ML20247C003
| ML20247C003 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/23/1989 |
| From: | Blake J, Coley J, Glasman M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20247B982 | List: |
| References | |
| 50-424-89-03, 50-424-89-3, 50-425-89-03, 50-425-89-3, IEB-80-08, IEB-80-8, NUDOCS 8903300098 | |
| Download: ML20247C003 (14) | |
See also: IR 05000424/1989003
Text
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UNITED STATED
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST., N.W.
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ATLANTA GEORGIA 30323
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Report Nos.: 50-424/89-03 and 50-425/89-03
Licensee: Georgia Power Company
P. O. Box 1295
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Birmingham, AL 35201
Docket Nos.: 50-424 and 50-425
License Nos.: NPF-61 and CPPR-109
Facility Name: Vogtle 1 and 2
Inspection Conducted: January 9-13, 1989
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Inspector:
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J. L.'Coley'
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Approved by:
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J.
./Blake, Chief
Dite Signed
M epials and Processes Section
ng(neering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of
licensee actions on previous inspection findings (Unit I and 2)
licensee identified items (50.55(e)) (Unit 2), and NRC Bulletin 80-08
(Unit 2).
Results:
In the areas inspected one violation, 425/89-03-01
(paragraph 2.b.(10)) was identified which dealt with the failure of
the licensee to report a potential 10 CFR 50.55(e) item on a Class 1
forged tee in a timely manner as required by Georgia Power company's
(GPC) Quality Assurance Procedure QA-04-02. As a result of the above
finding and discussions held with the licensee concerning this matter
programmatic weaknesses in reporting 10 CFR 50.55(e) occurrences were
indicated.
8903300098 09030D
ADOCK 050004D4
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REPORT DETAILS
1.
Persons Contacted '
Licensee Employees
- G. Bockhold, Gt:neral Manager of Nuclear Operations
- E. Groover, QA Site Manager, Construction
- C.' Hayes, Project QA Manager
- W. Nicklin, Compliance Supervisor
Other licensee employees contacted during this inspection included
engineers, quality assurance and administrative personnel.
NRC Resident Inspectors
. R. Aiello, Resident Inspector
- C. Burger, Senior Resident Inspector
- J. Rogge, Senior Resident Inspector
- Attended exit interview
2.
Licensee Action on Previous Inspection Findings and Licensee Identified
Items (92701, 92702 and 92700)
GPC has set a fuel' load date for Unit 2 of February 9,1989.
Region II
considers this date to be realistic, assuming that no unforeseen delays
occur in the licensee's remaining construction and preoperational testing
efforts.
However, all outstanding construction items are expected to be
closed or resolved to NRC's satisfaction by fuel load, initial
criticality, or prior to exceeding five percent power.
The inspectors' objectives this inspection were to review the licensee's
corrective actions on those open items designated to the Materials and
Processes Section by Region II Management.
Items Examined are as follows:
a.
Action on Previous Inspection Findings (Units 1 and 2)
(1)
(Closed) Severity Level (SL) IV violation, 50-425/88-37-01,
" Failure to Detect Damage to Pressurizer Surge Line."
GPC
letter of response dated September 22, 1988, has been reviewed
and determined to be acceptable by Region II.
The inspectors
held discussions with Quality Assurance Site Managers and
examined the corrective actions as stated in the letter of
response.
The inspectors concluded that GPC had determined the
full extent of the subject noncompliance, performed the
necessary survey and follow-up actions to correct the present
.
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conditions and ~ developed the necessary corrective actions to
preclude recurrence of similar circumstances.
The corrective
actions identified in the letter of response . have been
implemented.
(2)
(Closed)
Severity
Level IV
Violation
50-424/87-11-02,
50-425/87-07-02, " Failure to Provide Adequate Report for
significant Construction Deficiency."
GPC letter of response
dated March 31, 1987, has been reviewed and determined to be
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acceptable by Region II.
The inspectors held discussions with
the Bechtel Engineering Supervisor for Heating,-Ventilation and
Air Conditioning (HVAC) and examined the corrective actions as
stated in the letter of response. The inspectors concluded that
. GPC had determined the full extent of the subject noncompliance,
performed the necessary survey and follow-up actions to correct
the present conditions and developed the necessary corrective
actions ' to preclude recurrence of similar circumstances.
The
corrective actions identified in the letter of response have
been implemented.
(3)
(Closed) Severity Level IV Violation 50-425/88-20-01, " Failure
to Install HVAC systems in accordance with FSAR." GPC letter of
response dated June 22, 1988, and Supplement of Letter of
Response dated June 23, 1988, have been reviewed and determined to
be acceptable by Region II.
The inspectors held discussions
with the Bechtel Engineering Supervisor for HVAC and examined the
corrective actions as stated in the . letter of response.
The
inspectors concluded that GPC had determined the full extent of
the subject noncompliance, performed and necessary survey and
follow-up actions to correct the present conditions and
developed the necessary corrective actions to preclude
recurrence of similar circumstances.
The corrective action
identified in the letter of response has been implemented.
(4)
(Closed) Inspection Followup Item 50-425/88-20-02, " Unavailable
HVAC Documentation."
The licensee had located the documenta-
tion, AX4AJ07-320-2, " Topical Report on Desigr and Testing of
Fan Cooler Filter Systems for Nuclear Applications (AAF-TR-
7101)."
The inspectors reviewed the instruction and the
satisfactory test results.
(5)
(Closed) Inspector Followup Item 50-425/88-33-02, " Protection of
Pennanent Plant Equipment from Uncontrolled Leakage."
The
inspectors discovered that this item had been closed by
Region II in Inspection Report No. 50-425/88-78.
(6)
(0 pen) Unresolved Item 425/88-02-02, " Banded Microstructure in
Ten Inch Safety Injection (SI) Piping"
In NRC Inspection Report 50-425/88-02, an unresolved item was
identified concerning the metallurgical adequacy of 10 inch
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Schedule 140 type 316 pipe manufactured to SA-376 in the SI
system, specifically, the Cold Leg Accumulator lines. The code
and procurement specifications require a fully annealed micro-
structure, however, the licensee was informed that the subject
material contained a " highly banded microstructure" as is
indicated by a report dated February 27, 1985 from Associated
Metallurgical Consultants (AMC) to Southern Company Services
(SCS).
SCS requested AMC to perform metallurgical analysis on
a sample of the subject material to determine why inspection of
this material wa; not possible with 45-degree shear waves; SCS
and preliminary NRC measurements have shown that sound enters
the material at approximately 22 degrees when using 45-degree
wedges. AMC concluded that this was due to the banded
microstructure in the material.
The licensee's initial response to the NRC's concerns was
contained in a report from Law Engineering of Atlanta, Georgia,
to GPC dated March 15, 1988 in which Law determined that no
unusual conditions were observed, and that the material' had an
equiaxed austenitic microstructure.
Law's conclusion was "the
material met the requirements of ASTM A376."
Results of corrosion testing performed by Cortest Columbus of
Columbus, Ohio detailed in a report to GPC dated August 30, 1988,
indicated that the material met requirements of ASTM A262
Practice A.
These corrosion tests were performed on specimens
which were in the as-received condition as well as a
cross-section of a weld in a welded specimen.
At this time, these are the inspectors' concerns:
(a) The Law Engineering report concluded that the material was
equiaxed, however, microphotos in the Cortest report
clearly display banding. The microstructure of the subject
material as well as other material,12 inch Schedule 140
provided by the same vendor, are shown in figures Ia, 2a,
3a, and 4a of the Cortest Report.
(b) Moreover, reproductions of microphotos produced by Law
Engineering of the subject material were given to the
inspector during a previous inspection because the
microphotos in copies of the Law Engineering report
provided to the inspector were not readable.
A number of
these microphotos were not included in the Law report, yet
they displayed a high degree of banding in spite of Law's
conclusion that the material was not banded.
(c) The Cortest report was not clear as to whether the
corrosion test included the Heat Affected Zone (HAZ) of the
welded specimen.
In addition, the photos were not
discernible in the xerox copy provided to the inspector.
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Pending further licensee action and NRC reviw, this item
remains open.
b.
Licensee ' Identified Items Per 10 CFR 50.55(e) and Vogtle's Quality
Assurance Procedure QA-04-02
(1)
(Closed) Construction Deficiency Report (CDR)88-143, Engineered
Safety Features Air Filtration Bolting, Unit 2
There are 'four ESF Air Filtration Units in the current Unit 2
Design; two redundant trains are provided for the control room,
and two for the piping penetration area.
Each filtration unit
is supported in place by
"C" channels bolted to angle clips
which in turn are anchored to the foundation. The holes through
which the bolting is passed (between the angle clips.and the C
channels) in the angle clips are slotted to accommodate field
adjustment.
This construction deficiency was due, in part, to
inadequate drawings and failure of the contractor to follow
procedures related to the installation of the bolts between the
angle clips and the C channels.
Since the vendor drawings did not specify bolting material,
washer type / placement, and torque requirements, the contractor,
P/KF, mistakenly assumed that standard bolting material was
supplied, however, per site procedure, substituted'high-strength
bolts. Lock washers or oversized washers were also omitted from
the original installation because the vendor drawings did not
specify these requirements.
Instead, the vendor installed
plated washers on the nut side of the bolted connection, on the
C channel side, and snugged the bolts.
Since high-strength bolts were installed without lockwashers,
lock nuts, or without being torqued to the proper pre-tension-
value, the integrity of the bolted connection could not be
assured.
If the connection were to relax or loosen, failure
could potentially occur during a seismic event.
The licensee reviewed all other equipment within the scope of
P/KF's field engineering and installation work and found no
other ex_ spies of the deficiency described herein.
Following discovery of this discrepancy, the licensee contacted
the filtration unit vendor, American Air Filter, and they
indicated that for seismic qualification, ASTM A-449 or
equivalent high strength bolts pretensioned to 355 foot-pounds
with a lock washer on the nut side were required. To implement
corrective action, a Field Change Request (FCR) was written by
Bechtel for removal of all accessible bolting and replacement of
these bolts with the specified high strength bolting, including
oversize washers on the bolt side, and lock washers on the nut
side and torquing the connection to 355 foot-pounds.
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inspectors subsequently reviewed ~ the applicable FCR, and
inspected the bolted connections on ESF air filtration units
2-1561 N7 001, and 2-1531 N7 001.
The bolted connections
included the washers per requirements of the vendor, and there
were no gaps visible in the connection between the angle clips and
the C channel.
This item is closed.
(2)
(Closed) CDR 86-120, Valcor Solenoid Valve Spring Failure,
Unit 2
Valcor Engineering Corporation notified GPC and Bechtel in June
1986 and indicated that the 17-7PH springs used in certain
Solenoid Valves (SV) 'of their manufacture were subject to
hydrogen embrittlement when exposed to reactor coolant at
temperatures greater than 440 degrees F.
The time to failure
was given as 1-2 years.
Based on information supplied to the
NRC' under Part 21, NRC IN 86-72, " Failure of 17-7 PH Stainless
Steel Springs Due to Hydrogen Embrittlement," was issued by the
NRC August 19, 1986 on the same subject.
Bechtel and Valcor then identified two SV's which contained
17-7PH springs exposed to reactor coolant flow at temperatures
in excess of 440 degrees F.
These two valves, 2HV-8208, and
2HV-8209 were in th Post Accident Sampling System liquid return
line, and were mo ified by replacing the 17-7PH springs with
Elgiloy springs.
Elgiloy springs, per Valcor's correspondence
with Bechtel, was considered a suitable replacement for the
17-7PH springs in the respective valves.
The inspectors
verified that the two valves were modified by examination of
Maintenance Work Order (MW0) 28805855 dated June 13, 1988.
Following the initial notification to the NRC of the spring
embrittlement problem, GPC made an additional report of
under-rated seal-in contacts on magnetic reed switches
associated with the Valcor and other SVs in Unit 2.
These
contacts were rated at 0.5 Amp at 125VDC. However, the licensee
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found that the contacts carried 1.25 Amp, 125VDC; it was found
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that during design, the contact ratings were overlooked.
As a
result, the licensee conducted a review of direct acting
solenoid valves and derived a list of SVs subject to problems
associated with under-rated seal-in contacts.
Corrective action
was implemented by diversion of the excess seal-in current by
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MDR 137-8)g an additional auxiliary relay (Potter & Brumfield
interposin
to carry the seal-in current for the SVs.
The
magnetic reed switch, following the modification, carries only
the seal-in current for the MDR 137-8 relay which is 0.082 Amp;
well within the capability of the reed switch contact rating of
0.5 Amp.
The control circuit changes were implemented by FCR's
17660, 17661, 17662, 17676, 17677, and 17707.
These FCRs were
reviewed by the inspectors and were found to adequately
incorporate the necessary changes in control circuitry to
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prevent overloading the magnetic reed switch contacts.
This
item is closed.
(3)
(Closed) CDR 84-70, Bettis Damper and Valve Actuators, Unit 2
G. H. Bettis, a manufacturer of pneumatic actuators used in
construction of Vogtle 1 and 2 reported that certain rotary
actuators of their manufacture were found to have less than
adequate performance, in that, the actuator motion was jerky and
irregular, and the stroke times were greater than 15 seconds.
The 15 second stroke time was representative of many Bettis
customer specifications.
The reason for the degraded
performance was due to specific combinations of ethylene
propylene seals, and hydrocarbon based grease (Mobil 28) used in
manufacture of the actuator.
Bettis indicated that the seals
absorbed the grease and became swollen much the same as a sponge
when it absorbs water.
The result was the seal would expand
against the movable position rod and " set" (i.
e., flatten) if
the actuator was used infrequently.
As a result, Bettis issued
a Part 21 report, and GPC notified the NRC of a Construction
Deficiency because these actuators operate various valve and
damper assemblies which must open or close within a specified
time period in response to an Engineering Safety Features (ESF)
signal to isolate or vent various mechanical and HVAC systems.
GPC, in their evaluation, identified 70 dampers and four valves
supplied with G. H. Bettis actuators susceptible to the seal
swelling problem and elected to rebuild these actuators using
new seals and Dow Corning Molycote 44 lubricant. This lubricant
is considered compatible with the ethylene propylene seals as it
is not hydrocarbon based.
Following the rebuild work, GPC
checked the performance of the actuators which included stroke
time and smoothness of operation.
The inspectors verified-
proper replacement of seals and grease per Bettis requirements
and that the actuator met required stroke times by reviewing the
MW0s and Construction Acceptance Test (CAT) sheets for the
following actuators:
Required
Measured
Tag Number
Stroke time
2-JV 12713A
30 sec
2.5 sec
2-HV 12716
30 sec
8.5 sec
2-HV 12734
30 sec
2.2 sec
2-HV 12596
30 sec
1.0 sec
2-HV 12147
5 sec
3.9 sec
2-HV 12149
5 sec
2.9 sec
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2-HV 12606
6 sec
2.6 sec
2-HV 12604
6 sec
1.5 sec
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The inspectors found the corrective action _ adequate, and the
performance of the rebuilt a::tuators listed above within
required performance limits. This item is closed.
(4)
(Closed) CDR 86-132, Containment Purge System Register Damper,
Unit 2
On November 17,1986, Region II was notified of a potentially
reportable condition concerning a loose damper in the exhaust
register on the containment normal purge system. A final report
on this item was sent to Region II on December 16, 1986.
The
containment normal purge system is designed to purge the
containment atmosphere to the plant vent stack while introducing
filtered and treated make up air from the outside to reduce
containment airborne radioactivity levels below that required for
personnel access.
Supply and exhaust registers with opposed blade dampers (0B0)
are provided at the normal purge supply and return openings for
air f ow adjustment and distribution.
The OBDs are attached to
the g"ill sections of the registers using spring clips provided
by the register supplier, Krueger Manufacturing Company.
During testing of the containment normal purge system for air
flow adjustment, one of the exhaust registers in the normal
purge system pulled loose and broke apart.
The damaged parts
traveled through both containment isolation valves and were
found in the duct work between the isolation valve and the
filtration unit.
The root cause of the reported condition was
that the specification did not require the supplier to provide
registers with a positive means to secure the damper.
The
detached damper, if drawn into the duct, could have damaged the
containmen' isolation valve or lodged in the valve seats to
prevent containment isolation.
A review was performed on other
HVAC systems designed by Bechtel Engineering and it was
determined that the containment normal purge system is the only
system where a failure of non-safety-related components
(dampers) could impact the safety function of downstream
safety-related components. To prevent the exhaust dampers in the
normal purge system from becoming loose in the future, the
damper sections and grill sections of the exhaust registers have
been modified and were secured together by tackwelds or Pop-
Rivets.
The adequacy of this modification is demonstrated in
calculation No. X4C 1506V02, Revision 0.
A common drawing
change required for implementing the corrective actions has been
issued.
The inspectors reviewed the licensee's corrective
action and discussed the corrective actions with Bechtel's Civil
Engineering supervisors for the HVAC system.
The actions
identified in the report have been completed.
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(5)
(Closed) CDR 87-139, Control Room - Essential HVAC Improper-
Design, Unit 2
The licensee's final report was submitted on April 14, 1988.
The initial discrepancy was that in certain accident conditions
involving the failure of one diesel train, the possibility existed
that a short-circuit exhaust path could be left in the control-
room emergency HVAC duct work by partially open isolation
dampers in the failed train. The isolation dampers are designed
to maintain the position they are in at the time of power loss.
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This problem was solved by installing backdraf t dampers.
However, a broadness' review of this discrepancy discovered tf t
if more than two of the four 100 percent capacity fant. are
operating at the same time, the fans would operate in the surge
range of the fan curves.
This scenario could result in damage
to one or more of the fans. This subsequent problem was solved
by installing flow switches in conjunction with a lead / lag
circuit which will prevent more than one train per unit of the
control room essential HVAC system from automatically operating
at the same time.
The inspectors held discussions with the
cognizant engineers concerning these discrepancies and reviewed
the licensees corrective actions.
The actions identified in
the licensee's report have been implemented.
(6)
(Closed) CDR'84-66 Containment Pipe - Rack Welds, Unit 2
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On July 20, 1984, the licensee notified Region II of a 50.55(e)
item involving cracks in Unit I containment pipe-rack welds.
In
reporting this item the licensee assumed the problem 'was
applicable to the Unit 2 pipe-rack installation.
Therefore,
the CDR included both units, however, Unit 2 had not installed
their pipe-rack prior to the corrective action on Unit 1 and
therefore the Unit I resolution was incorporated in the Unit 2
installation.
The Unit 1 CDR was closed in NRC Inspection
Report Nos. 50-424/85-40 and 50-425/85-31.
The inspectors held
discussions with the GPC QA Manager concerning this item and
reviewed supporting information. This item is considered closed.
(7)
(Closed) CDR 88-144, Valves Installed Opposite to Direction of
Flow, Unit 2
During system flushing and start up testing the licensee found a
number of valves were installed backwards.
The licensee's
review indicated that there were a total of 29 valves
improperly installed due to three reasons: flow arrows were not
stamped on the valve bodies, flow arrows were stamped in the
wrong direction, and flow arrows were incorrect or absent
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on the associated isometrics.
The licensee, however, indicated
that as a result of an engineering evaluation,12 valves are
acceptable as is, and the remaining 17 valves had to be
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reversed for correct flow in the intended direction through the -
. valve.
Regarding the valves which' will not be- reversed; GPC .
indicated that vencors were contacted to determine if thc valves
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' were operable with flow through the valve = internals in either
direction, and the applicable valves were acceptable for use. in
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either flow direction, these valves' include gate and' plug and
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ball. valves as . opposed to check, or globe valves. -
The
inspectors. also .noted that- the licensee contacted the Dresser
Industries,. the vendor who supplied valves which were stamped
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with the flow arrows in the wrong direction, to determine if this-
was a widespread problem. - Dresser ' indicated that the valves
involved were _ part of a four valve ' order and' one valve failed
the hydro test, and was not shipped.
The remaining three were
shipped ? to the Vogtle Project, and' were detected- by the
licensee. Dresser further stated that it was their opinion that.
this-was an isolated error due to human error, and the first such
incident brought to their attention.
To ascertain if the licensee performed the required rework to
reverse the valves identified as needing to be reversed, the
inspectors reviewed several completed Operations Deficiency
Reports (00R) for four safety related valves which were
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identified in the group of 17 valves which had to be reversed.
These valves were as follows:
Tag Number
ODR Number
System
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T-2-88-4 58
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Control Valve
T-2-87-173
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Isolation Valve
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2HV-10953
The above documentation was 'found satisfactory in -that it
substantiated that the required rework was. completed. This item
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is closed.
(8)
(Closed) CDR 86-128, Emergency Diesel Generator Building
Ventilation System, Unit 2
On September 12, 1986, the licensee notified Region II of a
potentially reportable condition which indicated that the
emergency diesel building ventilation system was not delivering
design air flow.
On October 31, 1986, the licensee notified
Region II in their final report that after modifications which
included hermei,1cally sealing the diesel generator building,
insulating the diesel exhaust piping and performing a
comprehensive evaluation of the resulting condition, they had
concluded this item was not reportable since the required
temperature could be maintained.
However, a new minimum
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calculated' design air flow of 70,000 CFM/ Fan at a static
pressure of 2.6 inches water gauge (WG) was established rather
than the 95,000 CRi/ Fan at a static pressure of 1.7 inches WG as
shown in the Final Safety Analysis Report (FSAR).
The new
calculated design flow rate is the minimum air flow needed to
maintain the diesel generator building at 120 F during diesel
operation.
The inspectors held discussions with Bechtel's Civil Engineering
Supervisor concerning this issue and reviewed the new design
calculations (X4C2107V03), the work modification documents, and
final air flow preoperational test results.
The inspectors
concurred that the fans would be adequate to furnish the air
flow necessary to maintain the diesel generator building at
120 degrees F during operation and this item is considered
closed.
(9)
(Closed) CDR 88-148 Anchor Darling Valve Weight Discrepancies,
Unit 2
As a result of as-built reconciliation of piping stress
analyses, the licensee was informed of significant discrepancies
between valve assembly weights shown on valve assembly drawings
and valve assembly weights used in valve seismic reports for two
valves located in the Refueling Water Storage Tan) (RWST)
recirculation line.
These valves (2HV-10957, 58) close on
receipt of a low water level signal in the RWST.
The weights
listed on the assembly drawings were 195 pounds less than the
weights shown on the seismic report for the applicable valves.
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As a result, the pipe stresses were higher at locations upstream
of the valves.
A break at one of these locations :ould result
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in insufficient water volume in the RWST for saf( ty injection
and containment spray functions.
The licensee then sent a letter to the vendor, Anchor Darling
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Valve (A/DV), requesting revision of the drawings such that
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actual valve weights are reflected on these documents and A/DV
responded in kind. The licensee also conducted an investigation
to determine if other valve vendors could possibly have the
wrong weights listed on their respective assembly drawings. The
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licensee considered the results satisfactory in that weights
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listed were within
10 percent, actual weight, or within normal
,
manufacturing tolerances.
Corrective action by the licensee included reconciliation of the
increased valve weights into the stress analysis of the
applicable piping system and installation of an additional
restraint for one of the affected valves.
This work was
substantiated by a review of drawing V2-1204-H061, Rev. 2, showing
the addition of the extra restraint below Valve 2HV-10957. This
item is closed.
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(10) '(Closed) CDR 88-147, "ASME Class 1 Forged Tee Fittings"
On November 14, 1988, GPC notified Region II of a potentially
reportable condition per 10 CFR 50.55(e) involving certain
Unit 2 ASME Class 1 Tee Fittings, which had been block forged
instead of extruded.
On December 15, 1988, GPC submitted their
final report.
The inspectors' review of this report revealed
that as a result of the stress analysis considering snubber -
reduction for isometric drawing 2K4-1201-049-02, higher than
1
allowable stresses for the 12"x12"x6" reducing Tee on' the
residual heat removal line from the reactor coolant system hot
leg loop were indicated. A walkdown performed on April 30, 1987,
to measure the wall thickness of the tee to obtain as-built"
information that might aid in reducing stresses at the tee
discovered that a " block forged" reducing tee was installed in
lieu of an extruded tee.
The stress analysis for Unit 2 had been
performed based on a extruded reducing tee at this location. The
stress analysis did not consider the effects of wall thickness
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variation and discontinuities due to machining the forging. The
-ASME Code rec;stres thermal transient analysis to be performed for
all structural discontinuities in ASME Class 1 piping systems.
The root cause for the forged tee not being considered in the
original stress analysis was determined to be the failure of the
piping vendor, Pullman Power Products (PPP), to notify GPC before
using non-standard forged tees.
This requirement was given in
an attachment to the purchase specification.
A technical review of this condition concluded that it was
prudent to replace the block forged reducing tee with an
extruded 12"x12"x12" tee and a extruded 12"x6" reducer rather
than expending resources to justify the forged tee.
The
licensee at tnis point however, violated GPC's Quality Assurance
Department Procedure QA-04-02, "Significant Deficiency / Defect
Reporting," in that, paragraph 1.B. states in part that, that the
following guidelines shall be used to determine if the
occurrence
is
a
potentially reportable
item under
could the deficiency were it to have remained
uncorrected, have affected adversely the safety of operations of
the plant at any time throughout the expected life time of the
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plant, and does it represent any one of the following
conditions:
(a) A significant breakdown in any portion of the Quality
Assurance Program
(b) A significant deficiency in the final design as approved
,
and released for construction
Specific examples given in the procedure for reporting
deficiencies under 10 CFR 50.55(e) included the following:
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<y
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(a) Deficiencies which require replacement of: a safety; class
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-structure, system or component'
(2)1 Deficiencies which require. extensive evaluation
In addition, QA-04-02 paragraph 1.F. states, "the initial ' report
shall be 'made without having officially determined whether the
occurrence is. reportable and will be reported as a' potential-
l-
.10'CFR50.55(e)."
As a result of firiding this- tee,' a d' rawing review was performed
to identify all ASME Class 1 tees.
The locations were walked
down to identify any forged tee fittings.
A' total of 44 ASME
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Class .1 tees were identified' .'ncluding the one previously
discussed. Three were extruded ano' 11 had been forged.
An extensive evaluation was performed on the 40 forged tees
remaining in various installed systems.
The review found the.
forged tees in place to be acceptable but resulted in eleven new
high energy line break locations.
The licensee concluded in their December 15, 1988, letter (191
months after the deficiency was -identified) that the
installation 'of the forged tee in the RHR line, without
consideration of effects of variations in wall thickness and-
structural discontinuities, could potentially have led to a
significant' safety hazard as defined by 10 CFR 50.55(e). Total
time allowed to report a potential 10 CFR 50.55(e) to NRC as
~
delineated in GPC procedure QA-04-02 is' 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.
This
violation was reported to the licensee as Item No. 425/89-03-01,
" Failure to Report Potential 50.55(e) Item on Class 1 Forged
Tees as Required by GPC Procedure QA-04-02."
c.
NRC Bulletins, Unit 2
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(Closed) NRC Bulletin 80-08, " Examination of Containment Liner
During an NRC-inspection at a particular facility, examination by
radiograph of primary containment liner penetration sleeve-to-process pipe
(fluid head fitting) welds revealed rejectable defects not originally
found by ultrasonic examination. Apparently, ultrasonic signals from
the weld backing bar masked signals from defects.
Further
investigation found similar problems at other facilities. A Bulletin
was issued to acquire information from all facilities to
determine the generic nature of the problem.
Review of GPC letter of
response dated June 26, 1980, revealed that GPC had radiographer all
penetration welds at Vogtle Unit 2 and therefore has performed the
examination in accordance with Bulletin 80-08 recommendations.
No further action is required and this item is considered closed.
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Within the areas examined, violations or deviations were not
identified except as noted in paragraph 2.b.10 above.
3.
The inspection scope and results were summarized on. January 13, 1989, with
those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results listed
below.
Proprietary information is not conteined in this report.
Dissenting comments were not received from the licensee.
(0 pen) Violation 425/89-03-01, Failure to Report Potential 50.55e Item on
Class 1 Forge Tees as required by Quality Assurance Department Procedure
QA-04-02 (Paragraph 2.b.10).
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