ML20215B675
| ML20215B675 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/25/1986 |
| From: | Rice P GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-1201, NUDOCS 8612120278 | |
| Download: ML20215B675 (6) | |
Text
_-_______ _____ _ _ _________ _ ______ ___________ __ __ ___ ___
Gaorg'a Power Company h
Post O'fce Box 282 Wwnesboro Georg:a 30830
' Telephone 404 554-9%1, Ext NJ 404 724 8114. Ext ?M UG E 3 P4:n8 Georgia Power P. D. Rice gP t
F-sneew n!"c p n November 25, 1986 l
United States Nuclear Regulatory Commission i
Region II File: X7BG10 Suite 2900 Log:
GN-1201 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/86-62 Attention: Mr. Roger D. Walker The Georgia Power Company wishes to submit the following information
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concerning the violations identified in your inspection report 50-424/
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86-62.
Violation 50-424/86-62-03,
" Inadequate Construction Procedures for Installation and Inspection of Spring Supports and Clamps" - Severity Level IV Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.
Pullman Power Products (PPP) procedures IX-32 and IX-50 were inade-quate relative to the installation / inspection of spring hangers and snubber clamps and in the control of clamp bolting materials.
PPP has revised procedure IX-50 to more clearly define installation and inspection requirements for spring-type pipe supports and associated hardware.
In addition, Site Instruction #94 has been developed and implemented to provide further guidance in the setting of spring cans and the installation or removal of stop pins.
Spring can adjustments have been performed and stop pins have been removed for all Unit 1 safety-related supports in accordance with Site Instruction #94.
Docu-mentation recording this work is available for review at the site.
PPP procedure VIII-1 and Site Instruction #64 provide adequate direction for the marking of small support parts.
Procedure IX-50 con-tains a reference to procedure VIII-1.
Procedure IX-32 was revised on July 7,1986, to address marking of small support parts.
In addition, action has been taken to mark existing small support parts in accordance with revised procedure IX-32 and Site Instruction #64.
This activity is documented on process sheets which are available for review at the site.
8612120278 861125 PDR ADOCK 05000424 O
PDR i
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80 Page Two Revisions have also been made to PPP procedure IX-32 and the asso-ciated process sheet to address the inspection of snubber clamp installa-tions.
All snubber clamps installed previous to the procedure revision will be identified and evaluated for adequacy.
This action is expected to be completed by December 12, 1986.
Upon completion of the reinspection described above, all corrective actions relative to this violation will be completed.
Violation 50-424/86-62-04, " Discrepancies in Design Documentation" Severity Level IV The Notice of Violation cites three specific examples of design document discrepancies.
Georgia Power Company acknowledges the first example but takes exception to the second and third examples.
The first example involves the location of pipe support V1-1202-001-H004 outside the designed location in excess of the applicable tolerance of eight inches.
The original pipe stress analysis for this support (1K4-1202-001-01) modeled its location at 4'-0" northeast of the nearest piping elbow.
The as-built configuration has the support at 4'-10 1/16" from the elbow.
This discrepancy was overlooked during the 75% phase of the final design verification.
During the 100% phase of the verifica-tion, the 10 1/16" discrepancy between the stress calculation and as-built condition was addressed and the analysis was corrected in Revision 3 of calculation 1K4-1202-001-01, dated November 13, 1986.
The Vogtle Project has conducted numerous technical and QA evalua-tions of the V-SAMU final design verification program.
These include audits by Bechtel and Southern Company Services QA and the Independent Design Review conducted by Stone and Webster.
These evaluations have confirmed that the resul ting calculations are technically sound with only occasional, isolated oversights due to human error. These oversights have been demonstrated to have no significant impact to the design ade-quacy.
To preclude recurrence, V-SAMU has conducted training of analysis personnel to reinforce the importance of applying adequate attention to detail to avoid oversights.
The most recent training session is documented in correspondence GTSD-VFDV-4534, dated October 6, 1986.
The second example cited in the Notice of Violation involves a dimension used in pipe support calculation V1-1204-028-H026.
This dimen-sion was interpreted by the NRC inspector to extend from the bottom of a horizontal wide flange beam to the top of an embed plate and to be shown in the drawing and calculation as one inch.
The inspector measured the dimension in the field to be five inches.
Georgia Power Company's evaluation of this example has determined that the one inch dimension shown in the drawing and calculation is actually the distance between the top of the embed plate and the top of the weld between the tube steel and the embed plate.
The elevation of the horizontal wide
f Page Three flange beam is determined by the top-of-steel elevation on the drawing.
The correct nominal dimension between the bottom of the beam and the top of the embed plate is 5 13/16".
The installed dimension of 5" is within the tolerance allowed by the specification; therefore, the support installation and analysis is correct.
The third example cited in the violation involves blank signature spaces in calculation packages VI-1204-028-H004, H005, and H006.
V-SAMU calculation packages provide two blocks for approval signatures.
The applicable Westinghouse procedure (WCAP-9805, Section 6.2) requires only the approval signature of the reviewing engineer.
In the three calculation packages above, the approval signature in each case was that of a reviewing engineer and the second space was left blank.
Proper signoff of the calculations can be readily verified simply by determining whether the signature is that of a responsible engineer.
Section A12.7 of the Vogtle Project Reference Manual states that the quality assurance program for Westinghouse V-SAMU activities is defined in the Westinghouse Water Reactor Division Quality Assurance Plan (WCAP 8370/7800).
Table 17-1 of WCAP 8370/7800 provides positions on applicable Regulatory Guides and industry standards.
For USNRC Regulatory Guide 1.88 (Revision 2),
which provides guidelines for the maintenance of quality assurance re-cords, the Westinghouse position states, "It should be recognized that in all cases it is not appropriate to completely fill out all records, particularly for those records completed on pre-printed forms."
There-fore, leaving the second signature space blank on the calculation packages is consistent with Westinghouse quality assurance plan requirements and is acceptable to the Vogtle Project.
A memorandum will be issued to appropriate V-SAMU personnel by December 5,
1986, to achieve consistency in documenting calculation approvals.
V-SAMU personnel will be directed to leave the second signa-ture block blank when the calculation is approved first by a responsible engineer.
Upon issuance of the memorandum described above, all corrective actions relative to this violation will be complete.
Violation 50-424/86-62-06, " Discrepancies Between Pipe Supports, Design Documentation and QC Documentation" - Severity Level IV This violation identified a number of specific discrepancies between design documents, as-built conditions, and inspection records.
Georgia Power Company has evaluated each of the discrepancies, resulting in the following conclusions:
Item 1 - Supports V1-1202-405-H036 and V1-1202-405-H033 were installed and inspected at a time when procedure IX-50 required location within 1/4" only for supports adjacent to items of concentrated mass such as a valve or flange.
The requirement to install all supports within 1/4" became effective on August 30, 1984.
The discrepancies relative to supports V1-1302-022-H002 and l
V1-1302-025-H001 are acknowledged.
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7 c.
Page Four Item 2 - The flare bevel weld length discrepancies for supports V1-1202-405-H036 and V1-1302-025-H002 are acknowledged.
Item 3 - As indicated in the USNRC inspection report, there was some difficulty in obtaining an accurate measurement of the plate on support V1-1202-001-H004.
Subsequently, the plate has been carefully measured and found to meet design requirements.
Item 4 - Supports V1-1204-007-H043 and V1-1202-001-H008 were found to have small clearances between the pipe and support and are acceptable per the requirements of procedure IX-50.
The clearance discrepancy is acknowledged for support V1-1217-176-H007.
Item 5 - Support V1-1203-034-H009 is adequate as installed.
Additional welds were omitted from DCN-1 of the drawing but are shown on the subsequent Revision 3.
Additional welds may be added to AISC members per procedure X-18.
Item 6 - The 2'-9" dimension from the wall connection to the pipe center-line is within the installation tolerance provided in DCN-R1 for support V1-1203-034-H010.
Item 7 - This discrepancy is addressed in the response to violation 86-62-04.
Support V1-1204-028-H026 is acceptable as installed.
Item 8 - Although different weld patterns may exist, the design weld callouts for each of the supports referenced in this item have been met.
The different patterns are resultant from the addition of welds not specified in the design, which is allowed for AISC welds in PPP procedure X-18.
The intention of typical weld symbols does sometimes require clarification but in most cases prove adequate.
In cases where clarification is required it is requested by the field and provided by design engineering.
Item 9 - In certain cases, the P&ID number identified on the isometric drawing may differ from that shown on the LDL.
The reason for this difference is that the isometric drawing normally references the P&ID which shows the line, while the LDL refer-ences the P&ID where the line originates.
It is not required nor intended to have the isometric drawing and the LDL identify the same P&ID numbers.
Revision 15 to P&ID 1X4DB121 changed the pipe class for lines 1204-128-3/4" and 1204-129-3/4" from "GG0" to "LL1" on August 22, 1985.
Subsequent revisions 16, 17, and 18 of the P&ID also correctly show the pipe class as "LL1,"
which agrees with the LDL.
P&ID 1X4DB121 does not indicate a line number for the 3/4" tap line to relief valve PSV8853A because the branch line carries the same identification as the main header.
The line size change from 1204-028-4" to 1204-028-3/4" is indicated on isometric IK3-1204-028-02.
c Page Five The identification of N0DE points on an isometric drawing is only intended to indicate the general area of a support.
The actual location of the supports is indicated on the support drawing.
For support V1-1204-201-H007 (N0DE 705) the actual location is correctly shown on support drawing V1-1204-H007.
" Installers Notes" are added to isometric drawings by PPP to serve only as a guide during installation as allowed in PPP procedure III-4.
The scope of these notes has been reduced to a minimum in recent practice.
The accuracy of technical information, such as design temperature and pressure, is checked against the supporting design document, such as the Line Designation List.
Item 10 - The discrepancies identified in this item were evaluated by PPP and documentation has been corrected where appropriate.
Strut checklists are used as an inspection guide.
Support V1-1205-007-H601 was identical to other supports being inspected at that time; therefore, only one checklist was used.
The confusion surrounding the documentation for support VI-1205-010-H015 is the result of several design changes.
Three ATCW's were issued on the support.
One was subsequently voided and another was revised as it was incorporated into a DCN.
The revision required the issuance of additional _ process sheets for further work to the support.
Final acceptance of the support, however, was based on the approved DCN's.
No hardware impacts resulted from the discrepancies identified in this item.
For the above examples, hardware discrepancies were identified on Deviation Reports to ensure proper resolution.
Through its evaluation of the acknowledged discrepancies, Georgia Power Company has concluded that the discrepancies are not indicative of deficiencies of a program-matic nature in the installation and inspection of pipe support systems, but are isolated cases of craftsman and/or inspector error.
Where appro-priate, craftsmen and/or inspection personnel have been given corrective instruction in project procedural requirements to prevent recurrence.
All corrective actions relative to this violation have been com-pleted.
l These responses contain no proprietary information and may be placed l
in the USNRC Public Document room.
l l
Yours truly, l
69 P. D. Rice REF/PDR/tdm l
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Page Six xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 H. G. Baker.
D. R. Altman L. T. Gucwa J. P. O'Reilly P. R. Bemis C. W. Hayes G. F. Head J. A. Bailey G. A. McCarley R. E. Conway
- 0. Batum R. W. McManus R. H. Pinson G. Bockhold Sr. Resident (NRC)
.C. W. Whitney C. E. Belflower C. C. Garrett (0PC)
B. M. Guthrie J. F. D'Amico J. E. Joiner (TSLA)
D. E. Dutton W. D. Drinkard D. Feig (GANE)
R. A. Thomas E. D. Groover NORMS I
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