IR 05000425/1988026
| ML20153F666 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/19/1988 |
| From: | Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153F650 | List: |
| References | |
| 50-425-88-26, NUDOCS 8809070397 | |
| Download: ML20153F666 (32) | |
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p af 4 UNITED STATES "
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NUCLEAR REGULATORY COMMitSION
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101 M AfilETT A sTnE ET. N.W.
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i Report No.:
50-425/88-26 Licensee: Georgia Power Company P. O. Box 4545
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Atlanta, GA 30302 Docket No.: 50-425 Construction Permit No.:
CPPR-109 Facility Name:
Vogtle Unit 2 Module:
No. 17/19. Eloctrical Raceways l
and Supports Reviews Conducted: May 4 - 26, 1988 l
On-Site Inspections Conducted:
May 16 - 26, 1988 Inspectors:
/de/ /k/d # _..
N19) N M. O. fiu'nt,' Reactor Inspector, Region II Dde S'thned Team Member C. G. Bruch, Consultant, Region II (EG&G Idaho, Inc.)
Approved by b/
W/
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T. E. Conlo C Chief Date Signed i
Plant Systems Section l
Division of Reactor Safety, Region II l-Background:
This evaluation was performed for one of eleven Readiness Review SUMMARY Modules produced as part of a Pilot Readiness Review Program being operated by the licensee pursuant to a recommendation I
contained in N'JREG 1055.
The NRC agreed to participate in the program by reviewing and commenting on each module.
Scope:
This evaluation was performed by reviewi - the module report, examining supporting documentation and,nspecting associated hardware.
The licensee's review was verified by sampling hardware and documentation seen by the licensee's reviewers,
samoling hardware and documentation not selected by the l
licensee's reviewers, by reviewing records of previous NRC inspections at Vogtle and by interviewing licensee personnel who i
were closely associated with preparing the module.
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Results:
Major weaknesses and verification errors were not found. One
Unresolved Item was identified which involved incomplete l
verification of safety train separation criteria application, r
thermal separation criteria and tray cover installation.
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8809070397 000024 gDR ADOCK 05000425 PNU
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REPORT DETAILS
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1.
Persons Contacted Licensee Employees
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M. Cusach, Q.C. Inspector (Electrical)
- D. Edenfield, RRT Engineering Supervisor
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- A. Harrelson, Manager, Electrical Construction
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'R. Hollands, Superintendent, Electrical Compliance J. Jacobs Electrical Engineer
- E. Laner, Supervisor, Electrical Engineering Group l
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Lavoy, RRT I&C Team Leader J. Lovekamp Deputy Supervisor, Civil Engineering Group
- R. McManus, Manager, Readiness Review J. Orchard, Leader, Hazards Group R. Poole, Q.C. Inspector (Electrical)
- W. Ramsey, Manager, Engineering
- P. Rico, Vice President & Project Director R. Smith, Project Manager, Electrical and I&C R. Thomas, Member, Readiness Review Board R. Valdez, Project Quality Engineer NRC Inspector R. Scheppens, Senior Resident inspector, Construction
- Attended exit interview Acronyms and abbreviations used throughout this report are listed in the
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last paragraph.
2.
Module 17/19 Electrical Raceways and Supports a.
Unit 2 Review The Readiness Review Program is being conducted at the initiative of Georgia Power Company (GPC) management to assure that all design, procuarement, construction, and operational commitments hAve been properly identified and implemented at the Vogtle Electric Generating Plant (VEGP) Unit 2.
Module 17/19, which was submitted on March 1, 1988, presents an assessment of the compliance of the Electrical Raceways and Supports contained in Seismic Category I structures with Ft.1 Safety Analysis Report (FSAR) commitments and regulatory requirements.
This evaluation was conducted to determine if the results of the program design, fabrication and installation for review of Electrical Raceways and Supports presented in this module represented an effective and accurate assessment of the requirements,
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that the requirements were properly implemented, and that the resolu-tions of the findings identified in Module 17/19 were correct.
It should be noted that a comparable review had been completed for VEGP Unit 1 in separate modules as follows during 1985 and 1986:
Module 17 Raceways Module 19 Electrical Supports.
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These two technical areas have been combined by the licensee into a single module for the Unit 2 review, b.
NRC Review Objective The objective of this review and inspection was to evaluate the licensee's VEGP Unit 2 Readiness Review of Electrical Raceways and Supports. The evaluation was to be accomplished through a detailed examination of all sections of the module to include:
Assuring the accuracy of the information contained.
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Verifying that the Electrical Raceway and Support commitments
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identified in the module are correct along with being in conformance with FSAR commitments and regulatory requirements.
Checking a representative sample of the documents reviewed by
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the Readiness Review Staff along with other documents selected by the inspectors.
Inspecting a representative sample of the Electrical Raceway and
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Support components currently installed in Unit 2.
Reviewing reports of past Nuclear Regulatory Commission (NRC)
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inspections at Vogtle Unit 2 that pertain to Mcdule 17/19.
Assessing the Modulc 17/19 findings and the licensee's resolu-
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tion thereof.
Assuring that the findings and lessons learned from the Unit 1
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review were appropriately recognized in the Unit 2 review.
i Verifying that credit can be taken for those aspects of the
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Unit i review that are directly applicable to Unit 2.
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c.
Review Scope The total module was reviewed by the Region !! inspection team for organization and content. This part of the NRC review disclosed that Module Sections 1, 2, 3, 4, and 5 presented data on module organiza-tion, project organization, commitments, program description, audits
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I and special investigations.
These sections were descriptive and presented niaterial that was similar to that presented in the similar
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numbered sections in Modules 17 and 19 for Unit 1.
These sections did not require the review depth given to Lections 6 and 8 which
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coverev the program verification and review assessment plan respec-l
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tively Sections 1 through 5 w re reviewed relative to changes that l
occurre in the Vogtle Projecs and Readiness Review programs since i
the Utit 1 review, however.
Moule Section 7 was similar to
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Sectier: 8 of the Unit 1 modules anc consisted of management's
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certification of the review effort and findings.
Section 7 of the f
Unit 1 modules reflected the Independent Design Review made as part
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of the Unit i review. The licensee did not repeat this in the Unit 2
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Readiness Review on the basis that the design s.as essentially similar
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for both units, was performed by the sams organization and was
essentially complete at the time of the Unit 1 Readiness Review.
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i was considered that reverification of an essentially complated
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program would be redundant within the Unit 2 review.
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Sections 6 and 3 contain the majority of the new material and
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disclosed those aspects on' the Unit 2 review that differed from that examined by NRC pursuant to the Unit I review, Review of
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these two sections included an examination of content; review of i
findings, concerns and observations; review of a sample of items l
reviewed by tu GPC Readiness Review Team (RRT); and preparing for i
j an examinatiot. of an independently selected sample of records and i
t field construt. tion.
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Site Inspection (
i The site inspection was conducted at Vogtle Unit 2 during May 16-26, j
1988. The following activities were conducted:
f Determining the RRT organizational element responsible for
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Module 17/19 and interviewing key staff members.
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j Verifying the module review boundary.
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Making a general verification of the material presentec in I
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Sections 1 through 5 and 7 of the module report.
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Obtaining supplemental documentation copies required for review I
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Reviewing prograr.matic and review methodology changes taking
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place since the eeview of Unit 1 Modules 17 and 19.
I Assessing the licensee's Module Assessment Plan for adeqmcy of
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j depth and coverage within the trodule boundary.
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' Performing commitment tracing for commitments that were new or
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changed since tha Unit i review.
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Performing a construction program verification review of. Module
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Sections 6 and 8.
The new and the changed commitments were traced into selected first
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and second order verification documents.
They were traced backward through the FSAR, or other commitment sources, to the parent require-ments.
Continued office review was made af ter the inspection trip to evalu-ate data gathered, draf t the module review report, and identify any items that might require further field review and analysis.
The review plan, module report, and examination data gathered to date were checked for potential gaps and incomplete work. The results of the office review disclosed that sufficient information had been obtained during the site visit and that the data gathered fully scpports the NRC findings presented in this module review.
3.
Evaluations-The evaluation of each module section is p.ovided in the remainder of this report using a module section-by-section format. Included are a descrip-tion of the section, what was reviewed, the basis for acceptance, and a
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statement of any required followup or evaluation.
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a.
Section 1 - Introduction
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(1) Review Introduction and Section Examination This section of the module provided a description of the intent and content of Module 17/19. Also provided was a description of the Vogtle Unit 2 hardware covered within the module, an outline of the module organization and an overview of the project status.
This section was examined by the inspectors for content, background and accuracy of information. Clarification of information con:erning the module boundary and project status was required.
This was accomplished during discussion with RRT personnel.
(a) Boundary Definition The descriptive diagrams used in Subsection 1.2 of the Unit 1 Modules 17 and 19 were not repeated in Module 17/19 for Unit 2.
The information given in Module Subsection 1.1 was reviewed in detail with the RRT counterpart to clarify
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the boundary definition. presented. The information gained during the review did not disclose verification error. The following clarifications were obtained for the boundary:
Concrete expansion anchor bolts for electrical
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supports were within Module 17/19 for installation and within the Unit 1 Module 8 for design.
Bolts that attach conduit and cable trays to electri-
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cal supports or to structural steel were within Module 17/19.
Electrical support anchor welding to embeds and to
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structural steel was within Module 17/19.
Conduit junction boxes were within Module 17/19.
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(b) Module Organization The medule organization portion of the section was examined by the inspectors and no instance of inaccuracy or need for clarification was found.
The differences in module
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organization as compared with the Unit 1 Modules 17 and 19 have been noted in Section 1 of this report. These are not considered significant since it was not necessary to repeat
the design review aspects for Unit 2.
A specific question was asked concerning the existence of significant changes subsequent to the August 1, 1987 cutoff date for Module 17/19 data. The RRT counterpart responded with a statement that there were no changes to the informa-tion contained in the module with the exception of an increase in the project status percent complete number for the conduit and conduit supports. Evidence of significant module-basis change since the August 1,1987 cutoff date was not discovered during the review.
(c) Project Status The status shown in Subsection 1.3 of the module ranges from 80 percent for conduits and conduit supports to essentially 100 percent for trays and tray upports.
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former number was found to be close to 100% due ;o progress made since August 1987.
The latter was found to be slightly less than 100% due to the absence of tray covers l
pending cable installation completion. Review of the basis for these numbers disclosed that earned value was based on installation completion an1 satisfactory inspection of each individually numbered hardware item.
This information is
maintained in the EE-580 Cable and Raceway Tracking and Control System.
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(2) Inspection Results The clarifications provided by the RRT, as noted above,
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correlated with other information reviewed by the inspectors.
The examination did not disclose significant verification errors or a basis for programmatic concern.
Followup or additional evaluation of Module Section 1 is not required.
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b.
Section 2 - Organization i
(1) Review Introduction and Section Examination
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This section of the module provided a description of the organizations employed for project design and field construction activities.
The integration of these into the total project management matrix for the subject of Module 17/19 also was
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provided.
This section was examined by the inspectors for content and background information.
The information presented
agreed with that obtained by the inspectors durino past inspec-tions at both Unit 1 and 2.
No instances of variance from the Section 2 information were found during the course of the total module review.
Also, the information presented did not
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differ essentially from that examined during the review of
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Unit 1 Modules 17 and 19, except for engineering and project t
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management changes occurring subsequent to the Unit 1 review.
These primarily were the transfer of Bechtel Home Office
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Engineering (H0E) functions to the Bechtel Project Field
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Engineering (PFE) office at the plant site.
The transfer was accompanied by some reorganization.
These changes were found
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to t, ave low programmatic impact since PFE originally was an
extension of HOE many of the same people were retained and the design was at the nearly-complete stage.
Further evolution of the engineering o sanization has taken place since the August 1, 1987 module cutoff date. The separate functions of design and installation engineering depicted on Figures 2-2 and 2-3 of the module are undergoing consolidation.
This is caused by the decreasing number of personnel required as hardware installation nears completion.
(2)
Inspection Results The examination did not disclose significant verification errors or a basis for programmatic concern.
Followup or additional evaluation of Module Section 2 is not required, c.
Section 3 - Commitments (1) Review Introduction and Section Examination
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n This section of the module describes the commitment selection
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and sources along with containing a list of commitments and implementing documents.
These are displayed in two matrices.
The first is entitled "Commitment Matrix"-and lists 68 commit-ments by the Georgia Power Company for VEGP Unit 2 along with the source document reference for ecch commitment.
The second is entitled "Implementation Matrix" and lists source documents and requireraent features referred to within ' each commitment along with the document reference where the feature has been implemented. An identification review was made to verify if the commitments listed in the Unit 1 Modules 17 and 19 had been accurately carried forward into Module 17/19 for Unit 2.
Anomalies were discovered and a sample was selected comprised of'
the four commitments listed as changed along with the eight not correlating between the Unit 1 and Unit 2 modules. A review of these twelve was made to verify the proper implementation of the listed commitments.
This was accomplished by examining the sample to check the commitment source (typically FSAR and referenced standards) for the exact requirement and to verify (within the project documentation) that the requirement had been carried through accurately.
(a)
Identification Review The examination of Section 3 started with a reading of the module for content.
The commitment listings of Section 3 of the module were compared with the corresponding listirgs of Unit 1 Modules 17 and 19. The following anomalies were discovered:
Four commitments (76, 79, 4973 and 5025) were identi-
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fied as being changed in the Unit 2 Module. Of these, 76 and 79 had been listed in Unit 1 Module 17 and 19 along with 4973 in Unit 1 Module 19.
Further review disclosed that 5025 had been added since the Unit I review.
Seven commitments (1010, 1014, 1017, 1018, 2905, 4688
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and 5062) were not identified as new (or changed) in the Unit 2 Module although they had not been listed in the Modules 17 or 19 for Unit 1.
Further review disclosed that 1010, 1014, 1017 and 1018 had been included in other modules in the Unit 1 review but were considered by the RRT as being appropriate to Module 17/19.
Commitment 2905 was generally covered but not specifically identified in the Unit 1 General Appendix I.
Commitment 4688 was found to be essen-tially identical to 1018.
Commitment 5061 was found to be essentially identical to Commitment 160 of the Unit 1 Module 1,
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One commitment (2360) listed in the Unit 1 Module 17
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did not appear in the commitment matrix for Unit 2
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Module 17/19.
Review also disclosed that it was
essentially identical to Commitment 4115.
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Implementation Review
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The 12 commitments listed above in Subsection 3.c.1.(a)
were selected for verification. The examination of this sample consisted of:
Verifying correspondence between the Module Commitment
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~ Matrix and the Module Implementation Matr;x for each commitment.
Reviewing the referenced commitment-source documentation
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for a clear statement of requirement fu each commitment within the sample.
Checking the document listed in the Module Implementation
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Matrix for proper first and second order implementation of the requirements embraced by the commitment.
The commitments listed in the Unit 1 Modules 17 and 19 had been examined by NRC during the review of those modules.
Accordingly, examination of commitments carried forward (without anomaly) from those modules into the Unit 2 Module 17/19 was not made.
The individual commitments reviewed along with the review resuits are listed in Table 1 of this report. Several anomalies were discovered and are outlined in that table.
Additional discussion concerning the licensee's commitment review also is included in Subsection 3.f(2)(a) of this report.
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Inspection Results The examination of Module Section 3 did not disclose substantial verification errors, other than noted above, or programmatic concerns. Followup or additional evaluation of Module Section 3 is not required.
d.
Section 4 - Program Description (1) Review Introduction and Section Examination This section cf the Module describes work process and control for the design and construction of hardware covered by the module.
This is supplemented by documentation listings, flow charts, and an outline of program changes.
The section was examined by the inspectors for content, background for the
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review of later sections (especially Sectiori 6, Program Assess-ment) and for the veracity of the information presented.
A detailed examination of the section was not made by the inspectors since the material contained was largely descriptive and not in the nature of an assessment.
Credit was taken for the examination of similar material during the Unit I review.
(a) Design Subsection 4.1 was examined for content and general agree-ment with information developed during past NRC inspec-tions.
In addition, the flow chart referenced in this subsection was reviewed for logic and accuracy.
The foregoing provided general agreement between commitments and he activities covered by the Design Program.
(b) Construction Subsection 4.2 was examined for content and general agree-ment with information o;,,21oped during past NRC inspec-tions. The flow charts referenced in this subsection were reviewed for general logic and compared with programmatic documents for accuracy. Several anomalies were apparent in the flow charts (Figures 4-2 and 4-3).
These anomalies were explainable as simplifications of more complex processes detailed in the documents along with incomplete editing.
(c) Program Changes.
Subsection 4.3 outlined program changes involving activities directly related to raceways and supports that had occurred since the Unit 1 Readiness Review.
Three out of the four changes affected procedures and personnel. The changes were directed at strengthening existing practices.
The fourth involved allowing an increased conduit support spacing for nonsafety related conduits in Category 1 areas. The four changes were listed in the module without significant description or detail.
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Accordingly, the basic documentation, covering the changed programs, was reviewed for content and potential ambiguity.
The latter was not found during the review.
(d) Materials and Training.
Specific descriptive detail was provided in Section 4 of the Unit 1 Modules 17 and 19 relative to Materials and Training. Comparable activities were not described in Section 4 of Unit 2 Module 17/19.
The review made of the Unit 1 Modules relative to these activities and the licensee's programmatic continuity from Unit 1 to Unit 2 is considered adequate. Further review in these areas was not made.
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Inspection Results The Section 4 examination did not disclose verification errors or further basis for. programmatic concerns.
Followup or additional evaluation is not required, e.
Section 5 - Audits and Inspections (1) Review Introduction and Section Examination.
This section provides a discussion of the audits of Module 17/19 related activities and documents made by GPC and Bechtel Power Corporation (BPC) along with the inspections made by NRC. The audits and inspections performed subsequent to the Readiness Review, of Unit 1 Modules 17 and 19, were those reported. Also included was e discussion of the Unit 1 Readineta Review find-ings t.nd certain conditions discovered, since the Unit 1 Readiness Review, that were reportable or potentially reportable under 10 CFR 50.55(e) or 10 CFR 21.
It was noted that Unit 1 General Appendix I entitled "Project Quality Assurance Organization" provided the description and validation of the various audit progrea
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' Subsections were provided for Program Description,' Summary and Conclusions, Assessment Activities and Results, along with
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Findings.. The licensee's review specifically.was intended to assure thst:
Project procedures implemented licensing commitments.
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Actions taken to resolve problems identified during the
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' Unit 1 Readiness Review have been effective in preventing recurrence in Unit 2.
Program and organizational enhancements made for Unit 2
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have maintained the quality of the design and construction effort.
~ Installed hardware complies with engineering requirements.
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This section of the module presented most of the new material (Unit 2 specific) and reflected that portion of the licensee's review of matters not covered by the earlier review of Unit 1.
Accordingly, this section received a detailed examination by the inspectors.
(a)
Introduction and Program Description.
Subsections 6.1 and 6.2 were read for content and to assure that they were in consonance with material presented earlier in the module. These subsections are largely descriptive and were found to agree with information presented in other sections of the module. Subsection 6.3 summarized later portions of the module, viz. Sections 6.4, 6.5, and 8.
Error in the summary was not found. The penultimate paragraph of module Subsection 6.3 contained the following licensee conclusion:
Based on Readiness Review assessment activities and Project responses to findings, Readiness Review has concluded that all Module 17/19 findings represent isolated cases of failure to meet design or procedural requirements or procedural inadequacies and do not identify any safety or generic program concerns.
In addition, completion of the corrective actiot, committed to by the Project concerning the Module 6 Finding 2RRF-006-011 will ensure compliance with related Module 17/19 licensing commitments.
The verification of this represented a considerable portion of the NRC review, however.
The results of the verifica-tion are detailed in the following part of report Section 3.
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(b) Assessment Activities and Results.
The licensee's assess-ment activities were divided into three parts as follows:
Part 1 - Commitment Implementation and Unit 1 Finding
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followup.
Pcrt 2 - Programs and Activities.
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Part 3 - Completion.
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Thc licensee reviewed the information preser.ted in Section 5 of the module (Audits and Inspections) along with NRC reports of inspections at four non-GPC owned plants to identify new areas of industry concern that might have been overlooked. The result of the foregoing was an assessment plan detailed in Section 8 of the module and reported on in Subsections 6.4 and 6.5 of the module. The NRC Inspectors examined a sample of the licensee's verifications, in each of the three assessment activity parts, along with selecting an independent sample of examination items in assessment parts 1 and 3.
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(2) Part 1 Examination Part 1 of the licensee's assessment was divided into verifica-tion of (1) the commitments listed ti. Section 3 of the module and (2) followup of the Unit 1 Readiness Review Findings.
(a) Commitment Verification. The examination of commitments
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started with an NRC 2 election of a sample of 12 commitments from the 68 listed in Subsection 3.4 of the Module.
The selection was comprised of eight of those found to repre-sent anomalies as reported in Subsection 3.c(1)(a) of this report. That is, they appeared to be different from those listed in or had not been.arried forward from the Unit 1 Modules 17 and 19.
The remaining four of the NRC sample were those identified by the licensee as new within the 68 listed in Section 3 of the module.
The NRC sample included seven design commitments, one construction commit-i ment, and four listed as both design and construction commitments.
The remaining 56 commitments were found to have been included in Modules 17 and/or 19 of the Unit 1 Readiness Review. Credit was taken for the NRC review of the commitment sections of those modules and further examination of the 56 was not made.
(b Train Separation Criteria.
The licensee referred to a Module 6 Finding (2RRF-006-011) in the Design Commitment paragraph of module Subsection 6.4.1.
This came from an investigation by the RRT of train separation criteria differences between the Final Safety Analysis Report (FSAR)
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Subsection 8.3.1 (commitments 76 and 79) and those listed in Construction Specification X3AR01-E8, Attachment B.
The problem previously had been addressed by the licensee pursuant Deficiency Evaluation Report (DER) 186.
It had been reported to the NRC as a Reportable Item under the 10 CFR 50.55(e)/10 CFR 21 procedures on February 24, 1988.
l Action had been taken by the licensee during the construction of Unit 1 to reduce the need for Fire Separation Barriers otherwise required by NRC Regulatory Guide (RG) 1.75 where appropriate separation distances between train cabling was not provided during installation. This was based on actual tests conducted by a certified laboratory in accord with Institute of Electrical and Electronic Engineers (IEEE) Standard 384-75 as allowed by l
The test results had been incorporated into an FSAR
amendment approved by the NRC.
The results also had been incorporated by various revisions to the following:
i Design Criteria (DC) 1810--Raceway Systems
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Construction Specification X3AR01-E8--Raceway Systems
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Field Procedure ED-T-02--Raceway Installation.
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The deficiency noted in the Module 6 Finding 2RRF-006-011 was that document revisions did not result in a consistent set of
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criteria for judging the acceptable reductions from the train separation distances otherwise required by RG 1.75.
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The licensee's action to resolve the condition reported in 2RRF-006-011 included the following.
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I Commissioned a
second and supplementary series of
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laboratory tests to provide data for additional separation l'
conditions not contemplated by the first series of tests.
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Develop a FSAR amendment to incorporate the analysis made
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pursuant to the second laboratory test series.
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forwarded to the NRC for approval on March 14, 198A but had not been approved at the time of the NRC site visit for
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Module 17/19.
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Revised DC-1810 to incorporate the FSAR revisions that had
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been forwarded to the NRC for approval.
Decided not to provide further revision to either Construc-
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tion Specification X3AR01-E8 or Field Procedure EO-T-02 to
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bring them into substantial alignment with the pending FSAR change.
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Developed a walkdown guideline to be used during the
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Finalization Walkdown inspections (retrofit requirements identification) referred to in Subparagraph 6.4.1 of the Module. This guideline was reported as being in general alignment with X3AR01-E8 and E0-T-02 but also not reflect-ing the changes in DC-1810 that had been made pursuant to the second series of laboratory tests.
Discussion with licensee personnel and inspection of the various documents provided the following additional information:
The proposed FSAR change and the changes made to DC-1810
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are in full alignment with each other for safety train separation criteria.
X3AR01-E8, ED-T-02, and the walkdown guideline are in close
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but not total alignment with each other for safety train separation criteria.
The two foregoing sets of documents are not in close
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alignment with each other.
Licensee personnel asserted that the differences in the five prescriptive documents represented a conservative (safe)
situation.
This is because the documents are employed in a manner that results in field inspection activities using the most restrictive two documents, i.e., EO-T-02 and the walkdown guideline. These do not reflect the reduced train separation criteria supported by the second series of laboratory tests.
Hardware situations noted as deficient using these are referred to Engineering far analysis This analysis can use the more liberal criteria (less separation distances) supported by the second series of laboratory tests. Any distances remaining in violation, af ter the application of this criteria, are to be resolved by hardware relocation or by the installation of an appropriate fire separation barrier.
Preliminary review of the five safety train separation criteria documents disclosed that the criteria were complex since they were structured to recognize a large variety of hardware situa-tions.
In addition, only two of the five documents (proposed FSAR change and the DC-1810) used a similar format and presenta-tion style.
No document was of fered by the licensee that described differences in the criteria as reflected by the documents. The difficulty noted in recognizing the differences, in verifying the correctness and in proving the ascertion of
conservative "safe" program operation together resulted in a contribution to Unresolved Itc,425/81-26-01 detailed in Subsectirn 3.f.(4) and listed in Section 4 of this report,
,
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_ _ - - - - - - - - - - - - -. _ _ - -. - _. - - -
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- - - - - - - - - - - - - - - - -. - - - - - _ - -
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-(c) Uniti Findings Followup The NRC examination of the RRT's review of the Unit 1 Readiness Review Findings (as listed in Section 5 of the module) is noted within Subsection 3.e.(1)(c) of this report.
The inspectors verified the incorporation of appropriate Unit 1 findings by examining the applicable Unit 1 Readiness Review Modules.
,i addition, the licensee's determinations relative to each finding were examined.
Error was not found in this examination other than the absence of Unit 1 Finding RRF-12-023 (Conduit Spacing to Avoid Cable Ampacity Reduction). This had been transferred to the Unit 2 data base for Module 12.
The kRT finding followup investigation resulted in one Unit 2 finding.
This was Finding 2RRF-17/19-005 (Level II Violation of licensing commitments or engineering
-
requirements with no safety concerns).
The finding involved the apparent lack of a program to seal conduits in a manner that would prevent water entry into electrical equipment.
Conduit sealing had been. accomplished for Unit 1 pursuant to Finding RRF-17-003 under a procedure controlled by the Civil Discipline.
This responsibility was transferred to the Electrical Discipline for Unit 2 but was not incorporated into the electrical practices.
The licensee's response to this finding was to revise Procedure ED-T-33 (Electrical Facility Completion and Turnover) to incorporate provisions for conduit sealing, where needed.
The NRC Inspectors reviewed Finding 2RRF-17/19-005 and the licensee's response to it.
Appropriate changes to incorporate conduit sealing requirements were found in ED-T-33 along with the actual installation requirements being described in Construction Specification X3AR01-E8.
(3) Part 2 Examination Part 2 of the RRT assessment activities (Program and Activities)
involved a review of the cable tray cover activities snd the fire / separation barrier request program. These had been identi-fied as changed since the Unit 1 Readiness Review.
(a) Cable Tray Cover Installation. The module Subsection 6.4.2 reported that the RRT did not assess cable tray installa-tion activities.
This was because most tray covers were not installed due to cablo pulling operations in progress at the time of the module preparation. This same condition was noted by the inspectors at the time of the site visit.
Review did disclose that the licensee had set up a practice for verifying tray cover installation in Procedure GO-A-50 (Nucien Construction Area Turnover).
Also, specific i
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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e
checks for this are included in the Field Procedure ED-T-02 checklists which are used during the area turnover walk-downs to verify installation completion.
The inspectors were unable to verify the program effectiveness since area turnover is at an early stage for areas containing
Class 1E electrical raceways.
This contributes to Unresolved Item 425/88-26-01 detailed in Subsection 3.f.(5)
and listed in Section 4 of this report.
(b) Fire Separation Barrier Request Program The Fire Separation Barrier Request (FSBR) Program was examined due to the changes made since the Unit I review.
Field Procedure ED-T-32 (Fire / Separation Barrier Request)
was examined for evidence of the program changes and for general coordination with other program activities, l
'
l Verification error was not found.
It was noted that the FSBR Program was closely associated with the Safety Train Separation Program and problems discussed previously in Section 3.f.(2)(b) of this report.
This is because train separation distances, not acceptable under the reduced distance criteria resulting from and supported by approved FSAR changes (laboratory data implementation), must be l
resolved by separation barrier installation or by hardware I
relocation.
Thus, the full verification of the program could not be made pending the outcome of Unresolved l
Item 425/88-26-01 detailed in Subsection 3.f.(5)
and presented in Section 4 of this report.
l (4) Part 3 Examination The licensee's objective for Part 3 (Completion) of the assess-ment was to evaluate the conformance of installed raceways ano supports to licensing commitments and design requirements along with evaluating quality documentation. Five categories of I
l hardware had been reviewed by means of the sampling check-lists l
included in Section 8 of the module.
The review included both I
documentation and associated hardware located within Unit 2.
The NRC examinat'on involved:
Inspecting samples selected from the samples assessed by
-
the RRT.
l Performing an examination of samples of hardware (and
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supporting documentation) independent of those checked by the RRT.
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t (a) RRT Assessment. The RRT hardware verification using Module Section 8 checklists is summarized as follows:
Item Number Checklist Trays 39 locations 17/19-301 Conduits 25 each 17/19-302 Raceway Occumentation 64 sets 17/19/303
Tray Support & Doc.
16 each 17/19-304 Conduit Support & Doc.
25 each 17/19-305 t
The NRC examination of the foregoing RRT verification sample involved spot checking the actual ' check lists filled in by the RRT and inspecting selected hardware from the RRT sample.
A minimally sized hardware sample was used as the objective was to assure that the RRT had performed the assessments as described in Module Subsection 6.4.3.
Verification error was not found in these examinations.
The RRT hardware assessment resulted in four findings classified within the following Readiness Review System for impact:
Violation of licensing commitments, project Level I
-
procedures, or engineering requirements with indication of safety concern.
L Violation of licensing commitments or engineering Level II
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requirements with no safety concerns.
Level III -
Violation of project procedures with no safety
concerns.
The four RRT hardware findings were:
17/19-001 (Level II) Tray support not in accord with installa-tion drawings.
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17/19-002 (Level II) Inadequately torqued bolts.
17/19-003 (Level II) Inadequate thermal separation from hot l
pipe.
17/19-006 (Level II) Tray size difference between installation
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drawings and EE-580 raceway installation card.
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The foregoing findings were analyzed by the inspectors for attributes that included:
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Problem statement clarity
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Backup documentation completeness j
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Response statement adequacy
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RRT conclusion-logic
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Finding conflict with other NRC information.
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The examination of the four RRT findings did not disclose verification error.
(b) NRC Independent Sample Verification. An independent sample of 14 individual raceways and associated supports was selected for field walkdown. The sample was selected to provide a broad range of hardware types and Category I locations. The sample was outside of that selected by the RRT and was intended to be a further verification of design conformance. Documentation was assembled relative to both the prescribed requirements and the actual Quality Control inspection.
The hardware was inspected for attributes including:
Design conformance
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Support location
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Identification marking
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Bolt torque
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Welding (if not concealed by subsequent painting)
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Separation criteria
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Foreign commodities on electrical supports
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EE-580 Card correlation
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Tray cover installation
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Deviation report documentation
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Quality Control inspection evidence.
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The results of this examination are listed in Table 2 of this report.
Two verification errors were found in the foregoing. These were:
Tray Covers - The current missing-tray-covers situation
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is detailed in Report Section 3.f.(2)(a) and covered by Unresolved Item 425/88-26-01 detailed in Subsection 3.f.(5) and listed in Section 4 of this report.
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Thermal Separation Conduit (Jacketed flexible
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conduit) was found to be in contact with its associ-ated SOLA regulating transformer 2-1807-43-RX7 in
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Room 47, Level 1, Auxiliary Building.
Transformer heat was melting the outer jacket of the conduit.
A check for thermal separation criteria in field procedure E0-T-02, Exhibit 18 (Q.C.
Inspection l
Checklist) and Exhibit 13 (Hot Pipe Separation i
Criteria) failed to disclose a requirement to apply
the same criteria to hardware other than piping.
This contributes to Unresolved Item 425/88-26-01 detailed in Subsection 3.f.(5) and listed in Section 4 of this report.
(5) Inspection Results The examination of the Program Assessment section of the Module resulted in one Unresolved Item as follows:
425/88-26-01 - Incomplete verification of safety train separa-
'
tion criteria application, thermal separation criteria and tray
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cover installation.
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This is summarized as follows:
(a) Safety Train Separation Criteria Application. The licensee does not have a ready cars of demonstrating process
!
conservatism in the current application of electrical
,
raceway train separation criteria.
The existing criteria vary in the prescriptive documents that reflect implemen-tation of the Wyle Laboratories test data used as the bases
.
for not installing fire separation barriers otherwise
!
required by NRC Regulatory Guide 1.75. This is covered in j
Subsections 3.f.(2)(b) and 3.f.(3)(b) of this report.
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(b) Thermal Separation Criteria.
The licensee did not have or show the use of appropriate thermal separation criteria for space between electrical raceways and thermally hot equip-ment other than piping.
This is covered in Subsection 3.f.(4)(b) of this report.
(c) Cable Tray Cover Installation.
The licensee readiness
,
review dia not carry out the planned review element of cable tray cover installation activities due to
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pulling operations then in progress.
This is covered in Subsection 3.f.(3)(a) of this report.
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Section 7 - Assessment of Module Adequacy (1) Review Introduction and Section Examination Section 7 of the module contains certifications 'by the following:
Project Engineering Manager
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Vice President Vogtle Construction
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Project Quality Assurance Manager
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Readiness Review Board Chairman.
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These certifications reflected review by upper management cf the module and assurance that it accurately reflected both the review made and the plant / programs reviewed by the RRT. The Readiness Review Board certification' added assurance that corrective actions, then proposed, were acceptable and would bring Electrical Raceways and Supports into full FSAR compliance upon implementation.
The Inspectors examined the certifications and considered them to reflect the actions of appropriate managers who had the responsibility to closely monitor the Readiness Review and to assure its quality.
(2)
Inspection Results The examination did not disclose error or perfunc'.ory certifica-tion.
The certifications given are supported by the results found in the NRC examination of the other sections of the module.
Followup or additional evaluation of Module Section 7 is not required.
h.
Section 8 - Assessment Plans and Checklists (1) Review Introduction and Section Examination This section of the module provides the licensee's formal plan for the documentation and hardware to be reviewed for Module 17/19.
The plan details the review approach including objec-tives, scope, assessment, and general instructions.
An extensive set of checklists covering nine designated review areas included:
FSAR Design Commitment Implementation
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FSAR Construction Commitment Implementation
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Fire / Separation Barrier Control Number
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i Tray Cover Installation
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Construction Completion of Tray Installation
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Construction Completion of Conduit Installation
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Raceway Final Documentation
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Tray Support Documentation j
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Conduit Support Documentation.
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Section 8 of the module was read for content. The check lists were examined for relevancy to the objective and scope of the assessment plan.
Section 6 of the module was checked to verify
,
that all aspects of the Section 8 assessment plan were followed
,
in the execution of the Readiness Review.
The completed
'
Section 8 check lists were spot checked in the RRT review i
files to assure that the check lists were used, that relevant information was obtained/ analyzed / entered and that all cases of deviation were pursued to an adequate resolution / reporting.
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It was noted that check lists 101 and 102 pertained to licensee commitments. The specific commitments that the check list items pertained to were not noted in either the module or the lists.
This was clarified by the RRT as follows:
Check List 101 Check List 102 Item Commitment Item Commitment
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32
35
27
- 29
76 l
79
84
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84
18
,
20
74
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35
4973
22
4973 i
131 i
18 & 160 t
4116
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4114 i
133
126
!
4273 i
1013
1497
2188 i
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- Commitment moved to Module 12.
f L
Verification error was not found in the foregoing.
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(2)
Inspection Results The Section 8 examination did not disclose verification error or the basis for. programmatic concern.
Followup or additional evaluation of Module Section 8 is not required.
4.
Review Findings One finding was identified during the NRC evaluation of the module. This is detailed in Section 3.f.(5) of this report. All of the deficiencies noted within this finding are considered to have minimal safety signifi-cance at this point of review but should be evaluated further to preclude safety problems. This has been identified as an Unresolved Item (URI)
based on the nature of the followup action required. It will be addressed by the NRC during the routine inspection program unless designated as closed in the finding.
5.
Conclusions The NRC has reached tSe following conclusions for Electrical Raceways and Supports at VEGP Unit 2 based on the review of Module 17/19.
a.
Summary of Specific Conclusions The following Module sections have been determined to be acceptable with the exception of items and areas discussed earlier in this report. A summary of the report comments for each section is as follows.
(1) Section 1 - Introduction The boundary between Module 19 and the related Modules is generally clear as defined in Section 1.
Minor clarification of the data presented was required fcr definition completeness.
The Module Organization and Project Status were correct as of the date of Module publication.
Electrical raceways and supports were essentially complete as of the site visit with the exception of tray covers.
These generally haven't been installed due to uncompleted cable pulling and testing.
(2) Section 2 - Organization and Division of Responsibilities The organization description and responsibility presented in Section 2 of the Module were reviewed and verified as being correct as of the time of Module preparation.
Some minor changes have taken place during the interim to consolidate design and installation functions within the site engineering office.
This is an adaptation to the reduced staffing require-ments as construction nears completio _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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(3) Section 3 - Commitments The commitments listed in Section 3 were reviewed to determine changes from those listed in the Unit 1 Modules 17 and 19.
Twelve of 68 gave evidence of change or difference from the Unit I review.
Examination of these was made to assure correct identification and implementation.
(4) Section 4 - Program Description The design program description presented in Section 4 was reviewed and verified as being correct (5) Section 5 - Audits and Special Investigations The audits and special investigations information presented in Section 5 was reviewed and verified as being correct.
(6) Section 6 - Program Verification The program assessment reported in Section 6 of the Module was verified as being generally adequate. The NRC review disclosed three areas of incomplete verification which resulted in URI 88-26-01.
This involved thermal separation criteria, safety train separation criteria application and tray cover installa-
'
tion. The five findings by the RRT were found to be clearly stated, adequately documented, properly recognized by manage-ment.
(7) Section 7 - Assessment of Module Adequacy l
The certifications presented in Section 7 of the module were
[
found to reflect action on the part of the cognizant managers having responsibility to assure the adequacy of the Readiness Review.
.
(8) Section 8 - Assessment Plan and Checklist The assessment plan presented in Section 8 of the module was verified as being adequate for the purpose and being followed substantially during the Readiness Review.
Clarification was required to relate two of the check lists to module Section 3 commitments.
b.
General Conclusions The examination performed by the NRC indicated that GPC management supported the Readiness Review by active participation and adequate resources.
No evidence of coercion, or attempt to dilute either the effort or the findings, was disclosed.
The RRT displayed the
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requisite competence and professionalism for a review of this nature.
The licensee's program was comprehensive and provided adequate assurance that the plant Electrical Raceways and Supports will perform in accord witn NRC requirements and FSAR commitments.
Possible exception to this is the open Unresolved Item (URI-425/
83-26-01) resulting from the NRC examination and which is listed in Section 4 of this report.
It does not appear that the foregoing represent significant program-matic weakness provided that additional licensee response is suffi-cient to enable closure for currently open NRC item for VEGP Unit 2.
Pending resolution of the open item identified above, the NRC concludes that the GPC program for Electrical Raceways and Supports complies with NRC requirements and FSAR commitments. This conclusion is based on information currently available to the inspectars and reviewers.
Should subsequent contradictory information become available, it will be evaluated to determine what effect it may have on the above conclusion.
6.
Exit Interview The review scope and findings were summarized on May 26, 1988, with those persons indicated in ",ection 1 of this report.
The inspectors described the areas inspected ald discussed in detail the inspection findings listed below. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
Item Number Description and Reference 425/88-26-01 URI -
Incomplete verification of Thermal Separation Criteria, Safety Train Separation Criteria Application and Tray Cover Installation.
Dissenting comments were not received from the licensee.
7.
Acronyms and Abbreviations Design Criteria DC
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Deficiency Evaluation Report DER
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Field Change Request FCR
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Final Safety Analysis Report FSAR
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General Design Criteria GDC
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Georgia Power Company GPC
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Home Office Engineerina HOE
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Institute of Electrical and Electronic Engineers IEEE
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Nuclear Regulatory Commission NRC
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OIL
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Open Items Listing Project Field Office PFE
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Quality Assurance QA
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Quality Control QC
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Regulatory Guide RG
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Rigid Galvanized Steel RGS
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Readiness Review Team RRT
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Unresolved Item URI
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Vogtle Electric Generating Plant VEGP
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l A8tl I.
00suttiMtwl SAMPLE ytRiflCA110h SY het REGION !! thSPtCIORS Beference Come1teent Cemettmen1 Wer1fIcatten
.
_humber SeweCe Sectten Camdtment Sublect Decument featere Decument Reestks
_
isAs 8.3.1.4.3 Cable re. ting - elnlaum f ive f eet vert. three feet hers.
DC-1810 ISAR change pending to laplement Unit 2 separatten spreading, control Zahotatory test-data-supported Change and thet town reens separatton reJuctton.
F9 f1A4 C.3.1.4.3 Cable routing - minimum f ive f eet ver t.. three f eet hora.
l#C-1810 ISAS change pending te splemen t Unit 2 separatten general plant areas laboratory test-data-supported Change separation redactlens 1910 f$4R 3.F.8.3.1.2 Selsmic subsystem analysts -
N del response spectrum or DC-1810 mot in Unit 1 Module 19 t,ut was Category I cable trays equivalent static load method DC.2166 Ref erence he 1010 % Unit 1 DC-1000-C Module 18A.
1014 f5Aa 3.7.8.3.S Seismic subsystem analysis -
Peak accelerations value 0C 10004 leas Reference me. 1014 in Unit I acceleratten f acter for multiplied by 1.5 valess lower Module 21J.
equivalen* static load factor justifled analysts 1917 f5A4 3.7.8.3.7 Selsmic subsystem analysts -
Square rest of sum of squares DC-1810 Ws Reference 1013 in Unit I comb. of medal responses mathemat b I method for combining DC-2 3 f,6 Module 18A.
values DC-1000-C Sechtel 10P.4A 1018 85Aa 3.F.S.3.7 Selsmic subsystem analysts -
Regulatory Guide 1.92 requirements DC-1000-C Was Reference 1018 in Unit I comb. et msJat responses for square root of sum of squares N dule 18A.
2%0 85Aa 8.l.1 Ilectric power system -
10 Cf R 50 Appendnu A General High Energy Same requirement as Ref erence enstrennental and missile Design Criterlen he. 4 tlne Break ho. 4115 of Unit 1 Modwie 19.
design bases Program 3et in Module 11/19 commitment (HitSA)
ma t r i s.
290%
- 5Aa 17.3.2 QA program requirements Regulatory Guide 1.30 QA manual hot in N dule 11/19 lap. matrix.
Stellar to Ref. he. 686 in Ndule 6.
4688 15Ak 3.F.S.3.6 Selsmic subsystem analysts -
Square teet et sum of squares DC-1000.C 51stlar to Reference he. 1018 case. of earthquake cut *en mathematical method f or combining Specification requlrement.
-
camponents app. QG 4973 ISAR l.9.94.2.1 Welding visual acceptan(e Welding in accord with AWS Specification Ident1 fled as changed commitment unit 2 criterld 08.5 pfler to 12/2/85 app. VC in Module 17/19. Was in Unit I Change bdule 19.
S02%
ISAR 3.8.4.5 Weldlag of raceway supports Weldlag in accord with AWS DC-1000.C Identitled as changed comm!1tment unit 2 01-1 1975 or later editten in Ndule 17/19.
Change S062 isAs S.3.1.4.2 Cable derating and flit -
RG I.7S separation measurement Spec.
Generally covered by Reference i
separatten acaturement when is f rom upper most cable X3Aa01.ta No. 160 of Unit B Module 17.
cables are above tray sidewalls
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(LECIRICAL RACtkAYS AND SUPPOSIS -lhD(PihDtN1 SAMPti HALED 0hN Rt2L IS tocalica J tem Designattu
,
Irpe Mountlaq In_ge(tton Results Containment Cable tray 2A153AlQA3 6* a 24* punc hed bottom Bolted to suppor t 20 feet hofs, run Passed level A Support 15-004-65 Cantilever are Bolted to embedded strut Ar m Passed Suppert 15-004.67 Cantilever are Bolted to embedded strut Arm Passed Suppert 15-004-70 Cantilever are Welded ?o eat,edded plate Ar m Passed Contalement Cable tray 2AIS23tNS8 4* a 18* pun (hed bottom Bolted to support 30 f eet nors. run Passed tevel A Suppor t 15-005 73 Push bra (e vertical and are Welded. to structural steel Iree and are Passed Cent 41 ament Ce>,dult 2A153AEW214 1 1/2* RGS stub Conduit strap 3 feet long stub tevel A Suppor t (1)
--
Strap Bolted to structural steel Strap Passed Containment Conduit 28152381133 3* RGS Conduit straps total run Passed t evel 3 Supports (2)
-
Strap Bolted-str ut uelded to embed
$*.r aps Passed Suppe t ( 1 )
--
Strap Ot tiled in anchor Strap Passee Centrol Sidg.
Coedult 2Ct340RSI31 3* NGS Conduit stra p 20 f eet hor s. r un Passed level A Sug* ports (4)
--
Strap Bolted to embedded strut Straps Passed Centrol Sidg.
Conduit 2A1341RS005 2* RGS Condutt strap 14 f eet hor s, r un Passed tevel A Supports (3)
-
Strap Bolted to e tedded strut Straps Passed Control Sidg.
Cable tray 2Al34ltusG 6* a 24* punched bottom Bolted to support 18 f eet h >rs. f un Passed tevel A Support 15-154-21 Cantilever are Welded to embedded State Ar m Passed Support 15-154-22 Cantilever are Welded to cad >edded plate Ar m Passed Suppert 15-154-23 Cantilever are Welded to embedded plate Ar s.
Passed l
Austltary 5149 Cable tray 28t 445 t HCL 6* s 24* solid bottum Bolted
? teet ver t. r un and tee Passed I
tevel i Suppert 15-130-94 Cantilever are Bolted to embedded strut Ar m Paned
b
Aunillary kidg.
Conduit 2 1801-Y3 RIl I-l/4* Jacketed flealble mone total run hot passed d
tevel i AustI14ry $14g.
Suppor t het identified 10* square tubular stee t Not inspected f oreign tuwmodities Passed <
tevel I N-tra.se (also suppor ting l
tray 21't 445tWCt ver t1(al run]
Auaillary BlJo Cable tray 2Sl453tIOVA 6* a 6* punched bot tem Bolted 6 feet hors. run Passed level 3 tuppor t 15 453-247 Cantilever are Drilled in arahor s Ar m Passed m set 15 453-248 Cantilever are Welded to 1/5 uelded to Arm and iuppor t Passed embedded plate catension Aemillar y Sidg.
Conduit 2A14352El35 3* RGS Strap 50 f eet hor s. and vert.
Passed t eve l i Supports Straps (3)
Drilled in druhors Straps Passed l
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(continued)
locatten Itee
_tksignattoa Irpe Mounting Inspection
__ kej u l t s Aus. feed Water Consult
?CisCFR5802 4* kGS Strap and concrete encasement 6 feet vert. run Passed tevel I Suppect
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Strap Dr111ed in anchor Strap Passed t'4W Walee use. A Cable tray 2AI S38t BI Mot inspected Not laspe(ted hot inspec ted hot inspected Rats, tevel Suppor t 15-31 Iree Welded to embedded plate tree Passedd
_.
a.
Iransfermet designatten.
6.
Condelt teaching het SOL A regulating transf ormer --see report Subsettien 3.f(4)(b) and URI 4?$/88-26-01.
Pipe suppor ts V7-1204 161-4s004 and v?-I?)4-032-M6SS we:ded to elec trical cable tray suppor ts ar e covered by lleld Change Request (-ICR8-8504F.
c.
4.
7/32* spa (leg with pipe suppor t V2-120?-001.N-002 questlened. Selsatt separatton criteria in lable I of Appendt SC. Selsmic Criteria for VfGP, allows separallen as small as contac _
s
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....
Carolina Power and Light Company
cc w/ enc 1:
LP' W. Howe, Vice President Brunswick Nuclear Project (fd R. Dietz, Plant General Manager p P. Beatty, Jr., Vice Prasident Robinson Nuclear Project Department LM E. Morgan, Plant General Manager bec w/ enc 1:
/_Jat Resident Inspectors ORS. Technical Assistant Document Control Desk State of North Carolina State of South Carolina RII RII RI!
h [yss rtridge os y OV rrelli se, y ess 8,
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ENf' 05URE Document ALARA Committee Meeting Minutes (Corporate and Station)
ALARA Program Procedures (Corporate and Station)
Past and Present ALARA Initiatives (Cobalt Reduction, Chemical Decon, Fuel Integrity, Submicron Filtration, etc) (Corporate and Station)
ALARA Training Courses (lesson plans, etc, other than that provided in general employee training) (Corporate and Station)
ALARA Program Assessments / Audits (Corporate and Station)
RWP Implementation Procedures Post Outage Reports Outage and Annual Collective Dose Goals and Actual Exposures (by tasks)
Number of People Badged Annually Exposure Breakdown by Department and the Tasks Annually
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