ML20127E883
| ML20127E883 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/02/1985 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127E871 | List: |
| References | |
| GN-571, NUDOCS 8505200242 | |
| Download: ML20127E883 (9) | |
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.Georpa Power Cornpany l*j
. Route 2 Box 299A
. 11 i
j Waynesboro, Georgia 30830 g.
. Telephone 404 554 9%1 Ext. 3360
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- 404 724-8114. Ext. 3360
'g pfR 17. S u 0 3 Georgia Power
- D. o. Foster Vice President and Project General Manager '
the southern electrc system Vogtle Project :'
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- United States Nuclear Regulatory Commission Office of-Inspection and Enforcement FIIe: X78G10 Region li - Suite 2900 Log:.
GN-571 101 Marletta Street, Northwest Atlanta,' Georgia 30323
Reference:
50-424/84-36,' 50-425/84-36 Attention ~. Mr. Roger D.. Walker The : Georgia Power Company-wishes to submit the following informa-
- tion in response to the violations identified in USNRC Inspection report 50-424/84-36 and 50-425/84-36.
4 Violation 50-424, 425/84-36-01l
" Failure to Follow NDE Procedures"
-Severity Level V The violation identified two-specific discrepancies:
a.
Pullman Power Products ' (PPP) magnetic particle examinations were 1 conducted wIthout verifying magnetic f feld adequacy wIth a magnetic fleId indicator.as required by PPP procedure;IX-MT-5-AWS75.
b.
- PPP' ultrasonic -thickness examinations were conducted without performing -an ~ Intermediate thickness verification as required by PPP procedure X-20(B).
Georgia ' Power. Company of fers. the following response pursuant to the criteria of 10 CFR 2.201:
- 1. -.. Georgia Power Company acknowledges the violation as.identifled in
- thelRC Inspection report.
2.
In both' cases cited in:the NRC Inspection report, the violation is
. attributed uto inadequate trainingi of nondestructive examination personnel.in nthe requirements. of magnetic particle' and ultrasonic examination procedures.
3.
- Pullman Power Produc'ts-will evaluate the technique used by the MT
' inspector to determine-If test results were adversely impacted.
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- t 50-424/84-36, 50-425/84-36 Page 2 Pullman Power Products will also re-examine and evaluate a representative sample of previously performed ultrasonic examinations' concentrating on. the technicians involved in the specific discrepancies cited in the NRC. Inspection report.
The results of these evaluations will be used to establish a confi-dence level for the adequacy of previous nondestructive examina-tions.
Depending upon the evaluation
- results, additional
' corrective' ections, such as rework and additional re-examinations, may.be required.
4.
. To prevent f urther violations, all PPP nondestructive examination personnel have been retrained in magnetic particle and ultrasonic examination procedure requirements.
5.
Pullman Power Products expects to complete the evaluation of previous magneilc particle and ultrasonic evaluations by June 15, 1985. -Georgia Power Company will report the results of the evalua-tion to the NRC upon completion.
Violation 50-424, 425/84-36-02
" Lack of Procedure for UT Calibration Standards" Severity Level V The violation Identified a failure to provide for the identification and control of UT calibration blocks in PPP procedures.
As a result, ultrasonic thickness measurements were performed using uncontrolled and essentially unidentified calibration blocks.
Georgia Power Company offers the following response pursuant to_the criteria of 10 CFR 2.201:
1.
Georgia Power Company acknowledges the violation as identified in the NRC inspecifon report.
2.
The violation is attributed to the inadvertent omission of UT calibration block controls from appropriate PPP procedures.
3.
-The uncontrolled calibration block was removed from service while all other'PPP UT calibration blocks were examined. One additional unidentified block was found.
Samples from both calibration blocks were analyzed and found to be stainless steel.
Both blocks were also measured and found to be acceptable for UT instrument calibra-tion.
Identification numbers were applied to both blocks.
4.-
To prevent further violations, PPP procedure Xll-2, " Calibration of Tools, Measurement and Test Equipment", is being revised to reflect an improved UT calibration block control program which has already been developed and implemented.
5.
-Revisions to PPP procedure Xil-2 are expected to be completed and approved by June 7, 1985.
Full compliance with applicable regula-Ltory requirements will be' achieved at that time.
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'50-424/84-36,-50-425/84-36
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'Vfoiation 50-424, 425/84-36-03
" inadequate Procedures for installation and~lnspection,of Pipe Supports" -
-Severity Level IV The, viol'etion,Identifled ' two. specific cases of f allure to adequately reflect specification requirements in the PPP pipe support fabrication,.
installation,'and--inspection procedure.
_a. - The procedure did : not.. provide _or reference required manuf acturer Instructions for the Installation of spring-hangers Land _ pipe-
-clamps.
As a result, PPP pers_onnel Installed and inspected J pipe
. support components wIthout details of. the manuf acturer's ' instruc-tions.
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The procedure did not incl ude : specif ication ~ requirements - for the -
use_ of hardened ' washers in structural bolted connections for pipe support miseelIaneous steeI.
Georgia Power-. Company of fers the following response pursuant to the eriterIa of 10 CFR 2.201r-Georgia' Power Company acknowledges -the violation as identifled in
~1.
the MtC inspection report with one' exception. Paragraph 6.b of the-NRC inspection report states that two spring hangers (Identified as Y1-1204-010-H010 and VI-1204-012-H002 in. paragraph 6.c) ware not' properly Installed and inspected due,.in part, to the fact that the hangers were. not dead Ioaded._
lt should be noted that-the two hangers in question have not. received final loading adjustments and this. aspect of 'the hanger installations have not yet been inspected.
This is reflected in the installation process sheets for hangers - VI-1204-010-H010 and VI-1204-012-H002.
Final loading adjustments -and ~ Inspections of spring hangers wIll' be performed prfor to ' ~ system operation.
Georgla iower Company,
- however, acknowledges that the :Iack of specificity in 'PPP procedure IX-50 and the inadequate distribution of manuf acturer instructions;could m
Lhave-an adverse affect on quality.
2.
The violation was caused by a f ailure to ensure that installation and Inspection' personnel were provided with alI necessary Informa-tion to meet specification requirements.
3.
The following corrective actions are being/will be taken relative to the violation:
a.
A sampling program will be. established to determine the acceptability.of previously installed pipe supports requiring F
the use of manufacturer instructions. Pullman Power Products'
~ revised procedure -IX-50 (see SectIon 4 of this response).wIII be used in conducting the reinspections.
Depending upon-the
.results of the sample evaluation, additional corrective actions may be required.
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50-424/84-36,'50-425/84-36 Page 4 b.
A review of pipe support drawings is being conducted by engineering to identify Installed - pipe supports using struc-tural bolted connections.
Supports identified by engineering will be reinspected by PPP QC for bolting discrepancies.
All discrepancies will be Identified in Deviation Reports.
4.
The following actions will be taken to prevent f urther violations:
a.
Pul lman _- Power Products procedure IX-50 will be revised to include ' appropriate Installation and Inspection information from manufacturer instructions.
As an Interim measure until corrective actions can be completed, final inspections of pipe supports requiring manuf acturer instructions have been sus-pended.
Revisions to PPP procedure IX-50 will also contain some ciarifyIng informatton regarding final adjustment and Inspection of spring hangers.
b.
PulIman Power Products procedure IX-50 wIII be revised to include the specification requirements for pipe support structural bolted connections.
The words "unless noted otherwise" will be removed from the requirement cited in paragraph 5.d of the NRC Inspection report to reduce confusion and ensure consistency in pipe support installations.
5.
The following schedule has been established for completion of corrective actions:
a.
A completion date for the sample evaluation of Installed pipe supports requiring the use of manufacturer instructions cannot be predicted at this time. Georgia Power Company will provide a report to the NRC by June 15, 1985, giving either the results of the evaluation or'a schedule for.Its completion.
b.
The reinspection of pipe supports using structural bolted connections and the identification of any discrepancies in Deviation Reports is expected to be completed by May 25, 1985.
c.
All revisions to PPP procedure IX-50 wil l be completed by April 25, 1985.
Violation 50-424, 425/84-36-04
" Control and Installation of Rock Bolts"
' Severity Level IV The violation Identifies improperly Installed rock bolt concrete anchors In that hardened steel washers were not placed under the nuts.
Three procedural problems were cited in the causes of the violation:
a.
Pullman Power Products material receiving and storage proce-dures did not provide adequate controls for bolts, nuts, and washers af ter rock bolts were disassembled by PPP warehouse personnel.
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50-424/84-36, 50-425/84-36 Page 5 b.
Construction personnel Installed rock bolts without washers even through the manuf acturer's Instructions requiring the washers were included in the appropriate PPP procedure.
c.
Pullman Power Products QC Inspectors accepted rock bolt installations without the washers in violation of procedure requirements.
Georgia Power Company of fers the following response pursuant to the criteria of 10 CFR 2.201:
1.
Georgia Power Company acknowledges the violation as identifled in the NRC Inspection report with one point of clarification. Georgia Power Company has investigated the way rock bolts are supplied by the vendor and has found that the nuts and washers are usually shipped in containers separate from the rock bolts.
Therefore, disassembly of the rock bolts by receipt and warehouse personnel is not a basic cause for the violation.
2.
.The' violation is attributed to a lack of clarity In PPP procedure IX-1 requirements for the use of washers in rock bolt Installations and inadequate training of PPP construction and inspection per-sonnel in these requirements.
3.
Georgia Power Company and Pullman Power Products will conduct a reinspection of all rock bolt Installations.
Installations without washers will be identified in, Deviation Reports.
4.
To prevent further violations, PPP Procedure IX-1 has been revised to clarify the requirements for the installation of washers with rock bolts.
Pullman Power Products craf t and QC personnel have been trained in the provisions of - the revised procedure.
in addition, Georgia Power Company procedure GD-T-26, which provides instruction to contractors other than PPP in the Installation of rock bolts, will also be revised to clarify requirements for washers in rock bolt Installations.
5.'
All corrective actions are expected to be completed by June 1, 1985. FulI compilance wIth appiIcable regulatory requirements w11I be schleved at that time.
Violation 50-424, 425/84-36-05
' Design Control" Severity Level IV The violation identified four specific design control problems. Georgia-Power Company of fers the folIowing responses for each of the spectfIc discrepancies identifled in the NRC inspection report pursuant to the criteria of 10 CFR 2.201:
a.
Pipe supports were redesigned and renumbered on two piping Isometric drawings without the issuance of drawing change notices.
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50-424/84-36, 50-425/84-36 Page 6 1.
Georgia Power Company acknowledges the discrepancy as identi-fled in the NRC inspection report.
2.
The discrepancy occurred because controls were not in place at the time changes were made to the Isometrics to ensure a cross-check between the fabrication isometric and support tag numbers.
3.
To correct the discrepancy, drawing change notices were issued for the two drawings cited in the NRC Inspection report (1K3-1204-008-02 and 1K5-1301-001-01) to correct the Identi-fled errors.
in addition, f if ty-nine other Isometrics con-sisting of 452 supports, were randomly selected to review against associated calculations and support drawings for similar errors.
Seventeen of the 452 supports were found to contain discrepancies requiring reconcillation.
This indi-cates an error rate of about 3.7% which is considered small and is evidence that the Identified discrepancies are not generic.
An as-built reconciliation, including a walkdown verification, was already planned for safety-related piping systems prior to operation to ensure that Isometrics accurately reflect the engineering analysis and support design.
4.
To prevent further violations, cross checks have been established among Project Field Engineering, the Vogtle Structural Analysis Mobile Unit, and the Georgia Power Company Quantity Tracking System to ensure consistency between f abri-cation isometrics, support drawings, and calculations, and to ensure that changes are Identified in drawing change notices as required.
5.
All discrepancies identified in the random sample review will be corrected by April 12, 1985.
b.
Walkdowns were performed of piping Isometric IK3-1204-008-02 af ter supports H001 and H002 had been deleted.
No Interface with design engineering determined if replacement supports had been designed.
1.
Georgia Power Company acknowledges the discrepancy as identi-fled in the NRC inspection report.
2.
The discrepancy resulted due to a f ailure to establish ade-quate cross-checks between stress calculations and hanger drawings and between f abrication isometrics and hanger draw-Ings during installation. As a result, the stress calculation for Isometric 1K3-1204-008-02 f ailed to reflect the deletion of two supports and the replacement of them with two others.
3.
The subject stress calculation has been revised to reflect the correct supports.
The review of fifty-nine isometrics de-scribed in the response to item "a" and the resulting correc-tive actions are also applicable to this discrepancy.
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~50-424/84-36, 50-425/84-36 Page 7 4.
Actions to prevent recurrence described in the response to item "a" are also applicable to_ this item.
5.
All corrective actions relative to this discrepancy are expected to be completed by April 12, 1985.
c.
Design calculations for replacement supports on isometric 1K3-1204-009-02 were not available at the site or the A/E's office.
1.
Georgia Power Company acknowledges the violation as identified in the NRC Inspection report.
2.
A search of site and A/E home of fice f fles failed to produce the calculations.
It is presumed that the calculations were either lost during a transfer of calculations from the A/E-home office to the site or misfiled.
3.
Pipe supports Vl-1204-010-H010 and VI-1204-008-H017, which were cited in the NRC Inspection report, were regenerated by design engineering and new calculations were produced and placed on file. The original design of the supports was found to be adequate.
The sample review of Isometric drawings and associated calculations and support drawings described in item "a"
of this response did not identify any other cases of missing calculations.
4.
Since the time the missing calculations were produced, a formal data and document control section was established in the Project Field Engineering organization to properly control and maintain calculations performed on site and those trans-ferred to the site from the A/E home of fice.
This action should effectively prevent further violations of this type.
I 5.
All corrective actions relative to this discrepancy are complete.
d.
Design errors were found which included the use of the wrong thermal expansion coef ficients, the wrong modulus of elasticity, and errors in calculation of seismic acceleration.
1.
Georgia Power Company acknowledges the violation as identifled in the NRC Inspection report.
l 2.
The discrepancies identifled in the NRC Inspection are attributed to human error and failure to obtain formal approval for the use of material coef ficients from later ASME code editions.
l In the case of the use of moduli of elasticity based on carbon steel for stress analyses of stainless steel materials, the proper modull of elasticity were actually used in the analyses, but the incorrect value was transcribed in the analyses documentation.
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.50-424/84-36, 50-425/84 -
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Relative to seismic acceleration calculations,.the applicable response spectra was actually -used as input to the computer program; however,.the Hengineer erroneously -tabulated the-
' values obtained' in the computer analysis on the design ~calcu-lat!on sheet rather than marking the section "not applicable".
.This gave tho' impresston that the square-root-of-the-sum-of-the-squares method was used when, in fact, it was not.
3 cThe values for coefficient of thermal expansion and modulus of elasticity in Section til of the ASME Code, 1980 Edition, are the :same - as 'those in the 1977 Edition, Summer 1979 Addenda.
~These values are more realistic than those-In 'the 1974 Editions through the Summer 1975 Addenda of the Code.
3.
Use of the later ASE Code values for the coefficient of thermal L expansion and the modulus of elasticity was formally
. approved by the Vogtle Project on November 15, 1984.
e Correctlons to applicable analysis documentation rolatIve to.
the previously mentioned errors is in progresss.
4.
To prevent f urther violations, a desk top instruction was prepared for computer analysis engineers to ensure they are -
aware of applicable code and standard changes.
In additlon, checks will be _ performed on ' calculations as revisions occur to ensure that analyses are documented in accordance with project procedures.
5.
All corrective actions relative to ~this discrepancy are expected to be completed by April 12, 1985.
These responses contain no proprietary information and may be placed In'the NRC Public Document Room.
Yours truly,
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D. 0. Foste REF/DOF/tdm i
a
50-424/84-36,50-42'5/84-36 Page 9
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U. S. Nuclear. Regulatory Commission
. Document Control Desk
~ Washington, D. ' O. -20555
- R.-J. Kelly R. E. Conway
..G. F. Hood.
J. T. Beckham
.R. A. Thomas D. E. Dutton-
-W. F. Sanders (NRC).
-R. H. Pinson
.B. M. Guthrie.
E. D.. Groover R. W. McManus J. A. Bailey.
O. Batum-H. H.' Gregory W. T. Nickerson
-D.:R..Altman-
~D. L. Kinnsch (BPC)
J.
L'. Vota (W)
L. T. Gucwa-
.C. E. BelfIower F. B. Marsh (BPC)
.G. Bockhold P. D. Rice C. S. McCal1-(OPC)
E. L.'Blake,.Jr. (Shaw, et.'al.)
J.
E.' Joiner.(Troutman, et. al.)
-D. C. Teper (GANE)
L. Fowler-(LEAF)
T.. Johnson (ECPG)
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