ML20235G012
| ML20235G012 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/23/1987 |
| From: | Conlon T, Fillion P, Mcelhinney T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235F975 | List: |
| References | |
| 50-338-87-26, 50-339-87-25, NUDOCS 8709290405 | |
| Download: ML20235G012 (9) | |
See also: IR 05000338/1987026
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ll
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101 M ARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-338/87-26 and 50-339/87-25
Licensee: Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos.:
50-338 and 50-339
License Nos.:
Facility Name:
North Anna 1 and 2
Inspection Conducted: August 17-21, 1987
Inspectors:
9-23-/7
,
P.JyFillion
Date Signed
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T. F. McElhinney
Date Signed
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Approved by: C
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T. E. Conlon, Chier
Date Signed ~
Plant Systems Section
Division of Reactor Safety
SUMMARY
Scone:
This routine, announced inspection was in the areas of resolving open
items and addressing worker concerns conveyed to the NRC.
Results:
One violation was identified, Failure to Generate a Nonconfermance
Report for Nonconforming Equipment.
8709290405 070923
ADDCK 05000338
G
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- G. Kane, Assistant Station Manager for Operations
- T. Abercrombie, Electrical Lead Engineer, SE0
- G. Harkness, Licensing Coordinator
C. A. Zalesiak, Civil /EM Lead Engineer, SE0
R. Jones, Supervisor of Quality, 0&M Inspection
R. E. Sidle, Supervisor of Maintenance Activities
M. L. Bowling, Assistant Station Manager
B. C. Davis, Senior Construction Specialist
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Other licensee employees contacted included construction craftsmen,
engineers, technicians, and operators.
NRC Resident Inspector
- J. Caldwell
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on August 21, 1987, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
The following new
item was identified during this inspection:
Violation 338/87-26-01, Failure to Generate a Nonconformance Report
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for Nonconforming Equipment, paragraphs 5.d and 5.e.
The licensee did identify some material as proprietary during this
inspection, but this material is not included in this inspection report.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation 50-338, 339/85-11-01, Inadequate Review of Reactor Trip
Breaker Maintenance Procedures.
The licensee transmitted his response to
this violation in a letter, dated June 18, 1985.
By a letter, dated
July 25, 1985, the NRC acknowledged the licensee's response and accepted
the determination of root cause and corrective action.
The inspector
reviewed procedures EMP-P-EP-8 and 8A which were updated August 29, 1985.
The changes made in this revision corrected the deficiencies described in
Report 85-11.
The inspector also reviewed the current revision of
EMP-P-EP-8, dated April 15, 1987, and found the procedure to be
administrative 1y adequate.
Procedure EMP-P-EP-8A has been deleted.
The
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inspector also reviewed a memorandum from the station manager to
supervisors and procedure writers, dated August 30, 1985, on the
importance of reviewing procedures for technical and administrative
accuracy.
The inspector determined that the corrective actions outlined
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by the licensee in his response to this violation have been implemented,
and, therefore, open item 338, 339/85-11-01 is closed.
4.
Unresolved Items were not discussed during this inspection.
5.
Employee Concerns
A former electrical craftsperson expressed safety concerns in early 1985
to the NRC investigative staff in Atlanta, Georgia.
Several of these
concerns were addressed during the inspection.
The NRC's evaluation and
conclusions are described in this section,
a.
A former electrical craftsperson told the NRC he or she knew, in at
least two instances, that quality assurance acceptance tags were not
attached to boxes of miscellaneous electrical equipment such as
terminal lugs that were installed in safety-related systems.
The NRC
inspector began his evaluation of this allegation by interviewing
personnel who inspect equipment as it is received at the site and
reviewing the relevant procedures.
This investigation revealed the
following procedures and practices to be in effect at the site now
and probably were in effect since 1978:
(1) Quality control acceptance tags, either stick-on or tie-wrap
type, are affixed to material that is accepted for storage or
use upon receipt at the site.
(2) A permanent marking is made of the purchase order number, safety
classification and stock number.
The purpose of the permanent
marking is to provide traceability should the quality control
acceptance tag be lost.
(3) Miscellaneous items such as terminal lugs are all treated as
safety-related items, even though a portion of the stock may
ultimately be used in a nonsafety-related application.
The NRC inspector went to the warehouse and inspected several samples
of boxes of terminal lugs.
Receipt dates were in 1984 and 1987.
Each box had the permanent marking and QC acceptance tag.
It is impossible to independently determine whether or not a box of
miscellaneous items was issued from the warehouse without the proper
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tags and markings in the past.
The safety significance of the
particular allegation is small because the quality control inspection
for a miscellaneous item merely confirms the catalogue number on the
box matches that in the purchase order.
Such L check should have
been made at least three times in the receipt and installation
process:
upon receipt at the warehouse; at the cuality control
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inspection; and at installation.
In summary, the particular
allegation referred to something that happened in the past that is
impossible to. verify now, implications of the allegation are of low
significance and implementation of procedures appears to be in effect
today.
The NRC does not plan any further investigation of this
matter.
b.
A former electrical craftsperson told the NRC that, in his or her
opinion, a group of engineers who worked at the site under a contract
between the licensce and a major engineering firm were "not very
good".
The NRC inspector randomly selected several engineers from
the particular group and reviewed their qualification statements.
The educational background and work experience of the selected
individuals met or exceeded the licensee's criteria for technical
support personnel.
The NRC inspector was satisfied that there is no
real substance to this allegation, and therefore, this item is
closed.
c.
A former electrical craftsperson told the NRC that occasionally
welding work was carried out in the plant without a firewatch and the
firewatch did not always remain at his post for a period of thirty
minutes after welding ceased (as specified in the procedures) at the
end of the work day. The NRC inspector confirmed that plant specific
procedures clearly call for posting a firewatch whenever hotwork is
carried out in the plant.
Administrative Procedure ADM 20.23, dated
March 31, 1983, refers to the Fire Protection Plan which, in turn,
requires that a Flame- Permit be obtained for hotwork in the plant.
The flame permit has the following signature block, " Work area and
all adjacent areas inspected 1/2 hour after work completed and found
fire safe."
It may be signed by the firewatch, responsible foreman,
or supervisor.
Also, the work order forms indicate whether or not a
firewatch is required for a particular task.
Welding work may be
performed by either the Plant Maintenance Department . or the
Engineering and Construction Department.
The NRC inspector
questioned both the supervisory and craft personnel about firewatch
activities.
Each person interviewed emphatically stated that
firewatches were always posted when required. They also stated that
it is regular procedure for welding work to cease 1/2 hour before
lunch time and 40 minutes before end-of-day to allow for cleanup and
the required firewatch time (1/2 hour).
Two of the persons
interviewed stated that they had been at the site since 1973 and the
above procedures and practice had always been in effect.
They also stated that they could not remember any occasion when a
fire was started due to welding work or other hotwork.
In summary,
the NRC inspector did not find that NRC requirements were v'olated or
are being violated with respect to the posting of firewatches.
The
practice of stopping welding work thirty to forty minutes before
end-of-day contradicts part of the allegation. This item is closed.
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d.
A former electrical craftsperson told .the NRC that he or she was
concerned about the quality of terminations at the plant.
In order
to address this safety concern, the NRC inspector selected a sample
of terminations for inspection.
Terminations inspected are itemized
in Table 5.D.
TABLE 5.D
Equipment
Equipment
Termination
Identification
Description
Type
1-EI-CB-05
One section of the main
Control
control panel (two terminal
strips inspected)
15H2(1)
4160V switchgear
Control and power
compartment for
emergency generator
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MCC1H1-1/C3(1)
Motor control center
Control and power
compartment for
MOV-SD-1008
1-EI-CB-54(1)
Protection Channel 4
Instrumentation
(yellow) Primary Plant
Process
1-EI-CB-53(1)
Protection Channel 3
Instrumentation
(blue)
NOTE (1): All field wiring terminals inspected.
Approximately 400 control and instrumentation terminal points were
inspected for the following attributes:
(1) Different size wire had different size lugs.
(2) When two wires were terminated on the same point, lugs were
back-to-back with washer in between to aake a good connection.
(3) Wires could be seen in lug inspection hole indicating that wires
were fully inserted into barrel.
(4) Crimp faced outboard and appeared proper.
The 4160V emergency generator leads were inspected at their
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connection point to Bus H2.
This was a taped termination with two
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conductors per phase.
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The terminations inspected were properly. made except for one lug that
was either broken before installation or improperly crimped. ' This
one wire is at 1-EI-CB-05, first section on left as viewed from rear,
terminal strip TA point '73.
Whereas the allegation was assumed to
refer to the manner in' which terminations were made during the
original-installations.or subsequent modifications, the evidence did
not support the claims.
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The individual also mentioned an NRC inspector had " written up" a
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problem involving terminations.
The complete list of open items for
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North Anna was checked, but no item involving terminations was found.
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However, while' inspecting the sample of terminations as described
above, three terminal points were found to be damaged.
The damage
. was obviously caused by a short-circuit.
The snort-circuit had
apparently been caused by a tool inadvertently being placed across
two or more lugs.
The three damaged terminals were at 1-EI-CB-05,
first section on the left as viewed from the rear, terminal strip TA
points 67, 68 and 69. The damage. consisted of melted lugs and burned
insulation. The wires on points 67 and 68 are in the main steam line
trip valve'TV-MS101A control circuit, which is safety-related 125VDC.
The circuit was functioning properly.
Since the circuit is fairly
complex, the effects of possible eventual failure modes such as an
open wire or high resistance connection could not be positively
determined during the inspection.
The inspector showed the damaged
terminals to several members of the plant staff.
A work order
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(No. 453423) was issued during the week of the inspection to repair
the tenninals.
The wire on terminal 69 is in a nonsafety related circuit.
The terminal lugs at terminals points TA-67 and 68 (cable
nos. IMSSAPC315 and IMSS3PK001) in I-EI-CB-05, the main control
panel, are safety-related and were. significantly damaged by a
.short-circuit occurring in the past.
The individual who
inadvertently caused the short-circuit must have known that damage
had occurred, but that person did not report the damage'nor cause it
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to be repaired.
This constitutes a violation of NRC requirements to
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identify and repair any conditions adverse to quality.
This matter
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is an example of Violation 338/87-26-01, Failure to Generate a
Noncenformance Report for Nonconforming Equipment.
e.
A former electrical craftsperson told the NRC that he or she knew of
one instance when the structural steel of an instrumentation rack was
ground down without proper authorization.
He or she said this
instrumentation rack was located behind the Unit 1 main control
panel.
He or she also said that instrumentation racks 1-EI-CB-301A,
B, C and 2-EI-CB-301A, B, C were modified by tapping holes without
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authorization.
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The latter of the above statements was address'ed by the NRC first.
The tapping of new bolt holes in a structure such as the racks in
question is normally an allowable field modification (i.e., without
specific approval).
The drilling of a few small holes does not
affect the structural integrity of a structure.
Therefore, the
worker's concern with regard to the drilling of holes in the
instrument rack does not indicate that any NRC regulations or
licensee's commitments were violated.
With respect to the former statement, evidence indicates that the
following events took place.
Multiplexer support rack 1-EI-CB-300
was fabricated in the site shop as part of Design Change 81-S20A,
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NUREG-0696, Short Term I&C Project - Remote Multiplexer Installation.
After the rack was built, it was found that the power supply cabinet
did not fit into the rack because the rack was slightly too narrow.
Workers began to grind down the four vertical members, which are 4" x
4" x 3/16" weight tube steel, in order to allow insertion of the
power supply cabinet in the rack.
After some grinding was completed,
orders were given to stop the grinding work.
Then Field Change (FC)
No. 42 was prepared to change the original arrangement of cabinets in
1-EI-CB-300 and other racks.
The final arrangement has the power
supplies mounted outside the rack.
No grinding was done on the
corresponding Unit 2 rack because FC No. 42 had changed the
arrangement before any grinding had started or before the rack was
fabricated.
Unit 2's rack is the same dimension as Unit l's.
1-EI-CB-300 was put in place behind the main control panel about
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July 1983 and the multiplexer were installed about April 1984.
Whereas the licensee could not find any documentation which approved
the grinding work or evaluated the effect of reducing the tube steel
thickness, NRC requirements were violated. The rack is classified as
safety-related by the licensee and is required to be seismically
designed because it is located adjacent to the main control panel.
During the inspection, the licensee presented the NRC inspector with
a calculation which showed the rack in question to be seismically
qualified as installed.
The calculation modelled the vertical
members as U-shaped steel.
This was done for simplicity and
uncertainty about the amount of metal removed by grinding.
The NRC
accepted the calculations as being correct.
Quality control inspections of the instrumentation rack would not
have been expected to detect that the steel had been ground down.
This matter is an example of Violation 338/87-26-01, Failure to
Generate a Nonconformance Report for Nonconforming Equipment.
f.
A former electrical craftsperson expressed concern a' bout possible
violations of the electrical separation criteria at the main control
panels.
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Specification NAS-3012, Criteria Specification for Design and
Identification of Electrical Cable Systems for North Anna Power
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Station Units 1 and 2 SR/NSR,. dated April 9,1987, covers electrical
separation criteris
Basically, the specification calls for a
separation of six inches between wires of redundant systems within a
control panel and allows neutral wires to be routed with one, and
only one, group of redundant cables.
The main control' panels are
laid out such that individual sections are assigned to a particular
train; thus, allowing . the required six inch separation to be
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maintained.
In some cases, all four channels of the Reactor.
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Protection Systems are in the same section of the control panel.
However, whenever this is necessary, such cables and devices are
protected by metal barriers or metallic , flexible conduit. Depending
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on factors such as voltage level and power limitations, separation
distances of less than six inches may be acceptable.
Walkdowns by
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the NRC inspector .did not reveal any examples of violations of the
electrical separation criteria.
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g.
A former electrical craftsperson alleged that during the' 1984 Unit 1
outage, conduits were damaged by the polar crane trolley and that the
damage was not properly evaluated.
The inspector reviewed the
licensee's logbook of Nonconformance Reports (NCR) to determine
whether or not any NCRs had been generated in 1984 related to this
concern.
NCR 84-209, dated July 23, 1984, states in part, that the
polar crane struck conduits and an instrumentation line support
during the Unit i refueling outage.
The damaged - equipment was
classified nonsafety-related.
Final ~ disposition of NCR 84-209 was
made on August 4, 1987.
Apparently, unbeknownst to the alleger, the
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damage he was concerned about' had been reported and corrected.
h.
The eighth and final safety concern investigated during this
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inspection involved possible damage to cables in the emergency
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switchgear room.
The person alleged that covers were missing from
cable trays in the emergency switchgear rooms while welding work was
in progress.
As a result, cables may have been damaged.
(The
allegation implies that no other form of protection was used in lieu
of the covers.)
In order to followup on this concern, the inspector
walked down the cable trays in the emergency switchgear room. Cables
inside the following cable tray sections were inspected:
1TC035P
1TC0320
1TK008P
1TC036P
1TC0360
1TK009P
1TC037P
1TC0370
1TK0990
1TC0300
1TC0410
1TL0020
1TC0310
1TK006P
ITL0030
Unit 2 Emergency Switchgear Room
2TC0260
2TC027P
2TL0020
2TC0340
2TC028P
2TK006P
2TC0350
2TK0080
2TK011P
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' Inspection of_ .the cables . in these safety-related trays included
-looking.for arc, strikes on the cables, weld splatter, bent trays or-
tray covers impacting on cables, and debris in the trays.
The
inspector did not identify any indication of damaged cable due to
welding activities'in the: Emergency Switchgear Rooms for Units 1 and
2.
The inspector, however, did notice a corrugated cable tray cover
for tray 1TC0366 was damaged. The cover appeared to have been walked
on,_ which bent the cover onto the cables.
The. licensee removed the
damaged cover and the cables were visually inspected for damage.
This examination verified that no damage was done to the cables by
the bent tray cover.
The damaged cover was repaired and replaced.
The licensee informed the inspectors that the cable tray cover was
not required for safety train separation purposes, but is used. to
prevent _' debris from entering the tray.
The inspector also reviewed
the velding and flame permit which is required to be initiated per
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MMP-C-W-1 Mechanical ' Maintenance Procedure for Welding on
Sa fety-Related Equipment.
This permit requires covers to be
suspended beneath work to collect sparks prior to starting work. The-
inspectors- also reviewed the NCR logbooks for the 1981 - 1985 time
period looking for NCRs involving damage to equipment from welding
sparks, etc.
NCR 85-10, dated January 14, 1985, documented such a
case.
Three conduits were damaged by arc strikes and weld splatter.
As a result of this NCR, a memorandum was distributed to construction
personnel on January 25, 1985, to reemphasize the importance of
protecting equipment and piping during welding operations.
The
memorandum also states that Refrasil is available in the electrode
issue station and should be used to protect equipment and piping,
etc., against arc strikes. and splatter.
As a result of this
investigation, the inspectors were unable to substantiate the
employee's concern.
It is apparent that the licensee has adequate
controls in place to protect equipment from weld splatter and arc
strikes.
6.
Open Items
Two open items related to the reactor trip breaker inspection, generic
letter 83-28, were resolved.
(Closed) IFI 338, 339/85-11-05, Work Order Processing.
Review of
Administrative Procedure ADM 16.7, Corrective Work Orders, dated July 9,
1987, indicated that the licensee has revised this procedure to include a
flowpath for work orders and instructions covering the use of any
procedures listed on work orders.
The inspector had no further questions
regarding this matter and this item is closed.
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(Closed) IFI 338, 339/85-11-06, Review Changes in Administrative Procedure
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ADM 16.5 for Processing Emergency Work Orders. The inspector reviewed the
procedure, which was revised on May 16, 1985, and found it now includes
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instructions for generating an Equipment History Form for each Emergency
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Work Order. This item is closed.
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