IR 05000424/1985035
| ML20138Q841 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/11/1985 |
| From: | Blake J, Girard E, Hallstrom G, Vias S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138Q828 | List: |
| References | |
| 50-424-85-35, IEB-79-03, IEB-79-3, IEB-83-06, IEB-83-6, NUDOCS 8512300028 | |
| Download: ML20138Q841 (61) | |
Text
{{#Wiki_filter:! [@Kfc -- o UNITED STATES . 'o NUCLEAR REGULATORY COMMisslON [ ',$ REGION 11 g j 101 MARIETTA STREET.N.W.
- ATLANTA, GEORGIA 30323
%...../ Report No.: 50-424/85-35 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 Construction Permit No.: CPPR-108 Facility Name: Vogtle Unit 1 Inspectors: / / - E. H. Girard Date Signed ( !} l2 I W S Jy Viis Date Signed
/ &[//[5(' / ' < ' Hallstrom Date Si'gned . Approved by: .. '/N /2-sIf J.f.fBlale, Section Chief Date' Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This special, announced inspection entailed approximately 1000 inspec- ,. tor-hours on site and in Region II office in the area of Readiness Review Module 4, Mechanical Equipment and Piping.
Results: No violations or deviations were identified.
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e a INTRODUCTION This inspection report documents Region II inspection activities relative to the evaluation of Georgia Power Company's (GPCs) Readiness Review Module 4, Mechani-cal Equipment and Piping. The inspection activity was started during NRC Inspec-tion 424/85-29 (reportcd August 5,1985) and was completed during the inspection period described in this report.
The inspection was conducted to aid in determining whether Module 4 provided an acceptable basis for its reported conclusion - that the Vogtle Electric Generat-ing Plant (VEGP) Unit 1 mechanical equipment and piping was in accordance with applicable licensing commitments.
The inspection report contains a description of the inspectors' activities and of their preliminary findings.
GPC will be afforded an opportunity to respond to this report and its findings before a final NRC evaluation of the GPC Module 4 Readiness Review is developed and reported.
Readiness Review Module 4 is one portion (module) of a many part review being conducted by GPC to aid in assuring that VEGP Unit I will be operationally ready in accordance with scheduled plans for obtaining an operating license. The GPC Module 4 review activities, data and results are summarized in their Module 4 report, which was submitted to the NRC June 25, 1985. The module report consist-ed of eight sections: 1.0, Introduction; 2.0, Organization and Division of Responsibility; 3.0, Commitments; 4.0, Program Description; 5.0, Audits; 6.0, Program Veri #ication; 7.0, Independent Design Review; and 8.0, Program Assessments / Conclusions.
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2 REPORT DETAILS 1.
Licensee Employees Contacted Licensee Employees D. O. Foster, Vice President & Project General Manager W. T. Nickerson, Deputy Project General Manager P. D. Rice, Vice President & General Manager Quality Assurance, (QA) C. E. Belflower, Quality Assurance Site Manager, Operations , G. Brockman, General Manager, Vogtle Nuclear Operations Division E. D. Groover, QA Site Manager, Construction ^ C. W. Hayes, Project Quality Assurance Manager R. W. McManus, Readiness Review (RR) Discipline Manager, Construction G. McWhorter, RR Comitments Identification Leader Other Organizations W. C. Ramsey, Southern Cc.npany Services (SCS), RR Project Manager G. R. Trudeau, Bechtel Power Corporation (BPC),RR Special Assistant R. D. Andrews, BPC RR Team Member G. C. Bell, BPC, QA Representative D. Bush, SCS, RR QA Representative D. L. Kinnsch, BPC, Project Field Engineer C. R. Myer, BPC, RR Mechanical Design Team Leader A. Nakashima, BPC, RR Discipline Manager (Appendicies) R. C. Somerfeld, BPC, RR Mechanical Construction Team Leader J. Steele, Pullman Power Products (PPP) Quality Assurance Manager C. M. Sumers, BPC, RR Team Member Z. G. Tucker, BPC, RR Team Member W. M. Wright, SCS, RR Discipline Manager (Design) NRC Resident Inspectors J. Rogge, Senior Resident Inspector (Operations) R. Schepens, Resident Inspector 2.
Exit Interviews The inspection scope and findings were summarized during exit interviews conducted on August 2, August 23, August 30, and September 6, 1985.
Addi-tional telephonic clarifications were conducted on August 15, September 18, and September 27, 1985. A summary of items identified during the inspection is listed below, a.
Unresolved Item 424/85-35-01, Assurance of Adequate Readiness Review Coverage of Module 4 - paragraph 3.b.
b.
Inspector Followup Item 424/85-35-02, Omission of Westinghouse Offsite Activities from Readiness Review - paragraph 3.c.
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c.
Unresolved Item 424/85-35-03, Design Control of Intermediate Pipe Breaks - paragraph 4.d.(4).
d.
Unresolved Item 424/85-35-04, Design Control of Moderate - Energy Class 1 Piping - paragraph 4.d.(5).
e.
Unresolved Item 424/85-35-05, Implementation of ANSI N45.2.11 - para-graph 4.d.(11).
f.
Unresolved Item 424/85-35-06, Adequacy of Preparation and Revisicn of Design Criteria (DCs) - paragraph 7.b.(3)(a).
g.
Inspector Followup Item 424/85-35-07, Calculation Corrective Actions - paragraph 7.b.(3) (b).
h.
Inspector Followup Item 424/85-35-08, Maximum Design Pressure Discrepancy - paragraph 7.b.(3)(c).
i.
Unresolved Item 424/85-35-09, Adequacy of Drawing and DCN Reviews - paragraph 7.b.(3).(c).2.
j.
Inspector Followup Item 424/85-35-10, Review of Construction Specifi-cations and Procedures - paragraph 7.b.(3).(d).
k.
Unresolved Item 424/85-35-11, Inadequate Review of Procurement Specifi-cations - paragraph 7.b.(3).(g).6.
1.
Unresolved Item 424/85-35-12, Inadequate Review of Vendor Drawings - paragraph 7.b.(3).(h).2_.
m.
Unresolved Item 424/85-35-13, Inadequate Resolution of Readiness Review Design Verification Findings - paragraph 7.b.(3).(i)2_.
n.
Unresolved Item 424/85-35-14, Undersized /0verground Welds - paragraph 7.c.(2),(c).1._ o.
Unresolved Item 424/85-35-15, Undocumented Piping Supports - paragraph 7.c.(2).(c).2.
p.
Inspector Followup Item 424/85-35-16 Inconsistency in the Use of Low Carbon Stainless Steel - paragraph 7.c.(2).(c).3.
q.
Inspector Followup Item 424/85-35-17, Inadequate Resolution of Readi-ness Review Findings - paragraph 7.c.(2).(d).4_.
The licensee did identify as proprietary some of the materials provided to and or reviewed by the inspectors during this inspection; however, details from these materials are not included in this report.
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3.
Section 1.0, Introduction a.
Section 1.0 of the report indicated that Module 4 covered design and construction commitments and activities for ASME Section III mechanical equipment and piping, with certain exceptions.
It identified these exceptions in its Table 1.1-1 and stated they would be covered in other Readiness Review documents that would be submitted for NRC evaluation later.
From subsequent review of the module report, discussions with the Readiness Review staff, and examinations of Readiness Review documen-tation, the inspectors identified additional exceptions to the Module 4 scope description given in Section 1.0, Table 1.1-1.
For example, the inspectors found that none of the offsite design, procurement or manufacturing activities of Westinghouse, who was responsible for the plant's Nuclear Steam Supply System (NSSS), were to be included in the Readiness Review.
In their previous onsite evaluation of Module 4, the inspectors had identified an Inspector Followup Item 424/85-29-01, Readiness Review Module 4 Boundaries, expressing their concern that the boundaries on Westinghouse activities to be assessed in Module 4 were unclear.
The inspectors have determined that this item should be closed and replaced by two others, b.
First, there apparently was not a sufficient GPC Readiness Review description of Module 4 scope or boundaries to assure that either the individuals who performed the Review or the NRC inspectors fully understood what coamitments and activities were to be covered in Module 4.
The inspectors identified this as Unresolved Item (UNR) 424/85-35-01, Assurance of Adequate Readiness Review Coverage of Module 4.
This item will remain open pending further NRC examination of GPC Readiness Review submittals to determine the extent to which important activities and commitments for mechanical equipment and piping may have been omitted or inadequately treated in the Review.
Relative to further NRC examination of GPC submittals that will be conducted for UNR 424/85-35-01, the inspectors have identified the following nechanical equipment and piping commitments and activities for which they believe adequate Readiness Review coverage should be verified: (1) Readiness Review commitments associated with criteria for pressure relief devices that are described in Table 1, Note (3) in this report.
(2) Technical aspects of activities for design of mechanical equipment and pi ing (reportedly to be covered in the independent design review. (3) Piping stress analysis (reportedly to be covered in Module 11).
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. (4) Welding procedure and welder qualifications, as they relate to pipe welding (reportedly to be covered in Module 8).
(5) Interface activities with Westinghouse (reportedly to be covered in Module 16).
(6) Qualification of QC personnel responsible for inspection of mechanical equipment and piping (reportedly to be covered in Readiness Review Appendix F).
(7) Control of design of mechanical equipment and piping (reportedly to be covered in Readiness Review Appendix B).
l (8) Document control (reportedly to be covered in Readiness Review Appendix D).
J NOTE: Of particular interest are the review, approval, and issuance process for revisions to specifications and procedures; and assurance that all review parties understand the basis for
drawing revisions.
(9) Equipment qualification (reportedly to be covered in the indepen-dent design review and/or in Readiness Review Appendix J).
t (10) Valve operators (reportedly to be covered in Module 20).
! (11) Piping material controls and equipment maintenance (reportedly to be covered in Readiness Review Appendix E).
' (12) Procurement activities for piping and mechanical equipment (re- ' portedly to be covered in Readiness Review Appendix C).
c.
Second, Readiness Review management informed the inspectors that the l , Westinghouse offsite activities had been omitted from the Review , ! because Westinghouse had such extensive experience in the area covered . by them and because their performance had been so often and extensively l audited by the NRC and others.
The inspectors are concerned that the omission of offsite Westinghouse activities from the Readiness Review is significant and that further evaluation will be required concerning this omission.
This is identified as Inspector Followup Item 424/85-35-02, Omission of Westinghouse Offsite Activities from Readiness Review.
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4.
Section 3.0, Commitments a.
Section 3.0 provides the commitments GPC identified for Module 4 and the verification of their implementation. This section of the Module 4 < report was extensively evaluated by the NRC inspectors.
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Subsections 3.1 through 3.3 of Section 3.0 provided brief introductory information - including a definition of a commitment, information regarding the sources of the comitments, and a listing of the typical documents that were determined to implement commitments.
Subsections 3.4 and 3.5 of Section 3.0 presented respectively, a matrix listing the comitments identified and a matrix listing the documents considered to implement the comitments.
In addition to providing a listing of the comitments identified, Subsection 3.4 provides an identification of all the other Readiness Review modules to which each Module 4 comitment was assigned and a determination as to whether implementation of the commitment was a design organization responsibil-ity, a construction organization responsibility or the responsibility of both.
The Subsection 3.5 matrix includes, for each comitment, an identification of design and/or construction documents that were determined to implement the comitment.
Region II inspectors reviewed. the material presented in Module 4, Subsections 3.4 and 3.5 matrices to determine whether the Readiness Review had satisfactorily identified comitments for the module and if it had satisfactorily determined their inclusion in implementing documents.
b.
Early in the performance of the inspection the inspectors held discus-sions with the Readiness Review personnel to determine how they had accomplished the identifications of commitments and verification of comitment implementation documented in the Module 4 report matrices.
The Readiness Review personnel related that these activities were performed as follows: (1) Readiness Review program procedures were provided'which included guidelines on comitment identification.
These procedures define a comitment as an obligation to comply with an industry standard, Regulatory Guide (RG), Branch Technical Position (BTP), or owner plan of specific action.
NOTE: This definition differs from the comitment definition stated in Module 4 report Subsection 3.2, which did not include an " owner plan of specific action" as a comitment.
(2) Readiness Review personnel were required to identify comitments from a review of the VEGP Final Safety Analysis Report (FSAR), GPC responses to Inspection and Enforcement Bulletins (IEBs), and GPC responses to NRC generic letters.
The majority of comitments were taken from the FSAR. The first phase of comitment identifi-cation required a detailed search of each FSAR chapter to identify and subgroup (assign to a module or modules) all comitments within the chapter.
A copy of the FSAR was annotated to indicate the boundaries, module assignments, and a reference number for each comitment.
This information together with results from review of responses to IEBs and to generic letters was entered - _.
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into a computerized database (the master Readiness Review computer list).
Database entries used key descriptive phrases to indicate the commitment subject and document feature involved.
A tabula-tion of the master computer list was then completed for all commitments assigned to Module 4.
(3) Follow-on phases of commitment identification were completed by teams of Readiness Review personnel who were actively involved in Module 4 Readiness Review work.
There were two Readiness Review teams (RRTs) for Module 4, a design specialized RRT and a con-struction specialized RRT.
The RRT members refined and completed final identification and assignment of Module 4 commitments and necessary corrections were entered into the master computer list.
The comitment identification matrix included in Section 3.4 of the Module 4 report was completed by tabulating a listing from the master computer list of all commitments so assigned.
(4) Responsibility for verification of comitment implementation for Module 4 was assigned to either the design RRT, the construction RRT, or both, depending on the comitment involved.
RRT members were required to verify objective evidence of commitment implemen-tation from design and construction documents for all Module 4 commitments.
(5) The majority of design comitment implementation verification was accomplished by the design RRT through examination of system Design Criteria (DC) documents, procurement specifications, or design calculations for reference to or reflection of the commit-ment involved.
(6) The majority of construction comitment implementation verifica-tion was accomplished through construction RRT examination of i construction procedures.
c.
The inspectors performed their evaluation by examining the Readiness Review identification and implementation for a sample of comitments which the inspectors independently selected.
For their sample the inspectors chose 70 FSAR entries and all (nine) of the IEB responses that described safety-related commitments that appeared to apply to Module 4.
(Note: Hereafter commitments identified and numbered by the Readiness Review will be underlined to differentiate them from other usages of the word.)
The Module 4 comitment and implementation matrices were then checked to determine if the Readiness Review had identified comitments for the FSAR entry locations and for IEB res-ponses, i.e., Readiness Review comitments that might represent the comitment material in the inspectors independently selected sample.
From the Module 4 commitment and implementation matrices, the inspec-tors identified 75 comitments that appeared to represent comitments from their selected sample.
Commitments representing the remaining nine of the inspectors' selected sample could not be found in the Module 4 - - - - - - - - - -
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4 matrices.
For seven of the missing nine, the inspectors accepted Readiness Review personnel explanations and rationales indicating they were addressed by commitments assigned to other Readiness Review modules.
Of the two remaining, one was shown to have not been identi-fied as a comitment by the Readiness Review; and the other, although , identified as a comitment, had been erroneously omitted from assign-ment to Module 4.
These latter two, together with the 75 already found in the Module 4 matrices, provide a total of 77 Module 4 comitments.
These 77 and the seven (for a total of 84) of the inspectors' original sample that are ascribed to other Readiness Review modules are listed in Table 1 of this report. The 77 Module 4 comitments represent about 30% of the (260) comitments given in the Module 4 report (Subsections i 3.4 and 3.5) matrices.
, The inspectors examined the Readiness Review identification and verification of implementation of comitments through a process that included: J (1) Detailed examination of the subject and feature descriptions provided for each comitment in the Module 4 (Subsections 3.4 and 3.5) matrices to determine if they addressed appropriate comitment material.
(2) Examination of the Readiness Review annotated FSAR to determine if all the comitment material was acknowledged.
e - (3) Review of the implementation documents identified in the (Module 4 Subsection 3.5) implementation matrix to determine if they comp-letely implemented the comitments stated in the associated FSAR Sections or IEB responses, d.
The inspectors found that 17 of the 77 Module 4 comitments (over 20%) " associated with their independently selected sample were either inade-quately identified, or inadequately verified as implemented, or both.
These findings are indicated in Table 1.
Because of their signifi-cance, the basis for each of these findings is summarized below by comitment: ' (1) Comitment 332 This comitment was taken from FSAR Subsection 6.1.1.1.2 (Engi-neered Safety Features (ESF) Construction Materials) which re-quires that "no cold worked austenttic stainless steels having
yield strengths greater than 90,000 psi are used for components of the ESF."
The commitment was properly identified and assigned to Modules 16, 20, and 18A. However, it was improperly excluded from '
Module 4 as ESF components (mechanical equipment and piping) are covered by Module 4.
Therefore, its identification was inadequate since it was not included in the Module 4 matrix and its implemen-tation was not assessed. The inspectors brought the matter to the attention of Readiness Review management who agreed that the <
commitment should have been included in Module 4.
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l l (2) Comitment 384 , l This commitment was taken from FSAR Tat,le 9.2.1-3 (NSCW System
Component Data) which requires that Nuclear Service Cooling Water l (NSCW) pumps be designed to ASME III, Class 3 requirements. This ! comitment was correctly identified and assigned to Module 4.
RRT verification of implementation was based on the reference to ASME III included in Section 2.0 of-document DC-1202.
However, the relevant ASME Class was not identified in Section 2.0 of DC-1202 and verification of implementation was incomplete.
(3) Comitment 950 This commitment was taken from FSAR Subsection 3.6.2.1 (Criteria Used to Define High/ Moderate-Energy Break / Crack Locations and Configurations) and was assigned to Module 4.
The comitment concerns ASME Class 1 piping outside the primary reactor coolant loops and requires the postulation of high-energy break locations at terminal ends and at intermediate locations. The boundaries of ' the commitment were identified by RRT in an annotated copy of the FSAR and confirmed by discussions with Readiness Review personnel.
The boundaries were chosen so as to omit the requirements for postulation of breaks at terminal ends.
Further, the requirements for postulation of breaks at intermediate locations were identi-l fled as separate Module 4 comitment 954.
The resultant was that commitment 950 was lim'ted to the simple l reference to ASME Class 1 piping in FSAR Suosection 3.6.2.1.1A.
l None of the actual requirements were identified as part of the ~ comitment.
l (4) Commitments 951, 954, 956, and 1543 i Module 4 comitments 951, 954, 956, and 1543 address sections of the FSAR that provide criteria for postulating intermediate pipe , l break locations. They are included, respectively, in FSAR Subsec-l tions 3.6.2.1, 3.6.2.1.1A, 3.6.2.1.1B and 1.9.46.
Exceptions to l the pipe break criteria contained in them were requested by GPC by letter dated April 26, 1984, and granted by NRC by letter dated l June 28, 1984.
The NRC approval was conditioned upon GPC imple-
mentation of certain programatic controls - including controls i that would assure welded attachments would be at least five pipe l diameters from postulated break locations.
The exceptions to the FSAR criteria were used in certain design calculations and RRT was aware of their use as evidenced by RRT Finding 4-75.
This Finding identified deviations from the intermediate pipe break criteria described in the FSAR and the response to the Finding pointed out l the exceptions that had been granted by NRC. The exceptions Snd, l especially, conditions on their application were not considered by the RRT in their verification of implementation for comitments 951, 954, 956, and 1543.
The exceptions and the conditions oT their use should have been considered portions of the commitments, - - - - - - -
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and, as they were not, RRT identification and verification of , implementation for comitments 951, 954, 956, and 1543 was ' incomplete.
i The inspectors questioned whether GPC had provided controls to assure that the five pipe diameter condition for application of
the exceptions had been implemented.
GPC's response indicated that the issue identified by the inspectors will be addressed in Module 11.
The possible lack of controls is considered an unre-solved item concerning possible inadequate design control of intermediate pipe breaks and is identified as Unresolved Item 424/85-35-03, Design Control of Intermediate Pipe Breaks.
. , (5) Comitment 959 This Module 4 comitment was taken from FSAR Subsection 3.6.2.1.2.4.C which requires postulation of through-wall leakage cracks on moderate energy Class 1 piping where the maximum stress in the piping is greater than 1.2 Sm. The Module 4 report imple-mentation matrix indicates that this commitment was verified as implemented by Table 1 in 0C-1018.
However, this comitment was not implemented by DC-1018 and GPC has indicated that DC-1018 will be revised to include it.
This is considered an unresolved item
concerning design control of moderate energy Class 1 piping and is < identified as Unresolved Item 424/85-35-04, Design Control of Moderate-Energy Class 1 Piping.
(6) Comitment 1599 This Module 4 comitment was taken from in FSAR Subsection 1.9.148 ' which requires conformance to RG 1.148, March 1981, Functional Specification for Active Valve Assemblies in Systems Important to Safety in Nuclear Power Plants.
FSAR Table 3.9.B.3-10 provides an evaluation of specifics of RG 1.148 requirements which are in . addition to the ASME Code requirements versus conformance at Plant
Vogtle. RRT verification of implementation of this commitment was based on conformance to the ASME Code as referenced in Table 1 of DC-1010.
i Reference to the ASME Code did not ensure conformance to RG 1.148 and RRT verification of implementation of the comitment was inadequate.
(7) Comitment 1841 and 1842 < These Module 4 comitments were taken from FSAR Subsection ' 3.6.2.3.2.2, which provide requirements associated with break propagation in large Reactor Coolant System (RCS) piping.
The , ' requirement that propagation of the break to the unaffected loops be prevented to ensure the delivery capacity of the accumulators -. - --. -~ - -. -. -. - . - . - _.. - - - _ -.
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1 , and low head pumps was identified as comitment 1841.
The
requirement that propagation of the break on the affected loop j does not exceed 20% of the flow area of the line which initially l ruptured 'was identified as comitment 1842. However, the follow-ing additional prerequisite criteria (FSAR Subsection 3.6.2.3.2.1)
were not identified as part of commitments 1841 and 1842: (a) The minimum performance capabilities of the engineered safety systems are not reduced below that required to protect against the postulated break, i (b) The containment leak tightness is not decreased below the
design value.
(c) Propagation of damage is limited in type and/or degree to the
extent that: -1.
A pipe break which is not a loss of Coolant Accident (LOCA) will not cause a LOCA, steam, or feedwater break.
2.
An RCS pipe break will not cause a steam or feedwater break, and vice versa.
! Failure by RRT to correctly identify all comitments in comit ments 1841 and 1842 caused their subsequent verification of implementation to be incomplete.
(8) Comitment 2486 This Module 4 comitment was taken from FSAR Subsection 5.4.7.2.5, _ which requires that the entire Residual Heat Removal (RHR) system be designed as Nuclear Safety Class 2 (ASME III, Class 2) with i exceptions of the suction isolation valves, which are Safety Class
1 (ASME III, Class 1).
The Module 4 report implementation matrix
indicates that this comitment was verified as implemented by DC-1205.
However, the exception that suction isolation valves be ' Class 1 is not included in DC-1205 and RRT verification was incomplete.
, (9) Commitment 4675 This Module 4 comitment was obtained from GPC's response to IEB-83-06 (Nonconforming Materials Supplied by Tube-Line Corpora-tion).
It concerns the adequacy of piping materials supplied by a . vendor.
In the response letter, dated November 23, 1983, GPC t comitted to take the following actions to assure that the piping materials they had received from the subject vendor would comply with the applicable code requirements: >
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(a) Conduct audits of the vendor and the vendor's suppliers to assure that there was satisfactory traceability for and welding performed on the materials which they supplied.
(b) Perform physical and chemical property checks on samples of the materials supplied by the vendor to verify compliance with specifications.
A further comitment indirectly implied by the licensee's response was to determine what materials the vendor had supplied to Vogtle.
The RRT did not identify the above comitments but rather identi-fied comitment 4675 as a commitment to invoke ASME Code Sub-article NX-2600 to accept the material.
The inspectors found that, although GPC referenced NX-2600 in their response it was not a comitment.
The reference to NX-2600 was simply a descriptive statement identifying the normal Code requirements that had been utilized.
It was not a pledge to perform any special action in response to the IEB.
Readiness Rcview management stated that the GPC pledge to perform property checks and audits was considered descriptive and not in accordance with their guidelines for comitments. The inspectors reviewed the Readiness Review commit-ment definition described in a (unsigned, unapproved, and undated) guidance document that Readiness Review personnel stated provided the comitment identification criteria utilized.
The inspectors found the guidance somewhat unclear, but noted that it stated that the definition of a comitment included "an obligation to comply with owner plans of specific actions". The inspectors found that the audit and the material property checks proposed in response to the IEB were owner plans of action and that, even using the Readiness Review definition, they should have been cons'dered commitments.
The RRT identified the normal material procurement specification as implementing the IEB response comitment. The inspectors found that this specification provided only normal Code requirements and did not invoke any requirement that would address concerns ex-pressed by IEB-83-C6.
(10) Comitments 4890, 4891 and 4893 These three Module 4 commitments were obtained by GPC from their response to IEB-79-03 (Longitudinal Defects in ASME SA-312 Type 304 Stainless Steel Pipe Spools Manufactured by Youngstown Welding and Engineering Company).
The concern addressed by the IEB was that undetected unsatisfactory weld defects were found in piping that had been supplied to the nuclear industry from an identified materials manufacturer. The defects were stated to be in longitu-dinal weld seams which had been welded without filler metal. The piping with the defective welds was reportedly manufactured and examined to meet ASME Section III criteria, which permitted weld . - - - - - - - - - - - - - - - - - - -- - - - - - -
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13 acceptance on the basis of ultrasonic examination as an alterna-tive to radiography.
The manufacturer was understood to have performed ultrasonic examinations in accepting the defective welds.
Actions requested by the NRC in response to the IEB included (1) identification of longitudinally welded piping material supplied by the subject manufacturer for safety-related applications and (2) volumetric re-examination of longitudinal welds in the pipe to assure their acceptability.
In their re-sponse letter, dated May 9,1979, GPC stated their identification of related piping materials that had been installed in Vogtle safety-related piping systems.
In describing the use of the pipe they stated that it had been used in pipe spools " designed in accordance with the 1974 edition of the ASME Code, Section III, Class 2 (including addenda through Sumer 1975) and Code Case N-32".
This information was incorrectly identified as commitments 4890 and 4891.
In responding to the concern for the acceptability of the longitudinal welds in the piping material, GPC stated that the seam welds had received 100% radiographic examination, that the spools had t'een accepted by GPC's inspector, and that the piping material manufacturer identified in the IEB had been removed from the spool fabricator's approved bidders list.
From the above, the Region II inspectors identified four actions which could be construed to be comitments: (a) Identification of related piping (b) 100% radiography of the longitudinal seam welds in the material (c) Acceptance by GPC's inspector (d) Removal of the manufacturer from the approved bidders list Of the above, RRT recognized only the 100% radiography as a commitment (4891), and this was not sufficient identification to assure that the comitment was understood. The inspectors found, in examining the RRT implementation verification, that RRT had considered the radiography to be a standard code requirement.
It was in fact, not a definite code requirement.
As indicated in IEB-79-03, ultrasonic examination was a code acceptable alterna-tive examination method.
Ultrasonic examination was the method that apparently failed to detect defects in the defective welds described in the IEB.
The inspectors found that, even had comitments 4890 and 4891 been correctly identified as comitments, they were not adequately verified as implemented.
The document entry referenced in Module 4 as implementing the comitments refers only to ASME Section !!! and does not address the other aspects of the stated comitments . _ . _ _ -. , -
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! l I l (Code Class and revision and Code Case number).
The identifica-l tion and verification of implementation for comitments 4890, 4891 and 4892 is incomplete on the basis described above.
(11) Unidentified Comitment (ANSI N45.2.11) FSAR Section 17.1.2 states that the GPC QA program will conform with ANSI N45.2.11 Draf t 2. Rev. 2 (Quality Assurance Require-ments for the Design of Nuclear Power Plants).
FSAR Section 17A.3 states that the Bechtel (GPC's Architect and Engineer) QA program is responsive to the intent of ANSI N45.2.11 Draft 2, Rev. 2.
RRT did not identify these statements as a comitment.
The inspectors did note, however, that the Module 4 report, Section 6.1 indicated that ANSI N45.2.11 was applicable to the Vogtle design and portions of ANSI N45.2.11 were referenced in some RRT checklists for review of design documents. The inspectors consid-er that additional NRC examination of design program documents and discussions with GPC will be required to determine whether ANSI N45.2.11 was satisfactorily implemented.
Pending completion of the examination and discussions, the matter is considered an unresolved item in that design control measures may not have . assured implementation of the standard.
This is identified as ! Unresolved Item 424/85-35-05, Implementation of ANSI N45.2.11.
l l S.
Section 4.0, Program Description Section 4.0 provides a summary description of VEGP program work activities for design and construction of mechanical equipment and piping.
This section did not receive a detailed NRC review since it was essentially l
descriptive information rather than assessment data.
It was represented as ! a summary description of the program as understood by the personnel perform-l ing the Readiness Review and it wat examined by the NRC inspectors to l determine if it appeared to be a satisfactory summary description.
The l inspectors judged the program description based on their knowledge of the program from their past inspections of VEGP (e.g., see NRC Inspection Reports 424/80-02, 83-12, 84-12, 84-23, 84-36 and 85-14). which were mainly l inspections of construction activities; and on the basis of experience > l gained in their review of program procedures and other documents during i performance of the inspection described herein. The inspectors are aware of l no concerns with regard to the adequacy of GPC's program other than those ' which are documented in NRC reports or/and will be tracked and resolved as part of the licensing process for VEGP.
6.
Section 5.0, Audits l Section 5.0 describes a review of past audit findings (ir,cluding NRC inspec-l tion findings) that was conducted as part of the Module 4 Readiness Review.
GPC performed the review to assess the adequacy of the emphasis they had l placed on resolution of audit findings related to the scope of Module 4.
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This area was not inspected in detail by the NRC Inspectors because it assessed data that was more indirectly obtained than that described in other important report sections (e.g. Module 4 report Sections 3.0 and 6.0) and because the NRC was already familiar with much of the data (e.g., from the findings of.NRC inspections, review of the INP0 self assessment, and review of items reported in accordance with 10 CFR 50.55e).
The NRC inspectors examined the data and rationale presented to determine if it supported the section's conclusion, which was in essence, that proper emphasis had been placed on resolution of audit findings.
The inspectors also examined the material presented relative to NRC findings to determine if it was an accurate presentation, basing their evaluation on their own past knowledge of NRC findings (as from inspections the Region had conducted - see paragraph 5 of this report for examples) and from sumary information
they obtained by review of NRC reports assessing GPC's performance (NRC Reports 424/84-01,33-06and82-14).
The inspectors found that the presentation of NRC findings was accurate and ' that the data and raticnale presented supported the section's conclusions.
7.
Section 6.0, Program Verification a.
Section 6.0 describes GPC's verification to assure that the VEGP design and construction programs adequately implement comitments.
It con-tains summary data supporting the review assessment, including Readt-ness Review findings (violations of licensing comitments, project procedures or engineering requirement identified by the reviewers) and their resolution.
The Readiness Review tindings were classified into levels of importance to plant safety. The following levels were used: Violation of licensing commitments, project procedures, I - or engineering requirements with indication of safety concerns.
Violation of licensing commitments or engineering II -
j requirements with no safety concerns.
Violation of project procedures with no safety concerns.
!!! - Section 6.0 is divided into two subsections, Subsection 6.1, which describes design program verifications and Subsection 6.2, which describes construction program verification.
The verifications in the two subsections were performed completely independent of one another and, as a consequence, GPC did not check any piping or mechanical j equipment items through the entire process of design and construction.
NRC inspectors who evaluated this section examined both design and construction aspects of some items (e.g., an RHR encapsulation vessel , - - -. - . - - - - - - -. - - - - - .. - - - .. - - - - - - - - . - - - . -. .. - - - . - - -. - - . . . - - - - - - - - -.. - - -.. - - - . - - .
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i l ! and associated piping) to aid in ensuring that significant aspects of I work processes were not overlooked in the assessment.
The NRC er. amination of the Readiness Review described in the respective design and construction subsections is provided below.
b.
Subsection 6.1, Design Program Verification l l (1) As described in the Module 4 report, Readiness Review verification I of the design program was performed by a design RRT consisting of ' six personnel experienced in power plant design engineering. The verification was intended to ensure, through sampling, that the design processes for mechanical equipment and piping had been adequately controlled and had resulted in proper implementation of licensing commitments in design documents.
The module report describes the design program verification as having been performed in two phases.
l ' Phase I i ! Phase I was the verification of implementation of commitments ! documented in the Module 4 report Subsection 3.5 implementation matrix.
Inspection of this phase is discussed in paragraph 4 of this report.
Phase !! Phase !! was the verification that (1) the design program commit-ments and requirements were satisfactorily carried through and , implemented in second-order design documents a d that (2) the ! design activities were conducted in accordance with project procedures and QA requirements.
. The design RRT conducted Phase II by reviewing samples of commit-ments, requirements, and the documents that represented program design activity accomplishment (e.g., drawings, procurement specification, and calculations). Samples were reportedly select-ed by the RRT based on their applicability to systems and equip-ment that were considered representative - the RHR, NSCW and AFW systems and the CCW heat exchangers and boric acid storage tank.
(2) NRC Inspection of Readiness Review Verification of Commitment and Requirement Implementation in Second-Order Design Documents l The design commitments and requirements which were verified to have been implemented in second-order design documents by the RRT during the Phase !! verifications are identified in Module 4 report Tables 3.5 and 6.1.2.
The RRT definition of second-order design documents was, apparently, that they were any documents other than design criteria documents.
According to the Module 4 l . - - - - - - - -. - - - . - - - - - - - - - - - - - - - - . - - - - - -
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report, the comitments verified in such secor.d-order design documents were approximately 20% of the Module 4 design comi tments. The inspectors performed their examination of th'e Readiness Review verifications as follows: (a) Sample Size Verification The inspectors examined the commitments in the Module 4 Tables 3.5 and 6.1.2 to determine if the number verified as implemented in second-order design documents (in accordance with the apparent Readiness Review definition of second-order design documents) was as stated.
The inspectors determined that the approximately 20% stated in the module report was accurate.
However, the inspectors determined that the Readiness Review verifications were often only partial verifications, in that: 1, Where implementation was required to be carried out in many documents, only a sample may have been checked and the size of the population of implementing documents was not reported (e.g., comitments 4929 and 4927 in the commitments verification matrix).
j
Where the implementation was accomplished through offsite actions, details of offsite implementation were J sometimes not considered.
Instead, letters stating that the actions had been performed were considered adequate l verification (e.g., comitment 4673 in the implementa-tion matrix, comitment 4931 and requirements from FSAR Sections 6.3.2.2.4 and 6.3.2.1 in the comitments verification ratrix).
3, The review of design calculations as secondary comit-ment implementation documents did not verify the techni-cal adequacy of commitment implementations.
The implementation verifications stopped at design documents, the accurate transformation of design comit-ments and requirements into hardware features was not directly assessed. (b) Determination of the Adequacy of Readiness Review Verification The inspectors reviewed the design commitment and requirement implementation verifications listed in the Readiness Review comitments verification matrix (Module 4. Table 6.1-2) by . - - - - - . - - . . - . - - - -. -
. , . .
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reverifying implementation of a selected sample. The inspec-tors' sample included 11 of the 40 commitments and requirements listed in the matrix plus one related commit-ment.
The inspectors sample and.the results of their re-verifications are given in Table 2 of this report.
The inspectors found, as indicated in Table 2, that the implemen-tation was correct as stated in the Readiness Review report.
, (3) Inspection of Readiness Review Verification That Design "ocuments are Developed and Utilized in Accordance With Project Procedures and Design OA Requirements The RRT reviewed selected samples of design documents to verify their proper preparation and use. The verifications were perform-ed using checklists where considered appropriate.
The NRC inspectors selected and reviewed samples of the documents reviewed by the RRT and examples of the RRT findings. The inspec-tors also examined and evaluated additional samples of documents, not reviewed by the RRT, to provide a broader coverage for some equipment items and to avoid checking only documents that had already been checked by the RRT.
For most of their ir.spection the inspectors examined the documents utilizing the same criteria and checklists as the RRT.
The results of the inspectors' examina-tions and evaluations.were then compared with the results obtained by the RRT on the same items.
A~ summary of the types and number of design documents reviewed by the RRT and the NRC inspectors is given in Table 3.
The inspectors' evaluation and resultant findings are described below under headings for the type of design documents reviewed and a heading for the Readiness Review Find-ings.
(a) Design Criteria The module report indicates that the RRT reviewed Design Criteria documents (DCs) to ascertain whether they imple-mented the Module 4 commitments. This was done in the develop-ment of their implementation matrix.
The NRC inspectors , did not extensively review the DCs but instead examined them to verify RRT implementation checks and as necessary to perform evaluations of other items (e.g., system drawings) to determine if the items complied with the DCs. These DCs are identified in Tables 1 and 5 of this report.
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Reviews performed by the inspectors revealed discrepancies in three DCs that were not. identified by the RRT in their review of the same documents: 1_ A failure to incorporate revised intermediate pipe break criteria and controls in DC-1018 (partially identified by the RRT in Readiness Review Finding 4-75, see the discussion of commitments 951, 954, 956, and 1543, in Subsection 4.d.(4) of this report).
~ A failure to incorporate all criteria for postulation of
through-wall leakage cracks in moderate energy Class 1 piping in DC-1018 (see discussion of commitment 959 in Subsection 4.d.(5) of this report).
~ A failure to revise DC-2702 to reflect changed criteria
for the location of RHR and CS system containment sump post-accident sampling system lines (discovered by NRC inspectors in their evaluation of the RRT review of drawings and drawing change notices, which is described later in subsection 7.b.(3).(c)). - A failure to revise DC-1204 to reduce the requiremer.t
for containment isolation valves in the lines from the RHR sumps from two to one (discovered by NRC inspectors in their evaluation of the RRT review of drawings and drawing change notices, which is described later in this subsection 7.b.(3).(c)). As noted for the first of the DC errors and omissions listed above, it was partially identified by the RRT in their Finding 4-75.
The RRT also identified two other Findings 4-66 and 4-67, involving errors and omissions in DCs.
This indicates the possibility of a generic problem in the prepa-ration and review of DCs and their revisions.
This is identified for subsequent NRC review as Unresolved Item 424/85-35-06, Adequacy of Preparation and Revision of DCs.
(b) Calculations The RRT performed programmatic (not technical) reviews of 36 of the 313 calculations considered to be within the scope of Module 4.
The RRT utilized a checklist in reviewing the calculations. This checklist is given in Figure 6.1-1 of the Module 4 report.
The NRC inspectors rechecked 22 of the 36 calculations.
The calculations rechecked by the inspectors, the criteria used and the inspectors' findings are identified in Table 4 of this report.
The inspectors determined that the RRT review of calculations was generally satisfactory.
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The RRT identified a relatively large number of findings in their review of calculations, nine of the 16 findings that were identified during Module 4 design verifications.
In addition, the NRC inspectors identified several discrepancies that appeared to be of minor safety significance. These are indicated in Table 4.
They involve calculations X6CXA-35, which had been reviewed by the RRT, and calculations 1K3-1202-111-02 and 110-02, which had not been reviewed by the RRT.
Because of the large number of RRT findings rela-tive to design calculations and because of the inspectors' discovery of additional (although minor) calculation discrep-ancies, the inspectors determined that the calculations should be examined further by GPC and the NRC to assure that the safety concerns have received adequate corrective action.
Followup on the corrective action for the calculations is identified as Inspector Followup Item 424/85-35-07 Calcula-tion Corrective Actions.
(c) Drawings and Drawing Change Notices The module report states that the Readiness Review of this area concentrated on changes to drawings and their impact on other drawings.
The RRT used Module 4 report checklists (Figures 6.1-2 and 6.1-3) in performing their reviews.
The drawings and changes reviewed by the RRT included system Piping and Instrumentation Diagrams (P& ids) and associated Drawing Change Notices (DCNs), one Area Drawing, and the related Isometric Drawings (IS0s).
For their review, the NRC inspectors selected examples of P& ids, IS0s, DCNs and some of the associated RRT completed checklists.
The sample selected by the inspectors included three P& ids (two revisions of one, making a total of four), seven IS0s, 68 DCNs and five RRT completed checklists (one for a P&ID, one for an 150 and three for DCNs). The examples selected and reviewed by the inspectors, the inspectors' review criteria, and the inspectors' findings are given in Table 5 of this report.
For their review of P& ids, IS0s, and DCNs, the inspectors generally used the same review criteria (RRT checklists) as the RRT.
The inspectors accomplished their reviews of RRT completed checklists by reviewing the checklist entries and associated drawings or DCNs with the RRT member who had pe formed the checklist. The inspectors' reviews were conducted to determine if the RRT reviews provided a satisfactory assessment of the adequacy of GPC's preparation of drawings and DCNs.
The inspectors' review of the checklists and checklist performance identified several items of concern, whereas the other examinations they performed identified one. The latter concern was with regard to a discrepancy between the maximum - -
. . -. , . .
design pressure. indicated on ISO 1K3-1205-019-02 and that given in the Line' Designation List. This discrepancy was not identified by the RRT although they reviewed the same 150.
The inspectors determined that it should be examined further by GPC,and the NRC to assure that its significance is minor and that it receives any necessary corrective action.
This - further examination is identified as Inspector Followup Item (IFI)424/85-35-08, Maximum Design Pressure Discrepancy.
The items of concern established during the inspectors' review of RRT completed checklists were as follows: , . - The inspectors' review of RRT Figure 6.1-2 checklists
completed on ISO 1K3-1205-003-01 and P&ID 1X4DB122 - revealed that the RRT performance of the checklists did not provide a significant assessment of the drawings.
The inspectors' review of the completed checklist found that seven of eight checklist items on each had been marked not applicable (NA). The only checks made were in response to the checklist item 2 question "Has drawing received all required signatures?" The RRT considered this to be a check to ascertain that the standard
signature blocks on the drawings had been initialed.
It was not even a check to see if the initials in the blocks were by the personnel authorized to sign-off the drawings.
,
In performing the Figure 6.1-2 checklist review of P&ID 1X4DB122 and ISO 1K3-17.05-003-01 (referred to above) the RRT reviewer marked checklist item 4 not applicable.
This item asks "Have design criteria been maintained or incorporated?" The NRC inspectors saw no reason that Item 4 could not or should not be checked, and they performed the check by examining the ISO and P&ID to determine if they were in accordance with criteria given in the applicable DC (DC-1204).
The NRC inspectors found that the DC-1204 specified two containment isola- ' tion valves in the RHR line from the containment sump, but the P&ID and ISO showed only one, indicating that either the P&ID and ISO or the DC were incorrect.
The Figure 6.1-3 checklist utilized by the RRT in performing reviews of DCNs appeared to be a satisfactory checklist. The inspectors' examination of completed Figure 6.1-3 checklists indicated satisfactory completion of most checklist items.
However, the inspectors found an incorrect RRT verification of a significant checklist item for one of the four completed DCN checklists that they reviewed.- The first item on check-list Figure 6.1-3 is to determine whether the change is in . - -- - .-. --.
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. , ' accordance with current DC requirements.
ISO 1K3-1205-003-01, DCN-11 relocated a post-accident sampling system line on the RHR system suction piping from the containment sump.
, < DC-2702, Post-Accident Sampling System (PASS), indicates a direct connection of the PASS line to the sump and that there is no interface between the RHR system and PASS.
The DCN change, then, was not in accordance with DC-2702.
The inspectors consider the inadequacies in the drawing I checklist (Module 4 Figure 6.1-2) and the incorrect and . omitted RRT verifications described above to be identified as Unresolved Item 424/85-35-09, Adequacy of Drawing and DCN Reviews.
Readiness Review management indicated the drawing , and DCN noncompliance with DC requirements (DC-1204 and 2702) .' described above were the result of failure to properly revise
the DCs to incorporate accepted design changes. The apparent uncorrected changes in DC-1204 and -2702 were identified for further review as Unresolved Item 424/85-35-06, Adequacy of ' Freparation and Revision of DCs.
(Seeparagraph7b.(3).(a)) ' (d) Construction Specifications The construction specifications are design documents which , l provide the requirements for development of the (field)
construction procedures that control field work.
The GPC module report Indicated that the design RRT limited their review relative to construction specifications to 12 con- > i struction specification change notices (CSCNs). According to
the module report, the construction RRT reviewed the field i procedures and the associated construction specification j sections to verify implementation of the FSAR commitments.
With regard to the statement in the Module 4 report that
indicated the construction RRT had reviewed specification l sections, the inspectors found no documented evidence of the review in the implementation matrix or elsewhere. Readiness o Review management informed'the inspectors that the construc-i tion RRT had concentrated on review of the construction j procedures to assure they implemented the consnitments.
The i inspectors found that the implementation matrix did indicate j ~ RRT review of most construction procedures..However, the inspectors noted that GPC construction procedures for re-i ! ceipt, storage, and maintenance of mechanical equipment and j the nondestructive examination' (NDE) procedures associated i, with welding were not included.
l !
The inspectors were informed that the procedures for receipt, l storage, and maintenance would be addressed in a separate Readiness Review appendix (Appendix E) covering material
control.
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The inspectors found no evidence that the RRT intended to assess the (construction) welding NDE procedures.
The inspectors do not consider the assessment necessary because the NDE procedures have received extensive review in NRC inspections and based on the inspectors' experience, NDE procedures are not revised to make them less conservative.
! . The NRC inspectors only briefly reviewed construction proce- , dures in their evaluation of the Readiness Review, as they were already familiar with them from past inspections that
had detected no procedural discrepancies that are not being satisfactorily addressed.
Examples of construction proce-dures reviewed by the NRC in recent inspections are listed in ~ Table 6.
, l The inspectors consider that the apparent failure of the RRT i to perform a significant review of the construction specifi-cations and the construction procedures for receipt, storage . and maintenance may represent a minor deficiency in the ' performance of the Readiness Review.
The inspectors have determined that the significance of this deficiency should be examined further by GPC and the NRC and this is identified Inspector Followup Item 424/85-35-10, Review of Construction Specifications and Procedures.
(e) Field Change Requests (FCRs) From the Module 4 report it is unclear how many FCRs were l written that apply to Module 4.
The RRT selected and re- ' viewed a sample of 71 utilizing a checklist. The RRT had one finding, Finding 4-80.
The finding was that one of the 71 , ! FCRs failed to include a rationale for the disposition i ! provided.
For reasons described in the module report, the RRT determined that the finding was a violation of a project procedure for which there was no safety concern.
For their evaluation of the RRT review the NRC inspectors selected and examined a sample consisting of 17 FCRs that.had l not been reviewed by the RRT and one that had been. The NRC l sample and the findings are given in Table 7.
All FCRs j examined were considered satisfactory.
(f) DeviationReports(DRs) ! l The RRT performed a detailed review of 100 DRs (includes Nonconformance Reports, the former title for DRs) which the l module report states were selected based on the following: 1, Interfacing disciplines and organizations were involved
Design documents were affected - - - - - - - -. ..
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The review had only one Finding (Module 4 report Find-ing 4-97) of a deficiency in a DR.
The conclusion of , the RRT was that the Finding was a procedural violation with no safety concern.
The NRC inspectors evaluated the RRT review through examination of 28 DRs, 27 of which were DRs that had been reviewed by the RRT.
The DRs reviewed by the > ! inspectors are listed in Table 8.
The inspectors found no procedural discrepancies in the DRs and identified no deficiencies in the RRT review of this area, i (g) Procurement Specifications The module report indicates that the RRT performed a detailed review of six procurement specifications utilizing Module 4 checklist Figure 6.1-7.
The review. identified two findings, both considered violations of project procedures with no safety concern.
Both involved inconsistencies with design criteria.
The NRC inspectors evaluated the RRT review of procurement specifications by examining one of tne six specifications that the-RRT had reviewed and assessing the
adequacy of the review.
The specification examined by the , inspectors (X4AH04 Shop Fabricated Atmospheric Tanks....), ' the criteria used in performing the assessment and the inspectors' findings are described in Table 9.
The inspec- - tors performed the assessment by (1) independently reviewing the specification utilizing selected items from the checklist that had been used by the RRT in their review, and (2) reviewing the specification and checklist completed by tne RRT with the RRT member who performed the review.
The NRC ! inspectors found the following apparent deficient conditions
for the RRT review performed using the 15 item RRT checklist:
The RRT reviewer considered checklist Item 2 to be the ~ same as Item 1 and as a result made no check for that item.
Item 4 was a check to determine if the specification included the requirements of ANSI N45.2.1174 and NRC Regulatory Guide 1.64. Rev. 2.
The -74 revision of ANSI N45.2.11 is not applicable to the Vogtle equipment design.
The applicable revision of ANSI N45.2.11 is Draft 2. Rev. 2.
Regulatory Guide 1.64 is not applica-ble at all.
The specification example reviewed did not include any reference to ANSI N45.2.11. RRT management ' stated that compliance with the essential requirements , of ANSI N45.2.11 had been obtained in the specification
through its reference to ANSI N45.2-71. Additional NRC review will be required to verify the RRT rationale that ANSI N45.2-11 may be substituted for ANSI N45.2.11. The - - -. - - - - -
a .
inspectors are concerned that reference to RG 1,64 and the newer revisions of ANSI N45.2.11 in the RRT check-list indicate some lack of attention to detail in the Readiness Review process.
- Checklist items 7 and 8, which were for checks of
calculations, were marked anot applicable" because they were not reviewed, not because they could not have been reviewed.
The inspectors understood that they were not reviewed because they were not readily available on site.
Checklist items 11 and 12 were; (11) "were SDDRs incor-porated into this specification" and (12) "were MSCNs - , incorporated into this specification."
Supplier Devia-tion Disposition Requests (SDDRs) are documents used by suppliers to request deviations from purchase orders (or specification requirements).
Material Specification Change Notices (MSCNs) are documents used to provide a means of making and documenting changes to a bill of material specification (not changes to equipment speci-fications) without the necessity-of revising the speci-fications.
The inspectors noted that for the equipment specification review the RRT reviewer.had marked check-list Item 11 "yes" and Item 12 "no."
The RRT reviewer stated these entries were based on examination of the revision blocks on the specifications to determine if the blocks indicated that SDDRs and MSCNs had been incorporated during the revisions.
There was no recog-nition that MSCNs did not apply to equipment specifica-tions (Item 12 should have been marked not applicable) and there was no verification that all SDDRs applicable to the specification were included in the revision blocks or if any of them were fully incorporated.
Checklist Item 13 was to verify that the specification complied with the requirements of the DC and the FSAR commitments.
The RRT reviewer marked the item "yes".
The inspectors found that the specification did not incorporate the requirements of Regulatory Guide 1.44 from DC-1204. Also, the inspectors noted that radiation levels specified for CCW surge tanks, ACCW tanks and isolation valve encapsulation vessels did not include units (e.g., RA0S).. There was no apparent identifica-tion of detail FSAR commitments or DC requirements which the RRT reviewer was to verify as-incorporated for verification of this checklist item.
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- There was no checklist item requiring assessment of the
adequacy of the procurement specification revision process.
The conditions described above and measures to assure that applicable design bases and other requirements are included or referenced in procurement documents are identified as Unresolved Item 424/85-35-11, Inadequate Review of Procurement Specifications.
(h) Vendor Documentation According to the Module 4 report, the Readiness Review of vendor documentation included examples of vendor drawings, SDDRs, equipment qualification documentation, field equipment change orders (FECOs) and supplier quality verification documentation lists (SQVDLs). The RRT identified no findings relative to vendor documentation.
The NRC inspectors per-formed a limited evaluation of the Readiness Review in this area through examination of RRT performance relative to one of six vendor drawings they reviewed.
The drawing example selected by the inspectors was the RHR Isolation Valve Encapsulation Vessel drawing.
The selection was made to continue continuity of review -relative to the RHR system a valve encapsulation vessel and associated piping.
The RRT review was conducted using the Module 4 Figure 6.1-8 check-list.
The inspectors evaluated the adequacy of the RRT , checklist and the RRT performance of checklist items by reviewing the vendor drawing and the associated RRT completed checklist with the RRT reviewer to determine if the checklist and its performance resulted in a satisfactory review.
The vendor drawing reviewed, the review criteria used by the NRC inspectors and their findings are summarized in Table 9.
The inspectors found that the RRT review of the drawing appeared to be incomplete, in that,
The drawing was partially illegible, a discrepancy that the RRT failed to identify in their review of the same drawing.
The checklist (Module 4 report, Figure 6.1-8) completed by the RRT in reviewing the drawing resulted in a cursory review. Seven of the ten items on the checklist were either marked "not applicable" or were simply not performed by the RRT.
In addition, one item on the checklist that was marked as having been performed was not applicable (Item 1). The inspectors found that only three of the ten checklist items appeared to contain significant review criteria for the vendor drawing (Items 4a, 4b, and 5b.c). and none of the three were , performed by the RRT.
The inspectors determined that
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each of the three could have been performed. The three items were as follows: Item 4a "Are selected data and materials on the . vendor document in compliance with the procurecent specification?" (The RRT member who performed the checklist simply failed to complete this item. It was not marked "not applicable.") Item 4b "Are selected materials on the vendor . document in compliance with the code if code item?" (The RRT member who performed the checklist marked this checklist item not applicable.
He informed the inspectors that he did not recall why.)
"Does the supplier's design conform to Item 5.bc - . the licensing commitments / design criteria?" (This item was marked "not applicable" by the RRT member who performed the checklist. He stated that he did so because he did not accomplish review of the item.)
The inadequacies in the RRT checklist and the RRT performance of the checklist and the failure of the RRT to note the drawing illegibility, described above, are identified as Unresolved Item 424/85-35-12, Inadequate Review of Vendor Drawings.
(i) Readiness Review Design Verification Findings During the performance of verification activities the design RRT raised a number of questions which required clarification or resolution, or which were findings of deviations from ccnnitments or procedures that required project evaluation, disposition, and corrective actions. RRT questions or issues were documented and processed.
The design RRT identified 16 Findings, some of which have already been mentioned above.
Of the 16 Findings, the RRT determined that three represented safety concerns while the other 13 did not.
In their assess-ment of responses received from the project for the Findings, the RRT reported that they concluded that the Findings do not affect the design adequacy of existing piping and equipment.
The inspectors evaluated the RRT resolution of their Findings by first reviewing their descriptions of the Findings and responses to determine if the. information satisfactorily supported their conclusion regarding the Findings.
The inspectors determined, based on the information presented in the. module report, that the RRT conclusion was adequately.
supported.
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Subsequently, the inspectors examined examples of Readiness Review information requests and Findings to determine if they had received satisfactory responses, and if the Findings and responses were accurately depicted in the Module 4 report.
Two Information Requests and two Findings were selected and examined.
The two Information Requests reviewed by the inspectors, the criteria used by the inspectors in assessing the responses to the requests and the inspectors' findings as to the adequacy of the responses are given in Table 10. The inspectors found that the information requests received satisfactory responses.
The Readiness Review Findings reviewed by the inspectors, the inspectors' review criteria and their findings are sumarized in Table 11 and described in greater detail below:
Finding 4-75 - This Finding was that a calculation failed to postulate intermediate pipe breaks in accor-dance with DC-1018.
The response received by the RRT from project management for this Finding was that elimination of the breaks in the calculations was in accordance with an NRC approved change.
The response also stated that DC-1018 had originally not reflected the change because the change notice had been misplaced.
The response stated that the DC had now been revised to incorporate the change and that review and identifica-tion actions had been implemented to prevent recurrence of unincorporated DC changes.
The RRT determined that the response was acceptable.
As described in the discussion of commitments 951, 954, 956, and 1543 in 4.d.(4) above; the inspectors found that there were conditions included in the NRC approval of the change in requirements for postulation of intermediate pipe breaks.
Project and RRT personnel failed to recognize and verify implementation of the conditions and, based on the absence of that verification, the in3pectors identified (in Subsection 4.d.(4) above) Unresolve i Item 424/85-35-03.
In view of the failure of project and RRT personnel to recognize and assurc implementation of the subject conditions (which are not recognized in DC-1018), the inspectors consider the RRT's resolution of their Finding 4-75 to have been inadequate.
Finding 4-85 - This Finding was that Project Classes stated on the specification and the technical provisions for the RHR isolation valve encapsulation vessel were incorrect.
Project Classes indicate the level of quality requirements applicable to the item, e.g., ASME Code Class.
The project response to this Finding was
. .
that while the incorrect Project Class had been identi-fied on the documents, the specific requirements given in the text of the documents assured that the proper requirements were met.
To assure that proper Project Classes were indicated on other documents, the response stated that eight specifications were checked and no other discrepancies were found.
The inspectors had reviewed the specification and technical provisions for the RHR isolation valve encap-sulation vessel and agreed with the response that the requirements given in the text assured adherence to the intent of the correct Project Class. The inspectors did find, however, other pamples of apparent improper Project Classes on the following documents: a.
Field Change Request M-FCRB-6398 b.
Calculation X6CXA-35 (Project Class 212 versus 111 specified for it in the Line Designation List) -- c.
Proposal for Shop Fabricated Atmospheric Tanks Built to Section III of the ASME Boiler and Pres-sure Vessel Code (proposal for specification X4AH04) Based on the inspectors' identification of the addition-al documents with incorrectly specified Project Classes, described above, Readiness Review Finding 4-85 does not appear to have been satisfactorily resolvad by the Project or the RRT.
The inspectors found that it did not appear that either the RRT identified examples of improperly specified Project Classes for Finding 4-85 or those identified by the inspectors would have resulted in significant discrepancies in hardware or documentation.
However, the inspectors' findings indicate that misclassification may be more exten-sive then originally suggested by Finding 4-85.
The resolu-tion of both design verification Findings examined by the inspectors and is identified as Unresolved Item 424/85-35-13, Inadequate Resolution of Readiness Review Design Verifi-cation Findings.
c.
Subsection 6.2, Construction Program Verification (1) As described in the Module 4 report, the Readiness Review verifi-cation of construction was performed by a Construction RRT con-sisting of six personnel experienced in nuclear construction.
It was intended to ensure, through sampling, that the construction processes for mechanical equipment and piping had been adequately controlled and had resulted in proper implementation of licensing . - - - - - . . . - -
. .. - . . o .
commitments. The module report describes the construction verifi-cation as having been performed in two phases.
Phase I was an appraisal of completed piping hardwarc and associated quality documentation.
Phase II was an evaluation of in-process and related activities for piping and equipment installation.
Summary details of the RRT Phase I and Phase II reviews, the NRC evaluation of each phase and an NRC evaluation of the findings of the RRT reviews are described below: (a) Phase I The RRT conducted the Phase I review by selecting a sample, ' performing a physical inspection of the sample selected, and reviewing completed documentation associated with the sample.
The RRT Phase I sample included only items that had been installed and completed through hydrostatic testing.
No emergency core cooling systems (ECCSs) were inspected.
The RRT sample included piping (and valves) on the following isometric drawings: ' 1K3-1217-182-01, Auxiliary Component Cooling Water 1K3-1202-111-02, Nuclear Service Cooling Water , ! 1K5-2403-051-01, Diesel Generator IK3-1217-176-01, Auxiliary Component Cooling Water IK4-1202-001-04, Nuclear Service Cooling Water 1K3-1202-405-03, Nuclear Service Cooling Water , 1K3-2303-019-01, Fire Protection (Seismic I)-
These isometrics represent four large bore installations, three small bore installations and a portion of six tests out of 27 Code hydrostatic tests performed as of February 1, 1985.
The hardware assessed reportedly included 133 field welds and 14 valves. The physical inspections were conducted using a checklist developed from the construction procedures, which basically implement ASME Section III criteria. The checklist is provided in the Module 4 report as Figure 6.2-1.
For welds the checklist provided for checks of such attributes as contour, size, transi-tions, undercut, cracks, etc.
Valves were checked for identifica-tion, orientation, flow direction, handle / operator orientation and damage.
For the piping itself, the checks included location /orien-tation, dimensions / slope, size and type material, surface damage, and material / welder number identification and marking.
! - - T-a <-
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. ,
According to the module report, the Phase I RRT review of documen-tation included a review of each of the above listed isometric documentation packages for inclusion of all required documents, legibility of the documents, and administrative completeness of the documents.
In addition, a sample of the records was reported-ly examined in detail.
The sample examined in detail included 39 field welds, seven valves, one hydrotest package,16 pieces of field added pipe / fittings and six large pipe spools. The detailed review was conducted using checklists described in Module 4 Figures 6.2-2 through -4.
The RRT identified six Findings in their review of documentation involving: (1) discrepancies between material markings and information recorded; (2) weld process sheets that referenced improper procedure revisions; (3) an incorrect material description on a material requisition; (4) inadequate control of a fabrication sketch; (5) a missing QC verification of valve line up for a hydrotest; and (6) a missing material requisition.
(b) Phase II The RRT Phase II construction program review addressed examples of installed mechanical equipment, a variety of ongoing construction activities, and document / records con-trol.
The review reportedly conducted relative to each is summarized as follows:
Mechanical Equipment Field inspections and reviews of available documentation were conducted using checklists (Module 4 report Figures 6.2-5 and 6.2-6).
The walkdowns were to assess freedom from damage, maintenance and storage, configuration and location, and visual weld quality.
Documentation reviews checked procurement, installation and mainte-nance records to verify compliance with construction procedure and vendor requirements. Equipment considered in the review included: Auxiliary feedwater pump turbine driver . 1-1302-P4-001-K01 Chemical and volume control positive displacement . pump 1-1208-P6-001 Seal water heat exchanger 1-1208-E6-004 . Component cooling water pump 1-1203-P4-001 . Safety injection pump 1-1202-P6-001 . Boric acid storage tank 1-1208-T4-003 .
. .
Note: The review of mechanical equipment was the only Phase II review conducted by the RRT using formal checklists.
2_ Material Storage Examples of piping storage areas were inspected and storage reports were reviewed to determine compliance with procedural requirements for piping storage.
3_ Welding-Related Activities and Leak Testing The review of welding-related activities included observation of work and records for weld rod control, piping fit-up and cleanliness and in-process welding.
The sample size for the fit-up and cleanliness and in-process welding was very small, involving three welds for the former an one for the latter.
The review for leak testing included, for one test - the review of the test package prior to test, witnessing the test and review of the completed test package.
The reviews of welding-related activities and hydrotesting assessed compliance with ASME code and construction procedure requirements.
,
Deviation Reports A sample of 100 closed DRs pertaining to piping and equipment was reviewed for conformance with the applica-ble construction procedure (PPP Procedure XV-2).
5_ NDE/ Radiography The assessment of nondestructive examination and radiog-raphy was performed to ascertain compliance with project procedures and ASME Section III requirements.
The assessment was performed in two parts. The first was a review of 153 radiographs and associated inspection reports and the second was a review of liquid penetrant ' examination results ' for six welds, with performance witnessed for two of the six, p, Document / Records Control The assessment of document / records control was performed by the RRT to ascertain that drawings, including Design Change Noticee (DCNs), located in the field document control stations were current and that process sheets , were controlled in accordance with PPP procedure VI-5.
In selecting examples for assessment, past GPC audit findings (Audit GD07-85/22) that identified incidents of . - - - - - - - - - - - - - -. - - -
. .
incorrect drawing revisions at field document control stations were reportedly considered.
Fifteen DCNs and associated drawings and 20 process sheets were selected and checked.
The RRT Phase II review resulted in ten findings involving an improper anchor bolt spacing, a misplaced QC inspector eye exami-nation report, improper storage conditions and inspections, failure to document hydrotest vent points, unclear DR justifica- ~ ions, a failure to provide impact tests, bypassed ASME inspector treview and concurrence, document control station possession of an incorrect drawing revision, omission of required entries on radiography reports and the need for a revised response tc NRC on a 50.55(e) item for ER-309L weld wire.
The RRT determined that nine of the findings involved no safety concerns.
(2) NRC Evaluation of RRT Phase I and II Review The NRC inspectors evaluated the RRT Phase I and II reviews by examining and assessing selected examples of constructed hardware (equipment and piping) and associated records.
The inspectors' sample included some of the hardware inspected by the RRT in their review.
The remainder consisted of equipment and piping that was selected for assessment totally independent of the RRT sample; and some that was included to provide a continuity of review of selected equipment through both design and construction. The RHR isolation valve encapsulation vessel and associated piping provide an example of the latter.
The items examined by the inspectors, the criteria used in assessing the items, and the inspectors' comments / findings for the items are provided in Table 12.
Table 12 also indicates whether the RRT reviewed the hardware and records for the items.
The inspectors' examination of the RRT Phase I review, their examination of the RRT Phase 11 review and their findings are described below: (a) NRC Examination of RRT Phase I Review Relative to the RRT Phase I review, the NRC inspectors' examinations (as depicted in Table 12) represent two of the seven isometrics that were assessed by RRT plus five that were not included in the RRT review. The inspectors utilized the RRT checklists in many of their examinations to assess their adequacy.
(b) NRC Examination of RRT Phase II Review With regard to the RRT Phase II review, a comparison / discus-sion of the RRT and NRC verifications is as follows:
- .. . _ ~_ . .-.- . - . .
1_ Mechanical Equipment The NRC examinations included two of the seven mechani-cal equipment items addressed by the RRT.
The RRT checklist was used in performing the examinations such that its adequacy could be assessed.
The inspectors also examined hardware and records for four other equipment items utilizing RRT checklist criteria and other criteria as described in Table 12.
Material Storage The inspectors did not assess this area except to examine the RRT description of their performance and findings in this area.
From past inspections the inspectors were aware of piping storage discrepancies at Vogtle.
However, such discrepancies as have been experienced are very unlikely to result in serious damage and the inspectors elected not to address this ' area.
Welding Related Activities and Leak Testing The RRT performed a very limited review in this area checking only one leak test, three welds for fit-up and cleanliness and one in-process weld plus checks of welding material controls at the issue stations.
The , NRC inspectors did not perform an evaluation relative to any of the above except welding material control.
Controls were checked at an issue station.
Deviation Reports The inspectors did not specifically review DRs relative i to construction as part of their evaluation.
However, they have reviewed and were familiar with the DRs from past inspections (e.g., NRC Inspection 424/84-36).
5_ NDE/ Radiography The inspectors did not evaluate the RRT review in this area. The related GPC procedures and performance of the procedures have been accessed in past NRC inspections (e.g., 424/84-36, 84-13, 83-13, 84-26, 84-03, and 82-20).
Document / Records Control The RRT only reviewed a small number of documents in ( this area,15 DCNs and their associated drawings and 20 process sheets.
It was noted, however, that the _ - -. - ._- . ___ . _ ._ --
. .
Readiness Review is preparing an appendix (Appendix D) to cover document control to be issued for NRC evalua-tion.
On this basis, the NRC inspectors determined not to specifically evaluate any related material during their inspection.
(c) NRC Findings With regard to the construction RRT performance of their Phase I and II reviews.
The inspectors determined that some of the Readiness Review checklists did not appear to be well organized to provide efficient review, but found that an experienced individual could use them satisfactorily.
The inspectors did not identify any deficiencies in the review performed by the construction RRT. In the course of examining hardware, records and activities not assessed by the RRT, the inspectors did identify a number of items of concern.
None of these items by itself appeared to represent a major problem.
However, the items require additional inspection and resolution to determine their collective impact on the NRC evaluation of the Readiness Review of VEGP Unit 1 mechan-ical equipment and piping.
In examining the RHR isolation valve encapsulation vessel identified V-1-1205-V4-01, the inspectors noted apparent undersize welds / excessive grinding for bellows to flange (weld 49) and pipe to flange (weld 50) welds , as depicted on drawing IX4AH04-23-13.
Pending GPC evaluation of the condition and further NRC review to determine its significance, this is identified as Unresolved Item 424/85-35-14, Undersize /0verground Welds.
2_ While examining the piping and valve inside the RHR isolation valve encapsulation vessel the inspectors discovered structural members supporting the piping that were not depicted on the drawing.
The basis for and controls on the installation of these supports could not readily be determined.
Pending GPC investigation /evalua-tion of the cor.dition and NRC inspection of their findings this is identified as Unresolved Item 424/85-35-15, Undocumented Piping Supports.
During the review of records for the RHR isolation valve ~~ encapsulation vessel the inspectors found that all of the associated RHR system pipe was a low carbon grade of stainless steel, while the isolation valve was not. The inspectors requested that GPC explain the apparent inconsistency and identified it as Inspector Followup Item 424/85-35-16, Inconsistency in the Use of Low Carbon Stainless Stee. _ . __ ._.
.. _ _ _ _ _ _ _ __ -_ _
. .
36 ,
In examining the control of welding materials from an issue station the NRC inspectors identified apparent i discrepancies in conformance to PPP procedures VIII-3 and GWS III/I.
The discrepancy related to procedure VIII-3 was failure to conform to requirements for daily verification and recording of electrode holding oven . temperatures.
The discrepancy related to procedure GWS III/I was failure to issue proper revisions of welding technique forms to welders on issue of the electrodes revolved. These items were identified as unresolved but became Violation 424/85-40-03, Failure to Follow Proce- ,. dures for Control of Welding, in a subsequent inspection.
5 In examining the installation of mechanical equipment - the NRC inspectors identified apparent discrepancies in . coupletion of required preventive maintenance on NSCW pump motors. The discrepancies involved were failure to , j provide required energization of pump motor heaters.
This item was identified as unresolved but became Violation 424/85-40-04, Failure to Protect Permanent
Plant Equipment, in a subsequent inspection.
t ' (d) NRC Evaluation of RRT Findings and Their Resolution The construction RRT identified 18 Findings in their Phase I and II construction reviews.
The RRT also identified two i additional Findings (for a total of 20), one in review of audits and one in review of commitment implementation.
For convenience these latter two Findings-were discussed in Subsection 6.2 of the Readiness Review Module 4 report.
' The inspectors evaluated the construction RRT resolution of their 20 Findings, first reviewing their description of the Findings and responses in the Module 4 report to determine if the 1. formation supported their conclusions. The inspectors
determined, based on the information presented in the module report, that the RRT conclusions were adequately supported.
' Subsequently, the inspectors examined examples of Readiness Review findings in detail to determine if they had received , satisfactory responses, and if they were accurately depicted in the Module 4 report.
Four findings were selected and j examined.
. The Readiness Review Findings examined by the inspectors, the i inspectors' review criteria and their findings are summarized in Table 13 and described in greater detail below.
i a
- - - - -. - - - -. . - - - - - - . -. - - - -.. . -. - - - - - . .__ _ _ _, _ _ - - -
. .- - . o .
1 Finding 4-45 This Finding was that arc strikes and/or areas of weld spatter were found during RRT examination of Code piping.
The project response to this Finding was that PPP had removed the arc strikes / weld spatter in accor-dance with procedure IX-52.
All removal areas were evaluated by GPC and found not to affect the hardware.
The inspectors exa nined several of the areas involved (ISO 1K4-1202-001-04) and verified that removal had been accomplished with no adverse affect to the piping involved.
2_ Finding 4-46 This Finding was that a review of 133 weld process sheets revealed three instances where the material marking was not in accordance with the associated process sheet. The project response to this Finding was to correct the discrepancies based on other supporting i documentation for the welds involved.
The inspectors examined the hardware and supporting documentation for two of the discrepancies involved (welds 111-W-165 and 111-W-139 on ISO 1K3-1202-111-02) and verified that corrective action was properly accomplished.
Finding 4-56 This Finding was that as-built piping, in one instance (ISO IK3-1217-182-01), violated hot-pipe-to-raceway separation requirements of electrical construction specification X3AR01, Section E8.
The project response was to correct piping construction specification X4AZ01 and related PPP Procedure IX-3 'to include minimum separation requirements of 1" from installed piping to any other obstruction, issue DR ED-8341 to allow "use-as- - -is" of the condition for ISO-1K3-1217-182-01 and initiate a 100% reinspection program for piping systems already hydrotested.
The inspectors reviewed the proposed corrections to the procedures involved and verified adequate use-as-is engineering disposition for DR ED-8341.
Inspectors were informed that 100% rein-spection and necessary changes to the procedures were not yet complete, even though the July 16,1985, comit-ment date reported in Section 6.0 of the Module 4 was past.
(The completion date is also reported as June 1, 1985, in Section 8.0 of the Module 4 report).
The . inspectors also noted the potential for separation
problems in other areas of piping installations.
i -, -. - - - - - -. ., -g ,
. .
Additional separation problems (lack of 1" minimum separation between containment pipe rack R0001 and piping on ISO IK4-1201-036-01) were identified during a subsequent NRC inspection and continued NRC concern was identified as Inspector Followup Item 424/85-40-01, Assurance of Necessary Minimum Clearances for Installed Piping.
4_ Finding 4-83 This Finding concerned a potential construction defi-ciency that had been reported to the NRC in accordance with 10 CFR 50.55(e) (NRC item 424/CDR 83-42).
The potential deficiency was identified as hot cracks which had occurred during welder qualification testing for dissimilar metal joints (carbon steel to stainless steel) to be welded with the gas tungsten arc welding (GTAW) process and type ER309L weld wire. The final GPC report to the NRC on CDR 83-42 was dated December 18, 1983, and concluded that a substantial safety hazard / deficiency did not exist. This conclusion was supported by a BPC metallurgical report showing the significant causes of the hot cracking to be associated with the qualification testing due to high weld metal dilution and welder technique during qualification testing, which provided high heat input).
The type ER309L weld wire was within specification but near allowable limits on phosphorous and sulfur levels.
Reported corrective actions included BPC review of PPP carbon steel to stainless steel GTAW welding procedures to ensure that the potential for high heat input and excessive weld metal dilution was minimized and review of radiographic film of carbon steel to stainless steel production welds (primarily containment liner penetra-tions) to assure that none of the production welds contained defects due to hot cracking.
The review of radiographic film identified defects in containment liner penetration welds not associated with hot cracking and these defects were reported to the NRC in accordance with 10 CFR 50.55(e) (NRC item 424/CDR 84-56).
Finding 4-83, as stated in the Module 4 report, was that NRC wJs not informed of revised corrective action regarding CDR 83-42 in that applicable welding proce-dures were not revised since the weld wire was removed from the site.
The project response stated in the Module 4 report was that a revised response to the NRC would be submitted by May 30, 198 _. _. . . . i
The inspectors were aware of details concerning CDR 83-42 and related CDR 84-56 from previous NRC in- , spections (see NRC Inspection Reports 50-424/84-18, ' 84-30, and 85-14) and knew of no need for revision
to the final GPC report on CDR 83-42 transmitted on December 18, 1983. In discussions with the inspectors, project personnel denied any project commitment to RRT for a revised 50.55(e) response.
They stated that the details previously provided to the NRC had been correct.
The significance of the matter in which Finding 4-63 was resolved will be examined further by GPC and the NRC.
.It is identified for tracking purposes as Unresolved Item 424/85-35-17, Inadequate Resolution of Readiness Review Findings.
8.
Section 8.0 Program Assessments / Conclusions ' Section 8.0 provides a summary of corrective actions that remain open with regard to Readiness Review Findings, resumes indicating the backgrounds and qualification of design and construction team personnel, and the assessments , of various groups who participated in the development of the module.
The , inspectors examined the materials in and related to this section to evaluate I the personnel background and qualification information and to assure an understanding of the assessment statements.
, i c l l
, _.
_ .. _. -, ., , ~.,,, - -,,.,, -,. - _, -,. -,. _.. ~ _ - - _....
- - - - - - - - . _ ~ .- . . _-.~. . _ - ~ ~ -. - - . .. - - - . TABLE 1
COMMITHENTS REVIEWED (SHEET 1 0F 11) (SEE NOTE 1)
RRT MMB_@ SOURQ.( SECTION COMMUMBLSU_fqLOT DOCUMJET TEATU_RI NRC REXIE_WED f_l PLDMGS/ COMMENTS (SEE NOIE 2) ! l 145 FSAR 1.9.38 QA REQUIREMENTS, RG 1.38, MAY 1977 IDENTIFICATION AND SAilSFACTORY ' SHIPPING, RECEIVING, IMPLEMENTATION (INCORPORATED IN STORAGE AND HANDLING COMM11 MENT NO. 1578 TO RG 1.116)
' 154 FSAR 1.9.61 DAMPING VALUES FOR RO 1.61, OCTOBER 1973 IDENTIFICATION AND SATISFACTORY.
SEISMIC DESIGN OF IMPLEMENTATION NUCLEAR POWER PLANTS [ 217 FSAR 5.2.3 WELDER QUAL. FOR RG 1.71, DEC. 1973 IDENTIFICATION ACCEPTED EXPLANATION LIMITED ACCESSIBILITY THAT COMMITMENT BELONGS IN MODULE 8 AND VERIFIED ASSIGN-
MENT i 256 FSAR 5.2.3.4.6 CONTROL OF DELTA RG 1.31, APR. 1978 lDENTIFICATION AND SATISFACTORY FERRITE IN SS IMPLEMENTATION (INCLUDED REVIEW OF ADDlil0NAL DCs 1201 AND 1204) , 259 FSAR 5.2.3.4 SENSITIZED SS RG 1.44, MAY 1973 IDENilflCATION AND SATISFACTORY-IMPLEMENTATION (WAS NOT INCLUDED IN (INCLUDED REVIEW OF COMMITMENT IDENTIFI-ADDITIONAL DCs 1201 CATION MATRIX
AND 1204) (SECTION 3.4).
} LISTED AS COMMITMENT NO. 218 IN MASTER ! COMPUTER LIST) ' -322 FSAR 6.1.1.1 MATERIALS SELECTION ASME lit, NC-2160 IDENTIFICATION AND SATISFACTORY i AND FABRICATION AND NC-3120 IMPLEMENTATION ' 332 'FSAR 6.1.1.2 ESF CONSTRUCTION PROHIBITION OF COLD-IDENTIFICATION AND IMPROPERLY EXCLUDED MATERIALS WORKED AUSTENITIC SS IMPLEMENTATION FROM MODULE 4.
WITH YlELD SIRENGTHS.
( PROPERLY IDENT I FI ED CREATER THAN 90 KSI AND ASSIGNED TO , MODS 16, 20, 18A)
384 FSAR 9.2.1-3 NSCW SYSTEM EQUIPMENT EQUIPMENT CODES AND IDENTIFICATION AND INADE QUATE CPC (TABLE) DESIGN STANDARDS IMPLEMENTATION VERIfICAT10N OF IMPLEMENTATION, RRT VERiflCAil0N IS BASED ON REFERENCE TO ASME
lil IN SECI10N 2.0 [ OF DC 1202.
THE ' RELEVENT ASME CLASS IS NOT IDENTIFIED IN
SECTION 2.0.
> f - - -- - -- r,
, 1e - - - - - - - - - - - -
n- ~ LABLC_1 ^ COMMITMENTS REV1EWED (SHEET 2 OF 11) ,
(SEE NOTE 1) [
RRT NUMBER SOURCE SECTION COMMITMENT SUBJ[Cl QO_QpH @l_[[AJJRJ NRC RF,yJ W[D [l.,MDJECS/ COMME NT S (SEE NOIE 2).
_ ! t 682 FSAR 1.9.26 QUAL. CHOUP CLASS AND RG 1.26, REV. 3, IDENTIFICATION AND SATISTACTORY, BUT STANDARIS FOR WATER, FEB. 1976 IMPLEMENTATION UNNECESSARY DUPLl-i STEAM AND RADWASTE CATION OF COMM. 1753 CONTAINING COMPONENTS OF NPP 703 FSAR 1.9.58 QUALIFICATION OF RC 1.58, SE P, 1980 IDENTIFICATION ACCEPTED EXPLANATION INSPECTION PERSONNEL THAT COMMITMENT BELONGS IN APPENDIX
AND VERIFIED ASSIGN- - * MENT 711 FSAR 1.9.82 SUMPS FOR EMERCENCY RG 1.82, JUNE 1974 IDENilflCATION AND SATISFACTORY, BUT CORE COOLING AND IMPLEMENTATION UNNECESSARY DUPLICA-CONTAINMENT SPRAY TION OF COMM. 2515 SYSTEMS 880 FSAR 3.2.2-1 PRINCIPAL CODES ASME lil, CLASS 1, 2, IDENTIFICATION AND SATISFACTORY ' AND STANDARDS FOR 3 OR MC, NF, OR CS IMPLEMENTATION T.3.2.2-1 885 FSAR 3.2.2-1 CONST. CODES /STDS.
ASME Ill, D.1, SUB.
IDENTIFICATION AND SATISFACTORY
Q.G.-B IOR PRESSURE NC, CLASS 2 IMPLEMENTATION VESSELS, PIPING.
PUMPS, VALVES, ATM.
i STORAGE TANKS, 0-15 psig STORAGE TANKS, SUPPORTS, ! METAL CONT. COMP, CORE l SUPPORT STRS.
889 FSAR 3.2.2-2 CONST. CODES /STDS.
ASME'lli, D.1, SUB.
IDENTIFICATION AND SATISFACTORY Q.G.-C FOR PRESSURE ND, CLASS 3 IMPLEMENTATION l VESSELS, PIPING, t VALVES, ATM. STORACE l TANKS, 0-15 psig STORAGE , TANKS, SUPPORTS j 924-FSAR 3.5 MISSILE PROTECTION 10 CF R 50, APP, A, IDENFIFICATION AND SATISFACTORY CDC 4 IMPLEMENTATION [ 932 FSAR 3.5.1.3.2 PROTECTION AGAINST RG 1.115, JULY 1977 IDENilflCATION ACCEPTED E XPLANATION LOW TRAJECTORY TURDINE THAT COMMITMENT WAS MISSILES INCLUDED IN MODULE 1 ! 9t7 FSAR 3.6.1.2 SUB-COMPAR1MFNT BN-TOP-4, REV. 1 IDENilflCATION AND SATISFACTORY PRESSURE ANALYSIS (OCTOBER 1977) IMPLEMENTATION
948 FSAR 3.6.1.2 HIGH ENERGY LINE THERE ARE NO HIGH-IDENTIFICATION AND SATISFACTORY [ ' LOCATIONS ENERGY LINES IN THE IMPLEMENTATION PROXIMITY OF THE
'! CONTROL ROOM t w.
n . ,+, , n +, -.w~ e - ., -, - .-
_ _ . _ _ _ _.. - _ _. _. _ _ _. _ _. _. -. ... _ _ _. _..__ _ _ _ _ __.._____ __ _,_ m. _ __.. ~. _ _. _.. IABLE 1 COMMITMENTS REVIEWED
(SHEET 3 OF 11) ,- (SEE NOTE 1) . RRT NUMBER SOURCE S[CTI04 GQ_MMLT_MMT SUB.JLG[ DOCUMMLJfMURE NRC R[y[FE D [.lNDj NG$f_Q.OMME N T S (SEE NOIL 2) 950 FSAR 3.6.2.1 filGH ENERGY BREAK ASME lil, DeV.
1, IDFNTIFICATION AND INADEQUATE GPC ' LOCATIONS (CLASS 1) CLASS 1 IMPLEMENTATION IDENilflCATION OF COMMITMENT. GPC
! IDENTIFICAllON BASED l-ON REFERENCE TO ASME , i CLASS 1 PIPING.
. ! REQUIREMENTS FOR ! ! BREAKS AT TERMINAL
l ENDS OF CLASS 1 HIGH l i ENERGY PIPING OUTSIDE ' ! THE PRIMARY RCL WERE l NOT IDENTiflED AS
PART OF THE COMMIT- , MENT.
REQUIREMENTS FOR INTERMEDIATE BREAK LOCATIONS ARE ! INCLUDED IN COMMIT- } MENT 954 r 951 FSAR 3.6.2.1 HIGH ENERGY PIPE BTP MEB 3-1 IDENTiflCATION AND INADEQUATE CPC BREAKS (EXCLUDING lMPLEMENTATION, VERIFICATION Of REACTOR COOLANT-LOOP) INCLUDED REVIEW OF IMPLEMENTATION, RRT , r I ADDITIONAL REGULATORY VERIFICATION BASED ON-I ' BASES (APRIL 26, 1984, REFERENCE TO MEB 3-1 LETTER FROM GPC TO IN SECTION 1.0 OF l NRC AND RESPONSES) DC 1018.
RRY 08D , ' 10 ALLOW OMISSION OF NOT IDENTIFY OR INTERMEDIATE PIPE FOLLOWUP ON ADDI-BREAK LOCATIONS TIONAL REQUIREMENTS REGARDING MfNIMUM DISTANCE FROM WELDED j ATTACHMENTS.
! (UNR 85-35-03) [ 952 FSAR 3.6.2.1 HICH [NERGY PIPE IN ASME lit, NC-3652 IDENTIFICATION AND SATISFACTORY h CONTAINMENT PENETRATION IMPLEMENTATION AREAS l 934 FSAR 3.6.2.1 HIGH ENERGY BREAK ASME lit, NB-3653 IDENTIFICATION AND INADEQUATE CPC INTERMEDIATE LOCATIONS IMPLEMENTATION VERIFICATION Of i (CLASS 1) ( SEE COMMENTS ON lMPLEMENTATION, RRT ! COMM. 951) VERIFICATION BASED ON ! REFERENCE TO NB-3653 l IN SECTION 3.3.B.2 OF DC 1018 ( SEE COM- . l-MENTS ON COMM. 951) { (UNR 85-35-03) l
l
. I h ! t i
=
_ _ _ _ _.. ___.__m__._ _ __.m._ __ m ._____.______.m.___.______.-_.-._.-_ _ _.... _ _ _. . _ IABLE 1 COMM11HENTS REVIEWED , (SHEET 4 OF 11)- . (SEE NOTE 1) l ~ RRT 'HUMBER SOURCE ELCT lOff COMMITM M I_Suly[GT POCSMMU[Aluf![ NRQ_RLyl W[D FINRINGS/COMdENTS } (SEE NOTE 2) 935 FSAR 3.6.2.1 NON-NUCLEAR (NOT ASME ) ASME III FOR CLASS 2 IDENTIFICATION AND SATISFACTORY l PIPING BREAK LOCATIONS AND 3 PIPING IMPL EMENT AT ION ' 936 FSAR 3.6.2.1 HIGH ENERGY INTER-ASME Ill, NC-3600, IDENilFICATION AND . INADEQUATE GPC [ MEDIATE BREAK NC-3652 IMPLEMENTAT ION (SEE VERIFICATION OF ( LOCAiIONS (CLASS 2 COMMENTS ON COMM. 951) iMPL IMEN T AT ION, RRT r AND 3 ) VERIFICATION BASED i ON REFERENCE 10 l' NC 3652 IN SECTION , ! 3.38.3 of DC 1018 l (SEE COMMENTS ON i
l COMM. 951) l (UNR 85-35-03) . I 957 ISAR 3.6.2.1 ASME SEC. Ill AND F LOODING [FFE CTS FROM IDENilFICAllON AND SATISFACTORY t i NON-NUCLEAR PIPING PIPE BREAKS DETEPHINED IMPLEMENTAllON ,
MODERATE ENERGY ON BASIS OF 30 MIN.
! l OPERATOR TIME REQUIRED
( TO FFFICT CORRFCTIVE
ACTION i 935 FSAR 3.6.2.1 THROUGH-WALL LEAKAGE ASME lit, NE-1120 IDENilflCATION AND SATISFACTORY [ CRACl(S IMPLEMENTATION
959 FSAR 3.6.2.1 THROUGH-WALL LEAKAGE STRESS GREATER THAN IDENTIFICATION AND INADLQUATE GPC CRACKS ON CLASS 1 1.2 SM lHPLEMENTATION VERiflCATION OF ! MODERATE ENERGY IMPLEMENTATION (MATHlX INDICATES VERitlCAllON OF
INCLUSION IN DC-1018, i TABLE 1.
NRC i INSPECTORS FOUND t - THAT COMM. WAS NOT j IMPLMENTED BY DC-1018).
I (UNR 85-35-04) j f 960 FMR 3.6.2.1 THROUGH WALL LEAKAGE STRESS GREATE R THAN IDENTlflCATION AND SATISFACTORY ' CRACKS ON CLASS 2 AND O.4 (1.2 SH + SA) IMPLEMENIATION [ 3 MODERATE ENERGY j PIPING j 961 FSAR 3.6.2.3 LONGITUDINAL BREAK OMISSION ALLOWED IDENTiflCATION AND SAilSFACTORY POSTULATION AT INT.
WHERE: CLASS 1 - IMPLEMENTATION (LIMii INCORRECTLY l POINTS OF ASME Ill, STRESS DOES NOT REPORTED AS 0.85 l CLASS 1 2, AND 3 EXCEED 2.5 SM (1.2 SH + SA) ON BOTH ! ' HIGH ENERGY PIPING (NB-3653) AND/OR IDENTIFICATION MATRIX USAGE DOES NOT EXCEED ( SECTION 3.4 ) AND ' O.1 CLASS 2 AND 3 - IMPLEMENTATION MATRIX STRESS DOES NOT EXCEED (SECTION 3.5)) .8 (1.2 SH + SA)
(NC-3652) i [ i -- - - .. .. ... ... .- ,-. _ _ -,._ - -.. . - - - - - .. - -..
_ . _ - _. - - _ _ _ - - . l . IABLL1 COMMITMENTS REVIEWED l (SHEET 5 0F II)
(SEE NOTE 1) . RRT NUMBER SOURCE SECTION COMMITM(yT SUlyfSCT DOQUHFP(T FEATUR[ NRC RWi[W[D [JJjplNG$/ COMMENTS _ (SEE HOIE 2) 1509 ISAR 1.9.1.1 ECCS CONTAINMENT RG 1.1 REV.
O, IDENT4F1 CATION AND SAT 4SFACTORY HEAT REMOVAL SYSTEMS NOV. 1970 IMPLEMENTATION DESIGN l ' 1532 FSAR 1.9.29 SEISMIC DESIGN RG 1.29 SEPI. 1978 IDENTiflCATION AND SAilSFACTORY, HUT CLASSIFICATION iMPLEMENIAlloN UNNECESSARY DUPLI-CATION OF COMMITHENT NO. 1754 1537 FSAR 1.9.37 QA REQUIREMENTS FOR RG 1.37, MAR. 1973 IDENilFICATION AND SAilSFACIORY, BUT CLEANING IMPLEMENTATION UNNECESSARY DUPLICA-TION OF COMMITMENT 1578 1543 FSAR 1.9.46 PR0iECTION AGAINST CONFORMANCE 10 BIP IDENilflCATION AND INADEQUATE GPC PIPE BREAK INSIDE MEB 3-1 AND BTP IMPLEMENTATION VER'FICATION OF CONTAINMENT ASB 3-1 IN LIEU OF (SEI COMMENTS ON . IMPLEMENTATION, RR RC 1.46 COMM. 951) VERIFICATION BASED ON REFERENCES TO MEB 3-1 i l AND ASB 3-1 IN ' SECilON 1.0 OF DC-1018 ( SEE COMMENTS ON COMM. 951) (UNR 85-35-03) 1569 FSAR 1.9.85 MATERIAL CODE CASE RG 1.85, REV. 20 IDENTIFICATION AND SATISFACTORY l ACCEPT. ASME III, (NOV. 1980) IMPLEMENTATION t DIV. I 1371 FSAR 1.9.85 MATERIAL CODE CASE ASME lit, DIV. I IDENTIFICATION AND SAflSFACTORY ACCEPT. ASME IIt, lHPLEMENTATlON DIV. I 1378 FSAR 1.9.116 QA REQUIREMENTS RG 1.116, REV. 0-R IDENTIFICATION AND SATISFACTORY FOR INSTALLATION.
(JUNE 19T6) IMPL E MEN T AT ION INSPECTION AND TESTING OF MECHANICAL EQUIPMENT AND SYSTEMS 1379 FSAR 1.9.116 QA REQUIR[MFNIS ANSI N45.2.8-1975 IDENilflCATiolN AND SATISFACTORY, BUT FOR INSTsLLATION, IMPLEMENTATION UNNECESSARY DUPLl-INSPECTION AND TEST:NG CATION OF COMM. 1578 OF MICHANICAL EQUlPMENT AND SYSTEMS , l ' 1599 FSAR 1.9.148 FUNCil0NAL SPEC.
RG 1.148. REV. O IDENilflCATION AND INADLQUATE GPC FOR ACilVE VALVE (MARCH 1981) IMPLEMENTAllON VERIFICAll0N OF ASSEMBLIES IN SYSTEMS IMPl EMEN TAT ION, RRT IMPORTANT TO SAFEIY BASED VERIFICATION ON CONFOPMANCE TO ASME CODE (AS REFERENCED IN DC-1010-TI) RG. 1.148 SPEClflES REQUIRE- [ MENTS ADDITIONAL TO ASME >
TABLLI COMMITHENIS REVIEWED (3HfFT 6 0F 11)
(SEE NOTE 1)
RRT NUMBER sol'RCE SECTION COMM11MEMT SUBJLCT DOCUMEtiLrfATUR[ NRC_REylFWED f l ND I NGS/ COMME,J T_S (SEE NOTE 2) 1611 FSAR 1.9.139 GUIDANCE FOR RilR RG 1.139, REV. O IDENTIFICATION AND SAilSIACTORY (MAY 1918) IMPt E MIN T AT 10N 1688 FSAR 3.9.8.3.3 CRITERIA FOR PRESSURr 110% OF STEAM IDEllflFICAT ION AND SATISFACTORY REllEVING DEVICES, GENERATOR DLSIGN IMPLEMENTA110N (HOWLVER RRT 6 AILED MAXIMUM ALLOWA8tf PRESSURE PER ASME 10 IDENTIFY OTHER INIERNAL PRESSURE CODE COMMilMENIS IN FSAR MAIN STEAM PIPE OR SECJ10N 3.9.8.3.3 - HEADER SEE NOTE 3) (UNR 85-35-01) 1743 FSAR 3.1.5 PIPING SYSTEM PENE-10CFR50, APP. J IDE NilflCATION AND SATISFACTORY TRAT10N CONTAINMENT IMPL EMENT Ail 0N 1744 FSAR 3.1.5 RCPB PENE1 RATING ASME III, CL. 2 IDENTIF1 CATION AND SAT 1SFACTORY CONTAINMFNT IMPL EMF P'T AT ION 1753 FSAR 3.2.2 VEGP CI ASSiflCATION RG 1.26, TEH. 1916 IDENTIFICATION AND SATISFACIORY SYSTEM I MPL EML f4 T AT 10N 1754 FSAR 3.2.2 VEGP CL ASSi flCAT ION RG 1.29, SEP. 1978 IDENTIIlCATION AND SATISFACTORY SYSTEM IMPL EMENTAT ION 1764 FSAR 3.5.1.2 2 INCH AND LARGER ASME lil IDENTIFICATION AND SATISFACTORY VAL VE DESIGN CRITERI A IMPLEMENTATION TO PRECLUDE VALVE SIEM EJECil0N 1765 FSAR 3.5.1.2 2 INCH AND LARGER CONTROL Of LOAD DURING IDENTIFICATION AND SATISFACTORY VALVE DESIGN CRITERIA BOLT TIGHTENING IMPL E ME t4 T AT ION TO PRECLUDE VALVE STEM EJECTION - 1778 FSAR 3.8.2.1 PIPE ATTACHED TO ASME lil, CLASS 2 IDEN11FICAil0N AND SATISFACTORY CONTAINMENT WALL IMPLEMENTATION 1779 FSAR 3.8.2.1 ISOLATION VALVE ASME Ill, CLASS MC IDENTiflCATION AND SAilSFACTORY ENCAPSULATION VESSEL IMPL EMENTAT ION ASSEMBLlES 1781 FSAR 3.8.2.4 DESIGN OF FLUED HEAD ASME Il1 ARTICLE IDFNTIfICAT10N AND SATISFACTORY OF PROCESS PIPING NC-3000 1977 THRU IMPLEMENTATION PENETRATION ASSfMBLIES SUMMER 1978 ADDENDA 1786 FSAR 3.8.2.1 PROCESS PIPE PENE-MAXIMUM OPERATING IDENTiflCAll0N AND SATISFACTORY TRATION ASSEMBLlLS TEMPERATURE RANGE 445 IMPLEMENTATION (HIGH TEMP, PIPING) DEGREES T - 557 DEGREES F 1787 FSAR 3.8.2.1 PROCESS PIPE PENE-DESIGNED TO LIMIT IDENTiflCATION AND SATISTACTORY TRATION ASSEMBLIES CONCRfiE MAX! MUM IMPLEMENTATION (HIGH TEMP. PIPING) TEMPERATURE TO 200 DEGREES F
IARE_1 - COMMITMtNTS REVit'WED
(SHEET 7 OF 11) (SEE NOTE 1) RRT NUMBER SOURCE SEC1 ION p_0MMITHEf(T SUBJ[Cl DOCUMQiT__f[6LILR[ NRQ_[t[Y! f.W[D FlNDINGS/ COMMENTS (SEE NOTE 2) 1788 FSAR 3.8.2.5 STRUCTURAL ACCEPIANCE ASME lil, D.1. SUB. NC IDENTIFICATION AND SATISFACTORY CRITERIA (CLASS 2 PIPING) IMPLEMENTATION '1789 FSAR 3.8.2.6 MATERIALS, QC AND ASME fil, SUL. NC, IDENTIFICATION AND SATISFACTORY SPECIAL CONSTRUCilON ART. NC-2000 (CLASS 2 IMPLEME NTAT ION TECHNIQUES PIPING) 1832 IEB-80-08 C-80/02/26 WELDING OF PENETRATION SLEEVE TO FLUED HEAD IDENTIFICATION SATISFACTORY SLEEVE TO FLUED HEAD WELDS ARE PERFORMED AT (OR INTERMEDIATE VENDORS SHOPS AND ARE SLEEVE FOR FLUED HEADS SUBJECT TO 100% RADIO-EQUIPPED WITH INTER-GRAPHY PER ASME lil, MEDIATE SLEEVE) NC-5200 1841 FSAR 3.6.2.3 BREAK PROPAGAil0N, PROPAGATION OF BREAK IDENTiflCATION AND INADEQUATE. GPC DID LARGE RCS PIPING TO UNAFFECTED LOOPS IMPLEMENTATION NOT IDENTIFY OR FREVENTED VERIFY NECESSARY PREREQUISITE CONDI-TIONS AS PART OF THE COMMITMENT 1842 FSAR 3.6.2.3 BREAK PROPACATION, PROPAGATION OF BREAK IDENTiflCATION AND INADEQUATE ( SAME LARGE etCS PIPING IN AFFECTED LOOP DOES lHPLEMENTATION COMMENT AS COMM.
NOT EXCEED 20% OF FLOW NO. 1841) AREA 0F RUPTURED LINE 1855 FSAR 1.9.31 CONTROL OF FERRITE RG 1.31, REV. 3, IDENTIFICATION AND SATISFACTORY, BUT CONTENT IN STAINLESS APRIL 1978 IMPLEMENTATION UNNECESSARY DUPLI-STEEL WELD METAL CATION OF COMM NO. 256 1989 FSAR 3.8.2.4 STEEL CONTAINMENT, ASME lit, ART NE-3000 IDEN11FICATION AND SATISFACTORY ISOLATION VALVE 19T4 THRU SUMMER 1976 IMPLEMENTATION ENCAPSULATION VESSEL ADDENDA ASSEMBLIES, DESIGN 2170 FSAR 6.1.1.1 ESF CONS 1 MATERIALS ASME IX.
IDENTIFICATION AND SATISFACTORY WELD MATERI ALS ( S.S. ) IMPLEMENTATION 2346 FSAR 5.4.7.2 APPLICA8LE CODES AND THE ENilRE RHRS IS IDENTIFICATION AND INADE00 ATE GPC CLASSIFICATION DESiCNE D AS NUCLEAR IMPIEMENTATION VERIFICATION OF SAFETY CLASS 2 WITH THE I MPL E MEN TAT I ON.
RRT EXCEPil0N OF THE SUCTION VERIFICATION BASED ON ISOLATION VALVES, WHICH REFERENCE TO ASME ARE SAFETY CLASS 1 CLASS 2 IN SECTION 1.0 Of DC-1205.
THE EXCEPTION THAT RHR SUCTION ISOLATION VALVES ARE ASME CLASS 1 IS NOT INCLUDED IN DC-1205.
. --- - - - -
- _ _ _.. _.
. -. -.. _. _.
. __ _.
._ _. -.. .m , _ _ _. . _. = _. . -.., _ ., _. _ _ -.. 20LE_1 l COMMITMENTS REVIEWED l (SilEET 8 0F 11) - l (SEE NOIE I) ! l RRT - * l NUMBER SOURCE SECTIUM COMMITM(NT SUBH (T, 00CUMrifT FEATURE NRC R Q/lEWFD f,13DijGS/ COMMENTS (SLE NOIE 2) l '2486 FSAR 6.2.2.2 MATERIAL THAT CAN AUSTENITIS S.S.
IDENTIFICATION AND SATISFACTORY - ! COME IN CONTACT WITH IMPLEMENTATION ! REClRCULATION FLUID -- CSS 2515 FSAR 6.2.2.2 DESIGN OF THE CONTAIN-RG'1.82. JUNE 1974 IDENilflCATION AND SATISFACTORY MENT EMERGENCY CORE IMPLEMENTATION l COOLING SYSTEM SUMPS . 2809 FSAR 6.2.7.2.E FRACTURE TOUGHNESS-ASNE 111, DIV.
1, IDENTIFICATION AND SATISFACTORY TEST FOR PRESSURE SUBSECTION NE, 1974 IMPLEMENTATION BOUNDARY PIPING TilRU SUMMER 1975 ADDENDA 2816 FSAR 6.3.2.2.9 REFUELING WATER DESIGNED TO SEISMIC IDENilflCATION AND SATISFACTORY t STORAGE TANK CATEGORY I REQUIRE-IMPL EMENI AT ION l MENTS. HEATER PROVIDED l 10 MAINTAIN MIN. WATER l TEMP, OF 50 DEGREES F.
! l 4673 lEB-79-28 C-80/08/05 POSSIBLE MALFUNCTION REPAIR VALVES WITH IDENTIFICATION AND SATISFACTORY
i 0F NAMCO MODEL EA180 NAMCO EA180 POSI T ION I MPL EME NI AT I ON IDENTIFICATION BUT ' LIMIT SWITCHES 0 SWITCHES WlIH SWi1CH IMPLEMENTATION , l ELEVATED TEMPERATURES HOUSING NOS. BETWEEN VERIFICATION WAS l (SAFETY-RELATED EQUIP-01-79 AND 08-79, SUPERFICIAL. I T WAS I MENT) PLACING VALVES ON HOLD BASED ON LETTERS FROM UNTIL REPAIR IS COMPLETE BPC TO GPC STATING ( WHAT HAD BEEN DONE 4674 IEB-80-05 C-80/08/05 VACUUM CONDITION LOW PRESSURE OR HOLDUP IDENTIFICATION SATISFACTORY l RESULTING IN DAMAGE TANKS THAT CAH CONTAIN i TO CVCS HOLDUP TANKS PRIMARY SYSTIM WATER ARE DESIGNED INTO SYSTEM 10 PRECLUDE VACUUM CONDITIONS 4675 IEB-83-06 C-83/11/23 NONCONFORMING INVOKE ASME lli, SUB.
IDENTIFICATION AND INADEQUATE. THE 'l MATERIALS SUPPLIED BY NX-2600, 1977. (TO IMPLEMENTATION ACIUAL COMMITMENTS TUDE-LINE CORPORATION.
VERIFY THAT CHEM-WERE NOT RECOGNIZED l (LONG ISLAND CITY, NY COMPOSITION OF TUBE-LINE AND, THEREFORE, THEIR HOUSTON, TX, CAROL LINE FiiTINGS IS ACCEPT-IMPLEMENTAT10N WAS t ! STREAM, IL) ABLE, l.E., IN CONFORMANCE 'NOT VERIFIED.
FOR ASME SECT. 111, APPLICAIIONS) i l ! . l , ,.. , ,, c _.
- u - - .. + - - - .. - - ,. - - - - - --- -
_.
. _ _ _ _. _. _.. _ _... _.. -. _. _. _ _... _. _ _ _ _... _ _ _ _ _ _. _ _ _ _ _... _.. _., . - _ _. _ _., __... _.. ,.... _. .. . . TABLE 1
COMMITHENTS REV1EWED
(SHEET 9 OF 11)
l (SEE NOTE 1) , i .
RRT
i NUMBER SE RCE SECTIQM QOMMITjiENT SUlyLGI DOCUENLf[AALUR[ NRC_ELylEWED UNDINGS/ COMMENTS J-(SEE NOIL 2) " 4679 IEB-79-24 'C-79/11/01 FROZEN LINES ALL SAFETY-RELATED IDENTIFICATION AND SATISFACTORY PROCESS INS 1R. AND IMPLEMENTATION , SAMPLING LINES THAT ARE PHYSICALLY ROUIED IN AN AREA EXPOSED TO EX1REMELY COLD WEATHER , SHALL BE PROV10ED WITH ADIQUATE HEAT TRACING '- ' 4890 IEB-79-03 C-79/05/09 JACKETED PIPE SPCOLS ASME Ill, 1914 ED., ' IDENTIFICATION AND INADEQUATE. GPC RR
IN CONTAINMENT SPRAY CLASS 2, (NCL. ADDENDA IMPLEMENTATION PERSONNEL IDENTIFIED ' i SYSTEM AND RHR SYSTEM: THRU SUMMER 1975) COMMITMENTS WHERE.
j 4 SPOOLS THERE WERE NONE.
! i FURTHER THEY DID NOT ,. t VERIFY IMPLEMENTATION j OF TifE SIGNIFICANT ,
ASPECTS OF THE '
COMMITMENTS THAT WERE j IDENTIFIED ! I i 4891 lEB-79-03 C-79/05/09 ' JACKETED PIPE SPOOLS ASME Ill, CODE CASE IDENTIFICATION AND lNADEQUATE. SAME ,
IN CONTAINMENT SPRAY N-32 BMPLEMENTATION . COMMENT AS FOR -- ! SYSTEM AND RHR SYSTEM: COMMITMENT 4890.
i 4 SPOOLS ! 4892 IE8-79-03 C-79/05/09 JACKETED PIPE SPOOLS 100% RADIOGRAPHIC IDENTIFICATION AND INADF40 ATE.
COMMIT-I < ' IN CONTAINMENT SPRAY INSPECTION IMPLEMENTATION MENT WAS INSUFFICl- , i SYSTEM AND RHR SYSTEM: ENTLY IDENTirlED AND '
4 SPOOLS WAS NOT UNDERSTOOD j NOR PROPERLY VERIFIED j 4913 FSAR 9.2.1-1 NSCW SYSTEM DESIGN MAX. HEAT LOAD DURING IDENTIFICATION AND SATISFACTORY . I l ACCIDENT CONDITIONS-IMPLEMENTAll0N (MIS-IDENTIFIED AS l IS 349.8 MILLION BTU /HR COMMITMENT NO. 4923 iN HEPORT TABLE i 6.1-2 " COMMITMENTS
VERIFICATION MATRIX") !
4914 FSAR 9.2.1-1 NSCW SYSTEM DESlCN MIN. FEOW PER TRAIN IDENTiflCATION AND SATISFACTORY UNDER ACCIDENI IMPLEMENTATION < ! CONDITIONS IS
' 15,733 CPM . 4916 FSAR 3.2.2-1 NSCW SYSTEM DESIGN NSCW VALVES AND PIPING IDENTIIlCATION AND SATISFACTORY i OUISIDE CCNTAINMENT I MPLE MENT AT I ON APE ASME CLASS 3
' 4917 FSAR 3.2.2-1 NSCW SYSTEM DESIGN NSCW VALVES AND PIPING IDENTIFICATION AND SATISIACTORY
INSIDE CONIAINMENT IMPLEMENTATION , ARE ASME CLASS 2 i
1 i , _ , -,. -. ., m - , ,_ - e
LAB L U l l COMMITMENTS REVIEWED t (SHEET 10 0F 11)
l (SEE N01E 1)
RRT M_MB_LR SOURCE 1(Cl10J{ p_OMett.1MJ MI_E;lDRCI QOCUMEN M ATUR[ NRC RfylEWED f.l_tfDLtjGS/ COMMENTS m (SEE NOIE 2) 4928 FSAR 6.3.2.5 RHR SYSTEM PIPING 15 AUSTENITIC IDENilflCATION AND SATISFACTORY STAINLESS SIEEL IMPLEMENTAT10N 4929 FSAR 6.3.2.5 RHR SYSTFM PIPING IS ANSI CLASS 2 IDENilFICAil0N AND SATISFACTORY AND ASME CLASS 2 IMPLEMENTATION 4932 FSAR 3.2.2-1 BORIC ACID STORAGE BORIC ACID STORACE IDENTiflCAiloN AND SATISFACIORY TANK (BAST) TANK IS ASME CLASS 3 iMPLEMENTAll0N 4933 FSAR 3.2.2-1 BORIC ACID STORAGE BORIC ACID STORACE IDENTiflCAil0N AND SATISFACIORY 1 ANK (BAST) TANK IS SEISMIC CATE-IMPLIMENTATION CORY 1 --- IEB-77-04 C-78/Ot/03 CONTAINMENT SUMP Pil CALCULATIONS MUST BE IDENTiflCATION ACCEPTED EXPLANATION BASED ON MAXlMUM BORON THAT 1HIS COMMITMENT CONCENTRATIONS AND BELONGED IN MODULE WATER VOLUMES PERMITTfD 21W AND VERiflED ASSIGNMENT IEB-78-04 C-78/04/21 ENVIR0fMfNTAL QUAllIl-STEM MOUNTED tIMIT IDENTiflCATION ACCEPTED EXPLANAT10N --- CATION OR MODIFICATION SW11CHES ON VALVE S THAT THIS CGMMIIMENT Of DESIGN I t4SI DL THE CONTAINMt NI BELONGED IN MODULE 20 AND VERiflED ASSIGN-MENT IEB-79-03A C-81/04-02 ASME SA-312 TYPE 304 DEsiCN STRESSES IDENTIFICATION ACCEPTED EXPLANATION --- PIPE WITH LONGITUDINAL VERiflED LESS THAN 857.
THAT THIS COMMITMENT WELDS OF CODE ALLOWABLE BELONGED MODULE 11 AND TifAT IT HAD BEEN SO ASSIGNED . IEB-81-02 C-81/11/20 FAILURE OF GATE VALVES To BE MODIFIED IDENTIFICATION ACCEPIED EXPL ANATION --- VALVES TO CLOSE TO MEET REQUIREMENTS THAT COMMITMENT AGAINST DIFFERENTIAL BELOP,GED IN MODULE 16 PRESSURE AND VERiflED I T HAD BEEN SO ASSIGNED FSAR 17.1.2 QA REQUIREMENTS FOR ANSI N45.2.11, DRAFT IDENilflCATION INADEQUATE. GPC DID --- 17A.3 DESIGN OF NUCLEAR 2, REV. 2 NOT IDENilfY POWER PLANTS (UNR 424/85-35-03)
.-m _-. _. - _ m _ - - _ = _.. - _ _ _ - _ _ _ _ __ _ m .- . _. . .. . m - _ _ [ABR.,,,1 COMMITMENTS REVIEWED
(SHEET 11 0F - 11 ) ' (SEE NOTL 1) NOTES:
(1) The entries in the first five columns or this table vero taken from the CPC Module 4 report, Section 3.4 table, without substantive modification. Exceptions'to this are the last rive commitments, for wnich all entries were developed by NRC inspectors; and No. 1832, which had entires in the fourth and fifth columns modified by NRC inspectors for clarification. An explanation of the column headings is as follows: RRI Number - A reference.
number assigned to the commitment by GPC.
Source - The document containing the commitment (fSAR or lEH) identifies the fSAR section or GPC IEB response correspondence date.
Commitment Subject - The subject of the FSAR section or IEB.
Document / feature - The document or plant feature discussed in the ISAR section or the 108.
l NRC Reviewed - What the NRC review was to verify. Typically this was to verify Iden1111La11oD of the commitment i l-by the Readiness Review and in many instances to verify that CPC had properly determined implemagtalloD of_ the l commitment as indicated in thei r Module 4 report Sect ion 3.S.
findings / Comments - The NRC's findings as to whether CPC actions reviewed were satisfactory or inadequate, of ten accompanied by comments regarding the basis for the finding.
(2) ldenti fica t ion - indicates ' review to veri fy that the CPC Readiness Review properly identitled the commitment.
- Imolementation - indicates document review to verify that the CPC Readiness Review satisfactorily identified document sources (s) that implemented the commitment.
If the NRC review checked document in addition to these identified by GPC, the additional sources are given in parenthesis.
. (3) Other applicable cormitments associated with criteria-for pressure relieving devices (FSAR Section 3.9.B.3.3) and not identified by RRT during identification of commitments 1688 and 1689 (The Requirement to use a 2.0 ' dynamic load factor which was assigned to module 11) are as follows: j i a.
Relief valve connections will be spaced on the header so that the re i s no local interaction ( Implemented
by DC-1017 - 3.2.A.3) b.
Reaction force and moment affects on the steam header, supports, and connecting nozzles for each valve blowing for combinations of valves blowing shall be considered. The steady blowdown lead is not transmitted to the header but is carried by the structure, using a piston-type design (Implemented l by DC-1017 - 3.2.1) c.
The reaction force of the flowing valve shall be obtained from the valve manufacturer; however, the manufacturer's reaction force is verified by the total hydraulic reaction force analysis (Implemented by DC-1017 - 3.2.1) d.
Stress analysis of the safety and relier valve system is conducted including evaluation of the header local stresses due to reaction moment when applicable (Implemented by DC-1017 - 3.2.1) e.
Ma te ria l thicknesses are selected to accommodate expected loads and maintain stresses within allowable limits (Implemented by DC-1017 - 3.2.1) The inspectors questioned whether the above commitments would be assigned to other modules.
CPC's response did not indicate module assignments. Need for further review on this item is included in Unresolved Item
Item 424/85-35-01, Assurance of Adequate Readiness Review Coverage of Module 4.
t , ! l i , . , .- .. -. - - - - . _ - .-
-- __.. . . TABLE 2 COMMITMENTS AND REQUIREMENTS VERIFICATION REVIEW (SHEET 1 OF 2) , ( See Note 1) FSAR HRT Requ i rement/Commi tment Section Classification Descriotion or IEB Commitment Requirement Veri fication Documents Review findings / Comments FW System , Colg weather protection ICB 4679 PklD 1x4DB133-1 No heat tracing in c . + (See proper location f!r small dias.eter lines 79-24 com-but no note on ment) DWG. (See Note 2) dSCW va'Ives and piping ' Table 4916 P&lD 1X4DB133-2 Yes Satisfactory -
outalde centainment are 3.2.2-1 Proc. Specs X4AR01, for all docs.
X4AR21 and X5ACO3 all ASME Cisss 3 Docs.
,. NSCW valves and piping Table 4917 PalD 1X4DB135-1 Yes Satisfactory - IIulde Containment 3.2.2-1 Proc. Spec. X4AR01 for for both Docs both cre ASME Class 2 Docs.
MSCW pumps (2 per train) 9.2.1.2.2 X Proc. Spec. X4AF02 Yes Sa t i sf acto ry - Vendor Doc., Bechtel for all docs.
cnd standby pump are tog 1X4AF02-142-1 all
ruted at 8600 CPM at
Bingham-Wiliamette Docs.
230 ft. head Co. pump test curve , e '. St System Cold weather protection IEB-4679 P&lD IX4DB121, Rev. 14 No Sa t i sfacto ry f;r small diameter lines 79-24 RHR System Pising is austenitic 6.3.2.5.2B 4928 Line List Yes All documents IX4DR004, Rev. 4 for checked were ttainless steel.
FAB. ISO.
all sa t i s fac to ry 1K3-1205-003-01 Docs.
1K3-1205-004-01 1K3-1205-006-02 1K3-1205-019-02 Material Class AX40RD01 PalD IX4DB112 Rev. 13
_. -. - _- - l l l
( = Table 2 f COMMITMENTS AND RfQUIREMENTS VERiflCATION REVIEW
(SHEET 2 0F 2) l FSAR l C qui rement/Commi tment Section Classification RRT Description orIED Commitment Requirement Ve r i f icntog_pmamen t s Revlev Findings / Comments ANSI sarety class 2, 6.3.1 4929 P&lD 1X4DB122, Rev. 13 Yes All documents
saismic Category 1, ASME 6.3.2.5.28 TAB. ISO.
For checked were ! class 2 pipe 1k3-1250-nO4-01 all satisfactory th3-1205-006-02 Docs.
1K3-1205-019-02 Line List IX40R004, Rev. 4 Boric Acid Storage Tank Ustble BAST capacity is Table X Proc. Spec. X4AH03 Yss Sa t i s fac to ry 46,000 gal.
9.3.4-2 Table 1 Design temperature: 200*r Table X Proc. Spec. X4AHO3-Yes Sa t i s fac to ry 9.3.4-2 SK-4-76 Rev. G l Desi an pressure: Atmosphe ric Table X Proc. Spec. X4AH03-Yes Sa t i s facto ry 9.3.4-2 Sh-4-76 Rev. C Matorial: Austenitic SS Table X Proc. Spec. X4AH03 Yes Sa t i sfacto ry 9.3.4-2 Section 4 BAST is ASME Class 3 Table 4932 Proc. Spec. X4AH03 Yes Sa t i sfac to ry 3.2.2-1 Section 3.3.2 i l ! PAST is seismic Category 1 Table 4933 Proc. Spec X4AH03 Yes Sa t i s fac to ry Section 3.3.2 NOTES: l 1.
The t.ble headings are similar to those utilized in RR Modulo 4 report, Table 6.1-2.
For RRT review a "yes" entry" indicates that verification in the stated documents was examined by both the NRC and l the RRT.
"No indicates the verification was performed by the NPC but not the RRT.
2.
The commitment had been to include a note on all drawings requiring heat t rac i ng for small diameter piping susceptible to freezing temperatures. This was not done.
However examination or examples or drawings and design criteria documents by NRC indicated that other steps had been implemented that met the intent of the commitment.
! l i
. . . - _.
. . _.
_ _ _. _ _ _ _. t .. .. i.
I f TABLE 3 (; ' SUFHARY OF DESIGN DOCUMENTS REVIEWED BY'RRT AND NRC < Total RRT NRC
Review Area Number Reviewed Reviewed y , 260
-Commitments' Implementation.
-- . Design Criteria
23
, .t , Calculations;
313
21 s N ' Drawings'
l Machanical (P& ids)
11
Drawing Change-Notices ~4,000 ( 34,9
Procurement-
)6
' ' , ~ Specifications ) ' ' .( l ' ! Construction: Specification 368
0 ' Change Notices ', e ,i n ., ., , .Urknowd'
Field ' Change Requests $ ' ' f
'
e.
! - Daviation Reports d,4,000, '100
' f ,
, Supplier Deviation- ,146
0 ' I Disposition.R'equests e ,: > , kquipmintQualit'ication Unkn6wn \\I 2
Documentation Y-p Q.
,/ t ,- , Field engineering. Change ~20
0 '. - i.
Ordsrs < s .
' [ Unknown 4-0 Supplier Q0alityVerificationDocumen)tation
- l,.-
2, ~ List Specs.
' 'c Vendor Drawings Unknown
1 . d g >
q o ^ >- ) 61.
><
- \\
)#
'- /
- y*
's z; ,. .. p ,. (; I - s
. __ . -- . '
TABLE 4 CALCULATIONS REVIEWED
(SHEET 10F 3) ' NRC Numbel Title Description Reviewed For RRT Review Findings / Comments (SEE NOTE 1) X6CXA-17 . Whip / Jet AFW Pumphouse RRT checklist items Yes Sa t i s fac to ry X6CXB-074 Jet Load RRT checklist items Yes Sa t i s facto ry X6CXB-079 Jet Load RRT checklist items Yes Sa t i sfacto ry X6CXB-099 Jet Impingement RRT checklist items Yes Sa t i sfac to ry X6CXB-128 Jet Impingement RRT checklist items Yes Sa t i s fac to ry X6CXB-130.
Jet Impingement RRT checkIlst items Yes Sa t i s facto ry
X6CXD-08 Aux Bldg. Missies RRT checklist items Yes Satisfactory X6CXD-01 Unit 1 Containment Missle RRT checklist items Yes Sa t i s fac to ry Analysis X6CHG-20.1 AFW Pumphouse P/T Analysis RRT checklist items Yes Sa t i s ra'cto ry X4C1202VO4 NSCW Pump Verification RRT checklist items Yes Satisfactory X4C1302V03 AFW Pump - Overspeed Trip RRT checklist items Yes Sa t i sfacto ry Verification X6CXA-14 Whip / Jet Control Bldg.
RRT checklist items Yes Sa t i sfac to ry X6CXA-25 Whip / Jet AFW Pumphouse RRT checkIist items Yes Sa t i s rac to ry, Concur with GPC-RR Findings 4-71, 4-72.
X6CXA-34 Containment Jet lapingement RRT checklist items Yes Sa t i s fac to ry, Concur wi th CPC-RR Findings 4-89, 4-72.
X6CXC-025 Flooding RRT chec'klist items Yes Sa t i s fac to ry, Concur witt. CPC-RR Finding 4-68.
X4C1301V03 AFW Pump Steam Supply RRT checklist items Yes Sa t i s fac to ry, - and Exhaust Pressure Drops Concur wi th GPC-RR Finding 4-70.
X6CXA-35 SIS Jet Thrust RRT checklist items Yes Quality Class Listed as 212, LDL lists Class as 111.
Otherwise, satis-racto ri ly X4PCESS16 Pipe Wall Thickness RRT checklist items Yes Sa t i sfac to ry, Concur with CPC-RR , Finding 4-7. TACLE 4
CALCULATIONS REVIEWED (SHEET 2 Of 3) - NRC Number Title Description lleylgwed For RRT Review {Jydinos/ Comments (SEE NOTf'T) X4PCESS17 Pipe Wall Thickness PRT checklist items Yes Sa t i s fac to ry, Concur with GPC-RR finding 8-79.
X4PCESS20 Pipe Wall Thickness RRT checklist items Yes Sa t i s fac to ry, Concur wi th CPC-RR finding 4-79.
X4 PCESS22 Pipe Wall Thickness RRT checkiist items Yes Sa t i s fac to ry, Concur with CPC-RR finding 4-79, 1K3-1205-006-02 Stress Calculation Design Conditions No Sa t i sfac to ry X4CP-7008 (Piping basic design data), incorporation of design changes.
1K3-1205-019-02 Stress Ca lculation Design Conditions No Sa t i s fac to ry X4CP-7011 ( Piping basic design data).
Incorporation of design changes.
1K3-1202-111-02 Stress Calculation Design ConditiCns No Piping analysis X4CP-7169 (Piping basic design indicates for lines data).
1202-111-2" & Incorporation of 1202-376-2" design changes, pressure is 150 psig. LDL indicates that the pressure is 200 psig.
Support a t Nodo PT 50 deleted, no supporting documentation.
Otherwise, sa t i sf a c to ry.
1K3-1202-110-02 Stress Calculation Design Conditions No Piping analysis X4CP-7004 (Piping basic design indicates pressure data), is 150 psig.
LDL incorporation of indicates pressure design changes, to be 200 psig.
Otherwise, sa t i s fac to r. . . TABLE 12-1 INSPECTION AND RECORD REVIEW DETAILS FOR VALVE ENCAPSULATION VESSEL VI-1205-V4-001 (SHEET 1 0F 3) A.
Inspection Details Inspection for Compliance with Code and Drawing IX4AH04-23-13 Findings / Comments - Configuration Support / bracing in vessel that was not depicted on the drawing or described in the vessel specification.
The apparent lack of require-ments/ controls for these supports / brackets will be identified as Unresolved Item 424/85-35-15.
- Material thickness and weld size Sati sf actory for anchor bolt chairs , - Welds 7-12, 17, 18, 46, 47, 49, and 50 Welds 49 and 50 are partly undersize and show evidence of possible overgrinding.
This is identified as Unresolved Item 424/85-35-14.
The condition is possibly related to repairs described on DR MD 2264.
- Vessel nameplate Satisfactory - Valve nameplate Satisfactory i - General surface condition (all Satisfactory visible features) . ., . . . . .
. .
TABLE 12-1 INSPECTION AND RECORD REVIEW DETAILS FOR VALVE ENCAPSULATION VESSEL V1-1205-V4-001 (SHEET 2 0F 3) B.
Records Review Details Receipt Records Review for Compliance With Code, Drawing, and Procurement Specification Findings / Comments - Hydrotest Report Satisfactory - Air Test Report Satisfactory - Certification of Painting Satisfactory - Code Data Report for Vessel Satisfactory - Code NPV Report for Valve GPC requested to explain inconsistency-all piping is "L" grade but valve is not.
Inspector Followup Item (84-35-16) , - Pipe NPP-1 Code Data Report Satisfactory - Material Certifications for vessel Satisfactory flanges, 4" pipe and 14" pipe < - Material Certifications for E308-16, Satisfactory E309-16, ER308 and ER308L welding materials , - Penetrant Examination Reports for Satisfactory welds 17 and 18 ~ - Radiographic Examination Reports for Satisfactory welds 1, 3, and 46 - Welding Material Certifications and Satisfactory welder qualifications for welds 16, 17, and 46 i , . . - . . . . ....
. . TABLE 12-1 INSPECTION ANO RECORD REVIEW DETAILS FOR VALVE ENCAPSULATION VESSEL V1-1205-V4-001 (SHEET 3 0F 3) C.
Installation Records Reviewed for Compliance With Code and PPP Procedure Requirements Findings / Comments - Field Process Sheet for Tag No.
Satisfactory V-1-1205-V4-001 (dated 6/5/81) - for setting, bolting, and grouting - Material Requisition for Encapsulation Project class Vessel 1-1205-V4-001, SN 2431.10 improperly identi-fied as 212.
No apparent safety significance.
- Field Process Sheet for removing of Satisfactory expansion joint shipping clip - , Mark No. V-1-1205-V4-001 (dated 9/16/83) ' (included penetrant examination report, dated 5/31/85 for removal area.)
- Field Process Sheet for removing valve Satisfactory motor - Mark No. 1-1205-V4-001 (dated 9/20/82) - NCR MD-1888 (8/21/81) dispositioning Satisfactory damage to vessel head - Field Process Sheet for rewelding anchor Satisfactory bolts - Mark No. 1-1205-V4-001 (dated 10/12/81) - NCR MD-1217 (8/28/.81) dispositioning Satisfactory improperly installed anchor bolts - Periodic preventive maintenance / storage Satisfactory check record for vessel - Periodic preventive maintenance / storage Satisfactory check record maintained for valve up to turnover to operations - - - - - - - - - - - - - - - - - - - - - - - -
r --- l TABLE 12-2
INSPECTION AND RECORDS REVIEW DrTAILS FOR SPOOL FIECES , I .A Inspection Details l Spool Piece Identification Hardware inspegtlan findines Isometric IM3-1205-003-01 Spool Piece 003-S-08 Visual examination for configuration per drawing; Sa t i sf acto ry (14" pipe) proper Code requi red nameplate; 163' 2 3/16" elevation, S 6 15/86" length between elbows and 4" length between nipple and valve per drawing and final weld requirements per Code and drawing, o Spool Piece 028-S-01 Visual examination for configuration per drawing, Sa t i sfacto ry (14" pipe) proper Code required nameplate, orientation and identification or valve 122, 6" length per drawing a nd f i na l we l d requ i remen t s pe r Code a nd d raw i ng. Spool Piece 061-S-01 Visual examination for configuration per drawing Sa t i s fac to ry and riual weld requirements per Code and drawing
8.
Reco rd s Review Dela i l s Records Review rindings }gool Piece Identification Isometric IK3-1205-003-01 The following records were reviewed for compliance sa ti sfacto ry Spool Piece 028-S-01 with the Code and drawing - NPP-1 Data Report for spool piece (ASME Class 2) - NFV Reports for valve SNs E 9001-120-1 and - BI291 (Class 2) Pipe and rittings "L" grade austenitic stainless - steel Valve SNs match those noted in a walkdown - Radiography reports for pipe welds l - - Radiography reports for repairs to valve SN E9001-120-1 Valve materia l s for va lve SNs E9001-120-1 - ! and 81291 l l { l l l l -- .
, I
i t s IADtJ_1) [ RIADNiSS HEViIW MLCHANICAl. CONSIRUCI1ON IIAM IINDINGS HIVil.WID f~inding level / Resolution / NHC Number NR finding Category h oject_Responso Reviewed for findings / Comment 14-45 Arc strikes / weld
Hemoved in accordance liardware surveyed Sa t i s f ac to ry spatter on Code with PPP procedure IX-52.
f or complete removal piping.
4-56 Minimum clearanced on
Dispositioned use as is Unit I containment Additional sepa ra t i on installed code piping and minimum separation surveyed for additional problems identif'ied, 85-f0-01).
(inadequate hot pipe to r egia i remen t added to seperation problem ( l l' 8
raceway sepera tion).
specifications, specification revisions (See text) eeviewed.
(See text) 4-46 Weld stencils not en Ill Process sheets corrected Hardware surveyed / records sa t i s fa c to ry agreement with assoc-based on ha rdware veri f i-reviewed to substantiate lated process sheets, cation and other associated proper & complete corrective supporting data.
action.
4-83 Failure to notify NRC 1Il Revision of v er l a ted we l d i ng Agreement with detaiis re-tirasa t i s f ac to ry on revised corrective procedures not done since garding CDR 83-84? CPC project personnel action for 50.55(e) item wire was removed from site.
and related CDR 81-56 denied need
on fR-309L weld wire Revised response to be in NRC inspection report for a revised 82 -30 and response to a tot No. 05166 submitted to NRC Nos. 8'4-18,
88-134 CDR 83-42.
(See (42f/CDR 83-4?) (See Note)
4 Note) NOI[: besolution of CDR 83-4? by removal of the (R-309t weld wire f rom the site would not have satisfied related CDR 84-56 due to use of the wire on containment liner penetration welds.
Details regarding NRC review of these COHs a re item 428/85-35-17.
included in the inspection reports 16 sted, this item is identified as inspector followup
Inadequate Resolution of Headiness Review findings.
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