IR 05000424/1986016
| ML20215C807 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/05/1986 |
| From: | Conlon T, Novak T, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20215C758 | List: |
| References | |
| 50-424-86-16, NUDOCS 8612150432 | |
| Download: ML20215C807 (13) | |
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Report No.: 50-424/86-16 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No. CPPR-108 Facility Name: Vogtle Unit 1 Module: No. 17, Raceways Reviews Conducted: March 4, 1986 through July 2, 1986 On-Site Inspections Conducted:
March 18-21, 1986, May 19-22, 1986, June 3-6, 1986, and June 23 - July 2, 1986 NRC Offices Participating in Inspections / Reviews:
Office of Nuclear Reactor Regulation (NRR), Bethesda, MD Region II, Atlanta, GA Reviewer: John Thompson, Project Engineer, NRR Inspectors: Milton D. Hunt, Reactor Inspector, Region II Tnomas McElhinney, Reactor Engineer, Region II Approved by: C g#ss C
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T. E. Conlon, Chief (Module - All Sections)
Date Si~gned Plant Systems Section DivisionofRegctorSafety,RegionII
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M. V.' Sinkule, Chief DatefSigned Projects Section 2C+
Division of R sctoF Projects, Region II
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o T. Novak, Deputy Director /~
Dat'e Signed Division of PWR Licensing A Office of Nuclear Reactor Regulations (NRR)
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i 8612150432 861200 PDR ADOCK 05000424 G
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TABLE OF CONTENTS Topic Page Sunnary 111 Scope of Review
Metho'dology
Evaluations
Findings
Conclusions
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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM, MODULE 17, RACEWAYS SUMMARY The Readiness Review Program, is being conducted as an initiative of Georgia Power Company (GPC) management to assure that all design, construction and operational commitments have been properly implemented at the Vogtle Electric
Generating Plant Unit 1.
Readiness Review Module 17 was submitted March 4, 1986, and presents an assessment of the programmatic aspects of engineering design activities and construction activities as they pertain to the design and instal-lation of cable trays, exposed and imbedded conduits, flexible conduits, Seismic
. Category I duct banks, pull and junction boxes. The scope of this module covers raceway-to-raceway and. raceway-to-support connections.
The raceways supports, including bolted connections and/or welding integral to these supports or their attachment to the plant structure, were -examined during review of Module 19, Electrical Supports. Only raceway holddown clips and conduit strap ilistallations
were examined during review of Module 17.
This evaluation was performed by NRC reviews from the Office of Nuclear Reactor Regulation (NRR) and Region II.
The evaluation was accomplished through a detailed review of all sections of the module including:
1.
Verifying that design and construction commitments listed in the module are i
correct and comply with Final Safety Analysis Report (FSAR)
requirements; 2.
Reviewing a comprehensive and representative sample of the records reviewed by the Readiness Review Staff.
I 3.
Selecting and reviewing a comprehensive and representative random sample of records for the specifying, purchasing, receipt inspection and storage, installation and inspection of raceway systems and components.
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Reviewing reports of past NRC inspections at Vogtle Unit 1 and construction
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deficiency reports (CDR) submitted by GPC in accordance with the require-
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ments of 10 CFR 50.55(e).
During the review, it was apparent to the NRC reviewers and inspectors that GPC
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management supported the Readiness Review by active participation in the develop-
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ment and implementation of the program. This evaluation also indicates that the i
licensee's program review was comprehensive and provides adequate assurance that the raceways were designed and in:talled in accordance with NRC requirements and FSAR commitments except for the findings identified by the NRC inspectors. Two violations relating to the failure to follow procedures were identified.
These two violations were not related to the installation, inspection or documentation of raceways, but rather related to the protection of installed raceways and control and removal of raceway components.
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These violations were identified in inspection reports issued prior to this report in order that the conditions cited could be corrected as soon as practical and permit review of the corrective actions, to resolve these violations.
One inspector followup item was identified in these reports.
Violation 50-424/86-31-08:
Failure to Follow Established Appropriate
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Procedure to Properly Protect Installed Equipment / Components
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Violation 50-424/86-61-13, Failure to Maintain Control of QC Accepted Conduit Support CS-7C4-102-068.
Unresolved Item 50-424/86-61-12, Review Inadequate Separation of Conduits AE
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423 PS 021 and INE 423 RX 019.
Included as a finding associated with this report is the following item:
Inspector Followup Item 50-424/86-16-01, Readiness Review Finding 17-2 and
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GPC QA Audit identified improperly torqued Bolts Securing the Raceway to the Support Details on these items are discussed in the main body of this report. Additional and more specific details are provided in supporting Region II Inspection Report Nos. 50-424/86-31 and 50-424/86-61.
Resolution of these items will be addressed in future Region II routine inspections.
It does not appear that the Violations, Unresolved, and Inspector Followup Items identified represent a significant programmatic weakness in the installation of electrical raceways, iv
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1.
Scope of Review The review of Module 17, Electrical Raceways, was performed by reviewers from the Office of Nuclear Reactor Regulation (NRR) and inspectors from Region II. Module Sections 1.0, 2.0, 5.0, and 7.0, which contain informa-tion concerning the Module introduction, company organization, division of responsibility, work processes, audits, special investigations and conclu-sions regarding the assessment of the Module, did not require as detailed a review or evaluation as the remaining sections. Sections 3.0, 4.0, and 6.0 deal with the more significant aspects of the Module.
These sections discuss the applicant's commitments, method for implementing these commit-ments, design and construction program description, and the design and construction program verification.
Review of these sections included a detailed review of the content, examinations of items identified as find-ings, an examination of a sample of documents reviewed by the GPC Readiness Review Staff, and an examination of an independently selected sample of documents in conjunction with a field walkdown.
2.
Methodology a.
NRR Review The review and evaluation by NRR focused primarily on the commitment matrix of Section 3.4 and the implementation matrix of Section 3.5, where these sections impact with respect to Section 3.4 commitments.
In these cases, the review was extended to include other related sections of Module 17, such as Section 4.0, Program Description, and Section 6.0, Program Verification.
The NRR review consisted of a comparison of the commitments listed in Section 3.4 and the guidance contained in the Standard Review Plan (SRP), and other regulatory documents such as the Safety Evaluation Report (SER), FSAR, and Generic Letters.
The staff also reviewed the commitments to ensure that all commitments necessitated by the SRP were included in the Readiness Review Program (all modules).
Since no questions of clarifications were found, an evaluation was performed based on the results of the initial review.
b.
Region II Review The review and evaluation by Region II inspectors were accomplished by reviewing the module in its entirety in the Atlanta Regional office beginning on March 4,1986, and by inspections conducted at the Vogtle site on March 18 - 21, 1986, May 19 - 22, 1986, June 3 - 6, 1986, and June 23 - July 2,1986. (Inspection Reports Nos. 50-424/86-31 and 50-424/86-61).
Section 1.0, Introduction, which presents an introduc-tion of the content and intent of the Module and Section 2.0 Organiza-tion and Division of Responsibility, which presents a description of the organization and responsibilities for the design and construction of raceways, were only reviewed for general content and pertinent background informatio.
Review of Section 3.0, Comitments, was performed in two parts.
The comitment matrix was briefly reviewed by Region II personnel since NRR performed an in-depth review as previously discussed. This review was accomplished by verifying that the design and construction commitments contained in the FSAR were referenced in the comitment matrix. Review of the implementation matrix was accomplished by verifying that the comitments were being correctly implemented in project documents, such as the design and construction specifications and procedures.
The comitment sources reviewed include the FSAR, Institute of Electrical and Electronic Engineers (IEEE) codes, Regalatory Guides (RGs), and American National Standard Institute (ANSI) standards.
Review of Section 4.0 Program Description, was accomplished by compar-ing the program description in the four subsections with FSAR require-ments, specifications, and procedure requirements. The inspectors also compared the described program with the inspectors' understanding of program requirements that have been inspected against and reported in previous inspection report (50-424/85-20).
Review of Section 5.0, Audits and Special Investigations, was accomplished by examining the three subsections for general content which gives a description of the design and construction audit program.
The inspectors also examined GPC QA audits and NRC inspection reports to verify that the identified findings had been previously reviewed and addressed.
Seven audit findings from Section 5.0 were reviewed to verify that the corrective actions planned for the identified findings were adequate.
Similar type findings were examined and evaluated in the review of Section 6.2, Construction Program Verification.
Review of Section 6.0, Program Verification, centered around Section 6.2, Construction Program Verification.
Section 6.1, Design Program Verification, was reviewed for content and was compared to the inspectors' understanding of the design program that had been inspected against and reported in inspection reports (50-424/85-25, 50-424/85-20).
Review of Section 6.2 was accomplished by reviewing and examining the resolution of the six findings identified by the GPC Readiness Review Team, examining records and performing a field walk-down of cable trays, conduits, and junction boxes that had been select-ed by the GPC Readiness Review Team to verify proper installation. The inspectors also selected an independent sample of cable trays, con-duits, and junction boxes to verify that the installation process was adequate.
Review of the six findings included examination of the quality records, procedures, and specifications associated with the items identified in the findings.
Records were reviewed for the
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Readiness Review Team and the inspectors' independent samples to ascertain whether the records reflect the work completed in accordance with requirements in the following areas:
Electrical raceway material receipt and storage
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Electrical raceway installation
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Electrical raceway post-installation inspection
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Deviation identification (DRs) and/or fire barrier separation
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requests (FBSR).
The field walkdown was performed to verify that the raceways were installed in accordance with the appropriate project drawings, specifi-cations and procedures.
The raceways were inspected to verify that they conform to the project documents in the following areas:
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Installed length Design size and type
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From and to locations Separation of safety and non-safety trains
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Raceway cleanliness / damage
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Bolt size and torque values
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Raceway identification
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Raceway grounding 3.
Evaluations The evaluation of each section reviewed is provided below.
For each sec-tion, a description of the section, what was reviewed, and the basis of acceptance is provided.
a.
Section 1.0 - Introduction This section of the module presents an introduction to the intent and content of the module organization, areas of evaluation, and status of the project.
This section was reviewed primarily for content and background information.
No additional followup or evaluation of the section was required.
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b.
Section 2.0 - Organization and Division of Responsibility This section of the module presents a description of the organization and division of responsibility of GPC, Bechtel Power Corporation (BPC),
and Southern Company Services (SCS) for design, procurement, and
. installation of electrical raceways.
This section was reviewed for content only. No additional followup or evaluation of this section was required.
c.
Section 3.0 - Commitments (1) This section of the Module contains a listing of commitments and implementing documents which are presented in two matrices.
The first matrix is the comitment matrix which contains a listing of the sources and subject of licensee commitments.
Comitments listed in this matrix were identified by the Readiness Review Staff through a review of the FSAR, responses to NRC questions, responses to generic letters, and responses to IE letters.
The second matrix is the implementation matrix which contains a listing of documents and features discussed in the FSAR and implementing documents. The Readiness Review Staff reviewed these documents to verify compliance with the comitment requirements.
(2) NRR reviewers and Region II inspectors review and evaluation of this section was performed by comparing licensing comitments and corresponding source documents with the SRP, RGs, the provisions of the industry codes and standards, the NRC question and answer records, the staff's SER and the FSAR documents. The review also included a review of comitment sources and implementing specifi-cations and procedures to verify that the FSAR commitments were being correctly implemented in project documents.
(3) A total of 43 comitments were reviewed. Based on this review, no l
questions or clarifications were developed and no omissions were identified.
The staff has determined that the commitments for
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Module 17 comply with the FSAR, the SRP, RGs, and industry codes l
and standards.
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Section 4.0 - Program Description l
(1) This section of the Module describes the work process followed for the design, procurement, site material control, the installation i
l and inspection for electrical raceways.
l (2) Review of this section by Region II inspectors included a detailed examination of the four subsections and a comparison of the program description with FSAR requirements, specifications and procedure requirements.
The program was also compared with the inspectors' understanding of the programs requirements that have been inspected against and documented in previous inspection reports (50-424/85-25, 50-424/85-20).
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(3) Review of this section indicated that-the program described in the four subsections ~ is generally correct and is in agreement with FSAR and Project requirements.
e.
Section 5.0 - Audits and Special Investigations
.(1) This section contains a discussion of the QA audit process, which includes audits, by GPC, SCS, Institute of Nuclear Power Organiza-tions (INPO), BPC, and NRC inspections. This section was reviewed to confirm that the audit process was identifying and resolving findings in the proper manner.
(2) Review of this section included a review of the three subsections, GPC-QA audits, and NRC inspection reports. The GPC audits and NRC inspection-reports were reviewed to verify that the identified findings were reviewed and addressed. GPC audit findings were not reviewed in detail because similar findings which appear in Section 6.2 were examined and evaluated for correct resolution and significance.
(3) Review by the inspectors indicated that this section is an accu-rate presentation of the audit process with the exception of one discrepancy identified. The matrix in Section 5.1, Design Audits, contains four GPC-QA audits which do not pertain to Module 17, Raceways.
This discrepancy was identified as a minor editing problem, therefore, no followup is necessary.
f.
Section 6.0 - Program Verification (1) This section discusses the methods used to verify that the design and construction activities conform to licensing commitments and project procedures. This section is divided into two subsections.
Subsection 6.1 describes the design verification program and subsection 6.2 describes the construction verification program.
(2) Region II inspectors reviewed the established design and construc-tion verification programs. Section 6.1, Design Program Verifica-tion, was reviewed for content and was compared to the inspectors'
understanding of the design program that had been inspected against and reported in inspection reports (50-424/85-25, 50-424/85-20).
Review of Section 6.2, Construction Program Verification, was performed in three phases.
The first phase review was accomplished by reviewing and examining the resolution l
of the six findings identified by the GPC Readiness Review Team.
i The inspectors verified that the corrective actions planned had
been implemented. The inspectors have determined that the resolu-
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tion of these findings are adequate. The second phase review was i
comprised of an examination of records and a field walkdown of i
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raceways that had been selected by the GPC Readiness Review Team to verify proper installation.
The records were reviewed to ascertain whether they reflect the work completed in accordance with requirements and the walkdown was performed to verify that the raceways were installed in accordance with the appropriate specifications and procedures.
The inspectors conclude that the records reviewed adequately reflect the work completed on the raceways and that the walkdown verified that the raceways selected by the GPC Readiness Review Team were installed in accordanceswith the project documents. The third phase review was accomplished by selecting raceways not included in the GPC Readiness Review program and performing a record review and field walkdown as described above in the Phase II review.
This independent sample of raceways was taken to verify that any findings identified by the NRC inspectors were consistent with the findings identified in the raceway sample reviewed by the GPC Readiness Review Team.
Three findings were identified in Phase III by the NRC inspectors.
the first finding involves a violation of the separation require-ment between conduits of different separation groups.
Further investigation revealed that a fire separation barrier request had not been initiated even though the conduits had been QC inspected.
This item will remain open and is identified as Unresolved Item 50-424/86-61-12. Instances of separation violations were identi-fied by GPC QA Audit and the GPC Readiness Review Team identified as Readiness Review Finding 17-1 (Level II).
The second finding consists of low torque values obtained for cable tray hold down clips. The inspectors randomly checked the torque for a number of hold down clips and in many instances the torque value was below the 40 ft.-lbs. as required by the specifications and procedures.
This item will remain open and is identified as Inspector Followup Item 50-424/86-16-01.
The third finfing involves a Readiness Review Finding 17-2 (Level I) and a GPC QA audit which identified improperly torqued bolts securing the raceway to the support.
Since this problem was identified previously and numerous examples of improperly torqued cable tray bolts have been found, it is apparent that this problem still exists and that more attention is needed to generate an adequate resolution.
GPC advised that a study revealed that the torquing values as they now exist are adequate.
This study will be reviewed during subsequent inspections.
During various walkdowns to verify raceway installations, the RII inspectors identified certain conditions which appeared to violate site procedures.
Inspection in the containment building revealed a section of cable tray located just above grating level that had been stepped or walked in and on to the point that the sides and bottom of the tray were distorted.
This item was identified as violation 50-424/86-31-08, Failure to Follow Established Appropri-ate Procedure to Properly Protect Installed Equipment / Components.
As a result of this finding, an extensive program of craftsmen training and the posting of instructions describing the proper protection of cable trays has been implemented.
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Walkdown of the auxiliary feedwater rooms revealed a conduit support that had been disassembled.
No work order or removal form could be found to support this action. This condition was identi-fied as violation 50-424/86-61-13, Failure to Maintain Control of QC Accepted Conduit Support ES-7C4-102-068.
This support was restored by actions required as the result of a Deficiency Report issued by GPC at the time the condition was identified by the RII inspector.
(3) Review of this section indicated that the review performed by the GPC Readiness Review Team for the design and construction verifi-cation program was comprehensive and adequate. Examination of the findings indicate that a problem area still exists concerning the low torque values obtained for the cable tray hold down clips.
This item will be followed-up on subsequent NRC inspections.
Examination of the quality records indicated there were represen-tative evidence of quality controls for raceway installations and indicated that the installation process was being controlled in accordance with the requirements.
g.
Section 7.0 - Program Assessment / Conclusions This section contains open corrective actions and statements addressing the independent assessment of Module 17 by GPC QA staff, Stone and Webster Engineering Corporation, GPC Nuclear Construction and Engineer-ing, and the Paadiness Review Board.
This section was primarily reviewed for content and background information.
The open corrective actions will be followed up during future NRC inspections.
4.
Findings The following findings were identified by the Region II inspectors during the review of Module 17, Raceways.
The findings are identified as either a violation, an unresolved, or inspector followup item. An unresolved item is a matter which requires further information and investigation to determine if it is acceptable or may involve a violation or deviation. Deficiencies will be pursued as an Inspector Followup Item (IFI) in future routine inspections.
Violation 50-424/86-31-08, Failure to Follow Established Appropriate Procedures to Properly Protect Installed Equipment / Components Violation 50-424/86-61-13, Failure to Maintain Control of QC Accepted Conduit Support CS-7C4-102-068 Unresolved Item 50-424/86-61-12, Review Inadequate Separation of Conducts 1AE 423 RS 021 and INE 423 RX 019.
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Inspector Followup Item 50-424/86-16-01, Readiness Review Finding 17-2 and GPC QA Audit Identified Improperly Torqued Bolts Securing the Raceway to the Supports 5.
Conclusions The NRC has reached the following conclusions for raceways at Vogtle 1 based on the review of Module 17.
a.
Summary of Specific Conclusions The NRC has reached the following conclusions relative to the design, procurement, construction, and records for raceways for Vogtle 1.
With the exception of those items discussed earlier, we have determined the following to be acceptable.
(1) Section 1.0, Introduction - The scope of the module is clearly outlined in Section 1.0.
The Module organization and project status were correct as of the date of Module publication.
(2) Section 2.0, Organization and Division of Responsibility - This section was - reviewed for accuracy and was verified as being correct.
(3) Section 3.0, Commitments - The NRC has reviewed the commitments which were listed in matrix form.
We have determined that the commitments are clearly identified and accurately reflect the source of the GPC commitments.
The commitment matrix is compre-hensive and provides an accurate reference to the proper IEEE codes, RGs, and other applicable regulatory documents.
The implementation matrix was reviewed to verify that the commitments were implemented in the appropriate design, procurement, or construction procedure.
(4) Section 4.0, Program Description - The NRC reviewed the descrip-tion of your program in the following areas:
Design
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Procurement
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Site Material Control
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Installation and Inspection We have determined that your program description accurately reflects past and present programs involving raceways.
These programs conform to your commitments and are consistent with the associated implementing procedures.
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(5) Section 5.0, Audits and Special Investigations - We have reviewed the audit program described in this section of the Module.
We have concluded that GPC has an audit program that is in accordance with Appendix B and implementing procedures and is therefore
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acceptable.
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(6). Section 6.0, Program Verification - The design program verifica-i tion reported in subsection 6.1 of the Module was determined to be generally correct. The Construction Program Verification which is outlined in subsection 6.2 of the Module was also determined to be generally correct except for those items described in Section 3.f of this report.
The inspectors performed a walkdown of an inde-
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pendent sample of raceways along with a sample of raceways select-
ed by the Readiness Review Team to verify that the installation
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process was adequate.
The findings by the inspectors generally coincided with findings by.the Readiness Review Team. The inspec-
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tors also reviewed the supporting documentation for the sample
raceways and found it to be adequate.
Based on the walkdown and
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documentation review, the NRC has determined that the raceways are acceptable.
(7) Section - 7.0, Program Assessment /Cenclusions - This section con-
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tains a summary of open corrective actions which will be followed-up by NRC inspectors during future inspections.
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b.
General Conclusions
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The examination performed by the NRC indicated that GPC management supported the Readiness Review by active participation and adequate resources.
No evidence of coercion or attempt to dilute either the
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effort or the findings was disclosed. The RRT displayed the requisite
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competence and professionalism for a review of this nature.
The licensee's program was comprehensive and provided adequate assurance l
that the plant electrical equipment will perform in accord with NRC l
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l in Section 4 of this report.
The foregoing evaluation comments do not appear to represent significant programmatic weakness provided that the licensee response is sufficient to enable closure for all related and currently open NRC items for Vogtle Unit 1.
The NRC concludes that the GPC program for
electical raceways comply with the NRC requirements and FSAR commitments.
This conclusion is based on information currently available to the NRC inspectors and reviewers.
Should subsequent contradictory information become available, it will be evaluated to determine its effect on the
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above conclusion.
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