ML20235G012

Insp Repts 50-338/87-26 & 50-339/87-25 on 870817-21. Violation Noted.Major Areas Inspected:Resolving Open Items & Addressing Worker Concerns Conveyed to NRC

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: ML20235F973 ML20235F992 ML20235G012
References
50-338-87-26, 50-339-87-25, NUDOCS 8709290405
Download: ML20235G012 (9)

See also: IR 05000338/1987026

Text

ggB REco UNITED STATES

g 'o

NUCLEAR REGULATORY COMMISSION

y n REGION ll

y j 101 M ARIETTA STREET, N.W.

• 's ATLANTA, GEORGI A 30323

s...../

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.: NPF-4 and NPF-7

Facility Name: North Anna 1 and 2

Inspection Conducted: August 17-21, 1987

Inspectors: 9-23-/7 ,

P.JyFillion Date Signed

V- / 7"27

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._ Mt 7U  %

"

T. F. McElhinney Date Signed

Approved by: C /_ M4 pe/ 7-/7-f7

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

PDR ADDCK 05000338

G PDR

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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

Other licensee employees contacted included construction craftsmen, i

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

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 4

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 i

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 ,

connection point to Bus H2. This was a taped termination with two i

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.

[

The individual also mentioned an NRC inspector had " written up" a j

problem involving terminations. The complete list of open items for i

North Anna was checked, but no item involving terminations was found.

However, while' inspecting the sample of terminations as described

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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 '>

(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 j

to be repaired. This constitutes a violation of NRC requirements to 1

identify and repair any conditions adverse to quality. This matter i

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 i

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, 3

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 l

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

l 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 ,

maintained. In some cases, all four channels of the Reactor. j

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

j the NRC inspector .did not reveal any examples of violations of the

electrical separation criteria.

g. A former electrical craftsperson alleged that during the' 1984 Unit 1

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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

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made on August 4, 1987. Apparently, unbeknownst to the alleger, the

l damage he was concerned about' had been reported and corrected.

h. The eighth and final safety concern investigated during this 1

inspection involved possible damage to cables in the emergency i

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

ADM 16.5 for Processing Emergency Work Orders. The inspector reviewed the  !

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' procedure, which was revised on May 16, 1985, and found it now includes

instructions for generating an Equipment History Form for each Emergency

l Work Order. This item is closed.

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