IR 05000424/1988004
| ML20149G897 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/03/1988 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20149G895 | List: |
| References | |
| 50-424-88-04, 50-424-88-4, 50-425-88-03, 50-425-88-3, NUDOCS 8802190005 | |
| Download: ML20149G897 (11) | |
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UNITED STATES v
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- o, NUCLEAR REGULATORY COMM'SSION J\\
REGION la r
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j 101 MARIETT A STREET, N.W.
- t ATL ANTA CEORGI A 30323
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Report Nos.:
50-424/88-04 and 50-425/88-03
Licensee: Georgia Power Company P. O. Box 4545
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Atlanta, GA 30302 Docket Nos.:
50-424 and 50-425 Licanse Nos.:
NPF-61 and CPPR-109
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l Facility Name:
Vogtle 1 and 2 t
d 11-15, 1
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Inspection Cc ete Inspector: [
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M JM Date gned Wr".Alyns~rg$;
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Approved by.
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A J./J. Slale, Section Chief Date Signed E/igi eering Branch
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fivsionofReactorSafety j
SUMMARY
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J Scope:
This routine, unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters (927018) (92702B),
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housekeeping (548348), material identification and control (429028) material
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i control (429408), and heating ventilating and air conditioning systems (50100).
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Results:
No violations or deviations were identified.
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i REPORT DETAILS i
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I 1.
Persons Contacted Licensee Employees
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- L. N. Brooks, Civil Discipline Manager
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- E. D. Groover, Quality Assurance (QA) Site Manager - Construction
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- P. D. Rice, Vice President and Project Director
Other licensee employees contacted included construction cr0f tsmen, engineers, technicians, and office personnel.
NRC Resident Inspectors I
- R.Schepens,SeniorResidentInspector(SRI)
- Attended preliminary exit interview on January 14, 1988 l
- Attended exit interview on January 15, 1988 i
t 2.
Exit Interview l
l The inspection scope and findings were suninarized on January 14, 1988, at i
a preliminary exit interview conducted for the convenience of the i
licensta's staff who would not be on site on the last day of the i
inspection.
The preliminary exit interview was conducted with those l
persons indicated in Paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection finding. The inspector
conducted a final exit interview on January 15, 1988, with the person l
indicated in paragraph I above. No dissenting coments were received from l
the licensee.
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(0 pen) Unresolved Item 50-425/88-03-01:
"Apparent Failure to Install and l
Inspect HVAC Duct Supports in Accordance with Drawings" - Paragraph l
No 6.c.(1),
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Unresolved Item 50-425/88-03-02:
"Air Filter Housing Seismic
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Analysis" - Paragraph No. 6.c.(2).
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection, j
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Licensee Action on Previous Enforcement Matters (92701B) (927028)
(Closed) 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 t ted".
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GPC letters of response dated September 25, 1986, October 31, 1986 March 31, 1987 and July 23, 1987 have been reviewed and determined to be acceptable by Region II.
The inspector held discussions with cognizant management personnel and examined the corrective actions as stated in the letters of response.
The inspector concluded that GPC had determined the full extent of the subject deviation, perfomed the necessary survey an:I follow-up actions to correct the present conditions and developed the necessary corrective acticas to preclude recurrence of similar
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circumstances.
The corrective actions identified in the letter of j
response ha.1 been implemented.
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Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or
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deviations.
New unresolved items identified during this inspection are discussed in Paragraph 6c(1) and 6c(2).
5.
Independent Inspection Effort Housekeeping (548348), Material Identification and Control (429028) and
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Material Control (429408)
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The inspector conducted a general inspection of Unit 1 and 2 auxiliary
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buildings and the Unit 2 containment building to observe activities such as housekeeping, material identification and control; material control, and storage. The inspector found two Type 7018 Shielded Metal Arc Welding
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(SMAW) electrodes, abandoned on duct associated with EFS Airfilter Housing No. 2-1561-N7-001. This is similar to a concern discussed in NRC Region !!
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Report No. 50-424/88-03 and 50-42b/88-02.
I Within the areas examined no deviations wert identified.
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Heating Ventilating ind Air Conditioning (HVAC) Systems (50100)
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The inspector observed work in progress, conducted interviews, examined j
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completed work and reviewed records to determine:
whether the i
l installation of safety-(related HVAC systems in compliance with Nuclear Regulatory Comission NRC) requirements, licensee comitments, and l
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applicable codes; whether the licensee was adequately preparing,
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l reviewing, and maintaining a system of quality records; whether the i
j records reflect work accomplished consistent wich NRC requirements and
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Safety Analysis Report (SAR) comitments; and whether the records indicate
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any potentially generic problems, management control inadequacies, or other weaknesses that could have safety significance.
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Observation of Work and Work Activities (1) Personnel Interviews (Installation Fractices)
The inspector conducted interviews with three contractor
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(Pullman /Kenith Fartson (P/X-F)) personnel engaged in fitting l
and welding activities associated with the installation of
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isolation dampers with Nuclear Plant Maintenance Work Order l
(FWO) No. 28701912.
These interviews were conducted to confirm
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the following:
predefined and approved procedures are followed
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when it becomes necessary to relocate any seismic support or other safety-related equipment from its original location
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specified on drawings; any preinstallation field repairs or adjustments to the HVAC equipment are performed in accordance l
with the manufacturer's instructions and specifications to
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ensure that proper materials, replacement parts, and supplies r
are used, and perfonnance requirements are met and are reviewed l
by engineering for acceptance; preinstallation checks are inade i
I to ensure that bolts, nuts, and other fastener items are available and are of the correct type, size and material with required identif 4ation markings; and personnel engaged in the
installation and inspection of supports, ductwork, and other i
HVAC equipment have received adequate training to understand and perform work contained in relevant work and inspection
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procedures and instructions.
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(2)
Installation Activities (a) The inspector witnessed portions of the welding and fitting i
activities associated with MWO No. 28701912 to verify the i
following:
the latest issue (revision) of applicable
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drawings or procedures was available to the installers and is being used; and modifications to supports were approved
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by appropriate personnel before implementation.
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(b)
The inspector reviewed N2 cords of the concrete anchor bolts associated with the below listed Duct Supports to verify that anchor bolt type, diameter, embedment length, I
shoulder-to-cone measurement and torque requirements (where j
applicable) met installation requirements.
Record review
was elected as the window of opportunity had past for
direct observation of this activity.
Duct Support Record Examined
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2-132-92 2-132-87 2-132-89 i
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(3) As-Installed Equipment
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The inspector examined the installed equipment listed below for l
i proper location, configuration, identification, and damage.
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basis for this determination was the SAR system description,
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Piping and Instrumentation Diigrams (P&lDs), specifications, and
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i installation drawings.
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l Equipment Examined
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Air Handling Unit 2-1555-A7-003
Duct Supports
- 92,94, 89, 88 and 87 Fire Damper 2-1555-57-2105
l Duct Sections A-2710N, A-2710M, A-2710L
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l A-2710-K-T, A-2710K, A-2710J j
A-2720-A, A-2710B, A-2710-E A-2710-D A-27100 A-2710Q
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A-2710-5 and A-2710-H
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Air Filter Unit 2-1561-N7-001-000 l
Isolation Damper 2-HV-12614 Motor (Fan)
2-1561-N7-001-M01 Duct Supports
- 195 and 77 l
Duct Sections A-3927B, A-3927A, A3927
A-3814, A3815, A3815-A j
A-3816. A-3817 and A3818 l
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Review of Records l
(1) The inspector reviewed receipt inspection check sheets for the
below listed components to assure that inspections complied with
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l Component Records Examined
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Duct Support A-27100. A-2710C, A-10G l
A-2710-H, A-3927A, A-0015 l
Air I.It Unit 2-1561-N7-001-000
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Isolation Damper 2-HV-12614
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Fire Damper 2-1555-57-2105 i
Air Handling Unit 2-1555-A7-003 i
l (2) The 'nspector reviewed the installation thspection records for
the below listed systems to detemine whether required i
inspections of various aspects of HVAC systems and supports were J
J conducted, and to assess the adequacy of the inspection effort and the inspection records.
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l System 1 - Air Handling Unit 2-1555-A7-003 from Support No. 92 to
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Support 87
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System 2 - Air Filter Unit 2-1561-N7-001 from Duct Section A-3927 to Damper 2HY-12614 c.
Observations Relative to the inspections above the inspector made the following observations:
(1) System 1 Completed, inspected and accepted Heating Ventilating and Air Conditioning (HVAC) Nuclear Safety Related Seismic Class 1, Duct Support No. 2-132-88 is depicted on Field Change Request (FCR) No. FCRB-5367F and Bechtel Power Company (BPC) drawings No. AXD67WO41 Revision 1.
Drawing AXD67WO41 details for Type 301 specifies dimension
"D" (the distance between the center line of the duct sectinn and a 5x5x3/8-inch square tube) (see Attachment 1) to be 1-foot 0 inches maximum (12-inchos maximum).
In point of fact the actual
"0" dimension is 141/2-inches.
Subsequent to the identification of this discrepant condition by the NRC inspector the licensee documented the discrepancy in Deviation Report (DR) No. PK-4184.
This condition indicates that the installing craftsman failed to install the duct in accordance with the applicable drawing and that the Quality Control (QC) inspector accepting the discrepant nuclear safety-related, seismic category 1 HYAC duct support failed to inspect the duct support in accordance with the applicable drawing.
Failure to install and inspect the duct support in accordance with the applicablo drawing brings into sharp focus the following:
the craf tsman exceeded the 12-inch maximum specified by the drawing; the craf tsman failed to get ar engineering evaluation of the descrepant condition; ti.e craf tsman offered for inspection a duct support that deviated from the drawing; the QC inspector failed to identify fact that the "0" dimension exceeded the drawing maximum of 12-inches; the QC inspector accepted the descrepant condition; the QC inspector signed the inspection record indicating that the duct support conformed to the drawing when in point of fact it did not. By installing and accepting this descrepant nuclear safety-related seismic category 1 HVAC duct support, the installing craftsman and the accepting QC inspector usurped the prerogative, responsibility, and authority of the designer to evaluate and accept conditions outside of design envelope as defined by drawings.
The above indicates that the licensee was in apparent violation of NRC Regulations.
However at the tire of this inspection the following remained unresolved:
how the regulstory requirement was violated; when and for how long the violation existed; by
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i whom the regulatory requirement was viclated; whether there are
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multiple examples of the violation; the root cause of the
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violation; the apparent safety significance of the violation; whether there is evidence of management involvement and to what extent; and, how many opportunities the licensee had to discover the violation.
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Pending the resolution of the above issues this matter will be identified as unresolved item identified as 50-425/88-03-01:
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"Apparent Failure to Install and Inspect HVAC Duct Supports in i
Accordance With Drawings".
(2) System 2
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The 2-1561-N7-001 Engineered Safety Feature (ESF)
i Airfilter Housing is attached to the datum foundation by
3-1/2x3-1/2x1/4x4-inch angle clips.
These angle clips are shown l
en Attachment (2) and share a horizontal interface with the foundation, and a vertical interface with the airfilter housing.
l The interfaces are secured by bolting.
The NRC inspector noted
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that several of these angle clips had only line contact at the top and bottom edge of the vertical interface the result of interference from a fillet weld on the air filter housing (see Attachment 3).
The Vogtle plant (VEGP) Final Safety Analysis i
Report (FSAR) Section 6.5.1.3.E states in part "the ESF filter
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systems are designed to seismic category I requirements. The NRC l
inspector discussed the above with the licensee, pointing out, that those connections with on'v double line contact could not j
be considered as friction connections.
In view of the above, i
the NRC inspector questioned whether the lack of friction
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connections on the supports of a seismic category 1 component.
l abrogated the seismic analysis and qualification of the l
equipment, and therefore by deviated from a comitment to the i
commission ( FS AR 6. 5.1. 3. E).
The licensee contacted the manufacturer of the air filter housing American Air Filter
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(AAF) relaying the NRC inspectors concern.
AAF indicated, to the licensee, that as long as the bolts connecting the clips to i
the filter housing were tight the seismic analysis and l
qualification was valid.
AAF stated that they would send supporting docurcentation to the site.
The NRC inspector stated pending NRC review of the AAF documentation this matter will be identified as unresolved item 50-425/88 03-02:
"Air Filter
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Housing Seismic Analysis".
(3) Cormn i
The doct. mentation associated with air handling Unit 2-1555-A7-003 (System 1) wae. co npleted including the QA review.
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The documentation associated with air filter Unit 2-1561-N7-001 (Systert 2) was corplete to a point but had not had it3 final QA
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There were numerous inconsistencies in the air filter Ieyita ?) documentation (no QA review) and none identified in
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i the air handling (system 1) documentation (QA review completed).
l The inspector examined several hundred documents associated with each system. The inspectors obvious conclusion was that "Quality of Paper" is "inspected in" by QA review and not built in by
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conscientious personnel who generate the documentation with keen i
attention to detail.
It should be noted that no violations or deviations were noted relative to either documentation package.
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Within the areas examined no violations or deviations were identified, i
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Table of Acrong s and initialisums
AAF American Air Filter
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j BPC Bechtel Power Company
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Deviation Report DR
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Engineered Safety Features ESF
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i Field Change Request FCR
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Final Safety Analysis Report FSAR
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Heating Ventilating and Air Conditioning
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Maintenance Work Order
MWO
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Nuclear Regulatory Comission NRC
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Piping and Instrumentation Diagram P&ID
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Pullman /Kenith - Fortson
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P/K-F
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Quality Assurance l
f QA
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Quality Control
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Region II RII
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Senior Resident Inspector SRI
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i 10 CFR 50 -
Title Ten, Code of Federal Regulations Part 50 i
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