ML20137K748
| ML20137K748 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/30/1985 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | NRC |
| Shared Package | |
| ML20136E513 | List: |
| References | |
| FOIA-84-663 NUDOCS 8509120252 | |
| Download: ML20137K748 (5) | |
Text
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o m;)o, UNITED STATES f
y 7,g NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555 f
g
,j January 30, 1985
+....
Docket Nos: 50-424 and 50-425 i
l l-MEMORANDUM FOR: See attached distribution list
.j FROM:
Elinor Adensam, Chief Licensing Branch No. 4 f
Division of Licensing
SUBJECT:
V0GTLE-RESPONSE TO DES COMMENTS FOR INCLUSION IN FES q
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Enclosed are copies of all coninents received to date on the Vogtle DES with the appropriate responding branch or individual designated. The reviewers have already been provided with the enclosure and were asked to inform the oro.fect manager, Melanie Miller, of any incorrect and incomplete response assignments by noon February 1,1985.
The FES is scheduled to be issued March 26, 1985.
In order to accomodate this schedule, the coment responses must be to DL by February 25, 1985.
f We are expecting some additional comments from the state of Georgia. You should receive these through normal distribution. Also, the PM will be j
following up with response assignments ;for these coments.
Y M
Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing i
Enclosure:
1 As stated
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8509120252 050830
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t plant which ;
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becoming part of 2 Aquifer.-
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The Georgia F Qb as' demonstrated b)
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The DES fails
...... v i e v i e = n 6 uy the inadequacy of the quality assurance program at Plant Yogtle.
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q The success of a quality assurance program is ultimately tied to the generation of adequate confidence concerning the correct functioning of critical nuclear power
'i i Vs olant systems anc components.
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Repeated violations of NRC regulations by Applicant in the construction methods g
' applied to pipe-fitting, welds and other areas must be interpreted as undermining i
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t t confidence in the capability of coolant and containment systems to perform their essential tasks.
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Although' potential deficiencies involving welds in co'ntainment liner f
- netrations had been raised as an issue at least as early as April 29, 1981 (I & E file fX78G03-M18), problems involving the appropriate inspection of welds have occurred at least as recently a.s September 1983.
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Violation notification has'been' issued in several instances.related to
. implementing the req'uired test procedure's. As indicated in IR 501424/83-15 Appendix A, the aplicant's construction sheet for examination of reactor coolant pressure boundary welds did not specify the penetrant examination test required by NRC.
Such j
a failure, not simply'in the execution of a prescribed test', but the omission of the
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. ', test from the required procedure, certainly reduces the confidence in the correct j
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' functioning of a vital reactor safety system.
Failure to assure that non-destructive testing is conducted consistent with j
applicable codes led to another violation as reported in IR-50-424 and 50-425.
In this instance grit-blasting of the closure head weld cladding of Plant Vogtle Unit i (IE X7B610) was pe~rformed after liquid penetrant examination of the component. This
- represented not only a departure from the standard procedure of performing the
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,l~ degrading a critical steam system component after its final installation and examination on the component in its finished condition but an unintended method of l
i inspection. This is much more than a flaw in an isolated procedure; it is a basic.
- (!;. failure in established quality assurance methodology.
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Any adequate quality assurance program must take into account a broad. range of j " planned and systematic actions necessary" to establish confidence in the system in
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estion.,~Any'q'uality assurance program predicated exI:lusively on"the t
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..plementation of dictated procedures without regard to the exercise of critical ludgement and standards' of professional practica must be considered woefully I
inadequate.
In an examination of welding activities involving steel structures and supports in both Units 1 and 2 of Plant Vogtle, the applicant was cited for failure to include the heat-affected zone (HAZ) of the weld in acceptance radiographs (IR 52 50-424 Appendix' A Report Details).
In response to the notice of violation, the applicant defended its procedure by replying that the Code "gives no requirement for including the heat-affected zone in the area of interest" (X7B610).
This response,
'.t which erroneously equates methods of quality assurance with simple compliance to I written procedures', was so unacceptable to the NRC that it was directly criticized i
by Richard C. Lewis' even though the violation itself had been withdrawn.
In his
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" Interpretations of the code by ' Code Experts' make your response appear to set l
aside engineeri.ng reason when you consider that, based on failure analysis t
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L experience, the technical world realte.s that the heat affected zone of a weld l<
l 1s the most ' critical area of the welaxnt."
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In a related matter on November 18, 1982, welding on sections.of the
.,; containment dome of Unit 2 was conducted during a "very light misty rain." The l
r welding and site QA supervisors felt that the conditions were suitable for welding j
since the surfaces of the pieces. involved were not completely covered with moisture (425/82-29-02).
The inspector, more concerned with the quaTity of the weld than j
ith the "3eneral Welding Procedure Specification for Shielded Metal Arce
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r( ".scesses," prevailed upon the two to stop the work for the day.
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The applicant's disposition to prefer restrictive implementation of prescribed P
procedures to the more circumspect methods of professional practice does not contribute to. confidence in the proper functioning of a completed and operating
'lant Vogtle.
In addition to these procedural aspects of quality assurance, there are other questions involving the applicant's. " controlling the quality of the... component or
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system to predetennined requirements." In the~ case of quality control the repeated djscovery of inadequacies and. defects in the performance of an essential safety 1
subsystem would generate a cause for concern.
Furthermore, at some point in time, good quality control' practice mandates the abandonment of a suspect manufactured
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article in favor of a more reliable' alternative.
g The number of past and continuing. failures of the Georgia Power /Bechtel QA/QC j
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program represents a pattern which indicates an undue risk to the health and sahty of the public. Violations involving activities at times resulted from failure to provide documented procedures.
(For example, Report No. 50-424, 50-425/83-04 regar&.g concrete QC problems)
The severity of Quality Assurance performance at Plant Vogtle forced a meeting conducted 22 August 1983 at Georgia Power headquarters on the subject of Subcontractor Quality Assurance Perfonnance Allegation by Pullman Power Products quality control personnel about pipe support installation and piping installation Aafs well as job intimidation of quality control workers. Allegations had been made by a Walsh Cc:npany boilermaker th Twenty-three concerns which dealt [at improper welding and work practice had occurred.
with twelve separate items were discussed.
Defects were found during the reinspection of Pullman Power Products manufactured piping spool pieces.
(Letter from Ames P. O'Reilly to Georgia Power, 28' September
'983,
Subject:
' ' Summary of Meeting--Docket Nos. 50-424 and 50-425,- Vogtle 1 and 2).
Countless other specific problems with Quality Assurance, outlined in filings i;
with the Atomic Safety & Licensing Board in the operating license proceeding for this facility and described in numerous documents, also exist. These increase the dahger to the public and increase the potential for significant damage to 'the environment.
Yet the DES fails to address these concerns.
ma ur.a also falls to consider the potenIia'lWiEnNnfa1' impacts ~of i.;4
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faYhwe,of certain equipment at Plant Vogtle to withstand the conditions of an
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The concept of. environmental qualification, i.e. that safety sys.tems must be' able_to survive and pirrform their functions under accident conditions, is fundamental to NRC regulation,of nuclear power reactors. Safetf'is the "first, last 4
and permanent consideration" 'an&can lead to the shutdower'6f noncomplying plants.
Power Reactor Development
. v.' International Urtion oyf ElectYical Radio and t;[)
Machine Workers, 367 U.S. gCo396, 4'07 (1961)...f i;{,
s Applicant has not demonstrated that its prese;1t safety systems testing. methods, i VEGP FSAR Table 3.11.B.1-1, Figures 3.11.B.1-1, 3.11.B.2, are adequate to ensure WGetive operation under emergency ' conditions.. For example, in investigating accelerated aging of materials,.Sandia Laboratory has found that many materials
' experience greater damage from lower as opposed to raised dose rates when the total L ntegrated dosef s'the same.
Proceeding International Meeting on Li'cht Water i
' ' h Jeactor Sevue Accident Evaluation, August 19d3, T5-3.1; IndustWaTTesearch and
- development, June 1982 at 55-56.
Particularly sensitive are polymers which are
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIOS)
ACCESSION NBR:841211038o DUC.0 ATE: 84/12/04 NOTARIZED: NO DOCKET s c FACIL 50-424 Vogtle Electric Generatlng Plant, Georgia Power Co.
05000u2n 50-425 Vogtle Electric Generating Plant, Georgia Power Co.
05000a25 AUTH.NAME AUTHOR AFFILIATION g,
FOSTER,0.0.
Georgia Power Co.
RECIP.NAME RECIPIENT AFFILIATION 0y
'*i 9
EISENHUT,0.G.
Division of Licensing
SUBJECT:
Acvises of findings during QA audit designed t'o verify qualificat'lons of insp, exam t. testing personnel,per Generig n./g g*y Ltr 81-01,nine inspectors certificed w/o appropriate educ.
Inspector reauIred to obtain GED diploma by 850101.
COPIES RECEIVED:LTR.l. ENCL O SIZE ___ b _ __
DISTRIBUTION CODE: B0010 l
TITLE: Licensing Submittal: PSAR/FSAR Amdts & Related Correspondence l
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE /NAME LTTR ENCL ID CODE /NAME LTTR ENCL NRR/DL/ADL 1
o NRR LB4 LA 1
(
MILLER,M 01 1
INTERNAL: ACRS 41 e
d ADM/LFMB 1
(
ELD /HDS3 1
IE FILE 1
1 IE/DEPER/EPB 3o 1
IE/DEPER/IRB 35 1
1 g u oGASIF7 D M 1 1
NRR ROE,M.L 1
1 nnn/Ut/AEA6 1
i NRR/DE/CEB 11 1
1 NRR/DE/EHEB 1
NRR/DE/EQB 13 2
i NRR/DE/GB 28 2
NRR/DE/MEB 18 i
NRR/DE/MTEB 17 1
L NRR/DE/SAB 24 1
NRR/DE/SGEB 25 1
l NRR/DHFS/HFEB40 1
NRR/DHFS/LQB 32 1
l NRR/DHFS/PSRB 1
NRR/DL/SSPB 1
)
NRp/DSI/AEB 26 i
L NRR/DSI/ASB 1
1 NRR/DSI/CPB 10 1
L NRR/DSI/CSB 09 1
1 NRp/DSI/ICSB 16 1
1 NRR/DSI/METB 12 1
1 NRR/DSI/PSB 19 1
1 NRR/DSI/ RAD 22 1
1 NRR/DSI/RSB 23 1
L REG FILE 04 1
1 RGN2 3
L RM/DDAMI/MIB 1
3 EXTERNAL: BNL(AMDTS ONLY) 1 L
DMB/ DSS (AMDTS) 1 1
1 FEMA-REP DIV 39 1
LPOR 03 1
1 NRC PDR 02 1
NSIC 05 1
1 NTIS 1
PNL GRUEL,R 1
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- ac,if y
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n Q 0
gaff i
j TOTAL NUMBER OF COPIES HEGUIRED: LTTR 54 ENCL
.