IR 05000424/1986004

Matl Control Insp Rept 50-424/86-04 on 860106-0711. Violations Noted:Valve,Fitting,Flange,Pipe & Tubing Openings Not Capped & Welding Electrode Heat Accepted for Use W/O Evidence of Radiograph

ML20214L159
Person / Time
Site:	Vogtle
Issue date:	11/05/1986
From:	Belisle G, Russell Gibbs, Jackson L, Moorman J, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214L130	List: IR 05000424/1986004 ML20214L128
References
50-424-86-04, 50-424-86-4, NUDOCS 8612020588
Download: ML20214L159 (13)

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UNITE 3 STATES

.[kmmeru'o NUCLEAR REGULATORY COMMISSION

[ REGION 11

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• ATLANTA, GEORGI A 30323 h- t L

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Report No.: 50-424/86-04 Licensee: Georgia Power Company

.P. O Box 4545

, Atlanta, GA 3030 Docket No.: -50-424 License No.: CPPR-108-Plant: ~ Vogtle Unit 1, Waynesboro, GA _

Appendix 21E: Material Control Inspections: January 6-10, January 21-24, April 21-25, June 2-6, June 16-20, and July 7-11, 1986 Participating NRC Offices: Region II Office,' Atlanta, GA Inspectors: A L. H'. '3a'ciEsoif,9enctor Ir(spector, RII

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%k J. HsNoorinan, FIf, . Readtor Inspector, RII V /df[ ~

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shla R'. 'D.' Gibbs, Reactor Inspector, RII D4te' ' Signed Approved by: < M(n ~

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TABLE OF CONTENTS Topic Page Summary 1 Scope of Review 2 Methodology 2 Evaluation 3 Findings 7 Conclusions 8

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'V0GTLE ELECTRIC: GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM

~ APPENDIX-21E-MATERIAL CONTROL

SUMMARY

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- This report documents 'an - evaluation of - Appendix 21E of the Vogtle Readiness

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_ Review Pr_ogram. Thi_s ' program is _ being conducted as an initiative of Georgia Power Company (GPC) management - to assure that all design,- construction, and

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. operational-. commitments have been properly implemented at the Vogtle~ Electric

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' Generating ^. Plant (VEGP) Unit -1. Appendix _21E, which is one of an antic.ipated

' eight' appendices, presents a review and assessment of the program-implemented by

- the project for materials control from receipt through issue to contractors for construction, and equipment maintenance from receipt until turnover to Nuclear .

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. This evaluation was conducted to determine if the results of the program review of materials- control activities presented in this appendix are an effective and

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accurate assessment of mat"erials control and preventive maintenance reouirements; that these' requirements are being properly implemented; and that the resolutions

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l of. findings identified'in the appendix were correc This. evaluation was performed by NRC inspectors from Region -II. .The evaluation was accomplished through a detailed review of all sections of the appendix-by:

1) ' verifying th'at the materials control and preventive maintenance commitments listed. in the appendix are correct and comply with Final Safety Analysis Report i

. (FSAR) . requirements; 2) reviewing the appendix findings and evaluating : the correctnessLof their resolutions; 3) reviewing a comprehensive and representative sample of .'the ; records. -reviewed by the GPC Readiness Review Staff (RRS);

4)-selecting and reviewing a comprehensive and representative random sample of-

. installed hardware and records concerning materials control and preventive -

maintenance activities; and 5) reviewing prior ' inspection activities in this

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i p During -the review, it was apparent to the NRC inspectors that GPC management

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. supported the program by active participation in the development and implementa-tion of the program. This evaluation also indicates that the licensee's program

review

of a selected sampling of materials control and preventive maintenance -

! activities was comprehensive enough to evaluate the effectiveness of the progra The documents that were included in the materials control review were receiving inspection reports, maintenance reports, supplier quality verification documentation, and completed equipment maintenance storage list (EMSL) card Four findings resulted from the RRS evaluation of materials control. All

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findings were considered level III, in that the findings were not safety significant. Two violations were identified by the NRC inspectors, one violation is discussed in NRC Inspection Report No. 50-424/85 62 and the other one in Region II Inspection Report No. 50-424/86-58. The violations identified by the NRC inspectors during the evaluation of this appendix are summarized below:

1) Violation 50-424/85-62-01: Openings were not capped on valves, fittings, flanges, pipe, and tubing to protect weld end preparations; and sub-assemblies in the warehouse storage yard were not stored on cribbing or equivalen ) Violation 50-424/86-58-01: One heat of welding electrodes was accepted for use without documented evidence that the material had been radiographed; another heat of electrodes was accepted without acceptable drop weight tests being documented on the certified materials test repor ) One unresolved item and several inspector followup items were identified during the review and documented in IE Inspection Report No. 50-424/85-6 The applicant delineated the appropriate corrective action for thes2 items in a letter dated April 10, 198 The NRC subsequently reviewed and-accepted the response in a letter dated May 8, 1986. (These items have been closed.)

Violations and audit findings similar to those identified above are to be expected at a site as complex as VEGP. These kinds of deficiencies warrant continuing management attention. The licensee has assigned Vice Presidents of Construction, Operations, Engineering, and Support onsite to assist in resolution of problems. The inspectors concluded that appropriate actions have been taken to control these kinds of deficiencie Details of the above findings and violations are discussed in the body of this repor . Scope of Review As stated in Appendix 21E, Materials Control, this appendix was developed by four individuals having specific expertise in receiving inspection, storage, and preventive maintenance activitie Appendix 21E consists of eight sections, excluding the Exacutive Summary. These sections are: E1, Scope; E2, Responsible Organization; E3, Commitments and Methods of Implementation; E4, Program Description; ES, Audits; E6, Major Program Changes; E7, Equipment / Maintenance Verification Program; and E8, Program Assessment / Conclusio Sections El, E2, and E8 were not reviewed to the depth and scope of other sections in that these sections are self-explanator Sections E3 through E7 were reviewed in depth to assess the establishment of an adequate program and to evaluate the effectiveness of implementatio .

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~ Independent verification of materials control was' accomplished by a walkdown of warehouses, storage. yards, and the power-block and a detailed inspection andoreview sof a portion of the. spent fuel- cooling system. Violations:

. identified during.these walkdowns are identified incNRC Inspection Reporta Nos. : 50-424/85-62 and ' 50-424/86-58. 0ther, data. evaluated during the onsit Linspections and inspector followup items identified are- discussed in the-Evaluations =section of this repor k

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"2; Methodology The -technical review of Appendix 21E was conducted in the Region 'II office -

during.the week of-December 16, 1985, and was supported by onsite inspection activities during the' weeks of January 6-10, . January 21-24, April 21-25, _

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June 2-6, June 16-20,.and July 7-11, 198 The office review- of Section 3.0 compared .the applicant's accepted QA

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. program licensing commitments with the Standard - Review Plan (SRP)

(NUREG-0800) positions, regulatory guides, industry codes, and Vogtle Final Safety Analysis Report (FSAR) document During the- onsite inspections, the Program . Description, Section E4, was -

- reviewed to determine : if responsibilities and work processes described therein. were being implemented as written. GPC procedures were reviewed to-verify that essential elements of the' accepted QA program were incorporated into these procedures as necessary to evaluate the adequacy of their materials control program. Audit reports and RRS' findings were reviewed to determine the ' significance . of the problem ' areas . identified and the effectiveness of the' proposed or corrective actions taken. .The inspectors reviewed earlier revisions and the latest revisions'of procedures to verify that they contained- implementing requirements consistent with FSAR commitment Inspector followup items and minor typographical errors identified during

.the reviews and documented in NRC Inspection Report No. 50-424/85-62 were corrected by GPC and documented in their submittal of April 10, 1986. This j' ,

submittal was reviewed and ' accepted as stated in NRC letter dated May 8,

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Evaluation b The. evaluation of each section of Appendix 21E is provided below. For each

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section, a description of each section, what was reviewed, and the basis of

! acceptance are provided.

l Section E1 - Scope t-

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This section defines the boundaries for which the materials control

!- program at GPC was reviewed. The original scoping st&tement that was submitted to the NRC for review was determined by the inspectors to

encompass a larger boundary than information in subsequent sections of L the appendix would support. This was identified as Unresolved Item I

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424/85-62-02 to GPC during the exit interview conducted on January 24, 198 In'a letter dated April 10, 1986, GPC revised the scope of Appendix E to properly address the boundary and augment conclusions reached-in the appendi Section E2 - Responsible Organization Section E2 presents a description and breakdown of responsibilities among supply and erect contractors, GPC, and other contractors for

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-materials control. Since control of material after issuance- from GPC is addressed in various - other modules, this section was reviewed for background information only. No followup or evaluation of this section was require Section E3 - Commitments and Methods of Implementation The inspectors performed a review of Appendix 21E, Materials Control, in the Region II office during the week of December 16, 1985. This review evaluated commitments listed in the appendix against FSAR l

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commitments, industry standards, and ANSI standards. The scope of Appendix 21E covers material control from the time of receipt inspection onsite, until the material is issued to contractors for installation. Control of materials while being shop fabricated onsite and installed is covered in other modules. For example, control of piping material after it has been issued from the warehouse is covered in Module 4, Mechanical Equipment and Pipin Li kewi se , welding electrode control from receipt inspection until issuance from the warehouse is covered under Appendix 21E; however, welding electrode control after issuance from the warehouse is covered under the respective modul In addition, contractor material control addressed in Section E2, states that the evaluation of material control programs of contractors is addressed in the modules that are scoped to include work performed by these contractor Equipment maintenance and storage of material, whether in the warehouse or stored in place, until turned over to Nuclear Operations is addressed in Appendix 21E. However, some items in the EMSL program are discussed in the respective module Section E4 - Program Description Measures necessary to establish an adequate materials control program are required by the Field Procedure Manual (FPM). This manual requires a program for receipt, inspection, document review, storage, mainte-nance, handling, and inspector qualification for items received by GP Materials received onsite are inspected for shipping damage by warehouse personnel. Receipt inspections are performed by Quality Control personnel, who are qualified to perform inspections. Materials

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are_then placed in a HOLD status until the documentation received with these materials is reviewed and accepted by the QC Document Review Section. After the documentation is accepted, a Documentation Acceptance Report (DAR) is issued which authorizes QC to remove the HOLD status ta Materials are then acceptable for issue -to contractors. The materials control program, after issue, is described in respective module Storage and maintenance of materials and equipment have to meet ANSI N45.2.2-1972 requirements. Storage requirements are specified in GD-A-30 and maintenance requirements are specified in GD-T-09. Field'

Procedure GD-T-11 establishes guidelines for rigging, hoisting, and transporting of permanent plant equipment. The inspectors did not evaluate the adequacy of GD-T-11 since all major pieces of equipment have been installe The inspectors' selected tag numbered equipment while in the power-block and verified this equipment was listed on the EMS In addition, approximately 20 items were selected and a review was performed by the inspectors to verify that GPC had incorporated vendors recommended maintenance requirements into their EMSL program. The control of maintenance activities has been refined by listing all Quality (Q)

material on a computer progra This refined prog. ram automatically issues required maintenance printouts on the 20th of the preceding month; thereby preventing inadvertent oversights. Equipment is removed from the EMSL program when systems are turned over to Nuclear Operations. These turnovers are documented by memoranda. The implementation of the computer controlled program will enhance the EMSL progra e. 'Section E5 - Audits VEGP has been approved by Bechtel Power Corporation (BPC) and Westinghouse Electric Corporation as a materials supplier as defined by the American Society of Mechanical Engineers (ASME). Surveys have been performed by each of. these corporations which confirmed an acceptable materials control program. The inspectors reviewed these audits to verify scope and depth of audits which accepted VEGP as a materials supplie The inspectors concluded that adequate measures were established to implement an effective materials supplier progra Section E6 - Major Program Changes Significant major program changes have not been necessary at VEGP since the initial issue of MD-A-01. This procedure was issued as a result of a violation that was identified and documented in NRC Inspection Report No. 50-424/77-0 Field procedure GD-T-30 was issued in 1979 to combine mechanical and electrical receiving, receiving inspection, storage, and handling to standardize and simplify the proces Past

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and present revisions of procedures were reviewed by the inspectors to ensure commitments were incorporated into change The program changes described in Section E6 reflect an accurate presentation of changes through the RRS evaluation. Subsequent to Appendix 21E, GPC has implemented an enhancement to the EMSL progra This enhancement is discussed in Section E8 of this repor g. Section E7'- Equipment / Materials Verification Program The materials control verification. program was conducted in two phases by the RRS. Phase one compared the commitment source document to implementing procedures. As discussed in Section E3, the inspectors evaluated commitments listed in this appendix with FSAR commitment This review confirmed that the apper. dix implementation matrix is consistent with. FSAR requirements. Phase two involved a review of selected hardware and documentation associated with the hardwar The inspectors selected a portion of the spent fuel cooling system for independent review to verify proper control of materials. The specific portion reviewed included the ten-inch piping from the flange joint at weld Joint A (of spool #4) to weld joint 002-W-02 on Train B of the system (Reference Isometric Drawing #1K7-1213-002-02). The 3/4 inch piping from spool #4 to valve X022 was also included in the revie The following actions were taken and attributes were verified to confirm proper control of materials:

The material markings from the installed materials were recorde * The design drawings (including the drawing for spools 3 and 4, Isometric Drawing 1K7-1213-002-02 and drawing AX40R001) were reviewed to determine the correct material to be installe The information recorded and verified on the in process work sheets and the material markings previously recorded were compared to the design drawings to verify that the correct material had been installed and verified. This comparison also verified material traceability in accordance with 10 CFR 50, Appendix B, Criterion VII * The Receipt Inspection Records and Vendor Supplied Material Certifications (including certified material test reports (CMTRs))

for selected items were reviewed to assure that the records were on file and met ASME Cod No violations or deviations were noted during this inspection of the spent fuel cooling syste _.

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h. Section E8 - Program Assessment / Conclusions Minor violations such as those identified in NRC Inspection Report Nos. 50-424/85-62 and 50-424/86-58 are problem areas which require continuing management attention; however, violations of this nature ,

will occur on a project as complex- as VEGP. The ' RRS identified equipment which had not been incorporated into the EMSL program. This finding was similar to a violation documented in NRC Inspection Report No 50-424/85-42 in that recommended preventive maintenance requirements for the Engineering Safety Features Chillers had not been incorporated into the EMSL program. The licensee response to this violation dated on November 21, 1985, was considered acceptable by Region II. Subse-quent to the RRS finding, GPC evaluated all Q-listed material on the BPC equipment list and incorporated this equipment into the EMSL program. GPC has initiated a computer controlled EMSL enhancement program to preclude inadvertent oversights in performing preventive maintenance. Evaluation of the enhancement program verified adequate corrective action to close Severity Level IV violation (50-424/85-42-01), Failure to evaluate or incorporate manufacturer's recommenda-tions into the EMSL progra Receipt of specialty items such as reinforcing steel, cadwell supplies, waterproofing, waterstop, and joint filler materials were evaluated during NRC review of Module 1. Therefore, these specialty items were not considered in Appendix 21 Findings Finding El identified that documentation was not available to verify that all safety related equipment had been entered into the EMSL program or exempted by engineering evaluatio Additional investigation confirmed that some safety related equipment had not been included in the EMSL progra The items were evaluated, inspected for deterioration, and either entered into the program or exempted. This finding is similar to Violation 50-424/85-42-01, as discussed in Paragraph Finding E2 identified that two stainless steel subassemblies were missing one end cap eac This finding is identical to Violation 50-424/85-62-01, in that the inspectors toured laydown areas in the piping storage yard and verified that a substantial number of subassemblies were missing end caps and were not stored on cribbing or equivalent. The licensee's response to this violation dated April 10, 1986, was accepted by NRC letter dated May 8,1986. The inspectors have toured the piping storage yard on several occasions since April 1986 and confirmed that adequate corrective action has been implemente .

, Finding E3 confirmed that air filters in -temporary protective covers used to protect electrical equipment were .not always installed. The inspectors made- a tour of the power-block area and verified that GPC had implemented a program to prevent damage to equipment. The failure

>to include air filters in Griffolyn protective covers would not have a significant adverse effect on the equipment. Cleaning the equipment is sufficient to prevent deterioration from construction dust. .Therefore, this failure to install air filters would not cause a safety proble Finding E4 appeared to involve a finding that material had been conditionally released to the field without prior approval. Investiga-tion of this finding confirmed that the item had been processed properly and was later downgraded to a non-findin Finding E5 identified that material was received from an unapproved supplier. Investigation of this finding confirmed that the material was supplied from an acceptable supplier. However, similar problems with unapproved suppliers and documents reviewed by the inspector when

- evaluating certified material test reports were identified in Violation 50-424/86-58-0 . NRC Findings Several findings were identified during the review as follows: Violation - Openings were not capped on valves, fittings, flanges, pipe, and tubing to protect weld end preparations; and subassemblies in the warehouse storage yard were not stored on cribbing or equivalent.

., (50-424/85-62-01) (Closed) Violation - One heat of welding electrodes was accepted for-use without documented evidence that the material had been radiographed; another heat of electrodes was accepted without acceptable drop weight tests being documented on the certified materials test repor (50-424/86-58-01) (Closed) Unresolved Item - Approximately fifteen examples of missing or damaged covers or closures on safety-related spool pieces or valves in the auxiliary building. One example of a stainless steel spool piece capped with silver colored tap (50-424/84-26-03) (Closed). Inspector Followup Item - 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 material control requirements after issue from warehouse storag These areas appear to be evaluated in individual module (50-424/85-62-02) (Closed).

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e. Inspector Followup Item - The audit matrix and finding matrix of Appendix E fails to include all violations and audit findings germane to material control which have been identified at VEG (50-424/85-62-03) (Closed).

f. Inspector Followup Item - 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 appendi The inspector's review of this appendix identified that structural steel is not included in this appendi (50-424/85-62-04) (Closed).

g. Inspector Followup Item - 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 EMS This finding was classified as a Level III finding since Level II is defined as a violation of licensing commitments or engineering requirements with no safety concern (50-424/85-62-05) (Closed).

h. Inspector Followup Item - ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and 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 area Appendix E, Section E4.3.1, General Storage Requirements states that instrumen-tation, 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 (50-424/85-62-06)

(Closed).

i. Inspector Followup Item - 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 Storage, a conflict in storage requirement (50-424/85-62-07) (Closed).

j. Inspector Followup Item - Appendix E, Section E5.1; There are apparent conflicts in this section in that one statement says that GPC had 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 appear to be 100. (50-424/85-62-08)

(Closed).

k. Inspector Followup Item - Appendix E, Section E5.3, INP0 Evaluations, has a conflict similar to the one in (j) above in that the text of the section states that five findings were identified while the Total Findings appear to be only fou (50-424/85-62-09) (Closed).

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.c' o 10 Inspector Followup Item - Appendix E, Section E5.6, Summary, states that there were 120 total audit findings. .However, when the Total Findings columns from Section E5.1 to E5.5 are summed, the result is 139. (50-424/85-62-10)(Closed). Inspector Followup Item - The inspectors selected the EMSL cards for Safety Injection Pump Motors to evaluate the preventive maintenance performed on this equipmen These -logs contain discrepancie (50-424/85-62-11) (Closed). Inspector Followup Item - The inspectors noted_ that the audit matrix contains listings of violations concerning records which were perceived ,

to be applicable to Appendix 0 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 Materials Contro (50-424/85-62-12)

(Closed). Inspector Followup Item - Paragraph E3.1, Commitments, 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 progra (50-424/85-62-13)

(Closed).

The licensee took prompt corrective action on the items identified during the review and each item has been reviewed and closed out by the NRC. Items of this nature are to be expected at a site as complex as Vogtl Collectively, these items did not represent a programmatic breakdow . Conclusions The NRC has reached the following conclusions relative to materials control, storage, preventive maintenance, and documentation of these activities for Vogtle 1. With the exception of those items / areas discussed earlier, we have determined the following to be acceptable:

Commitments - The NRC has reviewed the commitments listed in Section 3.0 of the Readiness Review Appendix. We have determined that the commitments are clearly identified and accurately reflect the source of GPC commitment The matrix is comprehensive and provides an accurate reference to proper Codes, Regulatory Guides, ANSI standards, or other applicable regulatory documents. With respect to the Implementation Matrix, we confirmed that the commitments were reflected in the appropriate design specifications and Construction procedure {

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Program - The NRC reviewed the description of the GPC program as given in Section 4 of.this module. The following areas of the program were reviewed:

Specifications Equipment Maintenance Storage List Receiving Inspection Reports Certified Materials Test Reports Document Submittals We have determined that the program description in Section 4.0 accurately reflects past and current programs involving materials control and preventive maintenance. The programs conform to commitments and are consistent with implementing procedure Audits - We have reviewed the section on audits and arrived at the following conclusion. GPC had an acceptable audit program. The audits were conducted in accordance with 10 CFR 50, Appendix B and implementing procedures. The audits were comprehensive and performed in a timely manner. The audits were in sufficient detail to identify significant problems including root cause Audit findings were identified to management, evaluated, and tracked until resolved in an acceptable manner. BPC and Westinghouse Corporation audits approved GPC as a material supplie The RRS identified findings during the verification of materials contro These findings were categorized on the basis of their individual signifi-cance and cumulative programmatic effect. These findings were reviewed by the NRC and evaluated as acceptable. This conclusion was based upon an evaluation of the analysis by the RRS, review of supporting information, previous NRC inspections, and the inspectors' judgemen Based on the reviews performed by the NRC of Appendix 21E, Materials Control, the evaluation of findings identified by the RRS, and the independent sample of materials control activities selected and evaluated, we conclude that GpC has implemented an adequate materials control progra I