ML20212A281
ML20212A281 | |
Person / Time | |
---|---|
Site: | Vogtle |
Issue date: | 12/11/1986 |
From: | Livermore H, Rogge J, Schepens R, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20212A215 | List: |
References | |
50-424-86-74, 50-425-86-35, NUDOCS 8612220361 | |
Download: ML20212A281 (46) | |
See also: IR 05000424/1986074
Text
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pa maop, UNITED STATES
/ 'o NUCtEAR REGUtATORY COMMISSION
[* , REGION il
3 y 101 MAR!ETTA STREET.N.W.
- e ATL ANTA. GEORGI A 30323
\*...*/
Report'Nos.: 50-424/86-74 and 50-425/86-35
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Licensee: Georgia Poser Company
P.O. Box 4545
Atlanta, GA 30302
Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109
Facility Name: Vogtle 1 and 2
Inspection' Conducted: August 12 - October 15, 1986
Inspectors: /
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Date Signed
[ M,, H. H. Livermore,
Inspector, Senior Resident
Co struction .
f>'O JJ
p g J. F. Rogge, Senior Resident
v/alu
Date Signed
Inspeqtor, Op rations
[, , ht '
Ijd 7[O (
cf R. J. Schepens, Resident Date Signed
IO' Inspector, Operations & Construction
Approved By: [f 1.t a.k .- I bb
M.V.SinkulhS~ectidnChief Dat'e Signed
Division of Reactor Projects
SUMMARY
Scope: This routine, unannounced inspection entailed Resident Inspection in the
following areas: containment and safety related structures, piping systems and
supports, safety related components, auxiliary systems, electrical equipment and
cables, instrumentation, preoperational test program, initial fuel receipt
inspection, quality programs and administrative controls affecting quality, and
follow-up on previous inspection identified items.
Results: Two violations were identified " Failure to Achieve Appropriate
Corrective Action" - Paragraph 24, " Failure to Provide Adequate Procedure for
Testing Air Operated Valves with Bailey Controllers" - Paragraph 20.
8612220361
DR 861211
ADOCK 05000424 PDR
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DETAILS
1. Persons Contacted
Licensee Employees
- R. E. Conway, Senior Vice-President, Vogtle Project Director
D. O. Foster, Vice-President, Project Support
- P. D. Rice, Vice-President, Project Engineering
R. H. Pinson, Vice-President, Project Construction
W. T. Nickerson, Assistant to the Project Director
- W. W. Mintz, Project Completion Manager
M. H. Googe, Project Construction Manager
G. Backhold, Jr., General Manager Nuclear Operations
T. V. Greene, Plant Manager
H. P. Walker, Manager Unit Operations
- R. M. Bellamy, Plant Support Manager
- C. W. Hayes, Vogtle Quality Assurance Manager
- C. E. Belflower, Quality Assurance Site Manager - Operations
- E. D. Groover, Quality Assurance Site Manager - Construction
- W. E. Mundy, Quality Assurance Audit Supervisor
D. M. Fiquett, Project Construction Manager - Unit 2
- B. C. Harbin, Manager Quality Control
- G. A. McCarley, Project Compilance Coordinator
- W. C. Gabbard, Regulatory Specialist
C. F. Meyer, Operations Superintendent
T. Dannemiller, Te<* Engineer
C. L. Coursey, Maintenance Superintendent (Startup)
M. A. Griffis, Maintenan Superintendent
D. McCary, Engineering Supervisor, GPC/PKF
- G. R. Frederick, Quality Assurance Engineer / Support Supervisor 1
R. E. Spinnatu, ISEG Supervisor i
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J. F. D'Amico, Nuclear Safety & Compliance Manager ;
W. F. Kitchens, Manager Operations
V. J. Agro, Superintendent Administration
A. L. Mosbaugh, Asst. Plant Support Manager
- G' Yunker, Nuclear Security, Corporate
- M. P. Craven, Nuclear Security Manager
Other licensee employees contacted included craftsmen, technicians,
supervision, engineers, inspectors, and office personnel.
Other Organizations
H. M. Handfinger, Asst. Plant Support Manager - Bechtel
D. L. Kinnsch, Project Engineering - Bechtel
- Attended Exit Interview
2. Exit Interview (30703C)
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The inspection scope and findings were summarized on October 15, 1986 with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection finding listed below.
No dissenting comments were received from the licensee. The licensee did
not identify as proprietary any of the materials provided to or reviewed by
the inspector during this inspection.
(0 pen) Violation 50-424/86-74-01 " Failure to Achieve Appropriate Corrective
Action on the Implementation of a Formalized / Controlled Training &
Qualification Crane Operator Program for Operations Personnel Per QA Audit
Report No. OP11/16-86/17, Dated July 9, 1986." - Paragraph 24.
(0 pen) Violation 50-424/86-74-02 " Inadequate Procedure for Testing Air
Operated Valves With Bailey Controllers." - Paragraph 20.
(0 pen) Inspector Followup Item (IFI) 50-424/86-74-03 and 86-35-01 " Review
Results of Testing the Check Valves on the Feedwater Isolation Valves" to
verify new model 8F-C8!g-10-SS."-Paragraph 22.
(0 pen) Violation 50-424/86-09-01 " Failure to Perform and Adequate System
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Walkdown During Turnover of Safety Related Systems" - Paragraph 3.
(Closed) Unresolved Item 50-424/86-60-02, " Inadequate Instruction and
Training for Ray-Chem Electrical Splice Installations." - Paragraph 4.
(Closed) IFI 50-424/86-51-05, " Posting of NRC-3 and Part 21 Forms." -
Paragraph 4
Ten Part 21 Reports and shree Construction Deficiency Reports were closed -
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Paragraph 22.
The following NRC exit interviews were attended during the inspection period
by a resident inspector:
Date Name
August 18, 1986 A. Tillman, D. H. Thompson
G. A. Schnebli
September 5, 1986 W. H. Miller
W. Kleinsorge
September 12, 1986 G. A. Schnebli
September 26, 1986 T. F. McElhinney
L. H. Jackson, R. D. Gibbs
C. F. Smith, M. Shannon, R. A. Moore
L. E. Nicholson
Octotier 3,1936 N. Merriweather
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T. D.' Gibbons
G. A. Hallstrom
October 9, 1986 S. Q. Ninh
October 10, 1986 W. H. Miller, et. al.
On October 3, .1986, Mr. P. H. Skinner presented the results of his
inspection pertaining to allegations. The licensee was informed that his
inspection items would be documented in the resident inspector report. (See
paragraph Sa - h.)
3. Licensee Action on Previous Enforcement Matters (92702)
(0 pen) violation 50-424/86-09-01 " Failure to perform an adequate system
walkdown during the turnover of . safety related systems." The resident
inspections attended a meeting conducted by the licensee regarding the
P&ID walkdown summary, the purpose of the meeting was to inform _the
resident inspectors of the status as well as their findings, conclusions,
and actions as a result of their corrective action for the subject
violation. The licensee has written and conducted a special construction
acceptance test CAT-M-99 to perform a re-walkdown of all safety-related
systems. The status as of this meeting is that all safety-related system
re-walkdowns are complete and maintenance work orders have been written to
correct _ identified deficiencies found during their walkdown. Pending the
inspector's review of the completed package this item shall remain open.
4. Followup on Previous Inspection Items (92701)
(Closed) URI 50-424/86-60-02, " Inadequate Instruction and Training for
Ray-Chem Electrica; Splice Installations". Subsequent to the identification
of this item, a detailed Region based inspection was performed (Report
50-424/86-66; 50-425/86-31). More in-depth, unresolved item findings were
identified (01 through 07) for action. These findings are duplicate in
nature to Unresolved Item 50-424/86-60-02, therefore, this item is closed.
(Closed) IFI 50-424/86-51-05, " Posting of NRC-3 and Part 21 Forms". The
inspector has insured that NRC 3 and Part 21 Defect Reporting Requirement
forms have been posted in sufficient locations to permit employees to
observe a copy while traveling to or from their work places. This item is
closed.
5. Allegations
a. Allegation RII-85-A-0016-011, Investigation Concerning Stencilling
Small Bore Pipe Elbows
Concern
An alleger has stated that two individuals (including the alleger)
noticed several pieces of black small bore pipe elbows on the floor and
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also observed two workers with a box of stencils hammering the stencils
on the pipe elbows. The alleger could only identify one of the
individuals doing the work. The alleger stated that the other
individual who noticed the activities being performed said that they
were doing something that they were not supposed to be doing. The
alleger observed the workers stenciling the pipe and stated a concern
that they appeared to be doing something that they should not be doing.
Olscussion
The inspector reviewed the present procedure (GO-A-30, Receipt, Receipt
Inspection, Storage, and Handling, Revision 12) and procedures dating
back to January 7, 1983. The process, in summary, is as follows:
(1) Material is received in a warehouse from the manufacturer and
placed in a hold area.
(2) Shipping papers are compared to purchase orders to determine
if order is correct.
(3) A receipt -inspection checking for marking, material packaging,
damage, dimensions, etc. is then performed.
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(4) If a deficiency is noted a deviation report (DR), noting the
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problem is issued.
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(5) If no deviation is written the material is released to warehouse
personnel and moved from the hold area to the appropriate storage
area until requested.
(6) If a DR is written, the DR is submitted to an engineer who
recommends disposition. This can be to correct a problem, return
to manufacturer, use as is, reject, obtain valid documentation,
etc.
Based on discussions with warehouse personnel and QC receipt inspection
personnel, occasionally material is received by the warehouse without
the appropriate numbers stamped or etched into the pieces. When this
occurs a DR is written and generally the manufacturer sends a
representative to etch or stencil the f aulty pieces. This is done
using the DR corrective action section as the documentation and the
work is witnessed by a QC inspector inspector.
Dac ;f the individuals the alleger identified was the Senior Quality
Control Inspector in charge of receipt, handling and storage of
material in the warehouse at that time. His function is to assure the
work was performed in accordance with the documentation provided. This
person was interviewed by the inspector. He frequently observed the
marking process, and ensured that ill work was done by appropriate
paperwork. No substantiation that this allegation was or was not valid
could be obtained.
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The inspector also interviewed the individual that accompanied the
alleger. He had worked in the warehouse for several years. He stated
that the only stenciling or marking of any material that he was aware
of was performed in accordance with the required documentation. The
statement, "they were doing something that they were not supposed to be
doing", could not be substantiated by the person identified by the
alleger.
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The inspector concludes that the alleger did observe workers stenciling ,j
small bore pipe, but that it was done in accordance with controlled !
documentation and under direct observation of a senior quality control ;
inspector. No indications could be identified that this process was :
unacceptable. The remarks by the accompanying individual with the
alleger and the worker doing the stenciling could not be substantiated i
but could have been stated in a joking manner. ,
Cnrclusion !
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Based on this review, this concern is closed.
b. Allegation RII-85-A-0016-024 Concerning Certification of NDE Inspectors
Without Required Training.
Concern
An alleger stated that a senior civil inspector said that in the old
days he and several other inspectors walked into the training building
one day and the GPC instructors told them that they were NDE inspectors
and gave them certification cards. This senior civil inspector also
told the alleger that the inspectors did not receive any training and
that they were instantly certified for the job. This civil inspector
also made a joke of the situation by saying that they were so good that
they did not need any training. The alleger stated that this occurred
sometime during the period of 1977 to 1978. The alleger also stated a
concern that many of the individuals are senior inspectors today and
identified four additional senior individuals that may have received
certifications in the manner stated above.
Discussion
The inspector reviewed the training records for each of the individuals
identified in the allegation. These records provide dates of classroom
instructions and examinations given for each of these persons. The
examinations appear to be in the handwriting of each individual
concerned based on comparison with other documents in the training
records. Resumes of experience and educational requirements were also
reviewed. Records indicate that training was provided and subsequent
testing given to all of these persons. The inspector also reviewed
records of several other senior inspectors and found no indications
that ...ual training and testing was not provided.
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In addition to the review of training records, the inspector
interviewed the senior civil inspector and three of the other senior
inspectors identified in this allegation. Each stated that they had
received the appropriate training either at Vogtle or at the Hatch
Nuclear Stations.
Conclusion
The inspector can find no information to substantiate this allegation.
Based on this inspection this item is closed.
c. Allegation Ril-85-A-0016-012 Concerning Turnover of Systems to
Production With Open Deviation Reports
Concern
An alleger stated that while in charge of putting Deviation Reports
(DR) on the computer for tracking purposes, an open DR was identified
for a system that had already been turned over to production the day
before. The OR was associated with a piping system (either 2301, 2304,
2401 or 2403). The alleger also stated that the procedure requires the
system to be completely ready when it is turned over to production. In
addition to the DR, there was also a CWR (Construction Work Request)
open on the DR. The alleger stated the matter was reported to an
individual (presumably the alleger's supervisor) and that this
individual did not provide any information about the DR. The alleger
could not recall what the OR pertained to. The alleger said the DR was
sent to Bechtel as required. The alleger expressed concern that the DR
system had broken down in this case because the piping system in
question should not have been turned over to production with an open
OR. The alleger feels that this was an admi~nistrative oversight on
someone's part. The alleger also stated that the supervisor said the
OR was not important and not to worry about it. The alleger stated
that these concerns are still ongoing at the i l ant.
Discussion
The inspector reviewed the licensee's programs for turnover of systems
to production. These programs are detailed in Construction Procedure
GO-A-48, Nuclear Construction System Turnover and SUM-9 System
Turnover. GD-A-48 revision 0 was not issued until 7/26/85 so at the
time of this allegation construction was using SUM-9, revisions 0, 1,
2, 3 or 4 for preparing a system or portion thereof for turnover to
production. SUM-9 revisions 0 through the present revision 9, were
reviewed by the inspector. SUM 9 requires that for a turnover all work
is to be complete or documented in the turnover packaged. This allows
for minor work and documentation to still be open at the time of
turnover. The production review process then identifies which of these
items must be worked prior to production acceptance of the turnover
package. Since this process is a collection of known status items any
subsequent work or deficiencies identified would be handled by programs
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outside this turnover process. Deficiencies that are identified during
the period of time from when construction provides the turnover package
to production and production accepts the turnover (generally about I
week average), a construction completion engineer will meet with the
system startup engineer and add any deficiency (pen and ink change) to
the system punchlist (MTS) or replace the MTS with an updated MTS
containing the new deficiency. If a pen and ink change was made the
MTS, the computer is also updated to track the deficiency. Since a CWR
was written to correct the DR, it would not be tracked since there is
no reason to track two items, when tracking either will accomplish
statuing. The DR process is independent of the turnover process so
even if the DR was not identified on the turnover list, the DR would
have been cleared due to its own program. When the turnover has been
accepted by production, the system or portion thereof, is posted using
green jurisdictional tags to preclude any work unless the work is
allowed by production personnel.
The inspector also interviewed the individual identified by the alleger
as the person with whom the discussion regarding the DR took place.
This individual stated that in the early stages of the initial
turnovers to production, occasionally information was inadvertently not
included in the packages. The packages were updated by issue of a
revised package or pen and ink changes before final package acceptance
by production. This individual and other construction and productions
personnel interviewed by the inspector could not identify any case
where a temporarily misplaced or overlooked item caused a subsequent
rejection by production of the turnover package. Construction
determined in July 1985, that SUM-9 did not fully meet their needs and
generated a procedure (GD-A-48) to improve this process.
The inspector reviewed all turnover packages for systems 2301, 2304,
2401 and 2403. Since this allegation occurred prior to January 1985,
all turnovers associated with these systems af ter March 1985 were not
reviewed in depth. This eliminated systems 2304 and 2403. The
turnover packages associated with system 2301 prior to March 1985,
identified that pen and ink changes were made to MTS prior to final
acceptance by production of the package. The turnover packages
associated with system 2401 also identified a DR that had been added as
a pen and ink change prior to final acceptance. The open DR was sent
to Bechtel for resolution which is the normal process for DR's.
Conclusion
Although a DR was identified af ter a system has been turned over to
production, this does not indicate a breakdown in the turnover process.
The turnover process allows DR's and other items to be open at the time
the system is accepted by production. It does appear that this was an
administrative oversight but also appears to be an isolated case.
Since the DR was not identified it could not be determined that the
open DR was the same DR as shown with the pen and ink change in system
2401, only that the system described was being used at that time. It
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also does not appear that the OR system broke down since the OR was
sent to Bechtel for resolution. Although procedures have been revised
to minimize the oversight that occurred, programs are in place and
appear to be t'rking to correct any oversight that is identified.
Based on this review this item is closed,
d. Allegation Ril-84-0169-005, Concerns Regarding Pipe Break Restraints
(PBR) Repairs in Unit 2 Containment Building
Concern
An alleger stated that some PBR's in Unit 2 containment building had
accidentally been cut off by construction personnel. These PBR's were
to be repaired with additional structural steel sections using a
welding process which required the welds to be radiographed. The
alleger stated that the crew assigned to perform this work on the north
side of containment was not the same crew that repaired the PBR's on
the southeast side of containment.
The crew working the north side repairs had difficulty getting the
welds to pass the required radiographic inspections. The alleger
stated a concern that the crew was removed because they were taking too
long to repair the' PBR's and that the supervisor of the crews could get
the "B" shif t Quality Control to sign them of f without having to go
l through all the problems that the original crew experienced. The
alleger stated a concern that the PBR's on the southeast side of
containment were not properly installed or radiographed.
Discussion
The inspector investigated this cancern. Six pipe whip restraints were
inadvertently cut as identified in Deviation Report (OR) CD-2974 dated
Jan. 3, 1983. The disposition of this DR was, in part, to fabricate
new pieces, weld to existing stubs and perform radiographic inspections
of all new welds. Records of repairs to these six PBR's (three on the
north side of containment and three on the south side) indicate one
weld joint on one of the PBR's on the north side was rejected and
reworked two times before final acceptance. These failures were due to
excessive porosity. The PBR repairs on the south side of containment
showed one weld on two of the PBR's as having one weld rejected twice
and the third PBR had one weld rejected three times before final
acceptance. These were also due to excessive porosity.
Conclusion
The inspector concludes that the PBR's were properly repaired and
radiographed as specified in the corrective actions defined in the DR.
There appears no evidence that supports an implication that Quality
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Control was not adequately maintained since seven weld failures
occurred during repairs on the PBR's in the south side of containment
as compared to two failures in the north side of containment. Pased on
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this inspection, the inspector could not substantiate improper work
practices nor improper quality control personnel practices and thus
considers this item as closed.
e. Allegation RII-84-0169-10 and 12, QA/QC Record Keeping Practices Are
Inadequate for the Program.
Concern
An alleger stated that the Pullman Power Products (PPP) QC/QA record
keeping program is a shambles, that PPP will always rush to file and
update records when they find out that they are going to be audited,
and that a mistake is made when PPP is advised that an audit will be
conducted. The alleger further stated that the alleger heard that the
i PPP QA/QC paper work is so messed up that they will never be able to
get it straight, that documents are misfiled and that the records are
generally in very poor shape. .
Discussion
The licensee cortforms to ANSI N45.2.12 " Requirements For Auditing of QA
Programs for Nuclear Power Plants" in which paragraph 4.2.4 " Audit
Notification" states, " Involved organizations shall be notified of a
scheduled audit a reasonable time before the audit is to be performed."
The licensee generally provides a 3 to 7 day notification for their
required audits. The NRC also conducts routine audits of all licensees
and most f these audits are unannounced.
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Various audits have been performed by the licensee of the PPP QA/QC
record keeping- program and concluded no significant findings. In
addition, the NRC has performed audits of PPP's QA/QC documents
including welding documents and found them to be acceptable. The
inspectors reviewed the licensee's audits of PPP's QA/QC records
program as well as those performed by the NRC.
The Inspector reviewed various PPP QA/QC documents including welding
documents and found them to be acceptable. The Inspectors reviewed the
licensee's audits of PPP's QA/QC records program as well as those
performed by the NRC.
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Conclusion
This allegation was very general with no specific information
available. The inspectors reviewed the areas of concern in detail and
could not substantiate the allegation. Based on this investigation
this item is closed.
f. Allegation RII-84-0169-11, Excessive Heat Used During the Welding of
Pipe Break Restraint (PBR) Racks to Embed Plates.
! Concern
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An alleger stated that in Unit 1 containment too much heat was used
during the welding of PBR racks to embed plates. This individual felt
that the proper procedure was not used and that this resulted in a
large number of nonconforming reports (NCR's) being written because of
the overheating during welding.
Discussion
PBR's, at the Vogtle plant have been deleted with NRC approval,
therefore welding associated with these restraints would not constitute
a safety problem. The inspector has concluded that the welding that
was identified by the alleger was performed on pipe rack welds which
are commonly referred to as PBR's. Since this conclusion was reached ;
by the inspector, an investigation into welding problems identified ;
that there had been procedure and heat related problems associated with 4
these components. They were identified to the NRC Region II as a Part i
10 CFR 21 Reportable Item (CDR 84-66) in correspondence dated October ,l
17 and October 31, 1984. The corrective action identified in CDR 84-66 i
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was discussed in NRC Inspection Reports 50-424/84-30, 50-424/84-36,
50-424/85-03, 50-424/85-08, and 50-424/85-40. This CDR was closed by l ,
region based inspectors in report 50-424/85-40.
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Conclusion {
This allegation appears to have been associated with pipe. rack welds i
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rather than pipe break restraints. This problem was identified by the
utility through their 10 CFR 21 reporting process. The problem was
reviewed in detail by region based inspection personnel and addressed
by NRC in various reports identified above. Based on this
investigation the inspector considers this item as closed.
g. Allegation RII-84-0169-14, Concern That Pullman Procedure 32-III Is Not
A Qualified Procedure.
Concern
An alleger was told by an individual from Westinghouse that if the
fitup of the hot legs on either end was made land to land that the weld
procedure would not be qualified. This weld procedure (WPS) was
identified as (W)32-111. The alleger further stated that after
several discussions with other personnel the question of WPS 32-III
appeared to be resolved and that the procedure was qualified. The
fitup of the hot legs were made land to land. The alleger stated that
several days later the hot leg fitup was nodified to accept a K-insert
and based information on this the alleger concluded that procedure WPS
32-III was, in fact, not qualified.
Discussion
Procedure WPS 32-III was reviewed by a NRC welding inspector and
addressed in Inspection Report No. 50-424 & 425/85-11 dated April 8,
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1985. Discussion with the Westinghouse engineer that made this
statement to the alleger determined that he agreed with the inspector
that the procedure was qualified. The previous di!cussions between the
Westinghouse engineer and the alleger appears to have been a
communication problem. Discussion with additional personnel on site
indicate that the preferred method of this weld is with a consumable
insert. The hot legs were repositioned to accept a K insert. The
inspector reviewed all hot leg piping weld joint records for both units
and identified that inserts were used on each weld.
Conclusion
Welding procedure WPS32-111 is a qualified procedure. The omission or
addition of a consumable insert is not an essential variable in welding
procedure specifications but it is an essential variable on welders'
performance. Since the hot legs all had inserts installed the question
concerning land to land fitup is not applicable.
h. Allegation RII-84-A-0169-015, Concern That Repair of Hole In Weld
Repaired By An Individual That Was Not Certified And Not Properly
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Documented.
Concern
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l An alleger, while working with another individual in containment,
l stated that they observed a crew working on primary system piping. The
l alleger saw a supervisor perform some unauthorized welding. This
l welding occurred on a pipe being fit for automatic welding. A problem
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had apparently developed and the alleger observed the supervisor grab a
! welding torch and perform a manual butt weld. The alleger thought the
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weld was on the hot leg or cold leg on Unit 1 between the steam
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generator and reactor vessel. The alleger also identified the second
individual that witnessed this occurrence. Region II personnel
contacted this second individual. The second individual identified the
same observance except identified that the pipe was on the surge line
from the pressurizer to the hot leg and that this weld was the first
weld outside the wall east of the pressurizer.
Discussion
The inspector contacted the alleger and discussed the conversation
between Region 11 personnel and the second individual. The alleger
concurred that the weld was on the surge line from the pressurizer to
the hot leg. The inspector pulled all weld records for each weld on
this surge line and performed a review of this documentation. This
review indicated that two of the weld joints during fitup and root pass
welding were rejected and had to be cut out and rewelded. A third weld l
was rejected af ter final welding and had a portion of the weld ground l
out and rewelding performed. Each weld on this line was subsequently
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radiographed and found acceptable and also pressure tested during the
primary system hydrostatic test Records indicated that the welders
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performing these welds were certified and that supervisor was not
listed as assisting in the weld process.
Conclusion
Based on this inspection, the inspector considers that the weld joints
on the surge line between the pressurizer and the hot leg meet required
specifications. The concerns associated with the supervisor performing
work will be addressed in a subsequent report.
1. Allegation RII-83-A-0103, Alleged Falsification of Non Destructive
Examination (NDE) Documentation by a Quality Control (QC) Inspector.
Concern
A QC-NDE inspector was terminated for allegedly falsifying Liquid
Penetrant (LP) inspection reports. The individual was terminated from
employment on 4/18/84 after being confronted by Pullman Power Products
(PPP) management to point out location of welds recently inspected and
then not being able to do so.
Discussion
The inspector conducted a review of PPP's interoffice correspondence
which documented their justification for terminating the subject
individual for misconduct in preparing and submitting incorrect Quality
Assurance (QA) records falsely indicating that he had performed certain
tests.
The inspector followed and reviewed the PPP and GPC reinspection
program for the subject inspector's work. This review consisted of
reviewing interoffice correspondence which documented the status and
findings of the reinspection program at various phases during the
reinspection process, reviewing Liquid Penetrant examination records
documenting the reinspection of ISO / Weld No's. 2K3-2303-007-04/
A007-W-13A; IK3-1592-041-01/041-W-110; IJ7-1592-060-01/W:
IJ7-1592-060-01/U; IK4-1208-488-03/B; IK4-1203-488-03/A;
IK2-1592-111-01/111-W-120; IK2-1202-134-03/134-W-354 and
2K2-1592-007-02/007-W-15; and reviewing Deviation Report No's. PP-4654
and PP-5255 which documented to rework or repair as required the
deficient conditions identified during the reinspection program.
This matter was also identified by the licensee as a potential
reportable Deficiency No. CDR M-62 on April 24, 1984. Subsequently,
the final report was submitted on April 18, 1985 which documented the
licensee's evaluation of this matter as not reportable pursuant to the
requirements of 10 CF 21 and 10 CFR 50.55(e). This item was reviewed
and closed in Inspection Report No's. 50-424/86-60 and 50-425/86-27.
Conclusion
_
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13
The licensee identified all welds inspected by the subject individual
during period of employment from 1/7/82 to 4/18/84. This list
consisted of safety and non safety-related piping welds in accordance
with ASME and ANSI B31.1 Power Piping Codes as applicable. After
conducting several random sampling plan reinspections per Mil-STD-1050
the licensee decided to reinspect 100% of all accessible ASME welds
requiring LP inspection by Code (i.e. ASME Code Class 3 2" and smaller
- and ANSI B31.1 welds which were originally LP inspected were not
reinspected as apart of the reinspection program since they are not
required to be inspected initially in accordance with the Code) by this
individual. This was documented in a letter by the Unit 1 PPP QA
Manager dated 5/29/86. The licensee also identified other inspections
conducted by this individual which consisted of Ultrasonic Testing for
thickness measurements. A reinspection program per Mil-Std-105D was
implemented by PPP and the results were found to be acceptable. Based
on a review of the licensee's reinspection program, the inspector
concludes that the licensee's corrective action is acceptable,
I therefore, this concern is considered closed.
l
l j. Allegation RII-84-A-3128, Employee Concern Regarding Installation of
Ventilation Ducts.
'
Concern
During an audit of the licensee's Quality Concern program in May of
1984 the Senior Resident Inspector reviewed a Quality Concern file
which documented several concerns expressed by an employee during the
individual's exit interview. The employee's concern was that there was
improper workmanship used in the installation of ventilation ducts.
Details of the employee's concerns were contained in a ten (10) volume
notebook diary kept by the individual while employed at Vogtle.
Discussion
-
The licensee Quality Concern File No. 84V036 documented their
investigation into these concerns. The licensee contacted the former
employee after the exit interview in order to obtain a deposition and a
copy of the employee's ten (10) volume notebook diary. After a
comprehensive review of this material the licensee categorized
twenty-five (25) concerns of which at least three (3) were gleaned from
the employee's comments contained in the diary. GPC Ouality Assurance
Department investigated all of the concerns except for six (6) which
were investigated by the Quality Concern program.
The inspector conducted a review of all twenty-five (25) concerns
identified in the licensee's Quality Concern file. From this review
the inspector determined that eleven (11) of the concerns had been
previously identified and documented by either GPC via a Deviation
Report or an Audit Finding Report or the HVAC subcontractor via a
Non-Conformance Report (NCR) or a Corrective Action Request. Thirteen
(13) of the concerns were not found to be a concern since they were
.=
14
determined .either to be not a requirement, not a quality related
matter, .not substantiated, in compliance with approved procedures, or
adequate procedures were verified to be in place and compliance was
established by QA audits; and one (1) concern which was substantiated
was subsequently identified by a Deviation Report and a Corrective
Action Request.
The inspector conducted a review of the following documents to verify
that appropriate corrective action had been taken to resolve the
identified concerns: Deviation Report No's. MD-4877 (NCR-363), MD-4878
(NCR-368), CD-6899, MD-4056, and MD-4061; Audit Report / Audit Finding
Report ( AFR) No's. 84-1-QC, MO 08-83/29 (AFR No. 422), MD 08-83/69 ( AFR
No. 489), and AFR No. 341; Corrective Action Request No's. 17, 19, 20
and 23; Procedure No's. JP 3.3, JP 10.11, JP 13.3, JP 14.2, JP 15.1, JP
15.2, GO-A-06, GD-T-11, Specification No. X4AJ0-1, Division H-9; and
Potential Reportable Construction Deficiency Report No. 43, which was
subsequently determined not to be reportable.
Conclusion ,
The inspector has completed the NRC's review and follow-up to the
licensee's completed Quality Concern File No. 84V036. Based on this
review the inspector has concluded that the licensee has conducted a
comprehensive investigation into the concerns identified in Quality
Concern File No. 84V036. In Addition, where applicable, appropriate
corrective action was identified by the licensee. Based on the above.
the Resident Inspector's follow-up to Quality Concern File No. 84V036
is considered to be complete, therefore the item is closed.
k. Allegation RII-85-A-0210, Quality Control (QC) Inspector Alleges
Himself Unqualified and Questions Invalidation of Deviation Report (DR)
No. EO-10337.
Concern
On October 15, 1985 a QC Electrical Anchor Bolt Inspector at Vogtle
Electric Generating Plant filed the following allegations with the
Resident Inspector's of fice. The alleger stated that he has been
certified by the licensee as a Level II QC Electrical Anchor Bolt
inspector in accordance with ANSI N45.2.6 even though in his opinion be
does not have the required past experience in this field (i.e. , Anchor
Bolt Installation Inspection). Also, the alleger expressed a concern
regarding the justification given for invalidating DR No. E0-10337
since he feels it does not address the deviation noted.
Discussion
GPC Field Procedure Manual Procedure No. QC-A-01 " Qualification and
Certification of Technical Inspectors" establishes the GPC Quality
Control Program for qualification, certification, and training of
personnel who perform inspection. examination, and/or testing to verify
1
)
,
15
conformance to specified requirements during construction. This
procedure was written to comply with ANSI N45.2.6 (1978) and Regulatory
Guide 1,58 (September, 1980).
The inspector conducted a review of the alleger's Certification of
Qualification Record consisting of the individual's resume of prior
experience, supervisor's report of job experience, training completion
record, experience waiver, and eye examination. The supervisor's
report of job experience documented the fact that the individual
satisfied the experience and/or on-the-job training requirements for
certification in the area specified and at the designated level. The
training completion record documented the successful completion of all
required courses (i.e., general, specific, and practical). The
experience waiver documented that the individual did not meet the
minimum experience levels and that the required academic curriculum and
demonstration of the knowledge and skill necessary for performance at
the level for which the individual is certifying to be satisfactory by
performance.
The inspector questioned why the supervisor's report of job experience
documented that the inspector had the required experienc'e and than at a
later date an experience waiver was completed to document that the
individual did not have the required experience. The licensee stated
that as a result of an audit they were requested to verify experience
by contacting previous employers. During this review it was determined
that not all job sites contacted could or would release information to
verify this individual's previous employment. As a result an
experience waiver was completed and placed in the individual's file in
accordance with Procedure QC-A-01. Subsequently, the licensee has
contacted the individual's previous employer who was able to verify the
individual's previous experience at various job sites, consequently,
the subject individual did in fact meet the experience requirement as
originally stated in the suservisor's report of job experience. The
prcblem associated with the initial attempt failing to verify all of
the individual's previous experience was due to the licensee contacting
the various job sites that the individual worked at in lieu of
contacting his previous employer directly.
The inspector conducted a review of DR No. E0-10337. The discrepant
condition noted by the QC Inspector was that the edge distance on 3/4"
and 1" Type 14 conduit supports was not in compliance with GPC Field
l Procedure Manual Procedure No. GD-T-27. The DR was invalidated since
the spacing ar.d edge distance for these supports was determined by
applicable design drawings in lieu of GO-T-27. The inspector conducted
a review of the applicable Design Drawing No's, AX2094V050 and
AX2094051 which detailed conduit support type 14 installation criteria.
This detail refers you to Note 27 which states in part conduit shall be
attached to supports with the appropriate sized P2558 pipe strap and
bolting hardware. Refer to Unistrut General Engineering Catalog for
hardware detail.
!
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16
A review wa's conducted of the - manufacturer's standard sizes and
dimensions against those stated in the DR to determine that the conduit
pipe straps were in compliance. It should be noted that Procedure No.
GO-T-27 states "In case of disagreement between this procedure and the
specification or design drawings, the specification or design drawings
govern". The requirements contained in GD-T-27, Exhibit 1 are from
Bechtel Specification X2AP01 which are for normal face-mounted plates.
In this case, the design drawing which overrides the specification and
procedure specifies the use of Unistrut P2558 straps therefore Exhibit
1 of GD-T-27 is not applicable for this installation.
The inspector also conducted a review of the licensee's Quality Concern
File No. 85V0492 which documents their investigation of the same
concern. This review verified that the licensee conducted a meaningful
investigation of the alleger's concerns.
Conclusion ,
I
The inspector's review of the alleger's certification file revealed i
that he was certified in accordance with Procedure QC-A-01 and did in
fact meet the previous experience requirements as required by the .
Regulatory Guide and the ANSI Standard. Also, a review of DR No. ED !
10377 revealed that the deviation noted by the QC Inspector was in fact t
properly addressed as not a deviation. Based on the above, this j
allegation is considered to be unsubstantiated and is therefore j
considered to be closed. '
i
1. Allegation RII-86-A-0192, Instructions to Workers by General Foreman '
_
and Foreman Caused Workers to Violate Procedures.
Concern .
The alleger accompanied by a Pullman Power Products (PPP)
Administrative Manager and a PPP Union Steward came to the NRC Resident
- Inspector's Of fice on June 16, 1986 with the following information
j The alleger and co worker were given a job by their general foreman and
>
foreman to remove two stainless steel flanges. The general foreman
,
told them to remove the flanges and cover the openings with duct tape.
The flanges were to be taken with engineer's accompaniment to the
j' nuclear warehouse. The workers were also told that a clearance was not
needed. The workers went to the work area and removed the first
flange. At that point the foreman arrived and told the workers to
discontinue the work because PPP Quality Control inspection (QC) and
'
Georgia Power Company (GPC) Operations was needed. The forer.an stated
that QC was on the way to the job site. The PPP QC inspector arrived
- to check the work. The inspector stated a hanger interfered with the
removal of the second flange and additional paperwork would be
i required. The allegers co-worker took the first flange to the foreman
and on to the warehouse while the alleger went to turn in his tools and
'
then to the rest room. Upon Iaaving the rest room the foreman
l Intercepted the alleger and stated that the foreman had gone to the
I
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< _ _ _
_ _ _ _ _ _____ ___ __ _
17
work area and the workers were not there and that the GPC engineer was
there inspecting the work. The alleger was terminated the next day for
performance of work in an unsatisfactory manner. The alleger feels
that this action was inappropriate in that the foreman and general
foreman instructed the workers to violate procedures.
Discussion
The inspector reviewed the work documentation associated with this
item. GPC procedures and PPPprocedures were in control of this work.
PPP procedure XIII-4, Cleaning Procedure Section 9.7 states " Pullman l
Power Products QC (and GPC Nuclear Operations Personnel, if required by
^
the MWO) will perform the initial system entry cleanliness inspection".
A review of MWO 18607436 did not identify that GPC personnel were
required to perform this inspection. The foreman contacted GPC
personnel to determine if they wanted to perform this activity. GPC
opted to perform the inspection and the foreman states this information
was given to the workers. Based on this inspection there was no
procedure violation. l
)
Conclusion ;
,
There is no information to substantiate the alleger's statement that
procedures were violated. The remainder of the information provided by
the alleger appears to be a dispute between the employee and employer '
which is not an area that is addressed by the NRC. Based on this
inspection this item is closed.
m. Allegation RII-85-A-0230-01, Improper Welding Practices.
Concesa
Hangers on Loop 4 in Containment Building, Unit I were fabricated on
some steel incorrectly, and hangers were subsequently moved two (2)
times in an effort to correct the situation. Alleger feels the
mistakes were never corrected in spite of the two (2) additional
movements of the hangers.
Discussion
The inspector confirmed through discussions with the alleger's foreman
that the supports being questioned are identified as TS-1, 2, & 3 which
support the Reactor Vessel Level Inst: urnentation System (RVLIS)
Instrumentation Tubing Sensor Barrier Box and Valve Barrier Box. The
inspector reviewed the applicable drawing No. 1X5DPM713 depicting the
supports design and the documentation package which reflected that the
supports were reworked as a result of a design change and interferences
encountered in the field during installation. The inspector verified
that the reworks were properly documented and processed by Field Change
i Requests.
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l
Conclusion
Otscussions held with the foreman and Lead Instrumentation Engineer '
confirmed that_during the installation of the subject supports several
reworks were encountered as a result of design changes necessitated as
a result of conditions encountered in the field. In conclusion, the
inspector's review of this concern revealed that the subject supports
were installed in accordance with applicable design drawings and the
documentation package adequately documented the reworks as a result of
Field Change Requests. The hanger interferences encountered are
considered to be normal during the installation process of a project of
this magnitude therefore additonal corrective action was not required
or necessary.
Based on the above review this allegation was determined to be without
substance since there was no evidence found where steel was fabricated
incorrectly, nor were mistakes found to be not corrected. This item is
is considered closed.
n. Allegation RII-85-A-0230-02, Improper Welding Practices.
Concern
" Welders tacked these hangers up without pre-heating at all, and this
was done on the foreman's order."
Discussion
Discussions with the alleger's foreman revealed that the
instrumentation crew was aware of the preheating requirement when
welding a support to structural steel which is greater than 1-1/2
inches but did not realize that trik requirement (preheat) was also
applicable on tack welds. The foremar, stated that once he became aware
of this requirement by Quality Control he did not instruct any welders
to make tack welds without preheat.
The inspector conducted a review of 3PC Quality Concern File No.
85V0582 to review the alleger's allega. ion submitted to the licensee in
this area. The alleger identified Support No. ILT-503-M017-H12 to the
licensee as one which was tack welded without preheat. The inspector
reviewed the licensee's corrective action to this concern which
consisted of the following:
1) Deviation Report No. 10-1532 was written to document the
deficiency.
2) Construction Work Request No. 1-1259 os written to remove
Support No. ILT-503-M017-H12 and re-weld documenting the
preheat.
L
s. 19
3) Development of an inspection plan identified as Attachment AA
to -- GPC letter dated May 16, 1986 which documented the
licensee's re-inspection of hangers tack welded to structural
steel greater than 1-1/2 inches without preheat per
MIL-STD-1050. Results were satisfactory.
In additon, the alleger identified to the itcensee an additional hanger
(no identification number was reported by the submitter) to have also
been installed without preheat. This hanger consisting of two pieces
of tube steel was located on Unit 1 Containment, C-level, Loop 4 area.
The inspector confirmed through discussions with the alleger's foreman
that the hanger in question is identified as TS 1, 2, & 3. As noted in
Allegation No. RII-85-A-0230-01 these supports were reworked several
times due to design changes and interferences. The inspector reviewed
the documentation package for the installation of their supports which
documented that the tack welds were preneated.
During the licensee's investigation into this matter it was determined
that a procedure violation had occurred in that Pullman Power Products
Procedure No. IX-43 requires tack welds to be preheated. It was
further determined that this violation was a result of the
instrumentation crew not being properly trained in the requirements
contained in Pullman Power Procedure IX-43 pertaining to preheating
tack welds. Corrective action to prevent recurrence of this problem in
the future consisted of a development of procedure awareness among the
appropriate-perscqnel regarding the preheat requirement. The inspector
'
conducted several random interviews of instrumentation personnel to
i
verify that they are aware of the requirement to preheat tack welds on
support steel greater than 1-1/2 inches. This included the alleger's
foreman. This catter will not be cited as a violation since the
licensee identified this violation during their investigation into the
,
alleger's concerns and took the appropriate corrective action.
'Conclusicn
,
Based on the above review this allegation was determined to be
substantiated. The inspector verified that the licensee took the
appropriate corrective action to repair the identified supports, to
confirm that the existing instrurrent hangers installed without preheat
to tack welds were satisfactory by performing additional inspections
which exceeded original requirements in accordance with a sample plan
per MIL-STO-1050 and to train instrumentation crew in the requirement
of preheat tack welds per Pullman Power Procedure IX-43.
o. Allegation RIl-85-A-0230-03, improper Welding Practices.
Concern
The steel where the aforementioned hangers were welded was never
"magged".
- _ _ - _ - _ _ _ _ _ _ . _ _ _ _ .
=
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Discussions i
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.
! i. l
The' steel- to which the hangers are attached is identified as the
-
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'
'
containment pipe racks. These racks have been designed in accordance {
with the 'American Institute of Steel Constructioo(AISC) Manual. The l'
inspection criteria applied- to these pipe racks- comes out :of the i-
'
- American Welding . Society (AWS) D1.1 Structural Welding Code which
requires visual inspection of welds unless otherwise .specified by the .
-
engineer. In the case of the containment pipe racks the engineer has J"
specified . visual inspection as the acceptable , criteria. Magnetic A
particles inspection (mag) is ' not- requirmi. -
,
. Conclusion 4
s ,
+
Based on the-inspector's review this Lallegation was determined to bc ;
without substance, therefore this item is considered to be closed. l
" ^
p. Allegation RII-85-A-0230-04, Improper Welding Practices.
Concern
e.
'
y'
'
Alleger stated that alleger was told by a gener21 foreman to scribe the
alleger's welder number on stainless steel pipe even though alleger did
not perform the welding; and that the general foreman ordering this I
scribing knew the alleger did not do the welds. This scrib.e appears on i
reactor cooling = stainless steel piping located at Level C, Unit 1 l
. Containment Building, in a room marked 1W4, Column #27. '
- ,
,
Discussion o !
, The inspector conducted a review of GPC Quality Concern Program File
No. 85V0582 to review the alleger's allegation submitted to the .
licensee in this area. The alleger's co-worker identified Weld No. 19
on Isometric Drawing No. ISK5Y01003-A to the licensee as the weld in
'
question. The weld is on the low pressure side of the isolation valve
No. 1-1901-X4-091 to Level Transmitter No. ILT-1003 associated with the
Reactor Coolant Drain Tank 1-1901-T6-001. The applicable code is ANSI
B31.l Power Piping Code. Interviews conducted with the alleger's c
foreman, co-worker, and Quality Assurance personneE revealed that the
all.eger's co-worker was assigned the task to stenci) the subject weld
with the appropriate welder's symbol. This was necessitated since the ,
weld was found to be without a stencil and the welder who performed the
,
weld was no longer on site. The method utilized by Pullman to
determine the correct welder was to review the well rod ticket which
identified the welder's name and symbol. This was determined to be an
unwritten policy. Subsequently, Pullman has revised 'th<tir Procedure
GWS III/I, Paragraph 7.2.7 to clarify the weld stencil requirements.
The inspector conducted a review of the weld rod ticket for Weld No. 19
for Isometric Drawing ISKYSY01003-A which identified the welder who
made the weld. Also a review of the Isometric Drawing ISKY501033-A was
t
5>
w_ ~
$
, -.
9, , . - ___ ._ .___
a. -[
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conducted which showed the location of the weld to be in Room No. RC-07
in Unit 1 Containment Level C.
Conclusion
3
Based on the above review of this allegation, this item was determined
'
to be without substance in that the alleger's co-worker was requested
to place the appropriate welder's symbol on a weld since the welder who
performed the weld was no longer on site. The method described above.
-1.e. to restencil a weld with the correct welders symbol through
'
'
confirmation of the weld rod ticket, is considered to be an acceptable
practice when it is determined that the welder is no longer on site.
p Therefore, this item is considered to be closed.
t,
!t q. Allegation RII-85-A-0230-05, Improper Welding Practices.
~
Concern
Alleger was terminated for insubordination. Alleger stated that the
reasons for the act of insubordination and subsequent firing involved
the way jobs were being performed at Vogtle contradictory to Quality
Assurance requirements. Alleger stated that after informing the GPC
Quality Concerns Program of alleger's concerns, there were no visible
results and no one has even talked with alleger's co-workers about the
, concerns.
s
Discussion
The inspector has conducted several inspections of the licensee's
Quality Concern File No. 85V0582 which documented the alleger's
concerns, the licensee's investigation of the concerns, and the
response mailed to the alleger to address each concern. These reviews
are documented in Inspection Report No's. 50-424/86-09 and 50-425/86-04
and 50-424/86-60 and 50-425/86-27.
Conclusion
f
Based on the inspector's review of the alleger's allegations and the
licensee's Quality Concern File No. 85V0582 this allegation was
determined to be without substance. The inspector found that the
$'- license did in fact actively pursue and investigate all of the
4 alleger's concerns. In addition, the alleger's allegations did not
'k reveal any evidence where work was being performed at Vogtle
intentfodally ontradictory to Quality Assurance requirements, did
interview co-workers, and did contact the alleger with results,
therefore this item is considered to be closed.
6. General Construction Inspection - Units 1 & 2
i
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Periodic random surveillance inspections were made throughout this reporting .l
period in the form of general type inspections in different areas of both i.
facilities. The areas were selected on the basis of the scheduled
activities and were varied to provide wide coverage. Observations were made
of activities in progress to note defective items or items of noncompliance
with the required codes and regulatory requirements. On these inspections,
particular note was made of the presence of quality control inspectors, i
supervisors, and quality control evidence in the form of available process ;
sheets, drawings, material identification, material protection, performance i
of tests, and housekeeping. Interviews were conducted with craft personnel, l
- supervisors, coordinators, quality control inspectors, and others as they !
were available in the work areas. The inspector reviewed numerous !
construction deviation reports to determine if requirements were met in the j
areas of documentation, action to resolve, justification, and approval i
signatures in accordance with GPC Field Procedure No. GD-T-01. !
!
No violations or deviations were identified.
7. Fire Prevention / Protection and Housekeeping Measures - Units 1 & 2 (42051C) j
The inspector observsd fire prevention / protection measures throughout the
inspection period. Welders were using welding permits with fire watches and l
,: extinguishers.- Post indicator valves were being maintained in the open i
t
position. Fire fighting equipment is in its designated areas throughout the
,
plant. <
'
>
The inspector reviewed and examined portions of the following procedures
pertaining to the fire prevention / protection measures and housekeeping
measures to determine whether they comply with applicable codes, standards,
NRC Regulatory Guides and licensee commitments.
-SD-T-05, Rev. 6 Fire-Protection Equipment Inspection and Testing
-GD-T-15, Rev. 6 Welding and Cutting
-GD-T-17, Rev. 5 Housekeeping
, The inspector observed fire prevention / protection measures in work areas
containing safety related equipment during the inspection period to verify
the following:
- -
Combustible waste material and rubbish was removed from the work areas
as rapidly as practicable to avoid unnecessary accumulation of
combustibles
-
Flammable liquids are stored in appropriate containers and in
designated areas throughout the plant
-
Cutting and welding operations in progress have been authorized by an
appropriate permit, combustibles have been moved away, or safely
covered, and a fire watch and extinguisher was posted as required
,
p ;--. . . .
23
-
Fire protection / suppression equipment was provided and controlled in
accordance with appilcable requirements
No violations or deviations were identified.
8. Structural Concrete - Unit 2 (47053C)
a. Procedure and Document Review
The inspector reviewed and examined portions of the following
procedures pertaining tc the placement of concrete to determine whether
they comply with applicable codes, standards, NRC Regulatory Guides and
licensee commitments.
-CD-T-02, Rev. 18 Concrete Quality Control
-CD-T-06, Rev. 10 Rebar and Cadweld Quality Cont ,1
-CD-T-07, Rev. 8 Embed Installation and Inspection
b. Installation Activities
The inspector witnessed portions of the concrete placement indicated
below to verify the following:
(1) Forms, Embedment, and Reinforcing Steel Installation
- Forms were properly placed, secure, leak tight and clean.
- Rebar and other embedment installation was installed in
accordance with construction specifications and drawings,
secured, free of concrete and excessive rust, specified
distance from forms, proper on-site rebar bending (where
applicable) and clearances consistent with aggregate size.
(2) Delivery, Placement and Curing
- Preplacement inspection was completed and approved prior
to placement utilizing a Pour Card (Procedure Exhibit
CD-T-02*18).
- Construction joints were prepared as specified.
- Proper mix was specified and delivered.
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- Temperature control of the mix, mating surfaces, and
ambient were monitored.
- Consolidation was performed correctly.
- Testing at placement location was properly performed in
accordance with the acceptance criteria and recorded on a
Concrete Placement Pour Log (Procedure Exhibit CD-T-02*20).
- Adequate crew, equipment and techniques were utilized.
- Inspections during placements were conducted effectively
by a suf ficient number of qualified personnel.
- Curing methcds and temperature was monitored.
(3) Rebar Splicing
.. - - -- - . - , .- -.
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The inspector witnessed . cadwelding operations to veri fy the
following:
i-
- Inspections are performed during and after splicing by
qualified QC inspection personnel.
- Each splice was defined by a unique number consisting
of the bar size, splice. type, the position, the
- operator's-symbol, and a sequential number.
- Process and crews are qualified.
- The sequential _ number and the operator's symbol are
-
marked on all completed cadwelds.
The inspector also conducted random inspections of completed
cadwelds to verify the following:
. - Tap hole does not contain slag, blow out, or porous metal.
-Filler metal was visible at both ends of the splice sleeve
and at the tap hole in the center of the sleeve. No voids
'-
were detected at the ends of the sleeves.
- The sequential number and the operator's symbol are marked
on all completed cadwelds.
- No violations or deviations were identified.
t
9. _ Containment (Prestressing) - Unit 2 (47063C)
a. Procedure and Document Review
The inspector reviewed and examined portions of the following
specification, procedure, and drawings pertaining to the installation
of horizontal tendons, to determine whether they comply with applicable
codes, standards, NRC Regulatory Guides and licensee commitments. ,
!~ - X2AF04 Technical Provisions for Containment
- - Post-Tensioning System
! - AX2AF04-100-13 Field Instruction Manual for Installation
of VSL ES-55 Post-Tensioning System Within
Nuclear Containment Structures, Rev. 9
t
i b. Installation Activities i
i !
The inspector witnessed portions of the installation activities
indicated below to verify the following: ,
- The latest issue (revision) of applicable drawings or procedures
l are available to the installers and were being used. '
i - Tendons were free of nicks, kinks, corrosion; were installed .
L in designated locations; and that the installation sequence
and technique was per specified requirements. l
i
- Installation crew was properly trained and qualified. .
l
l
- ,- v -_-
.__ -
.
25
- OC inspection was properly performed by qualified personnel
in accordance with applicable requirements.
- Adequate protective measures were being taken to ensure
mechanical and corrosion protection during storage, handling,
installation, and post installation.
- Tendons were stressed in the proper sequence.
- All strands in the tendon were moving together during the
stressing and the tendon is being stressed from both ends
simultaneously.
- Elongation measurements were being taken properly and being
compared to the calculated elongation.
- Anchor head lift-off force was being taken and documented
properly.
- The stressing operation was being monitored to identify
any strand slippage.
The following tendons were observed during the inspection period:
Horizontal Buttress
Tendon No's. Activity
5 IS-2W Tendon Installation
6 2E-3E Tendon Installation
11 IS-2W Tendon Installation
No violations or deviations were identified.
10. Containment (Steel Structures and Supports) - Units 2 (48053C)
Periodic inspections were conducted to observe containment steel and support
installation activities in progress, to verify the following:
- Components were being properly handled (included bending or
straightening).
- Specified clearances were being maintained.
- Edge finishes and hole sizes were within tolerances.
- Control, marking, protection and segregation were maintained
during storage.
- Fit-up/ alignment meets the tolerances in the specifications and
drawings.
No violations or deviations were identified.
11. Safety-Related Structures (Structural Steel and Supports) - Units 1 & 2
(48063C)
Periodic inspections were conducted to observe construction activities of
safety-related structures / equipment supports for major equipment outside the
containment to verify that:
-
_
26
- Materials and components were being properly handled to prevent damage.
- Fit-up/ alignment were within tolerances in specifications and drawing.
requirements.
- Bolting was in accordance with specifications and procedures.
- Specified clearances from adjacent components were being met.
No violations or deviations were identified.
12. Reactor Coolant Pressure Boundary and Safety Related Piping - Unit 1 & 2
(49053C) (49063C)
Periodic inspections were conducted to observe construction activities of
the Reactor Coolant Boundary and other safety-related piping installations
inside and outside Containments. Verifications included but were not
limited to the following:
- Material and components were being properly handled and stored
in order to prevent damage.
- Fit-ups and alignments were within tolerances per specifications
. and drawings.
- Specified clearanc(s from pipe to pipe and adjacent components
were met.
- Piping was installed and inspected in accordance with applicable
drawings, specifications, and procedures.
- Those people engaged in the activity are qualified to perform the
applicable function.
- Drawing and specification changes (revisions) are being handled
and used correctly.
No violations or deviations were identified.
13. Reactor Coolant Pressure Boundary and Safety Related Piping Welding - Unit 1
& 2 (55073C) (55083C)
periodic inspections were conducted during daily plant surveillances on
safety-related pipe welding at various stages of weld completion. The
purpose of the inspection was to determine whether the requirements of
applicable specifications, codes, standards, work performance procedures and
QC procedures are being met as follows:
- Work was conducted in accordance with a process sheet which identifies
the weld and its location by system, references procedures or
instructions, and provides for production and QC sign-offs.
- Welding procedures, detailed drawings and instructions, were readily
I available in the immediate work area and technically adequate.for the
,
welds being made.
l - Welding procedure specification (WPS) were in accordance with
!
the applicable Code requirements and that a Procedure Qualification
-
Record (PQR) is referenced and exists for the type of weld being made.
- Base metals, welding filler materials, fluxes, gases, and insert
L
__ 3.
-_
27
materials were of the specified type and grade, have been properly
inspected, tested and were traceable to test reports or certifications.
- Purge and/or shielding gas- flow and composition were as specified in the
welding procedure specification and that protection was provided to
shield the welding operation from adverse environmental conditions.
- Weld joint geometry including pipe wall thickness was specified and that
surfaces to be welded have been prepared, cleaned and inspected in
accordance with applicable procedures or instructions.
- A sufficient number of adequately qualified QA and QC inspection
personnel were present at the work site, commensurate with the work in
progress.
- The weld area cleanliness was maintained and that pipe alignment and
fit up tolerances were within specified limits.
- Weld filler material being used was in accordance with welding
specifications, unused filler material was separated from other types of
material and was stored properly and that weld rod stubs were properly
removed from the work location.
- That there were no evident signs of cracks, excessive heat input,
sugaring, or excessive crown on welds.
- Welders were qualified to the applicable process and thickness, and that
necessary controls and records were in place.
No violations or deviations were identified.
14. Reactor Vessel, Integrated Head Package, and Internals - Unit 1 & 2 (50053C
and 50063C)
Periodic Unit 1 inspections consisted of examinations of the Reactor Vessel,
the integrated head package and the upper and lower internals in their
designated storage area. The Reactor Vessel was disassembled and internals
removed for inspection at the completion of Hot Functional Testing.
The Unit 2 inspections consisted of examinations of the Reactor Vessel with
the lower internals installed and the integrated head package and the
upper internals which are stored in their designated laydown area,
inspections determined that proper storage protection practices were in
i
place and that entry of foreign objects and debris was prevented.
No violations or deviations were identified.
15. Safety Related Components - Units 1 & 2 (50073C)
The inspection consisted of plant tours to observe storage, handling, and
protection; installation; and preventive maintenance af ter installation of
safety-related components to determine that work is being performed in
accordance with applicable codes, NRC Regulatory Guides, and licensee
commitments. '
l
During the inspection the below listed areas were inspected at various times
l during the inspection period to verify the fallowing as applicable:
-. ~
28
- Storage, environment, and protection of components were in accordance
-with manufacturer's instructions and/or established procedures.
-
Implementation of special storage and maintenance requirements _such as:
rotation of motors, pumps, lubrication, insulation testing (electrical),
cleanliness, etc.
- Performance of licensee / contractor surveillance activities and
documentation thereof was being accomplished.
- Installation requirements were met such as: proper location, placement,
orientation, alignment, mounting (torquing of bolts and expansion
anchors), flow direction, tolerances, and expansion clearance.
- Appropriate stamps, tags, markings, etc. were in use to prevent
oversight of required inspections, completion of tests, acceptance, and
the prevention of inadvertent operation.
Safety-Related piping, valves, pumps, heat exchangers, and instrumentation
were inspected in the following Unit 1 and 2 areas on a random sampling
basis throughout the inspection period:
- Residual Heat Removal Pump Rooms
- Diesel Generator Building
- Auxiliary Feedwater Pumphouse
- Containment Spray Pump Rooms
- Pressurizer Rooms
- Main Coolant Pump Areas
- Steam Generator Areas
- Safety Injection Pump Rooms
- RHR and CS Containment Penetration Encapsulation Vessel Rooms
~ Component Cooling Water (CCW) Heat Exchangers, Surge Tanks & Pump Rooms
- Cable Spreading Rooms
- Accumulator Tank Areas
- Chemical and Volume Control System (CVCS) Letdown Heat Exchanger
Pump Room
- Battery & Charger Rooms
4
- Nuclear Grade Piping, Valves & Fittings Storage Areas
- Spent Fuel Pool Heat Exchanger Rooms
- Pressurizer Relief Tank Area
- CVCS Centrifugal Charging Pumps & Positive Displacement Pump Rooms
- Bottom Mounted Instrumentation (BMI) Tunnel and Seal Table Area
- BMI and Supports Under Reactor Vessel
- NSCW Tower Pump Rooms and Pipe Tunnels
- Containment, Auxiliary Building, Control Building, and Fuel Handling
Building auxiliary (secondary) areas
No violations or deviations were identified.
16. Safety Related Pipe Support and Restraint Systems - Units 1 & 2 (50090C) ,
1
Periodic random inspections were conducted during the inspection period to l
observe construction activities during installation of safety-related pipe
supports to determine that the following work was performed in accordance
with applicable codes, NRC Regulatory Guides, and licensee commitments:
i
L
n
29
- Spring hangers were provided with indicators to show the approximate
" hot" or " cold" position, as appropriate.
- No deformation or forced bending was evident.
- Where pipe clamps are used to support vertical lines, shear lugs were
welded to the pipe (if required by Installation Drawings) to prevent
slippage.
- Sliding or rolling supports were provided with material and/or
lubricants suitable for the environment and compatible with sliding
contact surfaces.
- Supports are located and installed as specified.
- The surface of welds meet applicable code requirements and are free
from unacceptable grooves, abrupt ridges, valleys, undercuts, cracks,
discontinuities, or other indications which can be observed on the
welded surface.
No violations or deviations were identified.
17. Electrical end Instrumentation Components and Systems - Units 1 & 2 (51053C)
(52153C)
Periodic inspections were conducted during the inspection period to observe
safety-related electrical equipment in order to verify that the storage,
installation, and preventive maintenance was accomplished in accordance with
applicable codes, NRC Regulatory Guides, and licensee commitments.
During the inspection period inspections were performed on various pieces of
electrical equipment during storage, installation, and cable e ,inating
phase in order to verify the following as applicable:
- Location and alignment
- Type and size of anchor bolts
- Identification
- Segregation and identification of nonconforming
items
- Location, separation and redundancy requirements
- Equipment space heating
- Cable identification
- Proper lugs used
- Condition of wire (not nicked, etc.), ticStness of
connection
- Bending radius not exceeded
- Cable entry to terminal point
- Separation
No violations or deviations were identified.
w.,--
_ _ _ _
=
i
30
18. Electrical and Instrumentation Cables and Terminations - Unit 1 & 2 (51063C)
(52063C)
a. Raceway / Cable Installation
,
The inspector reviewed and examined portions of the following
f procedures pertaining to raceway / cable installation to determine
' whether they comply with applicable codes, NRC Regulatory Guides and
licensee commitments.
- ED-T-02, Rev. 10 Raceway Installation
- EO-T-07, Rev. 11 Cable Installation
Periodic inspections were conducted to observe construction activities
'
of Safety Related Raceway / Cable Installation.
In reference to the raceway installation, the following areas were
inspected to verify compliance with the applicable requirements:
- Identification '
- Alignment -
- Bushings (Conduit)
- Grounding
- Supports and Anchorages
In reference to the cable installation the following areas were
inspected to verify compliance with the applicable requirements: l
- Protection from adjacent construction activities (welding, etc.)
- Colled cable ends properly secured
- Non-terminated cable ends taped
- Cable trays, junction boxes, etc., reasonably free of debris
!
l
- Conduit capped, if no cable installed
- Cable supported
- Bend radius not exceeded
- Separation
f b. Cable Terminations
l
'
The inspector reviewed and examined portions of the following
procedures pertaining to cable termination to determine whether they
comply with applicable codes, NRC Regulatory Guides and licensee
commitments.
-
ED-T-08, Rev. 9 Cable Termination
In reference to cable terminations the following areas were inspected
to verify compliance with the applicable requirements.
- Cable identification
- Proper lugs used
- Condition of wire (not nicked, etc.)
'
- Tightness of connection
,
_ _ _ _ _ _ _ _ _ :--------
__
31
- Bending radius not exceeded
- Cable entry to terminal point
- Separation
No violations or deviations were identified.
19. Containment and Safety Related Structural Steel Welding - Units 1&2
(55053C) (55063C)
Periodic inspections were conducted during daily plant surveillances on
safety-related steel welding at various stages of weld completion.
The purpose of the inspection was to determine whether the requirements of
applicable specifications, codes, standards, work performance procedures and
QC procedures are being met as follows:
- Work was conducted in accordance with a process sheet or
drawing which identifies the weld and its location by system,
references, procedures or instructions, and provides for
production and/or QC signoffs.
- Welding procedures, detailed drawings and instructions, were
readily available in the immediate work area and technically
adequate for the welds being made.
- Welding procedure specification (WPS) were in accordance with
the applicable Code requirements and that a Procedure
Qualification Record (PQR) is referenced and exists for the
type of weld being made.
- Base metals and welding filler materials were of the specified
type and grade, were properly inspected, tested, and were
traceable.
- Protection was provided to shield the welding operation from
adverse environmental conditions.
- Weld joint geometry including thickness was specified and that
surfaces to be welded were prepared, cleaned and inspected in
accordance with applicable procedures or instructions.
- A sufficient number of adequately qualified QA and QC
inspection personnel commensurate with the work in progress
were present at the work site.
- Weld area cleanliness was maintained and that alignment and
fit-up tolerances were within specified limits.
- Weld filler material being used was in accordance with welding
specifications, unused filler material was separated from other
types of material and was stored and controlled properly, and
stubs were properly removed from the work location.
- There were no visual signs of cracks, excessive heat
input, or excessive crown on welds.
- Welders were qualified to the particular process and thickness;
, and that necessary controls a,1d records were in place.
No violations or deviations were identified.
1
.
r-
32
20. Preoperational Test Program Implementation / Verification - Unit 1 (70302)
(71302)
The inspector reviewed the present implementation of the preoperational test
program. Test program attributes inspected included review of
administrative requirements, doct. ment control, documentation of major test
events and deviations to procedures, operating practices, instrumentation
calibrations, and correction of problems revealed by testing.
Periodic inspections were conducted of Control Room Operations to assess
plant condition and conduct of shif t personnel. The inspector observed that
Control Room operations were being conducted in an orderly and professional
manner. Shift personnel were knowledgeable of plant conditions, i.e.,
ongoing testing, systems / equipment in or out of service, and
alarm / annunciator status. In addition, the inspector observed shift
turnovers on various occasions to verify the continuity of plant testing,
operational problems and other pertinent plant information during the
turnovers. Control Room logs were reviewed and various entries were
discussed with operations personnel.
Periodic facility tours were made to assess equipment and plant conditions,
maintenance and preoperational activities in progress. Schedules for
program completion and progress reports were routinely monitored.
Olscussions were held with responsible personnel, as they were available, to
determine their knowledge of the preoperational program. The Inspector
reviewed numerous operation deviation reports to determine if requirements
were met in the areas of documentation, action to resolve, justification,
corrective action and approvals. Specific inspections conducted are listed
below:
a. Preoperational Tests
(1) Test Procedure Review (70300)
The inspector reviewed the following listed preoperational test
procedures. Each test was reviewed for administrative format and
technical adequacy. The procedures were compared with licensee
commitments from the applicable FSAR Chapters, Regulatory Guide
1.68 and the Safety Evaluation Report (NUREG-1137). This included
veri fying that pertinent prerequisites were identified, initial
test conditions and system status were specified, acceptance
criteria were specified and management approval indicated:
NRC l
Procedure li1 Q . Test Title l
N o, No;
l-300-05 63050 Containment Struct4ral
Inteority Test
1-300-12 70307 Containment Integrated Leak
Rate Test
1-3KE-06 70453 Fuel Handling Machine
l
l
P
33
(2) Test Witnessing (70312)
The inspector witnessed selected portions of the following
preoperational test procedures as they were conducted. The
inspection included attendance at briefings held by the test
supervisor to observe the coordination and general knowledge of
the procedure with the test participants. Overall crew
performance was evaluated during testing. A preliminary review of
the test results was compared to the inspector's own observations.
Problems encountered during performance of the test were verified
to be adequately documented, evaluated and dispositioned.
Procedure NRC Insp. Test Title Activity Observed
No. No.
1-3AL-03 70438 AFW System Testing TO AFW Pump 48
During HFT Hour Run
1-300-10 70452 Shutdown Panel RCS Cooldown
Preoperational Fror.) 350 F to
Test 250 F Per
Abnormal
Operating
Procedure
18038-1
1-300-05 f.3050 Containment Installed
Structural Location of
Integrity Test Extensometers
and Walkdown
of Valve
Lineups
1-300-12 70313 Containment Installed
l Integrated Location of
Leak Rate Test RTD's and Data
Acquisition and
Processing Center
1-3KJ-05 70441 DG Train "A" Five (5)
l Synchronization, consecutive
l Load Rejection, Starts on Air
5 Air Starts and Receiver #2
35 Consecutive Per Section 6.3
, Starts
Train A DG
Operation With
i
.. .
34
Fuel Oil Day Tank
Makeup From Train B
Fuel Oil Storage
Tank Per Section
6.1.7
100% Load Rejection
Per Section 6.1.8
1-3EF-01 70439 Nuclear Service NSCW Pump P4-002 &
i
Cooling Water Discharge Valve
System 1 HV-11607
Preoperational Circuit Test
Test
1-3BK-01 70443 Containment Spray Suction Flow
Preopera tional Demonstration for
Test Simultaneous
Operation of SI,
Cent. Chg., RHR and
CS Pumps per Section
6.5
1-3KJ-05&O6 70441 DG Train "A"&"B" Train "A"&"B" 35
Synchronization Consecutive Air
Load Rejection, 5 Starts per Section
Air Starts and 35 6.4
Consecutive Starts
1-3BG-01 70433 Chemical Volume Train "B" CVCS Cold
and Control Shutdown Safety
System Grade
- Preoperational Charging Flow
l Test Base Line
Measurement per
Section 6.9
1-3BG-03 70434 Safety Injection Accumulator
Accumulators High/ Low Pressure
Preoperational Annunciator
Test Check-out per
Section 6.4
i 1-358-01 70317 Reactor Protection RPS Overpower
! Preoperational Delta Reactor
Test Trip Logic per
Section 6.13.3
,
3 h
35
1-3PB-01 92706 Class 1E 4.16 KV DC Control Power
Train "B" Bus 1AA02 per
Switchgear Section 6.1
Preoperational
Test
Breaker 1AA0205
Operation per
Section 6.3
1-3BC-01 70436 Residual Heat Testing of
Removal System Lockout Feature
Preoperational on Valves
1 HV-8809A&B per
Sections 6.4.1.1
& 6.4.3.1
The inspector also witnessed the hanging of Clearance
No. 1-8G-4990 for de-energizing 480 volt switchgear 1 AB-15, 1
AB-04, & 1 AB-05. This clearance was hung to support maintenance
in performing their preventive maintenance program in cleaning
Train "B" 480 switchgear & volt motor cnntrol centers. The
inspector verified proper implementation of Administrative
Procedure No. 00304-C, Rev 7 entitled " Equipment Clearance &
Tagging" during the performance of hanging Clearance
No. 1-86-4990.
(3) Test Results Evaluation (70400)
The inspector reviewed the following listed preoperational test
results. This review was performed to ascertain if an adequate
evaluation of the test results has been performed; test data was
within the established acceptance criteria, or that deviations are
properly dispositioned; appropriate retesting was performed where
necessary; administrative practices were adhered to; and that
appropriate review, evaluation and acceptance of the test results
have been performed.
Procedure NRC Insp. Test Title
i
No. No.
1-3KE-02 70553 Spent Fuel Cask Bridge Crane Preop
(Partial)
1-3KE-06 70553 Fuel Handling Machine (Partial)
Sec. 6.8
b. Construction Acceptance Testing (CAT)
The inspector conducted an inspection of the licensee's method of
preoperational testing of instrument and control air systems in
,
accordance with Regulatory Guide 1.68.3 dated April, 1982. FSAR
l
Section 1.9.68.4 states that safety-related pneumatic valves will be
l
l
._- _ _ _ _
._ ..
36
tested for both a simulated sudden loss of air and a gradual loss of
air pressure to verify that each valve assumes its Fail-Safe position.
The licensee's response to NRC Question 640.03 states that the valves
listed in Table 9.3.1-2 will be tested. This table does not list all
safety-related pneumatic valves. During discussions with the licensee
it appears that the licensee is testing all safety-related pneumatic
valves. However, there appears to be a conflict between the two (2)
statements made in the FSAR since Table 9.3.1-2 is not a complete
listing of all safety-related valves. This matter was identified to
the licensee and NRR. Further discussions with the licensee revealed
that the commitment is only to test those safety-related valves listed
in Table 9.3.1-2 since both the FSAR Section 1.9.68.4 and the response
to NRC Question 640.03 were amended at the same time (i.e. in Amendment
No. 15) even though all safety-related pneumatic valves are being
tested.
The inspector conducted a review of the licensee Construction
Acceptance Test (CAT) Procedure No. CAT-M-04 entitled Air Operated
Valves which implemented Section C-8 of the Regulatory Guide. The
inspector selected two system startup designator no's. from which to
review completed CAT M-04's to verify loss of instrument air test for
both cases (i.e., sudden & gradual) to pneumatic safety-related valves.
The inspector conducted a review of the following completed CAT's:
Residual Heat Renewal System (BC-01)
Failed
CAT No. Valve No. Position Comments
85-2922 1-HV-0607 F0 Not Tested for Sudden
Loss of Instrument Air
85-2923 1-HV-0606 F0 Not Tested for Sudden
Loss of Instrument Air
85-3093 1-HV-0618 FC Not Tested for Sudden
loss of Instrument Air
85-3094 1-HV-0619 FC Not Tested for Sudden
loss of Instrument Air
Chemical Volume & Control System (BG-03)
Failed
CAT No. Valve No. Positten Comments
85-4757 1-HV-8149A FC
85-4757 1-HV-82498 FC
85-4757 1-HV-8149C FC
85-4758 1-HV-8152 FC
-
_ _ _ - - _
,
!
37
85-4759 1-HV-8160 FC
85-4790 1-HV-15214 FC
85-4756 1-HV-8143 F0
86-491 1-HV-8153 FC
85-4755 1-PV-0131 F0 Not Tested for
Sudden loss of
Instrument Air
85-4789 1-HV-0123 FC Not Tested for
Sudden loss of
Instrument Air
85-4982 1-TV-0129 F0
85-4798 1-HV-0128 FC
86-1383 1-TV-03818 FO
86-1382 1-TV-0831A FC
85-4753 1-HV-8154 FC
86-1424 1-HV-7041 FO
86-1422 1-HV-7022 FC
86-1420 1-HV-7054 FC
86-1426 1-HV-7040 FO
86-1384 1-HV-387 FO
-
86-1381 1-HV-7046 FC
Six (6) CAT packages identified above had N/A for Step 6.4.1 which was
the applicable step for testing for a sudden loss of instrument air.
The step stated to de-energize the solenoid and verify that the valve
moved to its correct Fail position. Discussions with the licensee
revealed that the step was N/A since the valves in question did not
have a solenoid valve (i.e. , they had a Bailey Controller). Also the
licensee had decided that by closing the instrument air supply valve
thus simulating a loss of air the valve would move to its Fall-Safe
position in the same manner as for a gradual loss of air since the air
would bleed slowly out of the air supply tubing via the regulator and
the controller. Therefore, this step was determined not to be
applicable for pneumatic valves with Bailey Controllers.
The inspector informed the licensee that the Regulatory Guide stated to
shut of f the instrument and control air system in a manner that would l
simulate a sudden air pipe break. 1rocefore, by closing the instrument i
air supply valve you would vt b e. einolating a sudden loss of I
instrument air via a pipe break since shere is not a vent path. Thus
the valve would move to its Fail-Safe position slowly as the air is
bled out of the air supply line via the Regulator and the Cor. troller. l
However, by attaching a test fixture which would allow the air to be !
vented out of the supply line you would be simulating a sudden loss of
air via a pipe break and the valve will move to 1t Fall -Safe position
quickly.
In a subsequent meeting with the licensee the inspector was informed l
that all safety-related pneumatic valves not tested for a sudden loss ,
of instrument air were being identified and would be tested. l
_
38
Based on this review it appears that safety-related pneumatic valves
with Bailey Controllers were not tested for a sudden loss of instrument
air via a pipe break in accordance with Section C.8 of Regulatory Guide
1.68.3.
~
The foregoing is considered to be in violation of 10 CDR 50, Appendix
B, Criterion V and will be identified as Violation 50-424/86-74-02
" Inadequate Procedure for Testing Air Operated Valves With Bailey
Controllers".
21. Three Mile Island Task Action Plan Followup - Unit 1 (4254018) Operational
Staffing - Unit 1 (363018)
This inspection consists of verification that the licensee has implemented
the requirements of NUREG 0737, " Clarification of TMI Action Plan
Requirements" as committed to in the facility FSAR or other appropriate
documents. Verification consisted of one or more of the following
attributes, as appropriate, to determine acceptability for each listed
action item:
- Program or procedure established
- Personnel training or qualification
- Completion of item
- Installation of equipment
- Orawings reflect the as-built configuration
- Component tested and in service or integrated into the preoperational
test program
The following documents were utilized in performing the review, as
appropriate:
NUREG 0578 TMI-2 Lessons Learned Task Force Status Report
NUREG 0660 NRC Action Plan Developed as a Result of the
TMI-2 Accident
NUREG 0694 THI-Related Requirements for New Operating Licenses
NUREG 0737 and Clarification of TMI Action Plan Requirements
Supplement 1
FSAR thru Final Safety Analysis Report
Amendment 24
NbREG 1137 and Safety Evaluation Report
Supplements
On September 9 - 12, the inspector participated in an NRR lead review of the
propored organization for operation of Vogtle from the level of the senior
corporate of ficer down thru the plant operating staf f. This review was
conducted in Atlanta at the corporate office and onsite. In fo rma tion
contained within Chapter 13 of the FSAR was utilized in this review. From
this review the team learned that a major reorganization was in progress.
fhe team's review also included this new organt:ation in the review, but
noted that FSAR changes must be submitted and formal review performed. The
team also included an oversight review of the following TMI Action items:
'
39
a. I.A.1.1 - Shift Technical Advisors
b. I.A.I.2 - Shift Supervisor Administrative Duties
c. I.A.1.3 - Shift Manning
d. I.B.1.2 - Independent Safety Engineering Group
e. I.C.2 - Shift Relief and Turnover Procedures
f. I.C.3 - Shift Supervisor Responsibilities
g. I.C.4 - Control Room Access
! h. I.C.5 - Procedure for Feedback of Operating Experience to the
Plant Staff
1. I.C.6 - Procedure for Verification of Correct Performance of
Operating Activities
The results of the team review will be formally documented in a meeting
summary and Safety Evaluation Repurt,
22. Followup of Reportable Items - Units 1 & 2 (92700)
, This inspection was conducted to determine whether the reports have been
i
received by the licensee, evaluated and corrective action taken, where
i appropriate. The inspector utilized discussions with cognizant personnel
l and review of applicable documentation, and field verification as a basis
for closure of each item,
a. 50-424/50-425 P2179-01 (Closed) " Jacket Water Pump Assembly Drives".
This item was reported by TDI in a letter dated September 20, 1979.
This item is not applicable to the plant's type of diesel,
b. 50-424/50-425 P2131-01 (Closed) " Governor Lube Oil Cooler Location".
This item was reported by TDI in a letter dated December 9,1981. The
, deficiency concerns a possibility for engine non-availability if the
! coolers are installed above the governor lube oil level. Site
l
'
inspection confirmed that the lube oil coolers are properly installed.
The inspector verified the field installation,
c. 50-424/50-425 P2182-02 (Closed) " Start Air Sensing Line". This item
was reported in a letter dated March 19, 1982. The deficiency concerns
the possible failure of a non-seismic sensing line with a resultant
bleeding down of the air start receiver tanks. The suggested
correction was the installation of an 1/8" orifice upstream of a
qualified valve which would lengthen the time required for bleed down.
The Bechtel evaluation dated April 14, 1982 dismissed this as i
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reportable becausa the plant design utilized a dif ferent design. The
inspector examin a the latest P&ID drawing and determined that the
plant design has been changed since the evaluation and now includes
this design. A review of the design change indicated that the new
design was engineered to include the TDI recommendation. Field
verification by the inspector was not possible due to the design
including the orifice internal to the assembly. The Unit I weld
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process sheets were obtained which document orifice installation.
Unit 2 P&ID's and isometric currently depict the new design and normal
construction practices will ensure installation.
d. 50-424/50-425 P2183-01 (Closed) " Engine Mounted Fuel Oil Line". This
item was reported by TOI in a letter dated September 21, 1983. The
deficiency concerns the failure of the line due to excessive . line
vibration. While the deficiency is attributed to vibration problems at
the site where the problem first occurred. Several actions were
required to mitigate the potential for re-occurrence. The Test
Supervisor was interviewed to determine how these recommendations were
implemented and field verification performed. The applicant has
replaced the swageloc fitting with a thread tee, added an additional
support, and installed a spray shield.
e. 50-424/50-425 P2184-01 (Closed) " Fuel Control Levers on Diesel
Generator Engines Are Not Pinned". On November 29, 1984 the applicant
submitted the results of the site review to the NRC. This review
determined that the Vogtle diesels were properly pinned and cap screws
properly torqued. The inspector reviewed the original vendor report
dated October 2, 1984 and various other site documents. An inspection
of the fuel control levers was performed by the inspector to verify the
hardware installation is as stated.
f. 50-424/50-425 P2184-C2 (Closed) " Bonney Force lacks the Chemical
Overcheck Documentation". This item as reported by Pullman Power
Products letter dated March 22, 1984 concerns nine fittings where
the vendor had not performed a chemical check analysis. The inspector
reviewed a November 8, 1984 Pullman Power Products letter which
enclosed a certified material test report for each spool and determined
that the chemical analyses indicated that all were within the required
specification ranges.
g. 50-424/50-425 P2184-03 (Closed) " Deficient Gimpel Valve for Auxiliary
l Feedwater Pump Drive Turbine". This item as reported by Terry
Corporattun letter, dated February 3,1984 concerned a situation where
the ,pring load in the closing direction was not sufficient to overcome
the valve stem unbalance when the pressure below the valve seat exceeds
approximately 700 psig with the turbine near a no load condition. The
inspector reviewed FECO No. M-3-B and determined that the new springs
have been installed for the Unit 1 turbine auxiliary feed pump.
h, 40-424/50-425 P2184-04 (Closed) "High Pressure Injection Pump". This
item was reported by TOI in a letter dated July 13, 1984. This
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deficiency concerned the failure of a bracket which supports the pump.
The bracket failure was attributed to a material defect and was
dispositioned as a one-time failure. No corrective action was
necessary.
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1. 50-424/50-425 P2185-02 (Closed) "Possible Field Failure of Space
Heaters Supplied on GE Motors". This item as reported by Bingham-
Willamette Company letter, dated January 24, 1985 concerns the failure
of Wellman C 1pany manufactured space heaters which utilized epoxy
instead of ceramic end plugs. The- inspector reviewed the results of
the applicant's inspection and determined that none of the heaters of
this type exist onsite.
J. 50-424/50-425 P2185-06 (Closed) " Air Filter-Engine Control Panel".
This item was reported by TDI in a letter dated January 22, 1985.
This deficiency concerns the potential of having a polycarbonate
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transparent bowl (rated 150 psig at 125 F) where a metal bowl (rated
250 psig'at 175 F) should be installed to meet the service requirements
of 200 to 250 psig at room temperature.
k. 50-424/50-425 CDR 82-22 (Closed) " Leaks in Containment Cooling Coil
Units". The applicant determined this item to be not reportable in a
June 9, 1982 letter. The Southern Company Services, Inc. evaluation
dated June 18, 1982 was reviewed. This deficiency involves coil
leakage discovered when the coils were subjected to test pressure in
excess of the original immersion testing. The evaluation concluded
that the leakage was small, self sealing and would not degrade unit
operation. The inspector concurs with this evaluation. In addition,
the applicant oneumatically reinspected sixty-two colling coils and had
repairs made on the eight coils with leakage. These repairs were
performed by the vendor. Two N1 data forms were reviewed and the
inspector determined the repairs were performed as required by the
applicant.
1. 50-424/50-425 CDR 82-28 (Closed) "Bechtel Calculation". The applicant
determined this item to be not reportable in an October 29, 1982
, letter. Bechtel Power Corporation evaluation dated October 4, 1982 was
reviewed. This deficiency involved the lack of timely updating of
Bechtel calculations as identified by an INPO audit. The inspector
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reviewed copies of the af fected calculations and determined that the
corrections have been completed.
m. 50-424/50-425 COR 85-90 (0 pen) " Anchor Darling Main Feedwater Isolation
Valves". This inspection was performed to verify field installation of
the replacement check valves. All four feedwater isolation valves were
examined and the inspector noted that all eight check valves had been
replaced with new 8F-C8L-10-SS type check valves. The inspector was
informed that a slow depressurization test was not performed as part of
a formal preoperational test, however a plant surveillance was
performed. In discussion with the test supervisor concerning the
surveillance the inspector determined that the procedure isolates air
to the system but does not simulate a slow bleed of the air. The
licensee has committed to revise and perform the procedure to
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demonstrate check valve operability. Work on Unit 2 valves has i
not been performed. Final closure of this CDR will be contained 4
in NRC report 50-424/86-76 and 50-425/86-37. The' following IFI is I
identified 50-424/86-74-03 and 86-35-01 " Review Results of Testing {
the Check Valves on the Feedwater Isolation Valves" to verify new !
model 8F-C8L-10-SS. l
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23. Comparison of As-Built' Plant to FSAR Description - Unit 1(37301) :
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During the inspection period, pipe run walkdowns were performed where piping i
installation is near completion to determine whether the piping run is
installed as shown on current, approved drawings and in. accordance with !
applicable construction specifications. The following systems were walked !
down to verify that the installed system is in agreement with the applicable -
drawings, FSAR description, and proposed technical specificaticns.
FSAR Pipe Run
Section DWG. No./ Revision Title Inspected
10.4.7 IX4DB168-1/9 Condensate & Condensate
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System Supply To SG's
2&3
1X4DB168-2/8
IX4DB168-3/17 !
No violations or deviations were identified. !
24. Fuel Receipt and Storage - Unit 1 (60501B)
Inspections were conducted to ascertain whether new fuel was being properly
accepted, stored and safeguarded in accordance with NRC license SNM-1967.
During these inspections the inspector randomly selected various
requirements and verified implementation. Selected portions of security and
fuel receipt procedures were witnessed as they were performed. Overall crew -
knowledge and performance was evaluated during these inspections.
Documentation of the fuel receipts and problems encountered were verified to
be adequately documented, evaluated and dispositioned on a selected basis.
During this inspection the inspector attended licensee meetings held in i
preparation for fuel receipt, reviewed the area turnover packages and !
inspected the actual area to independently assess the status of licensee
readiness. The inspector discussed reportability requirements with the
Special Nuclear Material Custodian and his designees. The inspector
determined that while they were aware of the reportability requirements that
Procedure 0152-C was being revised to clarify these requirements. The
inspector informed the licensee that the address and phone numbers to the
NRC need to be corrected. Corrections to procedure 0152-C were approved on
September 30, 1986.
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The following requirements, guidance and licensee commitments were utilized
as appropriate.
- 10 CFR 70 Domestic Licensing of Special Nuclear
Material
- SNM-1967 Special Nuclear Materials License
Procedure and Document Review
The inspector reviewed and examined portions of the following procedures
pertaining to initial fuel receipt, inspection and storage operations, to
determine whether they comply with applicable codes, standards, vendor
specifications, NRC Regulatory Guides and licensee commitments,
procedure No./ Title
~~~ Revision
20014-C/0 Crane Operator Qualification
93000-C/0 Fuel Handling Control Procedure
93010-C/0
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Unloading, Inspection, and Storage of
New Fuel
93020-C/0 Technical Inspection of New Fuel
93100-C/0 Refueling Tools and Equipment Preservice
Inspection / Checkout
93110-C/0 New Fuel Assembly Handling Fixture
Operating Instructions
93360-C/l Limitations and Precautions for
Handling New and Partially Spent Fuel
Assemblies
Fuel Receipt Inspection Activities
The inspector witnessed portions of fuel receipt / inspection activities
indicated below to verify the following for compliance with applicable
procedural technical requirements:
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Receiving inspection included a review of the fuel manuf acturer
shipping and Quality Assurance records / documents as well as an
inspection for external damage, security seal integrity, shock
indicator integrity, and loose material or parts.
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Health Physics (HP) conducted required surveys.
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Fuel Assembly Accountability was maintained and controlled.
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Fuel Assembly Fuel Pins, Spacer Grids, and Top and Bottom Nozzles
were inspected for cleanliness, scratches, uniformity,
straightness, flow holes clear, and weld visually acceptable,
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Assembly Insert was located in correct assembly and inspected for
correct orientation, alignment, irregularities, and acceptable
drag forces.
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Fuel Assembly is stored in its correct location.
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Crane Operators were qualiiied.
The following fuel assemblies were inspected:
Fuel Assembly No. Activity Inspected
SA03 & 5A60 Container No. 180-Preparation of a
Loaded Shipping Container for Fuel
Assembly Removal.
5A53 & SA57 Fuel Assembly Removal from Shipping
Container, Transfer, Inspection,
and Storage in New Fuel Racks.
5A59 & 5A61 Fuel Assembly Inspection / Storage in
New Fuel Racks.
The inspector reviewed and witnessed the training for the spent fuel cask
crane operators conducted by the Operations Department. Operators had to
demonstrate their knowledge and proficiency by completing a checklist for
the following areas: Classroom technical lectures, equipment operational
qualification, equipment operational proficiency, and equipment /qualifi-
cation proficiency. The training consisted of " knowledge of how the crane
operates, a walkdown of crane components, and a demonstration of the ability
to properly remove a dummy fuel assembly from a shipping container and load
it into the new fuel storage area with the spent fuel cask bridge crane.
The inspector noted that the operator training program being conducted by
the Operations Department was not a formal procedurally controlled training
and qualification program. In addition, GPC QA Audit No. OPil/16-86/77
issued on July 9, 1986 by GPC-QA after conducting an audit of the security
plan and procedures and fuel handling and special nuclear material control
identified a weakness in this area. As a result of this inspection a QA
Audit Checklist item Card was placed on QA- file for timely followup to
ensure that the existing informal program would be procedurally controlled
and implemented prior to actual fuel receipt.
The foregoing is considered to be in violation of 10 CFR Part 50,
Appendix B, Criterion XVI and will be identified as Violation
50-424/86-74-01 " Failure to Achieve Appropriate Corrective Action on the
Implementation of a Forma 11:ed/ Controlled Training & Qualification Crane
Operator Program for Operations Personnel Per QA Audit Report No.
OPll/16-86/17, Dated July 9, 1986."
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A weakness was noted in the area of initial fuel receipt. The licensee had
not planned to have the spent fuel cask crane Preoperational Test complete
which includes a Test Review Board (TRB) review of test results prior to use
during initial fuel receipt until questioned by the Resident Inspectors. In
addition, once the preop had been accepted by the TRB the Resident
Inspectors in conducting their review identified that per the licensee's
special nuclear material itcense the new fuel assembly har.dling tool should
be preoperational tested prior to use during the initial fuel receipt. The
TRB had completed their review arid had noted that performing a
preoperational load test was n t necessary prior to use. Once this was
brought to the licensee's attention immediate corrective action was taken
and the new fuel assembly tool was preoperational tested prior to use.
Another weakness noted in preparation for initial fuel receipt was in the
area of security. Several discussions were held with the security manager
to ensure proper implementation of GPC's security plan. This was necessary
in order to ensure that the special post orders had identified all of the
areas of surveillance for which the guard would be responsible for
surveilling per the licensee's security plan.
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