ML20197A240
| ML20197A240 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/15/2020 |
| From: | Nicole Coovert NRC/RGN-II/DCI |
| To: | Yox M Southern Nuclear Operating Co |
| References | |
| NCP-2019-002 IR 2019010 | |
| Download: ML20197A240 (15) | |
Text
July 15, 2020 Mr. Michael Yox Regulatory Affairs Director Southern Nuclear Operating Company 7825 River Road, Bldg. 302, Vogtle 3&4 Waynesboro, GA 30830
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 - NRC INSPECTION REPORT 05200025/2019010
Dear Mr. Yox:
On March 27, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Vogtle Electric Generating Plant, Unit 3. The enclosed inspection report documents the inspection results, which the NRC staff discussed on May 21, 2020, with you and other licensee and contractor staff members.
The inspection examined a sample of construction activities conducted under your Combined License as it relates to safety and compliance with the Commissions rules and regulations and with the conditions of these documents. The NRC staff reviewed selected procedures and records, observed activities, and interviewed personnel.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Nicole Coovert Branch Chief Construction Inspection Branch 1 Docket No.: 5200025 License No: NPF-91
Enclosure:
NRC Inspection Report (IR) 05200025/2019010 w/attachment: Supplemental Information
M. Yox 2 cc w/ encls:
Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 Brian H. Whitley Regulatory Affairs Director Anne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, BIN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael Yox County Commissioner Site Regulatory Affairs Director Office of the County Commissioner Vogtle Units 3 & 4 Burke County Commission 7825 River Road, Building 302 (ESB)
Waynesboro, GA 30830 Bin 6031 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334
ML20197A240 Package: ML20197A246 NCP 2019-002: ML20197A032 OFFICE RII: DCO NRR NRR RII: DCO RII: DCO NAME APonko KKavanagh VHall MBailey NCoovert Nonconcur Via email Via email DATE 7/13/2020 7/5/2020 7/7/2020 7/13/2020 7/15/2020 Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) bhwhitley@southernco.com (Brian Whitley)
Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dlfulton@southernco.com (Dale Fulton) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David)
G2NDRMDC@southernco.com (SNC Document Control)
George.Taylor@opc.com (George Taylor) harperzs@westinghouse.com (Zachary S. Harper) james1.beard@ge.com (James Beard)
JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)
John.Bozga@nrc.gov (John Bozga)
Joseph_Hegner@dom.com (Joseph Hegner) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)
KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)
Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)
MKWASHIN@southernco.com (MKWashington) mphumphr@southernco.com (Mark Humphrey)
MSF@nei.org (Marvin Fertel) nirsnet@nirs.org (Michael Mariotte)
Nuclaw@mindspring.com (Robert Temple)
Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) ppsena@southernco.com (Peter Sena,III) r.joshi15@comcast.net (Ravi Joshi) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sjackson@meagpower.org (Steven Jackson) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)
TomClements329@cs.com (Tom Clements)
2 Vanessa.quinn@dhs.gov (Vanessa Quinn) wayne.marquino@gmail.com (Wayne Marquino)
William.Birge@hq.doe.gov (William Birge)
X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)
X2hagge@southern.com (Neil Haggerty)
X2wwill@southernco.com (Daniel Williamson)
U.S. NUCLEAR REGULATORY COMMISSION Region II Docket Number: 5200025 License Number: NPF-91 Report Number: 05200025/2019010 Licensee: Southern Nuclear Operating Company, Inc.
Facility: Vogtle Unit 3 Combined License Location: Waynesboro, GA Inspection Dates: March 25, 2019 through March 27, 2019 Inspectors: A. Ponko, Senior Construction Inspector, DCO S. Smith, Senior Construction Inspector, DCO Approved by: Nicole Coovert Branch Chief Construction Inspection Branch 1
2
SUMMARY
OF FINDINGS Inspection Report (IR) 05200025/2019010; 03/25/2019 through 03/27/2019; Vogtle Unit 3 Combined License inspection report.
This report covers inspection findings by NRC staff of Unresolved Item (URI) 05200025/2018-01, Welded Reinforcing Bar Splices. The U.S. Nuclear Regulatory Commissions program for overseeing the construction of commercial nuclear power reactors is described in Inspection Manual Chapter (IMC) 2506, Construction Reactor Oversight Process General Guidance and Basis Document.
A. NRC-Identified and Self Revealed Findings None B. Licensee-Identified Violations None
3 REPORT DETAILS Summary of Plant Construction Status See the routine integrated inspection report 05200025(26)/2020001 (ML20128J831) for the summary of plant construction status from January 1, 2020 through March 31, 2020.
- 1. CONSTRUCTION REACTOR SAFETY Cornerstones: Design/Engineering, Procurement/Fabrication, Construction/Installation, Inspection/Testing IMC 2504, Construction Inspection Program - Inspection of Construction and Operational Programs
- 92701 - Followup
- 92701-02.01 - Unresolved Item Followup
- a. Inspection Scope During the week of January 22, 2018, inspectors identified that the licensee was not performing destructive tests and nondestructive examination of welded reinforcing joints for the welded reinforcing steel hoops used in the north wall of the Unit 3 main steam east compartment at column line 11, between elevations 117-6 and 153-0.
The additional tests were noted in American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code (BPVC),Section III, Division 2, as referenced in Section 7.13, Welded Reinforcing Bar Splices, of ASME NQA-1-1994 Subpart 2.5, which the licensee committed to, without exception, in their Nuclear Development Quality Assurance Manual (NDQAM). The reinforcing hoops at this location were fabricated with direct butt joints using complete joint penetration groove welds. This issue was documented as Unresolved Item (URI) 05200025/2018-01, Welded Reinforcing Bar Splices, in NRC inspection report 05200025/2018001 (ML18134A348). The URI disposition was pending the inspectors review and evaluation of the licensees corrective actions, if applicable, and their position paper on the applicability of ASME NQA-1-1994, Subpart 2.5, Paragraph 7.13.
4 The licensee generated condition report (CR) 10465176 to document this issue but concluded that the ASME BPVC.III.2 reference in Section 7.13 of NQA-1-1994, Subpart 2.5, identifying additional testing for Welded Reinforcing Bar Splices beyond American Concrete Institute (ACI) 349 required testing, was not appropriate to
[VEGP 3/4] and was assessed as such in accordance with the NDQAM. The NRC staff reviewed the licensees evaluation on the applicability of ASME NQA-1-1994, Subpart 2.5, Paragraph 7.13 and engaged in discussions with technical staff from the Office of New Reactors (NRO) (now merged with the Office of Nuclear Reactor Regulation) to verify the licensees commitments for required inspection and testing activities for welded reinforcing bar splices.
Minor Violation of 10 CFR Part 50 Appendix B, Criterion II, Quality Assurance Program Following additional inspection conducted on March 25 - 27, 2019, and based on additional discussion and review, the NRC staff determined the licensees failure to meet a commitment in their quality assurance program, as written, was a performance deficiency related to a construction finding. Specifically, Southern Nuclear Company (SNC) committed to comply with ASME NQA-1-1994, Subpart 2.5, in its NDQAM, without exception, however, additional testing was not performed in accordance with Section 7.13 of Subpart 2.5.
Step 4.1 of Part II, Section 10, Inspection of the SNC NDQAM, Version 17.0, states, in part, that SNC commits to compliance with the requirements of ASME NQA 1994, Part II, Subparts 2.5 and 2.8 for establishing appropriate inspection requirements. Under this commitment, the inspectors noted that no exceptions were cited. ASME NQA-1-1994, Part II, Subpart 2.5, Section 7.13 states, in part, that welded reinforcing bar splices shall be subject to the requirements of para. 8.5, except that provisions of the ASME Boiler and Pressure Vessel Code (BPVC),Section III, Division 2 (ACI Standard 359) shall also apply.
The ASME Code,Section III.2 (2001 Edition with 2003 Addenda), Article XI-1560, Continuing Joint Performance Tests, requires destructive testing on a sampling basis of welded reinforcement splices to ensure the joints met tensile requirements. Additionally, the ASME Code,Section III.2, Article XI-1600, Examination of Welded Joints of Reinforcing Bar, requires radiographic testing examination of joint samples to verify weld quality.
The performance deficiency was evaluated against the more-than-minor evaluation questions in Appendix E, Examples of Minor Construction Issues, of Inspection Manual Chapter (IMC) 0613, Power Reactor Construction Inspection Reports, dated May 1, 2020. This performance deficiency was determined to be minor because ACI 349-01, Code Requirements for Nuclear Safety Related Concrete Structures, allowed the use of welded splices, and the licensee was committed to this code in their current licensing basis. Specifically, the subject reinforced concrete wall met the provisions of ACI 349-01 (code of record) for the construction, inspection, and testing of Unit 3 Wall 11, per Updated Final Safety Analysis Report (UFSAR) Subsection 3.8.4.2, Applicable Codes, Standards, and Specifications, and American Welding Society (AWS) D1.4-98, which is invoked by ACI 349-01.
5 AWS D1.4 establishes the integrity of the process and certification of the welders to meet the quality standards needed for these structures. AWS D1.4-98 Section 6, Qualification, establishes the welding procedure specification (WPS) document which provides direction to the welder or welding operators for making sound and quality production welds as per the code. A WPS is supported by a procedure qualification record (PQR). In addition, each welder is qualified, and their work inspected. Since the welders and welding procedures are required to be qualified to AWS D1.4-98, this provides in part, reasonable assurance that the welds have been made to a quality standard.
In addition, the NRC staff determined the following regarding the performance deficiency (PD):
- 1. the PD did not represent a substantive non-conservative error in a specification, computer program, design report, drawing, calculation or other design document that defines the technical requirements for a structure, system, or component (SSC);
- 2. the PD did not represent a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function;
- 3. the PD did not represent an adverse condition that rendered the quality of an SSC, unacceptable or indeterminate, and require substantive corrective action;
- 4. the PD did not represent an irretrievable loss or inadequate documentation of a quality assurance record that could preclude the licensee from demonstrating the adequacy of quality or from properly evaluating safety-significant activities;
- 6. the PD was not material to the acceptance criteria of an ITAAC (i.e., an ITAAC finding) because the PD did not prevent the licensee from meeting an ITAAC Design Commitment or approved Technical Specification, and the PD did not invalidate the performance of the Inspection, Test, or Analysis described in the ITAAC.
10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, states, in part, a [quality assurance] program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. Contrary to above, since the start of construction of Unit 3 Wall 11, the licensee failed to carry out those policies documented in the licensees NDQAM for Unit 3 Wall 11. Specifically, the licensee committed to comply with ASME NQA-1-1994, Subpart 2.5, in its NDQAM, without exception, however, additional testing was not performed in accordance with Section 7.13 of Subpart 2.5, for welded reinforcing steel hoops used in the Unit 3 north wall of the main steam east compartment at column line 11, between elevations 117-6 and 153-0. The licensee initiated CR 50050957 to address the failure to meet a commitment in their quality assurance program, as written. This failure to comply with 10 CFR Part 50 Appendix B, Criterion II, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
6 Minor Violation of 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings During the URI inspection follow-up activities, the NRC staff identified an additional minor violation of 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings. The NRC staff determined that the failure to adequately review and reconcile licensing basis impacts for the use of welded rebar splices in a safety related Unit 3 structure was a performance deficiency related to a construction finding. Specifically, VEGP Unit 3 UFSAR Section 3.8.4.6.1.2 states in part that, in areas where reinforcing steel splices are necessary and lap splices are not practical, mechanical connections (e.g. threaded splices, swaged sleeves or cadwelds) are used. UFSAR Section 3.8.4.6.1.2 did not specifically allow for the use of welded reinforcing bar splices. The NRC staff noted that the licensee used welded reinforcing bar splices instead of lap splices or mechanical connections in the hoops around the circular embedment for the main steam line placed in the north wall of the Unit 3 main steam isolation valve east compartment at column line 11 between column lines L and M and elevations 117-6 to 153-0.
The licensee initiated Engineering and Design Coordination Report (E&DCR) SV0-CR01-GEF-000543, Lap Splice Substitution, Rev. 0, dated 07/28/2015, which approved the use of welded splices. Form F-APP-GW-GAP-147-1, Licensing Impact Determination, concluded Based on the Current Licensing Basis keywords searched and the Current Licensing Basis document chapters/sections/tables/figures reviewed, no Current Licensing Basis impact is identified.
The licensee utilized procedures APP-GW-GAP-420, Engineering and Design Coordination Reports, Rev. 11, and APP-GW-GAP-147, AP1000 Current Licensing Basis Review, Rev. 4 to screen the E&DCR. Step 5.8.4 of procedure APP-GW-GAP-420, states in part, that the impact to safety margins, structural requirements, functional, and performance requirements shall be identified as part of the justification. Step 7.6 of APP-GW-GAP-147, states in part, that Licensing Impact Determinations should be performed from a perspective of verbatim compliance to the certified design. The NRC staff determined that the licensee did not consider the impacts to the current licensing basis or the verbatim compliance to the certified design with respect to the use of welded splices, which was not specifically approved for use per Section 3.8.4.6.1.2 of the licensees UFSAR.
The performance deficiency was evaluated against the more-than-minor evaluation questions in Appendix E of IMC 0613. This performance deficiency was determined to be minor because ACI 349-01 allowed for use of welded splices, and the licensee was committed to this code in their current licensing basis. Specifically, the subject reinforced concrete wall met the provisions of ACI 349-01 (code of record) for the construction, inspection, and testing of Unit 3 Wall 11, per UFSAR Subsection 3.8.4.2 and AWS D1.4-98, invoked through ACI 349-01. AWS D1.4 establishes the integrity of the process and certification of the welders to meet the quality standards needed for these structures. AWS D1.4-98 Section 6, Qualification, establishes the WPS document which provides direction to the welder or welding operators for making sound and quality production welds as per the code.
7 A WPS is supported by a PQR. In addition, each welder is qualified, and their work inspected. Since the welders and welding procedures are required to be qualified to AWS D1.4-98, this provides in part, reasonable assurance that the welds have been made to a quality standard.
In addition, the NRC staff determined the following regarding the PD:
- 1. the PD did not represent a substantive non-conservative error in a specification or other design document that defines the technical requirements for a SSC;
- 2. the PD did not represent a substantive failure to establish or implement an adequate program, process, procedure, or quality oversight function;
- 3. the PD did not represent an adverse condition that rendered the quality of an SSC, unacceptable or indeterminate, and require substantive corrective action;
- 4. the PD did not represent an irretrievable loss or inadequate documentation of a quality assurance record that could preclude the licensee from demonstrating the adequacy of quality or from properly evaluating safety-significant activities;
- 6. the PD was not material to the acceptance criteria of an ITAAC (i.e., an ITAAC finding) because the PD did not prevent the licensee from meeting an ITAAC Design Commitment or approved Technical Specification, and the PD did not invalidate the performance of the Inspection, Test, or Analysis described in the ITAAC.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to above, since the start of construction of Unit 3 Wall 11, a seismic Category I structure, the licensee failed to accomplish activities affecting quality in accordance with procedures. Specifically, the licensee failed to adequately review and reconcile licensing basis impacts in accordance with corrective action program and associated screening procedures for the use of welded reinforcing bar splices in a safety-related Unit 3 structure. The licensee initiated CR 50050960 to reconcile the differences in the UFSAR and the as-built plant configuration with respect to the use of welded reinforcing bar splices. This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- b. Findings No findings were identified.
8
- 4. OTHER INSPECTION RESULTS 4OA6 Meetings, Including Exit
.1 Exit Meeting.
On May 21, 2020, the inspectors presented the inspection results to Mr. M. Yox, Regulatory Affairs Director, Vogtle 3 & 4, and other licensee and contractor staff members.
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensees and Contractor Personnel K. Roberts, SNC Licensing Manager C. Castel, SNC Licensing LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Type Status Description 05200025/2018-01 URI Closed Welded Reinforcing Bar Splices (Section 4OA3)
LIST OF DOCUMENTS REVIEWED Section 4OA3 Documents Reviewed:
APP-GW-GAP-140, AP1000 Licensing Applicability Determination and 10 CFR 50.59/10 CFR 52 Appendix D Section VIII Screening, Rev. 1 APP-GW-GAP-142, AP1000 10 CFR 52 Appendix D Section VIII Processes for Changes and Departures Evaluations, Rev 0, APP-GW-GAP-147, AP1000 Current Licensing Basis Review, Rev. 4 Form F-APP-GW-GAP-147-1, Licensing Impact Determination APP-GW-GAP-420, Engineering and Design Coordination Reports, Rev. 11 ND-AD-002, Nuclear Development Corrective Action Program, Version 27.0
9 ND-LI-VNP-002, Applicability Determination and 50.59 / Departure Screening for VEGP 3&4, Version 16.1 Nuclear Development Quality Assurance Manual (NDQAM), Version 17.0 E&DCR SV0-CR01-GEF-000543, Lap Splice Substitution, Rev. 0, dated 07/28/2015 CR/CAPAL Written CR 10465176, CR 50050957, CR 50050960
10 LIST OF ACRONYMS ACI American Concrete Institute ASME American Society of Mechanical Engineers AWS American Welding Society BPVC Boiler and Pressure Vessel Code CFR Code of Federal Regulations CR Condition Report E&DCR Engineering & Design Coordination Report IMC Inspection Manual Chapter IR Inspection Report ITAAC Inspections, Tests, Analysis, and Inspection Criteria NDQAM Nuclear Development Quality Assurance Manual NQA Nuclear Quality Assurance NRC Nuclear Regulatory Commission NRO Office of New Reactors PD Performance Deficiency PQR Procedure Qualification Record SNC Southern Nuclear Company SSC Structures, Systems, and Components URI Unresolved Item UFSAR Updated Final Safety Analysis Report VEGP Vogtle Electric Generating Plant WPS Welding Procedure Specification ITAAC INSPECTED No. ITAAC No. Design Commitment Inspections, Tests, Analysis Acceptance Criteria Not Applicable