IR 05000424/1986003

Insp Repts 50-424/86-03 & 50-425/86-02 on 860113-24.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Housekeeping,Matl Control & safety-related Steel Structures & Supports

ML20138A288
Person / Time
Site:	Vogtle
Issue date:	03/04/1986
From:	Blake J, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138A283	List: IR 05000424/1986003 ML20138A275
References
50-424-86-03, 50-424-86-3, 50-425-86-02, 50-425-86-2, NUDOCS 8603140186
Download: ML20138A288 (22)

Text

-

UNITE 3 5TATES

/pR 884,##o NUCLEAR REGULATORY COMMISSION

[ , REGION 11 g j 101 MARIETTA STREET. * 't ATLANTA, GEORGI A 30323

\,*... /

Report Nos.: 50-424/86-03 and 50-425/86-02 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name: Vogtle 1 and 2 l Inspection Conduc ed: January 13-24, 1986 Inspector: /* h a-_m -

@Sd6 j G. A. HalTstrom ' ' Dat"e Signed Accompanying Personnel: L. G. Bruch, EG&G - Idaho, In G. K. Miller, EG&G - Idaho, In Approved by: 3 C J. ./BTake, Section Chief 'Dat6 Signed i E gitieering Branch tvision of Reactor Safety SUMMARY Scope: This special, announced inspection entailed approximately 200 inspector-hours on site in the areas of licensee action on previous enforcement matters (Units 1 and 2), housekeeping (Units 1 and 2), material control (Units 1 and 2),

safety-related steel structures and supports (Units 1 and 2), Readiness Review Module 8, Structural' Steel (Unit 1), and Itcensee identified items (50.55(e)).

Results: No violations or deviations were identified,

,

t 9603140186 860310 PDR ADOCM 0$000424 O PDR

_ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ -

.. . - _ _ _ _ _ _ _ _ _ _ _ _

. i

,

f REPORT DETAILS i

i Persons Contacted Licensee Employees

• D. O. Foster, Vice President and Project Support Manager

• C. W. Hayes, Project Quality Assurance (QA) Manager

• E. D. Groover, QA Site Manager - Construction

.

'

l R. W. McManus, Readiness Review (RR) Assistant Project Manager l G. M. Creighton, RR Team Member i l * A. McCorley, Project Compliance Coordinator l

L. N. Brooks, Civil Engineering Manager S. D. Halton, QA Engineering Support Supervisor i J. V. Dawsey, RR Team Member

'

R. F. Dinsdale, RR Team Member

• J. E. Seagraves, RR Discipline Manager (Construction)

J. B. Stanley, RR Team Member J. W. Corbett, Civil-Structural Quality Control (QC) Senior Inspector D. L. Dalenberg, Civil-Structural QC Senior Inspector Other licensee employees contacted included construction craf tsmen, engineers, technicians, operators, mechanics, and office personne Other Organizations

'

l *W. C. Ramsey, Southern Company Services (SCS), RR Project Manager l *G. R. Trudeau, Bechtel Power Corporation (BPC), RR Special Assistant

• J. H. Draggs, BPC, RR QA Representative

l

*M. R. Thaker, BPC, RR Civil-Structural Design Team Leader l *W. M. Wright, SCS, RR Discipline Manager (Design) '

l 0. Batum, BPC, General Heager, Vogtle Project Engineering l H. Derow, BPC, Piping Engineer, Materials Group l D. L. Kinnsch, BPC, Project Field Engineer

! J. L. Rudd, BPC, QA Engineer l D. L. Carlson, BPC, Materials and Quality Services Engineer l * Niehoff, BPC, Deputy Engineering Group Supervisor :

T. C. Clark, Pullman Power Products (PPP), Assistant QA Manager R. N. Riddle,'PPP, QA Supervisor NRC Resident Inspector

• Livermore, Senior Resident Inspector (Construction) ,

• Attended exit interview l

,

h

- - - _ _ . _ _ - - _ _ - _ - . . . - _ - - . . - - - - - _ .

f

.

2 Exit Interview The inspection scope and findings were summarized on January 24, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected. NRC questions intended to clarify the Module 8 report were discussed (See Attachment). No dissenting comments were received from the licensee and the Vice President and Project Support Manager agreed that Georgia Power Company responses would be provided by February 14, 198 (0 pen) Inspector Followup Item 424/86-03-01, 425/86-02-01; STRIVE Load Attachment Program paragraph 8.c.

(0 pen) Unresolved Item 424/86-03-02, 425/86-02-02, Polar Crane Design -

! paragraph 8.i(1).

,

(0 pen) Unresolved Item 424/86-03-03, 425/86-02-03, High Ctrength Belted l

Connections paragraph 8 i(2).

<

The licensee did identify as proprietary some of the materials provided to and reviewed by the inspector during this inspection; however, details from j those materials are not included in this repor . Licensee Action on Previous Enforcement Matters

! (Closed) Unresolved Item 424, 425/84-17-02, Visual Acceptance Criteria.

'

This item concerned deviations of visual acceptance criteria from the American Welding Society 01.1 Structural Welding Code (AWS 01.1-1975).

Appendix VC, Revs. O thru 8, to Bechtel Specification X4AJ01, Revision 12, includes several requirements for visual acceptance of l weldments on Seismic 1 steel structures and supports which are less I stringent than those imposed by AWS 01.1-1975.

l The licensee provided proposed engineering justification for all

'

deviations during an earlier inspection (Report No. 50-424,425/84-36).

t The proposed justification (Log: PFE-3730) had been reviewed and l additional concerns were identified to cognizant licensee personne Additional Bechtel sponsored clarification and engineering justifica-tion (File: X4A201: Logs: 855141, BG33246, an6 PFE-4883) were reviewed during an early 1985 inspection (Report No. 50-424,425/85-03)

and the licensee was informed that engineering justification and clarification were sufficient to resolve all concerns provided that adequate clarification could be obtained regarding the 3/32" undercut acceptance criteria incorporated in Specification No. X2AP01, Division CS, Section No. C5.1, Revision 4, paragraph C.5.1.5.8 versus the engineering justification of 1/16" undercut for Category A welds included in PFE-373 l l

l

-.

~

.

The licensee completed additional examination of this issue during the Readiness Review of Module 8 on Structural Steel. Need for additional clarification of statements on the Module 8 report on this issue was identified during a late 1985 inspection (Report No. 50-424/85-58).

Justification within PFE-3730 was partially dependent on an acceptable load tracking phase of the structural steel verification program. The acceptability of the program was not verified during readiness review of Module 8 due to its incomplete status. Clarification was further requested regarding the potential acceptance of main frame structural members with 3/32" undercu The inspector met with cognizant licensee and BPC personnel to examine

the BPC responses of January 10, 1986 (Log: BG34148) and January 15,

'

1986(Log: BG34154) on this issue.

l Less stringent undercut acceptance criteria than the previously

justified present limit of 1/16" requirements were specified during

November 1983 to June 1984 (Appendix VC) and October 1980 to August l 1981(C5.1, Revision 4).

BPC examined the construction activities completed during the October 1980 to August 1981 time frame (main structural steel erection l associated with levels C and D of the auxiliary building). Due to the type of connections involved (beam pockets in the walls). No attendant l

welding was required or completed for which the relaxed criteria j applie BPC also provided additional justification applicable to VC acceptance criteria during November 1983 to June 1984. The worst-case undercut condition allowed was 1/16" undercut in conjunction with 1/32" undercut, each applied to 50% of the flange width of the member. BPC l examined actual yield strengths recorded on Certified Material Test l Reports (CMTRs) for all 111 heats of Category 1 main structural steel i used at Plant Vogtle from November 1983 to June 1984. The least yleid strength for any heat was determined to be 36,300 psi (i.e., 300 psi or l approximately 1% greater than required by ASTM specification). The l

material associated with this heat consists of nine W14x193 columns l located at level A of the containment building.

l The most severe application of the full undercut allowance was i demonstrated to represent a reduction in column cross-sectional area of l approximately 1%. This 1% reduction is offset by the 1% increase above l minimum ASTM yield strength. Further design conservatism exists since l only 53% of the design capacity of these columns is required to meet the controlling design condition.

,

For all other main frame members in the containment building any l decrease in member capacity due to potential worst case undercut is L offset by a minimum increase of at least 5% above the minimum ASTM

! yield strength required.

l l

,

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ - _

'

.

The inspector concluded that NRC concern on this issue was satisfied since:

All Category 1 main structural steel had been examined and design margin justified for the potential worst case of relaxed VC acceptance criteri *

No welding had been required or completed utilizing the C undercut acceptance criterion of 3/32".

The inspector also concluded that the latest engineering justification removed any dependency on an acceptable load tracking program for acceptance of VC acceptance criteria. However, need for additional NRC review of the load tracking program is documented in paragraph below, (Closed) Violation 424, 425/84-30-01, Failure to incorporate Corrections on Revisions of Design Drawings i

Georgia Power Company's (GPC) letter of response dated December 27, 1984, has been reviewed and determined to be acceptable by Region II.

'

The inspector examined the corrective actions as stated in the letter of respons The inspector concluded that GPC had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the subject conditions, and developed the necessary corrective actions intended to preclude the recurrence of similar circumstances. The corrective actions identified in the letter of response were implemente (Closed) Violation 424,425/85-03-01, Failure to Adequately Accomplish Design Review GPC's supplementary letter of response dated May 10, 1985, has been reviewed and detennined to be acceptable by Region II. The inspector examined the corrective actions as stated in the letter of respons The inspector concluded that GPC had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the subject conditions, and developed the necessary corrective actions intended to preclude the recurrence of similar circumstances. The corrective actions identified in the letter of response were implemente (Closed) Deviation 424, 425/85-08-01, Deviation of Commitments to AWS D1.1 Requirements for Inspection of Porosity GPC's letter of response dated May 10, 1985, contends that a deviation did not occur based on engineering justification for allowable deviations from AWS D1.1 of Visual Acceptance Criteria (including porosity requirements). GPC's position is considered acceptable by Region II based on further evaluation and satisfaction of NRC concern

__ _ _ _ . _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ -

-

.

regarding Visual Acceptance Criteria as reported in paragraph above, (Closed) Violation 424, 425/85-08-02, Lack of Material Control From Instrumentation Satellite Warehouse GPC's letter of response dated May 10, 1985, has been reviewed and determined to be acceptable by Region II. The inspector examined the corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the subject conditions, and developed the necessary corrective

, actions intended to preclude the recurrence of similar circumstances.

!

The corrective actions identified in the letter of response were implemented.

l (Closed) Violation 424, 425/85-03-03, Failure of Pipe Support Field

'

Installation and Fabrication Procedure to Provide for Control of l Welding Quality l

l GPC's letter of response dated May 10, 1985, has been reviewed and l determined to be acceptable by Region II. The inspector examined the

!

'

corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject l violation, performed the necessary survey and followup actions to correct the subject conditions, and developed the necessary corrective actions intended to preclude the recurrence of similar circumstance The corrective actions identified in the letter of response were implemente (Closed) Violation 424, 425/85-14-02, Failure to Follow Procedure for Control of Welding Consumables l

'

GPC's letter of response dated June 6,1985, has been reviewed and determined to be acceptable by Region II. The inspector examined the corrective actions as stated in the letter of response and further reported in paragraph 3.h. below regarding similar violation i 424/85-40-03; 425/85-31-03. The inspector concluded that this item was

closed based on acceptable corrective actions regarding the more recent similar violatio (Closed) Violation 424/85-40-03, 424/85-31-03, Failure to Follow Procedures for Control of Welding GPC's letter of response dated November 1, 1985, has been reviewed and determined to be acceptable by Region II. The inspector examined the corrective actions as stated in the letter of response. This examina-tion included random surveillance over several days with no identified discrepancies for the following

l l

r

'

.

Conformance to electrode issue procedural re welding material distribution centers (WMDCs) quirements at PPP

Conformance to oven temperature requirements and review of attendant documentation

Query of PPP WMDC personnel (both shifts) regarding procedural requirements

Extensive field survey of electrodes issued for safety-related welding together with required documentatio The inspector concluded that GPC had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the subject conditions, and developed the necessary corrective actions intended to preclude the recurrence of similar circumstances. The corrective actions identified in the letter of response were implemente . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. Two new unresolved items identifies during this inspection is discussedinparagraphs8.i(1)and8.i(2). Independent Inspection Effort Housekeeping (548348), Material Identification and Control (429028) and Material Control 429408)

The inspector conducted a general inspection of Units 1 and 2 containments, the control building and the reactor auxiliary building to observe activities such as housekeeping, material identification and control; material control, and storag Within the areas examined, no violations or deviations were identifie . Steel Structures and Supports (Units 1 and 2)

The inspector observed welding work activities and reviewed records for steel structures and supports as described below to determine whether applicable code and procedure requirements were being me The appitcable code for pipe supports described herein, welded by PPP, is AWS D1.1-7 _ _ - _ _ - - _ _ _ - - - . _ - _ . - _ _ _ _ _ _ _ _ _ _ _

'

.

' Review of Nonwelding Quality Records (480668)

The inspector selected various safety-related structural components for review of pertinent records to determine conformance with procurement, <

storage and installation specifications and QA/QC site procedure ,

Records of the following items were selected for review to ascertain whether they (records) were in conformance with applicable requirements relative to the following areas: material test reports / certifications; I vendor supplied NDE reports; site receipt inspections; storage; *

installation; vendor nonconformance reports.

! ASME-NF Support Item Heat / Control No.

!

l S/16" x 2" SA36 Strap 35649/10819 NF i l

'

1/2" x 4" x 6" SA515 84542 ,

'

GR 70 Plate Within the areas examined, no violations or deviations were identified.

I WeldingActivities(551008)

l (1) Production Welding -

l The below listed welds were examined in-process to verify the  ;

l following: welding procedures and drawing available; WPS assigned

'

in accordance with applicable code; materials as specified;  ;

geometry as specified; fitua and alignments as specified; preheat }

l 1s.as specified; technique 'is as specified; welding electrodes are '

l as specified and consistent with tie code; welding equipment is as

'

specified; interpass temperature is controlled and consistent with the appitcable codes; interpass cleaning and backgouging are performed as specified; weld repairs are conducted in accordance ,

with specified procedures; base material repairs are properly documented; welder identification; and peening not done on root or -

final weld surface layer.

l Drawing / Support N Weld Status V2-1224-012-H014 R/2 Lug Backing Plate First Pass

!

to 4 x 4 Tube Steel

! V2-1392-055-H001 R/2 Plate to 4 x 4 Tube Fill Passes l

Steel i

V1-1204-124 H016 R/5 Strap to W12 x 65 First Pass Beam

!

l V1-1204-141-H003 R/1 1/2" x 6" x 7 3/8" First Pass

! Gusset to W14 x 257 l Beam Flange

!

. ,

'

.

V1-1204-141-H003 R/1 1/2" x 6" x 7 3/8" First Pass Gusset to W14 x 257 Beam Web V1-1204-144-H006 R/2 NF 5/16" x 2" Strap Fitup/ Tacks to 1" x 4" x 6" Plate and First Pass V1-1204-138-H001 4 x 4 Tube Steel to Fill Pass 4 x 8 Tube Steel

'

V1-1204-127-H012 R/4 1" x 10" x 10" Plate First Pass to Embed V1-1201-055-H601 R/0 Item C to Item D First Pass V1-1201-049-H003 R/3 NF 1/2" x 4" x 6" Fitup/ Tacks Plate to Channels The following inspector qualification status records and "QA/QC Inspector Qualification / Certification" records were reviewed relative to inspection of the weld joints listed abov Inspector Type of Certification AJF VT-I!

JFC VT-II DAC VT-!!

EAL VT-II (2) Welding Procedure Specifications and Quality Assurance Procedures (Units 1 and 2)

(a) WeldingProcedureSpecifications(WPS)applicabletotheweld joints listed in paragraph 6.b.(1), were selected for review and comparison with the ASME Code as follows:

WPS Process PQR IT8-!!!/I-1-BR-2 SMAW* 34A, 34B 1T12-111/I-1-08-12 SMAW/GTAWa* 45, 34A. 34B, SSA 558, 58

• SMAW - Shielded Metal Arc Welding

• • GTAW - Gas Tungsten Arc Welding The above WPSs and their su) porting Procedure Qualification Records (PQRs) were reviewet to ascertain whether essential, supplementary and/or nonessential variables, including thermal treatment, were consistent with Code requirements; whether the WPSs were properly qualified and their supporting

'

.

PQRs were accurate and retrievable; whether all mechanical tests had been performed and the results met the minimum requirements; whether the PQRs had been reviewed and certified by appropriate personnel and whether any revisions and/or changes to nonessential variables were noted. WPSs are qualified in accordance with ASME Section IX, the latest edition and addenda at the time of qualificatio (b) The below listed documents were reviewed to ascertain whether

<

the structural welding program had been approved by the licensee and whether adequate plans and procedures had been established to assure that welding would be controlled and accomplished consistent with comitments and regulatory requirement Document N Title

'

PPP-IX-50 " Pipe Support Field Installa-PCN #17, dated 4/1/85 tion and Fabrication Procedure" PPP-VI!!-3 " Control of Welding Materials" PCN #5, dated 2/27/85 PPP-V!-5 " Control of Process Sheets and PCN #2, dated 7/27/85 Weld Rod Stores Requisition" l PPP-X-18 " Field Welding Inspection" dated 11/15/85 PPP-GWS-111/1 " General Welding Standard" dated 3/28/84 (3) Welder Qualification The inspector reviewed the licensee's program for qualification of

'

l welders and welding operators for compliance with QA procedures and ASME Code requirements. The applicable code for welding qualification is ASME B&PV Code,Section IX, as invoked by GPC Specification X2AG06, Rev. 4, and X4AZ01, Section P.1, Rev. 8.

l The following welder qualification status records and " Records of Performance Qualification Test" were reviewed relative to the weld joints listed in paragraph 6.b.(1).

Weld Symbol Weld Symbol GL-3 PPP CY-1 PPP l YE PPP TK PPP l NM-3 PPP XP-1 PPP JF-3 PPP ZM-1 PPP JX-2 PPP RT-3 PPP '

.-_

.

Within the areas examined, no violations or deviations were identifie (4) Welding Filler Material Control The inspector reviewed the licensee's program for control of welding materials to determine whether materials were being purchased, accepted, stored, and handled in accordance with QA procedures and applicable code requirement The following specific areas were examined:

- Purchasing, receiving, storing, distribution, and handling procedures, material identification

- The following welding materials for those currently being used in completion of production welding were selected for review of purchasing and receiving records for conformance with applicable procedures and code requirements:

Type, Size Heat / Control N ;

E705-2 3/32" 97401 E7018 1/8" LLO23 E7018 3/32" MM013 E7018 1/8" KK086 E7018 3/32" MM022 E7018 S/32" EE079 E309L-16 3/32" GG092 i

'

E309L-16 1/8" GG098 ,

E308L-16 1/8" 1010 17 E308L-16 3/32" HH010 E308L-16 5/32" HH014 Within the areas examined, no violations or deviations were

-

' identifie . LicenseeIdentifiedItems(92700)

Prior to the inspection, the licensee identified the following item under 10 CFR50.55(e):

(0 pen) Item 424, 425/CDR 83-41. Embed plate Base Metal Failure

'

On June 6,1983, the licensee notified Region !! of a potential 50.55(e)

item concerning failure of embed plate material (Heat #7417461). Apparent lamellar tearing had caused failure of a flare bevel support-to-embed weld on a non-safety-related support. The final report was submitted on February 14, 198 The inspector reviewed supporting data from a reinspection program for safety-related supports which was completed to support the licensee's conclusion that the failure was an isolated l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

r

'

.

occurrence due to overweldin This item remains open pending further NRC review of the statistical data involve . Review of Readiness Review Module 8 Structural Steel General This inspection report docunents Region II's continuing site inspections relative to the evaluation of GPC's Readiness Review Module 8. Structural Steel. The inspection was conducted to aid in determining whether Module 8 provided an acceptable basis for its l reported conclusion, concerning Unit 1 of the Vogtle Electric l Generating Plant (VEGP), that the design and construction programs, and

processes associated with structural steel and welding, within the scope identified within this module were in accordance with applicable licensing connitments.

-

Readiness Review Module 8 is one portion (module) of a many part review I

being conducted by GPC to aid in assuring that VEGP Unit I will be l operationally ready in accordance with scheduled plans for obtaining an

'

operating license. The GPC Module 8 review activities, data and results are summarized in the Module 8 report, which was submitted to i

the NRC November 12, 198 The module report consisted of eight i sections: 1.0, Introduction; 2.0, Organization and Division of i

Responsibility; 3.0, Commitments; 4.0, Program Description, 5.0, Audits, 6.0, Program Verification, 7.0, Independent Design Review; and 8.0, Program Assessments / Conclusions.

l l Clarification of the Module 8 Report Need for clarifications of the Module 8 report was identified during an earlier inspectio The specifics are documented in Report No. 50-424/85-5 GPC responses for some of the issues / questions were

,

provided at the close of this inspection and NRC's assessment is not

,

yet complete. These issues are not addressed in this report. GPC i responses for two of the issues involved were provided during this inspection and were reported to be the major significant changes which have occurred after the April 30, 1985, effective date of the Module 8 repor The issues are the Visual Weld Acceptance Criteria (NRC Unresolved Item 424, 425/84-17-02) and the Structural Integrated Verification and Evaluation (STRIVE) program (i.e., Load Tracking l Program). Resolution of NRC concern regarding Visual Weld Acceptance l Criteria is reported in paragraph 3.a. need for further NRC assessment l of the Load Tracking Program is reported in paragraph 8.c. belo r

.

12 STRIVE Load Tracking Program Initial NRC concern regarding the STRIVE Load Tracking Program centered around its potential use as partial justification for relaxed visual acceptance criteria and its lack of assessment for acceptability during the Module 8 Readiness Revie Any dependency of Visual Weld Accept-able Criteria to the STRIVE program has been removed as reported in paragraph 3.a. However, need for further NRC assessment, regarding an acceptable STRIVE program is evidenced by the following:

Acceptability of the STRIVE Program was not assessed during the Module 8 Readiness Review

Adequate resolution of design verification finding 8-91 on containment internal steel is partially predicated on an L acceptable STRIVE program which "if implemented as planned, should

'

ensure adequate reconciliation of platform loading data."

Independent Design Review, Section 7.4.2.1.5 notes that the STRIVE program was not reviewed since "no project procedures were in i existence describing how this effort would be conducted." Further that "the conclusions of this review are based on the initial j design efforts and the presumption of a properly implemented load

.

verification program."

l BPC personnel provided further details on the STRIVE program during i

this inspection. Additional program specifics were provided through a l review of April 30, 1985 BPC correspondence and attachments (Log:

l 855920). Existence of controlling procedures was verified through i review of the Vogtle Project Reference Manual Part C, Section 40, Revision 0, dated December 20, 198 Completion of the STRIVE program including field verifications is schedule by June 1,198 The inspector determined that the STRIVE program should receive further NRC

,

examination, including a comparison of the program's results versus

! field verification for a sample of selected members. This further examination is identified as Inspector Followup Item 424/86-03-01; 425/86-02-01, STRIVE load tracking program, Section 1.0, Introduction Section 1.0 of the report indicated that Module 8 covered design and construction commitments and activities for Category 1 structural steel used at Plant Vogtle. The structural steel stated to be within the l scope of Module 8 included embeds, structural steel framing for containment internals and other Category 1 structures, anchorage for structures and equipment, pipe whip restraints, cranes and supports, liner plate systems and miscellaneous (,ategory 1 structural and stainless steel items. Readiness Review of the Welding Program at t

Plant Vogtle is also included in Module 8.

l

- _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ . - - _ _ _ _ _ _ _ _ _ _ _ _ _

r-

.

/

.

i Previous to this inspection, the inspector was aware of details associated with unresolved item 424/85-35-01, Assurance of Adequate Readiness Review Coverage of Module 4. This item anticipates further NRC examination of Readiness Review activities associated with ASME Section III mechanical equipment and piping which were not covered in the Module 4 report. One such activity is welding procedure and welder qualifications, as they relate to pipe welding. The inspector reviewed

'

this activity as included on Module 8 report sections 4.3.5 (program-matic description) and Sections 6.2 (Construction Verification). The inspector concluded that readiness review of welding procedure and g

welder qualifications related to pipe welding had been adequate as i included or. the~rMdule 8 repor \,

\ g , Section 2.0 Organization and Division of Responsibility

-

) f a

Section

, , construc$,. provides details on organization of the at plant design organization Vogtl This includesand field a brief a I destription of the organization, responsibilities, and interface

'

refetionships between GPC, BPC, and SCS for design, procurement, and

'; '

construction activities related to structural stee Field ct.nstruction organization details include those related to the three

, contractors performing the work covered within Module '

g The contractors involved are: Walsh Construction Company, the general civil contractor; Ingalls Iron Works Company; the Structural Steel erection and civi) fabrication shop contractor; and Chicago Bridge and

, Iron . (CB&I), responsible for the containment building liner plant

'

>

system, containmant locks and hatches, stainless steel liner plate for refueling canal, spent fuel pool liner, and steel liners for concrete tank The inspector completed the initial examination of Section 2.0. The L

objective during this examination was verification of general content i and accuracy. No significant errors or commissions were identifie i i

. Commitment Implementation 6i Section 3.0 provides the commitments GPC identified for Module 8 and

, the verification of their implementation. Subsections 3.1 through i' of Section 3.0 provided brief introductory information - including a definition of a commitment, information regarding the sources of the commitments, and aniisting of the typical documents that were deter-mined to implement comitment 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 commitments identified, Subsection providts an identification of other Readiness Review modules to which

'

, each Hodule 8 commitment was assigned and a determination as to whether implementation of the commitment was a design organization responsi-

,

)

+

+

i

r- ,- ,

,

.

'

? N

%

bility, a construction organization responsibility or the responsi-

'

bility of bot The subsection 3.5 matrix ifncludes, for each comitment, an identification of design and/or construction documents that were determined to implement the comitmen '

The inspector completed further review of trie material presented in the Module 8 Subsections 3.4 and 3.5 matrices "to determine whether the Readiness Review had satisfactorily identified commitments for the module and if it had satisfactorily determined their inclusion in implementing document NRC verification of implementation was completed for the majority of the previously chosen sample. During thfs review, apparent errors were identified in Table 6.1-2 which lists comitments whose implementation was reportedly verified to second level design documents. Clarifica-tion received from readiness review management was that Table 6.1-2 listed commitment subjects which had been verified to the second level design documents listed and that the . individual specific comitments were not implemented by the listed @. sign documents in all cases. The inspector concluded that the explanation provided by Readiness Review management was insufficient to remove all potential concern regarding verification of implementation to second level design documents for the specific individual commitments involve Further that supporting background documentation was insufficient to verify that Readiness Review had checked implementation of all individual commitments involve Therefore, an independent NRC verification of implementation to second level design documents was completed for all ' individual comitments listed on Table 6.1- Further details regarding NRC verification of commitment implementation will be provided in a later repor Program Description 4 Section 4.0 provides a summary description of VEGP program work activities for design and construction of Category 1 Structural Stee Section 4.0 also includes details regarding the project welding program. The inspector completed the initial examination of Section 4.0. The objective during this examination was verification of general content and accurac No .significant errors or omissions were identified. Necessary additional examination of details regarding the project welding program (Section 4.5) was not completed during this inspection. Further details regarding NRC examination of Section will be provided.in a later repor , ,

,

.

.

$ 1 L

, ,o

. -

l 15 l

. I t . Audits-

'% 471.-

,

Section-5.0 de. scribes a review of past audit findings (including NRC inspection findings) that was conducted as part of the Module 8 Readi_ ness Review. .GPC performed the review to assess the adequacy of '

I the: emphasis placed on resolution of audit findings related to the scope of.Mo'ule' d  !

!

The- inspector completed' further review of the data and rationale  !

i presented (including material relative to NRC findings), to determine l'

whether., proper emphasis had been placed on the resolution of audit

. finding ,

The inspector received clarification relative to acceptance criteria

'

' for structural welds and the STRIVE Load Tracking Program as reported in paragraphs 3.a., 8.b., and'8.c. The NRC examination of Section was not completed during. this inspection and further details will be provided in a later repor . Program Verification . l

.Section 6.0 describes.GPC's verification-to assure that the VEGP design and construction programs adequately implement commitment It  ;

contains summary data supporting the review assessment, including ,

- Readiness Review findings (violations of licensing comitments, project procedures' or engineering requirement identified by the reviewers) and a

their resolution. The Readiness Review findings were classified into levels of importance to plant safety. The following levels were used:  :

I -

Violation of licensing commitments, project procedures, or engineering requirements with indication of safety Concern ,

II -

Violation of licensing commitments or engineering requirements with no safety concern III -

. Violation of project procedures with no safety concerns.

Section 6.0 'is ~ ivided into two subsections, Subsection 6.1, which '

describes design program verification, and Subsection 6.2. which

<. describes construction program verificatio ,= (1) Subsection 6.1, Design Program Verification As described in the' Module 8 report, Readiness Review verification of the design program was' performed by a design RRT consisting of

'

!I

,'

'!

five personnel experienced in power plant design engineering. The verification was. intended to ensure, through sampling, that the

,f design processes for Category 1 ' Structural ' Steel - had been j

.

adequately controlled and had resulted in proper implementation.of >

'

licensing ' commitments in design documents. The module report

,

i$

.

l

- - ..,,,,+4 . , , . , - , , , . . - , - . . ,;--,- - , - , ,~,,,--,..,.---.,n.- .

,n,-.,-, , _

r-

.

l

describes the design program verification as having been performed in two phase Phase I was the verification of commitments documented in the Module 8 report Section 3.5 implementation matrix plus further review of selected commitments for their implementation on second-order design documents (Table 6.1-2). The NRC examination of Phase I during this inspection is discussed in paragraph Phase II was the verification that design activities were conducted in accordance with project procedures and QA require-ments (i .e. , ANSI N45.2.11). During the NRC examination of Phase II activities, an apparent discrepancy was identified regarding calculations for seismic qualification of the VEGP Polar Crane. Requested clarification is specified on the attachment to this repor The potential for inadequate Polar Crana design calculations is identified for subsequent NRC review as unresolved item 424/86-03-02; 425/86-02-02, Polar Crane Desig (2) Subsection 6.2, Construction Program Verification As described in the Module 8 report, the Readiness Review verification of construction was performed by a Construction RRT consisting of six personnel experienced in nuclear constructio It was intended to ensure, through sampling, that the construction processes for Category 1 Structural Steel had been adequately controlled and had resulted in proper implementation of licensing commitment The module report describes the construction verification as having been performed in three phases. Phase I was the verification of implementation of all construction related commitment The NRC examination of commitment implementation discussed' on paragraph 8.f. of this report included a sample of those commitments related to construction. Phase II included a technical review of construction records associated with Module 8 hardware scope and Phase III was field verification of randomly selected completed structure The Readiness Review verification of construction program activities resulted in 39 finding All except four of the findings were associated with either embedments (19) or Structural members (16).

The NRC _ field examination of Module 8 hardware during this inspection was limited to embedments and structural members to enable more rigorous assessment of potential generic problems and more in-depth review of most Readiness Review findings. Further details - regarding the hardware items examined, construction attributes assessed, Readiness Review checklists / assessment plans, and specifics of associated quality documentation will be included in a later report. An overview summary is as follows:

L

.

Embedments The objective of the Readiness Review assessment was to determine acceptability of the site programs for receipt of material, fabrication, installation, and inspection of embedded plates and anchor bolts. Quality documentation packages were examined for concrete placements on or near a randomly selected target date. Target dates were selected for each quarter of each year from 1978 through 198 Placements were chosen to represent a cross-section of elevations within buildings which comprise the power bloc A field examination was conducted of embedments within the placements and unique embeds chosen for further in-depth review of material receipt and fabrication documentatio The NRC assessment of embedded plates and anchor bolts began with examination of concrete placement documentation and random selection of placements in the Unit I containment, f auxiliary building and control building for field examina-tio During the field examinations, verification was completed for those unique embeds chosen by Readiness Review and additional embeds selected for further documentation review. A discrepancy was identified regarding the unique embed plate . (MK 11-TT-8027-15) associated with Readiness Review Assessment No.15A (Concrete placement A-11B-027B in Control Room Common Area Level B). Unique identification of all embedded plates within the placement was completed to establish that plate MK 11-TT-8027-15 was not include Readiness Review explanation for this discrepancy was that unique No. B027-15 had been obtained from the log of embeds fabricated for placement A-118-027B and had not been verified

. from field examinatio In order ~ to establish the discrepancy as an isolated case NRC field examinations were completed for 100% of the Readiness Review assesscents of

-

embedded item No similar discrepancy was identifie However, an additional example of discrepant conditions similar to those resulting in Readiness Review Finding 8-72 for concrete placement A-1118-027B was identified. Finding 8-72 identified disagreement between design drawing AX2011A003 and as-built conditions (F type embed plates shown

,

rather than TT type) for placement A-118-027B. NRC field

'

examination established that two of the TT embed plates shown on the latest drawing were not installe The inspector noted that the Module 8 report ' indicated that corrective actions had been completed for finding 8-72. Further that proposed corrective actions for adequate incorporation of-Design Change Notices (DCNs) within design drawings did not include' in-the-field verification of as-built condition Further that the two missing TT plates were . shown as installed on DCN 22 dated May 10, 1985, and issued to correct the discrepancy on drawing AX2D11A00 ., . . - . . .-

.

Readiness Review management informed that a significant change occurring after the effective date of the Module 8 report (see paragraph 8.b.) involved additional corrective actions in response to finding 8-7 Further that in-the-field verification by construction personnel of the as-built condition was now required prior to final DCN sign-of Also that the requirement for this verification was established by a revision of the PRM effective December 9, 198 Further that Deviation Report (DR)

No. CP-8487 had been issued to identify the discrepant condition on the crrostruction joint between placement A-118-027B and adjacent placement A-118-027 The inspector concluded that the missing TT plates was another example of a licensee identified problem and that additional corrective actions were sufficient to remove NRC concer *

Structural Members The objective of the Readiness Review assessment was to determine acceptability of the site programs for material receipt, fabrication, erection / installation and inspection of structural members. A total of 22 members were randomly selected for assessment from items installed in the field.

'

The sample included one member form each level of steel framing in the auxiliary, fuel handling and control buildings, six members from various elevations in the Unit I containment and one item from the Unit 1 steam tunne The NRC assessment of structural members began with a random

-

selection of three members previously examined by Readiness Review. An additional three members were selected to provide a broader coverage and to avoid examining only items already checked by Readiness Review.- A discrepancy was identified during examination of documentation relative to inspection of high strength bolting connections for member No. 5404-B4 (a suppcrting beam for the operating platform in Unit I containment). The inspection of the four connections involved was completed on December 7,1982 by an uncertified inspecto Readiness Review personnel informed that this type of discrepancy had been prcviously identified as a generic problem during GPC QA audits in 1982 (audit report CD04-82/90) and 1983 (AFR #353). Also, that Readiness Review finding 8-10 had identified an identical discrepanc However, that this type of discrepancy had been previously identified and justification provided during the Readiness

-

Review of Module 1, Reinforced Concrete Structure .. . - - , .

.

'

.

The inspector accepted the Readiness Review explanation after review of Section 6.2 of the Module 1 RR Report and the NRC Report No. 424/85-28. However, the inspector note.d that the present inspection program for high strength bolting was inadequate to identify potential overtorquing of high strength bolts to near failure limit Further that the common philosophy was that bolt overtensioning would not present a problem as long as the bolts did not break during

. installation. This is not a technically supportable interpretation of the AISC bolting specification commentary since the commentary is predicated on conformance to the AISC approved installation procedures. Also, that responses from QC inspectors established that potential overtorquing could have occurred due to lack of conformance to " turn-of-nut" requirements within Construction Procedure CD-T-16. The potential for additional corrective actions regarding high strength bolted connections is identified for subsequent NRC review as Unresolved Item 424/86-03-03; 425/86-02-03 High Strength Bolted Connection Attachment:

Substance of NRC Question on January 24, 1986 on Module 8

,

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . . . _ _ _ _ . _ _ _ _

, '.' -

.

.

ATTACHMENT

.

SUBSTANCE OF NRC QUESTION OF JANUARY 24, 1986 ON MODULE 8 Bechtel Specification Number X4ALO1, revision 1, dated'

December 14, 1978, provides " Technical Provisions for Furnishing, Detailing, Fabricating, and Delivery of Containment Building Polar Cranes for the Georgia Power Company, Alvin Vogtle Nuclear Plant, Burke County, Georgia". Paragraph 4. of Attachment 5 " Seismic Qualification for Polar Crane" requires dynamic analyses for eight different loading conditions for both Safe Shutdown Earthquake and Operational Ba' sis Earthquake as follows:

.

a. Trolly in center of span with full load in up positio b. Trolly in center of span with full load in mid positio .

c. Trolley in center of span with full load in low positio I l

'

d. Trolly in end of span with full load in up positio Trolly at end of span with full load in mid positio f. Trolly at end of span with full load in low positio . .. __, _ ..

l

,

.

.

g. Trolly in center of span with no loa f i

!

l h. Trolly at end of span with no loa l i

Load cases "b" and "e" are not included in the seismic design :

I calculation package (Bechtel Log Number AX4ALO1-46-2) provided [

by the polar crane supplier, Whiting Corporatio Please '

explain this discrepanc ,

Also, please provide justification that identification of the

!.

worst vertical loading condition will be obtained from analysis I

'

of only three positions, i.e., that a signfficantly more severe loading situation will not occur at some vertical position i

intermediate to the top, mid, or bottom positio i

!

[

i

,

l

>

0136h/023-6

. . . - . . --