ML20207J275
| ML20207J275 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/31/1986 |
| From: | Livermore H, Rogge J, Schepens R, Sinkule M, Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207J244 | List: |
| References | |
| 50-424-86-111, 50-425-86-50, NUDOCS 8701080368 | |
| Download: ML20207J275 (35) | |
See also: IR 05000424/1986111
Text
. ....
km CUg UNITED STATES
Do NUCLEAR REGULATORY COMMISSION
[ o REGloN II
g j 101 MARIETTA STREET. N.W.
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Report Nos.: 50-424/86-111 and 50-425/86-50
Licensee: Georgia Powe Company
P. O. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109
Facility Name: Vogtle 1 and 2
Inspection Conducted: October 22 --December 15, 1986
Inspectors: I. . [ l /!
- H. H. Livermore, Senior Resident Inspector Date Signed
Construction
$ ALQ
g J. F. Rogge, Senior Resident Inspector
r2/s/86
Date Signed
Operations f
6 6K A~I
R. J. Schepens, Resident Inspector
r#/9s
Date Signed
M Operations & Constructipn
@( w)
P. H. Skinner, Senior Resident Inspector
n/n/86
Date Signed
Catawba
Accompanying Perso nele C Bur er and C. Paulk
Approved by: _14ukd6
M. V.LSinkule', Section Chief
J/ A6
Dat'e Sfgned
Division of Reactor Projects
SUMMARY
Scope: This routine, unannounced inspection entailed Resident Inspection in the
following areas: containment and safety related structures, piping systems and
supports, safety related components, auxiliary systems, electrical equipment
and cables, instrumentation, preoperational test program, quality programs and
administrative controls affecting quality, and follow-up on previous inspection
identified items.
Results: No violations or deviations were identified.
8701090368 861231
PDR ADOCK 05000424
O PDR
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DETAILS
1. Persons Contacted
Licensee Employees
R. E. Conway, Senior Vice-President, Vogtle Project Director
C. Whitney, General Manager, Project Support
P. D. Rice, Vice-President,-Project Engineering
R. H. Pinson, Vice-President, Project Construction
W. W. Mintz, Project Completion Manager
R. W. McManus, Readiness Review
- G. Bockhold, Jr. , General Manager Nuclear Operations
- T. V. Greene, Plant Manager
- R. M. Bellamy, Plant Support Manager
- C. W. Hayes, Vogtle Quality Assurance Manager
- C. E. Belflower, Quality Assurance Site Manager - Operations
- E. D. Groover, Quality Assurance Site Manager - Construction
- W. E. Mundy, Quality Assurance Audit Supervisor
- D. M. Fiquett, Project Construction Manager - Unit 2
B. C. Harbin, Manager Quality Control
- G. A. McCarley, Project Compliance Coordinator
- W. C. Gabbard, Regulatory Specialist
C. F. Meyer, Operations Superintendent
R. M. Odom, Plant Engineering Supervisor
C. L. Coursey, Maintenance Superintendent (Startup)
M. A. Griffis, Maintenance Superintendent
j
E. M. Dannemiller, Technical Assistant to General Manager
G. R. Frederick, Quality Assurance Engineer / Support Supervisor
- R. E. Spinnatu, ISEG Supervisor
'
- J. F. D' Amico, Nuclear Safety & Compliance Manager
- W. F. Kitchens, Manager Operations
V. J. Agro, Superintendent Administration
- A. L. Mosbaugh, Asst. Plant Support Manager
M. P. Craven, Nuclear Security Manager
l Other licensee employees contacted included craftsmen, technicians,
supervision, engineers, inspectors, and office personnel.
'
Other Organizations
F. B. Marsh, Project Engineering Manager - Bechtel
H. M. Handfinger, Asst. Plant Support Manager - Bechtel
D. L. Kinnsch, Project Engineering - Bechtel
- Attended Exit Interview
2. Exit Interview (30703C)
The inspection scope and findings were summarized on December 15, 1986,
with those persons indicated in paragraph 1 above. The inspector described
the areas inspected and discussed in detail the inspection findings. No
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dissenting comments were received from the licensee. The licensee did not
identify as proprietary any of the materials provided to or reviewed by the
inspector during this inspection.
The following items were identified during this inspection:
Unresolved Item 50-424/86-111-01, " Review Inspection Results of the
Licensee's Inspection of Burn Damage on Limitorque Operator Power
Leads." - Paragraph 4
Inspector Followup Item (IFI) 50-424/86-111-02, " Review PRB Procedure
for Proper Incorporation of Technical Specifications." - Paragraph 26
IF! 50-424/86-111-03, " Review Revistor. 00005-C Regarding Overtime
Minimizing." - Paragraph 23
The following previous inspection items remain open due to incomplete
licensee action:
IFI 50-424/86-51-02, " Review Procedure 00301-C to Verify Incorporation
of Unfettered Access for NRC Resident Inspectors." - Paragraph 23
This inspection closed two violations, nineteen IFIs, two Construction
Deficiency Report and fourteen Three Mile Island Tcsk Followup Items.
Region based NRC exit interviews were attended during the inspection period
by a resident inspector. ,
'
3. Licensee Action on Previous Enforcement Matters (92702)
'
(Closed) Violation, 50-424/86-09-01, " Failure to Perform an Adequate System
>
Walkdown During the Turnover of Safety-Related Systems". This violation
,
identified a number of discrepancies between the as-built configurations of
the Residual Heat Removal (RHR) System and the Nuclear Service Cooling Water
,
(NSCW) System and the latest Piping and Instrumentation Diagram (P&ID)
F drawings for those systems. These discrepancies were not identified on the
system punchitsts as required by Startup Manual Procedure SUM-17 even though
!
a walkdown inspection had been conducted on the systems during turnover as
required by Construction Department Procedure GD-A-49. The inspector has
L reviewed the licensee's corrective action which consisted of but was not
' limited to: 1) Documenting the discrepancies identified on controlled
documents such as Deviation Reports and Field Change Requests, 2) Issuing
i FPCN 1 to Construction Procedure GD-A-49 which included provisions for
identifying discrepancies between Isometric Drawings and P& ids during
turnover walkdowns and documenting them on the Master Tracking System
Punchlists, and 3) Performing and documenting a re-walkdown of all safety-
- related systems in accordance with a special Construction Acceptance Test
. CAT-M-99. The licensee's results of the re-walkdowns conducted in
l accordance with CAT-M-99 was presented to the Resident Inspectors on
' September 24, 1986, as documented in Inspection Report No. 50-424/86-74 and
50-425/86-35. Based on this review the inspector has determined that the
( licensee has taken the appropriate corrective action; therefore, this item
is considered to be closed.
r
)
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(Closed) Violation 50-424/86-31-01, " Failure to Establish Appropriate
Procedures to Properly Control the Filling and Venting of Safety-Related
Systems". This violation identified several examples where approved
procedures were not used during filling and venting safety-related systems
but rather verbal instructions were given by a test supervisor to operations
personnel. Subsequently an error was made in sequencing the opening of
valves, which in turn, led to inadvertent overfilling of the Reactor Coolant
System above the 188' elevation. The inspector has reviewed the licensee's
corrective action which consisted of but was not limited to: 1) Additional
training to emphasize the importance of effective communication, avoidance
of operator errors, and the use of appropriate procedures to control work
activities, 2) System Operating Procedure 13011-1 for filling and venting
j the RHR System was revised to address the sections of piping between valves
8701A and 8701B (Train A) and 8702A and 8702B (Train B), 3) Startup Manual
'
Procedure SUM-37 was revised to establish policies to limit the use of
verbal instructions on the performance of work activities involving safety-
related equipment, and 4) A new Startup Manual Procedure (SUM 39, " Initial
Test Program Incident Reports") was developed to establish a report to
management for occurrences (like the RCS overfills) that were previously not
required to be reported. The procedure includes provisions for determining
the root cause of reported incidents and for prescribing appropriate
corrective action. Based on the above review the inspector has determined
that the licensee has taken the appropriate corrective action; therefore
this item is closed.
4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations. One new unresolved item identified during this inspection is
discussed in Paragraph 24.
5. Followup on Previous Inspection Items (92701)
(Closed) Inspector Followup Item (IFI) 50-424/85-26-02 & 50-425/85-25-02,
" Review Licensee Action on Information Notice Nos. 85-15, 85-19 & 85-25."
This Inspector Followup Item identified three (3) IE Information Notices
i which required followup by this inspector pending completion of the
licensee's evaluation process. The inspector has reviewed the licensee's
action and has determined that the IE Information Notices were distributed
to the appropriate departments for evaluation of applicability and that
appropriate corrective action has been taken. Based on this review this
item is considered to be closed.
(Closed) IFI 50-424/86-60-09, "QC Re-inspection Anti-Drug Program". As
noted in the Inspector Followup Item, the inspector was concerned that the
Vogtle Drug Program was lacking some continuity and detail to insure
standardization in the areas of: the formal QC notification process of
those called in on the Drug Abuse Hot Line; those who will be addressed by
QC for re-inspection (field engineers, QC, etc.); and detail decisien making
guidelines as to how a supervisor decides who will be tested or not.
The inspector reviewed the following newly issued Drug Program procedures:
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a) Management Action Procedure dated September 8, 1986.
b) Desk-top Procedure S-1920, Reporting Guidelines, September 27,
1986.
c) QC Re-inspection / Verification Status Sheet.
The procedures set forth additional details that satisfy the aforementioned
inspector concerns. Specific forms and notifications are now provided that
notify QC of all personnel that fail the drug and alcohol testing.
Guidelines are provided that determine exactly whose work is to be
re-inspected. Re-verification lists record the actions taken on all those
personnel in the re-inspection category. Guidelines are provided for
management evaluation of the quality of information, knowledge and
observation of the individual, and discretion and judgement to be used in
regards to the nature of the employee's duties. The inspector is satisfied
with the action taken and considers this item closed.
(Closed) 50-424/86-09-05, " Review Licensee Action to Resolve HVAC Handswitch
Nomenclature". This inspector followup item identified that handswitch
Nos. 1-HS-12004, 1-HS-12050A, 1-HS-12051A, 1-HS-12053A & 1-HS-12054A on the
Control Room HVAC Control Panel QHVC were labeled as " exhaust" fan whereas
the P&ID and the applicable operations procedure states " supply" fan. The
inspector has reviewed the licensee's action which included the replacement
of the handswitch switch plates with ones with the correct nomenclature,
i.e., " supply" fan. Based on this review the inspector has determined that
the licensee has taken the appropriate corrective action; therefore, this
item is considered to be closed.
(Closed) IFI 50-424/86-60-04, " Review Results of Baselining the Regulatory
Compliance Computer Database With the Readiness Review Module 7 Database".
The inspector reviewed a marked up version of Table 3.2-1 from Module 7
showing where the Master Operations Database contained each commitment.
Summary Tables were reviewed showing (1) Differences and (2) Those added
since issuance of Module 7. It was noted that several commitments listed in
Module 7 will not be in the Master Database. These commitments were
,
indicated in the package as " Design State of Fact" or " State of Fact".
i
(Closed) IFI 50-424/86-31-04, " Review Minimum Shift Crew Requirements".
Since this item was opened the Technical Specifications have developed to a
final status. The issue was brought to NRR attention and the decision was
to use the Standard Technical Specification (STS) format. While the STS
does not require personnel in a defueled state for a single unit site; it
,.
will when both units are operating.
(Closed) IFI 50-424/86-31-05, " Review Implementation of Technical
Specification Overtime Conflicts with 00005-C". Since this item was opened
the Technical Specifications have developed to a final status. NRR has
decided to change the wording in the Technical Specification to match the
licensee's proposal. The inspector has noted to NRR where their
requirements have been relaxed and will enforce the Technical Specification
as issued.
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(Closed) IFI 50-425/86-31-02, " Review Implementation of Negative Logic
Testing". This Inspector Followup Item identified that based on a review of
several Preoperational Test Procedures and discussions with test
supervisors that the AFW & CVCS System Preoperational Test Procedures did
not contain provisions for testing all valves and pumps with transfer switch
control to the remote shutdown panels for negative logic testing. The
inspector has reviewed the licensee's action which consisted of issuing and
implementing preoperational test procedure 1-300-15. This procedure
contained sections 6.8 through 6.12 which detailed a Generic Test Procedure
for testing valves and pumps transfer switch control for negative logic
testing which had not been previously identified for testing in their
respective System Preoperational Test Procedures. Based on this review the
inspector has determined that the licensee has taken the appropriate
corrective action; therefore, this item is considered to be closed.
(Closed) IFI 50-424/86-31-07, " Review Maintenance Procedure 20427-C for
Incorporation of the ANSI Requirement to Document Closecut Inspection
Results." This inspector has reviewed the licensee's action which consisted
of incorporating this requirement as Step 4.3.5.b.6 into Maintenance
- Procedure 20427-C, Revision 2. Based on this review the inspector has
determined that the licensee has taken the appropriate corrective action;
therefore, this item is considered to be closed.
(Closed) IFI 50-424/86-31-06, " Review Site Procedure 00402-C, Licensing
Document Change Request, for Resolution of Comments". The inspector
reviewed procedure 00402-C, Rev. 3 issued 11/3/86 and noted that this item
has been resolved.
(Closed) IFI 50-424/86-51-01, " Review Licensee Action for TMI Item I.C.3".
,
Procedure 00001-C, Rev. I has been revised to contain the correct delegation
of responsibil!ty. The applicant still needs to provide a management
directive as delineated when this item was open.
(Closed) IFI 50-424/86-60-03, " Review Technical Specification Surveillance
4.8.1.1.1 Implementation Procedure for Proper Verification of AC Independent
Power Sources." Procedure 14230-1, Rev. 1 issued 10/12/86 was reviewed for
proper incorporation of comments. A second issue regarding the deletion of
a technical specification surveillance was brought to NRR attention and
resolved as not applicable.
4 (Closed) IFI 50-424/86-12-30, 50-425/86-18-30, " Completion of Installation
of Telephone Systems." Installation of telephones required by the
Radiological Emergency Plan and implementing procedures have been completed
as required.
(Closed) IFI 50-424/86-12-61, 50-425/86-18-61, " Complete Communication Links
With South Carolina Counties of Aiken, Barnwell and Allendale."
Notwithstanding the Administrative Decision Link (ADL) to the South Carolina
Emergency Headquarters and Forward Emergency Operations Centers (EOC) as
requested by that State, all links required by the Emergency Plan have been
installed, tested, and declared operational.
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(Closed) IFI 50-424/86-12-62, 50-425/86-18-62, " Completion of All
Communication Links Specified in the VEGP Radiological Emergency Plan, and
Assurance of Their Operability." All such communication links have been
installed, tested, and determined to be operable.
(Closed) IFI 50-424/86-12-70, 50-425/86-18-70, " Include in the " Subsequent
Operator Actions" Sections of All Appropriate Off-Normal Procedures, A Step
Similar to That Provided in ADP 18036." This item was closed via Report
Nos. 50-424/86-112, 50-425/86-51.
(Closed) 50-424/86-12-103, 50-425/86-18-103, " Design & Installation of An
Emergency Siren System. The siren system has been installed, tested, and
declared operational.
(Closed) IFI 50-424/86-12-110 and 50-425/86-18-110, " Performance of a Study
or Drills to Verify the Ability to Meet Minimum Staff Augmentation Criteria
in NUREG-0654." The inspection reviewed the results on the drill performed
on November 20, 1986, to demonstrate that adequate numbers of personnel
could respond within 60 minutes of notification.
6. Allegations
a. Allegation RII-86-A-0142, Non-Certified Personnel Performing iQ' Class
Material Welding in the Fabrication Shop
Concern
Two individuals notified Region II personnel tht they had observed two
non-certified personnel, one a Quality Control inspector assigned to
the fabrication shop and the other individual hired as summer help,
performing welding on iQ' Class material. In addition to notifying
Region II, they also filed a concern in the GPC Quality Concern Program
(QCP).
Discussion
The inspector reviewed the results of the QCP investigation and action
taken as described in QCP File Number 86V0292. The QCP investigation
substantiated that these two individuals had performed welding as
stated in the concern. The individuals that performed the welding as
well as the certified welders (2) that permitted the welding to occur
were terminated. In addition, a Deviation Report (DR) identified as
ED-14,013 was generated to disposition all suspect material that could
have had unauthorized welding performed. In addition, the work that
had been performed by the QC inspector was reviewed and reverified on a
sampling basis. The results of this review and sampling process was
that no discrepancies were found of the work performed by the QC
inspector. Tte material that was not alredy installed in the plant
was destroyed. One piece of this material which visually appeared
questionable was sectioned into 28 inspection samples and analyzed by
the project welding supervision. All samples were found to be
acceptable. All cable tray supports that had been installed with the
exception of 2 (2 out of 25) were found and visually checked. These
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were determined to be acceptable based on the destructive examination
that was performed. The 2 supports that were not found were considered
acceptable even though they were not found. The reason they were not
found was the utility saw no reason to expend additional man-hours and
none of the inspected supports had been rejected (23 of 25). One of
the certified welders was also sent to the lab and re-evaluated. This
welder passed all requalification testing.
Conclusion
This allegation was confirmed to be correct. The utility took adequate
and prompt corrective action to resolve this concern. Based on this
review, the inspector considers this item closed.
b. Allegation RII-86-A-0082, Concern That a Label Was Changed on a Pacific
Scientific Snubber Without Required Process Documentation
Concern
During the last week of June 1985 a GPC inspector directed a craft
pipefitter to remove the identification plate from a snubber and
replace this plate with a new one. This work was accomplished without
any process paperwork or without the approval of the Authorized Nuclear
Inspector (ANI) as required by procedures.
Discussion
A Pacific Scientific snubber was received at the GPC warehouse on
March 6, 1985. During the receipt inspection, the inspector identified
that the tag number stamped on this component was incorrect. As a
result, the inspection could not be completed and a deviation report
(DR), identified by control number MD-08105, was issued by the
inspector detailing the problem. An engineer contacted Pacific
Scientific to obtain the correct documentation which was transmitted to
GPC on or about April 16, 1985. The tag was transmitted in error to
the GPC QC supervisor in charge of the warehouse who had the tag
installed by a Pullman Power Products pipefitter without required
documentation or without observance by the ANI representative. The
alleger discussed this with his supervisor, and they contacted GPC QC
supervision. GPC stated that a DR should be written to document this
but the alleger never saw this DR. The DR was written and is
identified as MD-08367 dated July 3,1985. The action to resolve the
DR was to have ANI verify vendor documentation and accept based on that
review. The ANI inspector performed his review and signed off the
documentation and DR on August 15, 1986.
The snubber that was in question was initially identified to be
installed in the Nuclear Service Cooling Water System, but has been
replaced by a Anchor Darling type snubber. The original snubber is
presently at Pacific Scientific labs for repair as it failed a stroke
test. (Reference DR MD-08756)
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Discussion with ANI and GPC QC indicate that this appears to have been
an isolated case.
Conclusion
Based on the inspector's review, the work was performed without the
'
. required process sheets as stated, but a DR was written to document and
correct this problem. Since this was an isolated case and the snubber
is no longer installed in the plant, the inspector considers this item
'
is closed.
c. Allegation RII-85-A-0203, Alleged Harassment and Intimidation
Concern
An allegation was made to Region II that stated the alleger was
harassed and intimidated for refusing to sign a dispositioned deviation
report for work he did not accomplish.
Discussion
The inspector reviewed this item in detail. This item concerned
Deviation Report (DR) ED-09068 dated June 1, 1985, which concerned
cables which had been installed and were found to be too short to reach
the required equipment. The corrective action had been performed and
signed off on the DR by the alleger. The alleger was told by his
supervision to remove the hold tags (2 had been initially installed)
and sign for the removal on the DR. The alleger did not find any tags
and put the words "No Hold Tags Found" and dated the entry. He did not
sign the block. Upon being requested to sign the block, the individual
would not sign stating that it violated the procedure which provided
administrative controls over the DR process. He was confronted by his
supervision and the intent of the step that the alleger would not sign
was explained to him but he refused to sign the step. The individual
received a 5-day layoff without pay and as a result filed a complaint
with the Department of Labor (DOL). The DOL case was concluded on
4 October 24,1986 (see D0L Case #E6-ERA-9). The ruling was in favor of
the utility. The inspector determined that it is a common practice if
no tags are found to write in "O, none or none found" and the block
signed and dated. This process was discussed during training of QC
inspectors primarily with supervisors and then disseminated to other
,
inspectors. The alleger's supervisor signed the DR in question.
1
Conclusion
The signature in the block provided on the DR for this action appears
to be an administrative control and has no significance to safety.
Interpretation of a procedure is a management tool and this tool was
used for this occurrence but a difference of opinion resulted.
Although an argument occurred, documentation indicates the alleger was
- never directed to sign the statement, but was requested several times
to sign the DR entry form. The procedure' for controlling DRs was
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subsequently revised and this should eliminate further problems in this
areas. Based on this inspection this item is closed.
d. Allegation RII-86-A-0083, Alleged Poor Welding and Construction
Practices.
Concerns
(1) The alleger stated that the plastic liner for the chemical storage
pond was not installed properly due to poor grading of the pond
area which'left sharp pieces of earth and rock which could damage
the liner.
(2) The alleger stated that the diametric welding done on the loop
side in containment was done using .35 and .40 stainless steel
welding wire which was obtained from the Diametric classroom weld
wire storage. The weld wire was not properly controlled by QA.
(This concern was reported anonymously to the Quality Concern
Program in June 1985.) The welding done using this weld wire was
on the C level, Unit 1 containment, 20 or 30 inch stainless steel
loop pipe on the reactor pumps sometime in January 1984.
1
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(3) The alleger stated that Tungsten Inert Gas (TIG) rigs were used to
cut holes in stainless steel piping for temporary pipe
installation for flushing. This caused slag and molten metal to
4
fall into the pipe. Even though flush boxes were used to trap any
loose metals from the welding process, there is still the
possibility that some weld metal remained in the line and this
could damage valves in the permanent line.
Discussion
This allegation was officially transmitted to Georgia Power Company
(GPC) by the NRC for review and appropriate action in a letter from
Virgil L. Brownlee, dated July 14, 1986. The GPC response to the
allegation is documented in a letter to the NRC Region II from
D. O. Foster, dated July 29, 1986. In their response GPC addresses
- each of the alleger's concerns and finds them to be unsubstantiated.
l
The inspector reviewed the GPC response and records documenting-
interviews with several employees who were involved with the specific
concerns. The inspector also reviewed QA audits and various other
documents pertaining to this allegation.
Conclusion
The inspector can find no information to substantiate this allegation;
therefore, based on this inspection this item is closed.
e. Allegation RII-84-A-0168, Concern Regarding Processing an NCR and
l Alleged Harassment Concern:
Concern
l
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(1) A weld rod issue ticket could not be signed properly by an
individual due to lack of information required to certify the
correct material. The issue ticket was signed inappropriately by
another person.
(2) An individual was told by a supervisor to sign the weld ticket
discussed in (1) above. The individual felt harassed by this
supervisor.
(3) Non-conforming items (NCR) were being re-written after being
submitted by inspection personnel.
(4) An arc strike was corrected and too much material was removed
during the corrective action, however the repair was accepted by
quality control inspectors by using techniques that were not
acceptable.
As part of this concern, a second individual identified additional
concerns as follows:
(5) A Class 3 valve was "taken apart" without a process sheet.
(6) Some QC inspectors still hold union cards and keep in close
contact with craft supervision.
(7) Some QC inspectors were approving inspections based on verbal
guidance from supervisors.
Discussion
The inspector reviewed the areas of concern identified above. The
following are the results of this review for each of the areas:
(1&2) The weld rod ticket was signed off by a QC inspector. This
QC inspector has been terminated as a result of this action and
other personal problems identified by a utility investigation of
the individual. The weld in question was re-examined and no
problems were identified. The harassment issue was also
investigated by the utility and substantiated. As a result the
involved supervisor was transferred from the QC group. The weld
ticket processing problems were reviewed and Pullman Company
initiated more stringent controls in this area as described in
Pullman Corrective Action Report CA 9-1.
(3) A review of NCR re-writing issue identified that an effort to
" clarify" NCRs was undertaken by Pullman management in mid-1984.
NCRs were re-written to add what supervision thought was "needed
material". This resulted in the re-write of numerous NCRs and
caused concern to be expressed by.the QC personnel originating the
reports. As a result of various inspector's comments, the
controlling procedure was revised to eliminate the re-write effort
and only allow corrections and additions to be made with the
originator's review and initialing of the changes.
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(4) A review of this item identified that a Ultrasonic Test (UT) was .
performed on the weld repair and it was found to be acceptable.
Discussion with NRC UT personnel indicate that UT is an acceptable
method to determine pipe wall measurements. This particular joint
is located in a drain line connection on non-safety class piping.
The inspector did not request a UT to be performed again since the
pipe was logged and was in a non-safety system.
(5) Investigation of this item identified that the valve in question
was removed from the process line. It was a flanged valve and
removal consisted of disconnection at the flanges. There is no
evidence to support a disassembly of the valve. The valve was
removed for flush purposes and not to repair the valve. Records
indicate this valve was removed and re-installed several times and
proper process documentation was maintained.
i
(6) The inspector reviewed this area and found that some QC
supervisors do continue to hold union cards. A discussion with
their management indicates no conflict of interest with this .
action. t
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(7) For this item, discussion with various inspectors indicate that
they receive guidance from their supervision but follow procedures
to approve inspections.
Conclusion
Based on the findings stated above and the corrective actions taken by
GPC, this item is closed,
f. Allegation RII 85-A-0016-015, " Employee Terminations Due to Drug Use".
Concern
,
The alleger was concerned that when employees are terminated for drug
abuse activity that Georgia Power Company (GPC) does not list the
reason for the termination in the individual's work records as drug
abuse activity. The alleger stated that the reason for the termination
is usually listed as misconduct or insubordination. The reason that
this is placed in the records is because GPC is concerned that the NRC
will make GPC go back and reinspect all of the work that was performed
by the worker.
Discussion
By letter dated June 5,1986, U.S. NRC Region II assigned the subject
allegation to Georgia Power Co. for action and disposition. A reply
was received on July 3 and 10, 1986. The inspector reviewed the reply
and notes that the licensee conducted an extensive and meaningful
investigation into the subject allegation.
i
The inspector reviewed the records of a sample of recent and older GPC
employee terminations that were due to failing or refusal of the drug
'
_ . _ _ _ _ _ _ _ - ______.-m._ _ , _ . - _ . - - - _ _ _ _ _ _ _ _ _ _ _ . . . _ . _ _ _ . _ _ . __.
.
12
and alcohol test. The subject allegation is correct in that GPC lists
the reason for termination as misconduct, insubordination, or any other
violation of work rules and does not state that the true termination
was due to drug abuse activity. The inspector notes that this practice
is standard and is applied in all cases by the Manager of GPC Personnel
although not specifically written in policy procedures.
The policy is applied by GPC Personnel Department in order to spare the
individual the stigma of a termination by drug abuse being
inadvertently provided to a future employer. In regards to outside
inquiries, GPC does not provide any details except that the person did
work at Vogtle. The inspector notes that Status 23 (Terminated - No
Rehire) is entered on the Personnel Separation Notices of all
individuals terminated for drug or alcohol abuse. This policy is
applied by the GPC Personnel Manager to all cases regardless of any
testimonials provided by the employee's supervisors. The inspector
also notes that aforementioned information in regards to entries in
termination records applies only to Georgia Power employees. Site
contractors such as PPP, PKF, Cleveland, Butler, Daniel, etc. handle
their own personnel separation records once GPC notifies them that an
individual has failed or refused a drug or alcohol test. The inspector
did not review contractor's separation processes since they were not in
the scope of the allegation.
In regards to the second part of the allegation, the inspector could
find no evidence that GPC was purposely using misconduct or
insubordination entries in termination records in order to avoid
re-inspections of the individual's work. Oa the contrary, with the
advent of the Vogtle Drug Program in 1984, each contractor addressed
the need for re-inspection of work of those terminated for drug abuse.
The notification system was not formalized but rather round-about with
GPC QC visiting each contractor to obtain information to centralize and
assure re-inspections were implemented. Specific drug terminations and
re-inspection information was sometimes relayed to the NRC, but not
every time as a matter of policy. In January 1986, GPC began a program
to re-identify all contractor personnel terminated under the provisions
of the Vogtle Anti-Drug Program whose work would require re-inspection.
This information was centralized with GPC QC for re-inspection
overview. A generic procedure was instituted that was used for sample
re-inspections. GPC QC now has a Re-inspection / Verification Status
List that records the actions taken on all previous site employees
whose work required re-inspections. Re-inspection is complete in all
but three cases (nearing completion). The inspector notes that
specific forms and notifications are now provided (by Procedure S-1920)
that notify QC of all personnel failing the Vogtle Anti-Drug Program.
Guidelines are now provided in a Management Action Procedure that
determine exactly whose work is to be re-inspected (i .e. , QC, QA,
Engineers,etc.).
Conclusion
The allegation is correct in that misconduct and insubordination are
some of the reasons used for drug / alcohol terminations. The inspector
_ _ _ _ _ _ _ _ _
. .
13
t
has no problem with this practice. The allegation is unfounded and '
.
incorrect in regards to GPC's purpose was to evade re-inspection of the
individual's work. GPC has an adequately documented, structured, and
controlled re-inspection program applicable to all terminations due to
the Vogtle Drug and Alcohol Program. This allegation is closed.
7. General Construction Inspection - Units 1 & 2
Periodic random surveillance inspections were made throughout this reporting
period in the form of general type inspections in different areas of both
facilities. The areas were selected on the basis of the scheduled
activities and were varied to provide wide coyerage. Observations were made
of activities in progress to note defective items or items of noncompliance
,
with the required codes and regulatory requirements. On these inspections,
- particular note was made of the presence of quality control inspectors,
supervisors, and quality contrel evidence in the form of available process
'
sheets, drawings, material identification, material protection, performance
of tests, and housekeeping. Interviews were conducted with craft personnel,
supervisors, coordinators, quality control inspectors, and others as they
were available in the work areas. The inspector reviewed numerous
construction deviation reports to determine if requirements were met in the
areas of documentation, action to resolve, justification, and approval
'
signatures in accordance with GPC Field Procedure No. GD-T-01.
No violations or deviations were identified.
8. Fire Prevention / Protection and Housekeeping Measures - Unit 2 (42051C)
The inspector observed fire prevention / protection measures throughout the
inspection period. Welders were using welding permits with fire watches and
extinguishers. Fire fighting equipment was in its designated areas
throughout the plant.
1
'
The inspector reviewed and examined portions of procedures pertaining to the
fire prevention / protection measures and housekeeping measures to determine
whether they comply with applicable codes, standards, NRC Regulatory Guides
,
and licensee commitments.
l The inspector observed fire prevention / protection measures in work areas
containing safety related equipment during the inspection period to verify
the following:
-
Combustible waste material and rubbish was removed from the work areas
as rapidly as practicable to avoid unnecessary accumulation of
combustibles,
-
Flammable liquids were stored in appropriate containers and in
designated areas throughout the plant,
-
Cutting and welding operations in progress have been authorized by an
appropriate permit, combustibles have been moved away or safely
covered, and a fire watch and extinguisher was posted as required, and
. -- ----_ . . - _. .----. - _ - - . - . . - - . _- . _ -
_. . _ _
. .
14
-
Fire protection / suppression equipment was provided and controlled in
accordance with applicable requirements.
No violations or deviations were identified.
9. Structural Concrete - Unit 2 (47053C)
a. Procedure and Document Review
The inspector reviewed and examined portions of the following
procedures pertaining to the placement of concrete to determine whether
'
they comply with applicable codes, standards, NRC Regulatory Guides and
licensee commitments.
-
CD-T-02, Rev. 18 Concrete Quality Control
-
CD-T-06, Rev. 10 Rebar and Cadweld Quality Control
-
CD-T-07, Rev. 8 Embed Installation and Inspection
b. Installation Activities
The inspector witnessed portions of the concrete placement indicated
below to verify the following:
4
(1) Forms, Embedment, and Reinforcing Steel Instailation
-
Forms were properly placed, secure, leak tight and clean.
-
Rebar and other embedment installation was installed in
accordance with construction specifications and drawings,
,
secured, free of concrete and excessive rust, specified
'
distance from forms, proper on-site rebar bending (where
applicable) and clearances consistent with aggregate size.
t
(2) Delivery, Placement and Curing
-
Preplacement inspection was completed and approved prior to
placement utilizing a Pour Card (Procedure Exhibit
CD-T-02*18).
-
Construction joints were prepared as specified. >
.
-
Proper mix was specified and delivered.
J
-
Temperature control of the mix, mating surfaces, and ambient
were monitored.
-
Consolidation was performed correctly.
!
j
-
Testing at placement location was properly performed in
accordance with the acceptance criteria and recorded on a
, Concrete Placement Pour Log (Procedure Exhibit CD-T-02*20).
i
!
_ _ .. . - - - _ ___ _ _ _ _ _ _ . , _ _ __ _- _-
. .
15
-
Adequate crew, equipment and techniques were utilized.
-
Inspections during plact ;nts were conducted effectively by a
sufficient number of qualified personnel.
-
Curing methods and temperature was monitored.
(3) Rebar Splicing
The inspector witnessed cadwelding operations to verify the
following:
-
Inspections are performed during and after splicing by
qualified QC inspection personnel.
-
Each splice was defined by a unique number consisting of the
bar size, splice type, the position, the operator's symbol,
and a sequential number.
-
Process and crews are qualified.
-
The sequential number and the operator's symbol are marked on
all completed cadwelds.
The inspector also conducted random inspections of completed
cadwelds to verify the following:
-
Tap hole does not contain slag, blow out, or porous metal.
-
Filler metal was visible at both ends of the splice sleeve
and at the tap hole in the center of the sleeve. No voids
were detected at the ends of the sleeves.
-
The sequential number and the operator's symbol are marked on
all completed cadwelds.
No violations or deviations were identified.
10. Containment (Prestressing) - Unit 2 (47063C)
a. Procedure and Document Review
The inspector reviewed and examined portions of the following
specification, procedure, and drawings pertaining to the installation
of horizontal tendons, to determine whether they comply with applicable
codes, standards, NRC Regulatory Guides and licensee commitments.
- X2AF04 Technical Provisions for Containment
Post-Tensioning System
- AX2AF04-100-12 Field Instruction Manual for Installation
of VSL E5-55 Post-Tensioning System Within
Nuclear Containment Structures, Rev. 9
. .
16
b. Installation Activities
The inspector witnessed portions of the installation activities
indicated below to verify the following:
-
The latest issue (revision) of applicable drawings or procedures
are available to the installers and were being used.
-
Tendons were free of nicks, kinks, corrosion; were installed in
designated locations; and that the installation sequence and
technique was per specified requirements.
-
Installation crew was properly trained and quaiified.
-
QC inspection was properly performed by qualified personnel in
accordance with applicable requirements.
-
Adequate protective measures were being taken to ensure mechanical
and corrosion protection during storage, handling, installation,
and post installation.
-
Tendons were stressed in the proper sequence.
-
All strands in the tendon were moving together during the
stressing and the tendon is being stressed from both ends
simultaneously.
-
Elongation measurements were being taken properly and being
compared to the calculated elongation.
-
Anchor head lift-off force was being taken and documented
properly.
-
The stressing operation was being monitored to identify any strand
slippage.
- The inspector notes that containment prestressing is now complete for
Unit 2.
!
No violations or deviations were identified.
11. Containment (Steel Structures and Supports) - Unit 2 (48053C)
Periodic inspections were conducted to observe containment steel and support
installation activities in progress, to verify the following:
-
Components were being properly handled (included bending or
straightening).
! -
Specified clearances were being maintained.
-
Edge finishes and hole sizes were within tolerances.
. .
17
-
Control, marking, protection and segregation were maintained during
storage.
-
Fit-up/ alignment meets the tolerances in the specifications and
drawings.
No violations or deviations were identified.
12. Safety-Related Structures (Structural Steel and Supports) - Unit 2 (48063C)
Periodic inspections were conducted to observe construction activities of
safety-related structures / equipment supports for major equipment outside the
containment to verify that:
-
Materials and components were being properly handled to prevent damage.
-
Fit-up/ alignment were within tolerances in specifications and drawing
requirements.
-
Bolting was in accordance with specifications and procedures.
-
Specified clearances from adjacent components were being met.
No violations or deviations were identified.
13. Reactor Coolant Pressure Boundary and Safety Related Piping - Unit 2
(49053C) (49063C) (37301)
Periodic inspections were conducted to observe construction activities of
the Reactor Coolant Boundary and other safety-related piping installations
inside and outside Containments. Verifications included but were not
limited to the following:
-
Material and components were being properly handled and stored in order
to prevent damage.
-
Fit-ups and alignments were within tolerances per specifications and
drawings.
-
Specified clearances from pipe to pipe and adjacent components were
met.
-
Piping was installed and inspected in accordance with applicable
drawings, specifications, and procedures.
-
Those people engaged in the activity are qualified to perform the
applicable function.
-
Drawing and specification changes (revisions) are being handled and
used correctly.
No violations or deviations were identified.
.
.
<
18 l
14. Reactor Coolant Pressure Boundary and Safety Related Piping Welding -
Units 1 & 2 (55073C) (55083C)
Periodic inspections were conducted during daily plant surveillances on
safety-related pipe welding at various stages of weld completion. The
purpose of the inspection was i.o determine whether the requirements of
applicable specifications, codes, standards, work performance procedures and
QC procedures are being met as follows:
-
Work was conducted in accordance with a process sheet which identifies
the weld and its location by system, references procedures or
instructions, and provides for production and QC signoffs.
-
Welding procedures, detailed drawings and instructions, were readily
available in the immediate work area and technically adequate for the
welds being made.
-
Welding precedure specification -(WPS) were in accordance with the
applicable Code requirements and that a Procedure Qualification Record
(PQR) is referenced and exists for the type of weld being made. l
l
-
Base metals, welding filler materials, fluxes, gases, and insert
materials were of the specified type and grade, have been properly
inspected, tested and were traceable to test reports or certifications.
-
Purge and/or shielding gas flow and composition were as specified in
the welding procedure specification and that protection was provided to
shield the welding operation from adverse environmental conditions.
-
Weld joint geometry including pipe wall thickness was specified and
that surfaces to be welded have been prepared, cleaned and inspected in
accordance with applicable procedures or instructions.
!
- A sufficient number of adequately qualified QA and QC inspection
personnel were present at the work site, commensurate with the work in
l progress.
- The weld area cleanliness was maintained and that pipe alignment and
fit-up tolerances were within specified limits.
! -
Weld filler material being used was in accordance with welding
,
specifications, unused filler material was separated from other types
i of material and was stored properly and that weld rod stubs were
l properly removed from the work location.
!
l
-
That there were no evident signs of cracks, excessive heat input,
sugaring, or excessive crown on welds.
l
-
Welders were qualified to the applicable process and thickness, and
that necessary controls and records were in place.
No violations or deviations were identified.
!
1
. .
19
15. Reactor Vessel, Integrated Head Package, and Internals - Units 1 & 2
(50053C) (50063C)
Periodic Unit 1 inspections consisted of examinations of the Reactor Vessel,
and the installed integrated head package and the upper internals in their
designated storage area. The lower internals was installed in the Reactor
Vessel during integrated ESFAS testing.
'
The Unit 2 inspections consisted of examinations of the Reactor Vessel with
the lower internals installed and the integrated head package and the upper
internals which are stored in their designated laydown area.
Inspections also determined that proper storage protection practices were in
place and that entry of foreign objects and debris was prevented.
No violations or deviations were identified.
16. Safety Related Components - Units 1 & 2 (50073C)
The inspection consisted of plant tours to observe storage, handling, and
protection; installation; and preventive maintenance after installation of
safety-related components to determine that work is being performed in
accordance with applicable codes, NRC Regulatory Guides, and licensee
commitments.
During the inspection the below listed areas were inspected at various times
during the inspection period to verify the following as applicable:
-
Storage, environment, and protection of components were in accordance
with manufacturer's instructions and/or established procedures.
-
Implementation of special storage and maintenance requirements such as:
rotation of motors, pumps, lubrication, insulation testing
(electrical), cleanliness,etc.
-
Performance of licensee / contractor surveillance activities and
documentation thereof was being accomplished.
-
Installation requirements were met such as: proper location, placement,
l orientation, alignment, mounting (torquing of bolts and expansion
anchors), flow direction, tolerances, and expansion clearance.
-
Appropriate stamps, tags, markings, etc. were in use to prevent
oversight of required inspections, completion of tests, acceptance, and
the prevention of inadvertent operation.
Safety-Related piping, valves, pumps, heat exchangers, and instrumentation
were inspected in the following Unit 1 and 2 areas on a random sampling
l basis throughout the inspection period:
.
'
-
Residual Heat Removal Pump Rooms
-
Diesel Generator Building
- - _ . - ._. - _- _.
. .
'
20
-
Auxiliary Feedwater Pumphouse
-
Containment Spray Pump Rooms
-
Pressurizer Rooms
-
Main Coolant Pump Areas
-
Steam Generator Areas
-
Safety Injection Pump Rooms
-
RHR and CS Containment Penetration Encapsulation Vessel Rooms
-
Component Cooling Water (CCW) Heat Exchangers, Surge Tanks & Pump Rooms
-
Cable Spreading Rooms
-
Accumulator Tank Areas
-
Chemical and Volume Control System (CVCS) Letdown Heat Exchanger Pump
Room
-
Battery & Charger Rooms
-
Nuclear Grade Piping, Valves & Fittings Storage Areas
-
Spent Fuel Pool Heat Exchanger Rooms
-
Pressurizer Relief Tank Area
-
CVCS Centrifugal Charging Pumps & Positive Displacement Pump Rooms
-
Bottom Mounted Instrumentation (BMI) Tunnel and Seal Table Area
-
BMI and Supports Under Reactor Vessel
-
NSCW Tower Pump Rooms and Pipe Tunnels
-
Containment, Auxiliary Building, Control Building, and Fuel Handling
Building auxiliary (secondary) areas
No violations or deviations were identified.
17. Safety Related Pipe Support and Restraint Systems - Units 1 & 2 (50090C)
Periodic random inspections were conducted during the inspection period to
observe construction activities during installation of safety-related pipe
supports to determine that the following work was performed in accordance
with applicable codes, NRC Regulatory Guides, and licensee ccmmitments:
-
Spring hangers were provided with indicators to show the approximate
" hot" or " cold" position, as appropriate.
-
No deformation or forced bending was evident.
-
Where pipe clamps are used to support vertical lines, shear lugs were-
l welded to the pipe (if required by Installation Drawings) to prevent
i
slippage.
-
Sliding or rolling supports were provided with material and/or
i lubricants suitable for the environment and compatible with sliding
contact surfaces.
-
Supports are located and installed as specified.
-
The surface of welds meet applicable code requirements and are free
i from unacceptable grooves, abrupt ridges, valleys, undercuts, cracks,
l discontinuities, or other indications which can be observed on the
!
welded. surface.
l
No violations or deviations were identified.
l
3 . __ _
_ -- ,_ ._. _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _
.
21
18. Electrical and Instrumentation Components and Systems - Units 1 & 2 (51053C)
(52153C)
Periodic inspections were coaducted during the inspection period to observe
safety-related electrical equipment in order to verify that the storage,
installation, and preventive maintenance was accomplished in accordance with
applicable codes, NRC Regulatory Guides, and licensee commitments.
During the inspection period inspections were performed on various pieces of
electrical equipment during storage, installation, and cable terminating
phase in order to verify the following as applicable:
-
Location and alignment
-
Type and size of anchor bolts
-
Identification
-
Segregation and identification of nonconforming items
-
Location, separation and redundancy requirements
-
Equipment space heating
-
Cable identification
-
Proper lugs used
-
Condition of wire (not nicked, etc.), tightness of connection
-
Bending radius not exceeded
-
Cable entry to terminal point
-
Separation
No violations or deviations were identified.
19. Electrical and Instrumentation Cables and Terminations - Units 1 & 2
(51063C) (52063C)
a. Raceway / Cable Installation
The inspector reviewed and examined portions of the following
procedures pertaining to raceway / cable installation to determine
whether they comply with applicable codes, NRC Regulatory Guides and
licensee commitments.
-
ED-T-02, Rev. 10 Raceway Installation
-
ED-T-07, Rev. 11 Cable Installation
Periodic inspections were conducted to observe construction activities
of Safety Related Raceway / Cable Installation.
In reference to the raceway installation, the following areas were
inspected to verify compliance with the applicable requirements:
-
Identification
-
Alignment
-
Bushings (Conduit)
-
Grounding
-
Supports and Anchorages
. .- .
..
____ ___. __ _ _ _ _}
__
.
. .
22
In reference to the cable installation the following areas were
inspected to verify compliance with the applicable requirements:
-
Protection from adjacent construction activities (welding, etc.)
-
Coiled cable ends properly secured
-
Non-terminated cable ends taped
-
Cable trays, junction bcxes, etc., reasonably free of debris
-
Conduit capped, if no cable installed
-
Cable supported
-
Bend radius not exceeded
-
Separation
b. Cable Terminations
The inspector reviewed and examined portions of the following
procedures pertaining to cable termination to determine whether they
comply with applicable codes, NRC Regulatory Guides and licensee
commitments.
-
ED-T-08, Rev. 9 Cable Termination
In reference to cable terminations the following areas were inspected
to verify compliance with the applicable requirements.
-
Cable identification
-
Proper lugs used
-
Condition of wire (not nicked, etc.)
-
Tightness of connection
-
Bending radius not exceeded
-
Cable entry to terminal point
-
Separation
- No violations or deviations were identified.
20. Containment and Safety Related Structural Steel Welding - Units 1&2
(55053C) (55063C)
Periodic inspections were conducted during daily plant surveillances on
safety-related steel welding at various stages of weld completion.
The purpose of the inspection was to determine whether the requirements of
applicable specifications, codes, standards, work performance procedures and
QC procedures are being met as follows:
-
Work was corducted in accordance with a process sheet or drawing which
identifies the weld and its location by system, references, procedures
or instructions, and provides for production and/or QC signoffs.
-
Welding procedures, detailed drawings and instructions, were readily
available in the immediate work area and technically adequate for the
welds being made.
.- , - - . --- . - -.-. - -. .-. .. .. - . .- , -
. .
23
-
Welding procedure specification (WPS) were in accordance with the
applicable Code requirements and that a Procedure Qualification Record
(PQR) is referenced and exists for the type of weld being made.
-
Base metals and welding filler materials were of the specified type and
grade, were properly inspected, tested, and were traceable.
-
Protection was provided to shield the welding operation from adverse
environmental conditions.
-
Weld joint geometry including thickness was specified and that surfaces
to be welded were prepared, cleaned and inspected in accordance with
applicable procedures or instructions.
-
A sufficient number of adequately qualified QA and QC inspection
personnel commensurate with the work in progress were present at the
work site.
-
Weld area cleanliness was maintained and that alignment and fit-up
tolerances were within specified limits.
-
Weld filler material -being used was in accordance with welding
specifications, unused filler material was separated from other types
of material and was stored and controlled properly, and stubs were
properly removed from the work location.
-
There were no visual signs of cracks, excessive heat input, or
excessive crown on welds.
-
Welders were qualified to the particular process and thickness; and
that necessary controls and records were in place.
No violations or deviations were identified.
21. Preoperational Test Program Implementation / Verification - Unit 1 (70302)
(71302)
The inspector reviewed the present implementation of the preoperational test
program. Test program attributes inspected included review of
administrative requirements, document control, documentation of major test
events and deviations to procedures, operating practices, instrumentation
calibrations, and correction of problems revealed by testing.
Periodic inspections were conducted of Control Room Operations to assess
plant condition and conduct of shift personnel. The inspector observed that
Contr'sl Room operations were being conducted in an orderly and professional
ma n r.e r. Shift personnel were knowledgeable of plant conditions, i.e.,
orgoing testing, systems / equipment in or out of service, and
alarm / annunciator status. In addition, the inspector observed shift
turnovers on various occasions to verify the continuity of plant testing,
operational problems and other pertinent plant information during the
- turnovers. Control Room logs were reviewed and various entries were
l discussed with operations personnel.
l
.- - - . .-- - . - - - - . . - . . - - - - - -
.- .-
.
. .
!
24
Periodic facility tours were made to assess equipment and plant conditions,
maintenance and preoperational activities in progress. Schedules for
program completion and progress reports were routinely monitored.
Discussions were held with responsible personnel, as they were available, to
determine their knowledge of the preoperational program. The Inspector
reviewed numerous operation deviation reports to determine if requirements
were met in the areas of documentation, action to resolve, justification,
corrective action and approvals. Specific inspections conducted are listed
below:
a. Preoperational Tests
(1) Test Procedure Review (70300)
The inspector reviewed the following listed preoperational test
procedures. Each test was reviewed for administrative format and
technical adequacy. The procedures were compared with licensee
commitments from the applicable FSAR Chapters, Regulatory Guide
1.68 and the Safety Evaluation Report (NUREG-1137). This included
verifying that pertinent prerequisites were identified, initial
test conditions and system status were specified, acceptance
criteria were specified and management approval indicated:
NRC
Procedure No. Inspection No. Test Title
1-300-01 70304 Integrated Safeguards and
Load Sequencing Test
1-3PK-02 70340 Battery Test IE
(2) Test Witnessing (70312)
l
l
The inspector witnessed selected portions of the following
l preoperational test procedures as they were conducted. The
l inspection included attendance at briefings held by the test
i supervisor to observe the coordination and general knowledge of
'
the procedure with the test participants. Overall crew
performance was evaluated during testing. A preliminary review of
the test results was compared to the inspector's own observations.
t Problems encountered during performance of the test were verified
i to be adequately documented, evaluated and dispositioned on a
j selected basis.
NRC
Procedure No. Insp. No. Test Title Activity Observed
i 1-300-01 70315 Integrated Safe- Train "A" Single
!
70316 guards and Load Train Test
! Sequencing Test Consisting of '
Response to ESFAS
With DG in Test Mode,
Response to LOSP in
!
l
- . _
. .
25
Conjunction with
ESFAS, Response to
Reset to ESFAS,
Stopping the Largest
Single Load, & DG
100% Load Rejection,
Per Steps 6.1-6.1.49
Train "A" Single
Train Test Consisting
of Tripping DG After
24 Hour Test,
Response to LOSP,
Interrupted by ESFAS,
Response to LOSP,
Response to LOSP and
SI, Simulated Loss of
Onsite Power and
Response to Reset to
Steps
'
ESFAS Per
6.1.58-6.1.116
1-3BC-01 70436 Residual Heat RHR System
Removal System Performance
Preoperational During Filling &
Test Draining the
Reactor Cavity
Per Section 6.19
'
1-3PK-02 70440 Battery Test IE First Discharge
Test Results
I
b. Followup of Event Occurring During Testing
The inspector followed up on the following events which occurred during
the inspection period:
(1) RHR Train "B" pump failed to start on 11/17/86 when attempting to
- start it for the performance of filling and draining the reactor
'
cavity per Section 6.19 of Preop 1-3BC-01.
(2) CCP Train "A" failed to start on 11/18/86 when attempting to start
it to verify proper flow path alignment as a prerequisite to ESFAS
Single Train "A" testing.
(3) 480 Volt switchgear 18806 failed to close in on 12/11/86 during
restoration from a Train "B" switchgea- outage. It was determined
! that all of the above safety-related equipment failed to operate
properly due to the breaker charging spring not being charged.
- The Gould Brown Boveri ITE Switchgear requires a manual operation
l
i
!
i
.,. . ._ , _ . - _ _ ,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
26
by the operator to ensure the breaker charging spring is charged.
Operations Procedure 13435-C (Circuit Breaker Racking Precedure)
contains a step for the operator to ensure that the charging motor
power control switch is in the on position and that the charging
spring spring charged indicator is visible during the racking in
process. The licensee has formed a task force to evaluate this
problem so as to determine whether there is a hardware or operator
problem with properly racking in these breakers since there have
been several occurrences of these breakers not being properly
racked in. The Resident Inspectors will continue to follow this
item.
No violations or deviations were identified.
22. . Plant Procedures - b.it 1 and 2 (42400B)
This inspection consists of a procedural review to verify that
administrative controls are established and implemented to control safety
related operations. Procedures are selected at random and reviewed for
technical adequacy and incorporation of requirements as appropriate for the
proper operation of a nuclear facility in the startup and operational phase.
The following requirements, guidance and licensee commitments were utilized
as appropriate:
- 10 CFR 50.59 Change, Tests, and Experiments
- 20 CFR 50 Appendix B Instructions, Procedures and Drawings
Criteria V
- ANSI N18.7-1976 Administrative Controls and Quality
Assurance for the Operational Phase
- Regulatory Guide 1.33 Quality Assurance Requirements for the
Rev 2, 1978 Operational Phase of Nuclear Power Plants
- FSAR Section 13 Conduct of Operations
- NUREG 0737, et al TMI Task Action Plan
No violations or deviations were identified.
23. Three Mile Island Task Action Plan Followup - Unit 1 (425401B)
This inspection consists of verification that the licensee has implemented
the requirements of NUREG 0737, " Clarification of TMI Action Plan
Requirements" as committed to in the facility FSAR or other appropriate
documents. Verification consisted of one or more of the following
attributes, as appropriate, to determine acceptability for each listed
action item:
-
Program or procedure established
-
Personnel training or qualification
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Completion of item
-
Installation of equipment
-
Drawings reflect the as-built configuration
-
Component tested and in service or integrated into the preoperational
test program
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The following documents were utilized in performing the review, as
appropriate:
NUREG 0578 TMI-2 Lessons Learned Task Force Status Report
NUREG 0660 NRC Action Plan Developed as a Result of the
TMI-2 Accident
NUREG 0694 TMI-Related Requirements for New Operating Licenses
NUREG 0737 and Clarification of TMI Action Plan Requirements
Supplement 1
FSAR thru Final Safety Analysis Report
Amendment 29
NUREG 1137 and Safety Evaluation Report
Supplements
(Closed) I.A.1.1 " Shift Technical Advisor." This item addresses the
specific requirements to provide an on-shift technical advisor (STA) to the
shift supervisor. Section 6.2.4 of the final draft of the Technical
Specifications incorporates this function into the operating staff. Final
Safety Analysis Report Section 13.2.2.1.6 defines the STA training program
which has been reviewed by NRR and found to be acceptable (See SER Section
13.2.2.2). The inspector reviewed Operations Procedure 11955-C, Shift
Technical Advisor Qualification Checklist, Training Procedure 60603 and
various other training prccedures discussing STA training requirements, and
discussed STA training with training personnel. This inspection identified
that the requirements of the FSAR have been incorporated into the STA
training program with one minor exception. This exception was that the FSAR
commits the STA's will obtain 4 weeks of hot participation experience at the
same type of plant prior to fuel load whereas the training procedures
commits to obtaining this experience prior to exceeding 20's of full power.
The training manager stated the training procedure will be changed to
reflect the requirements of the FSAR. The inspector considers this item is
closed for Units 1 and 2.
(Closed) I.A.1.2 " Shift Supervisor Administrative Duties." This item was
addressed in Inspection Report 50-424/86-51 and 50-425/86-23. The
administrative duties of the Shift Supervisor is detailed in F rocedure
10000-C Conduct of Operations. Revision 2 of Procedure 10000-C was reviewed
4 by the inspector. Although the attributes listed in Section 2.7 were stated
to be specific duties and responsibilities, the functions were performed by
other personnel with overview activities being performed by the Shift
Supervisor. The inspector discussed with several operations shift
supervisor personnel, the administrative requirements associated with this
function. None indicated that the administrative tasks being performed were
a problem and was above and beyond the requirements generally performed as
shift supervisor activities. Vogtle is establishing an additional shift
position designated as " common shift supervisor" who will be responsible to
assist the shift supervisor in some previous functions performed by the
shift supervisor. Based on this review Item I.A.I.2 is closed for both
units. In addition IFI 86-51-03 is closed since 86-51-01 addresses the
management directive discussed in this IFI.
(Closed) I.A.1.3 " Shift Manning - Limit Overtime and Establish Minimum
Shift Crew." The requirement was previously inspected in NRC Repert
50-424/86-31 where one IFI was identified to review the applicable procedure
1
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against TS. IFI 50-31-05 is closed in Paragraph 22 of this report.
(0pened) IFI 50-424/86-111-03 is identified to track one comment regarding a
revision to Procedure 00005-C to add general words concerning minimizing the
use of overtime " Review Revision 00005-C Regarding Overtime Minimizing".
(Closed) I.C.1 " Guidance for the Evaluation and Development of Procedures
for Transients and Accidents." This item was reissued in Generic Letter
No. 82-33 dated December 17, 1982. In a letter dated May 1, 1984, the
licensee submitted a procedures generation package. This submittal was
reviewed by NRR and is addressed in SER Section 13.5.2.1.2. The NRR review
identified a confirmatory item (Item 44) which was resolved in SSER #2. NRR
has concluded that the guidance is adequate for the development of Emergency
Operating Procedures. Based on this review this item is closed for Units 1
and 2.
(Closed) 1.C.3 " Shift Supervisor Responsibilities". This item was
addressed in Inspection Report Nos. 50-424/86-51 and 50-425/86-23. In that
report, this item could not be closed and Inspector Followup Item (IFI)
86-51-01; Review Licensee Action for TMI Item I.C.3 was opened. This IFI
was open pending a review of a corporate management directive or other
appropriate directive, resolution of the succession of responsibility chain
between the FSAR and Procedure 00001-C, and completion of NRC review. A
management directive issued specifically to all Nuclear Operations personnel
from the General Manager of Vogtle Nuclear Operations (GMVNO), dated
December 8, 1986, emphasizing the OSOS responsibilities as dictated in
Administrative Procedures and stating a review of these procedures were
required. A process has been established to reissue this directive on an
annual basis. This closes Item I.C.3 for Units 1 and 2 and closes IFI
50-424/86-51-01.
(Closed) I.C.4 " Control-Room Access." This item was addressed in
Inspection Report No. 50-424/86-51 and 50-425/86-23. In that report, this
item could not be closed and Inspector Followup Item (IFI) 86-51-02: Review
Licensee Action for TMI Item I.C.4 was opened pending a re/iew of procedures.
which describe the At-The-Controls areas and a clarification in procedures
for predesignated NRC personnel. The inspector reviewed procedures 00301-C,
Main Control Room Access and Personnel Conduct dated 12/2/86; 10000-C,
Conduct of Operations, dated 10/8/86; and 10003-C, Hanning the Shift, dated
9/11/86. This review indicated that predesignated NRC personnel access to
the control room is addressed in Procedure 00301-C and the figures contained
in the above procedures are consistent in their description of the AT-The
Controls area. Based on this review, Item I.C.4 is closed for Unit 1;
however, IFI 424/86-51-02 will remain open pending the license completion of
proposed procedure changes to address the original freedom of access
concerns for the NRC Resident Inspectors.
(Closed) I.C.5 " Procedures for Feedback of Operating Experience to Plant
Staff". The NRC staff has reviewed the proposed administrative requirements
as discussed in SER Section 13.5.1 and found them to be acceptable. The
inspector reviewed Procedure 00414-C, Operations Assessment Program dated
10/23/86 and 80009-C, Operations Assessment Program Coordination dated
11/7/86. Based on this review this item is closed for Units 1 and 2.
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(Closed) I.C.8 " Pilot Monitoring of Selected Emergency Procedures for
NT0L' s" . This item is addressed in SER Section 13.5.2.1 and states that
this item is no longer necessary because the staff has approved the
Westinghouse ERGS, and the applicant has committed to develop E0Ps based on
the Westinghouse ERGS. Based on this SER review this item is closed for
Units 1 and 2.
(Closed) II.D.3 " Valve Position Indication". This item was inspected in
NRC Report 50-424/86-60. The inspection resulted in Violation
50-424/86-60-01. This TMI item is considered closed pending completion of
corrective actions associated with the violation.
(Closed) II.B.1 " Reactor Coolant System Vents". This item involves the
installation of reactor coolant system and reactor head high point vents
remotely operated from the control room. FSAR Section 5.4.15 describes the
conformance of the vent system and valve configuration to the requiremencs
of NUREG 0737. SER Section 5.4.12 discussed conformance with the
requirements and NRR concludes the system is acceptable. A walkdown of the
head vent system and piping, including the valve position indication in the
control room was conducted. Reviewed P&ID's IX4DB111, 1X4DB112 and
1X4DB114. Reviewed Procedures 13001-1, 19221-1, 19241-1, 19261-1, 19263-1,
14725-1, and 1-388-01. The inspector had noted a problem regarding
Technical Specification 3.4.11, Reactor Coolant System Vents where the
applicant had only included two of the three remotely operated valves. In
the applicant's November 14, 1986 submittal this item was corrected.
(Closed) II.E.4.1 " Dedicated Hydrogen Penetrations". This item requires
containment penetrations for plants using external recombiners. An
acceptable alternative is a combined design that is single-failure proof for
containment isolation purposes and single-failure proof for operation of the
recombiners or a purge system. SER Section 6.2.5 addresses " Con.bustible Gas
Control in Containment" and NRR concludes that the hydrogen recombiners and
purge systems are acceptable. Walkdowns of the recombiners and purge
system, including the recombiner control panels were performed. Procedures
13130-1, 1-3GS-01, and 1-3GS-02 were reviewed.
(Closed) II.E.3.1 " Emerge / Power for Pressurizer Featers". This item
addresses having the cap 2~ility to supply a predetermined number of
pressurizer heaters from either the offsite power source or the emergency
power source. FSAR Section 5.4.10.3.1 describes conformance to the
requirements, and SER Section 8.4.9 has NRR acceptance of the provisions of
the FSAR Section. A walkdown of electrical buses INB01, INB10, IAA02, and
1BA03 to identify where operators would be required to perform transfer of
power was performed. Preoperationa' test procedures 1-3BB-01 and 1-38B-05
were reviewed.
(0 pen) II.F.1.2A " Noble Gas Monitor"
.2B " Iodine / Particulate Sampling"
.2C " Containment High-Range Monitor"
These items are the responsibility of another NRC section. These items
require the installation of specific instrumentation. A walkdown of the
Plant Vent Stack Monitor, Containment Vent Monitor, Containment Atmosphere
. .
30
Monitor, Turbine Building Exhaust Monitor, and the Containment High-Range
Monitors was performed. Procedure 14000-1 was reviewed. Preoperational
test procedures have not been completed at this time. These items will
remain open until closed by responsible sections.
(0 pen) II .F.1.2.D " Accident Monitoring - Containment Pressure". This item
addresses having continuous indication of containment pressure. SER Section
7.5.2.2 contains NRR's acceptance of the system for conformance. A walkdown
of the extended range containment pressure system, including the plasma
display on the control board was performed. Reviewed procedures 14228-1 and
1-3RP-03. This item will remain open until the preoperational test 1-3RP-03
has been completed demonstrating proper instrument performance.
(Open) II .F.1.2.E " Accident Monitoring - Containment Water Level Monitor".
This item requires continuous indication of containment water level in the
control room. A walkdown of the containment water level indicating system,
including the level transmitters was performed. Reviewed procedures
14000-1, 14228-1 and 1-3RP-03. This item will remain open until the
preoperational test 1-3RP-03 has been completed demonstrating proper
instrument performance.
(0 pen) I I . F.1. 2. F " Accident Monitoring - Containment Hydrogen Monitor".
This item discusses having a continuous indication of hydrogen concentration
in the containment atmosphere. The system must be capable of providing
continuous monitoring within 30 minutes of the initiation of safety
injection. A walkdown of system, including the hydrogen monitoring control
panels and control room indications was performed. Procedures 14000-1,
1-3GS-01, 1-3GS-02 and 1-3RP-03 were reviewed. This item will remain open
until the preoperational test procedures have been completed demonstrating
proper system performance.
(Closed) III . A.1.2 " Upgrade Emergency Support Facilities" This item is
i being closed by direction of the Emergency Preparedness Section based on
l extensive reviews during inspections as documented in the following reports
! 50-424/86-12 and 50-425/86-18; 50-424/86-29 and 50-425/86-14; and
!
50-424/86-112 and 50-425/86-51. This item is closed for both units.
i
(Closed) III.D.1.1 " Integrity of Systems Outside Containment Likely to
Contain Radioactive Material." This TMI-2 Action Plan requires that the
licensee shall implement a program to reduce leakage from systems outside
containment that would or could contain highly radioactive fluids during a
! 9.3.4.1.3.5 and 12.1.3 describes the licensee's commitment to have a program
to reduce leakage from licensee's systems . outside containment. NRR has
reviewed the FSAR submitted and subsequent licensee correspondence which
documents the licensee's intent to implement a program to reduce leakage
from systems outside containment. This item was found to be acceptable to
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the staff as documented in Section 11.5.3 of Supplement No. 3 to the SER
with the exception for the leak rate test results. A license condition was
identified in Supplement No. 3 to the SER in Section 11.5.3 stating that the
applicant must provide the leak rate test results before 5% power is
exceeded.
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I
The inspector conducted a review of the licensee's leakage assessment
program for compliance with the FSAR, subsequent correspondence, and Section
6.7.4 (a) of the VEGP Final Draft of Technical Specifications. The
following procedures were reviewed:
Procedure No. Title
50024-C Leakage Assessment Program
55010-1 Containment Spray System Leakage Assessment
55011-C CVCS Leakage Assessment
55012-1 Residual Heat Removal System Leakage Assessment
55013-1 Gaseous Waste Processing System Leakage Assessment
55014-1 Nuclear Sampling System Leakage Assessment
55015-1 Post Accident Sampling System - Liquid
55016-1 Safety Injection System Leakage Assessment
The inspector had the following comments regarding the above procedures:
1) The data sheets which identified areas in the system to check for leakage.
did.not reflect the latest system configuration, and 2) The data sheets did
not reflect a check for leakage assessment on the entire suction and return
lines to the RWST on the Containment Spray, Safety Injection and Residual
Heat Removal System. Discussions were held with the Engineering Department
Mechanical Discipline Supervisor responsible for developing and implementing
the Leakage Assessment Program. The procedures are currently undergoing a
revision to update them as a result of a physical field walkdown to verify
that the procedure can be used and that it reflects the latest configuration
as shown on the piping and instrument drawing. The licensee has committed
to review and resolve the inspector's comments as appropriate.
The licensee intends to perform these leakage assessment procedures to
collect system baseline leakrate data during the power ascension test phase
prior to achieving 5% rated thermal power.
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Based on the above review the inspector has determined that the licensee has
,
developed a sai ~. sf actory leakage assessment program and therefore when
properly implemented the requirement of NUREG-0737, Item III.D.1.1, will be
met. This item is closed for both units.
j, 24. Followup of Reportable Items - Units 1 & 2 (92700)
This inspection was conducted to determine whether the items have been
received by the licensee, evaluated and corrective action taken, where
appropriate. The inspector utilized discussions with cognizant personnel
and review of applicable documentation, and field verification as a basis
for closure of each item.
[ (Closed) 50-424/50-425 CDR 85-87 " Damage to Internal Wiring By Space
Heaters in Limitorque Valve Motor Operators." The applicant determined this
item to be reportable in a March 20, 1986 letter. The Bechtel Power
Corporation Final Engineering Evaluation Report dated February 28, 1986, was
reviewed. The space heaters and their associated wiring are not required to
perform or support the performance of a safety function, however, there was
evidence that damage had occurred to the safety related motor power leads.
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Damage to these power leads could render the motors inoperable, thereby
preventing the associated valve from performing the. intended safety
function. The results of the evaluation indicated that had this condition
gone uncorrected, it could have impacted the safety of the plant. In order
to prevent potential damage to the power leads of the Class IE Limitorque
motor operators, the applicant stated in letters to the dated November 18,
1985 and dated March 20, 1986, that the permanent power circuits to the
space heaters will be disconnected and as the circuits are disconnected,
existing internal wiring will be checked for damage and will be repaired or
replaced as necessary. Upon review of the documentation for CDR 85-87 the
inspector was unable to verify that the internal wiring was checked as
required. The applicant's further review of the corrective action indicated
that the work had been done, but documentation could not be located. The
inspector then selected seven of these valves containing the Limitorque
Motor Operators from Unit 1 for inspection. Assistance was requested from
Electrical Maintenance and Quality Control Personnel. During the inspection
two of the seven Limitorque Motor Operators were found to have burn damage ,
to the motor operator power leads. The applicant, in response to this NRC
finding, formed a task force to review the documentation and direct
re-inspections as appropriate. Re-inspections were performed on 110
operations with no further identification of burned power leads.
Documentation of positive QC inspections were located for an additional 47
valves, 10 are planned for inspection. Four valves contained within the
encapsulation vessels will not be inspected due to the lack of finding any
burned wire and access difficulty associated with these valves.
Until the results of inspections can be reviewed this item will remain
unresolved and identified as Unresolved Item 50-424/86-111-01, " Review
Inspection Results of the Licensee's Inspection of Burn Damage on Limitorque
Operator Power Leads".
(Closed) 50-424/50-425 CDR 86-93 " Process and Root-Vent-Drain Valves".
This item concerns a reportable condition where valves may not have been
installed in accordance with the design requirements defined in the Valve
Designation list as described in the GPC letter dated October 23, 1985. The
applicant kept the resident inspector apprised of this item thru routine
meetings. Bechtel evaluation DER-113 was reviewed. Documentation
demonstrated that work was completed.
25. IE Circular Program - Units 1 & 2 (92701)
This inspection consisted of a review of the IE Circular Program as defined
in VEGP Project Policy and Procedures Manual Section 7.7. The inspector
reviewed a random sample of previously issued circulars to determine if the
circulars were reviewed, if appropriate action was taken, if the results
were documented and maintained. All outstanding IE Circulars are considered
closed based on this programmatic review.
One problem was noted with Circular 77-CR-15 (Degradation of Fuel Oil to the
Emergency Diesel Generator). Upon inspecting actions regarding this
circular the inspector determined that zinc was used to coat the inside
surface of the diesel fuel oil storage tanks. Circular 77-CR-15 states that
zinc could degrade diesel engine performance by affecting the fuel. Further
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33
investigation revealed that NRR is aware of this discrepancy as stated in a
letter to Richard Conway of GPC from B. J. Youngblood of NRR, dated
November 21, 1986. This item will receive followup as part of the closeout
action associated with the license condition to be established by NRR.
No violations or deviations were identified.
26. Safety Committee Activity - Units 1 & 2 (40301)
.This inspection consisted of a review of the on-site and off-site safety
review committees to determine if they have been properly established and
functioning. The following requirements, guidance and licensee commitments
were utilized as appropriate:
-
10 CFR 50.59 Change, Tests, and Experiments
-
ANSI N18.7-1976 Administrative Controls and Quality
Assurance for the Operational Phase
-
Regulatory Guide 1.33 Quality Assurance Requirements for the
Rev 2, 1978 Operational Phase of Nuclear Power Plants
-
FSAR Section 13.4.1 Final Safety Analysis Report -
thru Amendment 27 Operational Reviews
-
NUREG 1137 and Safety Evaluation Report
Supplements
-
Draft Technical Section 6.4, Review and Audit
Specification
a. Plant Review Board (PRB)
This review included attendance at two PRB meetings and review of the
meeting minutes for the last 90 days. Administrative procedure 00002-C
Rev. 4, " Plant Review Board - Duties and Responsibilities" and pending
changes were reviewed against appropriate commitments. This review was
to determine if the following had been established:
(1) Responsibilities and authorities
(2) Review group membership
(3) Method and responsibility for designating alternate members
(4) Quorum requirements
(5) Meeting frequency
(6) Requirements for minutes
(7) Lines of communication with other review
l (8) The written program requires review of Technical Specification Section 6.4 items
,. _ , _ _ _ _ _ . , _ . ._ _ ._. . ._ _ . . _ _ - . _ . ,
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34
The following items were identified during the above inspection and
forwarded to NRR for resolution where Technical Specifications were
involved:
(1) Group membership had exceeded the allowed six members by the
addition of memoers from other departments and by designating two
members to represent operations. This item would be allowable by
the Final Draft Technical Specification (DTS).
(2) Membership Designation has been performed by the Chairman and not
by the GMVNO as required by DTS.
(3) Procedure 00002-C, Rev. 4 did not reflect the DTS accurately. The
licensee stated that the Final Draft Technical Specification would
be reconciled and incorporated.
Inspector Followap Item 50-424/86-111-02, " Review PRB Procedure for
Proper Incorporation of Technical Specifications". This item will be
reviewed post fuel load.
b. Safety Review Board (SRB)
This inspection ccnsisted of a review between the Final Draft Technical
Specifications and the procedures established to implement the
requirements. The following procedures were reviewed:
NOP-10-400 Safety Review Board 5/23/86
NOI-10-401 Conduct of the Nuclear Safety Review Board
Meetings 5/23/86
NOI-10-402 SRB Review of Documentary Material 8/15/86
NOI-10-403 Processing of SRB Material 5/23/86
NOI-10-404 SRB Records Retention and Handling 5/23/86
NOI-10-405 SRB Subcommittees 5/23/86
NOI-10-406 SRB Conduct on Onsite Reviews and Audits 8/15/86
In reviewing NOP 10-400, the inspector noted a caveat which states that
until the Technical Specification (TS) proposals between Hatch and
Vogtle are resolved, that the appropriate Plant TS will be the
controlling requirement. The applicant intends to standardize the SRB
administrative requirements between sites.
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The activities of the SRB will be further inspected after licensing.
- No violations or deviations were identified.
27. Management Meetings - Unit 1 (30702)
On December 12, 1986, the resident inspectors and members of the Region II
staff participated with Commissioner Carr and his aide in a GPC presentation
,
and site tour.
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