ML20140B094
| ML20140B094 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/07/1986 |
| From: | Belisle G, Jackson L, Moorman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20140B051 | List: |
| References | |
| 50-424-85-62, NUDOCS 8603210324 | |
| Download: ML20140B094 (7) | |
See also: IR 05000424/1985062
Text
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UNITED STATES
NUCLEAR REGULATORY COMMisslON
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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Report No.: 50-424/85-62
Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket No.: 50-424
License No.: CPPR-108
Facility Name: Vogtle Unit 1
Inspection Conducted: January 6-10, 1986
Inspectors:
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L. H. Jackson
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Datie Signed
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J. H. Modrman, III~ '
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Date Signed
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Approved by:
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G. A. BeUsle, Acting Section Chief
Dete' Signed
Division of Reactor Safety
SUMMARY
Scope:
This special, unannounced inspection involved 70 inspector-hours on site
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in the areas of Readiness Review Appendix E, Material Control.
Results:
One violation was identified - Failure to provide end caps to protect
weld end preparations for values, fittings, pipes, and tubing, and failure to
store piping subassemblies in accordance with procedures.
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
D. Adams, Warehouse. Supervisor
- E. Groover, Quality Assurance Site Manager (Construction)
D. McAffee, Quality Control Supervisor, Receivirg Inspection
R. McManus, Assistant Project Construction Manager II
Other licensee employees contacted included . engineers, technicians, and
office personnel.
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Other Organizations
A. Nakashima, Bechtel Power Corporation, Readiness Review, Discipline
Manager (Appendices)
- W. Ramsey, Southern Company Services (SCS), Readiness Review Project
Manager
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on January. 10, 1986, with
those persons indicated in paragraph 1 above.. The inspector described the
areas inspected and discussed sin detail the inspection findings.
No
dissenting comments were received.from the licensee.
Violation, Failure to provide end caps to protect weld end preparations
for valves, fittings, piping, and tubing, paragraph 5.a. and failure to
store piping subassemblies in accordance with procedures, paragraph 5.b.
Inspector Followup Item, The ' scope of Appendix E 'is -inconsistent with
the contents, paragraph 6.a.
Inspector Followup Item, Audit matrix: and ' finding matrix of' Appendix E
fail to include all violations and findings germane to materials
control, paragraph 6.b.
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Inspector Followup Item, W. C. Ramsey letter to D. 0 Foster addresses .
Structural Steel, paragraph 6.c.
Inspector Followup Item, Readiness -Review Finding El_ is classified as '
Level III which-is inappropriate, paragraph 6.d.
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Inspector Followup Item, Storage requirements for electrical equipment
conflicts with ANSI standards, paragraph 6.e.
Inspector Followup Item, Weatherproof and outside storage are specified
for like materials, paragraph 6.f.
Inspector Followup Item, Conflict in number of audits, paragraph 6.g.
Inspector Followup Item, INP0 findings are inconsistent, paragraph 6.h.
Inspector Followup Item, Summary of Section E5, Audits, states that 120
findings were identified, paragraph 6.i.
Inspector Followup Item, Equipment Maintenance Storage List (EMSL) of
Safety Injection Pumps and Motors contain errors, paragraph 6.J.
Inspector Followup Item, Improper classification of violations for
records, paragraph 6.k.
Inspector Followup Item, Regulatory Guide 1.28 not included,
paragraph 6.1.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved Items were not identified during this inspection.
5.
Readiness Review Implementation
The inspectors toured warehouses, laydown yards, shop areas, and th$
a.
powerhouse te verify material control adequacy as an approach to the
evaluation of this appendix.
Attention was given to the adequacy of
housekeeping, materials identification, rodent control, levels of
storage,
access. control, environmental
control,
sources of
contamination, electrical heater connections for motors, and fire
protection.
During this tour of the-warehouses, laydown areas and the powerhouse,
it was noted that piping subasse.nblies and-valves, piping, fittings,
and tubing were not being stored in accordance with ANSI standards in
that ANSI N45.2.2-1972, Packaging,. Shipping, Receiving, Storage, and
Handling of -Items for Nuclear Power Plants, paragraph 6.4.2 requires
that caps and plugs be used to seal openings in items having. sensitive
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internal surfaces and to protect threads and weld end preparations.
The inspectors observed that many end caps on valves had fallen off
while in storage and had not been replaced, that stainless steel pipe
and tubing stored in the warehouse yard were not capped in accordance
with the accepted Quality Assurance (QA) Program, and that weld end
preparations on flanges and fittings stored inside warehouses were not
consistently protected to prevent damage.
This failure to protect
valves, fittings, flanges, pipe, and tubing is identified as the first
example of Violation 50-424/85-62-01.
Similar violations were brought
to your attention in our letters dated 5/13/81, 7/12/82, and an
unresolved item by letter dated 10/17/84.
b.
The inspectors conducted a general inspection of the piping subassembly
yard and noted that many of these assemblies were not stored on
cribbing.
This failure to store subassemblies in accordance with ANSI
N45.2.2-1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.2-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., paragraph 6.1.2(4) is identified as the second example
of Violation 50-424/85-62-01.
A similar violation was brought to your
attention in our letter dated 5/13/81.
6.
Evaluation
a.
The scope of Appendix E states, "The scope addresses permanent plant
materials, parts and equipment at VEGP (Vogtle Electric Generating
Plant) from receipt through issue to contractors: for installation and
storage / maintenance to transfer to Georgia Power Company (GPC) Nuclear
Operations."
This scoping statement appears inconsistent with the text of Appendix E
in that many areas of material control are not discussed. A specific
example is that welding filler material does not appear in this
appendix.
Also, it appears that Appendix E does not address all
material control requirements after issue from warehouse storage.
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These areas appear to be evaluated in individual modules.
Until this
scoping statement is clarified, this is identified as Inspector
Followup Item 424/85-62-02.
b.
The audit mab-ix and finding matrix of Appendix E fails to include all
violations and audit findings germane to materials control which have
been identified at VEGP.
The following are examples of perceived
problems:
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Violation 424/79-07-02, Electrical preventive maintenance and
rotation of Spray Pump Motors and Safety Injection Pump Motors.
Violation 424/81-07-02, No record of EMSL inspections' of Reactor
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Pressure Vessel and Boric Acid Transfer Pump for 9/80 and 3/79.
Violation 424/82-16-01, Failure to perform periodic maintenance of
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equipment within specified maintenance period (this is listed
underinspection).
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Violation 424/82-19-01, Protection of valves.
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Violation 424/82-29-01, Failure to control the storage and
preservation of electrical equipment.
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Violation 424/84-11-01, Failure to follow procedure for protection
of electrical equipment in control room.
Until the audit matrix and finding matrix are reviewed and an
evaluation made to include /not include these violations, this is
identified as Inspector Followup Item 424/85-62-03.
c.
The transmittal letter to Mr. D. O. Foster from Mr. W. C. Ramsey dated
October 30, 1985, states in part that problems experienced by other
near term operating license utilities regarding structural steel are
considered in this appendix.
The inspector's review of this appendix
identified that structural steel is not included in this appendix.
Until this apparent wording error can be clarified, this is identified
as Inspector Followup Item 424/85-62-04.
d.
Readiness Review Finding El identified four equipment / material items
out of a sample of 34 for which there was no documented evidence to
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show that GPC Construction Engineering had evaluated them to determine
whether the items were to be entered into the EMSL or whether these
items were to be exempted from the EMSL.
This finding was classified
as a Level III finding by the Readiness Review Team.
This finding
appears to be a Level II finding since Level II is defined' as a
violation of licensing commitments or engineering requirements with no
safety concerns.
Until this apparent misclassification can be
corrected, this is identified as Inspector Followup Item 424/85-62-05.
e.
ANSI N45.2.2-1972, Packaging, Shipping, Receiving. . Storage, and
Handling of Items for Nuclear Power Plants, Section 2.7.2, states that
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instrumentation, electrical equipment, and batteries, shall be stored
in Level B storage areas.
Appendix E, Section E4.3.1, General Storage
Requirements states that instrumentation, electrical equipment, and
batteries will be stored in Level C storages. The inspectors verified
that the proper level of storage was actually maintained for the
equipment onsite.
However, until storage procedures are changed to
reflect the correct requirements, this will be identified as Inspector
Followup Item 424/85-62-06.
f.
Appendix E, Section E4.3.1, General Storage Requirements, states that
conduit and cable trays are to be stored in both Level C and Level D
Storage.
Until conflict in storage requirements is resolved, this is
identifed as Inspector Followup Item 424/85-62-07.
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g.
Appendix E, Section E5.1, states the following:
The Georgia Power Company (GPC) conducts regu;arly scheduled
audits to verify compliance with project commitments.
Audit
findings and recommended corrective measures are reported to the
management of the audited organization.
The audit results are
also reported to GPC management and the GPC Quality Assurance (QA)
organization tracks the acceptability and timeliness of the
response.
Georgia Power Company has conducted 55 audits relating to material
control.
The audits, summary descriptions of the findings, and
the categorization of each finding are presented in the audit and
finding matrixes at the end of this section.
The 38 GPC audits
resulted in the identitication of 97 findings during the period
from 1977 through the first quarter of 1985.
Categon
Total Findings
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Receiving
4
Storage
78
Maintenance
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Documentation
11
Total
100
There are apparent conflicts in this section in that one statement
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says that GPC has conducted 55 audits and another statement says
that they have conducted 38 audits.
This section also states that
there were 97 findings; however, the total findings. column sums to
100.
Until this apparent discrepancy in number of audits
conducted and total findings can be resolved, this is identified
as Inspector Followup Item 85-62-08.
h.
Appendix E, Section E5.3, INP0 Evaluations, has a conflict similar to
the one in (g) above in that the text of the section states that five
findings were identified while the Total Findings column sums to only
four. Until this apparent conflict in the number of total findings can
be resolved, this is identified as Inspector Followup Item
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424/85-62-09.
1.
Appendix E, Section E5.6, Summary, states that there were 120 total
audit findings.
However, when the Total Findings columns from
Sections E5.1 to E5.5 are summed, the result is 139.
Until this
apparent conflict in the number of total findings can be resolved, this
is identified as Inspector Followup Item 424/85-62-10.
j.
The inspectors selected the EMSL cards for Safety Injection Pump Motors
to evaluate the preventive maintenance performed on this equipment.
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These logs contain discrepancies which should have been identified and
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evaluated by the Readiness Review Team. A specific example is that the
EMSL card for the "B" Motor, tag number 1-1204-P6-004-M01, has been
listed as train "A"
since 10-31-83.
Also, there were questions
concerning documented records for preventive maintenance from early
1979 until 10-28-81.
However, during subsequent inspections, GPC was
able to produce records documenting maintenance on these pumps during
this period.
Until the mislabeling is clarified for the "A" and "B"
pumps and the records reviewed to assure preventive maintenance was
performed correctly, this is identified as Inspector Followup Item
424/85-62-11.
The inspectors noted that the audit matrix contains listings of
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violations concerning records which were perceived to be applicable to
Appendix D rather than E.
A specific example is that violations
424/79-13-03 and 424/83-13-03 appear to be more applicable to Records
than to Materials Control.
Until this apparent misclassification can
be clarified, this is identified as Inspector Followup Item
424/85-62-12.
Paragraph E3.1, Connitments, does not list Regulatory Guide (RG) 1.28,
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Quality Assurance Program Requirements, as being applicable to the VEGP
Materials Control Program.
It appears that RG 1.28 is applicable to
this program.
Until an evaluation can be performed by the licensee to
determine RG 1.28 applicability, this is identified as Inspector
Followup Item 424/85-62-13.
The inspectors are concerned that the violations and audit findings have
been listed in modules where they are riot applicable.
This would distort
the evaluation and lead to an inadequate evaluation of the overall program
effectiveness.
The RRT did not access the overall program effectiveness
from 1977 through 1985. Therefore, the inspectors were unable to adequately
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evaluate the acceptability of Appendix E.
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