ML20206E427

Insp Repts 50-424/87-12 & 50-425/87-08 on 870124-0309. Violations Noted:Failure to Adequately Control Locked Valves & to Establish Adequate Program to Collect & Evaluate Transient & Operational Cycles

ML20206E427
Person / Time
Site:	Vogtle
Issue date:	04/03/1987
From:	Livermore H, Rogge J, Schepens R, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206E344	List: ML20206E341 ML20206E411 ML20206E427
References
50-424-87-12, 50-425-87-08, 50-425-87-8, NUDOCS 8704130609
Download: ML20206E427 (46)

See also: IR 05000424/1987012

Text

-

N

p2 H!v UNITED STATES

'

-f ,

/ 'b NUCLEAR REGULATORY COMMISSION

.p #

p REGloN ll

.g j 101 MARIETTA STREET, N.W.

• t ATLANTA, GEORGI A 30323

4 o

9.....g

Report Nos.: 50-424/87-12 and 50-425/87-08

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302 ,

_

Docket Nos.: 50-424 and 50-425 License Nss.: NPF-61 and CPPR-109

'

Facility N"ame: -Vogtle 1 and 2

Inspection Conducted: January 24 - March 9,1987

Inspectors: f.8 b b d

H. H. Livermore, Senior Residen~t Inspector

.

3 87

Date'Sfgned

Ng Construction

3 5 67

J. F. Rogge, Senior Rosident Inspector Datg' Signed

M Operations

gg b u '

$

DaterSilgned

07

R. J. Schepens, Resident Inspector, Operations

Accompanying Personnel: G.M. Nejfelt, Resident Inspector, Hatch

E. ,Christnot, Project Engineer

Approved by: - 0 Lio Y 3 67

M. V! Sinkule, Section Chief Dats sign #d

Division of Reactor Projects

S'JMMARY

l

Scope: This routine, unannounced inspection entailed Resident Inspection in

the following areas: plant operations, radiological controls, maintenance,

surveillance, fire protection, emergency preparedness, ' security, outages

activities, containment and safety related structures, piping systems and

supports, safety related components, auxiliary systems, electrical equipment

and cables, instrumentation, startup, ' quality programs and administrative

controls affecting quality, employee concerns / allegations, and follow-up on

previous inspection identified items.

Results: Two violations were identified in the area of plant operation.

l

Failure to adequately control locked valves and failure to' establish an

l adequate program to collect and evaluate transient and operational cycles.

8704130609 870403

PDR ADOCK 05000424;

7

G PDR~

m.

,

., _

, , _ , , ,

. -

'

1 >

REPORT DETAILS

1. Persons Contacted

Licensee Employees

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

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

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

C. W. Whitney, General Manager, Project Support

W. W. Mintz, Project Completion Manager

• R. W. McManus, Readiness Review

• G. Bockhold, Jr., General Manager Nuclear Operations

E. M. Dannemiller, Technical Assistant to General Manager

T. V. Greene, Plant Manager

• 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

8. C. Harbin, Manager Quality Control

• G. A. McCarley, Project Compliance Coordinator

W. C. Gabbard, Regulatory Specialist

G. S. Lee, Operations Superintendent

R. M. Odom, Plant Engineering Supervisor

C. L. Coursey, Maintenance Superintendent (Startup)

M. A. Griffis, Maintenance Superintendent

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

R. E. Spinnatu, ISEG Supervisor

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

W. F. Kitchens, Manager Operations

V. J. Agro, Superintendent Administration

• A. L. Mosbaugh, Assistant Plant Support Manager

M. P. Craven, Nuclear Security Manager

Other licensee employees contacted included craftsmen, technicians,

supervisors, engineers, operators, maintenance, chemistry inspectors, and

office personnel.

Other Organizations

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

D. L. Kinnsch, Project Engineering - Bechtel

F. B. Marsh, Project Engineering Manager - Bechtel

• Attended exit interview.

. . . . . .

4

.e *

2

,

'2. Exit Interviews - Units 1 & 2 (30703'& 30703C)

The inspection scope and findings were summarized on March 9,1987, with

those persons indicatid in paragraph 1'above.- The inspector described the

!- . areas inspected and discussed in detail . -the inspection results. .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. Region based NRC exit interviews

4 were attended during the inspection period by a resident inspector. This

,

inspection closed one unresolved . item,. three Inspector Followup Items-

. (IFI), and six.-.10 CFR Part 21 reports. The~ items identified during this

4

inspection were:

a. Violation 50-424/87-12-01, " Failure - to Maintain Control ; of Locked

'

Valves" - Paragraph 4.a

I b. Violation 50-424/87-12-02, " Failure to Establish an Adequate Program

for the Collection and Evaluation of Transient'or Operating Cycles" -

Paragraph 18.d

, c. IFI 50-424/87-12-03, " Review' Revised Surveillance Procedure 14928-1"

l - Paragraph 4.b.(6)

I

d. IFI 50-424/87-12-04, " Review Completed Walkdown . Verification.

j Regarding Communication Cables in Safety Related Equipment" -

Paragraph 20.m

e. IFI 50-424/87-12-05, " Review Corrective' Action Due to Use of-

t Inadequate Procedure No. 22220-C" - Paragraph 20.h-

f. IFI 50-424/87-12-06, " Review Followup Interview Regarding QCP File

87V0044" - Paragraph 20.n

g. IFI 50-424/87-12-07, " Review Licensee's Investigation- of Containment

4

Ventilation Isolation Reset Capability for . Containment Post-LOCA

Purge Isolation Valves" - Paragraph 4.b.(12)

!'

h. IFI 50-425/87-08-01, " Review Implementation of FECO to Change ITE 27B- "

i Relay to New Model Under MWO 2-87-0034 and MWO 2-87-0035" -

,

Paragraph 19.h

3. Licensee Action on Previous Enforcement Matters - Units 1 & 2 (92702)~

I Not inspected.

.

4. Operational Safety Verification - Unit 1(71707,93702,90712,92700)

4

The plant began this inspection period in refueling (Mode'6) with initial

-

fuel loading in progress and subsequently completed on January 28. . Cold

,

Shutdown -(Mode 5) was entered on February 1, followed by - Hot Shutdown

(Mode 4) on February 20, and Hot Standby (Mode 3) on February 23. -Due to

1

,

... . - . , . . . - . , - - , , , , , . , _.. . . , . _ _ _ . _ , , , . ~ . .,_ . .- _, , m , ,m.,- .. ,,y.r..

'1

e )

3

High Vibration on the Number ~2. Reactor Coolant Pump the unit oroceeded_to

Mode-5 on February 26 to perform. repairs and returned to Mode 3 on -

March 1. .On March 9, Startup (Mode 2) commenced : and initial reactor

criticality. achieved 'at 8:37 a.m. , EST. ' Thirteen operational type events

were reported and received inspector ~ followup. Of the thirteen events,

eight were ESF type actuations, two related to failed equipment or

material . problems, one. involved Environmental Qualification of the Main

Steam Isolation Valves, and two were other type events. Within the .ESF

actuation category five were related to spurious containment, containment-

ventilation or control room isolations, and three were actuations of the

auxiliary feedwater system due to personnel errors,

a. Control Room Activities

Control . Room tours and observations were performed to verify that

facility operations were .being safely conducted within regulatory

requirements. These inspections consisted ofl one or .more of - the

following attributes as appropriate at the time of the inspection.

-

Proper Control Room staffing

-

Control Room access and operator behavior

-

Adherence to approved procedures for activities in progress

-

Adherence to Technical Specification (TS) Limiting Conditions

forOperations(LCO)

-

Observance of instruments and recorder traces of safety related

and important to safety systems for abnormalities

-

Review of annunciators alarmed and action in progress to correct

-

Control Board walkdowns

-

Observe the operabi',ity' of the safety parameter display and the

plant safety monitoring system

-

Discussion and interview with the On-Shift Operations

Supervisor, Shift Supervisor, and Reactor Operators and the

Shift Technical Advisor to determine the plant status, plans and-

assess operator knowledge  ;

-

Review of the operator logs, unit log and shift turnover sheets

'

During review of the shift supervisor log on 2/19/87, the inspector

noted that diesel generator-(DG) 1A main ' fuel oil valve

(1-2403-U4-031) had been logged in as being found in ~the

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

1 0

4

incorrect position (i.e., locked closed in lieu of locked open)

during the performance of the DG operability surveillance test

procedure no. 14980-1. The Inspector reviewed the following

clearances which had been taken out on the Train "A" diesel

generator during the diesel outage:

1-87-446 DG Train "A" Outage

1-87-0579 DG Train "A" Left Bank Intercooler

1-87-0235 DG Train "A" Fuel Oil Pump

The inspector also reviewed the latest diesel generator Train "A"

valve lineup procedure on file which was performed on 1/31/87 per

Operations Procedure No. 11145-1 and determined that another valve

lineup was not performed after the outage on the Train A diesel

generator. Discussions with shift personnel confirmed that once the

above valve was found mispositioned a complete valve lineup per

procedure No.1114-1 was performed on 2/18/87 on DG-1A prior to

re performing the DG operability surveillance per procedure

No. 14980-1.

From this review, the inspector determined that the latest

documentation which positioned the main fuel oil valve

(1-2403-U4-031) was clearance no. 1-87-446 which was installed on

2/7/87 and removed on 2/13/87. This clearance required the main fuel

valve (1-2403-U4-031) to be restored to the locked open position and

was signed off as being positioned correctly along with independent

verification. In addition, the inspector went to conduct a review of

the locked valve manipulation log per procedure 11888-1 to determine

if the position had been altered by this method of control. However,

the locked valve manipulation log had not been put into place as of

2/23/87. The inspector informed the licensee of this matter and the

locked valve manipulation was verified by the inspector to be in

place on 2/24/87.

Per operations procedure 10019-C, status changes in the positions of

locked valves shall be documented by one of the following means:

a) use of applicable alignment procedure; b) use of an approved

equipment clearance; or c) use of 11888-1, " Locked Valve Manipulation

Log". Contrary to this, the diesel generator Train A main fuel oil

valve was found on 2/18/87 to be in its other than required position

(i.e., locked closed in lieu of locked open).

The foregoing is considered to be in violation of Technical

Specification 6.7.la and will be identified as Violation

50-424/87-12-01, " Failure to maintain control of locked valves".

Additional underlying problems noted by the inspector are as follows.

The diesel generator was taken out of service for an outage on

2/7/87 and was being restored to service on 2/18/87. The DG valve

lineup per procedure 11145-1 was not performed prior to attempting to

perform the DG operability surveillance per procedure 14980-1. In

tfie precautions and Timitations section of surveillance procedure

M980-1, there is a statement to ensure that a current copy of

11145-1 was on file. Due to the extent of the outage on the diesel,

it would have been preferred that this valve lineup be performed

r o

5

prior to attempting to perform the surveillance. Discussions were

held with operations management on this matter and they acknowledged

that due to the extent of the outage, the vals e lineup should have

been performed after the outage. 0perations management also informed

the inspector that shift personnel were counseled regarding this

matter. Another discrepancy noted by the inspector during this

review was that procedure'10019-C requires a Deficiency Report (DR)

be initiated upon discovery of a valve locked in any position other

than that required. The inspector deemed it necessary to inform the

licensee of this requirement several times during the investigation

and noted that by the time of the exit interview the licensee still

had not informed the inspector if a DR had bcen written or not.

Finally, procedure 10019-C, " Control of Safety Related Locked Valves"

contains tables of locked valves which are incomplete. Discussions

with the responsible procedure writers confirmed their awareness of

the situation and that they were actively working on updating the

procedure to have an accurate and complete listing of all locked

valves. This matter should be given additional resources as

necessary to expedite the issuance of the revised procedure.

Subsequently, on 2/26/87, during an NRC inspection of the Auxiliary

Feedwater (AFW) system valve lineup, the steam generator No. 2 main

steam supply valve (1-1301-04-007) to the turbine driven auxiliary

feedwater pump was found to be in the locked closed position in lieu

of the required locked open position. The inspector reviewed the

following documentation to determine the latest valve manipulation.

Review of the AFW system alignment for startup and normal operation

procedure 11610-1 completed on 2/24/87 documented the valve to be

positioned and independently verified as being correctly positioned

(i.e., locked open). Review of clearances and lock valve manipu-

lation log did not reveal any documentation of valve repositioning.

Finally, review of the working copy of startup test procedure

1-5AL-01, "AFW System Test" did not document any repositioning of the

subject valve required or performed during the test. This is another

example of the above noted violation " Failure to maintain control of

locked valves" (50-424/87-12-01).

b. Facility Activities

Facility tours and observations were performed to assess the

effectiveness of the administrative controls established by direct

observation of plant activities, interviews and discussions with .

licensee personnel, independent verification of safety systems status j

and LCOs, licensee meetings and facility records. During these

inspections the following objectives are achieved:

(1) Safety System Status (71710) - Confirmation of system ,

operability was obtained by verification that flowpath valve  !

alignment, control and power supply alignments, component

conditions, and support systems for the accessible portions of

.- - . _

. - .-

"

_

i

t 3

6

.

the ESF trains were proper. The inaccessible portions are

confirmed as availability permi ts '. _ Additional indepth

inspection of theT Residual Heat' Removal . (RHR) System was '

-

performed to review the' system lineup procedure with the plant

drawings and as-built configurations, compare valve ' remote and -

local indications,:walkdowns were expanded.to include hangers

and supports,. and electrical equipment interiors. The: inspector

verify that the lineup was in. accordance with license

requirements for system operability. -

(2) Plant. Housekeeping _ Conditions - Storage of - material and

components- ard cleanliness conditions of ~various- areas

throughout the facility were observed to ' determine - whether

safety and/or. fire hazards existed.

(3) Fire Protection - Fire protection -activities, staffing and

equipment were observed to verify that fire brigade staffing was

appropriate and that fire' alarms, extinguishing equipment,.

actuating controls, fire fighting equipment, ' emergency

equipment, and fire-barriers were operable.

(4) Radiation Protection - Radiation . Control Areas . (RCAs) were

observed to verify proper identification and implementation.

(5) Security - Security controls were observed -to verify that

security barriers were intact, guard forces were on duty, and

access to the Protected Area (PA) was controlled in accordance

with the facility security plan. Personnel within the PA were

observed to verify proper display 'of badges and that personnel

requiring escort were properly escorted. Personnel ~within vital-

areas were observed to ensure. proper authorization for the area.

'

(6) Surveillance (61726, 61700) - Surveillance tests were observed

to verify that approved procedures' were being used; qualified

personnel were conducting the ' tests;' tests ' were adequate to

verify equipment operability; calibrated equipment was utilized;

and TG requirements were followed. The inspectors observed

portions of the following surveillances and reviewed completed'

data against acceptance criteria:

14210-1 Containment Building Penetrations Verification -

Refueling

24760-101 Steam Generator (Narrow Range) Level Transmitter

ILT-537 Calibration

14710-101 Remote Shutdown Panel Transfer Switch and Control

Circuit 18 Month Surveillance Test. l

43690-C Calibration of Containment Area Radiation (High '

Range) Monitors 1 RE-0005'and 1_RE-0006-

= _ _ _ _ _ _ _ _ _ _ ___ _ _ _ ______________ _ _ _ ____ _ _ _ _u

-

_ _ _ _ _ . _ _ _

_ _

__

t O

7

The_. inspectors reviewed the following completed / approved

surveillances to verify test data was accurate and complete;

' test documentation was reviewed and test discrepancies were

rectified; and that test results met technical specification

requirements.

24587-102 Containment Pressure ' Protection Channel II

1 P-936 Analog Channel Operational Test

24588-102 Containmei.t Pressure Protection Channel III

1 P-935 Analog Channel Operational Test

24589-102 Containment Pressure Protection Channel IV

1 P-934 Analog Channel Operational Test

24624-101 Containment High Range (1 RE-0005) Area Monitor

1 RX-0005 Channel Calibration

24625-101 Containment High Range (1-RE-0006) Area Monitor

1 RX-0006 Channel Calibration

24625-102 Channel Calibration and Analog Channel

Operational Test

14420-101 Solid State Protection System Train A(B)

Operability Test

During the inspection period a review of Surveillance Procedures

14210-1, " Containment Building Penetrations Verification -

Refueling" and 14928-1, " Containment _ Ventilation Isolation -

Refueling" was performed to verify that the requirements of

Technical Specification Surveillances 4.9.4 and 4.9.9 were met.

The inspector noted the following:

(a) Procedure 14210-1 did not require that all containment

building penetrations be reviewed to determine the

potential of a direct access path as a result of

maintenance activities, and

(b) Procedure 14928-1 was inadequate in the following-areas:

-

It did not verify that the containment normal and mini

purge isolation valves closed as a result of a high

radiation signal on the process containment vent

effluent monitor 1 RE-2565,

-

It did not verify that the containment post LOCA ,arge

isolation valves 1 HV-2624 A&B closed on a containment

ventilation isolation (CVI) signal,

.

t 6

8

-

It did not - verify that the containment radiation-

monitor 1 RE 2562 isolation valves 1 HV 12975,12976,

12977, and 12978 closed on a containment ventilation

isolation signal, and

-

It did not properly restore the containment radiation

monitor 1 RE-2562 isolation valves 1 HV 12975,12976,

12977, and 12978 to their normal system alignment

position (open).

The above comments were discussed with the licensee and a

commitment was. made to revise the subject procedures.

Subsequently, Procedure 14210-1 was revised and issued on

2/21/87. The revised procedure adequately addressed the above

comment relative to Procedure 14210-1. Pending review of the

revised Procedure 14928-1 to address the above noted comments

this item will be identified as IFI 50-424/87-12-03, " Review

Revised Surveillance Procedure 14928-1".

During initial core load CVI was -inoperable; therefore, the

licensee complied with Technical Specifications LCO 3.9.4 and

3.9.9 by administrative 1y requiring that all isolat. ion valves

which receive a CVI signal be closed. This was verified to be

accomplished v'a Clearance No. 1-87-0256.

(7) Maintenance Activities (62703) - The inspector observed

maintenance activities to veri fy that correct equipment

clearances were in effect; work requests and fire prevention

work permits, as required, were issued and being followed;

quality control personnel were available for inspect 1"n

activities as required; retesting and return - of systems to

service was prompt and correct; and TS requirements were being

,

followed. Maintenance backlog was reviewed. Maintenance was

-

observed and work packages were reviewed for the following

maintenance activities:

-

Reactor Assembly Including the Integrated Head Package Lift

and 0-Ring Installation

-

Diesel Generator Train "A" Turbocharger Intercooler Inlet

Adapter Crack In Weld At Inlet Flange to Adapter Repair,

DR #1-87-0172

.

-

Penetration No. 1040D Containment Spray Suction Line-

Removal of Incorrect Sealant Material, Maintenance Work

Order (MWO) #18702408

-

Penetration No. 1752 Auxiliary Component Cooling Water

Supply to Containment-Removal of Incorrect Sealant

Material, MWO #18702408

t

.- , - ~ - - -- _,, m. m .-. ,- , -y.---

, a

9

-

Diesel Generator 1A Dutage MW0s and Clearances. MWO

Nos. 18624489, 18702068, 18702107, 18701520, 18701851,

1871826, 18701825, 18702556, 18701681, 18701166, 18700990,

18702575, 18702435, 18701188, 18700829, and 1862597.

Clearance Nos. 187446, 1870579 and 1870235

-

MSIV Testing, Trouble Shooting and -Stroking Per MWO

No. 18702863

-

Repacking of PORV Block Valves 1 HV 8000 A&B Per MWO

18702953

(8) Cold Weather Preparations (71714) - The inspector reviewed

implementation of the cold weather preparation program.

Maintenance and engineering activities were reviewed to ensure

that proper equipment and sensitive systems had been identified.

Operational activities implemented when cold weather is pending

(temperatures less than 40 degrees F) were reviewed. The Safety

Evaluation Report, Section 7.5.2.6 and FSAR Question 420.11 were

reviewed as they pertain to area of freeze protection.

Operations Procedure N877-1, Cold Weather Checklist, Rev 0 was

reviewed. During interviews the inspector determined that OP 11877-1 had received no input from engineering. Engineering

stated that the procedure would be reviewed. This item will

receive future routine inspection next winter and no IFIs are

identified to track engineering's review.

(9) Plant Startup from Refueling (71711) - The inspector observed

the preparations for initial unit startup. Initial Reactor

Criticality was witnessed. The inspector noted that the startup

was conducted in a professional manner.

(10) Initial Fuel Loading Witnessing Units 1 (77574) - The inspector

conducted periodic inspections throughout the inspection period

of the initial core loading process. The inspection consisted

of, but was not limited to, the observation of work activities

to verify the following:

-

Licensee was conforming with all technical specification

requirements and license conditions applicable during

initial fuel loading.

-

Nuclear instruments were properly calibrated and were

operating with a . measurable count rate.

-

Operation staffing for licensed operators were in

accordance with the requirements of technical

specifications.

1

-

Inverse multiplication plots were being maintained in

accordance with procedural requirements.

l

l

!

. . . , , . ,. - -

. - . - . . . . . - - . . .

.. . . . - . , .

- -s

! ..,-  ?.

]-

' 10

.i .

i-

>

--

Boron concentration was being . verified by proper sampling

I .

and analysis at'the ' required frequency.

j -

' Refueling status boards in .the control room- and on the -

' refueling floor were maintained properly.

I -

Shift work schedules were within maximum' work time limits. +

i'

-

-Initial . fuel loading experienced .~ delays which were mainly

1'- attributable to problems with the sigma refueling machine and-

i nuclear instrumentation. ' As problems occurred,- the licensee was - -

observed taking' the conservative- approach' to- ensure

j- identification of the root cause, thereby achieving the proper

corrective action prior to. resuming with initial- fuel loading.

l Once problems -were corrected 'and operations personnel became '

more familiar with the equipment, fuel loading was observed. by

>

the inspector to progress in an efficient and safe-manner as

j covered.by applicable procedures.

!

) (11) Problem Identification System' Review-- The inspector conducted a

,

review of the licensee's' Deficiency Reporting (DR) and Recording

4

of Limiting Conditions for Operations'(LCOs) to verify

implementation per the following procedures

j 00150-C Deficiency Reports

10008-C Recording LCOs

i 11875-C LC0 Status Sheet

11876-C LCO Status Log

i

The inspector selected and' reviewed the following DRs to verify

j t. roper completion and evaluation for LCO reqairements.

Deficiency Report LCO (If' Applicable)

i .

[ 1-87~0521

-

8

1-87-0522

j'- 1-87-0523

1-87-0524

'

i

! 1-87-0525 1-87-218I ,

! 1-87-0526

i 1-87-0527 -

1-87-0528

1 1-87-0529 1-87-221I

!- 1-87-0530 1-87-217I

1-87-0531' '1-87-222I

j~ 1-87-0532 1-87-2251

1- 1-87-0533 1-87-220I I

i 1-87-0534 1-87-35 l

j 1-87-0535 '

i 1-87-0536 1-87-224I l

i

~l

j, '

l

,

i

-_, , ,, .2..-_-_ -- .,..r-- ..,..,-m,.

-

._ L,-,.,m.._,_-r.., .,,,m.~...,., , _ , , - . . , ,,,.e _  %, .--4

_ _ _ _ _ ._. _ _. _ __

, .-

11

1-87-0537 1-87-223I

1-87-0538 1-87-227I

1-87-0539

1-87-0540 1-87-2281

1-87-0541

1-87-0542

1-87-0543

1-87-0544

1-87-0545

1-87-0546

1-87-0547

1-87-0548

1-87-0549

1-87-0550

1-87-0551 1-87-236I

' 1-87-0552

1-87-0553

i 1-87-0554

1-87-0555

1-87-0556 1-87-209

1-87-0557 1-87-210

,

1-87-0558 1-87-2371

1-87-0559

1-87-0560

1-87-0561

1-87-0562

During the above review, the inspector noted inconsistencies in

the method of completing the technical specification LCO

required action section of the DR. This matter was discussed

with the licensee and a night order was written to clarify to -

operations personnel the proper method for completing this

section of the DR. Another matter identified to the licensee as

a result of this review was the backlog of open DRs. At the

time of the inspection, there existed approximately 760 DRs of

which only 10-12 were closed. The licensee informed the i

inspector that additional resources would be applied in this

area to reduce the backlog. The licensee also informed the

inspector of a major change which was being implemented to the

Deficiency Report procedure. Discussions were held with the

procedure writer to review these changes. The new deficiency

report procedure will be reviewed in depth during subsequent

3

inspections to verify implementation.

(12) Post-LOCA Containment Hydrogen Purge System Design and

<

Operational Review - The inspector conducted a review of- the

'

following documents to verify that. the post-LOCA containment

hydrogen purge system will function as designed and in

accordance with existing plant procedures.

,

, a

12  :

1

-

Document Title

FSAR 6.2.5 CombustibleGaspontrolinContainment

OP 19000-1 E-0 Reactor Trip or Safety Injection

OP'19200-1 F-0 Critical Safety Function Status

1 Tree

OP 19251-1 FR-2.1 Response to High Containment

Pressure

OP 13130-1 Post-Accident Hydrogen Control

P&ID 1X408213-1 Purifica. tion and Cleanup System

P&ID 1X6AA02-232-12 Functional Diagram Safeguard Actuation

System

P&ID IX6A-X01-409 -Solid State Protection System

Elementary

P&ID 1X3D-86-804A & Post-LOCA Purge Isolation Valves

P&ID 1X3D-86-B04B 1HV-2624A & B Elementary

The post-LOCA containment hydrogen purge system is provided as a

backup means of controlling hydrogen inside containment. It

provides a means of purging the hydrogen from the containment

and is intended as a backup to the hydrogen recombiner system.

The inspection consisted of a review of the post-LOCA purge

isolation valve elementary diagrams, . the safeguard activation

system logic and the SSPS elementary diagrams to verify that

1

these valves could be opened when the procedure directed the

operator to open them. The inspector noted that procedure

13130-1 directs the operator to reset Containment Ventilation

Isolation (CVI) and then to open the post-LOCA purge isolation

!. valves if containment hydrogen concentration can not be

maintained below 4% by other means. Review of the safeguard

actuation system logic diagram details indicate that the CVI

reset logic as consisting of a retentive memory with actuation

block (i.e., CVI can be reset with a high radiation signal still

present). However, review of the Solid State Protective System

(S.iPS) logic per the elementary diagram shows that the high-

radiation signal must be cleared before a reset could occur.

Discussion with operations personnel revealed that they were

instructed and trained that CVI could be reset with a high l

!

l

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

, *

1

13

radiation signal still present. Discussions with engineering

and preoperational test personnel including Westinghouse confirm

that CVI can not be reset with a high radiation signal still

present. CVI is initiated by containment radiation area low

range monitors (RE-0002 and RE-0003) and containment ventilation

monitors (RE-2565 A, B and C).

During an accident condition, CVI will be initiated. Therefore,

in order to open the post-LOCA purge isolation valves during an

accident condition, CVI will have to be reset with a high

radiation signal still present. Pending the licensee's

engineering department review of this matter, this item will

remain open and will be identified as Inspector Followup Item

50-424/87-12-07, " Review licensee's investigation results of CVI

reset capability for containment post-LOCA purge isolation

valves."

5. General Construction Inspection - Unit 2 (92706)

Periodic random surveillance inspections were made throughout this

reporting period in the form of general type inspections in different

areas of both 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 in noncompliance with the required codes and regulatory

requirements. On these inspections, particular note was made of the

presence of quality control inspectors, supervisors, and Quality Control

evidence in the form of available process sheets, drawings, material

identification, material protection, performance of tests, and

housekeeping. Interviews were conducted with craft personnel,

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

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

No violations or deviations were identified.

6. Fire Prevention / Protection and Housekeeping Measures - Unit 2(42051C)

The inspector observed fire prevention / protection measures throughout the

inspection period. Welders were using welding permits with fire watches

and extinguishers. Fire f'ghting equipment was in its designated areas

throughout the plant.

The inspector reviewed and examined portions of 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.

• L ,

i

14

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 were 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 with extinguisher was posted as required.

-

Fire protection / suppression equipment was provided and controlled in

accordance with applicable requirements.

No violations or deviations were identified.

7. Structural Concrete - Unit 2 (47053C)

a. Procedure and Document Review

The inspector reviewed and examined portions of the - following

procedures pertaining to the placement of concrete to dete mine

whether they comply with applicable codes, standards, NRC r.ogelatory

Guides and licensee commitments.

-

CD-T-02, " Concrete Quality Control"

-

CD-T-06, "Rebar and Cadweld Quality Control"

-

CD-T-07, " Embed Installation and Inspection"

b. Installation Activities

The inspector witnessed portions of the concrete placement indicated

below to verify tne 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.

!

_ _ ._ _ __ _

. - _ _ .

a

,

15

(2) Delivery, Placement and Curing

-

Preplacement inspection was completed and approved prior to

placement utilizing a Pour Card.

-

Construction joints were prepared as specified.

-

Proper mix was specified and delivered.

-

Temperature control cf 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.

-

Adequate crew, equipment and techniques were utilized.

-

Inspections during placements were conducted effectively by

a sufficient number of qualified personnel.

-

Curing methods and temperature was monitored.

(3) Rebar Splicing

The inspector witnessed cadwelding operations to ver'.fy the

following:

-

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 ont, 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.

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

.- __ _ _ - .

.

16

-

The sequential number and the operator's symbol are marked

on all completed cadwelds.

No violations or deviations were identified.

8. Containment (Steel Structures and Supports)-- Unit 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.

9. Safety-Related Structures (Structural Steel and Supports) -

Unit 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:

-

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.

10. Reactor Coolant Pressure Boundary and Safety Related Piping - Unit 2

(49053C,49063C,37301)

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:

-

w

-._

.

17

-

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 clearances 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.

11. Reactor Coolant Pressure Boundary and Safety Related Piping Welding -

Unit 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 signoffs.

-

Welding procedures, detailed drawings and instructions, were readily

available in the immediate work area and technically adequate for the

welds being made.

'-

Wolding 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

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.

=

.

18

-

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.

-

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.

12. Reactor Vessel, Integrated Head Package, and Internals - Unit 2 (50053C

and 50063C)

The inspection consisted of examinations of the reactor vessel installed

in containment, the reactor vessel head with the installed control od

drive mechanisms that are located on the refueling floor, and the upper

internals in their designated laydown area. Inspections also determined

that proper storage protection practices were in place and that entry of

foreign objects and debris was prevented.

No violations or deviations were identified.

13. Safety Related Components - Unit 2 (50073C)

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

protection; installation; and preventive maintenance after installation of

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

accordance with applicable codes, NRC Regulatory Guides, and licensee

commitments.

During the inspection the below listed areas were inspected at various

times during the inspection period to verify the following as applicable:

-

Storage, environment, and protection of components were in accordance

with manufacturer's instructions and/or established procedures.

'

.

19

-

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 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

-

Nuclear Grade Piping, Valves & Fittings Storage Areas

_ _ _ - _ _ _

.

.

20

-

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.

14. Safety Related Pipe Support and Restraint Systems - Unit 2 (50090C)

Periodic random inspections were conducted during the inspection period to

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:

-

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.

,

_. ,_

_ _ _ . . _ _

'

.

21

15. Electrical and Instrumentation Components and Systems - Unit 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

terminating 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.), tightness of connection

-

Bending radius not exceeded

-

Cable entry to terminal point

-

Separation

No violations or deviations were identified.

<

16. Electrical and Instrumentation Cables and Terminations - Unit 2 (51063C,

52063C)

a. Raceway / Cable Installation

The inspector reviewed and examined portions of the following

procedures pertaining to raceway / cable ins.allation to determine

whether they comply with applicable codes, NRC Regulatory Guides and

licensee commitments.

-

ED-T-02, " Raceway Installation" l

-

ED-T-07, " Cable Installation"  !

-

.

22

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:

-

Protection from adjacent construction activities (welding, etc.)

-

Coiled cable ends properly secured

-

Non-terminated cable ends taped

-

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

-

Conduit capped, if no cable installed

-

Cable supported

-

Bend radius not exceeded

-

Separation

b. Cable Terminations

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, " 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 j

-

Bending radius not exceeded  ;

-

Cable entry to terminal point l

-

Separation l

No violations or deviations were identified. l

17. Containment and Safety Related Structural Steel Welding - Unit 2 (55053C, I

55063C)

Periodic inspections were conducted during daily plant surveillances on

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

.

'

23

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 and records were in place.

No violations or deviations were identified.

- - - - - . . _ .

. \

24 l

!

18. Followup on Previous Inspection Items - Units 1 & 2 (92701)

a. (Closed) IFI 50-424/85-21-02, " Review Revision to Class IE Battery

Maintenance Procedures". The items identified in NRC Report

50-424/86-111 have been resolved.

b. (Closed) IFI 50-424/86-51-02, " Review Procedure 00301-C to Verify

Incorporation of Unfettered Access for NRC Resident Inspectors." The

inspector reviewed Revision 2, issued February 24, 1987, which

implements the final corrective action. The inspector also noted the

deletion in Step 3.1 that had previously clarified that Control Room

Access under emergency conditions would be limited, but included NRC

inspectors needed for emergencies. The inspector ascertained that

the new revision further clarifies who the inspectors would be and in

the event of an actual emergency additional personnel could be

readily authorized,

c. (Closed) Unresolved Item 50-424/86-111-01, " Review Inspection Results

of the Licensee's Inspection of Burn Damage on Limitorque Operator

Power Leads." This item was previously closed in NRC Report

50-424/86-136. Since that time the licensee has had an opportunity

to inspect the four operators contained within the encapsulation

vessels. The inspection results indicate that no burn damage to the

motor leads was identified. These results were reviewed by the

inspector.

d. (Closed) IFI 50-424/86-60-06, " Review the Establishment of a Plan to

Collect and Evaluate Transient or Operational Cycles". The inspector

reviewed Procedure 50040-C, Rev. O, January 10, 1987, " Component

Cyclic or Transient Limits". This procedure is intended to provide

the means to track the number of design transients which occur during

plant life. The procedure tracks these cycles which are identified

in the plant's Technical Specifications only. Since the procedure is

an engineering procedure it relies on other plant procedures for

notification that a cycle has occurred. The inspector reviewed the

record keeping and had discussions with the responsible engineer.

From this review the inspector determined that the established

program was not adequate in that:

(1) No full definition of what constitutes a cycle other than

presented in Technical Specification existed.

(2) The systems structures, or components of concern were not

identified to support a proper evaluation of when a cycle had

occurred.

(3) No method existed for partial cycle counting.

(4) Notification to engineering was not established within all

referenced procedures.

.

'

25

(5) Cycle collection and evaluation on equipment that is not in the

Technical Specification had not been established.

(6) Not all cycles placed on the plant from Hot Functional Test to

present had been counted. ,

This issue was originally identified by the licensee during the

readiness review program for Module 7. At that time it was

identified as Finding #7-4 Data Collection. During NRC review of

Module 7 this IFI was identified because the project did not address

the subject of establishing a plan -or program to collect the data

<

(NRC Report 50-424/86-60 dated September 4, 1986). The Operations

,

Quality Assurance organization performed additional reviews, and had

,

closed the issue based on issuance of the program. It was noted that

QA had intentions of performing an audit in April after the program

had time to function. Based on the discussion above and Item (1)

a thru (6) the following violation is identified:

I

50-424/87-12-02, " Failure to Establish an Adequate Program for the

Collection and Evaluation of Transient or Operating Cycles".

e. (0 pen) 50-424/86-117-31 " Verification of Key Control and Access to

Plant Equipment By Operations Staff". This item consists of two (2)

commitments by the licensee pertaining to the control of Power Block

interior doors and the control of panel / cabinet keys. The inspector

conducted a review of the licensee's program to control panel keys

throughout the plant. The inspection consisted of: 1) Reviewing the

revised plant lock and key control procedure (00008-C, Rev. 5) which

establishes the method for controlling panel keys and the requirement

for auditing the program at least once per year, 2) Reviewing the

panel key index which categorizes the cabinet keys by building and

elevation, 3) Verifying that a representative ' sample of keys on the

panel key index did in fact open their respective panel or cabinet,

,

'

and 4) Confirming that the program was understood and being

implemented with satisfactory results by interviews of operators.

Based on the above inspection the inspector has determined that the

licensee has satisfactorily addressed the control of panel / cabinet

keys. This item will, however, remain open pending the licensee's

completion and the inspector's review of the commitment pertaining to

the control of Power Block interior doors.

19. Followup of Reportable Items - Units 1 & 2 (92700)(36100)

This inspection was conducted to determine whether the items have been

i

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

appropriate. The inspector utilized discussions with cognizant personnel,

review of applicable documentation, and field verification as a basis for-

closure of each item.

- , - - , - - . -- - - ,_. . - , - - -

.

26

a. (Closed) 50-424/425 P2185-07 " Potential Valve Spring Failure In TDI

Diesel Engines." This item is identical to 50-424/425 CDR 86-94 and

is closed to eliminate dual tracking. It is noted that 50-424 CDR

86-94 was closed in NRC Report 50-424/86-103.

b. (Closed) 50-424/425 P2185-08, " Crack in Cast Iron Fan Hub". This

item is identical to 50-424/425 CDR 86-96 and is closed to eliminate

dual tracking. It is noted that CDR 86-96 was closed in NRC Reports

50-424/86-120 and 50-425/86-56.

c. (Closed) 50-424/425 P2186-02/P2186-05 "GE Type NGA15AG3 Relays

Incorrectly Wired." This item is identical to 50-424/425 CDR 86-123.

It is noted that 50-424 CDR 86-123 was closed in NRC Report

50-424/86-123.

d. (0 pen) 50-424/425 P2186-03, "BBC Brown Boveri K600/K800 Circuit

i

Breakers Wire Harness". This item as addressed in a Brown Boveri

letter to NRC dated June 30, 1986, concerns a defect where an

'

improperly secured wire harness could be cut by the racking gear.

The licensee informed the inspector that they have completed

l inspections and are currently assembling a complete package to assess

further reportability. The inspector will review the final package

when assembled.

i

e. (Closed) 50-424/425 P2186-04, "3050 Diaphragm Valves By Dresser".

This item is identical to 50-424/425 CDR 86-91. While verifying this

item the inspection noted that the CDR addressed 3/4" to 2" valves

where the P21 addressed 1/4" to 2". The licensee reaffirmed that the

CDR was correct by confirming that the site does not use 1/4" and

1/2" valves. It is noted that CDR 86-91 was closed in NRC Reports

50-424/87-05 and 50-425/87-05,

f. (0pened) 50-424/425 P2186-06, "Transamerica Delaval, Inc. (TDI) Time

Delay Relays". On October 1, 1986, Sacramento Municipal Utility

District reported deficiencies with Syracuse Electronic time delay

relays, Model TER-03803NL. Attachment 1 to the letter suggested that

Vogtle, as part of the TDI owner's group, may have these relays. The

licensee was provided a copy of the letter and was requested to

address the applicability of the letter for Vogtle.

g. (0pened) 50-424/425 P2186-07, " Insufficient Design Margin in Brown

Boveri Ground Detector Relays". On November 7, 1986, Brown Bovert

informed the NRC of a condition where the ITE 278 relays could fail

'

to detect a DC negative bus ground and upon receiving a positive bus

ground a short circuit of the batteries without an alarm signal could

result. This condition occurs with Catalog No. 239G0045 relays

(Note: see P21 86-08 below). The Bechtel evaluation concluded this

to not be reportable based on the fact that a single ground with

i

l

.

'

27

relay failure would not fault the DC bus. The inspector informed the

licensee that this evaluation did not address the two grounded bus

configurations as a result of not detecting the first ground and what

failure would occur to the 125 VDC bus. The licensee clarified the

evaluation with the inspector. The interim corrective action by the

vendor is to set the sensitivity dial to the 10 o' clock position.

The evaluation indicates that at Vogtle this may be the normal

setting and no further modifications are necessary. Pending final

clarification by the licensee of modification planned and/or the

assurance that these relays are properly set in the future this item

will remain open.

h. (Closed) 50-424/425 P2186-08, "Overstressed Circuits in Brown Boveri

Ground Detector Relays". On January 5, 1984, and as an attachment to

a November 7,1986 letter, Brown Boveri informed the NRC of a

condition where ITE 27B relays could be placed in a condition where

two grounds could be indicated by the relays and depending on how

this output is utilized may affect the plant. A review of the

Bechtel evaluation in response to the November 7, 1986 letter

revealed that this deficiency pertained to Catalog No. 23900505

relays. The licensee has replaced this type relay on Unit I with

Catalog No. 239G0045 relays. Unit 2 relays will be installed under a

field equipment change order (FECO). The evaluation also states the

relays are utilized to only annunciate a grounded condition. Since

this is a fault where the presence of two grounds would be indicated

the failure is in the conservative direction. One IFI is identified

for Unit 2, IFI 50-425/87-08-01, " Review Implementation of FECO to

Change ITE 278 Relay to New Model Under MWO 2-87-0034, and MWO

2-87-0035".

20. Allegations - Units 1 & 2

a. Allegation, RII 86-A-0281, Concrete Voids in Aux. Bldg Wall.

Concern

During form removal from a "0" level Auxiliary Building wall,

concrete honeycombing was detected when the permanently installed

form bolts inadvertently pulled out of the wall.

Discussion

i

By letter dated December 8,1986, U.S. NRC Region II assigned the

subject allegation to Georgia Power Company for action and

disposition. A reply was received on December 30, 1986. The

inspector reviewed the reply and the related GPC Quality Concerns

File 86V0854 and notes that the licensee conducted an adequate

investigation into the subject allegation.

1

,

.

28

The alleger was concerned that the concrete voids (honeycombing) that

remained when the bolts were removed were not patched correctly. The

event took place in the time frame of 1980 - 1981 and the location

given was very general. A construction foreman and a QC Inspector

were located who seemed to remember the event. Both recalled that a

Deviation Report was written and the QC Inspector remembered that the

area was repaired correctly by pressure grouting (not dry-pack).

Construction Deficiency Report CD-1090 and CD-810 were located and

appear to address the situation correctly.

Conclusion

l

Based on the findings stated above and other details provided in

l Quality Concern 86V0854, this allegation is closed.

b. Allegation, RII 86-A-0315, Individuals Directed to Perform Work for

i

Which They Were Not Qualified.

Concern

l

Two electrical craftsmen stated that they were directed to perform

electrical instrumentation installation work for which they were not

qualified.

Discussion

By letter dated January 7, 1987, U.S. NRC Region II assigned the

subject allegation to Georgia Power Company for action and

disposition. A reply was received on January 21, 1987. The

inspector reviewed the reply, and the related GPC Quality Concern

File 86V0781, and determined that the licensee conducted an adequate

investigation into the subject allegation.

Two workers were instructed by their foreman to install some

instrumentation RTDs and associated straps. The workers notified

their foreman that they had not been trained and certified for that

particular type of work. There appears to have been some sort of

,

effort to have the workers perform the task under engineering

i

'

supervision. Fortunately the system corrected itself, the workers

did not perform the task, and were later sent to a training and

certification class. Verbal discussions were held with management

,

and it appears that this incident was an isolated case. Interviews j

l with other workers indicates that there are no other cases of workers l

l performing work for which they were not trained, i

l

Conclusion 1

The allegation is correct in that the men were initially instructed

to install instrumentation they were not certified to install. No

work was performed and the men were later sent through training and l

l

4

l

!

.

'

29

certified. Corrective action to prevent recurrence appears adequate,

and there is no evidence of any workers performing tasks they were

not certified and trained to perform. This allegation is considered

closed.

c. Allegation, RII 86-A-0272, Cooldown of Weld by Application of Watered

Rags.

Concern

A craft foreman states that he was directed by Supervision to

cooldown a weld with watered rags. This practice is in violation of

procedures.

Discussion

The inspector reviewed GPC Quality Concern 86V5010 for additional

detail, and notes that Deviation Report PPP 15521 was issued

reporting the improper water cooldown of a structural weld. Location

was C Level, Containment 1, Imbed Plate 314 to Beam 33, a 1-1/4

structural A36 material weld. Procedure GWS-111/1, paragraph 5.4

states that welds of this material may not be cooled in this manner.

The DR was dispositioned "use-as-is" by virtue of rationale provided

in a letter from the PPP Welding Engineer, stating in summation, that

for this type and size of weld, plus circumstances of application,

there was no deleterious effect to the weld structure or material.

An NDE exam was then performed that produced acceptable results. The

inspector also notes that the accused Superintendent and General

Foreman deny they ever gave direction to cool the weld with water.

Corrective action was completed by reinstructing management and

workers that welds are not to be cooled down by water or wet rags.

Further investigation has determined that there are no other known

examples of welds being cooled down improperly.

Conclusica

The allegation that the weld was cooled down with watered rags is

correct. Whether the Foreman was specifically directed to do so is

unknown. Corrective action to prevent recurrence appears adequate

and the specific weld has been adequately dispositioned by Deviation

Report. The inspector considers this allegation closed.

d. Allegation, RII 86-A-0327, Electrical Separation Violations.

Concern

An anonymous alleger identified that a spacial separation violation

existed with high voltage cables in four specific Train-A cable trays

on Level A Hallway 58 wall penetration in the Control Building.

l

1

'

.

)

30

Discussion

By letter dated January 1, 1987, U.S. NRC, Region II requested

Georgia Power act on the subject allegation. A reply was received on

January 12, 1987. The inspector reviewed Quality Concerns file

86V0774 and notes that the licensee conducted an adequate

investigation into the subject allegation. The review indicates that

Deviation Report (DR) 11054 identified three of the four problem

electrical cable trays in November 1985. A review revealed that the

DR did not address the concern directly and a misinterpretation

assumed that a "use-as-is" disposition applied to the cable

separation problem. In November 1986 an electrical walkdown

inspection was performed as a result of the allegation and an

on going scheduled Systems Completion program. DR ED15118 dated

11-17-86 was written detailing numerous electrical cable separation

problems including the four cable trays in the subject allegation.

Disposition was for physical correction of separation violations and

"use-as-is" dispositions where applicable. The inspector notes that

the corrective action appears to be adequate. Causal factors appear

to be human error, pulling cable over cable causing the lower layer

to move, and other craft physically working in the tray (penetration

sealers). Long term corrective action is: to be more aware and

careful during the Unit 2 installation phase, and for QC to report

the same problem more than once if necessary, and not wait for a

collective walkdown. The inspector notes that a major revision to

Procedure ED-T-02 has been issued that details very explicitly

electrical separation criteria for craft and inspection. The

inspector also notes that a recent Region II electrical inspection

did not disclose any electrical separation violations.

I

Conclusion

'

The allegation of specific electrical cable separation violations was

correct. GpC performed adequate immediate and long term corrective

action to prevent recurrence. The inspector considers this

allegation closed.

e. Allegation, RII-86-A-0235, Safety Violations in Regard to the Reactor

Vessel Level Instrumentation System (RVLIS) Testing.

Concerns

(1) The validity of a pressure test performed on June 13, 1986, was

questioned by the alleger due to its duration and the type of

M&TE used.

(2) Oil contaminated the system when a vacuum pump backed up. This

oil was noted on June 21, 1986, by a co worker of the alleger,

, (3) The alleger stated that a vacuum pump failed on September 16,

1986 and pulled oil into the RVLIS capillary tubes,

i

.

'

!

31

Discussion

This allegation had been submitted to the Georgia Power Company (GPC)

! Quality Concern Program (QCP) as well as to the NRC. The QCP is

! tracking items (1) and (2), above, as File Number 86V0543 and item

! (3) as File Number 86V0826. The inspector reviewed in detail the

I

results of the investigation and action taken as described in the QCP

l files. The files indicate that the QCP response to item (3) involved

l

interviews with various personnel. As a result it was determined

that no record exists which documents the failure of a vacuum pump,

l therefore this item was declared unsubstantiated by GPC. The

inspector could not locate any record of a vacuum pump being used on

the system in September of 1986.

Item (1) involved a pressure test run for forty-five (45) minutes

using a 0-5000 psig AMATEK gauge of one psi increments. It was

alleged that the amount of movement of the gauge needle would not be

enough to detect a pinhole leak. Item (2) involved several vacuum

pumps being used in the vacuum test portion of a Westinghouse

procedure. On several occasions these vacuum pumps were alternately

turned off and on inadvertently which permitted one vacuum pump to

,

possibly draw oil out of an idled pump. The files indicate that the

l pressure test was re performed and allowed to run for two hours, and

! that extensive flushing of the system, with chemical analysis was

performed. Personnel interviews verified that oil, or what appeared

to be oil, was discovered in parts of the system and that vacuum pump

operation was a problem. A DR was written and dispositioned properly

involving the oil in the system. The inspector reviewed Maintenance

Work Order (MWO) 18610118, which was used to facilitate filling and

venting of the RVLIS, and interviewed various GPC and Westinghouse

personnel. The MWO indicates that the filling and venting was

I performed in accordance with Westinghouse procedure SS-E-81-2,

l Revision 5 under the direction of Westinghouse engineers. Entries in

l the MWO starting from 6/27/86 to 7/4/86 document flushing part of the

RVLIS with toluene, acetone and demineralized water along with

chemical analysis to determine the amount of oil and total organic

carbon.

Conclusions

Based on the inspector's review, the events involved in items (1) and

(2) did occur; however, effective corrective action was taken by the

licensee and the contractor in that:

(1) The pressure test was re performed and allowed to run for two

(2) hours which would have indicated pinhole leaks; and

(2) The section of RVLIS was chemically cleaned and flushed

satisfactorily.

The inspector considers these two items closed,

i

l

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

.

'

32

(3) Based on the inspector's review, the events involved in Item 3

could not be confirmed or denied. No information was available.

Also involved in this concern was an allegation of wrongful

termination of a Westinghouse engineer, who was part of the fill and

vent team. The Department of Labor has this allegation under review.

l A determination of the circumstances of the dismissal was not made by

!

the inspector as part of this review.

f. Allegation, RII 85-A-0175-002, River Intake Structure Piping.

Concern

The alleger worked in the River Intake Structure and during this time

l observed the following:

(1) The QC Inspector assigned to the River Intake Structure Piping

Systems was not checking packing rings.

(2) While walking from the River Intake Structure to the plant he

noticed a large dent in a 48-inch Class III pipe located

approximately halfway between the plant and the structure. The

dent is near a section of pipe supported by a concrete saddle

block and a Dearman Alignment Joint Clamp.

Discussion

l The inspector toured the River Intake Structure both interior and

I exterior and at no time was any excessive water leakage observed. A

large pipe exits the south side of the structure and disappears

underground. The pipe is wrapped with a black type of material prior

to entering the ground and no large pipe was observed above ground

between the structure and the plant or the cooling towers. The

'

inspector reviewed Piping and Instrument Diagram (P&ID) AX4DB152-1

I " River Intake Structure" and noted that the system in question is

designated as #1402. The Vogtle Project designates all 1400 series

systems as Balance of Plant (BOP) non-safety related.

Conclusion

This allegation could not be confirmed or denied due to the fact that

all large pipe is buried and there are no large water leaks. It was

noted that the system is non-safety related. Based on this review

the inspector considers this item closed.

!

_ _ _ - __ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - - _ _

_ _ _ _ .

'

.

!

1

j 33 .

!

i

,

'

g. Allegation, RII 86-A-0274, Fusible Links Improperly Sized or Not

! Installed.

!

Concern

Fusible links were not installed - or they were improperly sized in

j HVAC systems at Vogtle. A Deviation Report identified the problem

l

but was not acted upon (dispositioned),

1

Discussion

On December 6,1985, QC Receiving Inspection identified that eight

HVAC fire dampers were received with incorrectly sized fusible links

! installed. Deviation Report (DR) CD8376 was initiated identifying

the problem. Action was taken to obtain the 370-degree F. fusible  !

! links from the vendor for installation in the Auxiliary Building  ;

l dampers. Installation was completed on Unit I but not in Unit 2 *

! until September 1986, at which time the DR was closed. QC Inspection

I verified both unit installations and signed-off the Deviation Report

I as complete and acceptable on 9-11-86. The inspector verified that

an additional confirmation of installation was performed by

]

engineering.

1

'

Conclusion i

The allegation was correct in that incorrectly sized fusible links 3

1 were installed in HVAC dampers. The inspector notes that QC detected

i the problem and proper corrective action was taken. The inspector

! notes that the delayed corrective action for Unit 2 (approximately 9 1

l months) more than likely led the alleger to believe no action was

taken on the Deviation Report. No improper hardware was installed in

l the plant as the licensee tock proper corrective action. Based on

the findings stated above and other details provided in Quality

i Concern 86V0852, this allegation is closed.

I

h. Allegation, RII-86-A-0275, Use of I&C Calibration Procedures, Testing

Procedures, Vendor Manuals and Drawings (Prints).

! Concern

l The concern was received by both GPC and Region II. The inspector

.

reviewed the allegation and placed the concerns in seven areas as

follows: ,

(1) Manuals for Fluid Components, Inc., Field Calibrator FC-81 and

Monitor Calibrator FM-71-0 were not controlled.  :

;

'

l (2) Post LOCA Purge Controller, Tag No.1-FC-2693, calibration was

j performed to an inadequate procedure.

) (3) Flow Valve FV-12777, no vendor manual available.

\

!

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

.

34

(4) Vendor Drawings (Prints) X4AJ15-57 and X4AJ15-80 are the same

with the exception of additional information.

(5) Retest of the damper for Fan A-1535-N2-2001-No. I after

maintenance performed on damper.

.

(6) Lack of calibration procedure for Love Controllers Model 54.

1

i (7) The six items above are examples of the I&C shop not following

'

procedures as required by the NRC.

Discussion

l

The inspector reviewed procedures, interviewed personnel and reviewed

records. The following are the results of the review of the

'

allegation:

(1) The inspector requested .ind received from Document Control Items

l VM-1023 and VM-1024. Item VM-1023 is a Fluid Components, Inc.,

l instruction manual for Monitor Calibrator FM-71-D and Item

VM-1024 is an instruction manual for Field Calibrator FC-81 by

the same company.

(2) The inspector reviewed Procedure No. 22220-C, " Fisher Model 4150

l and 4160 Series Wizard II Controller and Transmitter

l Calibration" and reviewed Maintenance Work Order (MWO) 18619221.

!

This review indicated that the procedure was revised and the MWO

i was written to calibrate 1-FC-2693.

1

(3) The inspector received from Document Control and reviewed Vendor

Drawing X4AJ15-57-3 which is a three-way view of a valve with

information concerning the valve.

!

'

(4) The inspector received from Document Control and reviewed Vendor

Drawings (Prints) X4AJ15-57 and X4AJ15-80. Both are of the same

subject - a view of a valve.

(5) The inspector received from document control and reviewed MWO

A8602808 which indicated work performed on Fan A-1535-N7-001-000

(a possible misprint on the part of the alleger when he

,

indicated A-1535-N2-2001-No. I as the fan damper in question).

l

(6) The inspector located generic calibration procedure, 23830-C,

that successfully calibrated Love Controller Model 54 (e.g.,

ITIC-12678),

i

(7) The inspector observed work in the I&C shop, reviewed procedures i

and interviewed various personnel. l

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

'

.

35

Conclusion

Based on the above activity the inspector found the following:

(1) The Vendor Instructions appear to be controlled and are

available from Document Control. Therefore, this part of the

allegation could not be confirmed as safety significant.

(2) The review of the calibration procedure and the MWO indicated

that the initial calibration procedure was inadequate.

Therefore, this part of the allegation is confirmed. The

inspector was informed that additional correctiu action is

required to document other areas where the inadequate procedure

was used. This item is identified as Inspector Followup Item

(IFI) 424/87-12-05, " Review Corrective Action Due to Use of

Inadequate Procedure No. 22220-C".

(3) The review of the Vendor Drawing indicated that it is a three-

way view of the valve and has adequate information. It is not

necessary that all vendor information be in the form of Manuals,

as long as the information supplied is sufficient to perform a

particular task. The Vendor Drawing provides the necessary

information. Therefore, this concern could not be confirmed as

sfety significant.

(4) The review of the Vendor Drawings indicated that they are for

the same type of valve. In this particular case having two

drawings of the same subject is not safety significant. The

inspector was informed that drawing 4AJ15-57 was deleted.

(5) The review of the MWO indicated work was performed on the fan

involving the replacement of bearings. The MWO did not indicate

any retesting as being required. The removal and reinstallation

of the damper / fans during this work should not have affected the

test, provided the mechanical linkage was not disturbed. The

inspector found no evidence that this occurred. Therefore, this

part of the allegation could not be confirmed.

(6) A generic procedure is provided by procedure 23830-C to .

calibrate Love Controller Model 54. This portion of the

allegation is closed,

i

(7) The inspector concluded that although some of the items

discussed by the alleger may have occurred, collectively they do

not represent a breakdown in following procedures by personnel 1

involved in I&C work.  ;

1

i

1

l

1

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

_. . . - _. __ _ . . . . _

f

'

.

'

'

36

,

I 1. Allegation, RII 86-A-0288, Termination for Reporting Concerns to ,

Quality Concerns Program. '

l

t

Concern

An alleger submitted the following concerns:

1

l (1) The wrong grease was used in the Turbine Building bridge crane

and magnatorque motors.

}

, (2) A management letter was issued deleting the requirement to

l

tighten screws on electrical terminations,

i

j (3) Maintenance of Unit 2 Containment Polar Crane is past due. ,

l (4) Termination was due to reporting concern to GPC Quality Concern

i group.

Discussion

! By letter dated December 8, 1986, U.S. NRC Region II requested

! Georgia Power to act on the subject allegations. A reply was

received on December 30, 1986. The inspector reviewed Quality

! Concerns files 86V0855, 86V0665, 86V00485, 86V0627, and 86V0705 and

< notes that the licensee conducted an adequate investigation into the

l

subject allegations.

! Inspector reviews indicate that the wrong grease was used on a small

number of motors and magnatorques in the Turbine Building. The i

problem was detected and isolated to one individual and proper

corrective action was taken. The motors were purged, correct

greasing occurred, and the electrician involved, as well as others, l

!

was counseled. Action was appropriate.  !

'

The second allegation was also correct in that a memorandum was

issued from management directing that the regular maintenance

procedure requirement to check tightness of all termination screws on 1

the Unit 2 Polar Crane be deleted. The memo had well-meaning i

intentions but was incorrect. Corrective action was timely and  ;

appropriate. The memo was rescinded, all personnel were counseled,

'

,

! and all the Polar Crane electrical terminations were tightened. [

There were no other examples of procedure deviations, past or

f present.

!

! The allegation of past due maintenance was not substantiated. Review 1

of records by GPC indicates that the only change in the maintenance

schedule was a change of shif ts in order that overtime would not be

4

expended for the maintenance effort. A review indicates that this

j allegation was passed on second-hand from a previous allegation  ;

j closed out by Quality Concerns. No corrective action was required.

I i

-

1

i

i

.

'

l

37

l

l

l

l

l The inspector reviewed all interviews, testimony and records in

l regard to the allegation of retaliation for submitting a Quality

l Concern. The inspector notes that the subject allegation was

, submitted anonymously and that there is no indication or proof that

l any of the associated personnel knew of the person's involvement with

the concern until after his dismissal. The reasons for the alleger's

dismissal was for a litany of work rule violations that are well

l documented. The allegation is unfounded.

l '

Conclusion

As previously discussed, action was appropriate on all subject

i

allegations. The basic allegation of retaliation was unfounded.

Based on the aforementioned discussions, the subject allegations are

considered closed.

J. Allegation, RII 85-A-0186 Concerning Improper Design Practicos.

Concern

An alleger stated the following concerns:

(1) Incorrect welding material and the wrong type of welds were used

on containment spray hangers.

(2) There is a lessening of verification / validation in the area of

analysis because independent review responsibilities have been

relinquished by Bechtel.

(3) In some instances where valves have "Q" rated piping on one side

and non "Q" on the other side, the anchors holding the valve

support may not be rated "Q" and the analysis may not have Deen

performed properly.

(4) Engineering associated with a specific hanger may be faulty.

(5) Small dimension anchors which should have been hot formed, were

actually cold formed and may not be suitable for their intended

engineering purpose.

(6) Bolting material may be a problem in that high Strength

structural bolts were used with improper engineering

application. Bergen-Patterson clamps are not intended to

restrain more than two degrees of freedom but have been used in

applications where they will have to restrain more than six

degrees of freedoin.

This allegation was officially transmitted to Georgia Power Company

(GPC) by the NRC for review and appropriate action in a letter dated

January 9, 1987. The GPC response to the allegation is documented in

!

!

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

l

'

.

38

a letter to the NRC Region II, dated January 12, 1987. In their

response, GPC addresses each of the alleger's concerns and found five

to be unwarranted and the other identified only minor problems of

which no corrective action was required.

The following are the results of the inspector's review for each

concern: ,

(1) Engineering performed a preliminary review of the as-built

information for containment spray hangers in late 1985. That l

review determined that additional information was required

regarding weld configuration and clearances on the hangers.

This additional information was obtained in subsequent as-built

inspections. The existing information regarding as-built

containment spray hangers was then evaluated and reconciled

under the Final Design Verification program for safety-related

systems.

The weld material for the containment spray hangers was

determined to be in accordance with project requirements.

Quality Control inspects the welds, Quality Assurance audits the

welding process and Engineering provides as-built walkdowns.

The inspector was unable to find any open or unresolved

deviation reports or other issues regarding welding material or ,

containment spray hanger welds. ,

(2) The ANSI Standard (N45.2.11) and the standard industry practice 1

require that all safety-related design documents be authored by

a qualified individual and be verified by a second qualified i

individual independent of the author. Based on the inspector's

review, this requirement has been met continuously. In

addition, the change in arrangements between GPC and Bechtel and

between GPC and Westinghouse was identified to the NRC by

Amendment 18 (August 1985) to the FSAR Section 17A.1.8. ,

!

(3) Valves are frequently used to serve as the pressure retaining

boundary between "Q" and non "Q" piping and are supported by  !

anchors / supports. The design criteria for both "Q" and non "Q" '

anchors / supports is identical for these cases. Bechtel Design "

.

Manual DC-1017, requires that "Non-Q" anchors meet the same

design stress allowables as required for "Q" anchors. .

1

'

(4) This hanger / support was originally designed in the early 1980s,

was initially revised for installation on December 18, 1984, and

again on September 19, 1985, and was subsequently installed on

December 16, 1985. During each of these changes, the support  !

calculations were independently verified in accordance with

project procedures and two additional independent reviews were >

conducted during the Final Design Verification program. '

However, when the most recent calculation of record was reviewed

on January 9,1987, by an independent engineering group, minor .

1

'

.

39

dimensional errors were identified in the analysis model. The

engineering group lead engineer concluded by independent review

that the support is structurally sound and that the calculated

stresses are acceptable with respect to all project design

allowable stresses.

(5) From the description of the concern it was concluded that the

anchors in question are the part No. 51 anchor straps. The

anchor strap is a vendor fabricated pipe support component for

I

pipe sizes of 2 inches through 6 inches in diameter. Project

specification X4AQ01 defines that the contractor will fabricate

and supply components to the Alvin W. Vogtle Nuclear Power Plant

l

in accordance with the code. The applicable code of record for

l the project states that any process may be used to hot or cold

form or bend materials, provided impact material properties are

l

not reduced below minimum specified values. It is considered

l

the vendor's option as to the fabrication process used to form

! the anchor strap, provided compliance with applicable code

sections is maintained. Anchor straps are QC inspected at the

Vogtle site for rr.inimum thickness and fit-up gap between the

pipe and the strap. Inspections of some anchor straps noted

some excessive brake press indentations. The deficiencies were

documented at the time of inspection per project deviation

reports. The deviation reports were processed by the contractor

and forwarded to Engineering for evaluation. The deviation

reports were closed with "use as is", " repair" or " rework"

dispositions. A "use as is" or " repair" disposition has an

Engineering justification documented in the applicable pipe

support calculation.

(6) In order to obtain the required two or three directions of

support for small vent lines which branch off of larger process

piping, it is of ten necessary to support the small vent lines

directly fro'n the larger pipe to assure that both lines move

together thermally and that the vent line connection to the

process pipe is not overstressed. The structural attachment to

the process pipe must be capable of being a fixed point for

restraining all six degrees of freedom. To obtain this

capability, pipe clamps were bolted around the process pipe.

Unique calculations were performed for each clamp demonstrating

acceptability of the clamp for its intended design application

and no standard com>onent vendor capacity value was used for

these special applications. High strength bolts were

substituted for those supplied by the vendor to obtain the

required torque value and the clamp material was tested to

l

verify that the material would not yield at the required torque

l

values,

i

l

i

l

1

l I

E -----_--_

l

.

'

l

!

40

l

l

Conclusion

Based on the inspectors detailed review of each aforementioned

concern interviews with the appropriate managers of the involved

organizations, review of applicable documents, and review of the GPC

response, this item is closed,

k. Allegation, RII 86-A-0285, Discrepant Conditions Not Identified on

Operations Discrepancy Report (00R).

Concern

Loose wire terminations were detected on Safety Related Vendor

supplied relay panels. Preliminary Maintenance Work Orders (MWO)

were written to rework the terminals. Conditions identified on MW0s

should have been identified on an ODR in order to address appropriate

root cause and corrective action to prevent recurrence.

Discussion

By letter dated January 2, 1987 U.S. NRC, Region II requested

Georgia Power to act on the subject allegation. A reply was received

on January 23, 1987. The inspector reviewed Quality concerns file

87V0003 and notes that the licensee conducted an adequate

investigation into the subject allegation.

The allegation was correct in that an ODR was not written in

accordance with procedures SUM 18 and 22. Paragraph 6.1.2 (SUM 18)

states, in part, that an ODR is required if there is a condition

adverse to quality. As a result of the allegation ODRs were written

and corrective action to prevent recurrence was taken. All Unit 1

and 2 Auxiliary panels from Reliance Corp. were inspected and the

loose wires tightened. Causal factors were reviewed and isolated.

Test engineers and supervisors were counseled verbally and by memo to

insure retightening of terminations during preop testing; and

reminded of the requirements to document deficiencies por procedure.

Conclusion

The allegation was correct. The loose terminations should have been

recorded on Operation Deficiency Reports. The discrepancy does not

appear to be widespread. No other examples were found. As a result

of the allegation, prompt and adequate corrective action was

accomplished by GPC Quality Concerns. Based on the foregoing, the

inspector considers this allegation closed,

l

r'

l

l

.

41

1. Allegation, RII 86-A-0216, Improper Installations of Pipe Insulation.

Concerns

An alleger submitted the following concerns having to do with pipe

insulation:

(1) Insulation was installed over unclean pipe.

(2) Insulation bands were installed incorrectly on main steam

piping.

(3) Insulation was installed using mastic rather than fiberglass

cloth.

(4) Tape was used in lieu of wire for insulation installation on

pipe elbows.

Discussion

The inspector reviewed GPC Quality Concerns files: 86V0283, 86V0284,

86V0299, 86V0316, 86V0360, 86V0369, 86V0413, 86V0429, 86V0430,

86V0480, and 86V0666. The subject allegations were addressed in

these files as were many other allegations. The inspector noted that

the licensee conducted adequate investigations into the allegations.

The inspector's review indicated that there were no areas of unclean

pipe detected. Specific areas pointed out by the alleger, as well as

nearby areas, were reinspected and swiped. No visible or chemical

unclean areas were present. A walkdown inspection was performed on

the questionable areas of the main steam piping. Insulation bands

were installed with the correct spacing (e.g., maximum of 12").

Collars and bridles were correctly installed on vt.1ves. In regards

to the use of mastic directly on pipe surfaces, the inspector noted

that specification X4AP01 requires mastic installation in open

joints.

Mastic is an approved insulator, and sir.ce no vapor barrier was

required'for the specific area involved, a fiberglass cloth

installation was not necessary. The inspector reviewed licensee

action on the allegation of tape being used in lieu of wire for

insulation installation. Specification allows the use of tape as an

installation aid, but not for permanent installation. Areas

designated by the alleger, as well as surrounding areas, were

inspected. Only those isolated areas pointed out by the alleger had

tape still installed. Investigation determined that material

compatibility was acceptable. The incident appeared to be isolated,

but widespread acceptable corrective action was taken.

.__ _ -_ .. ~. . . _ _ . _ ._ _ __

<

. '

42  :

Conclusion

The inspector noted that proper carrective action was taken where  ;

appropriate. Based on aforementioned discussion, this allegation i

(86-A-0216) is considered closed, i

m. Allegation, RII 87-A-0018, Miscellaneous Electrical and

Instrumentation Concerns.  ;

Concern

An anonymous allegation made to NRC on January 23, 1987, was

transmitted to the licensee by NRC letter dated February 10, 1987.

The concerns were:

(1) 6" electrical separation criteria at the field cable and

internal wire junction of data module cabinet IRE 003 was not

satisfied.

,

(2) Non-safety communication equipment (e.g., pager phones) was [

installed in the Train "A" safety related wireways. Also some

non-safety fire protection wiring may have been added to the

Main Control Board (MCB).  ;

(3) Hydrostatic test for a reactor vessel leak-off line used an

improperly calibrated gauge; and resulted in a failure to i

satisfy the hydro pressure requirements.

(4) Unit 1 Plant Effluent Radiation Monitoring System (PERMS) module

1. ARE2532 that was located in Unit 2 was neither controlled nor -

protected. L

!

Discussion

!

The Itcensee responded on March 2, 1987, to NRC letter dated

February 10, 1987, to address the subject allegations. The licensee  ;

quality concerns file for these concerns was 87V0059. As of March 6,  ;

1987, none of these concerns have been formally closed by the f

Itcensee, because of the final reviews required. The results of this -

allegation review were i

(1) The failure of satisfying a 6" electrical separation criteria at i

i

the field cable and internal wire junction of data module

cabinet 1RE003 was substantiated by the Itcensee and resulted in l

l Deficiency Card (DC) 1-87-743. The separation problem occurred t

when an incorrect knock-out was used for the routing of a l

non-safety related communication control room link through l

cabinet 1RE003. Eleven similar panels were reviewed by the l

Itcensee for electrical separation of wires inside cabinets and

no discrepancies were found. Based on the information reviewed. l

the inspector determined this was an isolated problem.  ;

!

)

r-

l

' ,

.

43

l (2) The installation of non-safety communication equipment (e.g.,

pager phones) in the Train "A" safety related wireways was

substantiated by the licensee. Two bell type telephones were

found with communication lines routed in Train "A". DC 1-87-783

was written with the intent of correcting the problem. this

problem. In the licensee's response of March 2,1987, the

licensee committed to walk down the MCB and other switch boards

to verify that communication cable were routed correctly and

that temporary cables were removed. This verification was

completed on March 6, 1987. IFI 50-424/87-12-04, " Review

Completed Walkdown Verification Regarding Communication Cables

in Safety Related Equipment".

. Also, the incorrect wiring of non-safety related fire protection

( wiring to the MCB was not substantiated. The licensee verified

'

that non-safety fire protection wiring was correctly routed

outside the panels in question. However, during this

verification, one fire detection pull box was found by the

l

licensee not to be torqued as required by procedure 29606 which

I

and resulted in DC 1-87-783.

(3) The hydrostatic tost for a reactor vessel leak-off line (test

number 1-1201-35 completed on October 22, 1987) was found to

have used a test pressure gauge that was out of calibration.

This was because, the master test gauge, which was used for the

test gauge calibration, was out of calibration (e.g.,

approximately +150 psig with an actual condition of 3100 psig).

An engineering justification was performed to ensure compliance

with ASME Section III code requirements (i.e., to test a system

as a pressure not less than 1.25 times the system design

pressure).

Hydrostatic tests, which were performed using test pressure

gauges that were calibrated by the master pressure gauge in

question, were evaluated by the licensee with acceptable

results. The licensee's program to reverify testing performed

with test equipment that was later found to bo out of

calibration has been reviewed and accepted by the NRC in NRC

Report No. 50-424/86-20.

(4) The absence of control or protection of the Unit 1 Plant

Ef fluent Radiation Monitoring System (PERMS) module #ARL2532 in

Unit 2 was substantiated by the licensee. However, this

radiation equipment is not required by Unit 1 Technical

Specification Table 3.3.2 untti irradiated fuel is stored in the

Fuel Handling Duilding. To administrative control this

equipment during the Unit 2 construction, the licensee has

written maintenance work order (HWO) A8700648 to provide a

locked cabinet for this PERMS module.

.

---

___--_------------,----__.--.__.---------_-_---_----_m

l

'

o

44

,

The other concern of Unit 1 electrical cables and equipment

located in Unit 2 has been addressed by IFI 50-424/86-31-05,

which has been previously closed.

I Conclusion

l

Based on the inspector's detail review of each aforementioned concern

'

with licensee management and of documentation, this allegation

(86-A-0018) is closed,

n. Allegation RI! 87-A-0023, Termination for Identifying Safety Concerns

Concern

The following concerns were presented by the alleger:

(1) Termination of employment may have been caused by alleger's role

in Raychem electrical investigation.

, (2) Teflon tape may havo been improperly used on Conax cables in

!

Containment.

(3) Heat shrink tubing may have been installed without adhesive.

Discussion

The inspector reviewed GpC files in regard to the termination of the

alleger. The files are complete, extensive, and contain meaningful

infortration. There is no evidence that suggests that the alleger was

laid of f because of an association or participation with the Raychem

electrical investigation. The alleger was one of many selected for a

Reduction in Force (RIF) and the selection process was in accordance

with GPC procedures.

l The inspector reviewed the files and reports for information in

l

regard to the use of teflon tape in containment. The allegation is

one of second hand in nature, given to the alleger by a former

'

co worker. Investigation by QC and Quality Concerns indicates that

teflon tape may be used as splice material on Conax cables in

Containment. There are a few exceptions, but they are controlled by

specification and vendor instructions. Inspection instructions

address this issue. The Quality Concern File 87V0044 did not reveal

if a followup interview with the co-worker was initiated. Inspector

Followup Item (IFI) 50-424/87-12-06 " Review Followup Interview

Regarding QCP File 87V0044" is identified.

The inspector reviewed the QCP file and NRC Inspection Reports for

information on the use of adhesive on heat shrink tubing. During the

time of NRC Reports 50-424/86-95 and 50-424/87-06, the subject of

adhesive use was addressed. The allegation was true that an

inspector did write himself up for not insuring the use of adhesive

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

,

.

45

shimming for Raychem splices. The issue was known and corrected in

accordance with procedures. The NRC inspections noted above, and GPC

investigations found no other cases of omission of adhesive during

Raychem splicing.

Conclusion

The Quality Concern investigation was extensive, meaningful and ,

adequate. The inspector considers the allegations noted herein as

adequately addressed and therefore closed.

o. Allegation RII 87-A-0036, Failure to Follow the Smoking, Drinking and

Eating Procedure.

Concern

Plant Procedure 00253-C, " Smoking, Eating and Drinking Policy" was

not being implemented properly.

Discussion

On March 5, 1987, a Georgia Power Company employee concerned with

plant cleanliness informed the resident inspector office of the above

stated concern. This employee stated that the Auxiliary Building,

Health Physics Bathrooms, and the area directly outside the contain-

ment airlock routinely showed evidence of eating and smoking. He

also stated that he had not observed anyone violating the

cleanliness, but was unsure what to do if he did.

The inspector informed the employee of the proper reporting method,

that his observations have been already noted to management, that

management was planning additional action, and that these concerns

would be restressed at the next monthly resident exit.

The inspector interviewed the Plant Manager on March 6, 1987, to have

the individual's specific concerns relayed as well as ascertain what

actions were planned and the time table for implementation. The

Plant Manager had prepared a memo directed to All Personnel Working

in the Protected Area and the memo would soon be issued. The second

phase will be to become proactive in enforcement of the policy. On

March 9, 1987, upon entry into the protected area, the inspector

received a copy of the March 6,1987 letter. This letter clearly

establishes the individual as responsible for knowing the work rules

and reporting violations. The plant policy was attached which

included disciplinary action.

At the resident exit meeting on March 9, 1987, the issue was

restressed to upper management. The General Manager stated that

management was committed to a program to implement an effective i

policy.

-_

F

\

, 4

46

Conclusion

As previously discussed, plant management was aware of the problem

and was currently implementing a program to bring awareness and

enforcement. The basic allegation is substantiated, but based on

plant tours by the resident, the infractions are considered minor

with the appropriate action in progress by the licensee. This ,

allegation is closed. ,.

21. Management Meetings - Unit 1(30702)

This activity involves inspector participation and preparation in support

of the following meetings which presented site readiness.

-

February 11, 1987 meeting with Chairman Zech and Technical

Assistants.

-

March 3, 1987 meeting with Commissioner J. Asselstine and Special

Assistant.

l

l

l

l