ML20207T922
| ML20207T922 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/06/1987 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207T919 | List: |
| References | |
| 50-424-87-11, 50-425-87-07, 50-425-87-7, NUDOCS 8703240425 | |
| Download: ML20207T922 (9) | |
See also: IR 05000424/1987011
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-424/87-11 and 50-425/87-07
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Licensee: Georgia Power Company',
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P. O. Box 4545
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Atlanta, GA. 30302
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Docket Nos.:
50-424 and 50-425
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License Nos.:
NPF-61 and CPPR-109
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Facility Name: .Vogtle
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' Inspection Co
d: Jan ary 26 - 30,
1987.2
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. Inspect r:
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Dite si ned
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W. P.
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Appro ed by-
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J. J B ke, Section Chief
Date Signed "
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En ne ring Section
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DJ is, on of Reactor Safety
SUMMARY
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. Scope:
This routine, unannounced inspection was conducted in -the areas of
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licensee actions on previous enforcement matters (92701B)(92702B), housekeeping
(548348), material identification and control (4290213) material
control
(42940B),. safety-related heating ventilating and air conditioning (HVAC)- systems
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(50100) (Unit 2), steel structures and supports (Units 2), and licensee iden-
tified items.
Results: Two violations were identified
" Failure to Follow Design Manual For
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. PSAR/FSAR As-Built Changes"
paragraph 3f and " Failure to Provide Adequate '
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Report of Significant Construction Deficiency"
paragraph
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
- C. W. Hayes, Vogtle QA Manager
- T. Greene, Plant Manager
- E. D. Groover, Quality Assurance (QA) Site Manager Construction
Other licensee employees contacted included construction craftsmen,
engineers, technicians, operators, mechanics, security force members, and
office personnel.
Other Organizations
- F. B. Marsh, Project Engineering Manager , Bechtel Power Corporation (BPC)
NRC' Resident Inspectors
- A. H. Livermore, Senior Resident Inspector (SRI), Construction
J, Rogge, SRI Operations
R. Shepens, RI
- Attended exit interview
2.
Exit Interview (307038)
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The inspection scope and findings were summarized on January 30, 1987, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting comments were received from the licensee.
(0 pen) Violation 50-424/87-11-01 and 50-425/87-07-01:
" Failure to Follow
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Design Manual for PSAR/FSAR As-Built Changes
" paragraph 3f.
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(0 pen) Violation 50-424/87-11-02 and 50-425/87-07-02:
" Failure to Provide
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Adequate Report of Significant Construction Deficiency"
paragraph 8.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92701B)(92702B)
a.
(Closed) Violaticn 50-424/86-59-01:
" Failure to Procure HVAC Systems
That Were Fabricated, Installed and Inspected In Accordance With
Procedures and Drawings"
Georgia Power Company (GPC) letter of response dated September 25, 1986
has been reviewed and determined to be acceptable by Region II.
The
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inspector held discussions with the cognizant engineer and examined the
corrective actions as stated in the letter of response. The inspector
concluded that GPC had determined the full extent of the subject
violation, performed the necessary survey and followup actions, to
correct the present conditions and developed the necessary corrective
actions to preclude recurrence of similar circumstances.
The
corrective actions identified in the letter of response have been
implemented.
b.
(Closed) Deviation 50-424/86-59-02 and 425/86-26-02:
" Failure To
Procure Explosion Proof Motors As Committed"
GPC letters of response dated September 25, 1986 and October 31, 1986,
have been reviewed and determined to be acceptable by Region II. The
inspector held discussions with the cognizant engineer and examined the
corrective actions as stated in the letter of response. The inspector
concluded that GPC had determined the full extent of the subject
deviation, performed the necessary survey and followup actions, to
correct the present conditions and developed the necessary corrective
actions to preclude recurrence of similar circumstances.
The
corrective actions identified in the letter of response have been
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implemented.
c.
(Closed) Deviation 50-424/86-59-03 and 50-425/86-26-03:
" Failure to
Install Electrically Interlocked and Alarmed Control Room Doors as
Committed"
GPC letters of response dated September 25, 1986 and October 31, 1986
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have been reviewed and determined to be acceptable by Region II. The
inspector held discussions with the cognizant engineer and examined the
corrective actions as stated in the letter of response. The inspector
concluded that GPC had determined the full extent of the subject
deviation, performed the necessary survey and follow-up actions, to
correct the present conditions and developed the necessary corrective
actions to preclude recurrence of similar circumstances.
The
corrective actions identified in the letter of response have been
implemented.
d.
(Closed) Violation 50-424/86-72-01 and 50-425/86-34-01:
" Failure to
Establish Adequate Measures to Protect Installed Materials and
Equipment from Temporary Construction Loads"
GPC letter of response dated October 31, 1986 has been reviewed and
determined to be acceptable by Region II.
The inspector held
discussions with the cognizant engineer and examined the corrective
actions as stated in the letter of response. The inspector concluded
that GPC had determined the full extent of the subject violation
performed the necessary survey and followup actions, to correct the
present conditions and developed the necessary corrective actions to
preclude recurrence of similar circumstances. The corrective actions
identified in the letter of response have been implemented.
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e.
(Closed) Viola' tion 50-425/86-72-02 and 50-425/86-34-02:
" Failure to
Assure Applicable Requirements are Included in Procurement Documents"
GPC letters of response dated October 31, 1986 has been reviewed and
determined to be acceptable by Region II.
The inspector held
discussions with the cognizant engineer and examined the corrective
actions as stated in the letter of response. The inspector concluded
that GPC had determined the full extent of the subject nonconformance
performed the necessary survey and follow-up actions, to correct the
present conditions and developed the necessary corrective actions to
preclude recurrence of similar circumstances.
The corrective actions
identified in the letter of response have been implemented.
f.
(Closed) Unresolved Item 50-424/86-59-04 and 50-425/86-26-04: " Design
Control for Control Room Doors"
This matter concerns the fact that FSAR Section 6.4.2.2.2 states: "To
minimize inleakage, the control room access doors are equipped with
self-closing devices that shut the doors automatically following the
passage of personnel. Alarms are also provided to annunicate if any of
the doors are open after a changeover to emergency operation. Two sets
of electrically interlocked doors with a vestibule between acting as an
airlock, are provided at each of the two entrances and the emergency
exit to the combined control room and associated spaces."
This
however, is not the as-built condition. The doors to the control room
are installed in pairs, but they are not electrically interlocked and
alarms are not provided to annunciate if any of the doors are open
after a changeover to emergency operation.
At the time of the inspection reported in 50-424/86-59 and 50-425/
86-26, it appeared that the above was the result of a failure of
the design control system to establish adequate measures to assure
selection and review for suitability of application of materials,
parts, and equipment that are essential to the safety-related functions
of structures, systems, and components, but this could not be solidly
substantiated.
The licensee indicated they would investigate the
matter.
The licensee determined that the root cause of the above is as follows:
Control
building floor plan drawing AX1011A04, Rev. 9,
issued
November 12, 1981, showed that the two sets of doors at the entrances
are electrically interconnected and the one set of doors at the
emergency exit is locked and alarmed. On revision ten of the same
drawing, issued August 11, 1982, the interlock / alarm requirements were
removed from the drawing. The original design included the interlock
fiature and this feature was removed from the design drawing during the
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design evolution' process.
The original input for the VEGP FSAR was
developed in part based on the FSAR descriptions utilized by previously
licensed Bechtel plants of similar design.
This input was then
modified as necessary to reflect the specifics of the VEGP design. The
review process failed to identify the inconsistency between the VEGP
design detail and that described in the input with respect to the
interlock and alarm features.
The Vogtle Nuclear Project Design Manual, Section 3.4.6, requires
the following:
Every design criteria dealing with safety-related
structures, systems, or components shall include a separate section
entitled, "PSAR Comparison."
In this section, every substantive
difference between PSAR commitments and the current design shall be
identified and briefly described.
These comparisons will form the
basis for preparation of the FSAR.
Clearly the above difference was
not identified in the "PSAR Comparison" section which caused the
defacto false statement to be carried over in to the FSAR.
The
licensee stated that had the NRC not identified the above difference,
the plant would become operational with the defacto false statement
unidentified.
The above is of concern to the commission because the FSAR is the
official vehicle by which construction permit holders report the
as-built configuration of power reactor facilities to the commission
for consideration of operations licensing.
In view of the above it is evident that the licensee failed to follow
procedure (Vogtle Nuclear Project Design Manual Section 3.4.6).
For
activities affecting quality failure to follow procedure is a violation
of 10 CFR 50 Appendix B Criterion V.
This matter will be closed as
an unresolved item and opened as violation 50-424/87-11-01/and
50-425/87-07-01:
" Failure to Follow Design Manual for PSAR/FSAR
As-Built Changes."
Within the areas examined no violations or deviations were identified except
as noted in paragraph 3f.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Independent Inspection Effort
Housekeeping (548348), Material Identification and Control (429028) and
Material Control (429408)
The inspector conducted a general inspection of the Unit 2 Containment, and
both auxiliary control and fuel buildings to observe activities such as
housekeeping, material identification and control; material control, and
storage.
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Within the. areas examined no violations or deviations were identified.
6.
Safety-Related Heating, Ventilating, and Air Conditioning (HVAC) Systems
(50100)
Observation of Work and Work Activities
a.
Personnel Interviews (Installation Practices)
The inspector interviewed four craftsmen engaged in the fabrication /
installation of seismic supports, ductwork, isolation dampers or
additional safety-related HVAC equipment to confirm the following:
Predefined and approved procedures are followed when it becomes
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necessary to relocate any seismic support or other safety-related
equipment from its original location specified on drawings.
Any preinstallaticn field repairs or adjustments to the HVAC
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equipment are performed in accordance with the manufacturer's
instructions and specifications to ensure that proper materials,
replacement parts, and supplies are used, performance requirements
are met and are reviewed by engineering for acceptance.
Personnel engaged in the installation and inspection of safety-
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related supports, ductwork,
and other safety-related HVAC
equipment have received adequate training to understand and
perform work contained in relevant work and inspection procedures
and instructions.
b.
Installation Activities
The inspector witnessed portions of the installation activities
indicated below to verffy the following:
The latest issue (revision) of applicable drawings or procedures
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is available to the installers and is being used.
Modifications to supports are approved by appropriate personnel
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before implementation.
Activity
Component
Welding
Duct Section A-2575A
Welding
Duct Support DS-2072104-35
Within the areas examined, no violations or deviations were identified.
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7.
Steel Stiactures and Supports (Unit 2)
The inspector observed welding work activities for steel structures and
supports as described below to determine whether applicable code and
procedure requirements were being met.
The applicable code for the
activities examined was AWS D1.1-1975 and AWS D9.1-1980.
a.
Welding
The below listed welds were examined in process to determine work
conducted in accordance with traveler; welder identification and
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location; welding procedure assignment; welding technique and sequence;
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materials identity; weld geometry; fit-up; temporary attachments; gas
purging; preheat; electrical characteristics; shielding gas; welding
equipment condition; interpass temperature; interpass cleaning; process
control systems; identify of welders; qualification of inspection
personnel; and weld history records.
Welding Examined
Duct Section
A-2575A
Duct Support
D5-2072104-35
b.
Welding Filler Material Control (551528)
' The inspector reviewed the licensee's program for control of welding
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materials to determine whether materials were being purchased,
accepted, stored, and handled in accordance with QA procedures and
applicable code requirements.
The following specific areas were
examined:
Purchasing,
receiving,
storing,
distribution
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handling
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procedures, material identification
Welding material, purchasing and receiving records for the
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following materials were reviewed for conformance with applicable
procedures and code requirements:
Type
Size
Heat / Control No.
ER-705-2
0.035"
F7164
E-7018
3/32"
MM081
E-7018
1/8"
MM070
c.
Welder Qualification (551578)
The inspector reviewed the licensee's program for qualification of
welders and welding operators for compliance with QA procedures and
ASME Code requirements. The applicable code for welding qualification
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1s ASME B&PV Code Section IX as invoked by GpC Specification X2AG06
Rev. 4 and X4AZ01, Section P.1, Revision 8.
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The following welder qualification status records and " Records of
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Performance Qualification Test" were reviewed relative to the weld
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joints listed in paragraph 7a.
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Weld Symbol
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1020
Within the areas examined, no violations or deviations were identified.
8.
Licensee Identified Items
(Closed) Item 424, 425/COR-82-32:
"HVAC Duct Support-Design Inconsist-
encies" (10 CFR 50.55(e))
On September 30, 1982, the licensee notified IE:II of a 50.55(e) item
concerning inconsistencies in HVAC duct support drawings. The final report
was submitted on August 15, 1983.
The inspector of record for report
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50-424, 425/87-05 noted that the final report indicated that 120 duct
supports were identified as having significant deficiencies.
Further that
modification of these supports had not occurred as of the date of the final
report but was intended after additional correction of the pCI drawings to
conform to design requirements. Cognizant licensee personnel were unable to
locate quality data confirming proof of modification of the 120 supports
during that inspection.
The licensee informed this inspector that the CDR reported 120 defective
drawings which represented 120 supports.
Not all the 120 supports
represented had been fabricated or installed prior to issuance of Stop Work
Notice SW-M-06 in September 1982.
Conditions for the release to continue work were that HVAC contractor only
work to Bechtel Power Corporation (BpC) statused (reviewed for compliance to
design) DS drawings. BpC began statusing all DS drawings in September,
1982.
Design Evaluation Report DER-025 was issued to track this initial statusing
effort which addressed approximately 4700 drawings.
Upon completion of
this statusing effort, BPC identified 120 drawings which had significant
discrepancies from the design drawings.
The licensee was unable to provide the inspector of record for report
50-424, 425/87-05 quality data conforming the acceptability of the 120
supports.
This inspector discussed the above with the licensee noting that the
licensee's final report did not include sufficient information to permit the
evaluation of the corrective actions as the supports requiring corrective
actions could not be identified. The preceeding is clearly contrary to, and
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'therefore, in violation of 10 CFR 50.55(e)(3) which requires the holder of a
construction permit to submit a written report on a reportable deficiency
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within thirty (30) days. The report shall include a description of the
deficiency, an analysis of the safety implications and the corrective action
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taken, and sufficient information to permit analysis and evaluation of the
deficiency and of the corrective action. This matter will be identified as
violation 50-424/87-11-02, 50-425/87-07-02:
" Failure to Provide Adequate
Report of Significant Construction Deficiency"
The licensee was finally able to provide this inspector a partial list (51
of the reported 120) of supports. This list was gleaned from private notes
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of the BPC Engineer in California who identified the 120 deficient drawings.
Of the 51 deficient drawings gleaned, only 16 supports had been fabricated
or installed prior to the stop work notice.
This inspector reviewed
drawings, and inspection documentation for all 16 supports, made a field
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inspection, and found no deviations from design requirements. Based on the
above inspection and other inspections made by this inspector, of the HVAC
contractor, performed after the stop work notice, and prior to this inspec-
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tion, this matter will be closed as a licensee identified item and opened as
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violation 50-424/87-11-02 and 50-425/87-07-02: " Failure To Provide Adequate
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Report Of Significant Construction Deficiency."
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Within the areas examined no deviations or violations were identified except
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as noted above.
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