating that water had been present and to correct any problems areas.
l 4.7 Debris in cable Trays Debris in esble trays was considered to be a site-specific concern for BLN. Visual inspection of cable trays was done in conjunction with the element report concerning water standing in cable trays (see section 4.6).
A.
Visual inspections of surveyed areas produced no cable trays containing dirt or debris.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 31 0F 40 l
l 4.0 FINDINGS (continued)
B.
Reviewing related governing procedures revealed that BNP-QCP-10.27. R10 " Housekeeping," defines cleanness in section 4.1 and in section 6.1.2.4 which address the fact that during i
all housekeeping tours, specific observations are made where cable trays are installed that they do not contain tools, debris, or employees. Also, BNP-QCP-3.3, R13 " Cable Tr y " in the part pertaining to acceptance criteria Section 7.1.2.4, "the tray shall be free of debris and any foreign material." The verification record card denotes the area in which the inspector is to sign and date signifying that the initial inspection complies with section 7.1.2.4.
Also, section 7.3.1 pertains to cable tray cover verification, " Cable tray installation is l
complete and tray is free of debris and any foreign material."
l The inspector must signify the tray is free of debris and foreign material by signing the Cable Tray Verification Test 31 attachment.
C.
QA Deviation Report No. BL-S-5-434-D-01-Bellefonte Nuclear Plant revealed that Bellefonte had been cited by DNQA because foreign material and debris had been discovered laying on cables in cable trays. NRC-Report Nos. 50-438/85-06 and 50-439/85-06 revealed that Bellefonte had been cited by the Nuclear i
Regulatory Commission resulting in one violation, " Failure to
]
accomplish adequate housekeeping on cable, trays " in which 1
foreign materials and debris were discovered laying on cables in l
cable trays.
1 i
Conclusions I
Through visual inspection of random cable trays it was determined l
that no trays were found to contain employees, tools, materials or i
debris. The safeguards in the procedures concerning housekeeping l
and installation provide a monitoring device which continually monitors keeping employees, tools, materials and debris out of cable trays and off of cables. Plant management has placed 4-feet I 8-feet signs at the main entrances to the powerhouse buildings as a continuous reminder to engineers, inspectors, and craftsmen entering the buildings to keep everything except cables out of cable trays.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500-SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 32 0F 40 4.0 FINDINGS (continued) 4.8 Equipment components installed in an underground water source BLN concern II-85-060-001 is the.only concern associated with the rust of equipment components.
It does not address a specific. type, location, or elevation of the alleged rusted equipment components.
q l
This concern is vague and encompasses such a broad spectrum that an attempt to evaluate this concern without more pertinent information
'l concerning the type of equipment. location, or elevation of said equipment would be futile.
5.0 COLLECTIVE SIGNIFICANCE The concerns addressed by this subcategory reflect conditions which are expected to exist for the duration of the construction phase at WBN and BLN and to a lesser extent at the licensed plants. Safety-related features have been included in all sites' Preventive Maintenance and Housekeeping programs. Construction management has been increasingly effective at all sites by standardizing specific protection and inspection requirements for safety-related equipment. A notable exception to this increased participation of the Preventive Maintenance Groups in recognizing and correcting deficiencies are the findings addressing. ster in manholes which potentially damage equipment and cables. The issue of indeterminate maintenance status of system 31 instruments is an example of an assumed risk policy adopted by DNC management. Protection devices are provided in high risk areas and loss of instrumentation through construction damage and vandalism has been maintained at an acceptable level. The Employee Involvement Program and the ONP Maintenance Request program are viable solutions for most problems encountered from day-to-day, but as noted in the INPO findings pubilshed in 1985 optimum plant performance requires a comprehensive preventive maintenance program.
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e TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 33 0F 40 6.0 CAUSES The following is a summary of the causes of those findings which require corrective actions:
6.1 Caulking 6.1.1 Generic No generic causes were determined 6.1.2 Site Specific 6.1.2.1 WBN The deteriorated caulking condition is a result of i
the use of improper material and insufficient periodic inspections. Design review coordination between the cognizant feature engineer and the materials application groups did not occur for the implementation of the FCR that added caulking requirements to the TVA drawing 10W331-16. Rev. 2.
Routine periodic inspections for deterioration of nonnuclear safety-related civil features are not currently called for in maintenance procedures.
6.1.2.2 SQN l
No cause assigned. Cault has not been used to seal the lift eye bolt recesses in the ADGB missile l
shields.
6.2 Instruments 6.2.1 Generic No generic causes were determined.
6.2.2 Site Specific - WBN 1
No specific cause for the concern was determined from the evaluation.
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j TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 34 0F 40 6.0 CAUSES (continued) 6.3 Instrument Air Piping 6.3.1 Generic No generic causes were determined 6.3.2 Site Specific - WBN Hydrotesting the air line and leaving it in a wet layup configuration caused the rust problem.
Followup test procedures identitled the problem. An ECN resulting from an
{
NCR abandoned the rusty pipe and provided a new instrument I
air supply line.
o.4 Conduit 6.4.1 Generic j
Exposed thread rust on conduit fittings was deemed a generic type concern for SQN, WBN, and BLN. Surface rust was noted in areas of extreme element exposure, but required no equipment modification or replacements at this time. In the
{
powerhouse areas curveye.d at each site, minor evidence of j
conduit fitting rust was apparent. Thread lubricants such as "Kope Shield " as used in conduit connections, do appear to be rust, at first glance, when light coats of dust are present.
6.4.2 Site Specific - SQN Conduit surveyed in the area described in concern 00-85-5-010 displayed only minor surface rust which required no corrective action. No specific cause for the concern was assigned.
6.5 Electrical Control Cabinets 6.5.1 Generic Dust and/or metal particles inside electrical control cabinets is an ongoing concern. The design of the control cabinets perpetuates the problem throughout the construction phase. Preventive maintenance, housekeeping and work control procedures adeguately address the problem and preclude any i
instance where enough dust and/or metal particles could amass and cause equipment failure.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER: 3 FAGE 35 0F 40 6.0 CAUSES (continued) 6.5.2 Site-Specific-WBN The ventilation system in the Diesel Generator Rooms actually forces room air into the field flash and voltage regulator control cabinets. Permanent filtration systems are not installed on the cabinets to prevent dust and other airborne particles from entering the cabinets. Temporary filters are in place at this point in time and a permanent filtering system is being designed.
6.6 Water Standinr. in Cable Travs 6.6.1 G6neric No generic cause was assigned 6.6.2 Site-Specific - BLN Any of the following could have resulted in this concern:
a.
The CI observed cable tray installation during a period of time before the buildings were dried-in when rain could filter down through elevations and could be in trays.
l b.
The CI observed an incident where during a flush or hydro of piping or tubing systems, water leaked into a cable
- tray, The concern could have referred to cable trays in c.
manholes, in which case, the following causes should be considered:
l 1.
Manhole covers are installed below grade.
2.
Underground conduit fills with water and empties into
)
the manholes.
3.
Sump pumps installed in manholes are often inoperable.
4.
Inadequate design considerations for water removal from manholes.
5.
Poor housekeeping and/or preventive maintenance programs for addressing recurring problems.
l 6.
Management inattentiveness to trends of.having to I
pump water out of the manholes prior to performing work.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 i
PAGE 36 0F 40 6.0 CAUSES (continued) 6.7 Debris in Cable Trsys 6.7.1 Generic No generic cause was determined 6.7.2 Site-Specific - BLN l
l Either of the following could have resulted in this concern:
l a.
The CI observed an empty cable tray which contained debris before being inspected. This has existed in the
- past, b.
The CI observed an isolated incident of employees, tools, materials or debris being in a cable tray.
6.8 Equipment Components Installed In An Underground Water Source 6.8.1 Generic i
l No generic causes were determined l
l
)
6.8.2 Site Specific - BLN i
1 l
The K-form information is not specific enough to evaluate the l
concern and determine a cause. The CI indicated that any I
further information would compromise their confidentiality.
l 7.0 CORRECTIVE ACTION l
l 7.1 Caulking I
7.1.1 Generic No generic corrective actions.have been addressed.
7.1.2 Site Specific 7.1.2.1 WBN An FCR is to be initiated by WBN Mechanical Maintenance to modify the note on TVA drawing l
10W331-16 to eliminate the requirement to " fill the I
recess with caulk." Mechanical Maintenance will leave the cault as it presently is and make routine inspections at times when the shields are removed for other normal activities to determine when the rusted lift eye bolts require replacement. The o
a TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 37 0F 40 1
7.0 CORRECTIVE ACTION (continued) cault will be removed by mechanical maintenance as deemed necessary or a more suitable water resistant material will be used in its place.
(CATD 10500-WBN-01)
Future missile shield designs should avoid water traps and/or use more suitable materials for this type application. Also, minor design changes should be evaluated more thoroughly for the need to involve other cognizant design groups, such as when making material selections.
WBN Line Management provided the following as a Corrective Action Plan for CATD 10500-WBN-01: TVA
.drawine i nut 11_1 A no unis k*
--- a ed :: f:::: :
7 Ffy r
1.
g p
ulring
)
l cap i
Nr q es of the
]
tcp 1
at i
openi prevent colle gg,.
rec
- l. Requi licatio of etl
- ing in accordance with e n s e i n e_
eveta. unuo u nnq.
allow the lif ting eye bars to inhibit rust and deterioration.
l Plant instructions should be improved to better address periodic inspections of missile shields and other civil features such as caulking and lift eye bolts to detect deteriorated conditions requiring replacement or maintenance. These inspections are l
needed in both Construction and ONP preventative maintenance procedures.
(CATD 10500-WBN-02) k WBN Line Management provided the following as a cnerarti--
a-*t--
als: f;; 0;T; ;;,;u..on-vt; no i d on how h.t t
i progr
).
Any de nt condit. on Edentif eMR pr r-p^I".__
^
am, ith i fective design
'a---^
..r nodiriratiaa e---
r::::: Oj.....
go,6.
v.
2 an d aa 2."
7.1.2.2 SQN SQN should follow the guidelines established by WBN I
by initiating an FCR to eliminate the requirement to fill the recesses with cault.
(CATD 10500-SQN-01) l l
\\
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 38 0F 40 i
i 7.0 CORRECTIVE ACTION (continued)
SQN Line Management provided the following as a corre m w,. C -.. _"'-- fae PATD 10500-SQN-01: Since 1
r 21 If t dition becom Po )
t Sequoya 1, reps be init e_d ac g g e with t ie I
f exis t---"a
o c E/
O/
7.2 Instruments - WBN 4
No corrective actions are required because of this concern.
7.3 Instrument Air Piping - WBN WBN NCR 4386 and ECN 3740 were initiated to evaluate and disposition this air line problem. The ECN removed from use and capped the rusted air line and an alternate air supply was established The changes made were determined to be acceptable and meet prescribed requirements. No further corrective actions are required.
7.4 Conduit l
7.4.1 Generic - SQN, WBN, and BLN A.
Plant Management of both OC and ONP should encourage employee involvement and feedback in reporting deterioration of plant features observed during their day-to-day work ectivities during their weekly Employee Involvement meetings.
(CATD 10500-NPS-02)
B.
A statement should be added to governing procedures requiring conduit thread compound as designated in G-40 section 3.2.4.2 and inspect the compound on a survelliance basis during other inspections.
Co....':: ::-- --avidad for CATD 10500-NPS-02 is as t
n and identarical.lon is
. foljp
{ dig l) i I
ters of GI S G-40 sect;,ons a
e procedu es TN :eflATEtRM7E191""*
1 l
o w
l TVA EMPLOYEE CONCERNS REPORI NUMBER:
10500 SPECIAL PROGRAM l
REVISION NUMBER: 3 PAGE 39 0F 40 7.0 CORRECTIVE ACTION (continued) l l
7.5 Electrical Control Cabinets 1
7.5.1 Generic - All Plants l
l A.
Enhancement of employee awareness in conjunction with I
their day-to-day work activities together with l
management's encouragement of active participation in l
Employee Involvement meetings to report lack of cleanliness of plant facilities will aid in improving the f
overall cleanliness of electrical control cabinets.
I B.
Standardize requirements of similar equipment to the same I
degree of cleanliness for each plant and to establish l
standard inspection frequencies for electrical I
equipment.
(CATD 10500-NPS-01)
,_The corrective action for CATD 10500-NPS-01 is as i
L 'o1 s: The ap )ro r a aT.e preveuu re...-...n Lve i
d L
al ot L
cabine renc Q tand d racti
-66. 4.06 and 4.07 f br WBf KI~-
6-sn
.2; for BLN l
BNP-0C "onr-sr-a.a, L LQCT..., ~ ^ hr BFN Standard Practice M -4.4.
7.5.2 Site-Specific - WBN Install room and cabinet air filters to control airborne contaminants in the DGB.
Reference Operations Element Report 301.02. " Diesel Generator Reliability Problems." for further i
details and CATDs 301.02-VBN-01 and 301.02-WBN-04 for IR3 corrective measures necessary to address the identified l
problems.
I 7.6 Water Standinr. In Cable Trays 7.6.1 Generic - All Plants Manhole inspection requirements should be incorporated into the housekeeping and preventative maintenance programs.
Reference Operations Subcategory Report for Cable and Conduit.
7.6.2 Site-Specific - BLN Add to the housekeeping procedure, the requirement to inspect for water or visible moisture in the solid botton cable trays during their monthly inspection tours.
(CATD 10500-BLN-01) 1 I
l l
1 w
o TVA EMPLOYEE CONCERNS REPORT NUMBER:
10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 40 0F 40 7.0 CORRECTIVE ACTION (continued)
BLN Line Management provided the following as corrective action for CATD 10500-BLN-01*
""O i... uictated revision j
ren"^-t,.._..s one-11.
(
p ng proced are, j
BNI' 23 1
C nding wat er in call oms not tra ed to plant
{rsne o plunt opa r
- ons, as ancev7st operations fing idisEc
^'
.us nousatkeeping Che pklist,"
m."u 6 e or ML^
n...
1 ot the checklist req de--
!:.r. waon Ior any leaks or accumulation of water to be reported to plant maintenance.
7.7 Debric in Cable Trays 7.7.1 Generic No corrective action required 7.7.2 Site-Specific - BLN No corrective action required. Procedures governing housekeeping and cable trays are specific about maintaining cleanliness.
7.8 Equipment Components in Underground Water Source 7.8.1 Generic No corrective action requirec' 7.8.2 Site Specific - BLN No corrective action can be assigned until enough information is obtained to enable ECTG to investigate and evaluate the concern.
8.0 ATTACHMENTS 8.1 Attachment A - Listing of Concerns Indicating Safety Relationship and Generic Appilcability 8.2 Attachment B - List of Evaluators 8.3 Attachment C - List of Concerns by Issue
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- 1 TVA EMPLOYEE CONCERNS REPORT N'JHBER: 10500 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 1 0F 1 Attachment B List of Evalustors idBN Gerald L. Baker Charles Manning i
BLN Jim Henard BFN Guy Huff SON Guy Huff l
i l
l 1
l
v e
o e v
TVA EMPLOYEE CONCERNS REPORT NUMBER: 10500 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 1 0F 1 ATTACHMENT C l
List of Concerns by Issue Issue Concerns
- 1. 2.1, Caulking IN-85-231-003 1.2.2 Instruments IN-85-962-002 l
1.2.3 Rusted Instrument / Air Lines IN-86-205-003 1.2.4 Rusted Conduit 00-85-005-010 1.2.5 Contaminated Electrical OW-85-007-010 Control Cabinets IN-85-685-002 1.2.6 Water Standing in Cable Trays QCP 10.35-8-10 3.2.7 Debris in Cable Trays QCP 10.35-8-12 1.2.8 Equipment Installed in Underground Water Source XX-85-060-001 l
)
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l
_ _ _ _ _ _ _ _ _ _ _ _. _ _ _. _. - -