ML20198R700
| ML20198R700 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/23/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-920, NUDOCS 8606100174 | |
| Download: ML20198R700 (6) | |
Text
'
R* tao *a'xWa"'
Dk3 Waynestora Georgia 30830 Telephone 404 SSL9961 Ext. 3360 404 724-8114. Ext. 3360 h
h
,;J 3
Georgia Power D. o. Fost.,
Vice President Vogtle Project I'e sa,t*yvn electrc sprem May 23, 1986 United States Nuclear Regulatory Commission Region II File: X7BG10 Suite 2900 Log:
GN-920 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/86-11, 50-425/86-06 Attention: Mr. Roger D. Walkor The Georgia Power Company wishes to submit the following information concerning the violations and deviation identified in your inspection report 50-424/86-11 and 50-425/86-06:
Violation 50-424/86-11-01, 50-425/86-06-01,
" Inadequate Measures to Assure Correction of Design Criteria Documents" - Severity Level IV The violation identified discrepancies in three Design Criteria (DC-1018, DC-1204, 0C-27C2) and attributes the discrepancies to inadequate corrective actions relative to design criteria control problems identified during the licensee's INP0 Construction Project Self-Initiated Evaluation and the Module 4 Readiness Review.
Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
As indicated in the USNRC inspection report, Design Criteria DC-1018 did not include provisions that there be a five pipe diameter distance between postulated breaks and pipe supports because this was not under-stood to be a commitment to the USNRC.
Georgia Power Company has sub-i mitted additional information (File: X6BB06, Log: GN-902, dated May 9,
1986) on this matter to the office of Nuclear Reactor Regulation requesting a meeting to discuss the issue more fully.. A meetirg with i
cognizant members of the Nuclear Reactor Regulation staff has been scheduled for June 4,1986.
Georgia Power Company will take appropriate actions to resolve this matter as are agreed upon at the meeting.
Georgia Power Company acknowledges the discrepancies associated with Design Criteria DC-1204 and DC-2702 but maintains that the discre-pancies are not resultant from ineffective corrective actions in response to earlier evaluations.
Design criteria for the Vogtle Electric Generating Plant (VEGP) were initially prepared based on applicable regulatory requirements
[
8606100174 860523 PDR ADOCK 05000424 G
PDR k
E Page Two and industry standards, Georgia Power Company requirements, and the standard practices and experiences of the architect-engineer (Bechtel Power Corporation).
The criteria were general and functional in nature.
As the design of the plant progressed, the Design Manual evolved into a more detailed document and the design criteria were expanded to include an abundance of detailed descriptive material which extended beyond the design bases for the plant.
As a resul t, minor changes to implementing design documents such as drawings and specifications can impact the Design Manual.
As a result of the INP0 Self Initiated Evaluation, all VEGP design criteria were reviewed for compliance to engineering requirements.
Also during 1983, Bechtel conducted an evaluation of design requirements for all VEGP safety-related systems. This evaluation included a verifica-tion that design criteria requirements were correctly incorporated into implementing design documents.
Since May 1983, over 400 Design Manual Change Notices and 33 general revisions to the design criteria have been processed to maintain the Design Manual reflective of the evolving design.
These numbers are indicative of the Vogtle Project's concern with the correctness of the Design Manual.
The Readiness Review findings and uncorrected deficiencies in Design Criteria DC-1204 and DC-2702 cited in the violation are discrepancies in the descriptive material not typically included in design criteria, with the exception of Readiness Review Finding 4-75.
(This finding noted the untimely incorporation of the project's alternate pipe break criteria into Design Criteria DC-1018.
The alternate criteria was, however, promptly incorporated into the FSAR following the USNRC's con-currence.)
None of these discrepancies, including Readiness Review Finding 4-75, have had an adverse impact on the quality of the Vogtle c
design.
Actions to resolve the discrepancies identified by the Readiness Review findings and the USNRC have now been completed.
To prevent further problems in this area, provisions have been incorporated into design change controls to ensure that changes which impact design criteria are processed in a controlled manner.
The current project mechanism for implementing significant changes to the design is the Change Control Package (CCP).
Besides a description of the change and the design basis for the change, the CCP includes a checklist of documents potentially impacted by the design change.
Licensing documents (FSAR, Safety Evaluation Report, Technical Specifications, etc.) and the Design Manual are included on the checklist and space is provided to annotate the action item that tracks completion of required revisions to the impacted documents.
In order to provide additional assurance that changes to the Design Manual will be identified and properly controlled, appropriate project design personnel will receive remedial training to emphasize requirements I
and processes for maintaining accurate and up-to-date design criteria.
This training is expected to be completed by July 7,1986.
l l
l
F Page Three Violation 50-424/86-11-02, 50-425/86-06-02, " Failure to Promptly Identify Undersize Welds" - Severity Level IV The violation identified two welds on the Unit 1 RHR Isolation Valve Encapsulation Vessel (1-1205-V4-001) that were identified to the licensee on August 30, 1985, as being smaller than specified on the vendor drawing.
The licensee failed to identify the undersize welds even though an earlier visual inspection of the vessel identified six unsatisfactory welding-related conditions.
Although the undersize condi-tion for the welds had been reported to the licensee on August 30, 1985, the deficient condition was not identified for resolution on Deviation Reports until February 1986.
Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
Georgia Power Company acknowledges the violation but wishes to clarify certain statements in the USNRC inspection report relative to the Vogtle inspection program.
The Residual Heat Removal (RHR) and Containment Spray (CS) Isolation Valve Encapsulation Vessels were manufactured by Richmond Engir.eering Company (RECO), which is a certified ASME NPT stamp holder.
The Vogtle Project architect-engineer, Bechtel Power Corporation, conducts periodic evaluations of the REC 0 quality assurance program on behalf of the Georgia Power Company to provide assurance of product quality.
Georgia Power Company does not reinspect all welding attributes of ASME code-stamped items but does perform a visual examination of weld samples during receipt inspection for obvious surface defects.
It was during receipt inspection that some unsatisfactory welding conditions (slag pockets, arc strikes, undercut) were identified on vessel 1-1205-V4-001 and were documented on Deviation Report MD-2264.
Weld size is not a criterion for receipt inspection and, therefore, undersize weld conditions are not expected to be identified.
Georgia Power Company considers this program adequate and in full compliance with applicable -egulatory requirements.
It is Georgia Power Company's policy to have cognizant, responsible personnel in attendance at USNRC inspection exit interviews and to take prompt action relative to USNRC concerns identified at exit interviews.
l Those personnel in attendance at the exit interview of August 30, 1985, when the undersize weld condition was identified, failed to adequately communicate the inspection findings to the responsible personnel.
As a result, no corrective actions were initiated until the USNRC inspection report (50-424/85-35) was received in late December 1985, at which time a reinspection of all REC 0 encapsulation vessels was scheduled.
As indicated in the USNRC inspection report (50-424/86-11, 50-425/86-06),
this reinspection was completed on February 5,
1986, and identified additional similarly located undersize welds in other encapsulation vessels.
All discrepancies were documented on Deviation Reports to ensure they are properly resolved.
As a result of the reinspection, it was noted that the undersize conditions existed only in plate-type reinforced groove welds, which is an unusual weld configuration, and that the other welds in the encapsulation vessels were correctly sized.
Therefore, Georgia Power Company considers the undersize conditions l
F Page Four to be isolated to the REC 0 plate-type reinforced groove welds, which exist only in the encapsulation vessels.
To prevent further problems in this area, Georgia Power Company will ensure that cognizant, responsible representatives from all affected Vogtle Project organizations are present at USNRC inspection exit inter-views. This commitment is, by necessity, contingent upon USNRC inspection personnel providing advance information to the QA Site Manager as to the areas of his concerns.
In addition, a directive is being prepared for distribution to responsible management and supervisory personnel reminding them of their responsibilities to ensure that prompt appropriate action is taken relative to concerns identified by USNRC inspection personnel during exit interviews.
This responsibility includes notifica-tion of any project organization required to take ccrrective actions relative to the identified concerns.
The preventive measures described above are expected to be completed by June 6, 1986.
Violation 50-424/86-11-03, " Removal of Temporary Pipe Supports" - Severity Level IV The violation identified a failure by the licensee to document instructions, procedures, or drawings that would assure that temporary shipping supports in RHR Isolation Valve Encapsulation vessel 1-1205-V4-001 would be removed. Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.
l l
Ar, noted in the inspection report, Pullman Power Products, the piping contractor for the Vogtle Project, issued a field process sheet on October 27, 1981, to perform several operations on encapsulation vessel 1-1205-V4-001 including the removal of the temporary shipping braces.
A note was placed on the process sheet on April 22, 1982, indi-l cating that the temporary braces could not be removed until all welds I
to the vessel were completed.
The vessel welds were performed in accor-i dance with their own process sheets, which contained no reference to the subsequent removal of the temporary braces.
The process sheet dated October 27, 1981, was erroneously signed-off and taken out of circulation by Pullman Power Products QA document reviews before the temporary braces l
I were removed.
Georgia Power Company considers this oversight to be an isolated case of personnel error.
The temporary shipping supports have now been removed from RHR Isolation Valve Encapsulation Vessel 1-1205-V4-001.
Inspections were conducted of the other encapsulation vessels and no additional discrepan-l cies were found.
To prevent further discrepancies of this type, Pullman Power Products now requires that new process sheets be prepared for any work operation i
i
r-Page Five which could not be performed on the original process sheet.
The QA Document Reviewers are also required to inform the Engineering Department when any omission of work operation is detected.
Responsible field installation and dccument review personnel will be trained in the imple-mentation of these provisions.
In addition, engineering and QA/QC super-visory personnel have admonished responsible field installation and document review personnel to exercise greater care in the completion and closure of process sheets.
Implementation of preventive measures and training of responsible personnel are expected to be completed by June 6,1986.
Deviation 50-425/86-11-04, 50-425/86-06-04, " Failure to Inspect Supports" The Notice of Deviation states that, contrary to a commitment made in a letter dated July 11, 1983, the licensee did not assure inspection of any support weldments fabricated from heat numbers 7417461 and 7419919 in their investigation.
Georgia Power Company offers the following response to the deviation:
Georgia Power Company denies that a deviation from commitments has occurred.
Georgia Power Company's letter to the USNRC dated July 11, 1983 (File: X78G03-M41, Log: GN-240), was the first written communi-cation following verbal notification of a potentially reportable concern pursuant to the requirements of 10 CFR 50.55(e). A plan of investigation, proposed to Georgia Power Company by the Vogtle Project architect-engineer (Bechtel Power Corporation), was attached to the letter as Lackground information.
The cover letter clearly identifies the information as "an interim report" and "a proposed plan."
The proposed plan indicates that a field walkdown of supports similar to the one that failed would include samples of weldments made to embed plates fabricated from heat numbers 7417461 and 7419919, the heat numbers respectively of the failed support and a similar support tested to destruction, which also exhibited indications of lamellar tearing of the base metal.
Bechtel's preliminary evaluation, following metallurgical analysis of samples from the failed support by their Materials and Quality Services Department, attributed the support failure to lamellar tearing caused by large shrinkage stresses from heavy welding, compounded by embed plate inclusions and ferrite banding close to the plate surface.
Bechtel reported to Georgia Power Company that it is very unusual to see inclu-sions and banding close to the plate surface and that this condition is highly unlikely to exist uniformly or repeat itself within a given heat of material.
Therefore, the concern was not considered to be a heat-specific condition.
Based on these conclusions, and subsequent to correspondence GN-240, Bechtel recommended that the proposed field walkdown inspection be modified.
The modified plan called for the identification of the entire popula-tion of installed and inspected supports similar to the one that failed and the selection of a randomly selected sample from the total population
F Page Six to be used in a statistical analysis.
A detailed visual inspection and magnetic particle testing was to be conducted on each support in the sample to determine if any indications of lamellar tearing were present.
Georgia Power Company considers the statistical analysis to be an acceptable method for determining, the extent of discrepancies of this type.
Contrary to a statement in the USNRC inspection report, Georgia Power Company notified Region II in a letter dated December 19, 1983 (File X7BG03-M41, Log:
GN-294), that the field inspection program to be used in the evaluation was modified.
The letter provides a general description of the modified program and clearly indicates that the support sample which was visually inspected and magnetic particle tested was randomly selected from the total population of installed embed plate supports.
Based on the above information, it is Georgia Power Company's posi-tion that the evaluation of the embed plate base metal failure was adequate and that the USNRC was properly informed of changes in the evaluation plan.
These responses contain no proprietary information and may be placed in the NRC Public Document Room.
Your truly 0
D. #0. Foster REF/DOF/tdm xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 J. H. Miller R. A. Thomas L. T. Gucwa J. P. O'Reilly D. R. Altman C. W. Hayes G. F. Head P. R. Bemis G. A. McCarley R. E. Conway J. A. Bailey D. S. Read J. T. Beckham
- 0. Batum Sr. Resident (NRC)
R. H. Pinson G. Bockhold C. S. McCall (OPC)
P. D. Rice C. E. Belflower J.E. Joiner (TSLA)
B. M. Guthrie J. F. D'Amico D. C. Teper (GANE)
D. E. Dutton E. D. Groover NORMS