Rev 3 to 'Electrical Equipment,' TVA employee concerns ... · FRONT MATTER REV: 2 PAGE i OF viii Preface ... (ONP) employee concerns filed before February 1, 1986.. Concerns filed

TVA EMPLOYEE CONCERNSSPECIAL PROGRAM

REPORT TYPE: Subcategory - Construction

TITLE: Electrical Equipment

REPORT NUMBER: 19100

REVISION NUMBER: 3

PAGE 1 OF 24

REASON FOR REVISION:

Incorporate SRP comments Revision 1

Incorporate SRP comments,. Executive Summary, Revision 2and additional evaluation resulting from NRC comments

Incorporate SRP comments and Finalize Report Revision 3

PREPARATIONPREPARED BY:

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SIGNATURE DATE

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SIGNATURE DATE

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N/A_MANAGER OF NUCLEAR POWER

CONCURRENCE (FINAL REPORT ONLY)DATE

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p TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100SPECIAL PROGRAM

FRONT MATTER REV: 2

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Preface

This subcategory report is one of a series of reports prepared for theEmployee Concerns Special Program (ECSP) of the Tennessee Valley Authority(TVA). The ECSP and the organization which carried out the program, theEmployee Concerns Task Group. (ECTG), were established by TVA's Manager ofNuclear Power to evaluate and report on those Office of Nuclear Power (ONP)employee concerns filed before February 1, 1986.. Concerns filed after thatdate are handled by the ongoing ONP Employee Concerns Program (ECP).

The ECSP addressed over 5800 employee concerns. Each of the concerns was aformal, written description of a circumstance or circumstances that anemployee thought was unsafe, unjust, inefficient, or inappropriate. Themission of the Employee Concerns Special Program was to thoroughlyinvestigate all issues presented in the concerns and to report the resultsof those investigations in a form accessible to ONP employees, the NRC, andthe general public. The results of these investigations arescommunicatedby four levels of ECSP reports: element, subcategory, category, and final.

Element reports, the lowest reporting level, will be published only forthose concerns directly affecting the restart of Sequoyah Nuclear Plant'sreactor unit 2. An element consists of one or more closely relatedissues. An issue is a potential problem identified by ECTG during theevaluation process as having been raised in one or more concerns. Forefficient handling, what appeared to be similar concerns were grouped intoelements early in the program, but issue definitions emerged from theevaluation process itself. Consequently, some elements did include onlyone issue, but often the ECTG evaluation found more than one issue perelement.,

Suhcategory reports summarize the evaluation of a number of elements.However, the subcategory report does more than collect element levelevaluations. The subcategory level overview of element findings leads toan integration of information that cannot take place at the element level,Th'is integration of information reveals the extent to which problemsoverlap more than one element and will therefore require corrective actionfor underlying causes not fully apparent at the element level.

To make the subcategory reports easier to understand, three items have beenplaced at the front of each report: a preface, a glossary of theterminology uniquo to ECSP reports, and a list of acronyms (terms formedfrom the first letters of a series of words).

Additionally, at the end of each subcategory report the reader will find atleast two attachments. The first is a Subcategory Summary Table thatincludes the following information: the concern number, a brief statementof the concern, and a designation of nuclear safety-related concerns. Thesecond attachment Is a listing of the concerns included in each issueevaluated in the subeatagory.

TVA EMPLOYEE.CONCERNS REPORT NUMBER: 19100SPECIAL PROGRAM

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The subcategories are themselves sumrr':rized in a series of eight categoryreports. Each category report reviews the major findings and collectivesignificance of. the subcategory reports in one of the following areas:

management and personnel relations

" industrial safety

construction

" material control

" operations

" quality assurance/quality control

" welding

" engineering

A separate report on employee concerns dealing with specific contentions ofintimidation, harassment, and wrongdoing will be released by the TVA Officeof the Inspector General.

Just as the subcategory reports Integrate the Information collected at theelement level, the category reports integrate the information assembled inall the subcategory reports within the category, addressing parti'cularlythe underlying causes of those problems that run across more than onesubcategory.

A final report will integrate and assess the information collected by allof the lower level reports prepared for the ECSP, including the InspectorGeneral' a report.

For more detail on the methods by which ECTG employee concerns wereevaluated and reported, consult the Tennessee Valley Authority EmployeeConcrnn Tank Group Program Manual. The Manual spells out the program'sohjoctivos, ucuij,, organization, and roeponsibilitioe. It also opecifiesthe procedures that were followed In the Investigation, reporting, andcloseout of the issues raised by employee concerns.

TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100SPECIAL PROGRAM

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ECSP GLOSSARY OF REPORT TERMS'

classification of evaluated issues the evaluation of an issue leads to one ofthe following determinations:

Class A: lszue cannot be verified as factual

Class B: Issue is factually accurate, but what Is described Is not aproblem (i.e., not a condition requiring corrective action)

Class C: Issue is factual and identifies a problem, but corrective actionfor the problem was Initiated before the evaluation of the issuewas u,,dertaken

Class I): Insun In factual And presonts a problem for which correctiveaction has been, or is being, taken as a result of an evaluation

Class E: A problem, requiring corrective action, which was not identifiedby an employee concern, but was revealed during the ECTGevaluation of an issue raised by an employee concern.

colloctLive si~niflcance an analysis which determines the importance andconsequences of the findings In a particular ECSP report by putting thosefindings in the proper perspective.

conLcern (see "employee concern")

corrective action steps taken to fix specific deficiencies or discrepanciesrevealed by a negative finding and, when necessary, to correct causes inorder to prevent recurrence.

cr1terion (plural: criteria) a basis for defining a performance, behavior, orquality which ONP Imposos on Itself (see also "requirement"),

element or element report an optional level of ECSP report, below thesubcategory level, that deals with one or more issues.

mpkj.9oje conicern a formal, written description of a circumstance orclrcu•in tancoi that an omployee thinks unsafe, unjust, inefficient orInappropriate; unually documented on a K-form or a form equivalent to theK-form.


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ov. anIuat o,0.r the individuAl(s) assIgned the re spon i lhity to a (%ss a sp ecIfIcgroupinf, of employee concerns.

findinr.s includes both statements of fact and the judgments made about thosefacts during the evaluation process; negative findings require correctiveaction.

issue a potential problem, as interpreted by the ECTG during the evaluationprocess, raised in one or more concerns.

K.-form (see "empl oyoe concern")

relquirement a standard of performance, behavior, or quality on which anevaluation judgmont or decision may be based.

rout cause the undorlyilng reason for a problem,

*Terms esnential to the program but which require detailed definition have beendefined in the ECTG Procedure Manual (e.g., generic, specific, nuclearsafety-related, unreviewed safety-significant question).


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Acronyms

Al Administrative Instruction

AT.SC American .Institute of Steel Construction

ALARA A:i Low AL Reasonably Achievable

ANS; American Nuclear Society

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

AWS American Welding Society

BFN Browns Ferry Nuclear Plant

BLN Bellefonte Nuclear Plant

CAQ Condition Adverse to Quality

CAR Corrective Action Report

CATD Corroctlvo Action Trackin6 Document

CCTS Corporate Commitment Tracking System

CE(G-Ii Category Evaluation Group Head

CFR Code of Federal Regulations

(I. Concerned Individual

CMTR Certified Material Teot Report

COC Certificate ol' Conformance/Compliance

DCR Design Change Request

DNC Division of Nuclear Construction (see also NU CON)

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DNE Division of' Nuclear Engineering

DNQA Division of Nuclear Quality Assurance

DNT Division of Nuclear Training

DOE Department of Energy

DPO Division Personnel Officer

DR Discrepancy Report or Deviation Report

ECN Engineering Change Notice

ECP Employee Concerns Program

ECP-SR Employee Concerns Program-Site Representative

ECSI' Employee Concerns Special Program

ECTG Employee Concerns Task Group

EEOC Equal Employment Opportunity Commission

EQ Environmental Qualification

j;,MH'r Emrgoncy Modlcnl Roeponso Toomr

EN DES Enginoorinp, Doign

ETRr Employeo Response Team or Emergency Rosponoo Team

F CR HField Change Request

I'SVAR Finatl 'SafoLy Analysis Report

FYY Fiiuc•l Yonr

G;ET Genorail Employee Training,

HU' Hazard Control Instruction

HVAC llatinp,, Ventilating, Air Conditioning

II Innti.llalion Inotruction

INW1 Inraltitut.o of Nuclear Power Oporatione

IHN Inspection Rejection Notice

TVA EMPLOYEE CONCERNS REPORT NUMBER: 19100SPFCIAL PROGRAM

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I,/R Labor ReoI at: Ior,:• •:taf~'C

M&AI Modifications and Additions Instruction

MI Malnt'onanco InstructIon

MSPB Motrit. Sytsttuma Protection Board

MT Magnetic Particle Testing

NCR Nonconforming Condition Report

NDE Nondestructive Examination

N1P1 Nuclear Performance Plan

NPS :Nor-plant Specific or Nuclear Procelures System

NQAM Nuclear Quality Ansuranco Manual

NRC NucleAr Rogulatory Commission

NSB Nuclear Services Branch

NSR!, Nucloer Safoty Rovlew Sttaff

NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)

NUMARC Nuclnr Utility Management and Resources Committee

OSHA Occupational Safety and Health Administration (or Act)

ONP Office of Nuclear Power

OWCP Office of Workers Compensation Program

PIIR Pirnonal Ilistory Record

I,'r Liquid Penetrnnt Testing

QA Quality Assurance

QAP Quality Asturanceo Procoduroo

QC Quality Control

QCI Quality Control Instruction

TVA EMPLOYEE CONCERNS REPORT NUMlBER: 19100SPECIAL PROGRAM

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QCP Quality Control Procedure

QTC Quality Technology Company

RIF Reduction in Force

RT Radiographic Testing

SQN Sequoyah Nuclear Plant

SI Survoillance Instruction

SOP Standard Operating Procedure

SRP Senior Review Panel

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 Testing

VT Visual. Testing

WBECSP Watts Bar Employee Concern Special Program

WBN Watts Bar Nuclear Plant

WR Work Request or Work Rules

WP Workplans



REVISION NUMBER: 3

PAGE 2 OF 24

OUTLINE OF CONTENTS

1.0 CIHARACTERIZATION OF ISSUES

1 I I ntrodu .L ion

1.2 Description of Isoues

1.2.1 1 ann, -1'

1.2.2 Junction Boxes

1,7.3 11nnd Switches

2.0 SUMMARY

2.1 Summary

2.2 Sunmmary

2.3 Summary

2.4 Summary

2.5 Summary

2.6 Summary

of

of

of

of

of

of'

the Evaluation Process

Findings

Collective Significance

Causes

Corrective Action

3.0 EVALUATION PROCE"S

3.1 General Methods of Ev

3. 2 R,,qu I rm,, t.i, s or Cr ito

3.2.1 Pnnola


3.2.3 11and Switches

aluation

rna Ent.,nllahod for Individual lanuoe


REVISION NUMBER: 3

PACE 3 OF 24

4.0 FINDINGS

4-1 Findings on Panels

4.1.1 Generic

4.1.2 Site Specific

4.2 Findings on Junction Boxes

4.2.1 Gonerwric

4.2.2 Site Specific

4,3 In I j w• I O.1ft 11, 0100

4.3.1 Generic

4.3.2 Sito Spocific

5.0 COLUFCTIVE SIGNIFICANCE

5.1 Significance of Each Issue

5.1.1 PAnels


5.1.3 Hand Switches

5.2 Collective Significance of the Subcategory

5.2.1 Generic

5.2.2 Site Specific,

6.0 CAUSE

6.1 Panels

6.2 Junct.ion Boxo'o

6.3 Hand .1wi t. chon1

7-,7


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7.0 CORRECTIVE ACTION

7.1 Corrective Action Already Taken

7.2 Corrective Action from CATDs

8.0 ATTACHMENTS

Attachment A, "Subcategory Summary Table and List of Concerns"

Attachment B, "List of Evaluators"

Attachment C, "Liit of Concerns by Issue

1111111111111111111 ~IIIII II liii ItIllIllilI 1111

EXECUTIVE SUMMARY

Electrical Equipment

Report Number: 19100

ISSUE ASSESSMENT

This subcategory report addresses four safety related employee concernspertaining to the adequacy of material substitution, electrical equipmentinstallation practices and the perceived existence of obsolete hand switchesin the main control room panels. One issue noted that the as constructedconfiguration of the vendor drawings for the 480V Shutdown Board panels didnot reflect the as-designed TVA issued configuration drawings. This issue wasWBN specific and was not evaluated at any other site. One issue questionedthe acceptability of using galvanized steel as a junction box material atWBN. This issue pointed to an implied definition of acceptable materials asshown in the WBN QCP-3.03. One issue was raised by individuals who perceivedthat TVA was using obsolete hand switches in the main control room panels.

MAJOR FINDINGS

The configuration discrepancies documented by WBN NCR W-205-P showed thatterminal block strip labeling and wire labeling did not conform to theexisting as-constructed configuration vendor drawings available at that pointin time, Prior to initiating the NCR, there were no inspection criteriaavailable to riquire or control labeling on vendor supplied equipment wiring.Tho discrepancies were factual but all functional tests had been completed onthe control panels. No Conditions Adverse to Quality had been identified andthe oquipmont operated an designed, The Issue wan doomed to be factual, butthe condition had been Identified and addressed before the concern wasr)egistered, Sit) procedures for WBN are being revised to incorporateinspection rrquirements for interface terminal labelling and updating vendordrawings,

The junction box material substitution issue was consldhred to be notfaACual, find th,! concerned employoe referenced G-40 for a list of acceptablejunction box mat.rials, he would have found that galvanized steel is anacceptable material, The issue was evaluated at all four nuclear sites.Procedural clarification was undertaken at WBNobut no corrective action wasroquired at any of the other sites. The perceived obsolete hand switchesqustioned at W1IN wore of the Westinghouse Type W-2 configuration. In 1980,N[C itinuod bullotin No, IE 80-20. This bulletin identified a shortcoming Intho design of th, switches which left some uncertainty as to the position ofthe switch during operation of its controlled equipment. NRC gave eachutility utillzing the switches an option to either replace or modify theswit.ches. TVA took the modification option and added a position indicationcircuit to the switches which met the intent and requirements of the NRCbulletin, SQN took the same option and modified their W-2 handswitches. Theissue was deemed to be not factual,

4401 Tpnao i of 2

- flEEUEm'!E

COLLECTIVE SIGNIFICANCE

The major issue identified during evaluation of the concerns was the lack ofGeneral Construction Specification control for vendor supplied equipment.Existing policy limited DNC's inspection requirements to TVA wiringconnections at the termination points at the vendor supplied component.Configuration contrrl mandateo that vendor drawings and TVA drawings shallreflect the same configuration, and inspection procedures should incorporatethis requirement. DNE, DNC, and ONP management effectiveness in ensuringconfiguration control, as-constructed drawing control, work scope control,group responsibility assignment coordination, and ECN accountability has beenproven to be short sighted considering the findings and resultant reworkdocumented by this subcategory report and the data package associated with NCRWBN W-205-P. The technical adequacy of the equipment was never compromised.The operability of the safety-related equipment and the adequacy of thedocumentation was found to be acceptable.

CATDs issued by Operations in their 30804 report int4. by Construction in their1.1200 report and the rovislonn to WBN-QCP-3.06-2 andL QCP-3.06-3 as a rosult ofNCR.1225, Roviolon 1, will apsuro that the procedural controls neconsary toImplement the inspection requirements for vendor supplied equipment interfaceswill be in place. Updating of vendor supplied drawings necessary to maintainthe as-designed configuration control necessary for effective plant operationand maintenance of p1ant systemn and equipment will be controlled with theAdministrative Instructions A1-4.3 and 4.4.

U

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1.0 CHARACTERIZATION OF ISSUES

1.1 Introduction

This subcategory report for Electrical Equipment in the ConstructionCategory addresses four safety-related employee concerns.The concerns were site specific to Watts Bar Nuclear Plant (WBN) andpertain to the adequacy of material substitution, installation ofelectrical equipment, and electrical hand switches, These problemswere perceived to exist in electrical panels, junction boxes andhandswitches, and the concerns were categorized for evaluation intothree issues as follows:

Panels Hand Switches

HI-85-045-001WBP-85-016-003 HI-85-093-N02

Junction Boxes

IN-85-913-001

1.2 Description of Issues

1.2.1 Panels

One concern reported the 480V shutdown board panels have apotential nonconformance that has not been documented and,therefore, not in accordance with as-constructed andas-designed drawi'ngs.


One concern questioned the acceptability of materialsubstitution for electrical junction boxes, The Junctionboxes wore not manufactured from sheet metal and painted asrequired by General Construction Specification G-40 andApplicable electrical standard drawings, The boxes wereconstructed of galvanized steel, and may have been installedthroughout the plant.

1.2.3 Hand Switches

The concerns in this issue stated that hand switches in themain control room were declared obsolete and, rather thanchange the switches, nameplates and labels were changod,


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2,0 SUMMARY

2.1 Summary of Issues

Perceived issues addressed by' this subcategory consisted of concernsaddressing the configuration control of the 480V shutdown boardpanels, the use of "obsolete" hand switches in the main control roompanels and the acceptability of material substitution for electricaljunction boxes. The concerns addressed were site-specific to WBN,but the junction box issue was evaluated at all four nuclear plantsites.

2.2 Summary of the Evaluation Process

The evaluation methodology consisted of a thorough review of theapplicable procedures, documents, and standards to determine if theissues raised were adequately addressed. Listings of nonconformancereports (NCRs) were chocked to determine If previous documentationexisted on the subjects,

Quality Technology Company (QTC) files were reviewed for anyadditional Information that would assist In identifying specificitems related to the concerns.

Walkdowns were performed to determine compliance with plantprocedures.

Interviews were conducted with cognizant personnel to obtaininformation leading to a conclusion for the concerns.

2.3 Summary of Findings

Of th, thron ifnuen addressed, only ono was determined to befactual, The configuration control dincropancios for the 480Vshutdown board panels were substantiated, but the concernsaddressing the substitute junction box material and the "obsolete"hand switches proved to be not factual. Procedural clarificationhnn been Implomentod to spocifically authorizo galvanizod materialusage. The W-2 hand awitchon had boon modified prior to theissuance of the two concerns independent from the concernevaluation. The concerned individuals wore misinformed about thehand switch requirements.

The unMMAVy of tho Individual Issues follown:


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Panels

Configuration discropancien for the 480V shutdown board panelswore Identified and addressed by NCR W-205-P, Of the 3675discrepancies Identified, over 3,400 were terminal block and wirelabeling discrepancies.

Preoperational functional testing verified the installedconfiguration as being correct. The documentation and operabilityof the equipment was never questioned and no nuclear safety problemwas over identified,

Junction Boxes

The concern that galvanized steel junction boxes were not acceptableper DNE General Construction Specification 0-40 Is not valid,

Though G-40 did not specify galvanized steel was an acceptablejunction box material, it implied, by way of referencing anationally recognized standard, that the material was acceptable.The National Electric Code does recognize galvanized steel as anacceptable corrosion resistant material. The controlling siteprocedure, WBN QCP-3.03, has been clarified to reflect galvanizedsteel's acceptability.

Hand Switches

Discussions with cognizant Modifications Engineering personnelrevealed that NRC IE Bulletin Number 80-20 required certain handswitches in the main control room to be replaced or modified. TVADNE issued Engineering Change Notice (ECN) 3306 in April of 1982 tomodify the applicable hand switches by rewiring them,r This work wascompleted in 1984. The concern was voiced in 1985. Memorandumswere issued scoping the changes required as a result of human factorconcerns, NRC regulations, and control panel nameplate and labelchanges. Some of the label and nameplate changes were for themodified hand switches.

2.4 Snrnmnry of (,o1Joctivo_ iJgjnL canco

Collectively, inadequacies were pinpointed in the upper-tierGeneral Construction Spec'ificatIons and site-implomentedinntallatlon and Inspection procodurou, Thoro woro no controlline


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documents addressing configuration control requirements for vendorsupplied equipment. The coordination effort between design groupsresponsible for modifications to vendor supplied equipment needsto be strengthened to preclude the issue of scope of workdocuments (Impact and Justification sheets for ECNs) that arelabled "documentation only" but actually require physical work on

equipment. Misinformation also significantly affected theperception of employees who voiced concerns about theWestinghouse W-2 hand switches in WBN's main control roomand the material acceptability for junction boxes.

2.5 SuImmary of Causes

The causes identified for configuration discrepancies for theWBN .480V shutdown board panels are:

(1) No DNE or DNC procedures governing installation configurationcontrol for terminal wiring labeling.

(2) Lack of coordination between design groups before issuanceof scope of work documents for ECNs.

(3) Inadequate site Project Control review for scope of work onECNs designated as "for documentation only,"

The concerns addressing the W-2 hand switches displayed the CI'slack of knowledge of the events leading to the NRC IE Bulletin 80-20and the options available to TVA for modifying or replacing theswitches to comply with the bulletin. Information was availabledelineating the historical facts behind the requirement to increasethe efficiency and reliability of the switches.

-The concern related to the acceptability of galvanized steelelectrical junction boxes resulted from the site procedure'sfailure to list acceptable junction box materials or at leastreference the applicable G-40 section addressing junction boxes.

2.6 Summary of Corrective Action

Corrective action had already been taken relating to the employeeconcern which dealt with the 480V electrical panels in unit 1 atWBN. Vendor wiring for the unit 2 main control room panels at WBNis scheduled to be inspected. Corrective action is not required forthe employee concern associated with hand switches. Additionalcorrective action is not required for the concern on electricaljunction boxes, since the WBN site procedure has been revised topro cludo any futuro misintorprotatlon of tho motorial hccoptabillity,


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3.0 EVALUATION PROCESS

3.1 General Methods of Evaluation

The evaluation methodology at each nuclear-plant site consisted of areview of applicable design standards and specifications and siteimplemented installation and inspection procedures related to theissues. ECNs, NCRs, QTC files, and other related documents werereviewed for issue applicability.

Walkdowns were performed with cognizant personnel to verifyprocedural compliance of issue-related components.

Interviews were conducted with personnel directly involved with eachIssue to obtain additional information. These included discussionsabout previously accepted practices and standardo; masoclated withthe issues addressed by the concerns.

3.2 Requirements or Criteria Established for Individual Issues

3.2.1 Panels

The requirements for the 480V shutdown electrical panelinstallation, and the associatud problems, were summarized inthe nonconforming report NCR W-205-P, revision 1. This NCRdocumented the violation of the requirements, evaluated thecondition, and proposed corrective action, The correctiveaction has been completed for WBN unit one. Because of the

extensive ndture of this NCR, (3675. documented deficiencies),documentation of the as-constructed and as-designed conditionwas available. Further investigation was unnecessary toevaluate if any other potential installation violationaoxisted, since the employee concern was determined to befactual as established by NCR W-205-P.


TVA Construction Specification 0-40 and Eloctrical StandardDrawing SD-E13.6.3 established TVA requirements for junctionboxes. WBN Site Procedure WBN QCP-3.03, revision 18,oetAblishod current requirements for material acceptancecriteria for junction boxes. ThQ requirements of thesedocuments were used to evaluate the acceptability of thematerial used in the final installation, an questionod by theconcerned employee. Thoeso documents wore also compared toaccepted practices established at the site, as related by EEU


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PAGE 10 OF 24

personnel during interviews. TVA Nuclear SafeLy Review StaffReport No. I-85-524-WBN was evaluated to compare its conclusionsand the consistency of the findings with'this report. A draft ofthe revision to WBN QCP-3.03 was reviewed to evaluate theeffectiveness of clarifying the materials acceptable for use in,junction boxes.

Reviewed conduit and grounding drawing 45N810-7, Revision 35,.entitled "Conduit and Grounding, Floor Elevation 669.0,Ceiling Plan", and the Master Bill of Material for el'ectricalequipment to determine the numbering scheme used by DNE toidentify and describe those junction boxes specified forinstallation at SQN.

SQN Workplan number 12292 related to the implementation of ECN6823 was reviewed to determine the control method utilizedto ensure the proper installation of junction (splice) boxes.

SQN Electrical Maintenance Planning personnel wore contacted todiscuss the controls established or utilized during themaintenance request (MR) or work-release (WR) process relatedto junction box replacement.

SQN Procurement personnel were contacted to ascertain thedocumentation/certification requirements for procuringand receiving electrical junction boxes and a review of theaffected documents was performed.

3.2.3 Hand Switches

Discussions with selected EEU and Modifications personnel anda subsequent document review established the criteria forevaluation of the perceived problem with hand switches. Theevaluation was supported by scoping review of the workassociated with modification of the main control roomswitches including replacement of the labels and nameplates.Documents showed modification of hand switches was requiredby D14E ECN 3306. This modification was required ab a resultof the NRC IE Bulletin number 80-20, which establishedcriteria requiring either replacement or modification ofWestinghouse W-2 hand switches. The option given to allutilities utilizinj the W-2 hand switches was to replace ormodify the switches. ECN 3306 revealed TVA elected to modify -the hand switches. Workplan review showed the modificationwork was a result of the ECN and the NRC 80-20 bulletin.


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A document review produced evidence that nameplates andlabels were changed on the hand switches in the main controlroom. This work was a result of Human Engineering RelatedChanges and NRC regulations.

It was concluded through interviews that no obsolete handswitches had ever been installed in the main control room.

4.0 FINDINGS

4.1 Findings on Panels

4.1.1 Generic

Discussion

Not applicable.

Conclusion

The issue raised by the concern on Electrical Panels wasdetermined to be WBN site-specific and, therefore, notgeneric to any other TVA site.

4.1.2 Site Specific - WBN

Discussion

The roview of previously documented NCRs on the 480Vshutdown panels revealed that 3675 discropancies weredocumented on NCR W-205-P, Revision 1, initiated onNovember 20, 1984. NCR W-20S-P was initiated independentof the employee concern. The NCR grew out of what wasoriginally intended to be an ONP configuration walkdowncovering Browns Ferry, Sequoyah, and Watts Bar. The closurerequirement of the NCR consisted of completing a largescale configuration verification walkdown for electricalpanels in the Main and Auxiliary Control rooms at WBN. Thesediscrepancies had been evaluated, corrective actionestablished, verified complete, and the NCR closed on April22, 1985. For a complete discussion on NCR W-205-P, seeSubcategory Construction Report 11200. Terminal block andwire labeling accounted for 92.8 percent of the problems.


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Inspection procedures now require label verification forvendor supplied electrical equipment. Previously, noprocedure addressed the inspection requirements necessary toconfirm the labeling of terminal blocks and internal wiringfor vendor supplied equipment. Vendor wiring in unit 2 maincontrol room panels at WBN is scheduled to be inspected. Also,the electrical engineer now in charge of the main control roomunit 2, reviews all ECNs, regardless of category, for changerequirements including labeling changes.

The following is a summary of factors contributing toconfiguration control discrepancies:

1. Inspection requirements for labeling of terminal blockstrips were nonexistent when the panels were installed. 1R3In the early phase of construction, an agreement was madebetween Construction and ONP. that Construction would waituntil just before system transfer to install or updateterminal block identification strips. This was anaccoptod practico free of any procedural control, Theelectrical inspectors wore required only to verify thateach wire was attached to the appropriate terminal (e.g.,one through 12).

NCR 7225 Revision 1 documents the fact that the existingprocedures WBN-QCP-3.06-2 and QCP-3.06-3 are inadequatefor sufficiently establishing acceptance criteria for 1R3inspection of vendor and TVA interface terminal blocks.

2. The majority of the wire labeling discrepancies were onvendor wiring (commonly referred to as internal wiring).Most field wiring Is color coded and not labeled with tags.In the early construction phase of the project, a policywas established stating that DNC would not inspect vendor.wiring since each vendor had a certified QA program.Thus, TVA never inspected vendor wire labeling before thiswalkdown.

The TVA wiring diagrams reflected the as-designed configu-ration of the terminal interfaces, but the vendor drawingshad not been rovised to reflect the as-designed terminalconfigurations. The Corrective Action Plans for CATD11200-WBN-06 and 30804-WBN-02 provide assurance that IR3vendor drawings will be configuration verified prior tobeing used for any maintenance or repair work. WBNAdministrative Instruction AI-4.3 details vendor drawingconfiguration verification requirements.

I•J•T


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PAGE 13 OF 24

3. iNC has had, and continues to have a problem withEngineering Change Notices (ECNs) that are categorized"for documentation only." To fit this category, the ECNsmust not require physical changes to plant features.After the 480-volt control panels were installed, wereceived many ECNs with terminal block strip label changesmistakenly categorized (by DNE) "for documentation only."These changes were not scoped for work requirements bythe. WBN Project Control Unit because of the "fordocumentation only" designation.

Preoperational Test TVA-13A results provided assurancethat functional tests were complete for unit 1 480V shutdownboards. Several problems were identified as test deficiencies, butwere resolved during the test.

Conclusion

The concern that a potential nonconformance existed on the480V shutdown panels was factual. The completed correctiveaction on NCR W-205-P provided adequate documentation of theas-constructed, as-designed status of the unit 1 panels.This finding confirmed the employee's concern that the panelswere potentially nonconforming. The extensiveness of thedocumentation and evaluation of the NCR, and theindependently verified completed corrective action providedassurance the problem has been adequately addressed. Unit 2panels will be subjected to similar configuration controlwalkdowns.

Revisions to WBN-QCP-3,06-2 and QCP-3,06-3 and adherence toAI-4.3 requirements will preclude any future configuration lR3control problems with TVA/vendor interfaces on electricalequipment.

4.2 Findings on Junction Boxes

4,2.1 Generic

Discussion

The upper-tier DNE'specification did not specifically addressjunction box material, but only stated the material must meetthe requirements of an approved recognized nationalstandard. The National Electric Code, Article 370-20 (anapproved recognized standard), stated that the use ofgalvanized steel is an acceptable practice as a corrosionresistant material for metal junction boxes. The WBN siteprocedure did not specifically list galvanized steel as anacceptable material along with the listing of other


REVISION NUMBER: 3

PAGE 14 OF 24

materials. Review of Electrical Standard Drawing SD-E13.6.3revealed the boxes shall be constructed of sheet steel. Nospecific mention was given for a corrosion resistantmaterial. However, a requirement was given for paintingsurface mounted field fabricated boxes.

Conclusion

Because of a possible need for clarification in the DNEspecifications, this issue was generic to all other TVAnuclear sites. Evaluations at other sites revealed that theywere utilizing galvanized steel. Site procedures weredetermined to be adequate as were the DNE upper-tierprocedure and drawings. The revision for clarification ofthe WBN site procedure should preclude futuremisinterpretation of the intent.

4.2.2 Site Specific

WBN Discussion

The concern that junction boxes were not manufacturedaccording to G-40 or standard drawings was not factualbecause the intent was not to exclude galvanized steel, butto address painted steel since some method of corrosionprotection was required. A review of the DNE ElectricalConstruction Specification G-40 and Standard DrawingSD-E13.6.3 revealed junction box material was not specificallyaddressed but stated the material must meet the requirementsof an approvedrecognized national standard. Review of theNational Electric Code revealed galvanized steel, among othermaterials, was an acceptable corrosion resistant material forelectrical junction boxes. A review of the WBN site procedureWBN QCP-3.03, revision 18, revealed that galvanized steel wasnot previously listed as an acceptable material. Discussionswith DNC electrical engineers, Modification Unit engineers, andan electrical craft foreman confirmed that galvanized boxescould be found throughout the plant. Galvanized boxes werealso used at other si~qs,. but no other instances ofquestioning the galvanzied steel acceptability were voiced.The WBN. DNC Procedures and Training Unit was in the process ofclarifying the acceptability of galvanized steel in the siteprocedure. The investigation completed by the NSRS(Report Number I-85-524-WBN) was consistent with the findingsand conclusion of this report confirming that galvanizedsteel was an acceptable material for junction boxes. The NSRSreport findings stated that the intent of G-40 and theelectrical standard drawings was not. to exclude ,galvanizedstool, but to addronB painting bocauoe some method of corrooionprotoction lit requirod,


REVISION NUMBER: '3

PAGE 15 OF 24

Tho Investigation also concluded that the intent of theGenpral Construction Specification G-40 was not to excludegalvanized steel from the list of acceptable materials forjunction boxes.

Conclusion

Galvanized steel is an acceptable material for use inelectrical junction boxes and the employee concern isdetermined to be not factual.

SQN Discussion

A cognizant Modifications engineer was contacted to determineif clarification was required in regard to materialrequirements for junction box construction. SQN Modificationand Addition Instruction (M&AI)-6 "Installation of Conduitand Junction Boxes" Revision 6, was reviewed to determine ifclarification was required pertaining to a definition ofcorrosive resistant material.

The Modifications engineer interviewed indicated junctionboxes were either specific ,.nd procured by DNE or fabricatedon site using DNE standard drawings. Notes on the drawingsspecify the material type as sheet metal and the corrosionprotection used is paint. Problems or confusion had not beenidentified for the material requirements related to junctionb',x construction.

A review of M&AI-6 revealed that junction box material wasrequired to meet an approved recognized standard. Nospecific material requirements were given as examples tointroduce error or confusion related to the materialrequirements for junction box construction.

Review of conduit and grounding drawing 45N810-7, Revision 35revealed that junction boxes wore given unique identificationnumbers with the appropriate mark number assigned by theDivision of Nuclear Engineering (DNE). Each mark number wasto be utilized by the constructor during the installationprocess in conjunction with "The Master Bill of Material forElectrical Equipment," to describe the type of junction boxrequired at the specified location.

Review of the Bill of Material for various mark numbersrevealed a general description of the affected junction boxand included its size, type or NEMA rating, and otherpertinent data such as contract and item number, etc.(Reference 45BM826 R4 SliT 16 of 45, and 45BM828 R3 SHlT 14of 45),

77S 777-77ý7- 7 W


REVISION NUMBER: 3

PAGE 16 OF 24

Reference to the "type" of junction box was DNE'smethod to specify which TVA standard drawing was to beutilized during fabrication and assembly.

Conclusion

The site procedure is adequate as written and consistent with therequirements of G-40 and the National Electric Code.

Program enhancement could be accomplished by DNE should a listof acceptable materials be compiled and injected into thegoverning design out-put document (G.C.S-G40).

BFN Discussion

Modifications personnel were contacted to determine ifclarification was required in regard to material requirementsfor junction box construction. M&AI-27, dated Jujy 16, 1986,was reviewed to determine 'if clarification was requiredpertaining to a definition of corrosive resistant material.

Conclusion

Modifications personnel indicated junction box types werespecified by DNE. Fabrication was performed per the designspecification which included provisions/requirements forpainting to prevent corrosion. No deficiency was-notedrelated to junction box material requirements.

M&AI-27, "Installation of Electrical Conduit and SystemJunction Boxes," stated that materials used for junction boxconstruction shall meet the requirements of an approvednational standard. An attachment to the procedure providedmaterial specifications consistent with the National ElectricCode and lists painted steel, galvanized steel, aluminum orstainless steel as being acceptable. Independentverification is required'and no deficiencies were noted.

BLN Discueslon

A review of site procedures BNP-QCP-3.2, revision 12,BNP-QCP-3.26, revision 6, BNP-QCP-10.5, revision 6, andBNP-QCP-3.13, Revision 13, "Equipment Installation," providedthe acceptance criteria for corrosion protection of electricaljunction boxes.

A walk-through of the plant was performed to determine if ahardware problem existed as a result of inadequate materialselection for electrical junction boxes.

................ ATVA EMPLOYEE CONCERNS REPORT NUMBER: 19100

SPECIAL PROGRAMREVISION NUMBER: 3

PAGE 17 OF 24

Discussions were held with Electrical Engineers at the site.

Conclusion

The site procedures did not list specific materials acceptablefor electrical junction boxes. The BLN procedures provideassurance through unique number verifikation and shopinspections that the boxes installed meet DNE requirements.

All boxes observed during a walk-through of the plant werein good condition and free of corrosion.

Discussions with Electrical Engineering personnel revealed theonly galvanized electrical junction boxes used are thosesupplied with vendor equipment.

No hardware problem exists in the plant and no confusion existedas to the acceptability of the galvanized steel junction boxes,used. The site peocedures are fully adequate as written andensure the boxes installed meet DNE requirements.

Note: Since galvanized junction boxes are constructed of areactive metal similar to aluminum, and react withborated water to form hydrogen, the design basiscalculations for hydrogen build-up inside containmentshould include these and other similar items in theinventory process. The control of such reactivemetals within the confines of the containment isdiscussed in the WBN ECTO Construction Category,Subcategory Report 19200, "Conduit and Cable Tray."DNE provides the methods which will ensure that thesematerials are included in the design basis calculationfor hydrogen build-up and that future updates to thecalculation packaee will include these and other similarmaterials.

4,3 Findings on Hand Switches

4.3,1 Generic

Di0 cussion

Not Applicable


REVISION NUMBER: 3

PAGE 18 OF 24

Conclusion

The issue raised by the two concerns for hand switches wasWBN site specific,

4.3.2 Site Specific

Discussion

Discussion with a Modifications supervisor and cognizantModifications Electrical Engineering personnel revealed thatWestinghouse Type W-2 hand switches were required to bereplaced or modified as a result of NRC Bulletin'No. IE80-20, issued July 31, 1980. In response to this bulletin,TVA DNE issued ECN 3306 on April 7, 1982. This changerequired modification of approximately 60 W-2 hand switchesin lieu of replacement. This work consisted of rewiring thehand switches and was considered complete on March 3, 1983.

Discussions also produced documents revealing labels andnameplates were required to be changed in the main control-room. This change resulted from' human engineering relatedconcerns and NRC regulations. This work included changinglabels and nameplates on hand switches, which wasaccomplished in 1984.

Conclusion 0

The concern that "hand switches In the room control room weredeclared obsolete', but rather than change the switches, onlylabels and nameplates were changed" is not factual.

Modifications of the Main Control Room hand switches wereproperly evaluated and completed as verified throughdiscussions with cognizant personnel and a review ofinspection documentation. This work consisted of rewiring theexisting switches. Work was also scoped and completed on thechanging of hand switch labels and nameplates in the maincontrol room. There was no association between thesework-related items since the requirements for the workoriginated from completely different considerations,


REVISION NUMBER: 3

PAGE 19 OF 24

Note: A review of the G.C.T,F. preliminary evaluation at SQN onthis concern, SQN Report No, III-85-045-001 concludedsimilar findings. Since SQN and WRN have nearlyidentical main control room desrins, tho NRC BPulatin IF80-20 was also applicable to switches at SQN. DNEissued ECN L5591 to modify type W-2 switches at SQN. Theconclusions of the SQN report stating that no installedswitches had been declar~ed obsolete provides additionalcredence to the conclusions of this report.

5.0 COLLECTIVE SIGNIFICANCE

5.1 Significance of Each Issue

5.1.1 Panels

The significance of the issue concerning electrical panelconfiguration occurred because inspection requirements forlabeling of terminal strips was not procedurally addressedAt any lovelwhen the panels wore installed. Such inspectionswould verify label discrepancies with vendor wiring and designchanges not scoped by the site Project Controls Unit for ECNsthat are categorized "for information only." The findingsconcluded the concern was factual, but the perceived problemswith configuration control had been documented and correctedfor WBN unit I and inspections were planned for unit 2.

It is also significant to 'note that the requirements to main- Itain the as-designed status of vendor drawings existed in the IQuality Assurance Program Description for Design, Construction, JR3and Operation--Topical Report-TVA-TR75-l part 17.2.6 and in WBN IAI-4.3 but was not followed for the 480V shutdown board panels Idrawings.


This concern was determined to be not factual because theintent of G-40 was not to exclude galvanized steel and wasinadequately interpreted by the WBN site procedures. Siteprocedures were being revised before this evaluation tookplace to emphasize" the fact that galvanized steel was anacceptable junction box material,

5.1.3 Hand Switches

This concern was dotorminod to be not factual with regard tothe perceived problem that installed hand switches wereobsolete and rather than replace the switches, onlynameplates were chan~Qd, The findings concluded thnt


REVISION NUMBER: 3

PAGE 20 OF 24

replacement or modification of W-2 hand switches was required, andTVA chose to modify the switches. This modification consisted ofrewiring the switches to add a return to neutral indicatorcircuit, which may have gone unnoticed by the concernedemployees. The employees were apparently aware of the need toaddress a problem with the switches but were not Informed of therequired corrective action.

When a later effort was initiated to correct human factorconcerns which included the replacement of nameplates andlabels on hand switches, the employees may have incorrectlyperceived this work was related to the "obsolete" hand switchproblem.

5.2 Collective Significance of the Subcategory

5.2.1 Generic

The major issue identified during evaluation of the concernsfor this subcatagory was the lack of General ConstructionSpecification control for vendor supplied equipment as identi-fied in the 480V panel configuration control issue. Sitepro,:edures derived from G-specs depend on the adequacy of theG-specs to maintain design basis, control the quality, assurethe operability and maintain the as constructed configurationof all system components. Existing policy limited DNC'sinspection requirements to TVA wiring connections-at thetermination interface points at the vendor supplied component.Configuration control mandates that vendor drawings and TVAdrawings shall reflect the same configuration, and inopectionprocedures should incorporate this requirement.

The requirement to verify the vendor drawings' as-designedstatus prior to installation, repair, or maintenance of vendorsupplied equipment has been emphasized in the Topical ReportTVA-TR75-1 Part 17.2.6 "Quality Assurance Program Descriptionfor Design, Construction, and Operation" and in SiteAdministrative Instructions for Drawing Control of UnlicensedUnits.

Site implemented procedures at WBN are being revised toincorporate interface inspection requirements as a result ofCATDs issued by the Operations Category Report and the Work 1R3Control Subcategory Report evaluations. I

a*gI="uhliu-imr-i. .. 1 . . ....h.. o f.. -- Ii . . . . . . . . , . .


REVISION NUMBER: 3

PAGE 21 OF 24

5.2.2 Site Speciltic - WBN

DNE, DNC, and ONP management effectiveness in ensuringconfiguration control, as-constructed drawing control, workscope control, group responsibility assignment coordination,and ECN accountability has been proven to be short sightedconsidering the findings and resultant rework documented bythis subcatagory report and the data package associatedwith NCR W-205-P. Employees (Engineering, QA, and Craft)have been consistent in their application ofinstallation/documentatlon criteria as supplied by thegoverning procedures. When considering vendor suppliedequipment, employees did not question the lack of labelidentification on the terminal blocks. It is just anothercase of "It's always been done this way." Responsibilityfor documentation, inspection, and configuration control forvendor-supplied equipment must be addressed procedurally toprevent recurring inconsistencies in the configurationcontrol process. The technical adequacy of the equipmentwas never compromised. The operability of thesafety-related equipment and the adequacy of thedocumentation was never in question.

6 O CAJ')'F

6.1 Panel s

The causes identified for configuration discrepancies for the WBN480-volt 0hutdow board panels are as follows:

1. No 0lNE or DNC procedures governing vendor supplied equipmentroliting to the installed configuration/issued drawingconfigurAlon for terminal wiring labeling

2, 1.Ack of coordinntion hetweon design groups when issuing scopeof work dNumontn for ECNs.

3 1. InaueJAIa, Project Control review for scop6.of work on ECNsdonir'nattd as "do,:umontation only."

Note: I),tailod evaluatidn of panel configuration discrepancycontrol ij reported in the Construction Category,Suhcategory report number 11200, "Work Plan/Work Control."


REVISION NUMBER: 3

PAGE 22 OF 24

Operations Report 30804 also details findings proving thatvendor drawings which are not as-designed are being used to JR3

make repairs to CSSC plant equipment,

Discussion

The identifed cause for the 480-volt panel termination configurationdiscrepancies was .raced to the initiating.design organization'sidentification of work required in the field before issuing the

scope of work documents (I&J-sheets for ECNs) and their lack ofproviding updated vendor drawings to reflect'the scope of design JR3changes as part of the ECN process.

For example, when a circuit is modified to perform a differentfunction than what it was originally designed to perform, the designgroup responsible for that portion of the specific circuit issues ascope of work document. The design group responsible for thetermination end of the circuit (different from the group responsiblefor the function end of the circuit) reviews the scope of workdocument and revises the labeling portion of the drawing to agreewith the new function of the circuit and issues their scope of workdocument showing that there is no construction work required. Whenthe ECN cover sheet is prepared, the catagory designation iscontrolled by the details shown on the I&J-sheets from each groupinvolved in the change. If the cover sheet is prepared using theinformation on the I&J-sheet from the group assigning a"documentation only" category for their area of responsibility, thenthe ECN gets designated as "documentation only" upon Issuance toDNC, When the site Project Controls group receives an ECNdesignated as "documentation only," their representative files theECN away without doing a required work scoping. When the drawingshowing the physical work required arrives onsite, the responsibleEE scopes the work and write:; a workplan to do the work. Labelingchanges on vendor supplied terminal blocks do not fall within thescope of any site or design procedures presently in effect.Therefore, if the physical work is performed on the TVAwiring and is documented as being complete, the circuit is considered(by all groups involved) as being complete as shown the newest issueddrawings and is documented as such. The configuration shown on theTVA issued drawings at this point in time is different'than that 1R3shown on the vendor drawings.

The labeling is also shown on vendor supplied drawings and does notrequire any DNC inspections to verify labeling ordrawing/installation configuration control.

[77- 7--77-7_77-- 777,7ý


REVISION NUMBER: 3

PAGE 23 OF 24

Of the 3675 discrepancies documented by NCR W-205-P, 3412 wereidentified to be associated with labeling of vendor wiring.

Though the labeling discrepancies were pervasive throughout thecontrol panels, no quality or safety concerns were identified duringthe evaluation. All circuits were functionally tested anddocumented and would operate as designed.

If the vendor drawings had been updated to show the as-designedconfiguration as part of the design change process, the labeling 1R3discrepancies would not have existed.

6.2 Junction Boxes

The concern related to the acceptability of galvanized steel junctionboxes resulted from a misinterpretation of the procedural requirements.The CI interpreted that material not specifically mentioned was intendedto be excluded for use. Although the intent of WBN was not to excludethis material, the misinterpretation was due,,in part, to the siteprocedure. The procedure contained only a partial listing of approvedmaterials, not intending to exclude galvanized steel, but to address somemethod of corrosion protection. This could possibly have caused theemployee's concern. The potential for other sites to misinterpret theacceptability of galvanized steel caused this issue to be deemedpotentially generic. Further investigation proved this not to be thecase and the DNE upper-tier procedure was determined to Pe adequate.

6.3 Hand Switches

The concerns addressing 'the Westinghouse W-2 hand switchesdisplayed the Cl's lack of knowledge concerning the NRC 80-20bulletin and the switch modification work which had already takenplace. The information was readily available to the employee whichwould have explained the perceived problem away..

7.0 CORRECTIVE ACTION

7.1 Corrective Act:ion Already Taken or Planned

In regards to configuration discrepancies for electrical panellabeling, site implementig inspection procedures now address 1R3labeling of electrical items as a result of NCR 7225 Revision 1.Vendor wiring in the un.it 2 main control room panels at WBN isscheduled to be inspected. The Electrical Engineer In chargeof the unit 2 main control room now reviews all ECNs, regardlessof category, for any changes that may require physical work,Reference Construction Category Subcategory Report number 11200,"WorkPlan/Work Control" for CATDs which require DNE tc, update and 1R3issue vendor drawings as part of the design change process, I


REVISION NUMBER: 3

PAGE 24 OF 24

Corrective action hAs already been taken to clarify the junction boxmaterial requirements in WBN QCP-3.03 by the Procedures and TrainingSection, WBN, DNC.

No corrective actions were required as a result of the hand switch

concerns.

7.2 Corrective Action from CATD's

Non-applicable.

8.0 ATTACHMENTS

8.1 AttachmonLt _SS!LbcntRory, Summary Table and List of Congerns

8.2 Attachment Bi.t oEqvountoro

8.3 Attachmont C, Lint of Concerna by Invuo

B-

IFEREENCE?EQUENICY,.P - ISSS

- ECPS132J-ECPS132C- REQUEST

- R W1

ATTACM ENFATENNESSEE VALLEY AUTHORITY

OFFICE OF NUCLEAR POWEREMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

EMPLOYEE CONCERN INFORMATIOU BY CATEGORY/SUBCATEGORYSUBCATEGORY: 191 ELEC. EQUIPMENT

PAGE - 1:'RUN TIME - 08:36:02RUN DATE - 05/19/87

1EGORY: CO CONSTRUCTICN-PROCESS

HSUB R PLT

CAT CAT .DLOC:ONCERN "'U.BER

I -85-0-5-00-01

I REPORT APPL2 SAF RELATED

BF BL SQ WBHISTORICAL CONCERN

REPORT ORIGItl

Co 19100 S `,'tBNJ I t N N Y2 NA NA NA SS

QTC

02 IH 60100 S WBrl I I'll N N Y2 NA NA NA NO

I -85-093-N0201 CO 19100 rl WBN 1 N N N Y2 N•, NA NA SR

NRC

CONCERN DESCRIPTION

HAND SWITCHES IN THE MAIN CONTROL ROOM WERE DECLARED O0SOLEIE APPROX. IYEAR AGO RATHER THAN CHANGE SWITCHES

AS DIRECTED, ONLY THE LABELS AND NAME PLATES WERE CHANGED. WHEN CI QUESTIONED THIS PROCEDURE TO.HIS SUPERVISOR (NAME KNOWN TO QrC) HE HAS TOLD

" TO MIND YOUR OWN BUSINESS OR GETFIRED."

NRC IDENTIFIED THE FOLLOWING CONCERNFROM REVIEW OF THE QTC FILE: "DID

NOT REPLACE SWITCHES IN CONTROL ROOM." AFTER REVIEWHOF FILE, CONCERN INDICATED THAT SWITCHES HERE ORDERED TO BE REPLACED BUT WERE NOT. ONLY NAME PLATES AND TAGS REPLACED.

ELECTRICAL JUNCTION BOXES ARE NOT PER G-40 AND ELECTRICAL STANDARD DRAIIIHGS, IN THAT THEY ARE MANUFACTURED 0F GALVANIZED STEEL INSTEAD OF SHEETSTEEL WITH PAINT ONt BOTH SIDES. THESE JUNCTION BOXES MAY BE FOUND THROUGHOUT THE PLANT, ESPECIALLY Ill THE ADGB (AUXILLIARY DIESEL GENERATOR BUILDING C/I HAD HO FURTHER INFORMATION. NO FOLLOW UP REQUIRED.

480 VOLT SHUTDOWN PANELS (UNITS 1, 2& 0) HAVE A POTENTIAL NONCONFORMANC

E WHICH HAS NOT BEEN DOCUMENTED FORRESOLUTION. DETAILS KNOWHN TO QTC, WITHHELD DUE TO CONFIDENTIALITY. NOFURTHER INFORMATION MAY BE RELEASED.

NUCLEAR POWER DEPARTMENT CONCERN.CI HAS NO FURTHER INFORMATION. NO

FOLLOW UP REQUIRED.

REF. SECTION ICAT - COSUBCAT - 191

,.. 3 ..3 ) . ,s

14.3 3.13 4.~34,J

~.I.3, &3

.1 -85-913-00101T500Z

CO 19100 N WBN 1 Y Y .Y Y2 SR SR SR SR

1-85-524-IWBU QTCIa.t.1),.,.t 14.1,

.3P-85-016-00301T50233

CO 19100 N WBN .1 fl N N Y2 NA NA NA SR

QTC "2-1 •3.2.1 4.Ii

~il.l , I~

4 CONCERNS FOR CATEGORY CO SUBCATEGORY 191

CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.

- -'.'c~nr.:.......-



REVISION NUMBER: 2

PAGE 1 OF I

ATTACHMENT B

List of Evaluators

John Campbell B[,NHenry Loftis SQN, BFN, and BLNGary Lyles - BLNRob Brown - WBN



REVISION NUMBER: 2

PAGE 1 OF I

ATTACHMENT C

List of Concerns by Issue

Issue

1.2.1 Pianels


1.2.3 Hand Switches

Concerns

WBP-85-016-003

IN-85-913-001

HI-85-045-001HI-85-093-N02