IR 05000424/1986093

Insp Repts 50-424/86-93 & 50-425/86-43 on 860929-1003. Violation Noted:Failure to Protect Permanent Plant Equipment

ML20214P124
Person / Time
Site:	Vogtle
Issue date:	11/20/1986
From:	Blake J, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214P076	List: IR 05000424/1986093 ML20214P074 ML20214P097
References
50-424-86-93, 50-425-86-43, NUDOCS 8612040082
Download: ML20214P124 (25)

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AR #t: = UNITE 3 STATES

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.h 4'o , NUCLEAR REGULATORY COMMISSION

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, .101 MARIETTA STREET. .

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• 2 ATLANTA. G EORGI A 30323 .

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. Report'Nos.: 50-424/86-93 and 50-425/86-43 ,

,- Licensee: Georgia Power Compan '

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% -P. O. Box 4545 <

, ,. Atlanta, GA 30302

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'. c Docket Nos.': 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109

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Facility Name: Vogtle l'and 2 Inspection Co -

S ptember 29 'Octobe- 3,-1986 .

Inipec r: , o // Jo b t H 1strom: Date' Signed v

Acco anyin er C. G. Bruch, Consultant, Region II (EG&G Idaho)

Approved by: u //

J. J Blake, Section Chief Oate' Signed nee' ring Branc ision of Reactor Safety s

SUMMARY

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- Scope: This special announced inspection was conducted on site. in the areas of

' Licensee action on previous enforcement _ matters ~ (Units 1 & ~2), housekeeping .

(Units 1 & 2) materials. control (Units 1 & 2), reactor vessel internals (Unit 1),

reactor coolant piping (Unit 2) and safety-related piping (Unit 2).

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Results: One violation was identified - Failure - to protect permanent plant  !

equipment, paragraph l l

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REPORT DETAILS Persons Contacted Licensee Employees

• E. Conway, Senior Vice President

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H. Pinson, Vice President, Construction

• D. Rice, Vice President, Engineering

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

• D. Groover, QA Site Manager, Construction

• E. Belflower, QA Site Manager, Operations

• G. A. McCarley, Project Compliance Coordinator

• B. C. Harbin, Manager of Quality Control (QC), Construction

• C. R. Brewer, Assistant Manager of QC, Construction

• R. W. McManus, Assistant Project Construction Manager

• R. W. Bellamy, Plant Support Manager, Operations

• W. W. Mintz, Project Compliance Manager

• H. A. Griffis, Nuclear Operations Maintenance Superintendent

• J. F. Sanders, Unit 1 Construction Manager

• R. E. Hollands, Compliance Superintendent

• W. C. Gabbard, Senior Regulatory Specialist

• A. L. Masbaugh, Assistant Plant Support Manager, Operations

• J. F. D'Amico, Nuclear Safety and Compliance Manager

• A. I. Pago, Jr. , QC Section Supervisor, Construction Other licensee employees contacted included construction craftsmen, engineers, technicians, mechanics, and office personne Other Organizations

• 0. Batum,-Southern Company Services (SCS), Deputy to Vice President of Engineering-D. L. Kinnsch, Bechtel Power Corporation (BPC), Project Field Engineer (PFE)

• S. Pietrzyll, BPC, Assistant Ptt

• P. W. Strohman, BPC, Project QA Engineer D. Houghton, BPC, Home Office Engineering (HOE), Civil / Structural Engineer-ing Group Supervisor (EGS)

B. Platoni, BPC, PFE Civil / Structural EGS R. L, Rogers, BPC, H0E Senior Engineer M. Hutchinson, BPC HOE Containment Group Leader L. Case, BPC, Codes and Standards P. R. Thomas, BPC, RR Construction Team Leader D. L. Carlson, BPC, Materials and Quality Services (M & QS) Welding Engineer H. Freddy, BPC, PFE Staff Supervisor Barlow, Westinghouse - Vogtle Structural Analysis Mobile Unit (V-SAMU), Structural Engineering Manager

• B. L. Edwards, Pullman Power Products (PPP), Resident Construction Manager

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J. E. Miller, PPP, QA Manager

• T. J. Pruitt, Nuclear Installation Services Company (NISCO), Field QA/QC Manager NRC Resident Inspectors

• H. Livermore, Senior Resident Inspector (Construction)

• J. Rogge, Senior Resident Inspector (Operations)

• Attended exit interview Exit Interview The inspection scope and findings were summarized on October 3,1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected. No dissenting comments were received from the license . (0 pen) Violation 424/86-93-01 (Unit 1 only), Failure to Protect Permanent Plant Equipment, paragraph The licensee did identify as proprietary some of the materials provided to and reviewed by the inspector during this inspection; however, details from those materials are-not included in this repor . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item (424/86-03-03, 425/86-02-03), High Strength Bolted Connections This . item concerned ASTM A325 and A490 high strength steel bolts installed at plant Vogtle. Discussions with QC inspectors and other cognizant licensee ~ personnel had identified potential overtensioning of bolts on mainplate girder #5 at elevation 240' in the Control Buildin The girder was installed in August 1982, and potential overtorquing was observed due to lack of conformance to " turn-of-nut" installation requirements within construction procedure CD-T-16. Bolts in girder #5 were replace However, followup discussions with cognizant licensee personne' had established additional potential for overtensionin Further GPC response on this issue was transmitted by letters to Region II, dated April 17, 1986, (Log: GN-864) and May 12, 1986, (Log: GN-906). The adequacy of the engineering justification was questioned on several points as detailed within Inspection Report Nos. 50-424/86-39 and 50-425/86-1 The inspector completed additional discussions with cognizant licensee personnel during this inspection regarding this issu . . _ . . - . .- - - . .. .- .

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The : inspectors reviewed ' a September 26, 1986 : letter from BPC to .

Mr. P. D. Rice (Log: - BG 34882): whichiprovides. comparisons of; actual

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loads, allowable design . loads, spectfled l bolt pretension and ultimate- ^

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bolt capacity - for~ a random sample. of_ structural connections in , the

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containment and-control . buildings. , Review of. the connection shear and

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axial force ; data establish considerable - margin between actual and ,

allowable design loads under both Safe Shutdown Earthquake- (SSE) and -

Operating Basis Earthquake (OBE) conditions. 'Thn" data also'demonstr-ates a factor of safety from 2.0 (SSE) to 3.3~ (0BE) between . allowable s design' loads _ and. ultimate capacity. This.' data. was accepted 'as l verification of. the L licensee's contention -that the bolts will not

. experience loadings under 0BE and SSE which willibe beyond the_ initial ,

pretension established during installation. This supports thel general philosophy that bolt overtensioning would not present a problem as le .

as'the bolts'did not break during. installatio The ~ inspector ; also reviewed i an . 0ctober 2, 1986 letter from BPC to Mr. P. D. ' Rice which provides a' summary of . points supporting the '

conclusion that potential inadvertent overtorquing of high strength

' bolts at Plant Vogtle hasino adverse effects in the design intetrit Those points are as follows:

• -The design of VEGP structural steel connections does not exceed s the _ design allowables " for all . postulated , loading conditions identified in established-project design criteri * From' a review.of availableiliterature, the. maximum reduction -in tensile capacity to the point of incipient failure still results in a . minimum pretension in excess of design allowables'. There-fore, no design tensile load will cause any increase in the I tensile stress of the bol * High strength bolts of the types A-325 and A-490 have historically performed well' without reported : problems from long -term stress corrosion dus~ to .the control on material quality and heat-treatment processes to achieve specified limits of surface hardnes '

After revies of additional reference data supporting,the above points,

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the inspectorsconcluded that NRC concern on this issue was resolved for the following reasons:

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• Adequate Quality Control - The quality control required by construction procedure CD-T-16 (Structural Steel and Q-Decking)

and verified by NRC inspections (Report No. 424/86-18) provides reasonable assurance that the bolts in structural steel connec-

tions have -the minimum tension required by - the design calcula-

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No adverse effects from ' potential overloading - Analysis of critical elements (as reported above) of the various category I structures using the STRIVE Load -Flow Program (also see para-graph 8.b), along with retrofit correction of deficiencies found thereby, provide reasonable assurance that the bolted structural connections will perform safely under all design basis loading This also includes reasonable' assurance that the design safety factor accumulations for these connections, along with the STRIVE verified connection loadings, will prevent any unsafe bolt tension addition *

Adequate corrosion resistance - Reasonable assurance that environ-mentally induced corrosion is not a concern because the structural steel bolts do not come into contact with deleterious materials, fluids or vapors. Also stress induced corrosion is not a concern because the bolts conform to industry and design specification This was verified by NRC inspections of installation conditions, applicable installation and procurement- quality data, (see Inspection Report No. 50-424/86-18).

No report of industry problems due to overtensioning. Review of

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the pertinent literature together with discussions with code committee members, providing technical review of high strength bolts for structural connections, did not identify any current industry concern due to bolt preload overtorquin This item is considered-close b. (Closed) Violation (424/86-39-03, 425/86-19-03), Failure to Follow Procedures for Control of Welding Consumable GPC's letter of-response dated August 27, 1986, has been reviewed and determined to be acceptable by Region II. The inspector examined the-corrective actions as stated in the response. The examination included the following:

Verification of revision to GPC procedure MD-T-12 to provide clarification of approval requirements for welding material requisitions from welding material issue station * Verification of an authorization list which limits personnel authorized to approve requisitions for welding consumables to GPC personnel having expertise and direct engineering authority for welding operation *- Verification of retraining of GPC engineering personnel, warehouse personnel, and appropriate PPP personnel in project procedural requirements for the requisition, stocking and issuing of welding consumable .- . - - __ , - _ _ -- . - . -

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Field verification of weld rod issue station activities as reported in paragraph 6.b.(4)'.

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 necessar corrective actions intended to preclude the recurrence of similar circumstances, the corrective actions identified in the letter of response were implemente c. (0 pen) Unresolved Item (424/86-76-02), Weld Repair of Train A Encapsula-tion Vessel Bellows Expansion Join This item concerns weld repair of the bellows expansion joint of unit 1 Train A isolation valve encapsulation vessel 1-1206-V4-00 The applicable code for the isolation valve encapsulation vessel

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assemblies.(including expansion bellows) is Section 'III, Subsection NE-of the 1974 ASME Code, through Summer 1976 Addenda. Weld repair of bellows elements is permitted under Code Case N-315 dated February 14, 198 N-315 requires the use of a full scale facsimile bellows to qualify the repair procedure by subsequent fatigue testing and proof testing of the facsimil The' inspector had examined quality data and completed field examination of. the repair during a previous inspection (inspection report No. 424/86-76, 425/86-37) and established the following:

The Vogtle FSAR section 3.6.2.1.4 includes the commitment that the

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encapsulation vessels and their bellows expansion joints conform to ASME class MC requirements. Section 3.8.2.2 indicates that the requirements of Regulatory Guide (RG) 1.57 also apply and Section 3.8.2.4.4 commits to ' design and analysis in accordance with article NE-3000 of the ASME code. Section 1.9.84 commits to RG 1.84 for the use of ASME Code Cases and RG 1.84 requires NRC approval prior to use of Code Case N-31 * The bellows repair was not conducted to the requirements of Code Case N-315, but has been accomplished in accordance with

" guidelines" of ASME Section III and Section X BPC engineering justification of the repair (BPC letter, dated August 21, 1986, to Mr. P. D. Rice and supporting attachments - BPC Log No. PFE-12579) was also intended as the Certification of Compliance that the repair had been completed in accordance with guidelines of ASME Section XI and will meet its intended design functio , _ __ . . _ . _ - _ - - _ _

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• Th'e report from a recent joint testing program between - Pathway Bellows and a Region II licensee was referenced as, justification that- this type of repair would. require accepting a design penalty of loss of about 60% of average' cyclic life on a worst case basi Calculations by BPC with the 60% penalty indicated that design-requirements of NE-3365.2(g) were satisfie *

NRC concern had been identified as to whether licensee commitments to ASME Code conformance had been maintained and as to confirma-tion of the capability . of - the repaired bellows to meet its intended design function, i.e., evidence of conservatism equiva-

, lent to Code Case N-315 was questioned since a full scale facsimile bellows was not used to qualify the repair procedure nor was subsequent _' fatigue testing complete The inspector completed additional discussions with cognizant-licensee personnel during this inspection. Clarifications were established as follows:

• GPC conformance to FSAR commitments was partly related .to interpretation of article IWA-4120 of the ASME Code,Section XI ,

which requires that:

Repairs -shall be performed in accordance with the Owner's Design Specification and Construction Code of the component or system. Later editions of the ,

Construction Code or Section III, either in its entirety of portions thereof, may be use If repair welding cannot be performed in accordance with these requirements, the following may be use (a) IWB-4000 for Class 1 components (b) IWC-4000 for Class 2 components (c) IWC-4000 for Class 3 components GPC personnel explained that repair welding could not be performed to code case N-315 1.e. , the Construction code, since a full scale facsimile bellows was not available and could not be obtained within time to anticipated fuel loa Therefore Section XI guidelines had been use , - __ ,

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• Recent . GPC field investigations (operations deficiency report No.-T-1-86-3148 dated September 8,1986) had identified that th'e repaired bellows was " offset". Therefore neither the initial design calculations by Johnson Controls nor the BPC calculations

. previously reviewed by the inspector (attachment 3 to BPC log No. PFE-12579) were applicable to satisfying conformance to NE-3365.2(g). New calculations had been completed (also .identi-fied as attachment 3) and were provided to the inspector for revie The inspector noted that code case N-315 requirements to use a replicate no. of tests at zero when calculating the statistical stress factor Kss remained unsatisfied. (Kss = 1.470 - 0.44 times the number of replicate tests). This reduces conservatism when calculating the

. stress factor Ks (Ks = Ksc x Kss) .which is .used to ensure that established total combined stress limits'(S) are maintained; i.e., Ks x S = Sf where Sf is the total combined stress to failure at design cyclic lif BPC personnel responded that this requirement had not been included in the calculation. However total combined stress limits are not exceeded when using a Kss value of 1.4 The inspector noted that clarification of the FSAR commitments related to this matter must be obtained from the office of Nuclear Reactor Regulation (NRR). Further that facsimile bellows were available from unit 2. Cognizant Licensee personnel agreed to provide additional response on this item. This item remains open, (0 pen) Unresolved Item (424/86-18-06), Use of 25% of Live Load When Combined with Seismic Loads for Structural Steel Design This item was identified by the NRC Office of Inspection and Enforce-ment (I&E) during the examination of Readiness Review Module 8, Structural Steel. The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved all I&E concern However this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that repor (0 pen) Unresolved Item (424/86-18-09), Space Frame Modeling Accomp-lished With One and Not Two Cranes Being Positioned Within the Same Turbine Building (IE Open Item 85-64R-05).

This item was identified by I&E during the examination of Readiness Review Module 8, Structural Steel. The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved I&E concerns. However, this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that report.

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, (0 pen) Unresolved Item (424/86-18-10), Interaction of Turbine Pedestal and Building Structural Steel with Main Steam Piping Anchors (IE Open Item 85-64R-06).

This item was identified by I&E during the examination of Readiness Review Module 8, Structural Stee The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved I&E - concerns. However, this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that repor . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. One new unresolved item identified during this inspection is discussed in paragraph 6.b.(2).(b).

.5. Independent Inspection Effort Housekeeping (54834B), Material Identification and Control (42902B), and Material Control (429408)

The inspector conducted a general inspection on Units 1 and 2 containments, the control building and the reactor auxiliary building to observe activi-ties such as housekeeping, material identification and control; material control, and storag During the above inspection, the inspector noted deficiencies in the protection of permanent plant equipment due to uncontrolled water leakages at various locations and elevations in Unit I containment. The leakages were caused by inadvertent breaching of pressure boundary piping and condensation from compressed air manifolds used in coating operations. The inspector noted an uncontrolled leakage of approximately 5 gph into uncovered and powered electrical instrumentation penetrations Nos. 46, 47 and 48. The inspector was informed by Cognizant Licensee- personnel that construction was completed on these electrical penetrations and that final QC inspections had assured that covers had been installed. Further that GPC Operations Maintenance Procedure SUM-22 required issuance of maintenance work-orders (MW0s) before completing any work on the termination The inspector requested a response from operations maintenance personnel as to the status of open MW0s which could have resulted in open covers from several (over ten) electrical penetrations in Unit 1 containmen The inspector further noted that SUM-22 sections 6.6.3 thru 6.6.5 were intended to preclude the conditions observed. Cognizant Licensee perennel were unable to provide an explanation by the close of this inspectio . - . -

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-9 The l inspector' informed Cognizant Licensee personnel that this matter was considered a lack of conformance to 10 CFR 50 Appendix B, Criterion XIII, and - would be identified as Violation 424/86-93-01, Failure to Protect Permanent Plant Equipmen . Reactor Coolant and Safety-Related Piping (Unit 2)

The' inspector examined welding and nonwelding activities for reactor coolant and safety-related piping to determine whether applicable code and procedure requirements.were being met. The applicable code is the ASME Boiler and Pressure Vessel Code,Section III, 1977 Edition with Addenda through W7 Review of Nonwelding Quality Records (49055) and (49065)

The inspector selected various reactor coolant and safety-related piping components (e.g., pipe, fittings and welded-in 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; vendor supplied NDE reports; Nucelar Steam Service Supply quality release; site receipt inspection; storage; installation; vendor nonconformance report Item Health / Control N System 1 1/2" dia, sched 160 479154 Safety Injection SS Pipe 1 1/2" dia, sched 160 LABN Safety Injection SS LR 90 ell 3/4" dia. 3600 Psi S/N H021ABG Reactor Coolant SS Gate Valve 3/4" dia. sched 160 0A3403 Reactor Coolant SS Pipe Within the areas inspected, no violations or deviations were identi-fied, Welding Activities (1) Production Welding (55050)

The inspector observed in-process welding activities of reactor coolant and safety injection system piping field welds inside of containment as described below to determine whether applicable code and procedure requirements were being met.

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The below listed welds are examined in process to verify work

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conducted in accordance with traveler, welder identification and location, welding procedures, WPS assignment, welding techniqu and sequence, materials identity, weld geometry, fit-up; temporary attachments, gas, purging, preheat, electrical characteristics, shielding gas, welding equipment condition, interpass temperature, interpass cleaning, process control systems, qualifications of inspection personnel, and weld history record ISO Weld Size Status 2K4-1201-027-01 R/4 122-W-103 3/4" Fill pass 2K4-1204-079-02 R/0 245-W-134 1 1/2" Fit-up tacks-and root pass *

• Root pass discontinued due to loss of back purge shielding gas flo 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 lype of Certification BFB-PPP VT-II ODB-PPP VT-II WFT-PPP VT-II (2) Welding Procedure Specifications.and Quality Assurance Procedures (a) Welding Procedure Specifications (WPS) applicable to the weld joints listed in paragraph 6.b.(1), were selected for review and comparison with the ASME Code as follows:

Procedure Qualification WPS Process PQR Reports

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29-III/I-8-08-1 GTAW 125,132,133 (9/7/83)

27-III/I-8-08-12 GTAW 110,110(w),132,133 (4/14/83)

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The above WPSs and. their supporting Procedure Qualifica"Eton .

Records (PQRs) were reviewed .to ascertain whether essential, i '~'

supplementary .and/or nonessent,al . variables, i.ncluding

. thermal treatment, were consistent:with Code requirements; whether the WPSs were properly qualified and their supporting PQRs were accurate and _ retrievable; 'whethey. a.ll- 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 welding program had been approved bi; the licensee and whether adequate plans and procedures had been established to assure that welding would be controlled and accomplished consistent with commitments and regulatory requirement s -

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PPP-II-2, dated 8/15/86 NDE Personnei Qualifications I & II PPP-II-8, dated 6/12/86 Weldar Performance Qualification PPP-VI-6, dated 7/24/86 Field Preparation and Control of Project Procedures and Their Revisions PP-VII-2, dated 11/2/85 Material Control PCN #4, dated 7/31/86 PPP-VIII-3, dated 7/6/86 Control of Welding Materials (Field)

PPP-IX-19, dated 8/19/86 Requirements for Alignment and PCN #3, dated 9/10/86 Fit-up PPP-IX-43, dated 5/15/86 P ocedure for Preheat, Interpass and Post Weld Heat Treatment PPP-IX-50, dated 7/8/86 Pipe Support Field Installation an Fabrication Procedure PPP-IX-52, dated 8/20/86 Weld Spatter and ARC Strike Removal PPP-IX-58, dated 4/24/86 Weld Preparation for In-Service Inspection PPP-IX-65, dated 9/13/85 Installation and Inspection of Pipe PCN #4, dated 6/13/86 Whip Restraints

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PPP-X-10L dated 2/26/85 _ Welding-Surveillance Procedure-PPP-X-18,~ dated 7/25/86- Field Welding Inspection PPP-X-24,? dated _5/.%/86 Procedure for As-Builting Piping-

~PCN.#1, dated 9/11/86 Systems'and Related Components PPP.-XV-2,_ dated 4/14/86' Procedure For Handling Nonconfor-PCN #4, dated 8/9/86- mances (Field)

- PPP-XVI-2, dated _4/16/86 Corrective Action Procedure-PPP-GWS III/I, dated 5/28/86 Ge'neral Welding Standard for ASME Sections I,'III, VII and ANSI B3 :During.-the above examination the- inspector noted need for

. clarification of requirements ~within the - PPP-X-18 Procedure for Field. Welding Inspection. Procedure X-18. had -been revised to -

incorporate the NRC approved generic. _ Visual Weld Acceptance

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Criteria - (VWAC) for Structural Weldments. These criteria have also been ; adopted ' by ASME (Code Case-N-430, dated 2/28/86) for

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Class NE Pipe _ Supports. Section 9.0, Acceptance requirements, was

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not cle'ar ^ in distinction ' between: requirements for structural weldments/NF . supports and ASME _ code pipin Cognizant Licensee personnel agreed that potential existed for misinterpretation by

.QC Jinspector .

The inspector informed _ Cognizant : Licensee personnel that NRC concern .on this matter would be identified by_

Unresolved ~ item - 424/86-93-02, 425/86-43-02, Adequacy of _ Field Welding Inspection Proccdure.

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(3)l Welder Performance Qualification

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The _ inspector : eviewed the- PPP program for qualification- of welders and welding operators for compliance with QA p scedures and ASME Code requirement The following welder qualification status records and " Records of Performance Qualification Test" were-reviewed relative to the weld

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Welder Symbol- WPS

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FV 29-III/I-8-0B-1 HP2 27-III/I-8-08-12

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A The Linspector reviewed the PPP proghahi for control L of welding materials. to determine whether materials : were ,being purchased,'- . . ,

accepted, . stored and: handled in.accordance with QA procedurestand T applicable , code requirements.' The following . specific areas;were

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Purchasing,. receiving,-storing, and distribution and h'andlin procedures; material . identi ficatio'n; and inspection ofj l welding material issuing station *,

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.W elding material purchasing and receiving records for the'

i_ following -material applicable = to the weld- joints : listed in

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paragraph 6.b.(1). were reviewed for conformance .w tth'

applicable procedures

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and code requirement .,'

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Type LIize > Heat, Lot, Batch /N ER308L' '

1/16" X 36" 26245

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ER308L 3/32" X 36" P5474-ER308 /- ~1/8" X 36" P0443 Within the areas inspected,[no -violations or deviations were identifie ,,

7. -Reactor Vessel Internals - Welding-(U i'tR1) (550938) ,

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The inspector examined welding activities pertaining to field ' welding 'of -

Unit'l reactor vessel interrals to determine whether applicable code and

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procedure requirements were - b'eing met. . The applicable code for Unit 1 reactor vessel internals is thi ASME Boiler and Pressure Ve,dsel. Code, Section~III', 1974 Edition with /ddenda through Summer 57 ' Visual' Examination of Wel'ds ,, ,

t 'The below listed welds were examined relative to the following:

location, length, size and shape; weld surface. finish 'and appearance; transitions between different wall thi,cknesse,s,; weld reinforcement--

height and appearance; joint configurations on permanent attachments and structural supports; removal ~of temporary s 3ttachments, arc strikes and weld spatter; finishgrinding or machining of weld surface, surface finish and ' absence of wall thinning; surface defects, cracks, laps, lack' of penetration, lack of fision, porosity, slag, oxide film- and undercut exceeding prescribed limit m  !

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(1) Cruciform Instrumentation Welds lDowell Pin to Nut and nut locking cap to cruciform (4 welds) at

' lower core plate and secondary core plate (2 elevations)

Core Location' Cruciform ID N Weld N B-13' -70394 AAW B12

~H-15 70256 AAW HIS J-14 70259 AAW J14 N-14 70392 AAW N14 P-9 70260 'AAW P9

~(2) Energy Absorber to Base Plate Welds Core Location Weld N H-10 MMW 0 K-8 MMW 90 H-6 MMW 180 (3) 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 KJR PT-II, VT-II (4) The following liquid penetrant materials certification records relative to inspection of the weld joints listed above were reviewed to ascertain if the sulfur and halogen content of the material was within acceptable content limit Materials Batch N Liquid Penetrant 830030 Cleaner / Remover 83E005 Developer 83D025

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-e b. Welding Procedure Specification and Quality Assurance Procedures-(1)1 Welding Procedure . Specification (WPS) 1 applicable to- the weld

joints iisted in

paragraphs 7.a.(1) and 7.a.(2) were selected for

- review and comparison with the-ASME code as follows:

WPS- Process PQR 80.2.4, Re *GTWA (manual) 215, 216

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• GTAW - Gas Tungsten Arc Welding The above WPSs and their supporting Procedure Qualification

. Records - (PQRs) were reviewed to . ascertain whether essential, supplementary and/or nonessential variables, including thermal treatment, were consistent with-Code requirements; whether the WPS 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 note WPSsiare qualified in accordance with ASME section IX, the latest

- edition and addenda at the time of qualificatio ~ (2) The - below listed N : . lear Installation Services Company (NISCO)

procedures were reviewed to ascertain whether -the reactor vessel internals 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 consis-tent with commitments and regulatory requirement Document. Number Title E'S-4028 - Vogtle-17, Rev. C Reactor Vessel Internals Assembly-ES-300, Rev. F- General Welding Procedure ES-100-5, Rev. C Visual Inspection of Welds ES-56, Rev. F Welding Filler Material Control Procedure (Safety Related)

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ES-116-2, Rev. I Qualification & Certification of Inspection Personnel to ANSI N45.2.6, Written Practice for Corporate and all field Sites

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ES-142, Rev. Deviations and Corrective Actions ES-62, Rev. A Procurement and Material Control

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--ES-67, Rev. Cleanliness Re'uirements q and Contro K =ES-100-2, Rev. L Qualification and Certification of Non-destructive examination

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personnel. _-Written Practice fo Corporate and all field sites-ES-100-2, Rev. E l Liquid Penetrant Examination ES-110, Rev. A Stop Work Procedure-ES-116-3, Rec.;C Qualification and Certification'of Auditing Personnel ES-126, Rev.'C . Quality. Assurance Records and Retention ES-145, Rev. Change Notices and Change Requests ES-146, Rev. E- Document Control ES-147, Rev. C Process ~ Control

. Welder-Qualification The inspector reviewed the NISCO's program for qualification of welders and welding operators for compliance with QA procedures and_ ASME Code-requirement The following welder qualification . status records and " Records of

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Performance Qualification ~ Test" were reviewed relative to the weld

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. joints listed-in paragraphs 7.a.(1) and 7.a.(2).

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Weld Symbol' 'WPS N-5 80.2.4*

• Welder qualification tests were conducted on a full scale mockup o _ production weld Welding Filler Material Control The ' inspector reviewed the NISCO'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 requirements. The following specific areas were examined:

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

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• ' -- :The 1followi_ng' welding materials _ applicable; to the Lweld -joints

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listed in paragraphs = 7.a.(1) and 7.a.(2) were L selected for review

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of purchasing 'and . receiving -records for- conformance with applic '

L able procedures and code requirements:

Typee Siz .

Heat / Control N ER308L? 1/8" X 36" 05394 ER308L 3/32" X-36" 05394

'ER308L- 1/16" X 36" 26245 ER308L 3/32" X 36" 05766 Within the ' areas examined, no . violations or deviations were identifie , lPreviously Identified Inspector Followup It' ms e (0 pen) Inspector: Followup Item (424/86-39-02, 425/86-19-02), Fiild :

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-Confirmation of Distance Between Welded Attachments and the Location of Intermediate Pipe Break This item concerns proper application of a minimum distance criteria (5D' Criteria) 'from welded attachments .for the . postulation of inter-mediate- pipe breaks on high-energy ' ASME ' Code class piping. ~The inspector's previous inspections in this area had identified need for field' examinations to assure the as-bui_1t support locations in order to conduct : the _ engineering ' analyses involved. The inspector had'previ-ously noted that support location tolerances for.small diameter-' piping amounted to as much as three piping diameters. Therefore:a SD minimum

~ distance, criteria (or some ' alternate criteria requiring greater precision) could not be assured without field: examination Cognizant Licensee personnel informed ~ the inspector of technical'

decisions reached in response to NRC concern regarding the 50' Criteria (Violation 424/86-39-01, 425/86-19-01). Formal Licensee correspondence to the NRC Office of 14uclear reactor. Regulation (letters dated

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August 4, 1986 - log GN -1022 and September 30,1986 - Log GN-1090)

Regarding arbitrary intermediate pipe break criteria were provided to

< the inspector for review. Cognizant licensee personnel informed the inspector that formal NRC acceptance of the proposed revised criteria

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had not been received as the date of this inspection.

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The inspector noted that the proposed criteria included a minimum distance less than 50 for all high energy class 2 and 3 systems other than main steam and main feedwater systems'. The proposed criteria

(3/RT) requires greater precision regarding pipe support locations than i does SD. The inspector further noted that the method of implementation

- will be the use of as-built piping support and piping isometric E drawings to determine the distance between the edge of the welded L attachment' and the' edge of the break location. The inspector further

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noted that PPP procedure X-24 (As-builting Piping Systems and Related

. Components) did not require that exact distances be recorded unless

' support locations were outside the tolerances allowed by PPP Support Installation Procedure IX-50. Therefore, "as-built" drawings reviewed to date for imposing the subject criteria were suspect unless exact field measurements had been recorde This item remains ope (Closed) Inspector Followup Item (424/86-03-01, 425/86-02-01), Strive Load Tracking Progra This item was identified during the NRC Examination of Readiness Review Module 8, Structural Steel. Initial NRC concern regarding the STRIVE Load Tracking- Program centered around its potential use as partial justification for relaxed visual acceptance criteria for structural welds and its lack of assessment for acceptability during the Module 8 Readiness Review. Any dependency of Visual Weld Acceptable Criteria to the STRIVE Program has been removed as reported in Inspection Report No. 424/86-03. However, need for further NRC assessment, regarding an acceptable STRIVE program was evidence by the following:

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

' Adequate resolution of Readiness Review's design verification

, finding 8-91 on containment internal steel is partially predicated on an acceptable STRIVE program which "if implemented as planned, should ensure adequate reconciliation of platform loading data."

• Module 8 Independent Design Review, Section 7.4.2.1.5 notes that the STRIVE program was not reviewed since "no project procedures were in existence describing how this effort would be conducted."

Further that "the conclusions of this review are based on the initial design efforts and the presumption of a properly imple-mented load verification program."

BPC personnel provided initial details on the STRIVE program during a previous inspection. Program specifics were provided through a review of April . 30, 1985, BPC correspondence and attachments (Log: BS5902).

Existence of controlling procedures was verified through review of the Vogtle Pro,iect Reference Manual, Part C, Section 40, Revision 0, dated December 20, 1986. Licensee activities associated with the STRIVE program, including field verifications, were not completed during the NRC examination of Module Cognizant Licensee personnel provided further details on completion of the STRIVE program for the inspecotr's review during this inspectio The inspector noted that the STRIVE program objective was to provide and document final load verification for selected structural compon-ents, including the cumulative effects of significant field routed

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commodities, electrical supports, and structural field modifi-cation STRIVE had examined the following principal structural components:

Building Components Examined Containment Bld Structural Steel Girders, Beams, and Columns Auxiliary Bld Structural Steel Beams Control Bld Structural Steel Girders and Beams Other Category / Structures Major loaded Girders and Beams as determined by field walkdowns Types of loadings considered were as follows:

Large and small bore pipe supports Electrical cable tray supports HVAC duct and damper supports Electrical conduit supports

Equipment supports The inspector completed a comparison of the program's results for various beams in Unit 1 containment (B113, B120, B132 and 8133) versus field verification of the loads indicate No deficiencies were identified and the inspector determined that NRC concern on this matter was resolved. This item is considered close c. (Closed) Inspector Followup Item (424/86-07-01), Adequate Coverage of Module 8 Items Assigned to Other Module This item was identified during the NRC examination of Readiness Review Module 8, Structural Steel. During the onsite inspections of Module 8, the inspectors were informed of several activities scheduled to be covered in other modules rather than, or in addition to, Module Details were provided in Inspection Report No. 424/86-07 and Module 8 Final Review Report No. 424/86-1 The inspector reviewed the inclusion of those activities on other modules during this inspection as follows:

" Primary Loop Component Supports Anchorage design and any anchorage items of primary loop component supports which were cast in Category 1 concrete were included in Module Design and construction verification of other aspects of primary loop component support hardware were included in Module 16 (Nuclear Steam Supply System). This was verified by an overview examination of the following items from Module 16:

- Table 1.1-1 Module Hardware Programs

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Section 3.4 commitments (especially~ nos. 1532, 1544, 2188, 1578, 1579, 823, 888, 889, 1997, 4755, 4757, 4759, 4760, 4761, 4762, 4763, and 315)

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Paragraph 4.1.2.1 l - Design and analysis of coolant loop equipment supports by Westinghous Figures 4.4-3, 4.4-12 and 4.4-13 (Reactor pressure vessel, pressurizer and steam generator supports).

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_ Paragraph 6.1.2 - Key area verification of reactor coolant loop equipment support Paragraph 6.1.3.2 - Primary equipment support load Figure 6.1.2 - Design verification work shee Table 6.1-1 - Review summary of primary equipment support loads Pipewhip Restraint Hardware Design verification of pipewhip restraints was included in Module Other aspects, including construction verification was covered in Module 11 (pipe stress and pipe supports). This was verified by an overview examination of the following items from Module 11:

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Table 1.1-1 - Key hardware and associated activities

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Section 3.4 - Commitment (especially nos. 954, 950, 956, 5033, 4992,~49993 and 965).

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Paragraph 4.1.1.1'- Pipe Support design criteria development

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Paragraph 4.4.1.1 (Supplementary documents include pipewhip restrain drawings).

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Paragraph 4.4.3 Pipewhip restraints installation

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Paragraph 6.2.2 Pipewhip restraint review activities

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Paragraph 6.2.2.4 Pipewhip restraints installation (especi-ally findings 11-18 and 11-20).

Structural Steel Procurement Activities The structural steel procurement activities were incorporated in Module 8 by reference to Appendix C (General Appendix as a part of Module 21) within Module 8 paragraph 4.2. This was verified by an overview examination of the Module 21 Section C1 scope statements and the broad scope program for Vogtle procurement described in the remainder of the appendi .- . . . .-- - - - .

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' Structural Steel Material Control The structural steel material control activities were incorporated in Module 8 by reference to Appendix E (General appendix as a part of Module 21) within Module 8 paragraph 4.2. This was verified by the overview examination of Module 21 reported abov *

Commitment to IE Bulletin 79-02 The Module 8 commitment matrix section 3.4 indicated that commitment No.1825 to IEB 79-02 on Concrete Expansion Anchor-Bolts is assigned only to Module 8. Cognizant Licensee personnel clarified that some aspects of commitment.to IEB 79-02 were to be included in Module 11. The inspectors'had expressed concern that relative to the apparent lack or recognition of the manufacturer advised limitations by either DC-1000-C (Rev. 3) or by Calcula-tions X2Q5.2.7 and X2CK4.1.8.19 relative to the reduced pullout loads published in the April 1984 Phillips catalo (Inspector

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Followup Item (424/85-21-01). Technical concern was resolved during the NRC examination of Module 8 (see paragraph 3.g. (3)(d)-

of NRC Module 8 Review Report No. 424/86-18).

However, further readiness review of examination of revised pullout loads was included in Module 11. This was verified by.an overview examination of Module 11 section 3.4 commitments (page 9)

regarding pipe support base plate designs using concrete expansion anchor bolts and section 3.5 (page 6) which verifies implementa-tion within:

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DC-1000-C

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Calculation X2CQ5. DC-1017-T2 Cognizant Licensee nersonnel informed the inspector that the above details had been no.ed by NRC inspectors during examination of the modules involved. This item is considered close d. (Closed) Inspector Followup Item (424/86-18-01), Followup on Correction of Deficiencies Reported by NRR for Module 8 Commitments 981, 1606, and 199 Details of NRC requested clarification regarding those commitments are as follows:

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Commitment 981 - This involves damping values which are higher than those listed in RG 1.61. The licensee has identified (in Table 3.7.8.1-1 of the FSAR) that electrical cable trays and supports should have the higher damping values specified in Figure 3.7.B.1-7 of the FSAR. Therefore, it is necessary that the commitment be extended to include Figure 3.7.8.1-7 and that in no case should the cable tray dampling values exceed 15% of critical damplin .- _ ._ _ , - _ _ - - .

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i * Commitments 1606 and 1995 - Section 1.9.57 of FSAR (pertaining to use of RG 1.57) refers to Section 3.8.2 for conformance in design limits and load combinations for Class MC components while Section 3.8.2.8 refers back to Section 1.9.57 for the Vogtle position' of RG 1.57. Clarification is required to define the content of these commitment The inspector reviewed details in the licensee's April 3, 1986, letter-of response to Region II Administrator, J.' Nelson Grace (Log: GN-843)

and supporting attachments. A summary of the licensee's clarifications is as follows:

• Commitment 981 - The higher damping values are associated with electrical supports and incorporated in the FSAR figure 3.7.B.1-7 and . Table ' 3.7.B.1-1. Pertinent commitments (No. 4871 and 1497)

are included in Module 19 and were assessed by readiness review there in Readiness review identified no case where cable trays and supports exceeded the 15% critical dampin Commitments 1606 and 1995 - The FSAR subsections associated with these commitments 3.8.2.1 through 3.8.2.7 correspond to subsection II.1 through 7 of the acceptance criteria of section 3.82 of the NRC Standard Review Plan (SRP).

The inspector determined that the licensee's response was sufficient to resolve NRC concern. This item is considered close e. (0 pen) Inspector Followup Item -(424/86-18-03), Frame Calculation Review. Followup on review of two calculations, one for vertical frame and the second for floor framing below the operating level (IE Open Item 85-64R-01).

This item was identified by I&E during the examination of Readiness

< Review Module 8, Structural Steel. The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved I&E concerns. However this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that repor f. (0 pen) Inspector Followup Item (424/86-18-04), Unreferenced Fluid Pressure for Auxiliary Building Structural Steel - Follow-up on source of 15 psi criterion for fluid pressure and explanation of omission in calculations (IE Open Item 85-64R-02).

This item was identified by I&E during the examination of Readines:

Review Module 8, Structural Steel. The inspector was informed L, Cognizant Licensee personnel that additional GPC responded had resolved I&E concerns. However this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that report.

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23 (0 pen)~ Inspector Followup Item (424/86-18-07), Structural Sizing Calculations Review - Followup on the review of two calculations from memeber sizing along with transfer of data to drawing This item was identified by I&E during _the examination of Readiness

' Review Module 8, Structural Steel. The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved I&E concerns. However this item will be' further reported in I&E Inspection -Report No. 424/86-105 and remains open pending closure in

.that repor (0 pen) Inspector Followup Item (424/86-18-08), Polar Crane Ring Girder Calculations - Followup on ' proper incorporation at crane vendor input into design (IE Open Item 85-64R-04).

This item was ' identified by -I&E during examination of Readiness Review Module 8, Structural Steel . The inspector was informed by Cognizant Licensee personnel that additional GPC responses had resolved I&E concerns. However this item will be further repurted in I&E Inspection-Report No. 424/86-105 and remain open pending closure in that repor . Deficiencies In Module 8 Readiness Review (Closed) Deficiency (424/86-18-02), Module Data Deficiencies - Module presentations of information and data reflecting potential verifica-tion errors requiring resolution during examination 'in order to provide confidence in the licensee's revie Details regarding this item are reported in Model 8 Review Report No. 424/86-18, paragraph nos. 3.c(1)(a), 3.d(1)(d), 3.9(2)(a),

3.g(2)(b), 3.9(3)(a), 3.h(3)(a), 3.h(3)(c), 3.h(4)(b), and 3.h(4)(c).

The discrepancies were noted and resolved during the NRC examination of ,

Module 8. All were determined as not affecting the validity or conclusions of the module and are sc reported in Review Report No. 424/86-1 However this item has remained open pending further licensee response on additional specified followup corrective action Further corrective actions examined during this inspection are as follows:

• Issuance of an amendment to the module correcting typos and other errors in the commitment matrices (April 30, 1986 letter (Log: GN-886) to Region II Administrator, J. Nelson Grace and attachments).

• Transmittal of clarification regarding commitments (Log: GN-843)

(see further discussion in paragraph 8.d of this report).

Annotation of module checklists of readiness review files to reference closure documents for NRC identified discrepancies.

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24 Cognizant licensee personnel acknowledged -that there were editing and proofreading errors in the preparation of Module 8 and agreed to take due cognizance of this potential problem in any further effor Cognizant personnel further noted tt". the module is not. used for construction and engineering and that these items are not vital to the-impact of the Module nor. do they affect the conclusions. Cognizant licensee personnel informed the inspector that no further amendments to Module 8 will be issue The inspector determined that Licensee Corrective Actions were sufficient to resolve NRC concern on this matter. This item is considered close (0 pen) - Deficiency 424/86-18-05, Beam Connection Angle Discrepancies -

Connection details differing between design and drawing (IE Open Item 85-64R-03).

This item was identified by I&E during the examination of Readiness Review Module 8, Structural Steel . The inspector was informed by Cognizant licensee personnel that additional GpC responded had resolved I&E concern However, this item will be further reported in I&E Inspection Report No. 424/86-105 and remains open pending closure in that repor . _ . . . , - - - - , _ . - - _ , - . - - , - - - . . - _ - - - - , . _ ,

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