ML20203P335
| ML20203P335 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/14/1986 |
| From: | Blake J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20203P330 | List: |
| References | |
| 50-424-86-11, 50-425-86-06, 50-425-86-6, NUDOCS 8605070006 | |
| Download: ML20203P335 (25) | |
See also: IR 05000424/1986011
Text
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pa tico UNITED $TATES ,
p NUCLEAR REGULATORY COMMisslON +
y' >o,d, REGION 11,
g j 101 MARIETT A STREET, N.W.
- g ATLANTA, GEORGI A 30323
\..../
Report Nos.: 50-424/86-11 and 50-425/86-06
Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA .30302
Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109
Facility Name: Vogtle 1 and 2
Inspection Co . Fe r 24-28, 1986
Inspect : -
s' v fl 6
E. d Dat Si ned
Appr ,ed by: - 'I N 66
.A lake, Section Chief
~
Date Signed
deering Branch
sion of Reactor Safety
SUMMARY
Scope: This special announced inspection involved 41 inspector-hours on site in
the areas of licensee action on previous enforcement matters identified in
inspection of Readiness Review Module 4, review of construction deficiency
reports, and inspector followup items identified in inspection of Readiness
Review Module 4.
Results: Three violations and one deviation were identified - (1) Violation -
Inadequate measures to assure correction of design criteria documents, para-
graph 3.e. (2) Violation -
Failure to promptly identify undersize welds,
paragraph 3.J. (3) Violation - Removal of temporary pipe supports, paragraph 3.k.
(4) Deviation - Failure to inspect supports, paragraph 5. .
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8605070006 860424 4
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- M. H. Googe, Project Construction Manager
- R. E. Folker, Project Quality Assurance (QA) Engineer
E. D. Groover, QA Site Manager, Construction
R. W. McManus, Readiness Review (RR) Discipline Manager, Construction
Other licensee employees contacted included construction cra ftsmen,
engineers, technicians, operators, mechanics, security force members, and
office personnel.
Other Organizations
- W.' C. Ramsey, Southern Company Services (SCS), RR Project Manager
- G. R. Trudeau, Bechtel Power Corporation (BPC), RR Special Assistant
R. D. Andrews, BPC RR Team Member
- C. R. Myer, BPC, RR Mechanical Design Team Leader
R. C. Somerfeld, BPC, RR Mechanical Construction Team Leader
J. Steele, Pullman Power Products (PPP) Quality Assurance Manager - Unit 1
W.M. Wright,SCS,RRDisciplineManager(Design)
R. A. Keidel, Bechtel National Incorporated (BNI), Manager - Material and
Quality Services (M and QS)
K. W. Caruso, BNI, M and QS Lead Welding Engineer
D. L. Carlson, BNI, M and QS Coordinator
NRC Resident Inspectors
- J. Rogge, Senior Resident Inspector (Operations)
R. Schepens, Resident Inspector
Other NRC Personnel
M. A. Miller, Vogtle Licensing Project Manager
H. L. Brammer, Reviewer (Pipe Break Criteria)
F. J. Witt, Reviewer (Post Accident Sampling System)
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on February 28, 1986, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings listed below
except for the deviation. No dissenting comments were received from the
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licensee. Subsequently, in a telephone call on March 19, 1986, the
inspector informed the licensee of the below listed deviation.
a. Violation 424/86-11-01, 425/86-06-01, Inadequate measures to assure
correction of design criteria documents, paragraph 3.e.
b. Violation . 424/86-11-02, 425/86-06-02, Failure to promptly identify
undersize welds, paragraph 3.j.
c. Violation 424/86-11-03, Removal of temporary pipe supports, para-
graph 3.k.
d. Deviation 424/86-11-04, 425/86-06-04, Failure to inspect supports,
paragraph 5.
-The licensee did not -identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3. Licensee Action on Previous Enforcement Matters
References: (a) Letter dated February 7, 1986, from D. O. Foster
(Georgia Power Company) to J. N. Grace (NRC Region II)
responding to unresolved and inspector followup items
described in NRC Inspection Report 424/85-35.
(b) Letter dated April 26, 1984, from D. O. Foster (Georgia
Power Company) to H. R. Denton (NRC) providing technical
information to justify a request for approval of
alternate pipe break criteria.
(c) Letter dated June 28, 1984, f rom T. M. Novak (NRC
Division of Licensing) to D. 0. Foster (Georgia Power
Company) providing an evaluation and acceptance of
alternate pipe break criteria.
(d) Telecopy dated January 22, 1986 from T. Bennet (Bechtel
LA) to C. Meyer (Readiness Review Design Team Leader)
stating that the Vogtle design contains no moaerate
energy Class I lines.
a. (Closed) Unresolved Item (424/85-35-01): Assurance of Adequate
Readiness Review Coverage of Module 4.
The concern expressed in this item was that the extent of activities
and commitments that should be covered by Module 4 was unclear and, as
consequence, important activities and commitments might be totally
omitted from the Readiness Review 12 activities and/or connitments were
identified which the inspectors stated they believed should be verified
as adequately addressed.
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In Reference (a) the licensee responded to the concern expressed in
this item, describing the review coverage intended for Module 4. In
addition, they briefly described where and how the Readiness Review
addressed the 12 activities /comitments that the NRC inspectors had
identified for specific verification of adequate coverage.
The NRC inspector examined this unresolved item during the current
inspection through review of the licensee's response and through
discussions with responsible licensee and NRC personnel who had
completed or evaluated the Readiness Review activities (Module reviews,
Independent Design Review, or reviews of Appendices) that the licensee
indicated would cover the 12 activities /comitments. The inspector
found that evaluation of many of the reviews that the licensee
indicated would cover the 12 commitments / activities had, as yet, not
been undertaken by the NRC. Examples included Modules 16 and 20;
Appendices C, F and J, and the Independent Design Review. The
inspector selected 3 of 12 commitments / activities which he found had
been examined by NRC personnel and examined the adequacy of their
coverage. The commitments / activities considered by the inspector were
as follows:
Number (from Report 85-35) Subject
(4) Welding Procedure and Welder Qualifica-
tions
(8) Document Control
(11) Piping Material Controls and Equipment
Maintenance (Construction Maintenance)
Based on his examination of the above, the inspector noted only one
apparently minor area which did not appear to be covered in the
Readiness Review. That area was the development of equipment
maintenance requirements. Performance of equipment maintenance was
covered in the review and the inspector considers that any serious
deficiencies in development of equipment maintenance requirements
should have been detected in the review. (Note: Equipment maintenance
as addressed here is not maintenance for plant operation, but
maintenance prior to operation.)
The inspector's examination of this item found that both licensee
Readiness Review and NRC personnel are sensitive to the potential for
omissions of significant matters from the review and that any serious
omission is likely to be detected and resolved. Therefore, the
inspector considers that it is not necessary to have this matter
separately identified for separate evaluation. The unresolved item is
considered closed.
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b. (0 pen) Unresolved Item (424/85-35-03): Design Control of Intermediate
Pipe Breaks.
The concern expressed in identification of this item was that it
appeared that the licensee had not implemented a particular design
commitment they made in obtaining NRC acceptance of changes to design
criteria for postulation of intermediate pipe breaks. As understood by
the inspectors, this design commitment was a provision to assure that
welded attachments lay at least five pipe diameters from any postulated
pipe break locations that would be eliminated in accordance with the
revised criteria.
The licensee's response to this unresolved item, provided in Reference
(a), contended that the commitment questioned by the inspectors had not
been a commitment. They indicated that the NRC acceptance of their
proposed change to criteria for postulation of arbitrary intermediate
pipe breaks was based instead on their compliance with ASME
Section III, Subsections NC/ND-3645, generalized requirements that the
design appropriately consider the effects of local welded attachments.
During the NRC inspection described by this report the NRC inspector
discussed and reviewed the licensee's Reference (a) response with the
Module 4 Readiness Review Mechanical Design Team Leader. In addition,
the inspector reviewed the licensee's Reference (b) submittal that
contained the apparent commitments related to the proposed change in
criteria for postulation of intermediate pipe breaks and reviewed the
Reference (c) NRC evaluation and acceptance letter. Subsequently, the
inspector asked the NRC Vogtle licensing project manager to contact the
cognizant NRC review personnel to determine the validity of the
licensee's contention that acceptance . had been based on their
compliance with NC/ND-3645 rather than on a specific commitment that
welded attachments would not be closer than five piping diameters to
postulated break locations. The NRC Project Manager informed the
inspector that the NRC reviewer stated that the licensee's response in
Reference (a) was incorrect. The licensee's statements in their
Reference (b) letter, including a statement indicating that welded
attachment would be at least five pipe diameters from postulated pipe
break locations, were considered commitments and served, in part, as
the basis for NRC acceptance of alternate criteria for postulation of
intermediate pipe breaks. This was confirmed to Region II in writing.
The inspector informed the licensee of the response obtained from the
NRC reviewer and stated that the criteria that had been and was being
used for postulation of intermediate pipe breaks should be provided for
review in a subsequent NRC inspection.
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The licensee informed the inspector on March 18, 1986, that they plan
to contact NRC licensing personnel to resolve this item. Region II
will verify the licensee's prompt attention to this matter. The item
will remain open pending Region Ils review of the licensee's actions in
resolving this item.
c. (Closed) Unresolved Item (424/85-35-04): Design Control of Moderate
Energy Class 1 Piping.
This unresolved item identified NRC inspector's concerns that the
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licensee's design criteria documents did not contain or reference a
FSAR described commitment giving criteria for postulation of
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through-wall leakage cracks in moderate energy Class 1 piping. The
Module 4 Readiness Review report listed the FSAR commitment as being
implemented in Design Criteria (DC) 1018. However, the inspectors
determined that the criteria were not in the DC-1018 document.
Although the licensee initially stated that they did have moderate
energy Class 1 piping to which the commitment criteria would apply.
They have since stated, in Reference (a), that they determined they
have no moderate energy Class 1 piping. They also acknowledged that
the subject commitment criteria should have been in DC-1018 and stated
that the DC was revised to include the criteria.
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In the current inspection the NRC inspector verified the licensee's
internal communication, Reference (d), from their engineering organiza-
tion stating that they had no moderate energy Class 1 piping. The
matter is considered closed,
d. (Closed) Unresolved Item (424/85-35-05): Implementation of ANSI
N45.2.11.
This unresolved item was identified to expressed NRC inspector's
concerns that the licensee's Module 4 Readiness Review had not clearly
identified ANSI N45.2.11 as a commitment and it was not clear that
their design program adequately implemented this ANSI standard.
In the current inspection the inspector reviewed the licensee's
response to this item as described in Reference (a) and discussed the
matter with the Module 4 Readiness Review Design Team Leader. The
response indicated that ANSI N45.2.11 had not been identified as a l
commitment because the statements in the FSAR regarding its use were
general and the standard was applicable to other modules as well as
Module 4.
The inspector noted that general requirements to comply with ASME
Section III had been identified and addressed in Module 4 as commitment l
880, indicating an apparent inconsistency in the licensee's determina- '
tion of commitments. However, based on his discussions with the
Mechanical Design Team Leader, his examination of checklists and his
further examination of the ANSI N45.2.11 requirements, the inspector is
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satisfied that implementation of ANSI N45.2.11 was being adequately
addressed.
This item is considered closed.
e. (Closed) Unresolved Item (424/85-35-06): Adequacy of Preparation and
Revision of Design Criteria.
This item identified NRC inspector's concerns that the licensee's
Design Criteria documents contained errors and omissions indicating a
possible generic problem with the process of review and revision of
these documents. DC errors and omissions had been discovered by
Readiness Review personnel, as described in their findings 4-66, 4-67
and 4-75. In addition, the licensee had previously identified problems
with DCs not being updated in their INP0 Construction Project Self -
Initiated Evaluation (Finding DC.3-10) completed in 1983. Further, the
inspectors discovered four apparent omissions and errors in DCs 1018,
2702 and 1204 which had not been identified or corrected.
(1) A failure to incorporate revised intermediate pipe break criteria
and controls in DC-1018 (partially identified by the Readiness
Review Team (RRT) in Readiness Review Finding 4-75). This
specifically involves a failure to include the commitment that was
made in the licensee's April 26, 1984, letter (Reference (b)) in
requesting approval of alternate criteria for selection of
intermediate pipe breaks. Not included was a commitment that
arbitrary intermediate pipe break locations eliminated thru use of
the revised criteria be no closer to supports than five pipe
diameters.
(2) A failure to include criteria for postulation of through-wall
leakage cracks in moderate energy Class 1 piping in DC-1018.
(3) A failure to revise DC-2702 to reflect changed criteria for the
location of Residual Heat Removal (RHR) and Containment Spray (CS)
system containment sump post-accident sampling system lines.
(4) A failure to revise DC-1204, Section 6.0.2, to reduce the require-
ment for containment isolation valves in the lines from the RHR
sumps from two to one.
With regard to the above DC errors and omissions, the licensee
responded respectively:
(1) DC-1018 (Pipe Break Criteria - Interdiscipline) did not include
the provision that there be a five pipe diameter distance between
postulated breaks and pipe supports because this was not a
commitment. NRC acceptance required no changes other than those
addressed by finding 4-75.
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(2) DC-1018 did not include provisions for postulating cracks in
moderate energy Class I lines because there are no lines in that
category.
(3) DC-2702 (Post Accident Sampling System) is nonsafety-related.
Drawings and actual installation correctly reflect the intended
design. The design indicated in DC-2702 is a former design that
was revised. DC-2702 was not updated to reflect the correct
design due to an oversite.
(4) DC-1204 (Safety Injection System), Section 4.0.0.1 reflects the
correct design, which was incorporated in a past revision.
DC-1204, Section 6.0.2, was not corrected due to an oversite.
In the current inspection, the NRC inspector reviewed the above
licensee explanations and agrees with all except (1). The basis for
his disagreement with the licensee's response is that a cognizant NRC
reviewer indicated that statements in the licensee's April 26, 1984,
letter (with regard to the distance of postulated breaks from supports)
were considered commitments. The inspector finds that the licensee has
not maintained his Design Criteria documents (documents used to provide
the primary bases for the licensee's design) up-to-date and correct.
The licensee had been aware of and taken actions to correct and assure
proper updating in response to their Self-Initiated Evaluating Finding
(DC.3-10) and their later Readiness Review Findings (4-66 -67 and ,
-75). However, their corrective action measures apparently did not
assure that the Design Criteria were up-to-date and correct as
indicated by the inspectors discovery of the errors and omission
described in (1), (3) and (4) above. This is considered a violation of
10 CFR 50, Appendix B, Criterion XVI, which requires that the licensee
establish measures which assure prompt correction of conditions adverse
to quality, such as the errors and omissions noted in the DCs. This
violation is identified 424/86-11-01, 425/86-06-01, Inadequate Measures
to Assure Correction of Design Criteria Documents.
f. (0 pen) Unresolved Item (424/85-35-09): Adequacy of Drawing and DCN
Reviews.
This unresolved item identified NRC inspector's concerns that the
licensee's Readiness Review of drawings and drawing change notices
(DCNs) was unsatisfactory in that, for the examples of review
performance examined by the inspectors, the following evidence of
unsatisfactory review was noted:
(1) For the licensee's drawing reviews the checklists used had few
items verified and the verifications performed did not appear to
be significant or thorough.
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(2) For the DCN reviews the inspectors found that, in one of four they
examined, the Readiness Review reviewer failed to note a
significant discrepancy between the DCN and the applicable DC even
though the reviewer indicated a specific verification that the DCN
change was in accordance with the DC.
During the current inspection the NRC inspector addressed this item
through review of the licensee's Reference (a) response, discussions
with the Module 4 Readiness Review Mechanical Design Team Leader and
other involved personnel, and examination of additional checklists.
The licensee's general response for this unresolved item an: for
Unresolved Items 85-35-11 and -12 below (which also involve Readiness
Review checklists) was that:
(1) The checklists were developed for application to several design
areas and inherently included items that were not applicable to
all of the areas.
l
l (2) The checklist items were not intended as absolute check require-
l ments, but rather as guidance to be used by experienced reviewers.
NOTE: The licensee concluded that their checklists adequately
served this purpose.
(3) The reviewers did not always clearly describe the reasoning behind
their checks and acceptances of checklist items making it
! difficult to verify the exact check performed.
NOTE: The licensee stated that their personnel have been given
additional training to assure they better document their
performance in subsequent modules.
In addition to the above, the licensee provided a specific response to
the NRC findings in Unresolved Item 85-35-09 giving a logical
explanation of how the checklists were performed. However, it was
still not clear to the inspector that the actual review performed had
been thorough or accurate due, particularly, to the lack of reviewer
documentation of his efforts and to the reviewer's failure to note that
a drawing change he reviewed was not in accordance with the DC
(DC-2702), a check the review specifically verified on the checklist.
The licensee's response to the latter discrepancy was that DC-2702 is
not safety-related. The inspector found this explanation inadequate as
the DC-2702 system is clearly important to safety, the concern was for l
its interface with the safety-related RHR system, and the reviewer
specifically recorded DC-2702 as having been verified in his notation
on the involved checklist.
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The Mechanical Design Team Leader commented to the inspector that many
of the drawing and DCN reviews that the inspector had not examined, had
- been more complete and well documented than those which the inspector
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had previously examined. The inspector verified that this was the
.cause through examination of the following auxiliary feedwater system
(AFW) checklists:
Drawing Checklists (Module 4, Figure 6.1-2) for:
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Piping and Instrumentation Diagrams (P and ID)
1X4DB161-1, Revision 13
- P and ID 1X4DB161-2, Revision 12
DCN Checklists (Module 4, Figure 6.1-3) for:
- P and ID IX4DB161-1, Revision 13, DCNs 1 thru 38
- P and ID 1X4DB161-2, Revision 13, DCNs 1 thru 32
The inspector noted, however, that the important check for compliance
with the DC specified on each of there checklists lacked the detail to
provide evidence of a thorough review.
The licensee stated they would further verify the adequacy of the
reviews they had performed by re-reviewing several drawings and DCNs
and documenting the re-review in detail for further NRC evaluation.
Pending NRC evaluation of this re-review the unresolved item will
remain open.
g. (0 pen) Unresolved Item (424/85-35-11): Inadequate Review of Procure-
ment Specifications.
This item addressed NRC inspector's concern that the licensee's review
of procurement specifications in their Module 4 Readiness Review had
been inadequate and that the specifications might contain significant
unidentified deficiencies. This concern was based on the inspectors'
findings in examining the licensee's Module 4 review of Specification
X4AH04-(shop Fabricated Atmospheric Tanks...) which had been performed
by a licensee reviewer using their checklist 6.1-7. The inspectors had
found that a number of checklist items for the specification example
appeared not to have been performed satisfactorily and that the
specification contained the following apparent deficiencies which had
not been detected in the review.
(1) The specification failed to incorporate (fully) a requirement to
comply with Regulatory Guide 1.44 commitments.
(2) The specification failed to require compliance with ANSI N45.2.11.
(3) Radiation levels specified for some tanks did not include units.
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The inspectors examined this unresolved item through a review of the
licensee's Reference (a) response, discussions with the Module 4 ;
Readiness Review Mechanical Design Team Leader and other responsible i
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Readiness Review management, and examination of revision of the subject
specification to verify information described in Reference (a)
response.
l The licensee's general response with regard to the adequacy of the
reviews they had performed with their checklist is described in f.
above. With regard to the specific review addressed by this unresolved
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item, they responded (in Reference (a) and as supplemented by
discussions) as follows:
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(1) ANSI N45.2.11 does not apply significantly to the items covered by
the specification, as ASME Section III requirements are prescribed
and serve in place of the ANSI document requirements.
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(2) The only requirement from Regulatory Guide 1.44 not addressed in
the specification was a requirement to aid in assuring that the
welding procedures used did not result in sensitization. This
assurance was obtained through a requirement that the manufacturer
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submit his welding procedures for review and approval. Our review
of the submitted procedure verifies their adequacy.
l NOTE: The NRC inspector reviewed the welding procedures submitted
by one of the manufacturers and verified its apparent accept-
ability. These were the procedures for the valve encapsulation
vessels covered by the specification.
(3) The omission of the radiation level units is an error that
,
occurred in revision of the specification. It is not safety
significant, as proper radiation levels, including units, are
- given in the Appendix EA attachment to the specification. The
omission was not detected by the reviewer because it was not an
item he checked.
NOTE: The inspector verified that the radiation level units had
been given in the previous specification revision and that the
current Attachment EA had the correct units.
1
The inspector considered that the licensee's explanation showed that
the subject specification was satisfactory. However, the inspector
considers that revfew performance that the licensee documented for this
j checklist lacks sufficient recorded detail for him to conclude that the
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review was adequate.
As with item 85-35-09, the licensee stated they would further
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demonstrate the adequacy of their original review by reperforming
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several of the specification reviews and documenting the reviews in
! detail. Pending NRC evaluation of the reperformed reviews, this item
will remain open.
,
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h. (0 pen) Unresolved Item (424/85-35-12): Inadequate Review of Vendor
Drawings.
This item addresses NRC inspector's concern that the licensee's review
of vendor drawings for Readiness Review Module 4 had beer: unsatis-
factory and that the drawings might contain deficiencies. This concern
was based on the inspector's findings in their examination of the
licensee's Module 4 review of vendor drawing 1X4AII04-23-13 (i.e.,
Revision 13), which had been performed by a licensee reviewer using
their checklist 6.1-8. The NRC inspectors found that it appeared that
few significant checklist items had been performed and the reviewer
failed to note that certain important drawing details (e.g., weld
sizes) were illegible.
In the current inspection the inspector reviewed the licensee's
Reference (a) response to the item, discussed the item with the
Readiness Review Mechanical Design Team Leader and QA personnel, and
reviewed additional vendor drawing submittals (AFW Pump drawings and
Revisions 11 and 12 of the encapsulation vessel drawing). The
licensee's general response with regard to reviews which they performed
with checklists, such as the review of vendor drawings, is described in
f. above. With regard to the drawing illegibility addressed by the
unresolved item, they responded as follows:
Suppliers are required to submit drawings of good microfilm
quality. Revision 13 of the subject drawing was accepted with
portions illegible because the portion revised was legible and
Revision 12 had been determined to have acceptable microfilm
quali ty. Revision 11 of the drawing had been returned to the
vendor because of poor microfilm quality.
In addition to the above, the licensee provided explanation as to ' low
the review checklist had been used, noting in several instances that
the reviewer had simply elected not to perform certain checklist items
and that he instead chose to verify other data, (but did not document
the checks on the checklist).
The NRC inspector verified that the licensee did have a legible copy of
drawing IX4AH04. The Revision 11 that had been rejected by the
licensee for unsatisfactory microfilm quality was reasonably legible
while the copy of Revision 12 shown to the inspector, (that was
accepted by the licensee) was found partly illegible. Based on his
examination of other vendor drawings (the AFW pump drawings) and on
discussions with licensee QA personnel who had checked additional
vendor drawings in response to Unresolved Item 85-35-12, the inspector
was satisfied that the drawing illegibility he had found appeared to be
isolated and of no safety significance.
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With regard to the explanation of checklist use provided by the
licensee the inspector informed the licensee that the reviews were
supported by such limited documentation that he could not make a
conclusive determination as to their adequacy. The licensee stated
that they would further verify the adequacy of the reviews they had
performed by re-reviewing several vendor drawings and documenting the
re-reviews in detail. They indicated that they would notify the NRC
when the re-reviews had been completed and they would be available for
NRC evaluation. Pending NRC evaluation ]f the re-reviews this item
will remain open.
1. (0 pen) Unresolved Item (424/85-35-13): Inadequate Resolution of
Readiness Review Design Verification Findings.
This item expressed NRC inspectors' concern that the licensee had not
adequately obtained correction for deficiencies their Readiness Review
Team (RRT) had identified in their Module 4 Readiness Review Design
Verification Findings. The inspectors had examined the licensce's
resolution of two of the RRT findings identified and the inspectors'
observations were as follows:
(1) Finding 4-75
This finding was that a calculation failed to postulate inter-
mediate pipe breaks in accordance with DC-1018. The licensee's
internal project response to the finding, which was accepted by
the Readiness Review Team (RRT), was that:
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the calculation was acceptable as it had been performed to a
NRC approved change in the criteria described in DC-1018
due to misplacement of a change notice, DC-1018 had not been
revised, it was corrected in response to Finding 4-75
actions had been taken to prevent recurrence of unincor-
porated DC changes
The inspectors determined that the licensee's RRT failed to
recognize that there had been conditions upon NRC approval of the
change that were not included in the correction of DC-1018. The
licensee's failure to recognize these conditions, which were
commitments made in obtaining NRC acceptance, is addressed in
Unresolved Item 85-35-03 in b. above.
(2) Finding 4-85
This finding was that Project Classes stated on the specification
and technical provisions for the RHR isolation valve incapsulation
vessel were incorrect. The licensee's internal project response
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to this finding (which was accepted by the licensee's RRT) was
that, while the incorrect Project Class had been identified on the
documents, the specific requirements given in the text assured
that the proper requirements were met. To assure that proper
Project Classes were indicated on other documents, the response
stated that eight specifications were checked and no other
discrepancies were found. The inspector questioned the adequacy
of the corrective action in the response because the inspectors
had identified cdditional examples of misclassification in a Field
Change Request (FCR), calculation, and a specification proposal.
The licensee's response to unresolved item was as follows with
regard to the inspectors' obscrvations for the two findings and
associated responses:
(1) Finding 4-75
The licensee stated their disagreement with the inspectors'
observations for this item referring to their response for
Unresolved Item 85-35-03 above.
(2) Finding 4-85
The licensee provided explanations for each of the examples
cited by the inspectors.
The NRC inspector reviewed and discussed the licensee's response
with the Readiness Review Mechanical Design Team Leader. The
inspector agreed with the licensee's explanations for Finding
4-85. The licensee's explanation for Finding 4-75 did not appear
correct, as described for the related Unresolved Item 85-35-03
above. Pending resolution of 85-35-03 this item will remain open.
j. (Closed) Unresolved Item (424/85-35-14): Undersized /0verground Welds.
This unresolved item expressed a concern described by an NRC inspector
to licenste management personnel in a meeting dated August 30, 1985,
that RHR isolation valve encapsulation vessel welds were overground and
under size. These welds were on vessel 1-1205-V4-001, drawing
IX4AH04-23-13, and were identified as welds 49 and 50 on the drawing.
In their Reference (a) response to this item the licensee stated:
(1) The hardware involved was not part of the Module 4 Readiness Review
sample.
(2) The inspection of the welds questioned had not been the respon-
sibility of the project, but instead that of the vendor.
(3) The weld condition was being addressed on deviation reports (DRs)
MD-8721 and 8723.
. .
14
During the current inspection the NRC inspector examined this item by
reviewing the deviation reports that the licensee had prepared
following the examination of the subject vessel welds performed in
response to this unresolved item. In addition, the inspector also
reviewed related information on DRs MD-8725 and 2264. The discre-
pancies that were described on the four DRs were as follows:
MD-8721 (dated February 1, 1986)
This DR confirmed and documented the undersize condition for
vessel 1-1205-V4-001, weld 50, that had been identified by the NRC
inspector. In addition, it identified similarly located welds
that were undersize on other :imilar Unit 1 vessels fabricated by
the same manufacturer.
MD-8723 (dated February 4,1986)
This DR confirmed and documented the undersize condition for
vessel 1-1205-V4-001, weld 49, that had been identified by the NRC
inspector. In addition, it identified similarly located welds
that were undersize on other similar Unit i vessels fabricated by
the same manufacturer.
MD-8725 (dated February 5, 1986)
This DR documented the licensee's identification of undersize
conditions on Unit 2 vessels and welds similar to those covered by
DRs MD-8721 and MD-8723.
MD-2264 (dated July 20, 1982 and resolved March 19,1985)
This DR documented the licensee's identification and correction of
six unsatisfactory condition related to welding on vessel
1-1205-V4-001. This included the identification and removal of
slag pockets in weld 49. The licensee failed to recognize the
undersize condition for weld 49 when they inspected it following
the removal of slag pockets from the weld.
Based on the above, the inspector finds that the licensee failed to
comply with 10 CFR 50, Appendix B, Criterion V requirements that
activities affecting quality be accomplished in accordance with
documented procedures, instructions, or drawings, in that vessel
1-1205-V4-001 welds 49 and 50 did not comply with size requirements
given on drawing IX4AH04-23-12 and similarly located welds on similar
Unit 1 and 2 vessels also did not comply with drawing size require-
ments, as described in licensee deficiency reports MD-8721, 8723 and
8725. In addition, the licensee also failed to comply with 10 CFR 50,
Appendix B, Criterion XVI requirements that measures be established to
assure that deficiencies are promptly identified and corrected, in
that:
.
15
(1) Although the licensee identified (July 20, 1982) and corrected
complete March 19, 1985 six welding related deficiencies on vessel
1-1205-V4-001, including a deficiency on weld 49 (which they
visually re-inspected) they failed to detect and correct the
undersize weld condition.
(2) Licensee management was not prompt in identifying the condition in
that they did not identify the condition on a deficiency report
until February 1986, over five months after it was reported to
them by an NRC inspector on August 30, 1985.
The licensee's failure to comply with drawing requirements and their
failure to promptly identify the noncompliance with drawing require-
ments is identified as violation 424/86-11-02,425/86-06-02, Failure to
Promptly Identify Undersize Welds.
k. (Closed) Unresolved Item (424/85-35-15): Undocumented Piping Supports.
This unresolved item expressed NRC inspector's concern that structural
members supporting piping inside vessel 1-1205-V4-001 were not depicted
on the drawing and the basis for and controls on the installation of
these supports could not be readily determined.
The licensee's Reference (u) response to this item was as follows:
The piping and valve supports questioned by the inspectors are
temporary supports for shipping purposes. They are shown on
Bechtel approved vendor drawing number B-81-22. Revision 0 (vendor
document log number AX4A404-90-1). The drawing includes
instructions to remove the supports.
The RHR system has been turned over to Nuclear Operation for
pre-operational testing and the work completion checklist
identifies the vessel as requiring additional work as documented
by work item BC0626 and work order 18513301. The control of work
activities during the pre-operational test phase is described in
Module 3A which was submitted to the NRC on May 1,1985 with a
revision submitted on July 29, 1985.
During the current inspection the NRC inspector reviewed the licensee's
response to the item and questioned licensee personnel as to what
specific controls they had to assure that the subject temporary pipe
supports were removed at an appropriate time.
I
- .
16
The inspector was referred to and reviewed the following documents:
- Nuclear Plant Maintenance Work Order, Control No. 18513301, Work
Item BC-0626
The inspector found that this document only stated, " Secure
Encapsulation Vessel 1-1205-V4-001 and perform test 1-1205-10".
The document neither provided or referred to any criteria that-
assured removal of the supports.
- Field Process Sheet for Mark No. V-1-1205-V4-001, dated
October 27, 1981, and entitled " Process Sheet for Inspection
and Cleaning of Encapsulation Vessels. Also, to Allow Removal
of Shipping Braces and Installation of Electrical Penetration
by others".
The inspector found that this process sheet had included an
instruction for removal of the temporary supports (support
braces). The instruction for support removal was not performed,
but was accompanied by a modifying note (dated April 22,1982)
that stated the instruction was to be performed after welds were
complete. The step was never performed and there was no evidence
of it having been transferred to any other document for
performance. The field process sheet was considered complete and
had received final QA approval. There had been no requirement for
a QC inspection to verify the support removal.
In his review of the above and in discussions with licensee personnel,
the inspector found no documented criteria that would assure removal of
the subject pipe supports. This is considered noncompliance with
10 CFR 50, Appendix B, Criterion V requirements that documented
instructions, procedures or drawings be provided and used to assure
proper accomplishment of activities affecting quality, such as removal
of the supports. This noncompliance is identified as violation
424/86-11-03, Removal of Temporary Pipe Supports,
l '. (Closed) Unresolved Item (424/85-35-17): Inadequate Resolution of
Readiness Review Findings.
This item expressed NRC inspectors' concern that the licensee had not
adequately resolved Readiness Review Module 4 Construction RRT
findings. The concern was based on the inspectors' determination that
the resolution of finding 4-83 stated in the Module 4 report was
incorrect.
In their Reference (a) response the licensee stated that the response
provided in the Module 4 report had been based on certain correspon-
dence that was subsequently found incorrect. The response indicated
that the determination that the response was incorrect was not
completed until af ter the Module 4 report had been submitted to the
NRC. In the current inspection the NRC inspector verified that the
-_
.
17
licensee had become aware of the error, as stated in their Reference
(a) response. The licensee's resolution of the finding appears
adequate, though belated, and the matter is considered closed.
4. Unresolved Items
Unresolved items were not identified during this inspection.
5. Construction Deficiency Reports (CDRs)
(0 pen) Item 424, 425 CDR 83-41: Embed Plate Base Metal Failure
References: (a) Letter dated July 11, 1983, from R. E. Conway (Georgia
Power Company) to J. P. O'Reilly (NRC Region II)
providing on interim report on investigation of an embed
plate base metal failure.
(b) Letter dated February 15, 1984, from D. O. Foster
(Georgia Power Company) to J. P. O'Reilly (NRC
Region II) stating that the previously described embed
plate base metal failure had been determined not to be
reportable in accordance with 10 CFR 50.55(e).
(c) Georgia Power Company Nonconformance Report MD-4266,
dated April 9,1983, documenting separation of weld from
embed plate that occurred on piping support
V1-1901-043-H019.
(d) V. H. Wadhwani, Bechtel Group, Incorporated,
" Investigation of Weld Failures Between Welded Embed
Plates and Steel Support Tubes at the Vogtle Jobsite",
June 1983.
(e)
Letter dated July) 5,1983,
Power Corporation from M.
to J. A. Bailey MalcolmCompany
(Southern (Bechtel
Services) describing the status of the investigation of
the embed plate base metal failure.
(f) Letter dated August 1,1983, from M. Malcolm (Bechtel
Power Corporation) to D. O. Foster (Georgia Power
Company) describing the results of a meeting to discuss
a field inspection program to be conducted to further
investigate the pipe support weld failure (the embed
plate failure).
(g) Letter dated August 2,1983, from H. H. Gregory (Georgia
Power Company) to M. Malcolm (Bechtel Power Corporation)
describing the results of a survey to identify flare
bevel welds made to embeded and surface mounted plates.
r
e
.
18
(h) Letter dated September 12, 1983, from M. Malcolm
(Bechtel Power Corporation) to H. H. Gregory (Georgia
Power Company) describing the field inspection program
to be performed for further investigation of the pipe
support failure.
(1) Letter dated January 19, 1984, from M. Malcolm (Bechtel
Power Corporation) to J. A. Bailey (Southern Company
Services) describing the completed engineering
evaluation of the potential construction deficiency
involving the pipe support weld failure.
(j) " Commentary on Highly Restrained Welded Connections",
Reprint, AISC Journal, 61-78, Third Quarter /1973.
(k) L. F. Porter, "Lamellar Tearing in Plate Steels (A
Literature Su rvey )", United States Steel Corporation
Research Laboratory Technical Report, August 29, 1975.
(1) U.S. Nuclear Regulatory Commission, " Potential for Low
Fracture Toughness and Lamellar Tearing on PWR Steam
Generator and Reactor Coolant Pump Supports", USNRC
Report NUREG-0577 for comment, October 1979. Available
for purchase from USNRC Division of Technical
Information and Document Control, Washington, DC 20555.
(m) E. J. Kaufmann, A. W. Pense and R. D. Stout, "An
Evaluation of Factors Significant to Lamellar Tearing",
Reprint, Welding Research Supplement to the Welding
Journal, 43s-49s,liarch 1981.
(n) R. D. Stout and A. W. Pense, "Causes and Prevention of
Lamellar Tearing", Civil Engineering - ASCE, 74-75,
April 1982.
I
(o) G. A. Knoroveki, R. D. Krieg and G. C. Allen, Sandia
National Laboratories, " Fracture Toughness of PWR
Components Supports", USNRC Report NUREG/CR-3008,
February 1983. Available for purchase from National
Technical Information Service, Springfield, VA 22161.
(p) U.S. Nuclear Regulatory Commission, " Potential for Low
Fracture Toughness and Lamellar Tearing in PWR Steam
Generator and Reactor Coolant Pump Supports", Rev.1,
October 1983.
(q) J. L. Grover and R. C. Cipolla, Aptech Engineering
Services, incorporated, "The Significance of Lamellar
Tearing ir ".tructural Steels" Electric Power Research
Institute kcaort NP-3570, June 1984.
. - - -
- .
19
On June 6,1983, the licensee notified NRC Region II by telephone of a
support failure which they had determined was potentially reportable as a
construction deficiency in accordance with the requirements of
10 CFR 50.55(e). In their written report, dated July 11,1983 (Reference
(a)), the licensee informed NRC Region II that the potential deficiency
concerned a failure of a support constructed of rectangular tubular steel
welded to an embed plate. The support construction had involved welding one
flat face of a piece of tubular steel against the embed plate face utilizing
flare bevel welds placed along the two rounded edges of the tubular steel
that lay adjacent to the tubular steel / embed plate interface. The failure
occurred when a craf tsman stepped on the support. In a letter dated
February 14, 1984 (Reference (b)), the licensee informed Region II that they
had completed their investigation of the support failure and had determined
that it was not reportable in accordance with 10 CFR 50.55(e).
During the current inspection the NRC inspector examined the licensee's
investigation of the support failure through a review of literature on
lamellar tearing, a review of the licensee's documentation of their
investigations of the failure and discussions with cognizant licen3ee
personnel. The literature and licensee documentation reviewed are listed as
references above. Significant information and findings obtained by the
inspector in his review and discussions is summarized as follows:
a. The licensee reported that the failure occurred when an individual
stepped on the tubular steel portion of a pipe support fabrication from
tubular steel that was welded to an embed plate utilizing flare bevel
welds with fillet weld reinforcement.
b. The licensee indicated that failure occurred in the embed plate base
metal. The fracture ran the full length of the welds and pulled out
plate base metal about 1/16 inch deep,
c. The licensee reported that weld size was excessive, greatly exceeding
the size specified by the design drawing. The drawing specified
unreinforced flare bevel welds to join the tubular steel to the plate
(one on each side of the tube). The licensee found that the welds used ;
in practice had been flare bevels plus fillet weld reinforcements of
over 1/2 inch. The welds joined 3/8 inch thick (6w x 3d) tubular steel
to a inch thick plate.
d. Based on a metallurgical evaluation of the failure, the licensee
concluded that the failure was the result of lamellar tearing caused by
the large shrinkage stresses from heavy welding, compounded by embed
plate inclusions and ferrite banding close to the plate surface.
e. Based on his review of the licensee's metallurgical investigation
report (Reference (d)) and relevant literature (Reference (j) through
(g)) the inspector found that the licensee's conclusions in d. above
were amply supported, except that the literature does rot support
ferrite banding as a factor.
%... .
_
. _ . _ _ . _. __
-
. ,
4
'
20
,
f. In their July 11, 1983, written report (Reference (a)) on this item the
licensee presented a summary of the results from their metallorgical
investigation and also. described a test which they performed at the
site to investigate the failure. This test involved four similarly
,
welded (tubular steel welded to plate) supports which were visually
i' inspected, magnetic particle examined, and load tested to destruction.
For the testing, the licensee removed the weld from one tube edge / plate
interface on each of the supports and loaded the supports to failure ,
4
utilizing a hydraulic ram and a wedge. They noted that extensive
effort was required for each destructive failure. One of the four
samples exhibited magnetic particle indications an.d it failed by
lamellar tearing. Licensee personnel estimated that'the force required
to produce the destructive failure was well in excess of that required
! by design,
g. The licensee's July 11, 1983, letter stated that the following
additional investigation would be conducted to verify that lamellar
tearing had not occurred elsewhere:'
4
- A field walkdown of supports which utilize,weldments of similar
size and type will be conducted to confirst that lamellar tearing
i has not occurred elsewhere. Flare bevel' welds with reinforcing
fillet welds 3/8" and larger, on plates one inch or thicker will
'
be identified and evaluated based upon a detailed visual
inspection program. This inspection will include, as a minimum, '.
samples of weldments made to the embed plates fabricated from heat, ".
numbers 7417461 and 7419919. These are the heat numbers
respectively of the embed plates to which the subject support an'd
!
the fourth support tested to destruction were attached. In
,
addition, appropriate samples will be inspected using magnetic
'
particle testing to assure a higher confidence level on the
integrity of the existing installation. The 3/8" fillet
,
reinforcement is considered an appropriate threshold for the
initial scope of this investigation.
'
-
The final scope of this investigation will be determined after a
detailed assessment has been made of the proposed field walkdown
and MT sampling results have been obtained.
i h. In their internal letter of January 19, 1984, (Reference (i)), the
,
licensee described their completed evaluation of the support failure as
'
a potential construction deficiency >fn accordance with 10 CFR 50.55(e).
The investigation that the licensee performed to verify that lamellar
! tearing had not occurred elsewhere was described in that letter.
'
Significant aspects of the investigation, as determined by the NRC
inspector from his review of the letter, were as follows:
-
The investigation was conducted through visual and magnetic
particle examination of a sample of supports for evidence of
lamellar tearing. ,
4
, _ _ , _ , _ - . ._~_.,...,_~_._.~--,,_._,-_._..,y ,._._.y. . , , , _ . . . . . ~ _ . , _ _ . _ , . - , - - _ , . _ _ , , , , . _ _ _ _ . , , _ , _ _ . . . . ~ . , _ _ _ . - . , . - , . . . _ . , . , . _ , . _ . , . . , - - -
. - .
_
. .
21
-
The population of supports from which the sample for examination
was limited to previously inspected supports involving flare bevel
welds made to embed plates and surface mounted plates. This total
population consisted of 447 supports.
- Examination was performed on a sample consisting of 53 supports
selected at random on a statistical basis from the stated
population.
-
The following finding and conclusions were r.)orted:
No lamellar tear indication was identified in the inspection
of the samples.
There is a 95% confidence level that at least 95% of the
flare bevel welds included in the total population considered
will not have any lamellar tear indications.
There is one half of one percent probability of exceeding 1/2
inch overweld in the field. It should be noted that the
subject support that failed had 1/2 inch fillet reinforcement
which was not called out in the design drawing. It is
therefore concluded that significant overwelding is a rare
occurrence.
- The evaluation of the field inspection program results have
confirmed that the weld failure of the subject support was an
isolated event.
-
Examples of supports fabricated from plate heat numbers 7417461
and/or 7419919 were ot identified and included in the investiga-
tion. As noted in 9. above, the licensee had informed the NRC
that weldments made to embed plates fabricated from those heats
would be inspected as a minimum,
i. The licensee's internal letter of January 19, 1984 (Reference (i))
stated that the conditions that had made the original failed support
plate susceptible to lamellar tearing were considered highly unlikely
to exist uniformly or repeat within a given heat of plate material.
NOTE: No reference or data was provided in support of this statement.
k. Significant related data obtained by the inspector from literature on
lamellar tearing is as follows:
-
Lamellar tearing is a form of cracking that occurs in planes
essentially parallel to the rolled surface of a plate under high
thru-thickness (welding induced) loading. It tends to initiate
thru cracking or decoherence of elongated inclusions. (Reference
(o))
'
,
. .
22
- No relationship has been established between lamellar teaYing and
banding. (Reference (j))
- The zone of decohesion responsible for lamellar tearing generally
extends from the lower part of the weld heat af fected zone to 1/4
inch below the plate surface. (Reference (k))
- Most of the time lamellar tearing occurs beneath the plate surface
where it is best detected ,by ultrasonics (Reference (n)).
Ultrasonic examination is the most suitable method for detecting
lamellar tearing in completed weld joints. (Reference (j))
- Plate material susceptibility to lamellar tearing is strongly
dependent on base metal compositions, particularly on sulfur and
carbon content. (Reference (g))
NOTE: Based on licensee analysis cf the failed embed plate if
appears susceptible to lamellar tearing.
-
Only one documented inservice failure can be attributed to
lamellar tearing and this was not in a nuclear application.
(Reference (p))
-
Preliminary tests suggest that incipient lamellar tears buried
from view do not lower static strength of the joint seriously
unless they have propagated sufficiently to be detected 'by
ultrasonic examination. (Reference (m))
In reviewing the licensee's actions on this matter, the NRC inspector
found that the licensee's investigation was generally technically
sound. However, the inspector noted two factors that the licensee did
not appear to adequately consider to assure that they did not have
additional supports that exhibited lamellar tearing: .
- The licensee did not identify and inspect or test any. examples of'
supports fabricated from the heat of plate that originally failed,
such that they might verify that the plate metallurgical
characteristics had not resulted in additional examples of
lamellar tearing. As described in g. above, the licensee had
specifically reported to NRC Region II that additional support
examples from the failed heat of plate would be inspected. (The
licensee did not subsequently netify, Region II of their decision
not to inspect additional examples of the heats of plate that had
exhibited lamellar tearing.)
-
The preferred method for detection of lamellar tearing is
ultrasonic examination. The licensee employed magnetic particle
examination (rectf fied alternating current using prods) in their
investigation.
'
, ,
e
- n.
f
. - . . - - + - , , - , . -. . - - - - - . - - - - - - - - - - - - - - - _ - - - - . -
_
.
23
NOTE: The use of ultrasonic examination may not have been
practical for the support configurations involved in the
investigation but the inspector saw no pending evidence that its
use had even been considered. Pending further NRC examination of
the licensee's embed plate installation records and evaluation of
the examinations performed by the licensee to detect lamellar
tearing in their investigation, item 424,425 CDR 83-41 will remain
open. The licensee's failure to identify and inspect samples of
weldments made to embed plates fabricated from heat numbers
7417461 and 7419919 is considered a deviation from the commitment
made in the licensee's letter of July 11, 1983. This deviation is
identified 424/86-11-04, 425/86-06-03, Failure to Inspect
Supports.
6. Inspector Followup Items (IFIs)
a. (Closed) IFI (424/85-35-02): Omission of Westinghouse Offsite
Activities for the Readiness Review.
This item identified NRC inspector's concerns that the licensee had
omitted the offsite activities of the Nuclear Steam Supply System
suppliar (Westinghouse) from the Readiness Review.
In their response (see paragraph 3 above, Reference (a)) to this IFI,
the licensee acknowledged and described their basis for omitting
Westinghouse offsite activities from the Readiness Review. The
licensee's position on the matter is clear and will be acknowledged in
the final NRC report on Module 4. The inspector considers that no
further inspection of this item is necessary.
b. (Closed) IFI (424/85-35-07): Calculation Corrective Actions.
This item was opened by NRC inspectors for followup to assure that
corrective actions with regard to minor discrepancies in calculations
had receivr;d adequate attention.
During the current inspection the NRC inspector examined this item
through a review of the licensee's written response (Reference (a) in
paragraph 3 above) and discussions with the Module 4 Readiness Review
1
Design Team Leader. The inspector accepted licensee explanations
citing the lack of safety significance in the subject calculation
y discrepancies.
"
c. (Closed) IFI (424/85-35-08): Maximum Design Pressure Discrepancy
This IFI was opened to address an apparently minor discrepancy that the
inspector's observed in comparing a maximum design pressure given on an
isometric drawing with that indicated for the same line on the
licensee's Line Designation List.
,
- _ . - -. - - - - - ----- ._ - .-. _---.
. .
24
'
s
During the current inspection, the NRC inspector followed up on this ;
item by reviewing the II:ensee's response to the item (Reference (a) in
paragraph 3 above), discussing the item with the Module 4 Readiness
Review Mechanical Design Team Leader, and verifying correction of the -
. design pressure entry given on the isometric drawing. The licensee's
explanation of the discrepancy indicated that the pressure given on the
drawing is not used in stress analysis and had no impact on the system
design. This explanation was accepted by the inspector and the matter
is considered closed.
!
d. (Closed)IFI(424/85-35-10): Review of Construction Specifications and
'
Procedures. i
This item expressed minor concerns with regard to review coverage
provided by the Module 4 Readiness Review of the construction
specification and of construction procedures for receipt, storage, and
maintenance. The inspector's who identified this IFI based their
concern on the fact that there was no indicatten of a review of these
documents for commitment implementation in the Module 4 Readiness
Review report commitment section.
During the current inspection, the NRC inspector examined this item
through review of the licensee's written response (see paragraph 3
Reference (a)) and discussions with cognizant Readiness Review
<
personnel. The licensee's response pointed out that the subject
construction specification and procedures had been addressed in
development of Readiness Review Module 4 report, Section 4 which
provides the description of the licensee's program and includes '
, descriptions of procedures for receipt, storage and maintenance. The
response also noted with regard to the construction specification that
they had identified a significant finding (Finding 4-56) and a -
Readiness Review Information Request (RIR 4-6) which were evidence of
,
their review. The inspector verified the finding and the description i
of the procedures for receipt, storage and maintenance given in the
^
,
Module 4 report and accepts the licensee's explanation. The matter is
! considered closed.
i
! e. (Closed) IFI (424/85-35-16): Inconsistency in the use of low carbon
stainless steel.
.
This IFI was opened by the NRC inspectors to follow-up on an apparent
inconsistency in the composition of piping materials used in the RHR
isolation value encapsulation vessel. The inconsistency was that all
-
of the pipe was a low carbon stainless steel, while the valve itself
was not.
During the current inspection, the NRC inspector followed up on this item I
by verifying that the material specified for the valve in the design
- was not low carbon stainless steel. The inspector determined that the
materials were as specified by the designer. The matter is considered
closed.
_
- ._ _ __ _- . . . _ _ _ _ _ . - . _ .. _ _-_ _ .-