IR 05000424/1986059

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Insp Repts 50-424/86-59 & 50-425/86-26 on 860707-18. Violations Noted:Failure to Procure HVAC Sys Fabricated, Installed & Inspected W/Procedures & Drawings.Deviation Noted:Failure to Procure explosion-proof Fan Motors
ML20214M599
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 08/07/1986
From: Blake J, Kleinsorge W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214M588 List:
References
50-424-86-59, 50-425-86-26, NUDOCS 8609110192
Download: ML20214M599 (13)
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, UNITED STATES

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'o . NUCLEAR REGULATORY COMMISSIOh j" o '; REGIONll ,

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101 MARIETTA STREET. * t ATLANTA, GEORGI A 30323 '

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F Report Nos.: 50-424/86-59 and 50-425/86-26 .

Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 <

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Docket Nos.: 50-424 and 50-425 License Nos.: _

CPPR-108 and CPPR-109

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Facility Name: Vogtle 1 and 2 Insoection Con u 7-18, 1 Inspector: , / _ vc W.' effirorge / T@te ~ Signed Accompanyin r A L. Jones, P.E, PhD, EG&G-Idaho, Inc.

Approved by. _ .

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ake, Section Chief 9/7 (-

Date~ Signed En in ring Branch D,vi ion of Reactor Safety SUMMARY Scope: This special, anncunced inspection was conducted in the areas of houskeeping (548348), material identification and control (42902B), material control (429408), and review of readiness review module 18A, Heating, Ventilating, and Air Conditioning (HVAC).

Results: One violation was identified " Failure to Procure HVAC Systems That Were Fabricated Installed and Inspected in Accordance With Procedures and Drawings", paragraph 6.c. Two deviations were identified " Failure to Procure Explosion-Proof Fan Motors as Committed", paragraph 6.b(3) and " Failure to Install Electrically Interlocked and Alarmed Control Room Doors", paragraph 6.b(6)(e)

8609110192 860329 PDR

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O ADOCK 05000424 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

  • D. O. Foster, Vice President, Georgia Power Company (GPC)
  • E. D. Groover, Quality Assurance (QA) Manager - Construction
  • C, Belflower, QA Site Manager - Operations
  • R. W. McManus, Readiness Review (RR) Manager Other licensee employees contacted included construction craftsmen, engineers, technicians, and office personne Other Organizations
  • G. Dimitrew, Stone and Webster (S&W)
  • R. C. Sommerfeld, Bechtel Power Corporation (BPC)

NRC Resident Inspectors H. Livermore, Senior Resident Inspector - Construction

  • J. F. Rogge, Senior Resident Inspector - Operations
  • Attended exit interview Exit Interview The inspection scope and findings were summarized on July 18, 1986, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license (0 pen) Violation 50-424/86-59-01: " Failure to Procure HVAC Systems That Were Fabricated, Installed, and Inspected in Accordance with Procedures and Drawings" - paragraph (0 pen) Deviation 50-424/86-59-02 and 50-425/86-26-02: " Failure to Procure Explosion-Proof Fan Motors as Conunitted" - paragraph 6.b(3).

(0 pen) Deviation 50-424/86-59-03 and 50-425/86-26-03: " Failure to Install Electrically Interlocked and Alarmed Control Room Doors as Committed" - paragraph 6.b(6)(e)2)a).

(0 pen) Unresolved Item 50-424/86-59-04 and 50-425/86-26-04: " Design Control for Control Room Doors" - paragraph 6.b(6)(e)2)b).

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(0 pen) Inspector Followup Item 50-424/86-59-05: " Unidentified Conunitment - FSAR Section 9.4.5.5.F" - paragraph 6.b(3).

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2 (0 pen) Inspector Followup Item 50-424/86-59-06: " Unidentified Comitment - FSAR Section 6.2.5.1.3.D" - paragraph 6.b(6)(c).

(0 pen) Inspector Followup Item 50-424/86-59-07: " Unidentified Commitment - FSAR Section 6.4.2.2.2.J" - paragraph 6.b(6)(e)1).

(0 pen) Inspector Followup Item 50-424/86-59-08: " Unidentified Commitment - FSAR Section 6.4.2.2.2.L" - paragraph 6.b(6)(f).

(0 pen) Inspector Followup Item 50-424/86-59-09: " Unidentified Comitment - FSAR Section 6.4.2.2.2.N" - paragraph 6.b(6)(h).

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(0 pen) Inspector Followup Item 50-424/86-59-10: " Unidentified Comitment - FSAR Section 6.5.1.1.E" - paragraph 6.b(6)(1).

(0 pen) Inspector Followup Item 50-424/86-59-11: " Unidentified Commitment - FSAR Section 6.5.1.3.E" - paragraph 6.b(6)(j).

(0 pen) Inspector Followup Item 50-424/86-59-12: " Unidentified Comitment - FSAR Section 9.4.6.1.2. A" - paragraph 6.b(6)(k).

(0 pen) Inspector Followup Item 50-424/86-59-13: " Inadequate Implementation for Reference No. 4073" - paragraph 6.b(2).

(0 pen) Inspector Followup Item 50-424/86-59-14: "HVAC Specification Error" - paragraph 6.b(4).

(0 pen) Inspector Followup Item 50-424/86-59-15: " Heat Trace" -

paragraph (0 pen) Unresolved Item 50-424/86-59-16 and 50-425/86-26-16:

" Beveled Washers" - paragraph The licensee identified as proprietary some of the materials provided to or reviewed by the inspectors; however, these materials are not discussed in this repor . LicenseeActiononPreviousEnforcementMatters(92701B)(927028)

This subject was not addressed in the inspectio . Unresolved Items Unresolved items are matters about which more information is required to determine whether they acceptable or may involve violations or deviation New unresolved items identified during this inspection are discussed in paragraph Nos. 6.b(6)(e)2)b) and _ - - _ _ . - . .

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, Independent Inspector Effort i

The inspectors conducted a general inspection of auxiliary, fuel, and-

. control buildings to observe activities such as housekeeping, material identification and control, material control, and storag With regard to the inspection above, the inspectors noted activated but not installed heat trace cables adjacent to the Unit I containment personnel i hatch and adjacent to air handling unit A-1542-N7-001-000. The inspectors

{ discussed the above with the licensee. At the time of this inspection, the j licensee was not able to determine whether the heat trace cables -were

awaiting installation or had been installed and subsequently removed, and if i

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installed and subsequently removed, was the removal authorized. Pending the resolution of the above, this matter will be identified as inspector followup item 50-424/86-59-15: " Heat Trace".

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Within the areas examined, no violations or deviations were identifie i

+ Review of Readiness Review Module 18A, Heating, Ventilating, and Air

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Conditioning (HVAC)

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This inspection report documents Region II's second site inspection

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relative to the evaluation of GPC's Readiness Review Module 18A, HVAC.

l The inspection was conducted to aid in determining whether Module 18A i provided an acceptable basis for its reported conclusion, concerning

Unit 1 of the Vogtle Electric Generating Plan (VEGP), that the design and construction programs and processes associated with the safety-

, related and Seismic Category I heating, ventilating, and ' air l conditioning systems within the scope identified within this' module

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were in accordance with applicable licensing commitment NRC Questions The first Region II site inspection was reported in NRC Report 50-424/86-56 and 50-425/86-25, conducted during the period June 16-20, 1986. Six questions were submitted to the licensee on June 20, 1986, for clarificatio The six questions were made an attachment to NRC Report- 50-424/86-56 and 50-425/86-25; during the intervening period, the licensee researched .the questions and prepared replies to eac The inspectors reviewed the licensee's replies. A discussion of each question is provided below.

l (1) Question No.1 - FSAR Section 9.2.9.1.1.1.B. Reference No. 3441.

l The inspectors determined this commitment to be adequately

referenced for first order implementation.

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(2) Question No. 2 - FSAR Section 9.4.5.4.1.C, Reference No. 407 The inspectors determined that the commitment implementation was not adequately referenced. Additional reference to DC-1620-3.1G is require The licensee indicated that they would amend the commitment matrix as necessary to provide adequate commitment implementation reference. This matter will be identified as inspector followup item 50-424/86-59-13: " Inadequate Implementa-

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tion for Reference No. 4073".

(3) Question No. 3 - FSAR 9.4.5.5.F. Reference No. 4080: FSAR paragraph 9.4.5.5.F states "The- battery room exhaust fan motors are of explosion-proof construction and are designed for the specific service intende The fans are designed to Seismic Category 1' requirements." Reference No. 4080 shows implementation of design to Seismic Category 1 only. The inspectors determined that there is no implementation of explosion-proof construction for battery room fan motors. The fan motors that were procured for the battery room are not explosion-proo The Readiness Review Program did not identify as a commitment explosion-proof construction on battery room fan motors as committed to the Comission by FSAR Paragraph 9.4.5. Pending NRC review and evaluation for implementation and inclusion into the matrix, this matter will be identified as inspector followup item 50-424/

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86-59-05: " Unidentified Comitment-FSAR Section 9.4.5.5.F".

The licensee deviated from a commitment to the Comission in that

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they procured nonexplosion-proof battery room exhaust fan motors,

which is contrary to a comitment to the Commission stated in FSAR

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Section 9.4.5.5.F. which requires battery room exhaust fan motors to be explosion-proof. This deviation to a commitment to the Comission will be identified as deviation 50-424/86-59-02 and

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j 50-425/86-26-02: " Failure to Precure Explosion-Proof Fan Motors as Comitted".

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(4) Question No. 4 - FSAR Section 9.4.5.5.J, Reference No. 4084: The inspectors determined that the comitment implementation was'

correctly referenced; however, specification X4AJ07-4.88, Revision 10 should reference ANSI N509, paragraph 4.1, in addition to ANSI N509, paragraph 5.1 (the existing reference). The

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licensee indicated that they would so amend X4AJ07-4.88. This matter will be identified as inspector followup item 50-424/

86-59-14: "HVAC Specification Error",

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(5) Question 5 - FSAR Section 3.1.5, Reference No. 2026. The inspectors determined' that this comitment was incorrectly referenced. This item is within the scope of Readiness Review Module No. 8, not Module 18A. The licensee indicated that they would delete this commitment from matrix for Module 18 . . .

(6) Question 6 (a) FSAR Section 6.2.5.1.1.0 - The inspectors determined that this commitment is addressed in Readiness Review Module 4, Reference No. 206 (b) FSAR Section 6.2.5.1.2.C - The inspectors determined that this section is a description of system operatio (c) FSAR Section 6.2.5.1.3.D - This section states in part:

"6.2.5.1.3 Post-LOCA cavity hydrogen Purge System

. . . The system is designed to automatically start upon receipt of a safety injection signal."

The licensee informed the inspectors that this is a commit-ment and had not been identified (in error) by the Readiness Review Progra Further, the licensee indicated that they would incorporate this commitment into the matrix implemented by DC-1516-3.1 This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup iten. 50-424/86-59-06: " Unidentified Commitment FSAR Section 6.2.5.1.3.D".

(d) FSAR Section 6.2.5.1.5.A - The inspectors determined that this section is a description of system operatio The licensee indicated that they would acd this section to the data base for clarit (e) FSAR Section 6.4.2.2.2.J - This section states:

l " Control Room Access Doors i To minimize inleakage, the control room access doors are

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equipped with self-closing devices that shut the doors automatically following the passage of personne Alarms are also provided to annunciate if any of the doors are open after a changeover to emergency l operation. Two sets of electrically interlocked doors l with a vestibule between acting as an airlock, are i

provided at each of the two entrances and the emergency exit to the combined control room and associated spaces."

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The licensee informed the inspectors of the following:

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1) FSAR Section 6.4.2.2.2.J is a comitment, and had not been identified (in error) by the Readiness Review Program. Further, the licensee indicated that they would incorporate this commitment in the matrix. This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup item 50-424/

86-59-07: " Unidentified Commitment - FSAR Section 6.4.2.2.2.J" a) The doors to the control room are installed in pairs, but they are not electrically interlocked and alarms are not provided to annunciate if any of the doors are open after a changeover to emergency operation.

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1 In view of the above, the licensee clearly deviated from a comitment to the Comission in that they did not install electrical interlocks and alarms (to annunciate if any of the doors are open after a changeover to emergency operation) on the control room access doors. The above is contrary to a comitment to the Commission stated in FSAR Section 6.4.2.2.2.J which requires electrical interlocks and alarms (to annunciate if any of the doors are open after a changeover to emergency operations) on the control room access doors. This deviation to a comitment to the Comission will be identified as

deviation 50-424/86-59-03 and 50-425/86-26-03:

" Failure to Install Electrically Interlocked and Alarmed Control Room Access Doors as Comi tted" .

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2 It appears that the above deviation is the result of a failure of the design control system to establish adequate ' measures to assure selection and review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of structures, systems, and components. At the time of this inspection, the above could not be solidly substantiate The licensee indicated they will investigate the matter. Pending the completion of the

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licensee's investigation, and the subsequent NRC evaluation to determine whether the licensee violated 10 CFR 50, Appendix B, Criterion III, this matter will be identified as unresolved item 50-424/86-59-04 and 50-425/86-26-04: " Design Control for Control Room Doors".

(f) FSAR Section 6.4.2.2.2.L - This section states:

" Chlorine Detectors Redundant chlorine detectors are installed in the control room ventilation outside air intake plenu These detectors are capable of detecting the presence of chlorine in concentrations of 1 ppm and higher. Response time is 10 S at 10 ppm chlorine concentration with the alarm setpoint of 2 ppm."

The licensee informed the inspectors that this is a commit-ment, and had not been identified (in error) by the Readiness Review Progra Further, the licensee indicated that they would incorporate this commitment in the matrix implemented by DC-1531-3.1F, P, and Q and -4.0A. This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup item 50-424/86-59-08:

" Unidentified Commitment-FSAR Section 6.4.2.2.2.L".

! (g) FSAR Section 6.4.2.2.2.M - The inspectors determined that this is a commitment that was identified by the Readiness Review Program, and documented in Module 20, reference No. 510 (FSAR Section 11.5.2-2). The licensee indicated that they will add this section to the data base for clarit (h) FSAR Section 6.4.2.2.2.N - This section states:

"N, Smoke Detectors Redundant smoke detectors are installed in each control room ventilation outside air intake (a total of four detectors). These detectors indicate the presence of smoke entering the control room envelope from outsid Redundant smoke detectors are also installed inside the control room envelope. These smoke detectors detect smoke inside the control room envelop Each smoke detector actuates an alarm in the control room on the HVAC control panel".

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The licensee informed the inspectors that this is a commitment, and had not been identified (in error) by the Readiness Review Progra Further, the licensee indicated that they would incorporate this commitment in the matrix implemented by DC-1813-3.18 and -3.2 This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup item SN424/86-59-09:

" Unidentified Commitment-FSAR Section 6.4.2.2.2.N".

(i) FSAR Section 6.5.1.1.E - This section states:

" The failure of any active component in a filtration system, assuming loss of offsite power, cannot impair the ability of the system to perform its safety function."

The licensee informed the inspectors that this is a commit-ment, and had not been identified (in error) by the Readiness Review Progra Further, the licensee indicated that they would incorporate this commitment in the matrix implemented by DC-1620-3.1A and DC-1009-3.2 This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup iten 50-424/86-59-10: " Unidentified Commitment-FSAR Section 6.5.1.1.E".

(j) FSAR Section 6.5.1.3.E - This section states:

" The control room HVAC system, the electrical penetration filter exhaust system, the piping penetration filter exhaust system, and the fuel handling building post-accident exhaust system each consist of two independent and redundant filtration trains with respect to active component Should any active component in one train fail, filtration can be performed by the other train, which is powered from a separate Class IE electrical bus. Failure modes and effects analyses are provided in Section 6.4 and subsections 9.4.2, 9.4.3, ,

and 9.4.5".

The licensee informed the inspectors that this is a commit-ment, and had not been identified (in error) by the Readiness Review Program. Further, the licensee indicated that they would incorporate this commitment in the matrix implemented by DC-1531-3.1C, DC-1561-3.1D, DC-1542-3.1G, and DC-1562-3.10. This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup item 50-424/86-59-11: "Unidenti fied Commitment-FSAR Section 6.5.1.3.F".

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(k) FSAR Section 9.4.6.1.2.A - This section states:

"9.4.6.1.2 Power Generation Design Bases The containment normal HVAC systems are designed to maintain a containment ambient air temperature between 60 F and 120 F during normal plant operation to permit continuous operation of equipment within the containment. The system is also designed to prevent concrete structures within the containment from exceeding the maximum design temperature of 200 F, except for the concrete under the reactor vessel column baseplates, which is limited to 150 F."

The licensee indicated to the inspectors that this is a comitment. The first part of this section was identified by the Readiness Review Program as a commitment in this module described as reference 2511 (FSAR Section 6.2.2.1.1.2).

Further, the licensee informed the inspectors the second part is also a commitment, and had not been identified (in error)

by the Readiness Review Proara Further, the licensee indicated that they would in:orporate this commitment in the matrix implemented by DC-1620-3.1 This matter, pending NRC review and evaluation for implementation, will be identified as inspector followup item 50-424/86-59-12: " Unidentified Commitment-FSAR Section 9.4.6.1.2.A". System Walkdown The inspectors performed a walk-dawn of selected portions of safety-related HVAC systems contained in the fuel handling and auxiliary building The systems examined by the inspectors were fabricated, installed, and inspected and accepted by Pullman /

Kenith-Fortson (P/K-F), a Georgia Power Company (GPC) contractor under the P/K-F Quality Assurance Program. Subsequently, GPC accepted these portions (and others) of the HVAC systems (purchased material, equipment, and services), and turned them over to power operations as acceptable for operatio The inspectors noted the following discrepancies:

- Lock washer that was not completely compressed (loose) on the bolted connection between duct pieces A-2547 and A-2547 A loose bolt in the bolted connection between duct pieces F846 and F84 * - Two loose bolts securing damper AHV-12510 to support 109-3101-7 t- .

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  • - Three loose bolts securing instrumentation line supports on air handling unit A-1542 N7-001-00 Loose mounting bolt for the actuator on damper HV-1251 Two loose nuts on the bolted connection between air handling. unit 1-1555-A7-001 and the upper flex connectio The above is contrary to P/K-F procedure JP-14.2, Revision 3A, ICN #150

"HVAC Process Control Program" Exhibit 16 which requires compression oflockwashers(tight).

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One nut on a bolted connection on flex connector A-2542 did not have full thread engagemen * - One jam nut on an anchor bolt securing fan No. 525-215-2 did not have full thread engagemen * - One nut on the charcoal fill port, on air handling unit A-1542-N7-001-000 did not have full thread engagemen The above is contrary to P/K-F Procedure JP-14.2, Revision 3A, ICN

  1. 150, "HVAC Process Control Program", Exhibit 12 which requires nuts to be fully engaged (at least flush with bolt).
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Fan 525-215-2 downstream of air handling unit A-1542-N7-001-000 is sacured to the fan support structure by four bolts. The above is contrary to Bechtel Drawing No. AX4AJ07-366-4, which requires six bolts to secure fan 525-215-2 to the fan support structur Three slotted holes and three oversize holes in bolted connections on damper AHV-12512, with misalignment that exceeded 1/8-inch as determined by the licensee, did not have flat washers installed to

_unpensate for reduced fastener bearing surface area. The above is contrary to P/K-F Procedure JP-14.2, Revision 3A, ICN #150,

"HVAC Control Program" Exhibit 16, which requires flat washers be

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installed under bolt heads and nuts when misalignment exceeds '

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The cross brace on duct support No. DS-1088132-73 is located approximately one-inch further from the wall than specified on Plan Type 95 shown on Bechtel Drawing AX2D67W016, Revision * -

The "A" dimension for duct support No. DS-1093101-74 is 2' - 11 15/16". The above is contrary to Bechtei Drawing AX2009W109, Revision 10, which specifies the "A" dimension for duct support DS-1093101-74 to be 2' - 71".

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The "F" dimension on duct support No. DS-1093101-93 is one foot and four inche The above is contrary to Bechtel Drawino AX2D00W109, Revision 10 which specifies the "F" dimention for duct suppcrt DS-1093101-93 to be two feet and six-inche * -

Duct Section A2552A extends north Si-inches further than allowed by Bechtel Drawing No. 1X4DJ3132, Revision 1 Flexible Duct Section A-2542 did not have a permanently attached identification number tag as required by P/K-F Procedure JP-14.2, Revision 3A, ICN #150, "HVAC Process Control Program", Exhibit 1 Pressure Transmitted PDT-2524A is located 23 inches back from the front of air handling unit No. A-1542-N7-001-000. The above is contrary to Bechtel Drawing 4AX4J07-490-4, which requires Pressure Transmitter PDT-2624A to be located 21 inches back from the front of air handling unit No. A-1542-N7-001-00 ,

The items marked with an asterisk (*) were inspected by the Readiness Review Team but the associated discrepant condition was not identified by the Readiness Review Tea The above clearly indicates that P/K-F craftsmen failed to follow procedures and drawings in the fabrication and installation of the HVAC systems, and P/K-F inspectors failed to follow procedures and drawings in that they accepted nonconfonning material and equipment. Bechtel Power Corporation (BPC) Specification No. X4AJ01, Revision 18, "HVAC Equipment Installation and Duct Fabrication and Installation for the Georgia Power Company Alvin W. Vogtle Nuclear Pcwer Plant, Burk Count Georgia". Section H-9.2.3.3 requires that activit es affecting qual h; i

performed by P/K-F, 5e accorr.plished in accordance Wth procedures and drawing The above clearly indicates that Gr. accepted portions of the HVAC systems thrt did not conform to procurement documents (specificationX4AJ01).

Failure to accomplisn activities affecting quality in accordance with procedures and drawings, and failure to establish adequate measures to assure purchased materials, equipment, and services comply with purchase h cuments a.e violations of 10 CFR 50, Appendix B, Criterion V

and VI This violation will be identified as 50-424/86-59-01:

l " Failure to Procure HVAC Systems That Were Fabricated, Installed, and Inspected in Accordance With Procedures and Drawings".

'i;h regard to the examination above, the inspectors noted that beveled ashers were used in bolted connections on damper Nos. AHV-12510 and 12512, to compensate for non-parallel head or nut bearing surface . substantial number of the beveled washers were rotated, one as much is 90 from its intended orientation. The inspectors discussed the above with the licensee, who indicated that the only guidance that the licensee's mechanical inspectors had, for the installation, of beveled washers, was that beveled washers could be used to compensate for

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non-parallel bearing surfaces on bolted connections that exceeded a taper of 20:1. American Institute of Steel Construction (AISC) Steel Manual, Specification for Structural Joints Using A325 or A490 Bolts, Paragraph 3.a states in part:

"The slope of surfaces of bolted parts in contact with the bolt head and nut shall not exceed 1:20 with respect to a plane normal to the bolt axis".

At the time of this inspection, it could not be determined whether:

(1) any or all of the rotated beveled washers exceed the 20:1 requirement, (2) how much rotation can be tolerated before the 20:1 requirement is exceeded, and (3) whether rotated beveled washers, exceeding the 20:1 requirements, exist on other safety-related equipmen The licensee indicated that would preform a review of the above issues, so the NRC could determine .whether the licensee's existing procedures contained adequate and appropriate acceptance criteria for the installation of beveled washers. This matter will be identified as Unresolved Item 50-424/86-59-16 and 425/86-26-16:

" Beveled Washers".

Within the areas examined, no violations or deviations were noted except as noted in paragraph Nos. 6.c. and 6.b(3) and 6.b(6)(e), respectively.

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