ML20212A281

From kanterella
Jump to navigation Jump to search
Insp Rept 50-424/86-74 & 50-425/86-35 on 860812-1015. Violations Noted:Failure to Achieve Appropriate Corrective Action for Training Program & Failure to Provide Procedure for Testing Air Operated Valves W/Bailey Controllers
ML20212A281
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 12/11/1986
From: Livermore H, Rogge J, Schepens R, Sinkule M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20212A215 List:
References
50-424-86-74, 50-425-86-35, NUDOCS 8612220361
Download: ML20212A281 (46)


See also: IR 05000424/1986074

Text

I.

i

pa maop, UNITED STATES

/ 'o NUCtEAR REGUtATORY COMMISSION

[* , REGION il

3 y 101 MAR!ETTA STREET.N.W.

  • e ATL ANTA. GEORGI A 30323

\*...*/

Report'Nos.: 50-424/86-74 and 50-425/86-35

~

Licensee: Georgia Poser Company

P.O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109

Facility Name: Vogtle 1 and 2

Inspection' Conducted: August 12 - October 15, 1986

Inspectors: /

'

,

'

u- " [ /

Date Signed

[ M,, H. H. Livermore,

Inspector, Senior Resident

Co struction .

f>'O JJ

p g J. F. Rogge, Senior Resident

v/alu

Date Signed

Inspeqtor, Op rations

[, , ht '

Ijd 7[O (

cf R. J. Schepens, Resident Date Signed

IO' Inspector, Operations & Construction

Approved By: [f 1.t a.k .- I bb

M.V.SinkulhS~ectidnChief Dat'e Signed

Division of Reactor Projects

SUMMARY

Scope: This routine, unannounced inspection entailed Resident Inspection in the

following areas: containment and safety related structures, piping systems and

supports, safety related components, auxiliary systems, electrical equipment and

cables, instrumentation, preoperational test program, initial fuel receipt

inspection, quality programs and administrative controls affecting quality, and

follow-up on previous inspection identified items.

Results: Two violations were identified " Failure to Achieve Appropriate

Corrective Action" - Paragraph 24, " Failure to Provide Adequate Procedure for

Testing Air Operated Valves with Bailey Controllers" - Paragraph 20.

8612220361

DR 861211

ADOCK 05000424 PDR

32.5

__

w

.

DETAILS

1. Persons Contacted

Licensee Employees

  • R. E. Conway, Senior Vice-President, Vogtle Project Director

D. O. Foster, Vice-President, Project Support

  • P. D. Rice, Vice-President, Project Engineering

R. H. Pinson, Vice-President, Project Construction

W. T. Nickerson, Assistant to the Project Director

  • W. W. Mintz, Project Completion Manager

M. H. Googe, Project Construction Manager

G. Backhold, Jr., General Manager Nuclear Operations

T. V. Greene, Plant Manager

H. P. Walker, Manager Unit Operations

  • R. M. Bellamy, Plant Support Manager
  • C. W. Hayes, Vogtle Quality Assurance Manager
  • C. E. Belflower, Quality Assurance Site Manager - Operations
  • E. D. Groover, Quality Assurance Site Manager - Construction
  • W. E. Mundy, Quality Assurance Audit Supervisor

D. M. Fiquett, Project Construction Manager - Unit 2

  • B. C. Harbin, Manager Quality Control
  • G. A. McCarley, Project Compilance Coordinator
  • W. C. Gabbard, Regulatory Specialist

C. F. Meyer, Operations Superintendent

T. Dannemiller, Te<* Engineer

C. L. Coursey, Maintenance Superintendent (Startup)

M. A. Griffis, Maintenan Superintendent

D. McCary, Engineering Supervisor, GPC/PKF

  • G. R. Frederick, Quality Assurance Engineer / Support Supervisor 1

R. E. Spinnatu, ISEG Supervisor i

'

J. F. D'Amico, Nuclear Safety & Compliance Manager  ;

W. F. Kitchens, Manager Operations

V. J. Agro, Superintendent Administration

A. L. Mosbaugh, Asst. Plant Support Manager

  • G' Yunker, Nuclear Security, Corporate
  • M. P. Craven, Nuclear Security Manager

Other licensee employees contacted included craftsmen, technicians,

supervision, engineers, inspectors, and office personnel.

Other Organizations

H. M. Handfinger, Asst. Plant Support Manager - Bechtel

D. L. Kinnsch, Project Engineering - Bechtel

  • Attended Exit Interview

2. Exit Interview (30703C)

2

The inspection scope and findings were summarized on October 15, 1986 with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection finding listed below.

No dissenting comments were received from the licensee. The licensee did

not identify as proprietary any of the materials provided to or reviewed by

the inspector during this inspection.

(0 pen) Violation 50-424/86-74-01 " Failure to Achieve Appropriate Corrective

Action on the Implementation of a Formalized / Controlled Training &

Qualification Crane Operator Program for Operations Personnel Per QA Audit

Report No. OP11/16-86/17, Dated July 9, 1986." - Paragraph 24.

(0 pen) Violation 50-424/86-74-02 " Inadequate Procedure for Testing Air

Operated Valves With Bailey Controllers." - Paragraph 20.

(0 pen) Inspector Followup Item (IFI) 50-424/86-74-03 and 86-35-01 " Review

Results of Testing the Check Valves on the Feedwater Isolation Valves" to

verify new model 8F-C8!g-10-SS."-Paragraph 22.

(0 pen) Violation 50-424/86-09-01 " Failure to Perform and Adequate System

'

Walkdown During Turnover of Safety Related Systems" - Paragraph 3.

(Closed) Unresolved Item 50-424/86-60-02, " Inadequate Instruction and

Training for Ray-Chem Electrical Splice Installations." - Paragraph 4.

(Closed) IFI 50-424/86-51-05, " Posting of NRC-3 and Part 21 Forms." -

Paragraph 4

Ten Part 21 Reports and shree Construction Deficiency Reports were closed -

,

Paragraph 22.

The following NRC exit interviews were attended during the inspection period

by a resident inspector:

Date Name

August 18, 1986 A. Tillman, D. H. Thompson

G. A. Schnebli

September 5, 1986 W. H. Miller

W. Kleinsorge

September 12, 1986 G. A. Schnebli

September 26, 1986 T. F. McElhinney

L. H. Jackson, R. D. Gibbs

C. F. Smith, M. Shannon, R. A. Moore

L. E. Nicholson

Octotier 3,1936 N. Merriweather

1

- _.

- ,

!

!

3-

T. D.' Gibbons

G. A. Hallstrom

October 9, 1986 S. Q. Ninh

October 10, 1986 W. H. Miller, et. al.

On October 3, .1986, Mr. P. H. Skinner presented the results of his

inspection pertaining to allegations. The licensee was informed that his

inspection items would be documented in the resident inspector report. (See

paragraph Sa - h.)

3. Licensee Action on Previous Enforcement Matters (92702)

(0 pen) violation 50-424/86-09-01 " Failure to perform an adequate system

walkdown during the turnover of . safety related systems." The resident

inspections attended a meeting conducted by the licensee regarding the

P&ID walkdown summary, the purpose of the meeting was to inform _the

resident inspectors of the status as well as their findings, conclusions,

and actions as a result of their corrective action for the subject

violation. The licensee has written and conducted a special construction

acceptance test CAT-M-99 to perform a re-walkdown of all safety-related

systems. The status as of this meeting is that all safety-related system

re-walkdowns are complete and maintenance work orders have been written to

correct _ identified deficiencies found during their walkdown. Pending the

inspector's review of the completed package this item shall remain open.

4. Followup on Previous Inspection Items (92701)

(Closed) URI 50-424/86-60-02, " Inadequate Instruction and Training for

Ray-Chem Electrica; Splice Installations". Subsequent to the identification

of this item, a detailed Region based inspection was performed (Report

50-424/86-66; 50-425/86-31). More in-depth, unresolved item findings were

identified (01 through 07) for action. These findings are duplicate in

nature to Unresolved Item 50-424/86-60-02, therefore, this item is closed.

(Closed) IFI 50-424/86-51-05, " Posting of NRC-3 and Part 21 Forms". The

inspector has insured that NRC 3 and Part 21 Defect Reporting Requirement

forms have been posted in sufficient locations to permit employees to

observe a copy while traveling to or from their work places. This item is

closed.

5. Allegations

a. Allegation RII-85-A-0016-011, Investigation Concerning Stencilling

Small Bore Pipe Elbows

Concern

An alleger has stated that two individuals (including the alleger)

noticed several pieces of black small bore pipe elbows on the floor and

-

_ _ _ _-

-_

4

also observed two workers with a box of stencils hammering the stencils

on the pipe elbows. The alleger could only identify one of the

individuals doing the work. The alleger stated that the other

individual who noticed the activities being performed said that they

were doing something that they were not supposed to be doing. The

alleger observed the workers stenciling the pipe and stated a concern

that they appeared to be doing something that they should not be doing.

Olscussion

The inspector reviewed the present procedure (GO-A-30, Receipt, Receipt

Inspection, Storage, and Handling, Revision 12) and procedures dating

back to January 7, 1983. The process, in summary, is as follows:

(1) Material is received in a warehouse from the manufacturer and

placed in a hold area.

(2) Shipping papers are compared to purchase orders to determine

if order is correct.

(3) A receipt -inspection checking for marking, material packaging,

damage, dimensions, etc. is then performed.

l

(4) If a deficiency is noted a deviation report (DR), noting the

l

problem is issued.

1

I

(5) If no deviation is written the material is released to warehouse

personnel and moved from the hold area to the appropriate storage

area until requested.

(6) If a DR is written, the DR is submitted to an engineer who

recommends disposition. This can be to correct a problem, return

to manufacturer, use as is, reject, obtain valid documentation,

etc.

Based on discussions with warehouse personnel and QC receipt inspection

personnel, occasionally material is received by the warehouse without

the appropriate numbers stamped or etched into the pieces. When this

occurs a DR is written and generally the manufacturer sends a

representative to etch or stencil the f aulty pieces. This is done

using the DR corrective action section as the documentation and the

work is witnessed by a QC inspector inspector.

Dac ;f the individuals the alleger identified was the Senior Quality

Control Inspector in charge of receipt, handling and storage of

material in the warehouse at that time. His function is to assure the

work was performed in accordance with the documentation provided. This

person was interviewed by the inspector. He frequently observed the

marking process, and ensured that ill work was done by appropriate

paperwork. No substantiation that this allegation was or was not valid

could be obtained.

-

5

The inspector also interviewed the individual that accompanied the

alleger. He had worked in the warehouse for several years. He stated

that the only stenciling or marking of any material that he was aware

of was performed in accordance with the required documentation. The

statement, "they were doing something that they were not supposed to be

doing", could not be substantiated by the person identified by the

alleger.

.

The inspector concludes that the alleger did observe workers stenciling ,j

small bore pipe, but that it was done in accordance with controlled  !

documentation and under direct observation of a senior quality control  ;

inspector. No indications could be identified that this process was  :

unacceptable. The remarks by the accompanying individual with the

alleger and the worker doing the stenciling could not be substantiated i

but could have been stated in a joking manner. ,

Cnrclusion  !

'

Based on this review, this concern is closed.

b. Allegation RII-85-A-0016-024 Concerning Certification of NDE Inspectors

Without Required Training.

Concern

An alleger stated that a senior civil inspector said that in the old

days he and several other inspectors walked into the training building

one day and the GPC instructors told them that they were NDE inspectors

and gave them certification cards. This senior civil inspector also

told the alleger that the inspectors did not receive any training and

that they were instantly certified for the job. This civil inspector

also made a joke of the situation by saying that they were so good that

they did not need any training. The alleger stated that this occurred

sometime during the period of 1977 to 1978. The alleger also stated a

concern that many of the individuals are senior inspectors today and

identified four additional senior individuals that may have received

certifications in the manner stated above.

Discussion

The inspector reviewed the training records for each of the individuals

identified in the allegation. These records provide dates of classroom

instructions and examinations given for each of these persons. The

examinations appear to be in the handwriting of each individual

concerned based on comparison with other documents in the training

records. Resumes of experience and educational requirements were also

reviewed. Records indicate that training was provided and subsequent

testing given to all of these persons. The inspector also reviewed

records of several other senior inspectors and found no indications

that ...ual training and testing was not provided.

l

.

.

6

In addition to the review of training records, the inspector

interviewed the senior civil inspector and three of the other senior

inspectors identified in this allegation. Each stated that they had

received the appropriate training either at Vogtle or at the Hatch

Nuclear Stations.

Conclusion

The inspector can find no information to substantiate this allegation.

Based on this inspection this item is closed.

c. Allegation Ril-85-A-0016-012 Concerning Turnover of Systems to

Production With Open Deviation Reports

Concern

An alleger stated that while in charge of putting Deviation Reports

(DR) on the computer for tracking purposes, an open DR was identified

for a system that had already been turned over to production the day

before. The OR was associated with a piping system (either 2301, 2304,

2401 or 2403). The alleger also stated that the procedure requires the

system to be completely ready when it is turned over to production. In

addition to the DR, there was also a CWR (Construction Work Request)

open on the DR. The alleger stated the matter was reported to an

individual (presumably the alleger's supervisor) and that this

individual did not provide any information about the DR. The alleger

could not recall what the OR pertained to. The alleger said the DR was

sent to Bechtel as required. The alleger expressed concern that the DR

system had broken down in this case because the piping system in

question should not have been turned over to production with an open

OR. The alleger feels that this was an admi~nistrative oversight on

someone's part. The alleger also stated that the supervisor said the

OR was not important and not to worry about it. The alleger stated

that these concerns are still ongoing at the i l ant.

Discussion

The inspector reviewed the licensee's programs for turnover of systems

to production. These programs are detailed in Construction Procedure

GO-A-48, Nuclear Construction System Turnover and SUM-9 System

Turnover. GD-A-48 revision 0 was not issued until 7/26/85 so at the

time of this allegation construction was using SUM-9, revisions 0, 1,

2, 3 or 4 for preparing a system or portion thereof for turnover to

production. SUM-9 revisions 0 through the present revision 9, were

reviewed by the inspector. SUM 9 requires that for a turnover all work

is to be complete or documented in the turnover packaged. This allows

for minor work and documentation to still be open at the time of

turnover. The production review process then identifies which of these

items must be worked prior to production acceptance of the turnover

package. Since this process is a collection of known status items any

subsequent work or deficiencies identified would be handled by programs

m

i

7

.

outside this turnover process. Deficiencies that are identified during

the period of time from when construction provides the turnover package

to production and production accepts the turnover (generally about I

week average), a construction completion engineer will meet with the

system startup engineer and add any deficiency (pen and ink change) to

the system punchlist (MTS) or replace the MTS with an updated MTS

containing the new deficiency. If a pen and ink change was made the

MTS, the computer is also updated to track the deficiency. Since a CWR

was written to correct the DR, it would not be tracked since there is

no reason to track two items, when tracking either will accomplish

statuing. The DR process is independent of the turnover process so

even if the DR was not identified on the turnover list, the DR would

have been cleared due to its own program. When the turnover has been

accepted by production, the system or portion thereof, is posted using

green jurisdictional tags to preclude any work unless the work is

allowed by production personnel.

The inspector also interviewed the individual identified by the alleger

as the person with whom the discussion regarding the DR took place.

This individual stated that in the early stages of the initial

turnovers to production, occasionally information was inadvertently not

included in the packages. The packages were updated by issue of a

revised package or pen and ink changes before final package acceptance

by production. This individual and other construction and productions

personnel interviewed by the inspector could not identify any case

where a temporarily misplaced or overlooked item caused a subsequent

rejection by production of the turnover package. Construction

determined in July 1985, that SUM-9 did not fully meet their needs and

generated a procedure (GD-A-48) to improve this process.

The inspector reviewed all turnover packages for systems 2301, 2304,

2401 and 2403. Since this allegation occurred prior to January 1985,

all turnovers associated with these systems af ter March 1985 were not

reviewed in depth. This eliminated systems 2304 and 2403. The

turnover packages associated with system 2301 prior to March 1985,

identified that pen and ink changes were made to MTS prior to final

acceptance by production of the package. The turnover packages

associated with system 2401 also identified a DR that had been added as

a pen and ink change prior to final acceptance. The open DR was sent

to Bechtel for resolution which is the normal process for DR's.

Conclusion

Although a DR was identified af ter a system has been turned over to

production, this does not indicate a breakdown in the turnover process.

The turnover process allows DR's and other items to be open at the time

the system is accepted by production. It does appear that this was an

administrative oversight but also appears to be an isolated case.

Since the DR was not identified it could not be determined that the

open DR was the same DR as shown with the pen and ink change in system

2401, only that the system described was being used at that time. It

l

l

l

_

r

8

also does not appear that the OR system broke down since the OR was

sent to Bechtel for resolution. Although procedures have been revised

to minimize the oversight that occurred, programs are in place and

appear to be t'rking to correct any oversight that is identified.

Based on this review this item is closed,

d. Allegation Ril-84-0169-005, Concerns Regarding Pipe Break Restraints

(PBR) Repairs in Unit 2 Containment Building

Concern

An alleger stated that some PBR's in Unit 2 containment building had

accidentally been cut off by construction personnel. These PBR's were

to be repaired with additional structural steel sections using a

welding process which required the welds to be radiographed. The

alleger stated that the crew assigned to perform this work on the north

side of containment was not the same crew that repaired the PBR's on

the southeast side of containment.

The crew working the north side repairs had difficulty getting the

welds to pass the required radiographic inspections. The alleger

stated a concern that the crew was removed because they were taking too

long to repair the' PBR's and that the supervisor of the crews could get

the "B" shif t Quality Control to sign them of f without having to go

l through all the problems that the original crew experienced. The

alleger stated a concern that the PBR's on the southeast side of

containment were not properly installed or radiographed.

Discussion

The inspector investigated this cancern. Six pipe whip restraints were

inadvertently cut as identified in Deviation Report (OR) CD-2974 dated

Jan. 3, 1983. The disposition of this DR was, in part, to fabricate

new pieces, weld to existing stubs and perform radiographic inspections

of all new welds. Records of repairs to these six PBR's (three on the

north side of containment and three on the south side) indicate one

weld joint on one of the PBR's on the north side was rejected and

reworked two times before final acceptance. These failures were due to

excessive porosity. The PBR repairs on the south side of containment

showed one weld on two of the PBR's as having one weld rejected twice

and the third PBR had one weld rejected three times before final

acceptance. These were also due to excessive porosity.

Conclusion

The inspector concludes that the PBR's were properly repaired and

radiographed as specified in the corrective actions defined in the DR.

There appears no evidence that supports an implication that Quality

'

Control was not adequately maintained since seven weld failures

occurred during repairs on the PBR's in the south side of containment

as compared to two failures in the north side of containment. Pased on

L .

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _

9

this inspection, the inspector could not substantiate improper work

practices nor improper quality control personnel practices and thus

considers this item as closed.

e. Allegation RII-84-0169-10 and 12, QA/QC Record Keeping Practices Are

Inadequate for the Program.

Concern

An alleger stated that the Pullman Power Products (PPP) QC/QA record

keeping program is a shambles, that PPP will always rush to file and

update records when they find out that they are going to be audited,

and that a mistake is made when PPP is advised that an audit will be

conducted. The alleger further stated that the alleger heard that the

i PPP QA/QC paper work is so messed up that they will never be able to

get it straight, that documents are misfiled and that the records are

generally in very poor shape. .

Discussion

The licensee cortforms to ANSI N45.2.12 " Requirements For Auditing of QA

Programs for Nuclear Power Plants" in which paragraph 4.2.4 " Audit

Notification" states, " Involved organizations shall be notified of a

scheduled audit a reasonable time before the audit is to be performed."

The licensee generally provides a 3 to 7 day notification for their

required audits. The NRC also conducts routine audits of all licensees

and most f these audits are unannounced.

,

Various audits have been performed by the licensee of the PPP QA/QC

record keeping- program and concluded no significant findings. In

addition, the NRC has performed audits of PPP's QA/QC documents

including welding documents and found them to be acceptable. The

inspectors reviewed the licensee's audits of PPP's QA/QC records

program as well as those performed by the NRC.

The Inspector reviewed various PPP QA/QC documents including welding

documents and found them to be acceptable. The Inspectors reviewed the

licensee's audits of PPP's QA/QC records program as well as those

performed by the NRC.

! 9

Conclusion

This allegation was very general with no specific information

available. The inspectors reviewed the areas of concern in detail and

could not substantiate the allegation. Based on this investigation

this item is closed.

f. Allegation RII-84-0169-11, Excessive Heat Used During the Welding of

Pipe Break Restraint (PBR) Racks to Embed Plates.

! Concern

!

i

muum -

,. -

0

10

An alleger stated that in Unit 1 containment too much heat was used

during the welding of PBR racks to embed plates. This individual felt

that the proper procedure was not used and that this resulted in a

large number of nonconforming reports (NCR's) being written because of

the overheating during welding.

Discussion

PBR's, at the Vogtle plant have been deleted with NRC approval,

therefore welding associated with these restraints would not constitute

a safety problem. The inspector has concluded that the welding that

was identified by the alleger was performed on pipe rack welds which

are commonly referred to as PBR's. Since this conclusion was reached  ;

by the inspector, an investigation into welding problems identified  ;

that there had been procedure and heat related problems associated with 4

these components. They were identified to the NRC Region II as a Part i

10 CFR 21 Reportable Item (CDR 84-66) in correspondence dated October ,l

17 and October 31, 1984. The corrective action identified in CDR 84-66 i

'

was discussed in NRC Inspection Reports 50-424/84-30, 50-424/84-36,

50-424/85-03, 50-424/85-08, and 50-424/85-40. This CDR was closed by l ,

region based inspectors in report 50-424/85-40.

'

!

I

Conclusion {

This allegation appears to have been associated with pipe. rack welds i

'

rather than pipe break restraints. This problem was identified by the

utility through their 10 CFR 21 reporting process. The problem was

reviewed in detail by region based inspection personnel and addressed

by NRC in various reports identified above. Based on this

investigation the inspector considers this item as closed.

g. Allegation RII-84-0169-14, Concern That Pullman Procedure 32-III Is Not

A Qualified Procedure.

Concern

An alleger was told by an individual from Westinghouse that if the

fitup of the hot legs on either end was made land to land that the weld

procedure would not be qualified. This weld procedure (WPS) was

identified as (W)32-111. The alleger further stated that after

several discussions with other personnel the question of WPS 32-III

appeared to be resolved and that the procedure was qualified. The

fitup of the hot legs were made land to land. The alleger stated that

several days later the hot leg fitup was nodified to accept a K-insert

and based information on this the alleger concluded that procedure WPS

32-III was, in fact, not qualified.

Discussion

Procedure WPS 32-III was reviewed by a NRC welding inspector and

addressed in Inspection Report No. 50-424 & 425/85-11 dated April 8,

,

I

h y

11

1985. Discussion with the Westinghouse engineer that made this

statement to the alleger determined that he agreed with the inspector

that the procedure was qualified. The previous di!cussions between the

Westinghouse engineer and the alleger appears to have been a

communication problem. Discussion with additional personnel on site

indicate that the preferred method of this weld is with a consumable

insert. The hot legs were repositioned to accept a K insert. The

inspector reviewed all hot leg piping weld joint records for both units

and identified that inserts were used on each weld.

Conclusion

Welding procedure WPS32-111 is a qualified procedure. The omission or

addition of a consumable insert is not an essential variable in welding

procedure specifications but it is an essential variable on welders'

performance. Since the hot legs all had inserts installed the question

concerning land to land fitup is not applicable.

h. Allegation RII-84-A-0169-015, Concern That Repair of Hole In Weld

Repaired By An Individual That Was Not Certified And Not Properly

-

Documented.

Concern

l

l An alleger, while working with another individual in containment,

l stated that they observed a crew working on primary system piping. The

l alleger saw a supervisor perform some unauthorized welding. This

l welding occurred on a pipe being fit for automatic welding. A problem

i

had apparently developed and the alleger observed the supervisor grab a

! welding torch and perform a manual butt weld. The alleger thought the

+

weld was on the hot leg or cold leg on Unit 1 between the steam

l

generator and reactor vessel. The alleger also identified the second

individual that witnessed this occurrence. Region II personnel

contacted this second individual. The second individual identified the

same observance except identified that the pipe was on the surge line

from the pressurizer to the hot leg and that this weld was the first

weld outside the wall east of the pressurizer.

Discussion

The inspector contacted the alleger and discussed the conversation

between Region 11 personnel and the second individual. The alleger

concurred that the weld was on the surge line from the pressurizer to

the hot leg. The inspector pulled all weld records for each weld on

this surge line and performed a review of this documentation. This

review indicated that two of the weld joints during fitup and root pass

welding were rejected and had to be cut out and rewelded. A third weld l

was rejected af ter final welding and had a portion of the weld ground l

out and rewelding performed. Each weld on this line was subsequently

l

radiographed and found acceptable and also pressure tested during the

primary system hydrostatic test Records indicated that the welders

l

,

o

12 ,

performing these welds were certified and that supervisor was not

listed as assisting in the weld process.

Conclusion

Based on this inspection, the inspector considers that the weld joints

on the surge line between the pressurizer and the hot leg meet required

specifications. The concerns associated with the supervisor performing

work will be addressed in a subsequent report.

1. Allegation RII-83-A-0103, Alleged Falsification of Non Destructive

Examination (NDE) Documentation by a Quality Control (QC) Inspector.

Concern

A QC-NDE inspector was terminated for allegedly falsifying Liquid

Penetrant (LP) inspection reports. The individual was terminated from

employment on 4/18/84 after being confronted by Pullman Power Products

(PPP) management to point out location of welds recently inspected and

then not being able to do so.

Discussion

The inspector conducted a review of PPP's interoffice correspondence

which documented their justification for terminating the subject

individual for misconduct in preparing and submitting incorrect Quality

Assurance (QA) records falsely indicating that he had performed certain

tests.

The inspector followed and reviewed the PPP and GPC reinspection

program for the subject inspector's work. This review consisted of

reviewing interoffice correspondence which documented the status and

findings of the reinspection program at various phases during the

reinspection process, reviewing Liquid Penetrant examination records

documenting the reinspection of ISO / Weld No's. 2K3-2303-007-04/

A007-W-13A; IK3-1592-041-01/041-W-110; IJ7-1592-060-01/W:

IJ7-1592-060-01/U; IK4-1208-488-03/B; IK4-1203-488-03/A;

IK2-1592-111-01/111-W-120; IK2-1202-134-03/134-W-354 and

2K2-1592-007-02/007-W-15; and reviewing Deviation Report No's. PP-4654

and PP-5255 which documented to rework or repair as required the

deficient conditions identified during the reinspection program.

This matter was also identified by the licensee as a potential

reportable Deficiency No. CDR M-62 on April 24, 1984. Subsequently,

the final report was submitted on April 18, 1985 which documented the

licensee's evaluation of this matter as not reportable pursuant to the

requirements of 10 CF 21 and 10 CFR 50.55(e). This item was reviewed

and closed in Inspection Report No's. 50-424/86-60 and 50-425/86-27.

Conclusion

_

l

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _____.

13

The licensee identified all welds inspected by the subject individual

during period of employment from 1/7/82 to 4/18/84. This list

consisted of safety and non safety-related piping welds in accordance

with ASME and ANSI B31.1 Power Piping Codes as applicable. After

conducting several random sampling plan reinspections per Mil-STD-1050

the licensee decided to reinspect 100% of all accessible ASME welds

requiring LP inspection by Code (i.e. ASME Code Class 3 2" and smaller

and ANSI B31.1 welds which were originally LP inspected were not

reinspected as apart of the reinspection program since they are not

required to be inspected initially in accordance with the Code) by this

individual. This was documented in a letter by the Unit 1 PPP QA

Manager dated 5/29/86. The licensee also identified other inspections

conducted by this individual which consisted of Ultrasonic Testing for

thickness measurements. A reinspection program per Mil-Std-105D was

implemented by PPP and the results were found to be acceptable. Based

on a review of the licensee's reinspection program, the inspector

concludes that the licensee's corrective action is acceptable,

I therefore, this concern is considered closed.

l

l j. Allegation RII-84-A-3128, Employee Concern Regarding Installation of

Ventilation Ducts.

'

Concern

During an audit of the licensee's Quality Concern program in May of

1984 the Senior Resident Inspector reviewed a Quality Concern file

which documented several concerns expressed by an employee during the

individual's exit interview. The employee's concern was that there was

improper workmanship used in the installation of ventilation ducts.

Details of the employee's concerns were contained in a ten (10) volume

notebook diary kept by the individual while employed at Vogtle.

Discussion

-

The licensee Quality Concern File No. 84V036 documented their

investigation into these concerns. The licensee contacted the former

employee after the exit interview in order to obtain a deposition and a

copy of the employee's ten (10) volume notebook diary. After a

comprehensive review of this material the licensee categorized

twenty-five (25) concerns of which at least three (3) were gleaned from

the employee's comments contained in the diary. GPC Ouality Assurance

Department investigated all of the concerns except for six (6) which

were investigated by the Quality Concern program.

The inspector conducted a review of all twenty-five (25) concerns

identified in the licensee's Quality Concern file. From this review

the inspector determined that eleven (11) of the concerns had been

previously identified and documented by either GPC via a Deviation

Report or an Audit Finding Report or the HVAC subcontractor via a

Non-Conformance Report (NCR) or a Corrective Action Request. Thirteen

(13) of the concerns were not found to be a concern since they were

.=

14

determined .either to be not a requirement, not a quality related

matter, .not substantiated, in compliance with approved procedures, or

adequate procedures were verified to be in place and compliance was

established by QA audits; and one (1) concern which was substantiated

was subsequently identified by a Deviation Report and a Corrective

Action Request.

The inspector conducted a review of the following documents to verify

that appropriate corrective action had been taken to resolve the

identified concerns: Deviation Report No's. MD-4877 (NCR-363), MD-4878

(NCR-368), CD-6899, MD-4056, and MD-4061; Audit Report / Audit Finding

Report ( AFR) No's. 84-1-QC, MO 08-83/29 (AFR No. 422), MD 08-83/69 ( AFR

No. 489), and AFR No. 341; Corrective Action Request No's. 17, 19, 20

and 23; Procedure No's. JP 3.3, JP 10.11, JP 13.3, JP 14.2, JP 15.1, JP

15.2, GO-A-06, GD-T-11, Specification No. X4AJ0-1, Division H-9; and

Potential Reportable Construction Deficiency Report No. 43, which was

subsequently determined not to be reportable.

Conclusion ,

The inspector has completed the NRC's review and follow-up to the

licensee's completed Quality Concern File No. 84V036. Based on this

review the inspector has concluded that the licensee has conducted a

comprehensive investigation into the concerns identified in Quality

Concern File No. 84V036. In Addition, where applicable, appropriate

corrective action was identified by the licensee. Based on the above.

the Resident Inspector's follow-up to Quality Concern File No. 84V036

is considered to be complete, therefore the item is closed.

k. Allegation RII-85-A-0210, Quality Control (QC) Inspector Alleges

Himself Unqualified and Questions Invalidation of Deviation Report (DR)

No. EO-10337.

Concern

On October 15, 1985 a QC Electrical Anchor Bolt Inspector at Vogtle

Electric Generating Plant filed the following allegations with the

Resident Inspector's of fice. The alleger stated that he has been

certified by the licensee as a Level II QC Electrical Anchor Bolt

inspector in accordance with ANSI N45.2.6 even though in his opinion be

does not have the required past experience in this field (i.e. , Anchor

Bolt Installation Inspection). Also, the alleger expressed a concern

regarding the justification given for invalidating DR No. E0-10337

since he feels it does not address the deviation noted.

Discussion

GPC Field Procedure Manual Procedure No. QC-A-01 " Qualification and

Certification of Technical Inspectors" establishes the GPC Quality

Control Program for qualification, certification, and training of

personnel who perform inspection. examination, and/or testing to verify

1

)

,

15

conformance to specified requirements during construction. This

procedure was written to comply with ANSI N45.2.6 (1978) and Regulatory

Guide 1,58 (September, 1980).

The inspector conducted a review of the alleger's Certification of

Qualification Record consisting of the individual's resume of prior

experience, supervisor's report of job experience, training completion

record, experience waiver, and eye examination. The supervisor's

report of job experience documented the fact that the individual

satisfied the experience and/or on-the-job training requirements for

certification in the area specified and at the designated level. The

training completion record documented the successful completion of all

required courses (i.e., general, specific, and practical). The

experience waiver documented that the individual did not meet the

minimum experience levels and that the required academic curriculum and

demonstration of the knowledge and skill necessary for performance at

the level for which the individual is certifying to be satisfactory by

performance.

The inspector questioned why the supervisor's report of job experience

documented that the inspector had the required experienc'e and than at a

later date an experience waiver was completed to document that the

individual did not have the required experience. The licensee stated

that as a result of an audit they were requested to verify experience

by contacting previous employers. During this review it was determined

that not all job sites contacted could or would release information to

verify this individual's previous employment. As a result an

experience waiver was completed and placed in the individual's file in

accordance with Procedure QC-A-01. Subsequently, the licensee has

contacted the individual's previous employer who was able to verify the

individual's previous experience at various job sites, consequently,

the subject individual did in fact meet the experience requirement as

originally stated in the suservisor's report of job experience. The

prcblem associated with the initial attempt failing to verify all of

the individual's previous experience was due to the licensee contacting

the various job sites that the individual worked at in lieu of

contacting his previous employer directly.

The inspector conducted a review of DR No. E0-10337. The discrepant

condition noted by the QC Inspector was that the edge distance on 3/4"

and 1" Type 14 conduit supports was not in compliance with GPC Field

l Procedure Manual Procedure No. GD-T-27. The DR was invalidated since

the spacing ar.d edge distance for these supports was determined by

applicable design drawings in lieu of GO-T-27. The inspector conducted

a review of the applicable Design Drawing No's, AX2094V050 and

AX2094051 which detailed conduit support type 14 installation criteria.

This detail refers you to Note 27 which states in part conduit shall be

attached to supports with the appropriate sized P2558 pipe strap and

bolting hardware. Refer to Unistrut General Engineering Catalog for

hardware detail.

!

-. .- _ _ -

16

A review wa's conducted of the - manufacturer's standard sizes and

dimensions against those stated in the DR to determine that the conduit

pipe straps were in compliance. It should be noted that Procedure No.

GO-T-27 states "In case of disagreement between this procedure and the

specification or design drawings, the specification or design drawings

govern". The requirements contained in GD-T-27, Exhibit 1 are from

Bechtel Specification X2AP01 which are for normal face-mounted plates.

In this case, the design drawing which overrides the specification and

procedure specifies the use of Unistrut P2558 straps therefore Exhibit

1 of GD-T-27 is not applicable for this installation.

The inspector also conducted a review of the licensee's Quality Concern

File No. 85V0492 which documents their investigation of the same

concern. This review verified that the licensee conducted a meaningful

investigation of the alleger's concerns.

Conclusion ,

I

The inspector's review of the alleger's certification file revealed i

that he was certified in accordance with Procedure QC-A-01 and did in

fact meet the previous experience requirements as required by the .

Regulatory Guide and the ANSI Standard. Also, a review of DR No. ED  !

10377 revealed that the deviation noted by the QC Inspector was in fact t

properly addressed as not a deviation. Based on the above, this j

allegation is considered to be unsubstantiated and is therefore j

considered to be closed. '

i

1. Allegation RII-86-A-0192, Instructions to Workers by General Foreman '

_

and Foreman Caused Workers to Violate Procedures.

Concern .

The alleger accompanied by a Pullman Power Products (PPP)

Administrative Manager and a PPP Union Steward came to the NRC Resident

Inspector's Of fice on June 16, 1986 with the following information

j The alleger and co worker were given a job by their general foreman and

>

foreman to remove two stainless steel flanges. The general foreman

,

told them to remove the flanges and cover the openings with duct tape.

The flanges were to be taken with engineer's accompaniment to the

j' nuclear warehouse. The workers were also told that a clearance was not

needed. The workers went to the work area and removed the first

flange. At that point the foreman arrived and told the workers to

discontinue the work because PPP Quality Control inspection (QC) and

'

Georgia Power Company (GPC) Operations was needed. The forer.an stated

that QC was on the way to the job site. The PPP QC inspector arrived

to check the work. The inspector stated a hanger interfered with the

removal of the second flange and additional paperwork would be

i required. The allegers co-worker took the first flange to the foreman

and on to the warehouse while the alleger went to turn in his tools and

'

then to the rest room. Upon Iaaving the rest room the foreman

l Intercepted the alleger and stated that the foreman had gone to the

I

i

< _ _ _

_ _ _ _ _ _____ ___ __ _

17

work area and the workers were not there and that the GPC engineer was

there inspecting the work. The alleger was terminated the next day for

performance of work in an unsatisfactory manner. The alleger feels

that this action was inappropriate in that the foreman and general

foreman instructed the workers to violate procedures.

Discussion

The inspector reviewed the work documentation associated with this

item. GPC procedures and PPPprocedures were in control of this work.

PPP procedure XIII-4, Cleaning Procedure Section 9.7 states " Pullman l

Power Products QC (and GPC Nuclear Operations Personnel, if required by

^

the MWO) will perform the initial system entry cleanliness inspection".

A review of MWO 18607436 did not identify that GPC personnel were

required to perform this inspection. The foreman contacted GPC

personnel to determine if they wanted to perform this activity. GPC

opted to perform the inspection and the foreman states this information

was given to the workers. Based on this inspection there was no

procedure violation. l

)

Conclusion  ;

,

There is no information to substantiate the alleger's statement that

procedures were violated. The remainder of the information provided by

the alleger appears to be a dispute between the employee and employer '

which is not an area that is addressed by the NRC. Based on this

inspection this item is closed.

m. Allegation RII-85-A-0230-01, Improper Welding Practices.

Concesa

Hangers on Loop 4 in Containment Building, Unit I were fabricated on

some steel incorrectly, and hangers were subsequently moved two (2)

times in an effort to correct the situation. Alleger feels the

mistakes were never corrected in spite of the two (2) additional

movements of the hangers.

Discussion

The inspector confirmed through discussions with the alleger's foreman

that the supports being questioned are identified as TS-1, 2, & 3 which

support the Reactor Vessel Level Inst: urnentation System (RVLIS)

Instrumentation Tubing Sensor Barrier Box and Valve Barrier Box. The

inspector reviewed the applicable drawing No. 1X5DPM713 depicting the

supports design and the documentation package which reflected that the

supports were reworked as a result of a design change and interferences

encountered in the field during installation. The inspector verified

that the reworks were properly documented and processed by Field Change

i Requests.

l

,

.- -. - - - - - _ _

!

'

.

I

18 ,

l

Conclusion

Otscussions held with the foreman and Lead Instrumentation Engineer '

confirmed that_during the installation of the subject supports several

reworks were encountered as a result of design changes necessitated as

a result of conditions encountered in the field. In conclusion, the

inspector's review of this concern revealed that the subject supports

were installed in accordance with applicable design drawings and the

documentation package adequately documented the reworks as a result of

Field Change Requests. The hanger interferences encountered are

considered to be normal during the installation process of a project of

this magnitude therefore additonal corrective action was not required

or necessary.

Based on the above review this allegation was determined to be without

substance since there was no evidence found where steel was fabricated

incorrectly, nor were mistakes found to be not corrected. This item is

is considered closed.

n. Allegation RII-85-A-0230-02, Improper Welding Practices.

Concern

" Welders tacked these hangers up without pre-heating at all, and this

was done on the foreman's order."

Discussion

Discussions with the alleger's foreman revealed that the

instrumentation crew was aware of the preheating requirement when

welding a support to structural steel which is greater than 1-1/2

inches but did not realize that trik requirement (preheat) was also

applicable on tack welds. The foremar, stated that once he became aware

of this requirement by Quality Control he did not instruct any welders

to make tack welds without preheat.

The inspector conducted a review of 3PC Quality Concern File No.

85V0582 to review the alleger's allega. ion submitted to the licensee in

this area. The alleger identified Support No. ILT-503-M017-H12 to the

licensee as one which was tack welded without preheat. The inspector

reviewed the licensee's corrective action to this concern which

consisted of the following:

1) Deviation Report No. 10-1532 was written to document the

deficiency.

2) Construction Work Request No. 1-1259 os written to remove

Support No. ILT-503-M017-H12 and re-weld documenting the

preheat.

L

s. 19

3) Development of an inspection plan identified as Attachment AA

to -- GPC letter dated May 16, 1986 which documented the

licensee's re-inspection of hangers tack welded to structural

steel greater than 1-1/2 inches without preheat per

MIL-STD-1050. Results were satisfactory.

In additon, the alleger identified to the itcensee an additional hanger

(no identification number was reported by the submitter) to have also

been installed without preheat. This hanger consisting of two pieces

of tube steel was located on Unit 1 Containment, C-level, Loop 4 area.

The inspector confirmed through discussions with the alleger's foreman

that the hanger in question is identified as TS 1, 2, & 3. As noted in

Allegation No. RII-85-A-0230-01 these supports were reworked several

times due to design changes and interferences. The inspector reviewed

the documentation package for the installation of their supports which

documented that the tack welds were preneated.

During the licensee's investigation into this matter it was determined

that a procedure violation had occurred in that Pullman Power Products

Procedure No. IX-43 requires tack welds to be preheated. It was

further determined that this violation was a result of the

instrumentation crew not being properly trained in the requirements

contained in Pullman Power Procedure IX-43 pertaining to preheating

tack welds. Corrective action to prevent recurrence of this problem in

the future consisted of a development of procedure awareness among the

appropriate-perscqnel regarding the preheat requirement. The inspector

'

conducted several random interviews of instrumentation personnel to

i

verify that they are aware of the requirement to preheat tack welds on

support steel greater than 1-1/2 inches. This included the alleger's

foreman. This catter will not be cited as a violation since the

licensee identified this violation during their investigation into the

,

alleger's concerns and took the appropriate corrective action.

'Conclusicn

,

Based on the above review this allegation was determined to be

substantiated. The inspector verified that the licensee took the

appropriate corrective action to repair the identified supports, to

confirm that the existing instrurrent hangers installed without preheat

to tack welds were satisfactory by performing additional inspections

which exceeded original requirements in accordance with a sample plan

per MIL-STO-1050 and to train instrumentation crew in the requirement

of preheat tack welds per Pullman Power Procedure IX-43.

o. Allegation RIl-85-A-0230-03, improper Welding Practices.

Concern

The steel where the aforementioned hangers were welded was never

"magged".

- _ _ - _ - _ _ _ _ _ _ . _ _ _ _ .

=

,

'

y

n

s g

,

  • {

l

4

20 ,, .f

,

w ,

k '..

l

Discussions i

l

-

.

! i. l

The' steel- to which the hangers are attached is identified as the

-

!

'

'

'

containment pipe racks. These racks have been designed in accordance {

with the 'American Institute of Steel Constructioo(AISC) Manual. The l'

inspection criteria applied- to these pipe racks- comes out :of the i-

'

- American Welding . Society (AWS) D1.1 Structural Welding Code which

requires visual inspection of welds unless otherwise .specified by the .

-

engineer. In the case of the containment pipe racks the engineer has J"

specified . visual inspection as the acceptable , criteria. Magnetic A

particles inspection (mag) is ' not- requirmi. -

,

. Conclusion 4

s ,

+

Based on the-inspector's review this Lallegation was determined to bc  ;

without substance, therefore this item is considered to be closed. l

" ^

p. Allegation RII-85-A-0230-04, Improper Welding Practices.

Concern

e.

'

y'

'

Alleger stated that alleger was told by a gener21 foreman to scribe the

alleger's welder number on stainless steel pipe even though alleger did

not perform the welding; and that the general foreman ordering this I

scribing knew the alleger did not do the welds. This scrib.e appears on i

reactor cooling = stainless steel piping located at Level C, Unit 1 l

. Containment Building, in a room marked 1W4, Column #27. '

,

,

Discussion o  !

, The inspector conducted a review of GPC Quality Concern Program File

No. 85V0582 to review the alleger's allegation submitted to the .

licensee in this area. The alleger's co-worker identified Weld No. 19

on Isometric Drawing No. ISK5Y01003-A to the licensee as the weld in

'

question. The weld is on the low pressure side of the isolation valve

No. 1-1901-X4-091 to Level Transmitter No. ILT-1003 associated with the

Reactor Coolant Drain Tank 1-1901-T6-001. The applicable code is ANSI

B31.l Power Piping Code. Interviews conducted with the alleger's c

foreman, co-worker, and Quality Assurance personneE revealed that the

all.eger's co-worker was assigned the task to stenci) the subject weld

with the appropriate welder's symbol. This was necessitated since the ,

weld was found to be without a stencil and the welder who performed the

,

weld was no longer on site. The method utilized by Pullman to

determine the correct welder was to review the well rod ticket which

identified the welder's name and symbol. This was determined to be an

unwritten policy. Subsequently, Pullman has revised 'th<tir Procedure

GWS III/I, Paragraph 7.2.7 to clarify the weld stencil requirements.

The inspector conducted a review of the weld rod ticket for Weld No. 19

for Isometric Drawing ISKYSY01003-A which identified the welder who

made the weld. Also a review of the Isometric Drawing ISKY501033-A was

t

5>

w_ ~

$

, -.

9, , . - ___ ._ .___

a. -[

4 '

,

'

1

,

y -

s

3 21

.

j  :

'

conducted which showed the location of the weld to be in Room No. RC-07

in Unit 1 Containment Level C.

Conclusion

3

Based on the above review of this allegation, this item was determined

'

to be without substance in that the alleger's co-worker was requested

to place the appropriate welder's symbol on a weld since the welder who

performed the weld was no longer on site. The method described above.

-1.e. to restencil a weld with the correct welders symbol through

'

'

confirmation of the weld rod ticket, is considered to be an acceptable

practice when it is determined that the welder is no longer on site.

p Therefore, this item is considered to be closed.

t,

!t q. Allegation RII-85-A-0230-05, Improper Welding Practices.

~

Concern

Alleger was terminated for insubordination. Alleger stated that the

reasons for the act of insubordination and subsequent firing involved

the way jobs were being performed at Vogtle contradictory to Quality

Assurance requirements. Alleger stated that after informing the GPC

Quality Concerns Program of alleger's concerns, there were no visible

results and no one has even talked with alleger's co-workers about the

, concerns.

s

Discussion

The inspector has conducted several inspections of the licensee's

Quality Concern File No. 85V0582 which documented the alleger's

concerns, the licensee's investigation of the concerns, and the

response mailed to the alleger to address each concern. These reviews

are documented in Inspection Report No's. 50-424/86-09 and 50-425/86-04

and 50-424/86-60 and 50-425/86-27.

Conclusion

f

Based on the inspector's review of the alleger's allegations and the

licensee's Quality Concern File No. 85V0582 this allegation was

determined to be without substance. The inspector found that the

$'- license did in fact actively pursue and investigate all of the

4 alleger's concerns. In addition, the alleger's allegations did not

'k reveal any evidence where work was being performed at Vogtle

intentfodally ontradictory to Quality Assurance requirements, did

interview co-workers, and did contact the alleger with results,

therefore this item is considered to be closed.

6. General Construction Inspection - Units 1 & 2

i

,

4

,

i

,

22

f

i

i

Periodic random surveillance inspections were made throughout this reporting .l

period in the form of general type inspections in different areas of both i.

facilities. The areas were selected on the basis of the scheduled

activities and were varied to provide wide coverage. Observations were made

of activities in progress to note defective items or items of noncompliance

with the required codes and regulatory requirements. On these inspections,

particular note was made of the presence of quality control inspectors, i

supervisors, and quality control evidence in the form of available process  ;

sheets, drawings, material identification, material protection, performance i

of tests, and housekeeping. Interviews were conducted with craft personnel, l

supervisors, coordinators, quality control inspectors, and others as they  !

were available in the work areas. The inspector reviewed numerous  !

construction deviation reports to determine if requirements were met in the j

areas of documentation, action to resolve, justification, and approval i

signatures in accordance with GPC Field Procedure No. GD-T-01.  !

!

No violations or deviations were identified.

7. Fire Prevention / Protection and Housekeeping Measures - Units 1 & 2 (42051C) j

The inspector observsd fire prevention / protection measures throughout the

inspection period. Welders were using welding permits with fire watches and l

,: extinguishers.- Post indicator valves were being maintained in the open i

t

position. Fire fighting equipment is in its designated areas throughout the

,

plant. <

'

>

The inspector reviewed and examined portions of the following procedures

pertaining to the fire prevention / protection measures and housekeeping

measures to determine whether they comply with applicable codes, standards,

NRC Regulatory Guides and licensee commitments.

-SD-T-05, Rev. 6 Fire-Protection Equipment Inspection and Testing

-GD-T-15, Rev. 6 Welding and Cutting

-GD-T-17, Rev. 5 Housekeeping

, The inspector observed fire prevention / protection measures in work areas

containing safety related equipment during the inspection period to verify

the following:

-

Combustible waste material and rubbish was removed from the work areas

as rapidly as practicable to avoid unnecessary accumulation of

combustibles

-

Flammable liquids are stored in appropriate containers and in

designated areas throughout the plant

-

Cutting and welding operations in progress have been authorized by an

appropriate permit, combustibles have been moved away, or safely

covered, and a fire watch and extinguisher was posted as required

,

p ;--. . . .

23

-

Fire protection / suppression equipment was provided and controlled in

accordance with appilcable requirements

No violations or deviations were identified.

8. Structural Concrete - Unit 2 (47053C)

a. Procedure and Document Review

The inspector reviewed and examined portions of the following

procedures pertaining tc the placement of concrete to determine whether

they comply with applicable codes, standards, NRC Regulatory Guides and

licensee commitments.

-CD-T-02, Rev. 18 Concrete Quality Control

-CD-T-06, Rev. 10 Rebar and Cadweld Quality Cont ,1

-CD-T-07, Rev. 8 Embed Installation and Inspection

b. Installation Activities

The inspector witnessed portions of the concrete placement indicated

below to verify the following:

(1) Forms, Embedment, and Reinforcing Steel Installation

- Forms were properly placed, secure, leak tight and clean.

- Rebar and other embedment installation was installed in

accordance with construction specifications and drawings,

secured, free of concrete and excessive rust, specified

distance from forms, proper on-site rebar bending (where

applicable) and clearances consistent with aggregate size.

(2) Delivery, Placement and Curing

- Preplacement inspection was completed and approved prior

to placement utilizing a Pour Card (Procedure Exhibit

CD-T-02*18).

- Construction joints were prepared as specified.

- Proper mix was specified and delivered.

l

'

- Temperature control of the mix, mating surfaces, and

ambient were monitored.

- Consolidation was performed correctly.

- Testing at placement location was properly performed in

accordance with the acceptance criteria and recorded on a

Concrete Placement Pour Log (Procedure Exhibit CD-T-02*20).

- Adequate crew, equipment and techniques were utilized.

- Inspections during placements were conducted effectively

by a suf ficient number of qualified personnel.

- Curing methcds and temperature was monitored.

(3) Rebar Splicing

.. - - -- - . - , .- -.

-

'

i

!

s

24

The inspector witnessed . cadwelding operations to veri fy the

following:

i-

- Inspections are performed during and after splicing by

qualified QC inspection personnel.

- Each splice was defined by a unique number consisting

of the bar size, splice. type, the position, the

operator's-symbol, and a sequential number.

- Process and crews are qualified.

- The sequential _ number and the operator's symbol are

-

marked on all completed cadwelds.

The inspector also conducted random inspections of completed

cadwelds to verify the following:

. - Tap hole does not contain slag, blow out, or porous metal.

-Filler metal was visible at both ends of the splice sleeve

and at the tap hole in the center of the sleeve. No voids

'-

were detected at the ends of the sleeves.

- The sequential number and the operator's symbol are marked

on all completed cadwelds.

No violations or deviations were identified.

t

9. _ Containment (Prestressing) - Unit 2 (47063C)

a. Procedure and Document Review

The inspector reviewed and examined portions of the following

specification, procedure, and drawings pertaining to the installation

of horizontal tendons, to determine whether they comply with applicable

codes, standards, NRC Regulatory Guides and licensee commitments. ,

!~ - X2AF04 Technical Provisions for Containment

- Post-Tensioning System

! - AX2AF04-100-13 Field Instruction Manual for Installation

of VSL ES-55 Post-Tensioning System Within

Nuclear Containment Structures, Rev. 9

t

i b. Installation Activities i

i  !

The inspector witnessed portions of the installation activities

indicated below to verify the following: ,

- The latest issue (revision) of applicable drawings or procedures

l are available to the installers and were being used. '

i - Tendons were free of nicks, kinks, corrosion; were installed .

L in designated locations; and that the installation sequence

and technique was per specified requirements. l

i

- Installation crew was properly trained and qualified. .

l

l

,- v -_-

.__ -

.

25

- OC inspection was properly performed by qualified personnel

in accordance with applicable requirements.

- Adequate protective measures were being taken to ensure

mechanical and corrosion protection during storage, handling,

installation, and post installation.

- Tendons were stressed in the proper sequence.

- All strands in the tendon were moving together during the

stressing and the tendon is being stressed from both ends

simultaneously.

- Elongation measurements were being taken properly and being

compared to the calculated elongation.

- Anchor head lift-off force was being taken and documented

properly.

- The stressing operation was being monitored to identify

any strand slippage.

The following tendons were observed during the inspection period:

Horizontal Buttress

Tendon No's. Activity

5 IS-2W Tendon Installation

6 2E-3E Tendon Installation

11 IS-2W Tendon Installation

No violations or deviations were identified.

10. Containment (Steel Structures and Supports) - Units 2 (48053C)

Periodic inspections were conducted to observe containment steel and support

installation activities in progress, to verify the following:

- Components were being properly handled (included bending or

straightening).

- Specified clearances were being maintained.

- Edge finishes and hole sizes were within tolerances.

- Control, marking, protection and segregation were maintained

during storage.

- Fit-up/ alignment meets the tolerances in the specifications and

drawings.

No violations or deviations were identified.

11. Safety-Related Structures (Structural Steel and Supports) - Units 1 & 2

(48063C)

Periodic inspections were conducted to observe construction activities of

safety-related structures / equipment supports for major equipment outside the

containment to verify that:

-

_

26

- Materials and components were being properly handled to prevent damage.

- Fit-up/ alignment were within tolerances in specifications and drawing.

requirements.

- Bolting was in accordance with specifications and procedures.

- Specified clearances from adjacent components were being met.

No violations or deviations were identified.

12. Reactor Coolant Pressure Boundary and Safety Related Piping - Unit 1 & 2

(49053C) (49063C)

Periodic inspections were conducted to observe construction activities of

the Reactor Coolant Boundary and other safety-related piping installations

inside and outside Containments. Verifications included but were not

limited to the following:

- Material and components were being properly handled and stored

in order to prevent damage.

- Fit-ups and alignments were within tolerances per specifications

. and drawings.

- Specified clearanc(s from pipe to pipe and adjacent components

were met.

- Piping was installed and inspected in accordance with applicable

drawings, specifications, and procedures.

- Those people engaged in the activity are qualified to perform the

applicable function.

- Drawing and specification changes (revisions) are being handled

and used correctly.

No violations or deviations were identified.

13. Reactor Coolant Pressure Boundary and Safety Related Piping Welding - Unit 1

& 2 (55073C) (55083C)

periodic inspections were conducted during daily plant surveillances on

safety-related pipe welding at various stages of weld completion. The

purpose of the inspection was to determine whether the requirements of

applicable specifications, codes, standards, work performance procedures and

QC procedures are being met as follows:

- Work was conducted in accordance with a process sheet which identifies

the weld and its location by system, references procedures or

instructions, and provides for production and QC sign-offs.

- Welding procedures, detailed drawings and instructions, were readily

I available in the immediate work area and technically adequate.for the

,

welds being made.

l - Welding procedure specification (WPS) were in accordance with

!

the applicable Code requirements and that a Procedure Qualification

-

Record (PQR) is referenced and exists for the type of weld being made.

- Base metals, welding filler materials, fluxes, gases, and insert

L

__ 3.

-_

27

materials were of the specified type and grade, have been properly

inspected, tested and were traceable to test reports or certifications.

- Purge and/or shielding gas- flow and composition were as specified in the

welding procedure specification and that protection was provided to

shield the welding operation from adverse environmental conditions.

- Weld joint geometry including pipe wall thickness was specified and that

surfaces to be welded have been prepared, cleaned and inspected in

accordance with applicable procedures or instructions.

- A sufficient number of adequately qualified QA and QC inspection

personnel were present at the work site, commensurate with the work in

progress.

- The weld area cleanliness was maintained and that pipe alignment and

fit up tolerances were within specified limits.

- Weld filler material being used was in accordance with welding

specifications, unused filler material was separated from other types of

material and was stored properly and that weld rod stubs were properly

removed from the work location.

- That there were no evident signs of cracks, excessive heat input,

sugaring, or excessive crown on welds.

- Welders were qualified to the applicable process and thickness, and that

necessary controls and records were in place.

No violations or deviations were identified.

14. Reactor Vessel, Integrated Head Package, and Internals - Unit 1 & 2 (50053C

and 50063C)

Periodic Unit 1 inspections consisted of examinations of the Reactor Vessel,

the integrated head package and the upper and lower internals in their

designated storage area. The Reactor Vessel was disassembled and internals

removed for inspection at the completion of Hot Functional Testing.

The Unit 2 inspections consisted of examinations of the Reactor Vessel with

the lower internals installed and the integrated head package and the

upper internals which are stored in their designated laydown area,

inspections determined that proper storage protection practices were in

i

place and that entry of foreign objects and debris was prevented.

No violations or deviations were identified.

15. Safety Related Components - Units 1 & 2 (50073C)

The inspection consisted of plant tours to observe storage, handling, and

protection; installation; and preventive maintenance af ter installation of

safety-related components to determine that work is being performed in

accordance with applicable codes, NRC Regulatory Guides, and licensee

commitments. '

l

During the inspection the below listed areas were inspected at various times

l during the inspection period to verify the fallowing as applicable:

-. ~

28

- Storage, environment, and protection of components were in accordance

-with manufacturer's instructions and/or established procedures.

-

Implementation of special storage and maintenance requirements _such as:

rotation of motors, pumps, lubrication, insulation testing (electrical),

cleanliness, etc.

- Performance of licensee / contractor surveillance activities and

documentation thereof was being accomplished.

- Installation requirements were met such as: proper location, placement,

orientation, alignment, mounting (torquing of bolts and expansion

anchors), flow direction, tolerances, and expansion clearance.

- Appropriate stamps, tags, markings, etc. were in use to prevent

oversight of required inspections, completion of tests, acceptance, and

the prevention of inadvertent operation.

Safety-Related piping, valves, pumps, heat exchangers, and instrumentation

were inspected in the following Unit 1 and 2 areas on a random sampling

basis throughout the inspection period:

- Residual Heat Removal Pump Rooms

- Diesel Generator Building

- Auxiliary Feedwater Pumphouse

- Containment Spray Pump Rooms

- Pressurizer Rooms

- Main Coolant Pump Areas

- Steam Generator Areas

- Safety Injection Pump Rooms

- RHR and CS Containment Penetration Encapsulation Vessel Rooms

~ Component Cooling Water (CCW) Heat Exchangers, Surge Tanks & Pump Rooms

- Cable Spreading Rooms

- Accumulator Tank Areas

- Chemical and Volume Control System (CVCS) Letdown Heat Exchanger

Pump Room

- Battery & Charger Rooms

4

- Nuclear Grade Piping, Valves & Fittings Storage Areas

- Spent Fuel Pool Heat Exchanger Rooms

- Pressurizer Relief Tank Area

- CVCS Centrifugal Charging Pumps & Positive Displacement Pump Rooms

- Bottom Mounted Instrumentation (BMI) Tunnel and Seal Table Area

- BMI and Supports Under Reactor Vessel

- NSCW Tower Pump Rooms and Pipe Tunnels

- Containment, Auxiliary Building, Control Building, and Fuel Handling

Building auxiliary (secondary) areas

No violations or deviations were identified.

16. Safety Related Pipe Support and Restraint Systems - Units 1 & 2 (50090C) ,

1

Periodic random inspections were conducted during the inspection period to l

observe construction activities during installation of safety-related pipe

supports to determine that the following work was performed in accordance

with applicable codes, NRC Regulatory Guides, and licensee commitments:

i

L

n

29

- Spring hangers were provided with indicators to show the approximate

" hot" or " cold" position, as appropriate.

- No deformation or forced bending was evident.

- Where pipe clamps are used to support vertical lines, shear lugs were

welded to the pipe (if required by Installation Drawings) to prevent

slippage.

- Sliding or rolling supports were provided with material and/or

lubricants suitable for the environment and compatible with sliding

contact surfaces.

- Supports are located and installed as specified.

- The surface of welds meet applicable code requirements and are free

from unacceptable grooves, abrupt ridges, valleys, undercuts, cracks,

discontinuities, or other indications which can be observed on the

welded surface.

No violations or deviations were identified.

17. Electrical end Instrumentation Components and Systems - Units 1 & 2 (51053C)

(52153C)

Periodic inspections were conducted during the inspection period to observe

safety-related electrical equipment in order to verify that the storage,

installation, and preventive maintenance was accomplished in accordance with

applicable codes, NRC Regulatory Guides, and licensee commitments.

During the inspection period inspections were performed on various pieces of

electrical equipment during storage, installation, and cable e ,inating

phase in order to verify the following as applicable:

- Location and alignment

- Type and size of anchor bolts

- Identification

- Segregation and identification of nonconforming

items

- Location, separation and redundancy requirements

- Equipment space heating

- Cable identification

- Proper lugs used

- Condition of wire (not nicked, etc.), ticStness of

connection

- Bending radius not exceeded

- Cable entry to terminal point

- Separation

No violations or deviations were identified.

w.,--

_ _ _ _

=

i

30

18. Electrical and Instrumentation Cables and Terminations - Unit 1 & 2 (51063C)

(52063C)

a. Raceway / Cable Installation

,

The inspector reviewed and examined portions of the following

f procedures pertaining to raceway / cable installation to determine

' whether they comply with applicable codes, NRC Regulatory Guides and

licensee commitments.

- ED-T-02, Rev. 10 Raceway Installation

- EO-T-07, Rev. 11 Cable Installation

Periodic inspections were conducted to observe construction activities

'

of Safety Related Raceway / Cable Installation.

In reference to the raceway installation, the following areas were

inspected to verify compliance with the applicable requirements:

- Identification '

- Alignment -

- Bushings (Conduit)

- Grounding

- Supports and Anchorages

In reference to the cable installation the following areas were

inspected to verify compliance with the applicable requirements: l

- Protection from adjacent construction activities (welding, etc.)

- Colled cable ends properly secured

- Non-terminated cable ends taped

- Cable trays, junction boxes, etc., reasonably free of debris

!

l

- Conduit capped, if no cable installed

- Cable supported

- Bend radius not exceeded

- Separation

f b. Cable Terminations

l

'

The inspector reviewed and examined portions of the following

procedures pertaining to cable termination to determine whether they

comply with applicable codes, NRC Regulatory Guides and licensee

commitments.

-

ED-T-08, Rev. 9 Cable Termination

In reference to cable terminations the following areas were inspected

to verify compliance with the applicable requirements.

- Cable identification

- Proper lugs used

- Condition of wire (not nicked, etc.)

'

- Tightness of connection

,

_ _ _ _ _ _ _ _ _ :--------

__

31

- Bending radius not exceeded

- Cable entry to terminal point

- Separation

No violations or deviations were identified.

19. Containment and Safety Related Structural Steel Welding - Units 1&2

(55053C) (55063C)

Periodic inspections were conducted during daily plant surveillances on

safety-related steel welding at various stages of weld completion.

The purpose of the inspection was to determine whether the requirements of

applicable specifications, codes, standards, work performance procedures and

QC procedures are being met as follows:

- Work was conducted in accordance with a process sheet or

drawing which identifies the weld and its location by system,

references, procedures or instructions, and provides for

production and/or QC signoffs.

- Welding procedures, detailed drawings and instructions, were

readily available in the immediate work area and technically

adequate for the welds being made.

- Welding procedure specification (WPS) were in accordance with

the applicable Code requirements and that a Procedure

Qualification Record (PQR) is referenced and exists for the

type of weld being made.

- Base metals and welding filler materials were of the specified

type and grade, were properly inspected, tested, and were

traceable.

- Protection was provided to shield the welding operation from

adverse environmental conditions.

- Weld joint geometry including thickness was specified and that

surfaces to be welded were prepared, cleaned and inspected in

accordance with applicable procedures or instructions.

- A sufficient number of adequately qualified QA and QC

inspection personnel commensurate with the work in progress

were present at the work site.

- Weld area cleanliness was maintained and that alignment and

fit-up tolerances were within specified limits.

- Weld filler material being used was in accordance with welding

specifications, unused filler material was separated from other

types of material and was stored and controlled properly, and

stubs were properly removed from the work location.

- There were no visual signs of cracks, excessive heat

input, or excessive crown on welds.

- Welders were qualified to the particular process and thickness;

, and that necessary controls a,1d records were in place.

No violations or deviations were identified.

1

.

r-

32

20. Preoperational Test Program Implementation / Verification - Unit 1 (70302)

(71302)

The inspector reviewed the present implementation of the preoperational test

program. Test program attributes inspected included review of

administrative requirements, doct. ment control, documentation of major test

events and deviations to procedures, operating practices, instrumentation

calibrations, and correction of problems revealed by testing.

Periodic inspections were conducted of Control Room Operations to assess

plant condition and conduct of shif t personnel. The inspector observed that

Control Room operations were being conducted in an orderly and professional

manner. Shift personnel were knowledgeable of plant conditions, i.e.,

ongoing testing, systems / equipment in or out of service, and

alarm / annunciator status. In addition, the inspector observed shift

turnovers on various occasions to verify the continuity of plant testing,

operational problems and other pertinent plant information during the

turnovers. Control Room logs were reviewed and various entries were

discussed with operations personnel.

Periodic facility tours were made to assess equipment and plant conditions,

maintenance and preoperational activities in progress. Schedules for

program completion and progress reports were routinely monitored.

Olscussions were held with responsible personnel, as they were available, to

determine their knowledge of the preoperational program. The Inspector

reviewed numerous operation deviation reports to determine if requirements

were met in the areas of documentation, action to resolve, justification,

corrective action and approvals. Specific inspections conducted are listed

below:

a. Preoperational Tests

(1) Test Procedure Review (70300)

The inspector reviewed the following listed preoperational test

procedures. Each test was reviewed for administrative format and

technical adequacy. The procedures were compared with licensee

commitments from the applicable FSAR Chapters, Regulatory Guide

1.68 and the Safety Evaluation Report (NUREG-1137). This included

veri fying that pertinent prerequisites were identified, initial

test conditions and system status were specified, acceptance

criteria were specified and management approval indicated:

NRC l

Procedure li1 Q . Test Title l

N o, No;

l-300-05 63050 Containment Struct4ral

Inteority Test

1-300-12 70307 Containment Integrated Leak

Rate Test

1-3KE-06 70453 Fuel Handling Machine

l

l

P

33

(2) Test Witnessing (70312)

The inspector witnessed selected portions of the following

preoperational test procedures as they were conducted. The

inspection included attendance at briefings held by the test

supervisor to observe the coordination and general knowledge of

the procedure with the test participants. Overall crew

performance was evaluated during testing. A preliminary review of

the test results was compared to the inspector's own observations.

Problems encountered during performance of the test were verified

to be adequately documented, evaluated and dispositioned.

Procedure NRC Insp. Test Title Activity Observed

No. No.

1-3AL-03 70438 AFW System Testing TO AFW Pump 48

During HFT Hour Run

1-300-10 70452 Shutdown Panel RCS Cooldown

Preoperational Fror.) 350 F to

Test 250 F Per

Abnormal

Operating

Procedure

18038-1

1-300-05 f.3050 Containment Installed

Structural Location of

Integrity Test Extensometers

and Walkdown

of Valve

Lineups

1-300-12 70313 Containment Installed

l Integrated Location of

Leak Rate Test RTD's and Data

Acquisition and

Processing Center

1-3KJ-05 70441 DG Train "A" Five (5)

l Synchronization, consecutive

l Load Rejection, Starts on Air

5 Air Starts and Receiver #2

35 Consecutive Per Section 6.3

, Starts

Train A DG

Operation With

i

.. .

34

Fuel Oil Day Tank

Makeup From Train B

Fuel Oil Storage

Tank Per Section

6.1.7

100% Load Rejection

Per Section 6.1.8

1-3EF-01 70439 Nuclear Service NSCW Pump P4-002 &

i

Cooling Water Discharge Valve

System 1 HV-11607

Preoperational Circuit Test

Test

1-3BK-01 70443 Containment Spray Suction Flow

Preopera tional Demonstration for

Test Simultaneous

Operation of SI,

Cent. Chg., RHR and

CS Pumps per Section

6.5

1-3KJ-05&O6 70441 DG Train "A"&"B" Train "A"&"B" 35

Synchronization Consecutive Air

Load Rejection, 5 Starts per Section

Air Starts and 35 6.4

Consecutive Starts

1-3BG-01 70433 Chemical Volume Train "B" CVCS Cold

and Control Shutdown Safety

System Grade

Preoperational Charging Flow

l Test Base Line

Measurement per

Section 6.9

1-3BG-03 70434 Safety Injection Accumulator

Accumulators High/ Low Pressure

Preoperational Annunciator

Test Check-out per

Section 6.4

i 1-358-01 70317 Reactor Protection RPS Overpower

! Preoperational Delta Reactor

Test Trip Logic per

Section 6.13.3

,

3 h

35

1-3PB-01 92706 Class 1E 4.16 KV DC Control Power

Train "B" Bus 1AA02 per

Switchgear Section 6.1

Preoperational

Test

Breaker 1AA0205

Operation per

Section 6.3

1-3BC-01 70436 Residual Heat Testing of

Removal System Lockout Feature

Preoperational on Valves

1 HV-8809A&B per

Sections 6.4.1.1

& 6.4.3.1

The inspector also witnessed the hanging of Clearance

No. 1-8G-4990 for de-energizing 480 volt switchgear 1 AB-15, 1

AB-04, & 1 AB-05. This clearance was hung to support maintenance

in performing their preventive maintenance program in cleaning

Train "B" 480 switchgear & volt motor cnntrol centers. The

inspector verified proper implementation of Administrative

Procedure No. 00304-C, Rev 7 entitled " Equipment Clearance &

Tagging" during the performance of hanging Clearance

No. 1-86-4990.

(3) Test Results Evaluation (70400)

The inspector reviewed the following listed preoperational test

results. This review was performed to ascertain if an adequate

evaluation of the test results has been performed; test data was

within the established acceptance criteria, or that deviations are

properly dispositioned; appropriate retesting was performed where

necessary; administrative practices were adhered to; and that

appropriate review, evaluation and acceptance of the test results

have been performed.

Procedure NRC Insp. Test Title

i

No. No.

1-3KE-02 70553 Spent Fuel Cask Bridge Crane Preop

(Partial)

1-3KE-06 70553 Fuel Handling Machine (Partial)

Sec. 6.8

b. Construction Acceptance Testing (CAT)

The inspector conducted an inspection of the licensee's method of

preoperational testing of instrument and control air systems in

,

accordance with Regulatory Guide 1.68.3 dated April, 1982. FSAR

l

Section 1.9.68.4 states that safety-related pneumatic valves will be

l

l

._- _ _ _ _

._ ..

36

tested for both a simulated sudden loss of air and a gradual loss of

air pressure to verify that each valve assumes its Fail-Safe position.

The licensee's response to NRC Question 640.03 states that the valves

listed in Table 9.3.1-2 will be tested. This table does not list all

safety-related pneumatic valves. During discussions with the licensee

it appears that the licensee is testing all safety-related pneumatic

valves. However, there appears to be a conflict between the two (2)

statements made in the FSAR since Table 9.3.1-2 is not a complete

listing of all safety-related valves. This matter was identified to

the licensee and NRR. Further discussions with the licensee revealed

that the commitment is only to test those safety-related valves listed

in Table 9.3.1-2 since both the FSAR Section 1.9.68.4 and the response

to NRC Question 640.03 were amended at the same time (i.e. in Amendment

No. 15) even though all safety-related pneumatic valves are being

tested.

The inspector conducted a review of the licensee Construction

Acceptance Test (CAT) Procedure No. CAT-M-04 entitled Air Operated

Valves which implemented Section C-8 of the Regulatory Guide. The

inspector selected two system startup designator no's. from which to

review completed CAT M-04's to verify loss of instrument air test for

both cases (i.e., sudden & gradual) to pneumatic safety-related valves.

The inspector conducted a review of the following completed CAT's:

Residual Heat Renewal System (BC-01)

Failed

CAT No. Valve No. Position Comments

85-2922 1-HV-0607 F0 Not Tested for Sudden

Loss of Instrument Air

85-2923 1-HV-0606 F0 Not Tested for Sudden

Loss of Instrument Air

85-3093 1-HV-0618 FC Not Tested for Sudden

loss of Instrument Air

85-3094 1-HV-0619 FC Not Tested for Sudden

loss of Instrument Air

Chemical Volume & Control System (BG-03)

Failed

CAT No. Valve No. Positten Comments

85-4757 1-HV-8149A FC

85-4757 1-HV-82498 FC

85-4757 1-HV-8149C FC

85-4758 1-HV-8152 FC

-

_ _ _ - - _

,

!

37

85-4759 1-HV-8160 FC

85-4790 1-HV-15214 FC

85-4756 1-HV-8143 F0

86-491 1-HV-8153 FC

85-4755 1-PV-0131 F0 Not Tested for

Sudden loss of

Instrument Air

85-4789 1-HV-0123 FC Not Tested for

Sudden loss of

Instrument Air

85-4982 1-TV-0129 F0

85-4798 1-HV-0128 FC

86-1383 1-TV-03818 FO

86-1382 1-TV-0831A FC

85-4753 1-HV-8154 FC

86-1424 1-HV-7041 FO

86-1422 1-HV-7022 FC

86-1420 1-HV-7054 FC

86-1426 1-HV-7040 FO

86-1384 1-HV-387 FO

-

86-1381 1-HV-7046 FC

Six (6) CAT packages identified above had N/A for Step 6.4.1 which was

the applicable step for testing for a sudden loss of instrument air.

The step stated to de-energize the solenoid and verify that the valve

moved to its correct Fail position. Discussions with the licensee

revealed that the step was N/A since the valves in question did not

have a solenoid valve (i.e. , they had a Bailey Controller). Also the

licensee had decided that by closing the instrument air supply valve

thus simulating a loss of air the valve would move to its Fall-Safe

position in the same manner as for a gradual loss of air since the air

would bleed slowly out of the air supply tubing via the regulator and

the controller. Therefore, this step was determined not to be

applicable for pneumatic valves with Bailey Controllers.

The inspector informed the licensee that the Regulatory Guide stated to

shut of f the instrument and control air system in a manner that would l

simulate a sudden air pipe break. 1rocefore, by closing the instrument i

air supply valve you would vt b e. einolating a sudden loss of I

instrument air via a pipe break since shere is not a vent path. Thus

the valve would move to its Fail-Safe position slowly as the air is

bled out of the air supply line via the Regulator and the Cor. troller. l

However, by attaching a test fixture which would allow the air to be  !

vented out of the supply line you would be simulating a sudden loss of

air via a pipe break and the valve will move to 1t Fall -Safe position

quickly.

In a subsequent meeting with the licensee the inspector was informed l

that all safety-related pneumatic valves not tested for a sudden loss ,

of instrument air were being identified and would be tested. l

_

38

Based on this review it appears that safety-related pneumatic valves

with Bailey Controllers were not tested for a sudden loss of instrument

air via a pipe break in accordance with Section C.8 of Regulatory Guide

1.68.3.

~

The foregoing is considered to be in violation of 10 CDR 50, Appendix

B, Criterion V and will be identified as Violation 50-424/86-74-02

" Inadequate Procedure for Testing Air Operated Valves With Bailey

Controllers".

21. Three Mile Island Task Action Plan Followup - Unit 1 (4254018) Operational

Staffing - Unit 1 (363018)

This inspection consists of verification that the licensee has implemented

the requirements of NUREG 0737, " Clarification of TMI Action Plan

Requirements" as committed to in the facility FSAR or other appropriate

documents. Verification consisted of one or more of the following

attributes, as appropriate, to determine acceptability for each listed

action item:

- Program or procedure established

- Personnel training or qualification

- Completion of item

- Installation of equipment

- Orawings reflect the as-built configuration

- Component tested and in service or integrated into the preoperational

test program

The following documents were utilized in performing the review, as

appropriate:

NUREG 0578 TMI-2 Lessons Learned Task Force Status Report

NUREG 0660 NRC Action Plan Developed as a Result of the

TMI-2 Accident

NUREG 0694 THI-Related Requirements for New Operating Licenses

NUREG 0737 and Clarification of TMI Action Plan Requirements

Supplement 1

FSAR thru Final Safety Analysis Report

Amendment 24

NbREG 1137 and Safety Evaluation Report

Supplements

On September 9 - 12, the inspector participated in an NRR lead review of the

propored organization for operation of Vogtle from the level of the senior

corporate of ficer down thru the plant operating staf f. This review was

conducted in Atlanta at the corporate office and onsite. In fo rma tion

contained within Chapter 13 of the FSAR was utilized in this review. From

this review the team learned that a major reorganization was in progress.

fhe team's review also included this new organt:ation in the review, but

noted that FSAR changes must be submitted and formal review performed. The

team also included an oversight review of the following TMI Action items:

'

39

a. I.A.1.1 - Shift Technical Advisors

b. I.A.I.2 - Shift Supervisor Administrative Duties

c. I.A.1.3 - Shift Manning

d. I.B.1.2 - Independent Safety Engineering Group

e. I.C.2 - Shift Relief and Turnover Procedures

f. I.C.3 - Shift Supervisor Responsibilities

g. I.C.4 - Control Room Access

! h. I.C.5 - Procedure for Feedback of Operating Experience to the

Plant Staff

1. I.C.6 - Procedure for Verification of Correct Performance of

Operating Activities

The results of the team review will be formally documented in a meeting

summary and Safety Evaluation Repurt,

22. Followup of Reportable Items - Units 1 & 2 (92700)

, This inspection was conducted to determine whether the reports have been

i

received by the licensee, evaluated and corrective action taken, where

i appropriate. The inspector utilized discussions with cognizant personnel

l and review of applicable documentation, and field verification as a basis

for closure of each item,

a. 50-424/50-425 P2179-01 (Closed) " Jacket Water Pump Assembly Drives".

This item was reported by TDI in a letter dated September 20, 1979.

This item is not applicable to the plant's type of diesel,

b. 50-424/50-425 P2131-01 (Closed) " Governor Lube Oil Cooler Location".

This item was reported by TDI in a letter dated December 9,1981. The

, deficiency concerns a possibility for engine non-availability if the

! coolers are installed above the governor lube oil level. Site

l

'

inspection confirmed that the lube oil coolers are properly installed.

The inspector verified the field installation,

c. 50-424/50-425 P2182-02 (Closed) " Start Air Sensing Line". This item

was reported in a letter dated March 19, 1982. The deficiency concerns

the possible failure of a non-seismic sensing line with a resultant

bleeding down of the air start receiver tanks. The suggested

correction was the installation of an 1/8" orifice upstream of a

qualified valve which would lengthen the time required for bleed down.

The Bechtel evaluation dated April 14, 1982 dismissed this as i

'

reportable becausa the plant design utilized a dif ferent design. The

inspector examin a the latest P&ID drawing and determined that the

plant design has been changed since the evaluation and now includes

this design. A review of the design change indicated that the new

design was engineered to include the TDI recommendation. Field

verification by the inspector was not possible due to the design

including the orifice internal to the assembly. The Unit I weld

l

l

l

4

F

40

process sheets were obtained which document orifice installation.

Unit 2 P&ID's and isometric currently depict the new design and normal

construction practices will ensure installation.

d. 50-424/50-425 P2183-01 (Closed) " Engine Mounted Fuel Oil Line". This

item was reported by TOI in a letter dated September 21, 1983. The

deficiency concerns the failure of the line due to excessive . line

vibration. While the deficiency is attributed to vibration problems at

the site where the problem first occurred. Several actions were

required to mitigate the potential for re-occurrence. The Test

Supervisor was interviewed to determine how these recommendations were

implemented and field verification performed. The applicant has

replaced the swageloc fitting with a thread tee, added an additional

support, and installed a spray shield.

e. 50-424/50-425 P2184-01 (Closed) " Fuel Control Levers on Diesel

Generator Engines Are Not Pinned". On November 29, 1984 the applicant

submitted the results of the site review to the NRC. This review

determined that the Vogtle diesels were properly pinned and cap screws

properly torqued. The inspector reviewed the original vendor report

dated October 2, 1984 and various other site documents. An inspection

of the fuel control levers was performed by the inspector to verify the

hardware installation is as stated.

f. 50-424/50-425 P2184-C2 (Closed) " Bonney Force lacks the Chemical

Overcheck Documentation". This item as reported by Pullman Power

Products letter dated March 22, 1984 concerns nine fittings where

the vendor had not performed a chemical check analysis. The inspector

reviewed a November 8, 1984 Pullman Power Products letter which

enclosed a certified material test report for each spool and determined

that the chemical analyses indicated that all were within the required

specification ranges.

g. 50-424/50-425 P2184-03 (Closed) " Deficient Gimpel Valve for Auxiliary

l Feedwater Pump Drive Turbine". This item as reported by Terry

Corporattun letter, dated February 3,1984 concerned a situation where

the ,pring load in the closing direction was not sufficient to overcome

the valve stem unbalance when the pressure below the valve seat exceeds

approximately 700 psig with the turbine near a no load condition. The

inspector reviewed FECO No. M-3-B and determined that the new springs

have been installed for the Unit 1 turbine auxiliary feed pump.

h, 40-424/50-425 P2184-04 (Closed) "High Pressure Injection Pump". This

item was reported by TOI in a letter dated July 13, 1984. This

!

I

deficiency concerned the failure of a bracket which supports the pump.

The bracket failure was attributed to a material defect and was

dispositioned as a one-time failure. No corrective action was

necessary.

i

1

- ~.

41

i

f

1. 50-424/50-425 P2185-02 (Closed) "Possible Field Failure of Space

Heaters Supplied on GE Motors". This item as reported by Bingham-

Willamette Company letter, dated January 24, 1985 concerns the failure

of Wellman C 1pany manufactured space heaters which utilized epoxy

instead of ceramic end plugs. The- inspector reviewed the results of

the applicant's inspection and determined that none of the heaters of

this type exist onsite.

J. 50-424/50-425 P2185-06 (Closed) " Air Filter-Engine Control Panel".

This item was reported by TDI in a letter dated January 22, 1985.

This deficiency concerns the potential of having a polycarbonate

'

-

transparent bowl (rated 150 psig at 125 F) where a metal bowl (rated

250 psig'at 175 F) should be installed to meet the service requirements

of 200 to 250 psig at room temperature.

k. 50-424/50-425 CDR 82-22 (Closed) " Leaks in Containment Cooling Coil

Units". The applicant determined this item to be not reportable in a

June 9, 1982 letter. The Southern Company Services, Inc. evaluation

dated June 18, 1982 was reviewed. This deficiency involves coil

leakage discovered when the coils were subjected to test pressure in

excess of the original immersion testing. The evaluation concluded

that the leakage was small, self sealing and would not degrade unit

operation. The inspector concurs with this evaluation. In addition,

the applicant oneumatically reinspected sixty-two colling coils and had

repairs made on the eight coils with leakage. These repairs were

performed by the vendor. Two N1 data forms were reviewed and the

inspector determined the repairs were performed as required by the

applicant.

1. 50-424/50-425 CDR 82-28 (Closed) "Bechtel Calculation". The applicant

determined this item to be not reportable in an October 29, 1982

, letter. Bechtel Power Corporation evaluation dated October 4, 1982 was

reviewed. This deficiency involved the lack of timely updating of

Bechtel calculations as identified by an INPO audit. The inspector

h

reviewed copies of the af fected calculations and determined that the

corrections have been completed.

m. 50-424/50-425 COR 85-90 (0 pen) " Anchor Darling Main Feedwater Isolation

Valves". This inspection was performed to verify field installation of

the replacement check valves. All four feedwater isolation valves were

examined and the inspector noted that all eight check valves had been

replaced with new 8F-C8L-10-SS type check valves. The inspector was

informed that a slow depressurization test was not performed as part of

a formal preoperational test, however a plant surveillance was

performed. In discussion with the test supervisor concerning the

surveillance the inspector determined that the procedure isolates air

to the system but does not simulate a slow bleed of the air. The

licensee has committed to revise and perform the procedure to

l

t

!

- - .___ _

r

!

- 42 l

i

!

demonstrate check valve operability. Work on Unit 2 valves has i

not been performed. Final closure of this CDR will be contained 4

in NRC report 50-424/86-76 and 50-425/86-37. The' following IFI is I

identified 50-424/86-74-03 and 86-35-01 " Review Results of Testing {

the Check Valves on the Feedwater Isolation Valves" to verify new  !

model 8F-C8L-10-SS. l

.

!

23. Comparison of As-Built' Plant to FSAR Description - Unit 1(37301)  :

l-

During the inspection period, pipe run walkdowns were performed where piping i

installation is near completion to determine whether the piping run is

installed as shown on current, approved drawings and in. accordance with  !

applicable construction specifications. The following systems were walked  !

down to verify that the installed system is in agreement with the applicable -

drawings, FSAR description, and proposed technical specificaticns.

FSAR Pipe Run

Section DWG. No./ Revision Title Inspected

10.4.7 IX4DB168-1/9 Condensate & Condensate

-

Feedwater Feedwater

System Supply To SG's

2&3

1X4DB168-2/8

IX4DB168-3/17  !

No violations or deviations were identified.  !

24. Fuel Receipt and Storage - Unit 1 (60501B)

Inspections were conducted to ascertain whether new fuel was being properly

accepted, stored and safeguarded in accordance with NRC license SNM-1967.

During these inspections the inspector randomly selected various

requirements and verified implementation. Selected portions of security and

fuel receipt procedures were witnessed as they were performed. Overall crew -

knowledge and performance was evaluated during these inspections.

Documentation of the fuel receipts and problems encountered were verified to

be adequately documented, evaluated and dispositioned on a selected basis.

During this inspection the inspector attended licensee meetings held in i

preparation for fuel receipt, reviewed the area turnover packages and  !

inspected the actual area to independently assess the status of licensee

readiness. The inspector discussed reportability requirements with the

Special Nuclear Material Custodian and his designees. The inspector

determined that while they were aware of the reportability requirements that

Procedure 0152-C was being revised to clarify these requirements. The

inspector informed the licensee that the address and phone numbers to the

NRC need to be corrected. Corrections to procedure 0152-C were approved on

September 30, 1986.

I

i

-m' _-- _ - . _ _ _ .

- a.--_-

43

The following requirements, guidance and licensee commitments were utilized

as appropriate.

- 10 CFR 70 Domestic Licensing of Special Nuclear

Material

- SNM-1967 Special Nuclear Materials License

Procedure and Document Review

The inspector reviewed and examined portions of the following procedures

pertaining to initial fuel receipt, inspection and storage operations, to

determine whether they comply with applicable codes, standards, vendor

specifications, NRC Regulatory Guides and licensee commitments,

procedure No./ Title

~~~ Revision

20014-C/0 Crane Operator Qualification

93000-C/0 Fuel Handling Control Procedure

93010-C/0

-

Unloading, Inspection, and Storage of

New Fuel

93020-C/0 Technical Inspection of New Fuel

93100-C/0 Refueling Tools and Equipment Preservice

Inspection / Checkout

93110-C/0 New Fuel Assembly Handling Fixture

Operating Instructions

93360-C/l Limitations and Precautions for

Handling New and Partially Spent Fuel

Assemblies

Fuel Receipt Inspection Activities

The inspector witnessed portions of fuel receipt / inspection activities

indicated below to verify the following for compliance with applicable

procedural technical requirements:

-

Receiving inspection included a review of the fuel manuf acturer

shipping and Quality Assurance records / documents as well as an

inspection for external damage, security seal integrity, shock

indicator integrity, and loose material or parts.

-

Health Physics (HP) conducted required surveys.

-

Fuel Assembly Accountability was maintained and controlled.

-

Fuel Assembly Fuel Pins, Spacer Grids, and Top and Bottom Nozzles

were inspected for cleanliness, scratches, uniformity,

straightness, flow holes clear, and weld visually acceptable,

gyess_ __

44

-

Assembly Insert was located in correct assembly and inspected for

correct orientation, alignment, irregularities, and acceptable

drag forces.

-

Fuel Assembly is stored in its correct location.

-

Crane Operators were qualiiied.

The following fuel assemblies were inspected:

Fuel Assembly No. Activity Inspected

SA03 & 5A60 Container No. 180-Preparation of a

Loaded Shipping Container for Fuel

Assembly Removal.

5A53 & SA57 Fuel Assembly Removal from Shipping

Container, Transfer, Inspection,

and Storage in New Fuel Racks.

5A59 & 5A61 Fuel Assembly Inspection / Storage in

New Fuel Racks.

The inspector reviewed and witnessed the training for the spent fuel cask

crane operators conducted by the Operations Department. Operators had to

demonstrate their knowledge and proficiency by completing a checklist for

the following areas: Classroom technical lectures, equipment operational

qualification, equipment operational proficiency, and equipment /qualifi-

cation proficiency. The training consisted of " knowledge of how the crane

operates, a walkdown of crane components, and a demonstration of the ability

to properly remove a dummy fuel assembly from a shipping container and load

it into the new fuel storage area with the spent fuel cask bridge crane.

The inspector noted that the operator training program being conducted by

the Operations Department was not a formal procedurally controlled training

and qualification program. In addition, GPC QA Audit No. OPil/16-86/77

issued on July 9, 1986 by GPC-QA after conducting an audit of the security

plan and procedures and fuel handling and special nuclear material control

identified a weakness in this area. As a result of this inspection a QA

Audit Checklist item Card was placed on QA- file for timely followup to

ensure that the existing informal program would be procedurally controlled

and implemented prior to actual fuel receipt.

The foregoing is considered to be in violation of 10 CFR Part 50,

Appendix B, Criterion XVI and will be identified as Violation

50-424/86-74-01 " Failure to Achieve Appropriate Corrective Action on the

Implementation of a Forma 11:ed/ Controlled Training & Qualification Crane

Operator Program for Operations Personnel Per QA Audit Report No.

OPll/16-86/17, Dated July 9, 1986."

_ _ _ .

45

A weakness was noted in the area of initial fuel receipt. The licensee had

not planned to have the spent fuel cask crane Preoperational Test complete

which includes a Test Review Board (TRB) review of test results prior to use

during initial fuel receipt until questioned by the Resident Inspectors. In

addition, once the preop had been accepted by the TRB the Resident

Inspectors in conducting their review identified that per the licensee's

special nuclear material itcense the new fuel assembly har.dling tool should

be preoperational tested prior to use during the initial fuel receipt. The

TRB had completed their review arid had noted that performing a

preoperational load test was n t necessary prior to use. Once this was

brought to the licensee's attention immediate corrective action was taken

and the new fuel assembly tool was preoperational tested prior to use.

Another weakness noted in preparation for initial fuel receipt was in the

area of security. Several discussions were held with the security manager

to ensure proper implementation of GPC's security plan. This was necessary

in order to ensure that the special post orders had identified all of the

areas of surveillance for which the guard would be responsible for

surveilling per the licensee's security plan.

.

l

l

_