ML20247C003

Insp Repts 50-424/89-03 & 50-425/89-03 on 890109-13. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Licensee Identified 10CFR50.55 Items & NRC Bulletin 80-08 (Unit 2)

ML20247C003
Person / Time
Site:	Vogtle
Issue date:	02/23/1989
From:	Blake J, Coley J, Glasman M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247B982	List: ML20247B980 ML20247B989 ML20247C003
References
50-424-89-03, 50-424-89-3, 50-425-89-03, 50-425-89-3, IEB-80-08, IEB-80-8, NUDOCS 8903300098
Download: ML20247C003 (14)

See also: IR 05000424/1989003

Text

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NUCLEAR REGULATORY COMMISSION l

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• REGION 11

o\ e,,,, 101 MARIETTA ST., N.W.

ATLANTA GEORGIA 30323 ]

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Report Nos.: 50-424/89-03 and 50-425/89-03

Licensee: Georgia Power Company

P. O. Box 1295 i

Birmingham, AL 35201

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

Facility Name: Vogtle 1 and 2

Inspection Conducted: January 9-13, 1989

Inspector: kIf(n} n %n c,- h et 3"L . (ml eV' . 2bl/A7

Date'Signbd

J. L.'Coley'

U W h c- ~ a/n/pq  :

Date Si'gneti

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Approved by: -

/ / _2!R3P9

Dite Signed

J. ./Blake, Chief

M epials and Processes Section

ng(neering Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of

licensee actions on previous inspection findings (Unit I and 2)

licensee identified items (50.55(e)) (Unit 2), and NRC Bulletin 80-08

(Unit 2).

Results: In the areas inspected one violation, 425/89-03-01

(paragraph 2.b.(10)) was identified which dealt with the failure of

the licensee to report a potential 10 CFR 50.55(e) item on a Class 1

forged tee in a timely manner as required by Georgia Power company's

(GPC) Quality Assurance Procedure QA-04-02. As a result of the above

finding and discussions held with the licensee concerning this matter

programmatic weaknesses in reporting 10 CFR 50.55(e) occurrences were

indicated.

8903300098 09030D

PDR ADOCK 050004D4

G PNV

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REPORT DETAILS

1. Persons Contacted '

Licensee Employees

• G. Bockhold, Gt:neral Manager of Nuclear Operations

• E. Groover, QA Site Manager, Construction

• C.' Hayes, Project QA Manager

• W. Nicklin, Compliance Supervisor

Other licensee employees contacted during this inspection included

engineers, quality assurance and administrative personnel.

NRC Resident Inspectors

.*R. Aiello, Resident Inspector

• C. Burger, Senior Resident Inspector

• J. Rogge, Senior Resident Inspector

• Attended exit interview

2. Licensee Action on Previous Inspection Findings and Licensee Identified

Items (92701, 92702 and 92700)

GPC has set a fuel' load date for Unit 2 of February 9,1989. Region II

considers this date to be realistic, assuming that no unforeseen delays

occur in the licensee's remaining construction and preoperational testing

efforts. However, all outstanding construction items are expected to be

closed or resolved to NRC's satisfaction by fuel load, initial

criticality, or prior to exceeding five percent power.

The inspectors' objectives this inspection were to review the licensee's

corrective actions on those open items designated to the Materials and

Processes Section by Region II Management.

Items Examined are as follows:

a. Action on Previous Inspection Findings (Units 1 and 2)

(1) (Closed) Severity Level (SL) IV violation, 50-425/88-37-01,

" Failure to Detect Damage to Pressurizer Surge Line." GPC

letter of response dated September 22, 1988, has been reviewed

and determined to be acceptable by Region II. The inspectors

held discussions with Quality Assurance Site Managers and

examined the corrective actions as stated in the letter of

response. The inspectors concluded that GPC had determined the

full extent of the subject noncompliance, performed the

necessary survey and follow-up actions to correct the present

.

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conditions and ~ developed the necessary corrective actions to

preclude recurrence of similar circumstances. The corrective

actions identified in the letter of response . have been

implemented.

(2) (Closed) Severity Level IV Violation 50-424/87-11-02,

50-425/87-07-02, " Failure to Provide Adequate Report for

significant Construction Deficiency." GPC letter of response

dated March 31, 1987, has been reviewed and determined to be

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acceptable by Region II. The inspectors held discussions with

the Bechtel Engineering Supervisor for Heating,-Ventilation and

Air Conditioning (HVAC) and examined the corrective actions as

stated in the letter of response. The inspectors concluded that

. GPC had determined the full extent of the subject noncompliance,

performed the necessary survey and follow-up actions to correct

the present conditions and developed the necessary corrective

actions ' to preclude recurrence of similar circumstances. The

corrective actions identified in the letter of response have

been implemented.

(3) (Closed) Severity Level IV Violation 50-425/88-20-01, " Failure

to Install HVAC systems in accordance with FSAR." GPC letter of

response dated June 22, 1988, and Supplement of Letter of

Response dated June 23, 1988, have been reviewed and determined to

be acceptable by Region II. The inspectors held discussions

with the Bechtel Engineering Supervisor for HVAC and examined the

corrective actions as stated in the . letter of response. The

inspectors concluded that GPC had determined the full extent of

the subject noncompliance, performed and necessary survey and

follow-up actions to correct the present conditions and

developed the necessary corrective actions to preclude

recurrence of similar circumstances. The corrective action

identified in the letter of response has been implemented.

(4) (Closed) Inspection Followup Item 50-425/88-20-02, " Unavailable

HVAC Documentation." The licensee had located the documenta-

tion, AX4AJ07-320-2, " Topical Report on Desigr and Testing of

Fan Cooler Filter Systems for Nuclear Applications (AAF-TR-

7101)." The inspectors reviewed the instruction and the

satisfactory test results.

(5) (Closed) Inspector Followup Item 50-425/88-33-02, " Protection of

Pennanent Plant Equipment from Uncontrolled Leakage." The

inspectors discovered that this item had been closed by

Region II in Inspection Report No. 50-425/88-78.

(6) (0 pen) Unresolved Item 425/88-02-02, " Banded Microstructure in

Ten Inch Safety Injection (SI) Piping"

In NRC Inspection Report 50-425/88-02, an unresolved item was

identified concerning the metallurgical adequacy of 10 inch

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Schedule 140 type 316 pipe manufactured to SA-376 in the SI

system, specifically, the Cold Leg Accumulator lines. The code

and procurement specifications require a fully annealed micro-

structure, however, the licensee was informed that the subject

material contained a " highly banded microstructure" as is

indicated by a report dated February 27, 1985 from Associated

Metallurgical Consultants (AMC) to Southern Company Services

(SCS). SCS requested AMC to perform metallurgical analysis on

a sample of the subject material to determine why inspection of

this material wa; not possible with 45-degree shear waves; SCS

and preliminary NRC measurements have shown that sound enters

the material at approximately 22 degrees when using 45-degree

wedges. AMC concluded that this was due to the banded

microstructure in the material.

The licensee's initial response to the NRC's concerns was

contained in a report from Law Engineering of Atlanta, Georgia,

to GPC dated March 15, 1988 in which Law determined that no

unusual conditions were observed, and that the material' had an

equiaxed austenitic microstructure. Law's conclusion was "the

material met the requirements of ASTM A376."

Results of corrosion testing performed by Cortest Columbus of

Columbus, Ohio detailed in a report to GPC dated August 30, 1988,

indicated that the material met requirements of ASTM A262

Practice A. These corrosion tests were performed on specimens

which were in the as-received condition as well as a

cross-section of a weld in a welded specimen.

At this time, these are the inspectors' concerns:

(a) The Law Engineering report concluded that the material was

equiaxed, however, microphotos in the Cortest report

clearly display banding. The microstructure of the subject

material as well as other material,12 inch Schedule 140

provided by the same vendor, are shown in figures Ia, 2a,

3a, and 4a of the Cortest Report.

(b) Moreover, reproductions of microphotos produced by Law

Engineering of the subject material were given to the

inspector during a previous inspection because the

microphotos in copies of the Law Engineering report

provided to the inspector were not readable. A number of

these microphotos were not included in the Law report, yet

they displayed a high degree of banding in spite of Law's

conclusion that the material was not banded.

(c) The Cortest report was not clear as to whether the

corrosion test included the Heat Affected Zone (HAZ) of the

welded specimen. In addition, the photos were not

discernible in the xerox copy provided to the inspector.

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Pending further licensee action and NRC reviw, this item

remains open.

b. Licensee ' Identified Items Per 10 CFR 50.55(e) and Vogtle's Quality

Assurance Procedure QA-04-02

(1) (Closed) Construction Deficiency Report (CDR)88-143, Engineered

Safety Features Air Filtration Bolting, Unit 2

There are 'four ESF Air Filtration Units in the current Unit 2

Design; two redundant trains are provided for the control room,

and two for the piping penetration area. Each filtration unit

is supported in place by "C" channels bolted to angle clips

which in turn are anchored to the foundation. The holes through

which the bolting is passed (between the angle clips.and the C

channels) in the angle clips are slotted to accommodate field

adjustment. This construction deficiency was due, in part, to

inadequate drawings and failure of the contractor to follow

procedures related to the installation of the bolts between the

angle clips and the C channels.

Since the vendor drawings did not specify bolting material,

washer type / placement, and torque requirements, the contractor,

P/KF, mistakenly assumed that standard bolting material was

supplied, however, per site procedure, substituted'high-strength

bolts. Lock washers or oversized washers were also omitted from

the original installation because the vendor drawings did not

specify these requirements. Instead, the vendor installed

plated washers on the nut side of the bolted connection, on the

C channel side, and snugged the bolts.

Since high-strength bolts were installed without lockwashers,

lock nuts, or without being torqued to the proper pre-tension-

value, the integrity of the bolted connection could not be

assured. If the connection were to relax or loosen, failure

could potentially occur during a seismic event.

The licensee reviewed all other equipment within the scope of

P/KF's field engineering and installation work and found no

other ex_ spies of the deficiency described herein.

Following discovery of this discrepancy, the licensee contacted

the filtration unit vendor, American Air Filter, and they

indicated that for seismic qualification, ASTM A-449 or

equivalent high strength bolts pretensioned to 355 foot-pounds

with a lock washer on the nut side were required. To implement

corrective action, a Field Change Request (FCR) was written by

Bechtel for removal of all accessible bolting and replacement of

these bolts with the specified high strength bolting, including

oversize washers on the bolt side, and lock washers on the nut

side and torquing the connection to 355 foot-pounds. The

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inspectors subsequently reviewed ~ the applicable FCR, and

inspected the bolted connections on ESF air filtration units

2-1561 N7 001, and 2-1531 N7 001. The bolted connections

included the washers per requirements of the vendor, and there

were no gaps visible in the connection between the angle clips and

the C channel. This item is closed.

(2) (Closed) CDR 86-120, Valcor Solenoid Valve Spring Failure,

Unit 2

Valcor Engineering Corporation notified GPC and Bechtel in June

1986 and indicated that the 17-7PH springs used in certain

Solenoid Valves (SV) 'of their manufacture were subject to

hydrogen embrittlement when exposed to reactor coolant at

temperatures greater than 440 degrees F. The time to failure

was given as 1-2 years. Based on information supplied to the

NRC' under Part 21, NRC IN 86-72, " Failure of 17-7 PH Stainless

Steel Springs Due to Hydrogen Embrittlement," was issued by the

NRC August 19, 1986 on the same subject.

Bechtel and Valcor then identified two SV's which contained

17-7PH springs exposed to reactor coolant flow at temperatures

in excess of 440 degrees F. These two valves, 2HV-8208, and

2HV-8209 were in th Post Accident Sampling System liquid return

line, and were mo ified by replacing the 17-7PH springs with

Elgiloy springs. Elgiloy springs, per Valcor's correspondence

with Bechtel, was considered a suitable replacement for the

17-7PH springs in the respective valves. The inspectors

verified that the two valves were modified by examination of

Maintenance Work Order (MW0) 28805855 dated June 13, 1988.

Following the initial notification to the NRC of the spring

embrittlement problem, GPC made an additional report of

under-rated seal-in contacts on magnetic reed switches

associated with the Valcor and other SVs in Unit 2. These

contacts were rated at 0.5 Amp at 125VDC. However, the licensee f

found that the contacts carried 1.25 Amp, 125VDC; it was found '

that during design, the contact ratings were overlooked. As a

result, the licensee conducted a review of direct acting

solenoid valves and derived a list of SVs subject to problems

associated with under-rated seal-in contacts. Corrective action

was implemented by diversion of the excess seal-in current by ,

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interposin

MDR 137-8)g an additional

to carry the seal-inauxiliary

current relay

for the(Potter

SVs. & Brumfield

The

magnetic reed switch, following the modification, carries only

the seal-in current for the MDR 137-8 relay which is 0.082 Amp;

well within the capability of the reed switch contact rating of

0.5 Amp. The control circuit changes were implemented by FCR's

17660, 17661, 17662, 17676, 17677, and 17707. These FCRs were

reviewed by the inspectors and were found to adequately

incorporate the necessary changes in control circuitry to

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prevent overloading the magnetic reed switch contacts. This

item is closed.

(3) (Closed) CDR 84-70, Bettis Damper and Valve Actuators, Unit 2

G. H. Bettis, a manufacturer of pneumatic actuators used in

construction of Vogtle 1 and 2 reported that certain rotary

actuators of their manufacture were found to have less than

adequate performance, in that, the actuator motion was jerky and

irregular, and the stroke times were greater than 15 seconds.

The 15 second stroke time was representative of many Bettis

customer specifications. The reason for the degraded

performance was due to specific combinations of ethylene

propylene seals, and hydrocarbon based grease (Mobil 28) used in

manufacture of the actuator. Bettis indicated that the seals

absorbed the grease and became swollen much the same as a sponge

when it absorbs water. The result was the seal would expand

against the movable position rod and " set" (i. e., flatten) if

the actuator was used infrequently. As a result, Bettis issued

a Part 21 report, and GPC notified the NRC of a Construction

Deficiency because these actuators operate various valve and

damper assemblies which must open or close within a specified

time period in response to an Engineering Safety Features (ESF)

signal to isolate or vent various mechanical and HVAC systems.

GPC, in their evaluation, identified 70 dampers and four valves

supplied with G. H. Bettis actuators susceptible to the seal

swelling problem and elected to rebuild these actuators using

new seals and Dow Corning Molycote 44 lubricant. This lubricant

is considered compatible with the ethylene propylene seals as it

is not hydrocarbon based. Following the rebuild work, GPC

checked the performance of the actuators which included stroke

time and smoothness of operation. The inspectors verified-

proper replacement of seals and grease per Bettis requirements

and that the actuator met required stroke times by reviewing the

MW0s and Construction Acceptance Test (CAT) sheets for the

following actuators:

Required Measured

Tag Number Stroke Time Stroke time

2-JV 12713A 30 sec 2.5 sec

2-HV 12716 30 sec 8.5 sec

2-HV 12734 30 sec 2.2 sec

2-HV 12596 30 sec 1.0 sec

2-HV 12147 5 sec 3.9 sec

l 2-HV 12149 5 sec 2.9 sec

2-HV 12606 6 sec 2.6 sec

2-HV 12604 6 sec 1.5 sec

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The inspectors found the corrective action _ adequate, and the

performance of the rebuilt a::tuators listed above within

required performance limits. This item is closed.

(4) (Closed) CDR 86-132, Containment Purge System Register Damper,

Unit 2

On November 17,1986, Region II was notified of a potentially

reportable condition concerning a loose damper in the exhaust

register on the containment normal purge system. A final report

on this item was sent to Region II on December 16, 1986. The

containment normal purge system is designed to purge the

containment atmosphere to the plant vent stack while introducing

filtered and treated make up air from the outside to reduce

containment airborne radioactivity levels below that required for

personnel access.

Supply and exhaust registers with opposed blade dampers (0B0)

are provided at the normal purge supply and return openings for

air f ow adjustment and distribution. The OBDs are attached to

the g"ill sections of the registers using spring clips provided

by the register supplier, Krueger Manufacturing Company.

During testing of the containment normal purge system for air

flow adjustment, one of the exhaust registers in the normal

purge system pulled loose and broke apart. The damaged parts

traveled through both containment isolation valves and were

found in the duct work between the isolation valve and the

filtration unit. The root cause of the reported condition was

that the specification did not require the supplier to provide

registers with a positive means to secure the damper. The

detached damper, if drawn into the duct, could have damaged the

containmen' isolation valve or lodged in the valve seats to

prevent containment isolation. A review was performed on other

HVAC systems designed by Bechtel Engineering and it was

determined that the containment normal purge system is the only

system where a failure of non-safety-related components

(dampers) could impact the safety function of downstream

safety-related components. To prevent the exhaust dampers in the

normal purge system from becoming loose in the future, the

damper sections and grill sections of the exhaust registers have

been modified and were secured together by tackwelds or Pop-

Rivets. The adequacy of this modification is demonstrated in

calculation No. X4C 1506V02, Revision 0. A common drawing

change required for implementing the corrective actions has been

issued. The inspectors reviewed the licensee's corrective

action and discussed the corrective actions with Bechtel's Civil

Engineering supervisors for the HVAC system. The actions

identified in the report have been completed.

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(5) (Closed) CDR 87-139, Control Room - Essential HVAC Improper-

Design, Unit 2

The licensee's final report was submitted on April 14, 1988.

The initial discrepancy was that in certain accident conditions

involving the failure of one diesel train, the possibility existed

that a short-circuit exhaust path could be left in the control-

room emergency HVAC duct work by partially open isolation

dampers in the failed train. The isolation dampers are designed

to maintain the position they are in at the time of power loss. l

This problem was solved by installing backdraf t dampers.

However, a broadness' review of this discrepancy discovered tf t

if more than two of the four 100 percent capacity fant. are

operating at the same time, the fans would operate in the surge

range of the fan curves. This scenario could result in damage

to one or more of the fans. This subsequent problem was solved

by installing flow switches in conjunction with a lead / lag

circuit which will prevent more than one train per unit of the

control room essential HVAC system from automatically operating

at the same time. The inspectors held discussions with the

cognizant engineers concerning these discrepancies and reviewed

the licensees corrective actions. The actions identified in

the licensee's report have been implemented.

(6) (Closed) CDR'84-66 Containment Pipe - Rack Welds, Unit 2 l

On July 20, 1984, the licensee notified Region II of a 50.55(e)

item involving cracks in Unit I containment pipe-rack welds. In

reporting this item the licensee assumed the problem 'was

applicable to the Unit 2 pipe-rack installation. Therefore,

the CDR included both units, however, Unit 2 had not installed

their pipe-rack prior to the corrective action on Unit 1 and

therefore the Unit I resolution was incorporated in the Unit 2

installation. The Unit 1 CDR was closed in NRC Inspection

Report Nos. 50-424/85-40 and 50-425/85-31. The inspectors held

discussions with the GPC QA Manager concerning this item and

reviewed supporting information. This item is considered closed.

(7) (Closed) CDR 88-144, Valves Installed Opposite to Direction of

Flow, Unit 2

During system flushing and start up testing the licensee found a

number of valves were installed backwards. The licensee's

review indicated that there were a total of 29 valves

improperly installed due to three reasons: flow arrows were not

stamped on the valve bodies, flow arrows were stamped in the

wrong direction, and flow arrows were incorrect or absent '

on the associated isometrics. The licensee, however, indicated

that as a result of an engineering evaluation,12 valves are

acceptable as is, and the remaining 17 valves had to be

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reversed for correct flow in the intended direction through the -

. valve. Regarding the valves which' will not be- reversed; GPC .

, indicated that vencors were contacted to determine if thc valves

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direction, and the applicable valves were acceptable for use. in

either flow direction, these valves' include gate and' plug and

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ball. valves as . opposed to check, or globe valves. - The

inspectors. also .noted that- the licensee contacted the Dresser

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Industries,. the vendor who supplied valves which were stamped

with the flow arrows in the wrong direction, to determine if this-

was a widespread problem. - Dresser ' indicated that the valves

involved were _ part of a four valve ' order and' one valve failed

the hydro test, and was not shipped. The remaining three were

shipped ? to the Vogtle Project, and' were detected- by the

licensee. Dresser further stated that it was their opinion that.

this-was an isolated error due to human error, and the first such

incident brought to their attention.

To ascertain if the licensee performed the required rework to

reverse the valves identified as needing to be reversed, the

inspectors reviewed several completed Operations Deficiency '

Reports (00R) for four safety related valves which were

identified in the group of 17 valves which had to be reversed.

These valves were as follows:

Tag Number ODR Number System

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2HV-190A T-2-88-4 58 CVCS CCP Discharge Flow i

Control Valve

2HV-10951 T-2-87-173 SIS Grab Sample .

Isolation Valve l

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2HV-10952

2HV-10953

The above documentation was 'found satisfactory in -that it

substantiated that the required rework was. completed. This item ]

is closed.

(8) (Closed) CDR 86-128, Emergency Diesel Generator Building

Ventilation System, Unit 2

On September 12, 1986, the licensee notified Region II of a

potentially reportable condition which indicated that the

emergency diesel building ventilation system was not delivering

design air flow. On October 31, 1986, the licensee notified

Region II in their final report that after modifications which

included hermei,1cally sealing the diesel generator building,

insulating the diesel exhaust piping and performing a

comprehensive evaluation of the resulting condition, they had

concluded this item was not reportable since the required

temperature could be maintained. However, a new minimum

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calculated' design air flow of 70,000 CFM/ Fan at a static

pressure of 2.6 inches water gauge (WG) was established rather

than the 95,000 CRi/ Fan at a static pressure of 1.7 inches WG as

shown in the Final Safety Analysis Report (FSAR). The new

calculated design flow rate is the minimum air flow needed to

maintain the diesel generator building at 120 F during diesel

operation.

The inspectors held discussions with Bechtel's Civil Engineering

Supervisor concerning this issue and reviewed the new design

calculations (X4C2107V03), the work modification documents, and

final air flow preoperational test results. The inspectors

concurred that the fans would be adequate to furnish the air

flow necessary to maintain the diesel generator building at

120 degrees F during operation and this item is considered

closed.

(9) (Closed) CDR 88-148 Anchor Darling Valve Weight Discrepancies,

Unit 2

As a result of as-built reconciliation of piping stress

analyses, the licensee was informed of significant discrepancies

between valve assembly weights shown on valve assembly drawings

and valve assembly weights used in valve seismic reports for two

valves located in the Refueling Water Storage Tan) (RWST)

recirculation line. These valves (2HV-10957, 58) close on

receipt of a low water level signal in the RWST. The weights

listed on the assembly drawings were 195 pounds less than the

weights shown on the seismic report for the applicable valves.  !

As a result, the pipe stresses were higher at locations upstream

of the valves. A break at one of these locations :ould result l

in insufficient water volume in the RWST for saf( ty injection

and containment spray functions.

The licensee then sent a letter to the vendor, Anchor Darling

Valve (A/DV), requesting revision of the drawings such that

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actual valve weights are reflected on these documents and A/DV

responded in kind. The licensee also conducted an investigation

to determine if other valve vendors could possibly have the

wrong weights listed on their respective assembly drawings. The  !

licensee considered the results satisfactory in that weights l

listed were within 10 percent, actual weight, or within normal

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manufacturing tolerances.

Corrective action by the licensee included reconciliation of the

increased valve weights into the stress analysis of the

applicable piping system and installation of an additional

restraint for one of the affected valves. This work was

substantiated by a review of drawing V2-1204-H061, Rev. 2, showing

the addition of the extra restraint below Valve 2HV-10957. This

item is closed.

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(10) '(Closed) CDR 88-147, "ASME Class 1 Forged Tee Fittings"

On November 14, 1988, GPC notified Region II of a potentially

reportable condition per 10 CFR 50.55(e) involving certain

Unit 2 ASME Class 1 Tee Fittings, which had been block forged

instead of extruded. On December 15, 1988, GPC submitted their

final report. The inspectors' review of this report revealed

that as a result of the stress analysis considering snubber -

reduction for isometric drawing 2K4-1201-049-02, higher than 1

allowable stresses for the 12"x12"x6" reducing Tee on' the

residual heat removal line from the reactor coolant system hot

leg loop were indicated. A walkdown performed on April 30, 1987,

to measure the wall thickness of the tee to obtain as-built"

information that might aid in reducing stresses at the tee

discovered that a " block forged" reducing tee was installed in

lieu of an extruded tee. The stress analysis for Unit 2 had been

performed based on a extruded reducing tee at this location. The

stress analysis did not consider the effects of wall thickness i

variation and discontinuities due to machining the forging. The

-ASME Code rec;stres thermal transient analysis to be performed for

all structural discontinuities in ASME Class 1 piping systems.

The root cause for the forged tee not being considered in the

original stress analysis was determined to be the failure of the

piping vendor, Pullman Power Products (PPP), to notify GPC before

using non-standard forged tees. This requirement was given in

an attachment to the purchase specification.

A technical review of this condition concluded that it was

prudent to replace the block forged reducing tee with an

extruded 12"x12"x12" tee and a extruded 12"x6" reducer rather

than expending resources to justify the forged tee. The

licensee at tnis point however, violated GPC's Quality Assurance

Department Procedure QA-04-02, "Significant Deficiency / Defect

Reporting," in that, paragraph 1.B. states in part that, that the

following guidelines shall be used to determine if the

occurrence is a potentially reportable item under

10 CFR 50.55(e): could the deficiency were it to have remained

uncorrected, have affected adversely the safety of operations of

the plant at any time throughout the expected life time of the i

'

plant, and does it represent any one of the following

conditions:

(a) A significant breakdown in any portion of the Quality  ;

Assurance Program

(b) A significant deficiency in the final design as approved ,

and released for construction

Specific examples given in the procedure for reporting

deficiencies under 10 CFR 50.55(e) included the following:

- - - - - -

7

-

-

,

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y

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. ;.

x -

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-

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-

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(a) Deficiencies which require replacement of: a safety; class

-structure, system or component'

'

(2)1 Deficiencies which require. extensive evaluation

In addition, QA-04-02 paragraph 1.F. states, "the initial ' report

shall be 'made without having officially determined whether the

occurrence is. reportable and will be reported as a' potential-

l- .10'CFR50.55(e)."

As a result of firiding this- tee,' a d' rawing review was performed

to identify all ASME Class 1 tees. The locations were walked

'

down to identify any forged tee fittings. A' total of 44 ASME

.

Class .1 tees were identified' .'ncluding the one previously

discussed. Three were extruded ano' 11 had been forged.

An extensive evaluation was performed on the 40 forged tees

remaining in various installed systems. The review found the.

forged tees in place to be acceptable but resulted in eleven new

high energy line break locations.

The licensee concluded in their December 15, 1988, letter (191

months after the deficiency was -identified) that the

installation 'of the forged tee in the RHR line, without

consideration of effects of variations in wall thickness and-

structural discontinuities, could potentially have led to a

significant' safety hazard as defined by 10 CFR 50.55(e). Total

time allowed to report a potential 10 CFR 50.55(e) to NRC as

~

delineated in GPC procedure QA-04-02 is' 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. This

violation was reported to the licensee as Item No. 425/89-03-01,

" Failure to Report Potential 50.55(e) Item on Class 1 Forged

Tees as Required by GPC Procedure QA-04-02."

c. NRC Bulletins, Unit 2

i

(Closed) NRC Bulletin 80-08, " Examination of Containment Liner

Penetration Welds"

During an NRC-inspection at a particular facility, examination by

radiograph of primary containment liner penetration sleeve-to-process pipe

(fluid head fitting) welds revealed rejectable defects not originally

found by ultrasonic examination. Apparently, ultrasonic signals from

the weld backing bar masked signals from defects. Further

investigation found similar problems at other facilities. A Bulletin

was issued to acquire information from all facilities to

determine the generic nature of the problem. Review of GPC letter of

response dated June 26, 1980, revealed that GPC had radiographer all

penetration welds at Vogtle Unit 2 and therefore has performed the

examination in accordance with Bulletin 80-08 recommendations.

No further action is required and this item is considered closed.

I

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, ...

,

.. . .

'

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,

13

.

Within the areas examined, violations or deviations were not

identified except as noted in paragraph 2.b.10 above.

3. The inspection scope and results were summarized on. January 13, 1989, with

those persons indicated in paragraph 1. The inspectors described the

areas inspected and discussed in detail the inspection results listed

below. Proprietary information is not conteined in this report.

Dissenting comments were not received from the licensee.

(0 pen) Violation 425/89-03-01, Failure to Report Potential 50.55e Item on

Class 1 Forge Tees as required by Quality Assurance Department Procedure

QA-04-02 (Paragraph 2.b.10).

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