ML20207K601
| ML20207K601 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/18/1986 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207K558 | List: |
| References | |
| 50-424-86-110, 50-425-86-49, NUDOCS 8701090463 | |
| Download: ML20207K601 (20) | |
See also: IR 05000424/1986110
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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' REGION 11
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101 MARIETTA STREET, N.W.
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/ TLANTA, GEORGI A 30323
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Report Nos.: 50-424/86-110 and 50-425/86-49
Licensee: Georgia Power 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
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Inspection Cond
ed: November 3-7 and November 17-21, 1986
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Inspector: /
M
M. Mr 686
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E. H. Gi ra
Date Signed
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Approved by:
r J . 'J E}(p#($ectio
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Date SiQned
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at fals and Pr e
Section
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Div sion of
or Safety
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SUMMARY
Scope: This routine, announced inspection was conducted on-site in the areas of '
licensee actions on previous enforcement matters (Units 1 and 2), reactor coolant.
loop piping (Unit 2), concerns regarding deviation reports, licensee identified
items (Units 1 and 2), and inspector followup items (Units 1 and 2).
Results: No violations or deviations were identified.
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8701090463 861218
ADOCK 05000424
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
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- R. E. Conway, Senior Vice President and Project Director
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- P. D. Rice, Vice President of Project Engineering
- E. D. Groover, Quality Assurance (QA) Site Manager - Construction
- G. A. McCarley, Project Compliance Coordinator -
H. W. Swain, Mechanical Quality Control (QC) Section Supervisor
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- C. W. Hayes, Vogtle QA Manager
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E. M. Dannemiller, Technical Assistant to General Manager of
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Vogtle Nuclear Operations
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D. M. Fiquett, Unit 2 Construction Manager
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W. E. Burns, Nuclear Licensing Manager
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H. Pinson, Vice President of Construction
- L. B. Glenn, Manager of Quality Concerns
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W. R. Hinz,. Level III, Ultrasonic Examiner
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, mechanics, security force members, and
office personnel.
Other Organizations
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F. B. Marsh, Bechtel Power Corporation (BPC), Project Engineering Manager
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J. M. Carson, BPC, QA Manager
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- R. C. Sommerfeld, BPC, Readiness Review Staff
- P. R. Thomas, BPC, Readiness Review Staff
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R. Andrews, BPC, Readiness Review Staff
R. Carrion, BPC, Design Engineer
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J. F. Miller, Pullman Power Products (PPP), QA Manager
O. Batum, Southern Company Services (SCS), Deputy to Vice President
of Engineering
H. Brumitt, PPP, Training Officer
H. Derow, BPC, Engineer
R. Case, BPC, Codes Engineer
R. Freedy, BPC, Project Field Engineering (PFE) Technical Specialist
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N. Niehoff, BPC, Civil Structural Deputy Engineering Group Supervisor
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NRC Personnel
- J. F. Rogge, Senior Resident Inspector - Operations
- H. Livermore, Senior Resident Inspector - Construction
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R. Schepens, Resident Inspector - Operations
R. E. Johnson, Metallurgist, Office of Nuclear Reactor Regulation
(Member of Committee responsible for ASTM E399, Standard Test Method
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for Plane-Strain Fracture Toughness Testing of Metallic Materials)
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- h tended exit interview
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2.
Exit Interview
The inspection scope and finnings were summarized on November 21, 1986, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
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The licensee did not identify as proprietary any of the materials provided
to or reviewed by the insoector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
a.
(Closed) Unresolved Item (424,425/83-02-01):
Construction Deficiency
Reporting.
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This item identified the NRC inspector's concern with regard to the
licensee's reporting of construction deficiencies in accordance with
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In reviewing construction deficiency reports (CDRs)
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that had been submitted to the NRC by the licensee, the inspector had
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previously found that the reports did not always identify the causes of
the deficiencies or indicate that evaluations had been performed to
assure that the full extent of the deficiencies had been determined and
corrected. 10 CFR 50.55(e) requires the licensee to provide sufficient
information in the report to permit analysis and evaluation of the
deficiency and of the corrective action taken. Without any information
as to cause or any indication of an evaluation to assure that the full
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extent of the deficiency was determined, the report does not comply
with the 10 CFR 50.55(e) requirement.
During the current NRC inspection, the inspector reviewed three CORs
which the licensee found reportable (per 10 CFR 50.55(e)).
These
CORs are described in paragraph 7 below and are identified 424, 425
CDR 83-46, 85-88, and 86-112.
The inspector examined these CORs to
determine if the licensee described the causes of the deficiencies
or described evaluations to assure that the full extent of the
deficiencies were determined and that the corrective actions (including
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those to preclude repetition) were adequate. The inspector found that
in no case did the licensee describe the root cause. Further, they did
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not describe actions taken, in response to the root cause, to assure
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that the full extent of the deficiency was identified and corrected
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and that repetition would be precluded.
The licensee's reporting,
therefore, did not provide all of the information required by 10 CFR
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50.55(e).
To evaluate the safety significance of the licensee's
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actions, the inspector examined the licensee's internal documentation
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of the conditions described in the CORs and found that the cause
appeared adequately documented and that the corrective actions appeared
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adequate. As the deficiency in the ifcensee's reporting of the CDRs
did not appear to represent a safety significant deficiency in their
documentation or their corrective actions the inspector determined that
the matter would be considered closed on the basis of insufficient
safety significance.
b.
(Closed) Unresolved Item (424/83-13-09): Control of Field Memos Which
Affect Inspection Acceptance Criteria.
This item identified a concern that the licensee was disseminating
information identified as inspection criteria by means other than
controlled procedures. A similar matter was identified in Inspector
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Followup Item 424, 425/84-05-09, which expressed concern that the
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licensee had been using verbal instructions and memos to clarify QC
criteria.
Both of the above items appeared to principally involve
means being used by the licensee to clarify acceptance criteria for
pipe supports being installed by Pullman Power Products (PPP).
During the current inspection, the NRC inspector examined the concerns
with regard to Unresolved Item 424/83-13-09 and Inspector Followup Item
424, 425/84-05-09 as follows:
(1) The principal NRC inspector who performs routine inspections of
pipe supports was questioned regarding the adequacy of the support
inspection criteria that has been utilized by the licensee.
(2) Two PPP QC inspectors were questioned as to the adequacy of their
current inspection procedures and of the installed supports.
(3) The NRC inspectors who participated in NRC evaluations of the
licensee's reviews of the adequacy of their pipe supports
(described in licensee Readiness Review Modules 8 and 11) were
questioned as to the adequacy of the licensee's support inspection
procedures.
(4) A previous examination of this concern, described in NRC Report
424, 425/84-36, was reviewed to determine if it described any
related matters that would require resolution before the matters
described by the items could be considered closed.
(5) The NRC inspector questioned the PPP training supervisor to
determine whether concerns for clarification of support inspection
criteria were being adequately dealt with through the training
program.
From his discussions and review, the NRC inspector determined that the
concerns expressed in Unresolved Item 424/83-13-09 and Inspector
Followup Item 424, 425/84-05-09 had been or were beirg adequately
addressed through the following:
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(1) Deletion of the practice of using memos to clarify inspection
criteria.
(2) Improvements to the involved inspection procedures.
(3) Improved training of personnel.
(4) Specific actions that had been or were being taken in response to
other NRC items such as Violations 424, 425/84-36-03 and -04.
Based on the above, the NRC inspector concluded that the Unresolved
. Item 424/83-13-09 and Inspector Followup Item 424, 425/84-05-09 would
be considered closed.
c.
(Closed) Unresolved Item (424/85-35-09): Adequacy of Drawing and DCN
Reviews.
This unresolved item identified NRC inspectcrs' concern that the
licensee's Readiness Review of drawings and drawing change notices
(DCNs) for piping was unsatisfactory in that, for the examples of
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review performance examined by the inspectors, the following evidence
of unsatisfactory review was noted:
(1) For the licensee's drawing reviews, the checklists used had few
items verified and the verifications performed did not appear to
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be significant or thorough.
(2) For the DCN reviews the inspector found that, in one of four
they examined, the Readiness Review reviewer failed to note a
significant discrepancy between the DCN and the applicable Design
Criteria (DC) even though the reviewer indicated a specific
verification that the DCN change was in accordance with the DC.
The licensee's general response for this unresolved item and for
Unresolved Items 85-35-11 and -12 below (which also involve Readiness
Review checklists) was that:
(1) The checklists were developed for application to several design
areas and inherently included items that were not applicable to
all of the areas.
(2) The checklist items were not intended as absolute check require-
ments, but rather as guidance to be used by experienced reviewers.
NOTE: The licensee concluded that their checklists adequately
served this purpose.
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(3) The reviewers did not always clearly describe the reasoning
behind their checks and acceptances of checklist items making it
difficult to verify the exact check performed.
NOTE: The licensee stated that their personnel had been given
additional training to assure they better documented their
performance in subsequent modules.
In addition to the above, the licensee provided a specific response to
the NRC findings in Unresolved Item 85-35-09 giving a logical explana-
tion of how the checklists were performed. The explanation was not
verifiable, however, due to the lack of detailed original documentation
of the performance of the reviews.
In order to further examine the concern expressed in this item,
additional examples of drawing and DCN checklists completed by licensee
Readiness Review persunnel were examined by the NRC inspector as
described in NRC Report 424/86-11.
The examples examined were more
complete and better documented than those previously examined, but
still lacked the detail to provide evidence of a truly thorough review.
Responding to the inspector's continued concern regarding the lack
of evidence of thoroughness in the documentation of the reviews the
licensee re performed several drawing and DCN checklists and documented
the reviews thoroughly.
To assess the licensee's performance and
documentation of these re-reviews, the inspector examined two of the
re-reviews:
Drawings Checklist performed on Piping and Instrumentation Drawing
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IX4DB161-3R11
DCN/DCNR Checklist performed on DCN 30 for the above drawing
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From his examination of documentation provided, the inspector found
the two reviews listed above to have been thorough and satisfactorily
performed.
No apparent deficiencies in the drawing or DCN were
observed. Although the inspector could not ascertain with certainty
that the licensee's previous reviews had been satisfactorily performed,
he found no evidence that the reviews had overlooked any significant
programmatic deficiency nor that any further review of the matter was
warranted. On this basis, the item is considered closed.
d.
(Closed) Unresolved Item (424/85-35-11):
Inadequate Review of
Procurement Specifications.
This item addressed NRC inspectors' concern that the licensee's review
of procurement specifications in their Module 4 Readiness Review had
been inadequate and that the specifications might contain significant
unidentified deficiencies. This concern was based on the inspectors'
findings in examining the licensee's Module 4 review of Specification
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X4AH04 (shop Fabricated Atmospheric Tanks...) which had been performed
by a licensee reviewer using their checklist 6.1-7.
The inspectors had
found that a number of checklist items for the specification example
appeared not to have been performed satisfactorily and that the
specification contained apparent deficiencies which had not been
detected in the review.
The licensee's general response to this item is described in c. above.
Their response to the specific apparent deficiencies which the NRC
examination had identified was examined by the NRC inspector and
determined acceptable as described in NRC Report 424/86-11. However,
there remained a NRC concern that the licensee had not performed a
thorough review.
This concern was based on the lack of detailed
documentation of licensee review performance. The licensee responded
to this concern in the same manner as they responded to item 85-35-09,
described above. That is, they explained how their original review had
been performed and they re performed and better documented several of
their original reviews to conform their original findings. The NRC
inspector reviewed the licensee's explanation and examined their
documented re-reviews of the following specifications:
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X4AH03R8, Boric Acid Storage Tank
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X4AF03R8, Auxiliary Feedwater Pump and Driver
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X4AH04R8, Shop Fabrication of Atmospheric Tanks Built to ASME
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Section III
The inspector determined that the licensee adequately performed the
re-reviews and that the re-reviews demonstrated that there were no
significant deficiencies in the specifications. Although the inspector-
could not ascertain with certafnty that the licensee's original reviews
of specifications had been satisfactorily performed, he found no
evidence that the reviews had overlooked any significant programmatic
deficiency nor that any further reviews of the matter was warranted.
On this basis, the matter is considered closed.
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e.
(Closed) Unresolved Item (424/85-35-12):
Inadequate Review of Vendor
Drawings.
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This item addresses NRC inspectors' concern that the licensee's review-
of vendor drawings for Readiness Review Module 4 had been unsatis-
factory and that the drawings might contain deficiencies. This concern
was based on the -inspectors' findings in their examination of .the
licensee's Module 4 review of vendor drawing IX4AH04-23-13, which had
been performed by a licensee reviewer using their checklist 6.1-8.
The
NRC inspectors found that it appeared that few significant checklist
items had been performed and the reviewer failed to note that certain
important drawing details (e.g., weld sizes) were illegible.
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The licensee's general response to this item is described in c above.
Their response to the specific drawing deficiency identified by the NRC
was previously reviewed and determined acceptable, as described in NRC
Report 424/86-11. The defiuiency was found not to represent a safety
significant issue.
However, it was still considered, that the
licensee's documentation of their reviews (on checklists) lacked the
detail necessary to demonstrate adequate review performance.
The
licensee responded to this concern in the same manner as they responded
to items 85-35-09 and -11, described above. That is, they explained
how their original review had been performed and they re performed and
better documented several reviews to confirm their original findings.
The NRC inspector reviewed the licensee's explanation and examined
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their documented re-reviews of the following vendor drawings:
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IX4AF03-111-6, Outline, Terry Turbine
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1X4AF03-83-4, General Arrangement Drawing for AFS Pump and Steam
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Turbine Driver
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IX4AE01-51-9, Component Cooling Water Heat Exchanger
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The inspector found that the re-reviews were satisfactorily documented
and that they indicated no significant deficiencies in the vendor
drawings.
Although the NRC inspector could not ascertain with
certainty that the licensee's original review had been satisfactory,
he found no evidence that the reviews had overlooked any significant
programmatic deficiency nor that any further review of the matter was
warranted. On this basis, the matter is considered closed.
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f.
(Closed) Unresolved Item (424/85-35-13):
Inadequate Resolution of
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Readiness Review Design Verification Findings.
This item expressed NRC inspectors' concern that the licensee had not
adequately obtained correction for deficiencies their Readiness Review
Team (RRT) had identified in their Module 4 Readiness Review Design
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Verification Findings.
The inspectors had examined the licensee's
resolution of two Findings and had determined that both appeared to
have been inadequately resolved. During NRC Inspection 424/86-11, the
inspector reviewed the licensee's explanations of their resolution
of these Findings and accepted their explanation for one of the two.
Continued concern with regard to the technical issue contained in the
other Finding resulted in issuance of Violation 424/86-39-01; 425/86-
19-01.
During the current inspection, the NRC inspector reviewed additional
examples of the licensee's resolution of Readiness Review Findings
to determine whether the previously identified inadequate Finding
resolution was an isolated case. The inspector reviewed the licensee's
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resolution of three Readiness Review Module 4 Design verification
Findings and one design Finding from the related Independent Design
Review (IDR). The Findings involved were as follows:
Module 4 Findings
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RRF 4-93, Missing pipe spool documentation
RRF 4-78, Failure to identify design interface
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RRF 4-79, Failure to clearly identify engineering judgements/
assumptions per ANSI N45.2.11, Section 4.2.
IDR Finding
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Observation 22-B1,
Longitudinal pipe breaks have not been
evaluated at high stress points
The inspector found that the above Findings appeared adequately
resolved and that the Finding originally determined to be inadequately
resolved appeared to be an isolated case.
g.
(Closed) Violation (424/86-11-01; 425/86-06-01):
Inadequate Measures
to Assure Correction of Design Criteria Documents.
The licensee's letters of response, dated May 23 and August 18, 1986,
have been reviewed and determined to be acceptable by Region II. The
inspector held discussions with the licensee's representatives and
examined the corrective actions stated in the letters of response. The
inspector concluded that the licensee had determined the full extent
of the subject violation, performed the necessary survey and followup
actions to correct the present conditions and taken the corrective
action necessary to prevent recurrence of similar circumstances. The
corrective actions identified in the letter of response have been
implemented.
h.
(Closed) Violation (424/86-11-02; 425/86-06-02):
Failure to Promptly
Identify Undersize Welds.
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The licensee's letters of response, dated May 23 and August 18, 1986,
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have been reviewed and determined to be acceptable by Region II. The
inspector held discussions with the licensee's representatives and
examined the corrective actions stated in the letters of response. The
inspector concluded that the licensee had determined the full extent
of the subject violation, performed the necessary survey and followup
actions to correct the present conditions and taken - the corrective
action necessary to prevent recurrence of similar circumstances. The
corrective actions identified in the letters of response have been
implemented.
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1.
(Closed) Violation (424/86-11-03):
Removal of Temporary Pipe Supports.
The licensee's letters of response, dated May 23 and August 18, 1986,
have been reviewed and determined to be acceptable by Region II. The
inspector held discussions with the licensee's representatives and
examined the corrective actions stated in the letters of response. The
inspector concluded that the licensee had determined the full extent of
the subject violation, performed the necessary survey sand followup
actions to correct the present conditions and taken the corrective
action necessary to prevent recurrence of similar circumstances. The
corrective actions identified in the letters of response have been
implemented.
J.
(Closed) Deviation (4?4/86-11-04; 425/86-06-04):
Failure to Inspect
Supports.
The licensee's letter of response, dated November 6,1986, has been
reviewed and determined acceptable by Region II.
The inspector held
discussions with the licensee's representatives and examined the
records of the corrective actions stated in the letter of response.
The inspector concluded that the licensee had completed the necessary
actions regarding the deviation, including actions to avoid further
deviation.
The corrective actions stated in the letter of response
have been implemented.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions. A new unresolved item identified during this inspection is discussed
in paragraph 7.c.
5.
Reactor Coolant Loop Piping - Special Welding Applications (Unit 2)
(55178B)
The NRC inspector observed the repair of two reactor coolant loop piping
welds in progress to verify that the work and associated records were
in compliance with licensee commitments and NRC requirements.
The code
applicable to the licensee's welding of reactor coolant loop piping is ASME
Section III (77W77). The repairs checked by the inspector were on welds
identified 049-W-02 and 02A on isometric drawing 2K4-1201-049-02.
The
piping was 12 inch schedule 140 austenitic stainless steel and the repairs
involved grinding followed by re-welding.
In his observation of the work
and associated records, the inspector inspected / reviewed the following to
verify compliance with requirements and procedures:
a.
Proper qualification of the welding procedure
b.
All requirements applicable to the repair included in the pre edure
c.
Welder qualification
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Correct filler metal
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Within the area examined, no violations or deviations were identified.
6.
Concerns Regarding Deviation Reports
Specific concerns were expressed to Region II with regard to practices that
had been used in dispositioning certain PPP Deviation Reports (DRs). The
inspector examined these concerns, as described below, to determine if they
indicated any safety issues which would require NRC and/or licensee action
for resolution:
a.
DR'6819
The concern expressed with regard to this DR was that it was disposi-
tioned by an individual who was not a certified QC inspector. The NRC
inspector reviewed this DR and found that the approved disposition had
been made by design engineering personnel.
The inspector discussed
the qualifications of the engineering personnel and the adequacy of
the disposition with responsible licensee representatives and with
knowledgeable Region II inspectors who were onsite.
Based on his own.
review and on information provided by the licensee personnel and NRC
inspectors (whose specialities lay in the area covered by the DR), the
inspector concluded that the DR had been properly dispositioned by
appropriately qualified individuals.
The inspector believes that the
original concern may have been directed at the initial " recommended
disposition" on the DR.
The " recommended disposition" was inappro-
priate and was subsequently overruled in the " approved disposition"
made by the engineering personnel.
The NRC inspector concluded that
the disposition of the DR, although not made by a certified QC
inspector, was appropriate and therefore, that there is no valid safety
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concern with regard to DR 6819.
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b.
DR 7167
The concern expressed with regard to this DR was that the individual
who dispositioned the DR could not be readily identified, as only his
initials were given.
The NRC inspector reviewed the subject DR and
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found that, although the individual who dispositioned the DR only
recorded his initials below the disposition statement, his name was
signed at the bottom of the DR, making him readily identifiable.
The
inspector concluded that there was no valid safety cor.cern with regard
to DR 7167.
c.
DR 6391
The concern expressed with regard to this DR was that the DR had been
improperly vuided.
The individual who expressed the concern stated
that the Di documented a valve being taken apart without proper
documenta*, ion, specifically a process sheet, and it had been voided on
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the basis that a process sheet was not required. The individual stated
that, in his opinion, a process sheet _was required. The NRC inspector
reviewed the DR and related documentation and procedures.
Based on
this review, the inspector found that the DR had not involved a valve
being taken apart, but rather the disconnection of a valve to piping
bolted flange connection. Further, the inspector found that provisions
contained in the licensee's procedures had resulted in a properly
documented reconnection. The NRC inspector concluded that there was no
valid safety concern.
As indicated above, the NRC inspector found that the specific DR concerns
described above contained no safety issues which require NRC or licensee
actions for resolution.
The inspector also notes that, possibly related
generic concerns with regard to the licensee's DRs were examined by the NRC
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in followup items 424, 425/84-36-12 and -13, which were closed in NRC Report
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424/86-75 and 425/86-36.
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7.
Construction Deficiency Reports (CDRs) (92700)
The inspector examined the licensee's evaluation, reporting and correction
of items which had been reported to Region II as potential construction
deficiencies. The items and the review performed are described below:
a.
(Closed) Item 424, 425 CDR 83-41:
Embed Plate Base Metal Failures.
The deficiency described in this item concerned a failure of a support
constructed of rectangular tubular steel welded to an embed plate. The
support construction had involved welding one flat face of a piece of
tubular steel against the embed plate face utilizing flare bevel welds
placed along the two rounded edges of the tubular steel that lay
adjacent to the tubular steel / embed plate interface.
The failure
occurred when a craftsman stepped on the support.
In a letter dated
February 14, 1984, the licensee informed Region II that they had
completed their investigation of the support failure and had determined
that it was not reportable in accordance with 10 CFR 50.55(e).
The licensee's evaluation of the construction deficiency was examined
by the NRC inspector in a previous inspection and determined unaccept-
able, resulting in the issuance of the deviation identified in 3.J.
above. The deviation questioned both the veracity of the licensee's
reporting and the adequacy of their evaluation. As described in 3.J. ,
the licensee has provided a response to the deviation which has been
reviewed and determined ccceptable by Region II. The inspector held
discussions with responsible licensee representatives and examined
documentation supporting the evaluation work described in the deviation
response to verify that their evaluation of the original construction
deficiency had been satisfactorily completed, with no further
corrective actions necessary. The documentation reviewed consisted of
the following:
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Engineering instructions included in a memo from G. R. Henke (BPC)
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R. Keidel (BPC) dated 10/17/86 (File No. GRH-106-07) and
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entitled " Technique for Detecting Lamellar Tearing in Embed Plates
1 Inch Thick and Thicker"
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Georgia Power Ultrasonic Inspection report 000453 UT and
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associated Ultrasonic Calibration Data Sheets
Based on the inspector's verification that the licensee had satisfac-
torily completed their evaluation and that no further corrective action
was necessary, this matter is considered closed.
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b.
(Closed) Item 424, 425 CDR 83-46:
Pullman Power Products Hanger
Reinspection Findings.
The deficiency described in this item concerned extensive pipe support .
installation deficiencies. The final report for the item was submitted
to Region II in a letter dated May 18, 1984. The letter stated that
the deficiency had been determined to be reportable in accordance with
10 CFR 50.55(e) criteria. The report was reviewed by the NRC inspector
and determined acceptable except that the licensee's written evaluation
did not identi fy the root cause or the actions taken to preclude
recurrence. The inspector held discussions with responsible licensee
and contractor representatives (including the PPP QC inspectors and the
Training Officer) and reviewed supporting documentation (Nonconformance
Reports PP-3853, PP-3698, PP-3900, PP-3982, PP-4106, PP-4113 and
PP-4437) to verify that corrective actions had been completed.
The
inspector found that, although the root cause and action to preclude
recurrence were not described in the report to the NRC, it appeared
that the root cause (inadequate training and instructions) had been
recognized and that appropriate corrective actions to preclude
recurrence had been taken. This matter is considered closed,
c.
(Closed) Item 424,425 CDR 84-68:
Radius of Coped Structural Members.
References:
(1) Georgia Power letter to NRC Region II dated June 28, 1985.
(2) Bechtel Group Inc. memorandum from Y. Chung to R. Kiedel dated
May 17,1985 (File No. YC-055-15).
(3) Bechtel Group Inc. memorandum from Y. Chung to R. Kiedel dated
April 24,1985 (File No. YC-045-10).
The deficiency described in this item concerned sharp notches that had
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been left in the structural steel members of pipe supports when they
were coped for assembly. The supports involved included supports for
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reactor coolant loop piping.
The supports were fabricated in
accordance with practices in the American Institute of Steel Construc-
tion (AISC) Manual of Steel Construction, which specifies that the
re-entrant corners (of copes) "shall be shaped, notch free, to a radius
of at least h in."
The intent of the AISC practice was to assure the
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absence of stress risers or intensifiers which could lead to initiation
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and propagation of cracks at stress levels below those accounted for in
the normal design.
.
In a letter to NRC Region II dated June 28, 1985 (Reference 1),1 the
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licensee stated that they had performed linear-elastic fracture
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mechanics analyses on potentially affected safety-related structural
members and that the an :yses indicated there were no notch conditions
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that could affect plant safety. They concluded, therefore, that the
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deficiency was not reportable in accordance with 10 CFR 50.55(e)
requirements.
As they had determined that the deficiency was not
reportable (per 10 CFR 50.55(e), they were not obliged to and did not
report details of their evaluation to the NRC.
!
In the current inspection, the NRC inspector reviewed the licensee's
file on the CDR to assess the licensee's determination of non-
reportability.
The evaluation given to the inspector in the licensee's file indicated
that, while the notch conditions had been determined acceptable, they
had been repaired by radiusing the re-entrant corners. Subsequently,
in examining the some of the involved supports, the inspector
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determined that the radiusing had not been performed on many of the
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supports. He found that, following their evaluation, the licensee had
decided that they would not correct certain of the notch conditions
based on their determination that the conditions were acceptable. The
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inspector noted that the information initially provided to him did not
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indicate this and he expressed concern to the licensee that it might
have led him to conclude that the details of their evaluation were
relatively unimportant (as the condition analyzed in the evaluation had
reportedly been corrected).
Having found that the fracture mechanics analyses performed by the
licensee were the bases for acceptance of otherwise nonconforming
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conditions, the inspector examined the details of the analyses and
related data described in the References (2) and (3) memorandums listed
above.
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The inspector found that some aspects of the l'censee's analyses
appeared unsatisfactory and reviewed his concerns with a knowledgeable
NRC individual (a member of the ASTM committee responsible for the test
method for determining plane-strain fracture _ toughness of metallic
materials). In addition, the inspector questioned responsible licensee
personnel regarding their analyses.
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From his review and discussions the inspector found that the licensee's
analyses had included two apparent errors not acknowledged by licensee
personnel:
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(1) The licensee assumed a minimum critical stress intensity value
of 55 ksi in at 70 F for their A36 structural steel, based on
reference to data in Electric Power Research Institute (EPRI)
Report 3528 (June 1984). There is insufficient data to support
acceptance of this value. An acceptable minimum value, based on
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data given in NRC Report NUREG-0577 (For comment - October 1979),
is 36 ksi in at 75 F.
(2) The models used by the licensee .in their analyses ignored notch
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shape and total depth. Notch depth was assumed to be represented
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by the depth of the overcut that sometimes extended beyond the
notches being considered.
In the case of their support (pipe rack) R003, for example, this
resulted in the licensee using a value of 0.1. inch for notch depth,
whereas the actual depth was about 2.3 inches.
The inspector determined that the licensee's design stress values were so
low however, that the unradiused notches did not represent a safety concern.
For example, in response to questions regarding their design tensile
stresses for accident and faulted conditions, the licensee informed the
inspector that their latest stress analysis indicated only 2 ksi for the
involved beam in support R003. The stress intensity produced in the notched
R003 beam by this low stress would not result in crack propagation.
Based on analyses performed by the inspector, utilizing tensile stress data
provided by the licensee, the unradiused coped notches in the pipe supports
do not represent a safety concern.
d.
(Closed) Item 424, 425 CDR 85-88:
Longitudinal Pipe Breaks.
The deficiency described in this item concerned a failure to postulate
longitudinal pioe breaks at intermediate break locations in' ASME
Section III, Class 2 and 3 piping outside the containmant in accordance
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with NRC Branch Technical Position MEB 3-1.
The final report for this
item was submitted to Region II in a letter dated December 19, 1985.
The letter stated that the deficiency had been determined to be
reportable in accordance with 10 CFR 50.55(e) and 10 CFR 21.
The
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report was reviewed by the NRC inspector and determined to be
acceptable, except that the licensee's written evaluation did not
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identify the root cause or the actions taken to preclude recurrence.
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The inspector held discussions with responsible licensee and contractor
representatives and reviewed supporting documentation to verify that
corrective actions had been completed. The supporting documentation
reviewed by the inspector was as follows:
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Change Control Package (CCP) B10267E to re-route circuits to valve
1BRHV8801B
Maintenance Work Order (MWO) 18607779 to implement CCP B10267E
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Operations Deficiency Report T-1-86-2491 (deficiency referenced by
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MWO 18607779)
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Readiness Review Finding (RRF 22-B1, which identified the original
deficiency in postulation of longitudinal pipe breaks)
Independent Design Review Assessment associated with RRF 22-B1
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Project Reference Manual Section C-39 (changed to correct cause of
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the construction deficiency)
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In his review of the supporting documentation described above, the
inspector found that, although the licensee had not described the root
cause or the action to preclude recurrence in their CDR, the root cause
was identified in RRF 22-B1 and action to preclude recurrence had been
taken. This matter is considered closed.
e.
(Closed) Item 424, 425 CDR 86-112:
Defective Anchor Darling Shock
Arrestors.
The deficiency described in this item concerned defective parts in
mechanical shock arrestors.
The final report for this item was
submitted to Region II in a letter dated June 19, 1986. The letter
stated that the deficiency had been determined to be reportable in
accordance with 10 CFR 50.55(e) and 10 CFR 21. The report has been
reviewed and determined to be acceptable.
The inspector held
discussions with responsible licensee representatives and reviewed
supporting documentation to verify that the corrective actions
identified in the report have been completed.
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f.
(Closed) Item 424, 425 CDR 86-121: K Inserts May Not Have Been Fully
Consumed in Welding Stainless Steel Schedule 10 Piping Fitups.
The deficiency described in this item concerned apparently unsatisfac-
tory welds in Nuclear Service Cooling Water (NSCW) stainless steel
piping.
Discrepant weld conditions included unconsumed K inserts,
excessive piping mismatch and oxidation. In a letter dated August 26,
1986, the licensee informed NRC Region II that they had completed-
their evaluation of this deficiency and had determined that it was not
,
reportable in accordance with 10 CFR 50.55(e). As they had determined
that the deficiency was not reportable (per 10 CFR 50.55(e)), they were
not obliged to and did not report the details of their evaluation to
Region II.
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During this inspection, the NRC inspector examined the licensee's
evaluation to assess the licensee's evaluation and their determination
of non-reportability. To perform the assassment, the inspector held
discussions with responsible licensee representatives and with an NRC
3
resident inspector who had observed examples of the condition.
In
addition, the inspector reviewed the following supporting documenta-
tion:
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Georgia Power letter (internal distribution) dated August 25,
1986, containing a summary of the evaluation.
(File X78G03-M121,
V-A.14.164)
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Bechtel National, Inc. letter from Y. Chung to D. Kinnsch, dated
August 1, 1986.
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Weld Speciment Test Program dated August 11, 1986, describing
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physical tests and test results obtained on specimens used .to
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simulate deficient weld conditions.
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Letter from Reedy Associates to Georgia Power Company, dated
Aug'ust 8,
1986, describing an evaluation of the NSCW weld
deficiencies.
Based on his discussions and review, the inspector accepted the
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licensee's determination.
8.
Inspector Followup Item (IFIs)
a.
(Closed) IFI (424, 425/84-05-05):
Adequacy of Training Program for
Inspectors, Field Engineers and Craft.
This item was opened to follow up on concerns expressed to Region II
that PPP QC inspectors, field engineers and craft were not adequately
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trained.
Specific concerns expressed to the NRC were for the adequacy craft
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training in procedures, reading drawings, and weld symbols; field
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engineers being insufficiently knowledgeable and referring craft
questions to QC inspectors; and inadequate communication of procedure
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changes.
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The adequacy of the training and the ac
ns taken by the licensee to
improve PPP inspector, field engineer and craft training have been
previously examined in NRC Inspections 424, 425/84-23 and 84-36.
4
Further, the subject of PPP personnel training was examined in the
NRC assessment of Readiness Review Module 8' and it is a routine NRC
inspection subject.
No deficiencies were identified in the licensee's
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training which appear inadequately addressed.
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During the current inspection, the NRC inspector discussed PPP
personnel training with the PPP Training Officer, examined the current
related training program documents (identified T-II-1, T-II-3, T-II-5,
and T-II-6) and verified that records of the training were maintained.
Based on the previous inspection findings and on the current review
discussed above, the inspector determined that concerns with regard to
this matter have been adequately addressed and that the item should be
considered closed.
b.
(Closed) IFI (424, 425/84-05-07):
Pipe Improperly Sand Blasted.
This item was opened to follow up on a reported concern that the
licensee might not have detected all underwall conditions in pipe that
had been improperly sand blasted.
In following up on this concern during NRC inspection 424, 425/84-23,
the inspector found that the licensee's procedures for detecting
underwall conditions in sand blasted pipe did not appear adequate to
assure that all underwall conditions were found.
In the current inspection, the NRC inspector discussed this concern
with the BPC PFE staff supervisor.
This supervisor provided informa-
tion to the NRC inspector that indicated the underwall conditions which
might have been missed in the examinations would have been expected to
be acceptable without repair. This was based on design calculations
which demonstrated that the examples of underwall conditions detected
in safety related piping were acceptable. The inspector accepted this
explanation and the matter is considered closed.
c.
(Closed) IFI (424,- 425/84-05-09):
Clarifications of Engineering and
.
Procedural Practices.
This item expressed similar concerns to those described for Unresolved
Item 424, 425/83-13-09 and resolution of that item, described in 3.b.
above, is considered to also resolve this IFI.
d.
(Closed) IFI (424, 425/84-05-12): Weld Symbols.
This item was opened to follow up on concerns that non-standard weld -
symbols vere being used (on piping system drawings). The inspector
reviewed the licensee's response to this concern as stated in the
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licensee's July 23, 1984 letter to Region II and as recorded in the
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results of GPC Audit MD01-84/50.
The inspector found that the letter
and the audit acknowledged occasional difficulties with welding symbols
but indicated these discrepancies-had been resolved.
To further examine this matter, the NRC inspector held discussions
with PPP QC inspectors (responsible for inspecting piping supports
to drawing requirements), the PPP Training Officer (responsible for
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training QC inspectors and craft to understand weld symbols), and NRC
Region II inspectors (who have been examining piping supports and
drawings during routine NRC inspections).
In addition, the inspector
reviewed the reports of NRC inspections of piping supports.
From
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his discussions and review, the NRC inspector determined that, while
there had been instances of weld symbol discrepancies, these appeared
adequately addressed through licensee actions and/or other NRC
inspection items (e.g., Unresolved Item 424/86-62-05, entitled " Unclear
Use of Typical Welding Symbol Callouts"). Therefore, the followup item
is considered closed.
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e.
(Closed) IFI (424,425/84-05-13):
Unqualified Welding Procedures.
This item was opened to follow up on concerns that unqualified welding
procedures may have been used in welding performed by PPP.
The
adequacy of PPP welding procedures has been examined during routine NRC
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inspections and, based on discussions with other Region II inspectors
and on his own experience in examining PPP welding procedures and
performance. The NRC inspector found no basis for a continuing concern
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relative to this followup item.
f.
(Closed) IFI (424/85-29-02): Applicability of Statistical Methods to
Readiness Review.
This item was opened to follow up on a concern that the licensee did
not consider the use of statistical methods in performing their
Readiness Review of piping and mechanical equipment.
Licensee
representatives informed the inspector that there had never been any
intention of using statistical methods, that they instead relied on the
judgement of highly qualified individuals in selecting items to be
reviewed. The inspector discussed this with Region II management and
found that the lice see's approach was considered acceptable, as it was
consistent with the NRC's own approach in determining what items and
how many should be inspected (as described in NRC . Report NUREG-1055
dated May 1984). This matter is considered closed.
g.
(Closed) IFI (424/85-29-03): Questions Regarding Module 4 Commitments.
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This item was opened to follow up on NRC inspectors' questions
regarding the licensee's failure to identify and/or verify implementa-
tion of certain commitments as part of their Module 4 Readiness Review.
The inspector reviewed the related questions and found that they had
been adequately addressed during the NRC evaluation that culminated
,
in the issuance of NRC inspection report 424/85-35.
This matter is
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considered closed.
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h.
(Closed) IFI (424/85-29-04): Acknowledgement of Access and Shielding
Considerations in Designing for Inservice Inspection.
This item was opened to follow up on an inspector's concern that the
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licensee's design might not have adequately addressed shielding and
access considerations needed for inservice inspection. The inspector
cited a particular situation in the licensee's design as an example.
During the current inspection, the inspector reviewed an informal
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response prepared by the-licensee.
The response provided information
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which indicated that the specific situation the inspector had
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previously described would not present an access or shielding problem
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resulting in significant personnel exposures during inservice inspec-
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tions.
The inspector also reviewed the licensee's' design criteria for
inservice inspection. The inspector found that the design criteria,
identified DC-1011, complied with regulatory requirements.
Based on his review of the licensee's response to this item and on his
review of DC-1011, the inspector determined that this item should be
considered closed.
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