IR 05000424/1985062

Insp Rept 50-424/85-62 on 860106-10.Violation Noted:Failure to Provide End Caps to Protect Weld End Preparations for Valves,Fittings,Pipes & Tubing & Failure to Store Piping Subassemblies W/Procedures

ML20140B094
Person / Time
Site:	Vogtle
Issue date:	03/07/1986
From:	Belisle G, Jackson L, Moorman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20140B051	List: IR 05000424/1985062 ML20140B048 ML20140B057 ML20140B094
References
50-424-85-62, NUDOCS 8603210324
Preceding documents:	ML20205P678 (8 May 1986)
Download: ML20140B094 (7)

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UNITED STATES g"t 5 E7g'o g, NUCLEAR REGULATORY COMMisslON y , REGION ll y j 101 MARIETTA STREET, * I e ATLANTA, GEORGI A 30323

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Report No.: 50-424/85-62 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle Unit 1 Inspection Conducted: January 6-10, 1986 Inspectors: /r u yb 37 L. H. Jackson W / Datie Signed

.l' t (1 J. H. Modrman, III~ ' /

3f)fS Date Signed Approved by: m G. A. BeUsle, Acting Section Chief 1[)h Dete' Signed Division of Reactor Safety SUMMARY Scope: This special, unannounced inspection involved 70 inspector-hours on site ,

in the areas of Readiness Review Appendix E, Material Contro Results: One violation was identified - Failure to provide end caps to protect weld end preparations for values, fittings, pipes, and tubing, and failure to store piping subassemblies in accordance with procedure .

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REPORT DETAILS

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Licensee Employees D. Adams, Warehouse. Supervisor

• E. Groover, Quality Assurance Site Manager (Construction)

D. McAffee, Quality Control Supervisor, Receivirg Inspection R. McManus, Assistant Project Construction Manager II Other licensee employees contacted included . engineers, technicians, and office personne .,

Other Organizations A. Nakashima, Bechtel Power Corporation, Readiness Review, Discipline Manager (Appendices)

• Ramsey, Southern Company Services (SCS), Readiness Review Project Manager

• Attended exit interview Exit Interview The inspection scope and findings were summarized on January. 10, 1986, with those persons indicated in paragraph 1 above.. The inspector described the areas inspected and discussed sin detail the inspection finding No dissenting comments were received.from the license Violation, Failure to provide end caps to protect weld end preparations for valves, fittings, piping, and tubing, paragraph 5.a. and failure to store piping subassemblies in accordance with procedures, paragraph Inspector Followup Item, The ' scope of Appendix E 'is -inconsistent with the contents, paragraph Inspector Followup Item, Audit matrix: and ' finding matrix of' Appendix E fail to include all violations and findings germane to materials control, paragraph ~

Inspector Followup Item, W. C. Ramsey letter to D. 0 Foster addresses .

Structural Steel, paragraph Inspector Followup Item, Readiness -Review Finding El_ is classified as '

Level III which-is inappropriate, paragraph '

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Inspector Followup Item, Storage requirements for electrical equipment conflicts with ANSI standards, paragraph Inspector Followup Item, Weatherproof and outside storage are specified for like materials, paragraph Inspector Followup Item, Conflict in number of audits, paragraph Inspector Followup Item, INP0 findings are inconsistent, paragraph Inspector Followup Item, Summary of Section E5, Audits, states that 120 findings were identified, paragraph Inspector Followup Item, Equipment Maintenance Storage List (EMSL) of Safety Injection Pumps and Motors contain errors, paragraph Inspector Followup Item, Improper classification of violations for records, paragraph Inspector Followup Item, Regulatory Guide 1.28 not included, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved Items were not identified during this inspectio . Readiness Review Implementation The inspectors toured warehouses, laydown yards, shop areas, and th$

powerhouse te verify material control adequacy as an approach to the evaluation of this appendix. Attention was given to the adequacy of housekeeping, materials identification, rodent control, levels of storage, access. control, environmental control, sources of contamination, electrical heater connections for motors, and fire protectio During this tour of the-warehouses, laydown areas and the powerhouse, it was noted that piping subasse.nblies and-valves, piping, fittings, and tubing were not being stored in accordance with ANSI standards in that ANSI N45.2.2-1972, Packaging,. Shipping, Receiving, Storage, and Handling of -Items for Nuclear Power Plants, paragraph 6.4.2 requires that caps and plugs be used to seal openings in items having. sensitive

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internal surfaces and to protect threads and weld end preparation The inspectors observed that many end caps on valves had fallen off while in storage and had not been replaced, that stainless steel pipe and tubing stored in the warehouse yard were not capped in accordance with the accepted Quality Assurance (QA) Program, and that weld end preparations on flanges and fittings stored inside warehouses were not consistently protected to prevent damage. This failure to protect valves, fittings, flanges, pipe, and tubing is identified as the first example of Violation 50-424/85-62-0 Similar violations were brought to your attention in our letters dated 5/13/81, 7/12/82, and an unresolved item by letter dated 10/17/8 The inspectors conducted a general inspection of the piping subassembly yard and noted that many of these assemblies were not stored on cribbing. This failure to store subassemblies in accordance with ANSI N45.2.2-1972, paragraph 6.1.2(4) is identified as the second example of Violation 50-424/85-62-01. A similar violation was brought to your attention in our letter dated 5/13/8 . Evaluation The scope of Appendix E states, "The scope addresses permanent plant materials, parts and equipment at VEGP (Vogtle Electric Generating Plant) from receipt through issue to contractors: for installation and storage / maintenance to transfer to Georgia Power Company (GPC) Nuclear Operations."

This scoping statement appears inconsistent with the text of Appendix E in that many areas of material control are not discussed. A specific example is that welding filler material does not appear in this appendi Also, it appears that Appendix E does not address all

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material control requirements after issue from warehouse storag These areas appear to be evaluated in individual module Until this scoping statement is clarified, this is identified as Inspector Followup Item 424/85-62-0 The audit mab-ix and finding matrix of Appendix E fails to include all violations and audit findings germane to materials control which have been identified at VEGP. The following are examples of perceived problems:

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Violation 424/79-07-02, Electrical preventive maintenance and rotation of Spray Pump Motors and Safety Injection Pump Motor Violation 424/81-07-02, No record of EMSL inspections' of Reactor Pressure Vessel and Boric Acid Transfer Pump for 9/80 and 3/7 Violation 424/82-16-01, Failure to perform periodic maintenance of equipment within specified maintenance period (this is listed underinspection).

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- Violation 424/82-19-01, Protection of valve Violation 424/82-29-01, Failure to control the storage and preservation of electrical equipmen Violation 424/84-11-01, Failure to follow procedure for protection of electrical equipment in control roo Until the audit matrix and finding matrix are reviewed and an evaluation made to include /not include these violations, this is identified as Inspector Followup Item 424/85-62-0 The transmittal letter to Mr. D. O. Foster from Mr. W. C. Ramsey dated October 30, 1985, states in part that problems experienced by other near term operating license utilities regarding structural steel are considered in this appendix. The inspector's review of this appendix identified that structural steel is not included in this appendi Until this apparent wording error can be clarified, this is identified as Inspector Followup Item 424/85-62-0 Readiness Review Finding El identified four equipment / material items

out of a sample of 34 for which there was no documented evidence to show that GPC Construction Engineering had evaluated them to determine whether the items were to be entered into the EMSL or whether these items were to be exempted from the EMSL. This finding was classified as a Level III finding by the Readiness Review Team. This finding appears to be a Level II finding since Level II is defined' as a violation of licensing commitments or engineering requirements with no safety concern Until this apparent misclassification can be corrected, this is identified as Inspector Followup Item 424/85-62-0 ANSI N45.2.2-1972, Packaging, Shipping, Receiving. . Storage, and t

Handling of Items for Nuclear Power Plants, Section 2.7.2, states that instrumentation, electrical equipment, and batteries, shall be stored in Level B storage areas. Appendix E, Section E4.3.1, General Storage Requirements states that instrumentation, electrical equipment, and batteries will be stored in Level C storages. The inspectors verified that the proper level of storage was actually maintained for the equipment onsit However, until storage procedures are changed to reflect the correct requirements, this will be identified as Inspector Followup Item 424/85-62-0 Appendix E, Section E4.3.1, General Storage Requirements, states that conduit and cable trays are to be stored in both Level C and Level D Storag Until conflict in storage requirements is resolved, this is identifed as Inspector Followup Item 424/85-62-0 '

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5 Appendix E, Section E5.1, states the following:

The Georgia Power Company (GPC) conducts regu;arly scheduled audits to verify compliance with project commitments. Audit findings and recommended corrective measures are reported to the management of the audited organization. The audit results are also reported to GPC management and the GPC Quality Assurance (QA)

organization tracks the acceptability and timeliness of the respons Georgia Power Company has conducted 55 audits relating to material control. The audits, summary descriptions of the findings, and the categorization of each finding are presented in the audit and finding matrixes at the end of this sectio The 38 GPC audits resulted in the identitication of 97 findings during the period from 1977 through the first quarter of 198 Categon Total Findings i

Receiving 4 Storage 78 Maintenance 7 Documentation 11 Total 100

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There are apparent conflicts in this section in that one statement says that GPC has conducted 55 audits and another statement says that they have conducted 38 audit This section also states that there were 97 findings; however, the total findings. column sums to 10 Until this apparent discrepancy in number of audits conducted and total findings can be resolved, this is identified as Inspector Followup Item 85-62-0 Appendix E, Section E5.3, INP0 Evaluations, has a conflict similar to the one in (g) above in that the text of the section states that five findings were identified while the Total Findings column sums to only four. Until this apparent conflict in the number of total findings can

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be resolved, this is identified as Inspector Followup Item

424/85-62-0 . Appendix E, Section E5.6, Summary, states that there were 120 total audit finding However, when the Total Findings columns from Sections E5.1 to E5.5 are summed, the result is 13 Until this apparent conflict in the number of total findings can be resolved, this is identified as Inspector Followup Item 424/85-62-1 The inspectors selected the EMSL cards for Safety Injection Pump Motors to evaluate the preventive maintenance performed on this equipment.

These logs contain discrepancies which should have been identified and

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evaluated by the Readiness Review Team. A specific example is that the EMSL card for the "B" Motor, tag numberAlso, 1-1204-P6-004-M01, has been there were questions listed as train "A" since 10-31-8 concerning documented records for preventive maintenance from early 1979 until 10-28-81. However, during subsequent inspections, GPC was able to produce records documenting maintenance on these pumps during Until the mislabeling is clarified for the "A" and "B" this perio pumps and the records reviewed to assure preventive maintenance was performed correctly, this is identified as Inspector Followup Item 424/85-62-1 The inspectors noted that the audit matrix contains listings of violations concerning records which were perceived to be applicable to Appendix D rather than E. A specific example is that violations 424/79-13-03 and 424/83-13-03 appear to be more applicable to Records than to Materials Contro Until this apparent misclassification can be clarified, this is identified as Inspector Followup Item 424/85-62-1 . Paragraph E3.1, Connitments, does not list Regulatory Guide (RG) 1.28, Quality Assurance Program Requirements, as being applicable to the VEGP Materials Control Program. It appears that RG 1.28 is applicable to this program. Until an evaluation can be performed by the licensee to determine RG 1.28 applicability, this is identified as Inspector Followup Item 424/85-62-1 The inspectors are concerned that the violations and audit findings have been listed in modules where they are riot applicable. This would distort the evaluation and lead to an inadequate evaluation of the overall program effectiveness. The RRT did not access the overall program effectiveness >

from 1977 through 1985. Therefore, the inspectors were unable to adequately evaluate the acceptability of Appendix ,