ML20207K601

Insp Repts 50-424/86-110 & 50-425/86-49 on 861103-07 & 17-21.No Violations or Deviations Noted.Major Areas Inspected:Previous Enforcement Matters,Reactor Coolant Loop Piping,Deviation Repts & Inspector Followup Items

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: ML20207K556 ML20207K601
References
50-424-86-110, 50-425-86-49, NUDOCS 8701090463
Download: ML20207K601 (20)

See also: IR 05000424/1986110

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jp Mcg UNITED STATES

g NUCLEAR REGULATORY COMMISSION

g 'o,$ ' REGION 11

g j 101 MARIETTA STREET, N.W.

• t / TLANTA, GEORGI A 30323

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l 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

l Inspection Cond ed: November 3-7 and November 17-21, 1986

l Inspector: / M M. Mr 686

! E. H. Gi ra Date Signed

Approved by:

r J . 'J E}(p#($ectio ..i ~

ck[b

Date SiQned

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I at fals and Pr e Section

l Div sion of or Safety

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l 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

PDR

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ADOCK 05000424

PDR '

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REPORT DETAILS

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1. Persons Contacted

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Licensee Employees ,

i *R. E. Conway, Senior Vice President and Project Director  !

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i *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

i *C. W. Hayes, Vogtle QA Manager

E. M. Dannemiller, Technical Assistant to General Manager of

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i Vogtle Nuclear Operations

j D. M. Fiquett, Unit 2 Construction Manager

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W. E. Burns, Nuclear Licensing Manager

• R. H. Pinson, Vice President of Construction

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• L. B. Glenn, Manager of Quality Concerns

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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j F. B. Marsh, Bechtel Power Corporation (BPC), Project Engineering Manager

j J. M. Carson, BPC, QA Manager

i *R. C. Sommerfeld, BPC, Readiness Review Staff

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• P. R. Thomas, BPC, Readiness Review Staff

I 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 ,

j N. Niehoff, BPC, Civil Structural Deputy Engineering Group Supervisor i

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i NRC Personnel

• J. F. Rogge, Senior Resident Inspector - Operations

• H. Livermore, Senior Resident Inspector - Construction

i R. Schepens, Resident Inspector - Operations

R. E. Johnson, Metallurgist, Office of Nuclear Reactor Regulation

, (Member of Committee responsible for ASTM E399, Standard Test Method

for Plane-Strain Fracture Toughness Testing of Metallic Materials)

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• h tended exit interview

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The inspection scope and finnings were summarized on November 21, 1986, with l

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 insoector during this inspection.

3. Licensee Action on Previous Enforcement Matters

a. (Closed) Unresolved Item (424,425/83-02-01): Construction Deficiency

Reporting.

! This item identified the NRC inspector's concern with regard to the

, licensee's reporting of construction deficiencies in accordance with

10 CFR 50.55(e). In reviewing construction deficiency reports (CDRs) ,

i that had been submitted to the NRC by the licensee, the inspector had

previously found that the reports did not always identify the causes of

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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

l 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

l those to preclude repetition) were adequate. The inspector found that

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in no case did the licensee describe the root cause. Further, they did

, 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

i and that repetition would be precluded. The licensee's reporting,

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therefore, did not provide all of the information required by 10 CFR

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

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

Followup Item 424, 425/84-05-09, which expressed concern that the J

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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 g

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 '

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:

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Drawings Checklist performed on Piping and Instrumentation Drawing

IX4DB161-3R11

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DCN/DCNR Checklist performed on DCN 30 for the above drawing

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 I

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

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. ,

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- l

factory and that the drawings might contain deficiencies. This concern l

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

i 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

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

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 I

! 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

l RRF 4-93, Missing pipe spool documentation

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RRF 4-78, Failure to identify design interface

RRF 4-79, Failure to clearly identify engineering judgements/

assumptions per ANSI N45.2.11, Section 4.2.

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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,

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

d. 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 1

concern with regard to DR 6819. '

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 l

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 i

generic concerns with regard to the licensee's DRs were examined by the NRC )

in followup items 424, 425/84-36-12 and -13, which were closed in NRC Report ,

424/86-75 and 425/86-36. .l

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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)

to R. Keidel (BPC) dated 10/17/86 (File No. GRH-106-07) and i

entitled " Technique for Detecting Lamellar Tearing in Embed Plates l

1 Inch Thick and Thicker" j

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Georgia Power Ultrasonic Inspection report 000453 UT and I

associated Ultrasonic Calibration Data Sheets l

Based on the inspector's verification that the licensee had satisfac-

torily completed their evaluation and that no further corrective action l

was necessary, this matter is considered closed. J

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).

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The deficiency described in this item concerned sharp notches that had

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  :

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of at least h in." The intent of the AISC practice was to assure the

absence of stress risers or intensifiers which could lead to initiation

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 l

'

licensee stated that they had performed linear-elastic fracture

mechanics analyses on potentially affected safety-related structural

members and that the an :yses indicated there were no notch conditions l

that could affect plant safety. They concluded, therefore, that the  !

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  !

,

determined that the radiusing had not been performed on many of the {

1

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 '

inspector noted that the information initially provided to him did not ,

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 ,

conditions, the inspector examined the details of the analyses and

related data described in the References (2) and (3) memorandums listed ;

above.

'

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: ,

(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 l

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 ,

shape and total depth. Notch depth was assumed to be represented '

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 ,i

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 .

report was reviewed by the NRC inspector and determined to be I

acceptable, except that the licensee's written evaluation did not i

,

identify the root cause or the actions taken to preclude recurrence.

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

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Maintenance Work Order (MWO) 18607779 to implement CCP B10267E

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Operations Deficiency Report T-1-86-2491 (deficiency referenced by

MWO 18607779)

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Readiness Review Finding (RRF 22-B1, which identified the original

deficiency in postulation of longitudinal pipe breaks)

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Independent Design Review Assessment associated with RRF 22-B1

.

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Project Reference Manual Section C-39 (changed to correct cause of

'

the construction deficiency)

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.

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 I

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

3

discussions with responsible licensee representatives and with an NRC

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

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.

i Based on his discussions and review, the inspector accepted the

i

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 l

that PPP QC inspectors, field engineers and craft were not adequately

i trained.

Specific concerns expressed to the NRC were for the adequacy craft ,

training in procedures, reading drawings, and weld symbols; field j

engineers being insufficiently knowledgeable and referring craft  ;

questions to QC inspectors; and inadequate communication of procedure i

.

changes.

i

The adequacy of the training and the ac ns taken by the licensee to

improve PPP inspector, field engineer and craft training have been

4

previously examined in NRC Inspections 424, 425/84-23 and 84-36.

Further, the subject of PPP personnel training was examined in the

NRC assessment of Readiness Review Module 8' and it is a routine NRC

2

inspection subject. No deficiencies were identified in the licensee's

training which appear inadequately addressed.

,

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a--a ..,e

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p

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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 .,

licensee's July 23, 1984 letter to Region II and as recorded in the ,

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

'

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.

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

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 1

I

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.

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 '

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

i 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

l response prepared by the-licensee. The response provided information

I which indicated that the specific situation the inspector had

l previously described would not present an access or shielding problem

l_ resulting in significant personnel exposures during inservice inspec- I

l

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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