ML20196L623
| ML20196L623 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/21/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R GEORGIA POWER CO. |
| References | |
| NUDOCS 8807080072 | |
| Download: ML20196L623 (3) | |
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JUN 211988 Docket Nos. 50-424, 50-425 License Nos. NPF-68, CPPR-109 Georgia Power Company tATTN: Mr. R. P. Mcdonald Executive Vice President -
Nuclear Operations P. O. Box 4546~
Atlanta, GA 30302 Gentlemen:
SUBJECT:
NRC EVALUATION OF V0GTLE 2 READINESS REVIEW 0F HEATING, VENTILATING AND AIR CONDITIONING, MODULE NO. 18A The NRC has performed a review of the Heating Ventilating and Air Conditioning (HVAC) systems for Vogtle Unit 2 covered by Readiness Review Module 18A submitted on February 12, 1988.
This review has been performed as part of our routine inspection program (
Reference:
NRC Inspection Report Nos. 50-424/87-11, 50-425/87-07, 50-424/88-04, 50-425/88-03, 50-424/88-18, and 50-425/88-20).
Based upon NRC inspection review of those activities identified in the module, we have determined that the HVAC systems at Vogtle Unit 2 are acceptable with the exception of the two items in Enclosure 1.
This decision is based on information presently available to the inspectors and reviewers. Should information become available which was not considered during this review or which conflicts with earlier information, it will be evaluated to determined what effect it may have on the above conclusion.
Please contact us should you have any qt'estions concerning this letter.
Sincerely, I
J.NeldonGrace Regional Administrator
Enclosures:
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1.
List of Open Items 2.
Inspection Report Nos. 50-424/87-11, 50-425/87-07, 50-424/88-04, 50-425/88-03, 50-424/88-18, and 50-425/88-20 cc wiencls:
(See page 2) 8807080072 880621 DR ADOCK 05000424 4l
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F JUN 211988 2
Georgia Power Company cc w/ encl:
W. D. Rice, Vice President, Project Director p W. Hayes,.Vogtle Quality' Assurance Manager.
E Bockhold, Jr., General Manager,
- Nuclear Operations W. Gucwa, Manager, Nuclear Safety and Licensing W A. Bailey, Project Licensing Jianager tr. W. Churchill, Esq., Shaw, Jittman,PottsandTrowbridge l
W. Kirkland, III, Counsel, Office of the Consumer's Utility
~ Jouncil tr. Feig, Georgians Against Nuclear Energy bec w/ encl:
I L V Reis, 0GC Of1iopkins, NRR M. Sinkule, RII DRJ, Technical Assistant WRC Resident Inspector Document Control Desk State of Georgia f
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ENCLOSURE 1 List of Open Items Violations 50-424/88-18-01 and 50-425/88-20-01:
"Failure to Install HVAC Systems in Accordance with the FSAR" Inspector Followup Item 50-425/88-20-02:
"Unavailable HVAC Documents" l
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'N ENCLOSURE 2 r-9 g f 8 Coq [o, UNITED 57 ATES NUCLEAR REGULATORY COMMISSION u
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MAR 0 31987 y
Docket Nos. 50-424, 50-425 License Nos. NPF-61, CPPR-109 Georgia Power Company ATTN: Mr. James P. O'Reilly Senior Vice President-Nuclear Operations P. O. Box 4545 Atlanta, GA 30302 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-424/87-11 AND 50-425/87-07)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by W. P. Kleinsorge on January 26-30, 1987.
The inspection included a review of activities authorized for your Vogtle facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.
The inspection findings indicate that certain activities appeared to violate NRC requirements.
The violations, references to pertinent requirements, and elements to be included in your response are described in the enclosed Notice of Viola-tion.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely, JAt WW L sA R yes, eting Director Division of Reactor Projects
Enclosures:
(See page 2) l snaM 22 iff'
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Enclosures:
1.
NRC Inspection Report cc.w/encls:
R. E. Conway, Senior Vice President &
Project Directo-C. Whitney, General Manager Project Support P. D. Rice, Vice President, Project Engineering R. H. Pinson, Vice President, Project Construction C. W. Hayes, Vogtle Qual'.ty Assurance Manager G. B. Bockhold, General Manager, Nuclear Operations L. Gucwa, Manager, Nuclear Safety and Licensing M. H. Googe, Project Construction Manager l
J. A. Bailey, Project Licensing l
Manager l
B. W. Churchill, Esq., Shaw, Pittman, Potts and Trowbridge J. E. Joiner, Troutman, Sanders, Lockerman and Ashmore J. G. Ledbetter, Connissioner,
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Department of Human Resources l
C. H. Badger, Office of Planning and Budget D. Kirkland, III, Counsel, Office of the Consumer's Utility Council D. Feig, Georgians Against Nuclear Energy M. B. Margulies, Esq., Chairman, Atomic Safety and Licensing Board Panel Dr. O. H. Paris, Administrative Judge I
Atomic Safety and Licensing Board Panel G. A. Linenberger, Jr., Administrative Judge Atomic Safety and Licensing Board Par,el l
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t ENCLOSURE 1 NOTICE OF VIOLATION Georgia Power Company Docket Nos. 50-424, 425 Vogtle License Nos. NPF-61, CPPR-109 During the Nuclear Regulatory Comission (NRC) inspection conducted on January 26-30, 1987, violations of NRC requirements were identified.
The violations involved failure to follow design manual for PSAR/FSAR as-built changes and failure to provide an adequate report of a significant construction deficiency.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1986), the violations are listed below:
A.
10 CFR 50 Appendix B, Criterion V, as implemented by Section 17.1.5 of the FSAR requires activities affecting quality to be accomplished in accordance with documented procedures.
The Vogtle Project Design Manual Section 3.4.6 requires the following:
Every design criteria dealing with safety-related structures, systems or components shall include a separate section entitled, "PSAR Comparison."
In this section, every substantive difference between PSAR commitments and the current design shall be identified and briefly described.
These comparisons will form the basis for preparation of the FSAR.
FSAR Section 6.4.2.2.2 states:
"To minimize inleakage, the control room access doors are equipped with self-closing devices that shut the doors automatically following the passage of personnel. Alarms are also provided to annunciate if any of the doors are open after a changeover to emergency operation.
Two sets of electrically interlocked doors with a vestibule between, acting as an airlock, are provided at each of the two entrances and the emergency exit to the combined control room and associated spaces."
Contrary to the above, activities affecting quality were not accomplished in accordance with procedures as evidenced by the following:
The doors to the control room are installed in pairs, but they are not electrically interlocked and alarms are not provided to annunciate if any of the doors are open after a changeover to emergency operation.
The preceeding indicates that the requirements of the Vogtle Project Design Manual Section 3.4.6 were not followed.
This is a Severity Level IV Violation (Supplement II).
B.
10 CFR 50.55(e)(3) requires the holder of a construction permit to submit a written report on a reportable deficiency within thirty (30) days.
The report shall include a description of the deficiency, an analysis of the safety implications and the corrective action taken, and sufficient information to permit analysis and evaluation of the deficiency and of the corrective action.
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Docket Nos. 50-424, 425 Vogtle License Nos. NPF-61, CPPR-109 Contrary to the above, the licensee did not submit a report with sufficient information to permit analysis and evaluation of the corrective actions in that the licensee was unable to identify the 120 deficient heating ventilating and air conditioning duct supports reported in Construction Deficiency Report No. 82-32 of September 30, 1982.
The above is a Severity Level IV Violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation):
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION 01.4 W
Lui yes, Acting Director Division of Reactor Projects Dated at Atlanta, Georgia t
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50-424/87-11 and 50-425/87-07 Licensee:
Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.:
50-424 and 50-425 License Nos.:
NPF-61 and CPPR-109 Facility Name: Vogtle Inspection Co d: Jan ary 26 - 30, 1987 Inspect r:
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J. J B ke, Section Chief Date Signed En ne ring Section D) is on of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters (92701B)(927028), housekeeping (M834B), material identification and control (4290213) material control (429408), safety-related heating ventilating and air conditioning (HVAC) systems (50100) (Unit 2), steel structures and supports (Units 2), and licensee iden-tified items.
Results:
Two violations were identified "Failure to Follow Design Manual For PSAR/FSAR As-Built Changes" paragraph 3f and "Failure to Provide Adequate Report of Significant Construction Deficiency" paragraph - 8.
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a-t REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. W. Hayes, Vogtle QA Manager
- T. Greene, Plant Manager
- E. D. Groover, Quality Assurance (QA) Site Manager Construction Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.
Other Organizations
- F. B. Marsh, Project Engineering Manager, Bechtel Power Corporation (BPC)
NRC Resident Inspectors
- A. H. Livermore, Senior Resident Inspector (SRI), Construction J. Rogge, SRI Operations R. Shepens, RI
- Attended exit interview 2.
Exit Interview (30703B)
The inspection scope and findings were summarized on January 30, 1987, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
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(0 pen) Violation 50-424/87-11-01 and 50-425/87-07-01:
"Failure to Follow Design Manual for PSAR/FSAR As-Built Changes "paragraph 3f.
(0 pen) Violation 50-424/87-11-02 and 50-425/87-07-02:
"Failure to Provide Adequate Report of Significant Construction Deficiency" paragraph 8.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action o.1 Previous Enforcement Matters (92701B)(927028) a.
(Closed) Violation 50-424/86-59-01:
"Failure to Procure HVAC Systems That Were Fabricated, Installed and Inspected In Accordance With Procedures and Drawings" Georgia Power Company (GPC) letter of response dated September 25, 1986 has been reviewed and determined to be acceptable by Region II.
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t inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject violation, performed the necessary survey and followup 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, b.
'(Closed) Deviation 50-424/86-59-02 and 425/86-26-02:
"Failure To Procure Explosion Proof Motors As Committed" GPC letters of response dated September 25, 1986 and October 31, 1986, have been reviewed and determined to be acceptable by Region II. The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject deviation, performed the necessary survey and followup 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.
c.
(Closed) Deviation 50-424/86-59-03 and 50-425/86-26-03:
"Failure to Install Electrically Interlocked and Alarmed Control Room Doors as Committed" GPC letters of response dated September 25, 1986 and October 31, 1986 have been reviewed and determined to be acceptable by Region II. The inspector held discussions with the cognizant engineer and examined the coi rective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject l
deviation, performed the necessary survey and follow-up actions, to correct the present conditions and developed the necessary corrective i
actions to preclude recurrence of similar circumstances.
The corrective actions identified in the letter of response have been implemented.
d.
(Closed) Violation 50-424/86-72-01 and 50-425/86-34-01:
"Failure to l
Establish Adequate Measures to protect Installed Materials and Equipment from Temporary Construction Loads" l
GPC letter of response dated October 31, 1986 has been reviewed and l
determined to be acceptable by Region II.
The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject violation performed the necessary survey and followup actions, to correct the I
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.
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(Closed) Viola' tion 50-425/86-72-02 and 50-425/86-34-02:
"Failure to Assure Applicable Requirements are Included in Procurement Documents" GPC letters of response dated October 31, 1986 has been reviewed and determined to be acceptable by Region II.
The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of response. The inspector concluded that GPC had determined the full extent of the subject nonconformance 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.
f.
(Closed) Unresolved Item 50-424/86-59-04 and 50-425/86-26-04: "Design Control for Control Room Doors" This matter concerns the fact that FSAR Section 6.4.2.2.2 states: "To minimize inleakage, the control room access doors are equipped with self-closing devices that shut the doors automatically following the passage of personnel. Alarms are also provided to annunicate if any of the doors are open after a changeover to emergency operation. Two sets of electrically interlocked doors with a vestibule between acting as an airlock, are provided at each of the two entrances and the emergency exit to the combi 7ed control room and associated spaces."
This however, is not the as-built condition. The doors to the control room are installed in pairs, but they are not electrically interlocked and alarms are not provided to annunciate if any of the doors are open after a changeover to emergency operation.
At the time of the inspection reported in 50-424/86-59 and 50-425/
86-26, it appeared that the above was the result of a failure of l
the design control system to establish adequate measures to assure selection and review for suitability of application. of materials, Parts, and equipment that are essential to the safety-related functions of structures, systems, and components, but this could not be solidly substantiated.
The licensee indicated they would investigate the matter.
The licensee determined that the root cause of the above is as follows:
Control building floor plan drawing AX1011A04, Rev. 9, issued November 12, 1981, showed that the two sets of doors at the entrances are electrically interconnected and the one set of doors at the emergency exit is locked and alarmed.
On revision ten of the same drawing, issued August 11, 1982, the interlock /alurm requirements were removed from the drawing.
The original design included the interlock feature and this feature was removed from the design drawing during the l
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design evolution process.
The original input for the VEGP FSAR was developed in part based on the FSAR descriptions utilized by previously licensed Bechtel plants of similar design.
This input was then modified as necessary to reflect the specifics of the VEGP design.
The review process failed to identify the inconsistency between the VEGP design detail and that described in the input with respect to the interlock and alarm features.
The Vogtle Nuclear Project Design Manual, Section 3.4.6, requires the following:
Every design criteria dealing with safety-related structures, systems, or components shall include a separate section entitled, "PSAR Comparison."
In this section, every substantive difference between PSAR commitments and the current design shall be identified and briefly oescribed.
These comparisons will form the basis for preparation of the FSAR.
Clearly the above difference was not identified in the "PSAR Comparison" section which caused the defacto false statement to be carried over in to the FSAR.
The licensee stated that had the NRC not identified the above difference, the plant would become operational with the defacto false statement unidentified.
The above is of concern to the commission because the FSAR is the official vehicle by which construction permit holders report the as-built configuration of power reactor facilities to the commission for consideration of operations licensing.
In view of the above it is evident that the licensee failed to follow procedure (Vogtle Nuclear Project Design Manual Section 3.4.6).
For activities affecting quality failure to follow procedure is a violation of 10 CFR 50 Appendix B Criterion V.
This matter will be closed as an unresolved item and opened as violation 50-424/87-11-01/and 50-425/87-07-01:
"Failure to Follow Design Manual for PSAR/FSAR As-Built Changes."
Within the areas examined no violations or deviations were identified except as noted in paragraph 3f.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Independent Inspection Effort Housekeeping (54834B), Material Identification and Control (429028) and Material Control (429408)
The inspector conducted a general inspection of the Unit 2 Containment, and both auxiliary control and fuel buildings to observe activities such as housekeeping, material identification and control; material control, and storage.
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6.
Safety-Related Heating, Ventilating, and Air Conditioning (HVAC) Systems (50100)
Observation of Work and Work Activities a.
Personnel Interviews (Installation Practices)
The inspector interviewed four craftsmen engaged in the fabrication /
installation of seismic supports, ductwork, isolation dampers or additional safety-related HVAC equipment to confirm the following:
Predefined and approved procedures are followed when it becomes necessary to relocate any seismic support or other safety-related equipment from its original location specified on drawings.
Any preinstallation field repairs or adjustments to the HVAC equipment are performed in accordance with the manufacturer's instructions and specifications to ensure that proper materials, replacement parts, and supplies are used, performance requirements are met and are reviewed by engineering for acceptance.
Personnel engaged in the installation and inspection of safety-related supports,
- ductwork, and other safety-related HVAC equipment have received adequate training to understand and perform work contained in relevant work and inspection procedures and instructions.
b.
Installation Activities The inspector witnessed portions of the installation activities indicated below to verify the following:
The latest issue (revision) of applicable drawin'gs or procedures is available to the installers and is being used.
Modifications to supports are approved by appropriate personnel before implementation.
Activity Component Welding Duct Section A-2575A Welding Duct Support 05-2072104-35 Within the areas examined, no violations or deviations were identified.
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7.
Steel Structures and Supports (Unit 2)
The inspector observed welding work activities for steel structures and supports as described below to determine whether applicable code and procedure requirements were being met.
The applicable code for the activities examined was AWS D1.1-1975 and AWS 09.1-1980, a.
Welding The below listed welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure assignment; welding technique and sequence; materials identity; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature; interpass cleaning; process control systems; identify of welders; qualification of inspection personnel; and weld history records.
Welding Examined Duct Section A-2575A Duct Support 05-2072104-35 b.
Welding Filler Material Control (55152B)
The inspector reviewed the licensee's program for control of welding material.s to determine whether materials were being pur:hased, accepted, stored, and handled in accordance with QA procec'ures and applicable code requirements.
The following specific areas were examined:
Purchasing, receiving,
- storing, distribution and handling procedures, material identification Welding material, purchasing and receiving records for the following materials were reviewed for conformance with appifcable procedures and code requirements:
Type Size Heat / Control No.
ER-705-2 0.035" F7164 E-7018 3/32" MM081 E-7018 1/8" MM070 c.
Welder Qualification (551578)
The inspector reviewed the licensee's program for qualification of welders and welding operators for compliance with QA procedures and ASME Code requirements. The applicable code for welding qualification is ASME B&PV Code Section IX as invoked by GPC Specification X2AG06 Rev. 4 and X4AZ01, Section P.1, Revision 8.
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The following welder qualificatien status records and "Records of Performance Qualification Test" were reviewed relative to the weld joints listed in paragraph 7a.-
Weld Symbol 36 98 1020 Within the areas examined, no violations or dev' ations were identified.
8.
Licensee Identified Items (Closed) Item 424, 425/CDR-82-32:
"HVAC Duct Support-Design Inconsist-encies" (10 CFR 50.55(e))
On September 30, 1982, the licensee notified IE:II of a 50.55(e) item concerning inconsistencies in HVAC duct support drawings. The final report was submitted on August 15, 1983.
The inspector of record for report 50-424, 425/87-05 noted that the final report indicated that 120 duct supports were identified as having significant deficiencies.
Further that modification of these supports had not occurred as of the date of the final report but was intended af ter additional correction of the pCl drawings to conform to design requirements. Cognizant licensee personnel were unable to locate quality data confirming proof of modification of the 120 supports during that inspection.
The licensee informed this inspector that the CDR reported 120 defective drawings which represented 120 supports.
Not all the 120 supports represented had been fabricated or installed prior to issuance of Stop Work Notice SW-M-06 in September 1982.
Conditions for the release to continue work were that HVAC contractor only work to Bechtel Power Corporation (BPC) statused (reviewed for compliaace to design) DS drawings.
BPC began statusing all DS drawings in September, 1982.
Design Evaluation Report OER-025 was issued to track this initial statusing effort which addressed approximatt.ly 4700 drawings.
Upon completion of this statusing effort, BPC identified 120 drawings which had significant discrepancies from the design drawings.
The licensee was unable to provide the inspector of record for report 50-424, 425/87-05 quality data conforming the acceptability of the 120 supports.
This inspector discussed the above with the licensee noting that the licensee's final report did not include sufficient information to permit the evaluation of the corrective actions as the supports requiring corrective actions could not be identified. The preceeding is clearly contrary to, and
9 8
t therefore, in violation of 10 CFR 50.55(e)(3) which requires the holder of a construction permit to submit a written report on a reportable deficiency within thirty (30) days. The report shall include a description of the deficiency, an analysis of the safety implications and the corrective action taken, and sufficient information to permit analysis and evaluatio of the deficiency and of the corrective action. This matter will be identi,ied as violation 50-424/87-11-02, 50-425/87-07-02:
"Failure to Provide Adequate Report of Significant Construction Deficiency" The licensee was finally able to provide this inspector a partial list (51 of the reported 120) of supports. This list was gleaned from private notes of the BPC Engineer in California who identified the 120 deficient drawings.
Of the 51 deficient drawings gleaned, only 16 supports had been fabricated or installed prior to the stop work notice.
This inspector reviewed drawings, and inspection documentation for all 16 supports, made a field
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inspection, and found no deviations from design requirements. Based on the above inspection and other inspections made by this inspector, of the HVAC contrector, performed af ter the stop work notice, and prior to this inspec-tion, this matter will be closed as a licensee identified item and opened as violation 50-424/87-11-02 and 50-425/87-07-02: "Failure To Provide Adequate Report Of Significant Construction Deficiency."
hithin the areas examined no deviations or violations were identified except as noted above.
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FEB 051988 Docket Nos. $0-424, 50-425 License Nos. NPF-68, CPPR-109 Georgia. Dower Company ATTN: Mr. James P. O'Reilly Senior Vice President-Huclear Operations P. O. Box 4545 Atlanta, GA 30302 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-424/88-04 AND 50-425/88-03 This refers to the Nuclear Regulatory Comission (NRC) inspection conducted by W. Kleinsorge en January 11-15, 1988.
The inspection included a review of activities authorized for your Vogtle facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.
Within the ' cope of the inspection, no violations or deviations were s
identified.
Your attention is invited to the unresolved items identified in the inspection report.
This matter will be pursued during future inspections.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2 Title 10 Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Si
- erely, an R. Herdt, Chief Engine ring Branch Divis on of Reactor Safety
Enclosure:
NRC Inspection Report cc w/ enc 1:
(See page 2)
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FEB 05 L98g Georgia Power Company 2
cc w/ encl:
P. D. Rice, Vice President, Project Ofrector C. W. Hayes, Vogtle Quality Assurance Manager G. Bockhold, Jr., General Manager, Nuclear Operations L. Gucwa, Manager, Nuclear Safety and Licensing J. A. Bailey, Project Licensing Manager
- 8. W. Churchill, Esq., Shaw, Pittman, Potts and Trowbridge D. Kirkland, III, Counsel, Office of the Consumer's Utility Council
- 0. Feig, Georgians Against Nuclear Energy l
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Report Nos.:
50-424/88-04 and 50-425/88-03 Licensee: Georgia Power Company
- p. O. Box 4545 Atlanta, GA 30302 Docket Nos.:
50-424 and 50-425 License Nos.:
NPF-61 and CPPR-109 Facility Name:
Vogtle 1 and 2
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Inspection Con cts.
ar '11-15, Inspector:
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n Date Signe Approved by:
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J. J. JHale, Section Chief Da t'e 5 t'gned gi eering Branch iv sion of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of licensee, actions on previous enforcement inatters (927018) (927028),
housekeeping (548348), material identification and control (429028) material control (429408), and heating ventilating and air conditioning systems (50100).
Results:
No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- L. N. Brooks, Civil Discipline Manager
- E. D. Groover, Quality Assurance (QA) Site Manager - Construction
- P. D. Rice, Vice President and Project Director Other licensee employees contacted included construction craf tsmen, engineers, technicians, and office personnel.
NRC Resident Inspectors
- R. Schepens, Senior Resident Inspector (SRI)
- Attended preliminary exit interview on January 14, 1988
- Attended exit interview on January 15, 1988 2.
Exit Interview The inspection scope and findings were sumarized on January 14, 1988, at a preliminary exit interview conducted for the convenience of the licensee's staff who would not be on site on the last day of the inspection.
The preliminary exit interview was conducted with those persons indicated in Paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection findings.
The inspector conducted a final exit interview on January 15, 1988, with the person indicated in paragraph 1 above.
No dissenting coments were received from the licensee.
(0 pen) Unresolved : tem 50-425/88-03-01:
"Apparent Failpre to Install and Inspect HVAC Duct Supports in Accordance with Drawings" - Paragraph No.6.c.(1).
(0 pen) Unresolved Item 50-425/88-03-02:
"Air Filter Housing Seismic Analysis" - Paragraph Mo. 6.c.(2).
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (927018) (927028)
(Closed) Deviation 50-424/86-59-03 and 50-425/86-26-03:
"Failure to Install Electrically Interlocked and Alarmed Control Room Access Doors as Consni tted".
1 N
2 GPC letters of response dated September 25, 1986, October 31, 1986, March 31, 1987 and July 23, 1987 have been reviewed and determined to be acceptable by Region II.
The inspector held discussions with cognizant management personnel and examined the corrective actions as stated in the letters of response.
The inspector concluded that GPC had determined the full extent of the subject deviation, perfomed the necessary survey and follow-up actions to correct the present coriditions and developed the necessary corrective actions to preclude recurrence of similar ci rcumstances.-
The corrective actions identified in the letter of response have been implemented.
4.
Unresolved Items Unrosolved items are matters about which more infomation is required to determine whether they are acceptable or may involve violations or deviations.
New unresolved items identified during this inspection are discussed in Paragraph 6c(1) and 6c(2).
5.
Independent Inspection Effort Housekeeping (548348), Material Identification and Control (42902B) and Material Control (429408)
The inspector conducted a general inspection of Unit 1 and 2 auxiliary buildings and the Unit 2 containment building to observe activities such as housekeeping, material identification and control; material control, and storage. The inspector found two Type 7018 Shielded Metal Arc Welding (SMAW) electrodes, abandoned on duct associated with EFS Airfilter Housing No. 2-1561-N7-001.
This is similar to a concern discussed in NRC Region II Report No. 50-424/88-03 and 50-425/88-02.
Within the areas examined no deviations were identified.
6.
Heating Ventilating and Air Corditioning (HVAC) Systems (50100)
The inspector observed work in progress, conducted interviews, examined completed work and reviewed records to determine:
whether the installation of safety-(related HVAC systems in compliance with Nuclear Regulatory Consission NRC) requirements, licensee comitments, and applicable codes; whether the licensea was adequately preparing, reviewing, and maintaining a system of quality records; whether the records reflect work accomplished consistent with NRC requirements and Safety Analysis Report (SAR) comitments; and whether the records indicate any potentially generic problems, management control inadequacies, or other weaknesses that could have safety significance, i
3 a.
Observation of Work and Work Activities (1) Personnel Interviews (Installation Practices)
The inspector conducted interviews with three contractor (Pullman /Kenith Fartson (P/K-F)) personnel engaged in fitting and welding activities associated with the installation of isolation dampers with Nuclear Plant Maintenance Work Order (MWO) No. 28701912.
These interviews were conducted to confirm the following:
predefined and approved procedures are followed when it becomes necessary to relocate any seismic support or other safety-related equipment from its original location specified on drawings; any preinstallation field repairs or adjustmE1ts to the HVAC equipment are performed in accordance with the enanufacturer's instructions and specifications to ensure that proper materials, replacement parts, and supplies are used, and perfonnance requirements are met and are reviewed by engineering for acceptance; preinstallation checks are made to ensure that bolts, nuts, and other fastener items are available and are of the correct type, size and material with required identification markings; and personnel engaged in the installation and inspection of supports, ductwork, and other HVAC equipment have received adequate training to understand and perform work contained in relevant work and inspection procedures and instructions.
(2)
Installation Activities (a)
The inspector witnessed portions of the welding and fitting activities associated with MWO No. 28701912 to verify the following:
the latest issue (revision) of applicable drawings or procedures was available to the installers and is being used; and modifications to supports were approved by appropriate personnel before implementation.
(b)
The inspector reviewed records of the concrete anchor bolts associated with the below listed Duct Supports to verify that anchor bolt type, diameter, embedment length, shoulder-to-cone measurement and torque requirements (where applicable) met installation requirements.
Record review was elected as the window of opportunity had past for direct observation of this activity.
Duct Support Record Examined 2-132-92 2-132-87 2-132-89
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(3) As-Installed Equipment The inspector examined the installed equipment listed below for proper location, configuration, identification, and damage.
The basis for this determination was the SAR system description, Piping and Instrumentation Diagrams (PalDs), specifications, and installation drawings.
Equipment Examined Air Handling Unit 2-1555-A7-003 Duct Supports
- 92,94, 89, 88 and 87 Fire Damper 2-1555-S7-2105 Duct Sections A-2710N, A-2710M, A-2710L A-2710-K-T, A-2710K, A-2710J A-2710-A, A-27108, A-2710-E A-2710-0,A-2710C,A-2710Q A-2710-S and A-2710-H Air Filter Unit 2-1561-N7-001-000 Isolation Damper 2-HV-12614 Motor (Fan) 2-1561-N7-001-M01 Ouct Supports
- 195 and 77 Duct Sections A-3927B, A-3927A, A3927 A-3814, A3815 A3815-A A-3816, A-3817 and A3818 b.
Review of Records (1) The inspector reviewed receipt inspection check sheets for the below listed components to assure that inspections complied with the intent of the inspection procedures.
Component Records Examined Duct Support A-27100. A-2710C, A-2710G,
A-2710-H, A-3927A, A-3815 Air Filt Unit 2-1561-N7-001-000 Isolation Damper 2-HV-12614 Fire Damper 2-1555-S7-2105 Air Handling Unit 2-1555-A7-003 (2) The inspector reviewed the installation inspection records for the below listed systems to determine whether required inspections of various aspects of HVAC systems and supports were conducted, and to assess the adequacy of the inspection effort and the inspection records.
System 1 - Air Handling Unit 2-1555-A7-003 from Support No. 92 to Support 87 1
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i System' 2 '- Air Filter Unit 2-1561-N7-001 from Duct Section A-3927 to Damper 2HV-12614 c.
Observations Relative to the inspections above the inspector made the following L
observations:
(1) System 1 Completed, inspected and accepted Heating Ventilating and Air Conditioning (HVAC) Nuclear Safety Related. Seismic Class 1, Duct Support No. 2-132-88 is depicted on Field Change Request (FCR) W. FCRB-5367F and Bechtel Power Company (BPC) drawings No. AXD67WO41 Revision 1.
Drawing AXD67WO41 details for Type 301 specifies dimension "0" (the distance between the center line of the duct section and a 5x5x3/8-inch square tube) (see
, ) to be 1-foot 0 inches maximum (12-inches maximum).
In point of fact the actual "0" dimension is 141/2-inches.
Subsequent to the identification of this discrepant condition by the NRC inspector the licensee documented the discrepancy in Oeviation Report (DR) No. PK-4184.
This condition indicates that the installing craftsman failed to install the duct in accordance with the applicable drawing and that the Quality Control (QC) inspector accepting the discrepant I
. nuclear safety-related, seismic category 1 HVAC duct support failed to inspect the duct support in accordance with the applicable drawing.
Failure to install and inspect the duct support in accordance with the applicable drawing brings into sharp focus the following:
the craftsman exceeded the 12-inch maximum specified by the drawing; the craftsman failed to get an engineering evaluation of the descrepant condition; the craftsman offered for inspection a duct support that deviated 'from the drawing; the QC inspector failed to identify fact that the "0" dimension exceeded the drawing maximum of 12-inches; the QC inspector accepted the descrepant condition; the QC inspector signed the inspection record indicating that the duct support conformed to the drawing when in point of fact it did not. By installing and accepting this descrepant nuclear safety-related seismic category 1 F.YAC duct support, the installing craftsman and the accepting QC inspector usurped the prerogative, responsibility, and authr.,rity of the designer to evaluate and accept conditions outside of design envelope as defined by drawings.
The above indicates that the licensee was in apparent violation of NRC Regulations.
However at the time of this inspection the folltming remained unresolved:
how the regulatory requirement was violated; when and for how long the violation existed; by
6 wh'om the regulatory requirement was violated; whether there are multiple examples of the violation; the _ root cause of the violation; the apparent safety significance of the violation; whether there is evidence of management involvement and to what extent; and, how many opportunicies the licensse had to discover the violation.
Pending the resolution of the above issues this matter will be identified as unresolved item identified as 50-425/88-03-01:
"Apparent Failure to Install and Inspect HVAC Duct Supports in Accordance With Drawings".
l (2) System 2 1
The 2-1561-N7-001 Engineered Safety Feature (ESF) l Airfilter Housing is attached to the datum foundation by 3-1/2x3-1/2x1/4x4-inch angle clips.
These angle clips are shown on Attachment (2) and share a horizontal interface with the foundation, and a vertical interface with the airfilter housing.
The interfaces are secured by bolting.
The NRC inspector noted that several of these angle clips had only line contact at the top and bottom c: Ige of the vertical intsrface the result of i
interference from a fillet weld on the air filter housing (see l ).
The Vogtle plant (VEGP) Final Safety Analysis Report (FSAR) Section 6.5.1.3.E states in part "the ESF filter systems are designed to seismic category I requirements. The NRC inspector discussed the above with the licensee, pointing out, that those connections with only double line contact could not be considered as friction connections.
In view of the above, the NRC inspector questioned whether the lack of friction connections on the supports of a seismic category 1 component, abrogated the seismic analysis and qualification of the equipment, and therefore by deviated from a consnitment to the commission (FSAR 6.5.1.3.E).
The licensee contacted the manufacturer of the air filter housing, American Air Filter (AAF) relaying the NRC inspectors concern.
AAF indicated, to the licensee, that as long as the bolts connecting the clips to the filter housing were tight the seismic analysis and qualification was valid.
AAF stated that they would send supporting documentation to the site.
The NRC inspector stated pending NRC review of the AAF documentation this matter will be identified as unresolved item 50-425/88-03-02:
"Air Filter Housing Seismic Analysis".
(3) Coninon The documentation associated with air handling Unit 2-1555-A7-003 (System 1) was completed including the QA review.
The documentation associated with air filter Unit 2-1561-N7-001 (System 2) was complete to a point but had not had its final QA
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There were numerous inconsistencies in the air filter (system 2) documentation (no QA review) and none identified in the air handling (system 1) documentation (QA review completed).
The inspector examined several hundred documents associated with each system. The inspectors obvious conclusior. was that "Quality of Paper" is "inspected in" by QA review and not built in by conscientious personnel who generate the documentation with keen attention to detail.
It should be noted that no violations or deviations were noted relative to either documentation package.
Within the areas examined no violations or deviations were ide'nti fied.
7.
Table of Acronyms and initialisums AAF American Air Filter BPC Bechtel Power Company DR Deviation Report ESF Engineered Safety Features Field Change Request FCR FSAR Final Safety Analysis Report HVAC Heating '.'entilating and Air Conditioning MWO Maintenance Work Order NRC Nuclear Regulatory Commission P&ID Piping and Instrumentation Diagram P/X-F Pullman /Kenith - Fortson Quality Assurance QA Quality Control QC RII Region II SRI Senior Resident Inspector 10 CFR 50 -
Title Ten, Code of Federal Regulations Part 50 Attachments:
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pWo UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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MAY 261988 Docket Nos. 50-424, 50-425 License Nos. NPF-61, CPPR-109 Georgia Power Company ATTN: Mr. R. P. Mcdonald Executive Vice President -
Nucle'ar Operations P. O. Box 4545 Atlanta, GA 30302 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NOS. 50-424/88-18AND50-425/88-20)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by W. P. Kleinsorge on April 18-22 and May 2-5, 1988.
The inspection included a review of activities authorized for your Vogtle facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.
The inspection findings indicate that certain activities appeared to violate NRC requirements.
The violation, references to pertinent requirements, and elements to be included in your response are described in the enclosed Notice of Violation.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
l The responses directed by this letter and its enclosures are not subject to the l
clearance procedures of the Office of Management and Budget as required by the l
Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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MAY 261988 Georgia Power Company 2
I Should you have any questions concerning this letter, please contact us.
Sincerely, Alan R/ Herdt, Chief Engin6ering Branch Division of Reactor Safety
Enclosures:
1.
NRC Inspection Report cc w/encis:
P. D. Rice, Vice President, Project Director C. W. Hayes, Vogtle Quality Assurance Manager G. Bockhold, Jr., General Manager, Nuclear Operations L. Gucwa, Manager, Nuclear Safety and Licensing J. A. Bailey, Project Licensing Manager B. W. Churchill, Esq., Shaw, Pittman, Potts and Trowbridge D. Kirkland, III, Counsel, Office of the Consumer's Utility Council D. Feig, Georgians Against Nuclear Energy l
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t ENCLOSURE I NOTICE OF VIOLATION Georgia Power Company Docket Nos. 50-424 and 50-425 Vogtle License Nos. NPF-61 and CPPR-109 During the Nuclear Regulatory Commission (NRC) inspection conducted on April 18-22 and May 2-5, 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:
Title Ten Code of Federal Regulation Part 50, Appendix B, Criterion V requires that activities affecting quality to be prescribed by documented drawings and procedures of a type appropriate to the circumstances and that those activities be accomplished in acceptance with those drawings and procedures.
The Final Safety Analysis Report (FSAR) Section 6.5.1.3.E states in part "the ESF filter systems are designed to seismic Category 1 requirements."
American Air Filter (AAF) letter dated April 1,1988, appropriate to all the Engineered Safety Feature (ESF) air filter housing units in both units states in part:
"To meet the seismic qualification, the angle clips should be bolted to the base channels with Type A-449 high strength bolts, i
or equivalent, pretensioned to meet the friction connection requirement."
Type A-449 bolts have a minimum required tensile strength of 100 K!PS Square Inch (KSI)
The following procedures are appropriate to the installation of ESF air fil ter housing 2-1561 N7-001.
Procedure JP-513 "Installation and Inspection of High Strength Bolts", Paragraph 5.4 requires that bolted l
contract surfaces have burrs removed and shall be free of dirt, oil, loose scale, pits or other defects that would prevent solid seating or sound bearing of component parts.
Paragraph 6.2.2.d.1 requires that washers shall be installed under the bolt head and nut when the hole enlargement exceeds 1/8."
Bechtel Power Company (BPC) drawing 2X4AJ07-325-7, Section "8B", specifies 3/4-10 bolts.
l The following were identified as appropriate for Heating Ventilation and Air Conditioning (HVAC) Nuclear Safety-Related, Seismic Class 1, Duct i
Support No. 2-132-88 depicted on Field Change Request (FCR) No. FCR8-5367F and on the following BPC Drawings No. AXD67WO41 Revision 1.
Drawing AXD67WO41 Det6ils for Type 301, specifies dimension "0" (the distance between the center line of the duct section and a 5x5x3/8-inch square tube) to be 1-foot 0 inches maximum (12-inches maximum).
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- o Georgia Power Company 2
Docket Nos. 50-424 and 50-425 License Nos. NPF-61 and CPPR-109 Vogtle s
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a.
Contrary to the above, procedures and drawings were not, of a type, appropriate to the circumstances, to assure that proper bolting materials would be correctly installed, to comply with the commitments of the FSAR, as evidenced by the following:
Drawing 2X4AJ07-325-7 Section "B-8" specified "3/4-10 Hardware (by AAF)" with no specifi-cation.of bolt type, or torque (pretension) requirements.
The omission resulted in the Unit One ESF air filter housing assemblies being installed with snug tight (not pretensioned) unmarked bolts (presumed A-307 with a tensile st-ength of 60 KSI). The Unit Two ESF filter housing assemblies were rstalled with snug tight (not pretensioned) high strength bolts.
b.
Cont ary to the above, activities affecting quality were not accunplished in accordance with procedures, in that the installing craftsmen failed to install ESF air filter housing units and HVAC duct support in accordance wi^h drawings and procedures, and the QC inspectors accepted those discrepant conditions.
Specific examples are listed below:
1.
Relative to the ESF air filter housing assembly No. 2-1561-N7-001:
(a) Bolted contract surfaces were not free of defects (interfering filet welds) that prevented solid seating and sound bearing of the component parts.
(b) Washers were not installed under the bolt heads over the slotted holes.
i (c) A 5/8-inch diameters bolt was used when a 3/4-inch diameter bolt was required.
2..
Relative to HVAC duct Support No. 2-132-88:
The actual "0" dimension is 14-1/2-inches.-
The conditions cited in A and B. above have existed is some part since April 24, 1984.
The licensee has had at least 14 opportunities to discover portir7s of the cited conditions.
This is a Severity Level IV Violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Comission, ATTN:
Document Control Desk, Washington, DC 2055C. with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector Vogtle, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of l
e 3
Docket Nos. 50-424 and 50-425 Georgia Power Company License Nos. NPF-61 and CPPR-109 Vogtle t
Violation" and should include [for each violation]:
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Security or sa'feguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.
FOR THE NUCLEAR REGULATORY COMMISSION lan
. Herdt, Chief Engi eering Branch Division of Reactor Safety Dated at Atlanta, Georgia this day of May 1988 l
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v UNITED STATES NUCLEAR REGULATORY COMMISSION s
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Report Nos.:
50-424/88-18 and 50-425/88-20 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.:
50-424 and 50-425 License Nos.:
NPF-61 and CPPR-109 t
Facility Name:
Vogtle 1,and 2 Inspection Co of
s-22,1988 and May 2-5, 1988 Inspector:
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6 Approved by:.
J. J }Take,SectionChief Date S1gned
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ifion of Reactor Projects
SUMMARY
Scope:
This routine, unannounced inspection was in the areas of licensee actions on previous enforcement matters (927018) (927028), heating, ventilating and air conditioning (HVAC) system (Unit 2), and readiness review Module 18A.
"Heating Ventilation, and Air Condition."
Results:
One violation was identified. "Failure To Install HVAC Systems In Accordance With The FSAR.
t REPORT DETAILS 1.
Persons Contacted Licensee Employees
- A. B. Gallant, Project Compliance Coordinator
- E. D. Groover, Quality Assurance (QA) Site Manager Construction
- I. D. Innes, Civil Engineer
- R. W. McManuw, Readiness Review
- R. H. Pinson, Vice President
- P. D. Rice, Vice President / Project Director
- P. R. Thomas, Readiness Review Other licensee employees contacted included construction craftsmen engineers, technicians, and office personnel.
Other Organization
- J. P. Hawlew, Bechtel Power Company (BPC) Project Engineer
- F. C. Ling, BPC - Engineering Group Leader NRC Resident Inspector
- R. Schepens, Senior Resident Inspection (SRI)
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 5,1988, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection. findings.
No dissenting comments were received from the licensee.
The following new item (s) were identified during this inspection:
(0 pen)
Violation -
50-424/88-18-01 and 50-525/88-20-01:
"Failure To Install HVAC Systems In Accordance With The FSAR" -
Paragraph 3b (0 pen) inspection Followup Item -
50-424/88-20-02:
"Unavailable HVAC Documents" - Paragraph 5e The licensee did identify some material as roprietary during this inspection, but this material is not i~cludet
- this inspection report.
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3.
1.icensee Action on Previous Enforcement Matters (927018) (927028) a.
(Closed) Unresolved Item 50-425/88-03-01:
"Apparent Failure To Install and Inspect HVAC Duct Supports In Accordance With Drawings" This item identified the following condition:
completed, inspected and accepted HVAC Nuclear Safety-Related, Seismic Class 1, Duct Support No. 2-132-88 is depicted on Field Change Request (FCR) No.
FCRB-5367F and BPC Drawing No. ACD67WO41 Revision 1.
Drawing AXD672041, Details for Type 301, specifies dimension"D" (the distance between the center line of the duct section and a 5x5x3/8-inch square tube) to be 1-foot 0 inches maximum (12-inches maximum).
In point of fact the actual "D" dimension is 14 1/2-inches.
Subsequent to the identification of this discrepant conditions by the NRC inspector the licensee documented the discrepancy in Deviation Report (OR) No.
PK-4184.
This condition indicates that the installing craftsman failed to install the duct in accordance with the applicable drawing and that the Quality Control (QC) inspector accepting the discrepant nuclear sa fety-rela ted, Seismic Category 1 HVAC duct support failed to inspect the duct support in accordance with the applicable drawing.
Failure to install and inspect the duct support in accordance with applicable drawing brings into sharp focus the following:
the craftsman exceeded the 12-inch maximum specified by the drawing; the craftsman failed to get an engineering evaluation of the discrepant condition; the craftsman offered for inspection a duct support that deviated from the drawing; the QC inspector failed to identify fact that the "D" dimension exceeded the drawing maximum of 12-inches; the QC inspector accepted the discrepant condition; the QC inspector signed the inspector record indicating that the duct support conformed to the drawing when in point of fact it did not.
By I
installing and accepting this discrepant nuclear safety-related Seismic Category 1 HVAC duct support, the installing craftsman and
)
the accepting QC inspector usurped the prerogative, responsibility, l
and authority of tne designer to evaluate and accept conditions l
outside of design envelope as defir:ed by dr. ings.
The above is an example of failure to follnw procedure for activities affecting quality.
This matter will be closed as an unresolved item and became an example of Violation 50-424/88-18-01 and 50-425/88-20-01, discussed further in Paragraph 3.b.
b.
(Closed) Unresolved Item 50-425/88-03-02:
"Air Filter Housing Seismic Analysis" This item identified the following.
The 2-1561-N7-001 Engineered Safety Feature (ESF) air / filter housing assemblies is attached to the
3 I
datum foundation by 3-1/2x3-1/2x1/4x4-inch angle clips. These angle clips share a horizontal interface with the foundation, and a vertical interface with the air / filter housing.
The interfaces are secured by bolting. -The NRC inspector noted that several of these angle clips had only line contact at the top and bottom edge of the vertical interface the result of interference from a fillet weld on the air filter housing.
The Vogtle plant (VEGP) Final Safety Analysis Report (FSAR) Section 3.5.1.3E states in part "the ESF filter systems are designed to Seismic Category I requirements. The NRC inspector discussed the above with the licensee, pointing out, that those connections with only double line contact could not be considered as friction connection.
In view of the above, the NRC inspector questioned whether the lack of friction connections on the supports of a Seismic Category 1 component, abrogated the seismic analysis and qualification of the equipment, and thereby deviated from a commitment to the commission (FSAR 6.5.1.3.E).
The licensee contacted the manufacturer of the air filter housing, American Air Filer (AAF) relaying the NRC inspectors concern.
AAF indicated, to the licensee, that as long as the bolts connecting the clips to the filter housing were tight the seismic analysis and qualification was valid. AAF stated that they would send supporting documentation.
In addition to the above, but not documented in NRC Report Nos.
50-424/88-04, 425/88-03, The inspector noted that there were no washers installed between the bolt head and the angle clip's vertical surface, slotted hole (13/16 x li - inch).
As a result of this unresolved item, the licensee performed a reinspection of this air filter housing assembly's mounting bolts, as well as the mounting bolts for the remaining five Unit Two and eight Unit One other ESF air filter housing assemblies.
This inspection revealed that all the Unit One air filter housing assemblies were mounted with 3/4-10 snug tight (not torqued) unmarked (assumed Type A-307 which has a tensile strength 50 to 70 Kips / Square Inch (KSI) i bolts.
The inspection revealed that all but one bolt used to mount the unit two air filter units were 3/4-10 snug tight (not torqued)
Type A-325, or A-490 bolts (A-325 has tensile strength of 105 KSI and A-490 has a tensile strength of 150 KSI).
The remaining bolt was a j
snug tight (not torqued) 5/8-11.
I The applicable drawing available to the craftsman who installed the l
mounting bolts and the QC inspection who accepted the installation of l
the mounting bolts was 1X4AJ07-273-5 for unit one and 2X4AJ07-325-7 for unit two.
Section "B-B" from both drawings (Reproducerd as Attachment I herein) specifies "3/4-10 hardware provided by AAF."
The applicable procedure available to the craf tsmen and inspectors for the installation of Type A 307 bolting, P/L-F JP-14.2, "Process Control Program" Exhibit 16 specifies snug tight with the warning "Do Not Over Torque".
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e The Applicable Procedures available to the Unit Two Craftsmen and QC inspectors were:
P/K-F JP-513 "Installation and Inspection of High Strength Bolts" (Applicable To All Unit Two assemblies) and P/K-F MIP/ Equipment Installation Special Instruction Sheet No 2-1561-N7-002 Housing (Applicable To the 2-1561-N7-002 assembly only).
JP-513 Paragraph 5.4 requires that bolted contact surfaces shall.:ve all burrs removed and shall be free of dirt, oil, loose scale, pits or other defects that would prevent solid seating or sound bearing of component parts.
JP-513 Paragraph 6.2.2.d.1 requires that washers shall be installed under the bolt head and nut when the hole enlargement exceeds 1/8".
P/K-F MPI/ Equipment Installation special Instruction 2-1561-N7-002, Page 2 of 39, Item 7 specifies the use of Type A-325 equivalent or better 3/4-inch diameter bolting hardware to a snug tight condition.
In view of the above the installing craftsmen and the accepting QC inspectors followed the appropriate drawing and procedure require-ments for Unit One and Unit Two with the following exceptions:
1.
The bolted contact surfaces were not free of defects (the interfering fillet welds) which prevented solid secting and sound bearing of the component parts.
2.
Washers were not installed under the bolt heads over the slotted holes.
3.
A 5/8-inch diameter bolt was used when a 3/4-inch diameter bolt was required.
The support documentation submitted by AAF in response to the GPC question related to this unresolved item stated in part:
"To meet the seismic qualification, the angle clips should be bolted to the base channels with Type A-449 high strength bolts, or equivalent, pretensioned to meet the friction connection require-ment."
(Note:
Type A-449 bolts are equal to Type A-325 with a 105-KSI specified tensile strength)
The AAF letter indicates that neither the Unit One or Two air filter housing assemblies were installed in accordance with the FSAR, in that the Unit One assemblies were installed with under-strength bolts that were not pretensioned (torqued) and the Unit Two assemblies were installed with appropriate strength bolts that were not pretensioned (torqued).
The above clearly indicates the procedures and drawings were not of a type appropriate to the circumstance to assure that proper bolting materials would be correctly installed to comply with the Conmitments of the FSAR.
In addition, the installing craftsmen failed, to assure
7 s,
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that bolted contact surfaces were free of defects that would prevent those surfaces to seat solidly and have sound bearing, and to install washers under bolt heads over slotted holes, and that bolts were of a proper diameter.
The accepting QC inspectors accepted the same discrepant condition and the QC inspectors signed the inspection record attesting to the fact that the ESF Seismic Category 1 air filter housing assemblies were installed in accordance with procedures and drawings when in point of fact they were not.
The above condition has existed in some part since April 24, 1984.
The licensee has had at 1 tast 14 opportunities to discover portions of this violation, once i.ir each air filter housing assembly installation and inspection.
The above procedure inadequacies and, the examples of failure to follow procedures combined with the example of failure to follow procedure discussed in Paragraph 3a, show what activities affecting quality were not prescribed by documented drawings and procedures of a type appropriate to the circumstances and that those activities were not accomplished in accordance with those drawings and procedures.
'This is a violation of Title Ten, Code of Federal l
Regulations, Part 50 (10 CFR 50) Appendix B, Criterion V.
This matter will be closed as an unresolved item and opened as violation 50-424/88-18-01 and 50-425/88-20-01:
"Failure to Install HVAC Systems In Accordance With The FSAR."
S.
Heating Ventilating and Air Conditioni.ig (HVAC) Systems (50100) (Unit 2) l The inspector reviewed records to determine:
whether the installation of safety-related HVAC system in compliance with Nuclear Regulatory Commission (NRC) requirements, licensee comitments, and applicable codes; l
whether the licensee was adequately preparing, reviewing, and maintaining I
a system of quality records; whether the records reflect work accomplished consistent with NRC requirements and Safety Analysis Report (SAR) commitments; and whether the records indicate any poten'tially generic problems, management control inadequacies, or other weaknesses that could have safety significance, a.
The inspector reviewed selected documentation for the below listed components to verify seismic qualification per IEEE-344-1975, "Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Station", or other appropriate requirements.
l Content Fan with motor for air handling assembly 2 15561-N7-001-000 Cooling coils for air handling assembly 21555-A7-003 b.
The inspector reviewed selected documentation for the below listed mechanical components to verify conformance with the applicable portions of Regulatory Guide 1.52
}
c 6
e Components HEPA Filters Ser. No. 41344297-316 Neopreme Duct Gasket - ASTM-D-SCE-43,1 Silicone Ruber Sealant - 732 RTV c.
The inspector reviewed the below list Nonconformance (NCR) Reports to determine whether:
The records are being properly identified, stored, and can be retrieved in a reasonable time; the records are legible, complete, and indicate that reports are promptly reviewed by qualified personnel for evaluation and disposition of the immediate problem as well as for generic implications and trending; the records adequately document current status of nonconformances or deviation and corrective action; and resolution of nonconformances demonstrates good engineering practice.
NCR's Examined SQ-354 PK-3912 PK-2805 PK-3463 PK-3184 PK-3009 PK-2752 PK-2632 PK-3700 PK-4133 d.
The inspector reviewed the relevant portions of the below listed license audit reports concerning the installation of safety-related supports and HVAC systems to determine whether:
The required audits have been performed in accordance with schedule and functional areas l
in established audit plans; audit findings have been reported in sufficient detail to permit a meaningful assessmsnt by those responsible for corrective action, final disposition, and trending; and the licensee / contractor have taken proper and timely followup action on those matters in need of correction.
1 Audit Reports Examined CP-22-87/38 l
CP-20/CP-22-86/50 l
CP-22-86/29 e.
With regard to the inspection above the licensee was unable to provide the documentation described in ANSI /ASME N509-1980, "Nuclear Power Plant Air Cleaning Units and Components", Paragraph 5.4.2. for l
7 f
the 2-1561-N7-001-000, Moisture Separator Unit.
The licensee indicated that they would located the documentation and make it available to the inspector.
Pending NRC review of. this documen-tation, this matter will be identified as Inspector Followup Item 50-425/88-20-02: "Unavailable HVAC Documents."
Within the areas examined no deviations or violations were identi-fied.
6.
Readiness Review, Module 18A "Heating Ventilation, and Air Conditioning" Readiness Review Module 18A was submitted to the NRC on February 12, 1988, with an effective date of July 15, 1987.
The module was reviewed for program description, implementation, technical commitment adequacy, and program assessment.
The specific commi tments evaluated for adequacy are listed in.
Unit 2 HVAC activities were examined by the NRC and discussed in NRC Reports indicated below.
Report No 50-424/87-11 and 50-425/87-07 50-424/88-04 and 50-425/88-03 50-424/88-18 and 50-425/88-20 Within the area examined no violations or deviations were identified.
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Acronyms and initialisums American Air Filter AAF Bechtel Power Company BPC Deviation Report DR Engineered Safety Features ESF Field Change Request FCR Final Safety Analysis Report FSAR Heating Ventilating and Air Conditioning HVAC MWO Maintenance Work Order Nuclear Regulatory Commission NRC Piping and Instrumentation Diagram P&ID Pullman /Kenith - Fortson P/X-F Quality Assurance QA QC Quality Control Region II RII Senior Resident Inspector SRI 10 CFR 50 -
Title Ten, Code of Federal Regulation Part 50 Attachments:
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I 05/05/88 PLANT YOGTLE UNIT 2 READINESS REVlW I'ROGRAM COPNI1 MENT MATRIX MODULE 18A
=====================:====== u=====-
REF. COPMI1?ENT COPNI1?ENT COPMI1NENT DOCLNENT/
FSAR REMARKS NUMBER SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
=
======-==============================================-====================================================r
X 1855.00 FSAR
- 1. 9. 31. 2 CONTROL OF FERRITE RG 1.31
. 18A X
0 X
CONTENT IN STAINLESS X
STEEL WELD METAL X
X X 1549.00 FSAR
- 1. 9. 52. 2 DESIGN, TEST &
CONFDINS TO ANSI 18A X
X 25 X
MAINT: CRITERIA FOR M509-1976 OR 1980 i
X POST-ACC. ESF DEPENDING ON DATE OF X
A1NOSPHERE CLEAN-UP P.O., OR CONEDIWtS 10 X
SYSTEM AIR ANSI N509-1980 WIIEN FILTRATION &
SPECIFICALLY CALLED ADSORPTION UNITS OUT IN SPEC X 1550.00 FSAR
- 1. 9. 52. 2 DESIGN, TEST &
CONFOINS 1D ANSI 18A X
X 25 X
MAINT. CRITERIA FDR N010-1975 OR 1980 X
POST-ACC. ESF DEPENDING ON DATE OF X
A1N0 SPHERE CLEAN-UP P.O., OR CONFOINS 10 X
SYSTEM AIR ANSI N510-1990 WHEN FILTRATION &
SPECIFICALLY CALLED ADSORI"TION UNITS OUT IN SPEC X 715.00 FSAR
- 1. 9. Is2 COMBINING MODAL RG 1.92, REV 1, 2/76 18A X
0 SEE FSAR 3.7.B.
X RESPONSES & SPATIAL 3.7.N, 3.7.N.2.7 1
COMPONENTS IN X
SEISMIC RESPONSE X-ANALYSIS X 4973.00 FSAR
- 1. 9. 94. 2. 9 VISUAL WELDING WELDING VISUAL 18A X
20 X
ACCEPTANCE CRITERIA INSPECTION X
ACCEPTANCE CRITERIA X
IN ACCORDANCE WITH X
AWS DI.1-75 FOR INSPECTIONS PERFONMED PRIOR 1D 12/02/85, AND NCIG-01, REV. 2 FOR INSPECTIONS PERFORMED AFTER 12/02/85.
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,c l'ag No.
2 Or./05/8R PLANT VOCTLE UNIT 2 READINESS REVlw PHOGRAM COP 9tI1 MENT MATRIX - MODULE IBA
,: :====================..============
REF. COP 9fI1NENT COP 91I1 MENT COPN11 MENT DOCUMENT /
FSAR REMARKS Nt#SER SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
- ========================================================
===r====
============ ===========-=--===.
.:=====r X 2027.00 FSAR
- 3. 1.
5 CONMINANCE WITH NRC 10CFR50. APP. A, GDC,18A X
0 X
CDC, PRIMARY 56 X
CONTAIPMENT X
ISOLATION X
X 1012.00 FSAR
- 3. 7.B. 3. 1. 3 SEISMIC SUBSYSTEM MODAL RESPONSE IBA X
0 X
ANALYSIS OF CAT. I SPECTRIM OR I
SUBSYSTEMS AND EQUIVALENT STATIC X
COMPONENTS LOAD METHOD X
X 1014.00 FSAR
- 3. 7.B. 3. 5 SEISMIC SUBSYSTEM SEISMIC ACCELERATION 18A X
30 X
ANALYSIS, USE OF VALUES... ARE PEAK X
EQUIVALENT STATIC ACCELERATION VALUES X
IDAl; METHOD OF MULTIPLIED BY A X
ANALYSIS FAC1DR OF 1.5 UNLESS A LOWER FACTOR IS JUSTIFIED X 4688.00 FSAR
- 3. 7.B. 3. G SEISMIC SUBSYSTEM COMPONENT EARTHOUAKE IBA X
0 X
ANALYSES - THREE EFFECTS COMBINED BY X
COMPONENTS OF SRSS METHOD (NH X
EARTHOUAXE MOTION.
QUAL. BY ANALYSIS).
X X 6025.00 FSAR
- 3. 8.
- 4. 5 WELDING OF WELDING OF 18A X
X 25 ADDED BY FSAR AMEND.
X STRIX'TURAL STEEL STRUCTURAL STEEL, 25 X
MISC. STEEL, RACEWAY X
SUPPORTS, & HVAC X
DUCT SUPPORTS IS PERFOINED IN ACCOI).
WITH AWS DI.1-1975 OR LATER X 5117.00 FSAR
- 6. 2.
- 4. 3.C CONTAIPHENT PREACCESS MINI PURGE 18A X
0 X
ISOLATION SYSTEM, LINE ISOLATION X
DESIGN EVALUATION VALVES SHUT IN LESS X
THAN 5 SEC.
X
A t t a C n mta IL c
~~
Page No.
3 05/05/88 PLANT VOGTLE UNIT 2 READINESS REVIW PHOGRAM COP 9111NENT MATRIX - MODULE I8A
================_:====._
- =======
REF. COP 91I1?ENT COP 91I1NENT COP 9111NENT DOCINENT/
FSAR REMARKS NtMDER SOUNCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
- === =======_== =
- =========================================._============-
===================_-:=====...=e
==
X 5039.00 FSAR
- 6. 2.
- 5. 2. 2 CONTAIPMENT H/2 EXHAUST FILTERS AND '18A X
22 ADDED BY FSAR X
PUHGE SYSTEM EXHAUST DUCT M AMENDMENT 22 X
PLANT' VENT ARE X
DESIGNED AS SIESMIC X
CAT. I X 5055.00 FSAR
- 6. 4.
- 2. 2. 2.J HABITABILITY SYSTEMS lw0 SETS OF DOORS 18A X
30 X
WITH VESTIBULE ACT X
AS AN AIR LOCK AT X
CONTROL ROOM X
EXTRANCES X 5112.00 FSAR
- 6. 4.
- 2. 2. 2.J HABITABILITY SYSTEMS DOORS M RECORD IBA X
30 X
STORAGE AREAS ARE X
EQUIPPED WITH X
SELF-CLOSING DEVICES X
X 5113.00 FSAR
- 6. 4.
- 2. 2. 2.J HABITABILITY SYSTEMS ACCESS 10 RECORD 18A X
30 X
S MRAGE AREA THROUGH
.X AN AIRIDCK OR lwO X
DOORS IN SERIES X
X S0'32.00 FSAR
- 6. 4.
- 2. 3 HABITABILITY SYSTEMS CONVENTIONAL DLDGS, 18A X
25 X
- VENTILATION FOR REACMR X
LEAK-TIGHTNESS CONTAI!9ENT X
PUBLISHED BY ATOMICS X
INT *L, CAT.
NAA-SR-10100, 6-15-65 X 5114.00 FSAR
- 6. 4.
- 2. 4.E HABITABILITY COhTROL ROOM 18A X
30 X
SYSTEMS, INTERACTION DtvHTAYS WITH TWO X
WITH OTHER ZONES SETS G DOORS ACTING X
AS AN AlidDCX X
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4 Or.. O'.jun PLAN 1 VOGTI.E ITNIT 2 READINESS REVlW l'ROGilAM S
CarttI1 MENT MATRIX - MODULE IHA
= = = = = - = = = = = =. = = = = = = = = - = = = = = ~ = = = = = = = -
REF. COPNI1?ENT COPMITNENT COPNI1 MENT DOCINENT/
FSAR REMARKS NINBER SOURCE SECTION SIDJECT FEATURE MODULE DESIGN CONST AMEN
====================,---.
,========-====================================================:--==================
X 5115.00 FSAR
- 6. 4.
- 2. 4.E HABITABILITY DOORS M RECORD 18A X
30 SYSTEPE, INTERACTION SMf! AGE AREAS ARE X
WITH OTHER ZONES EQUIPPED WITH X
SELF-CLOSING DEVICES X
X X 5116.00 FSAR
- 6. 4.
- 2. 4.E HABITABILITY ACCESS 10 RECORD ISA X
30 SYSTEMS, INTERACTION STORAGE AREA THROUGH I
WITil OTHER ZONES AN AIRIDCK OR TWO X
DOORS IN SERIES X
X X 2123.00 FSAR
- 6. 5.
- 1. 1.B ESF FILTER SYSTEMS DESIGNED M MAINTAIN 18A X
30 DESIGN BASIS
-1/4-IN. WG WITH X
PIPING PENETRATION RESPECT 10 A1NOS.,
X FILTER EXHAUST NEGATIVE WITH X
X SYSTEM RESPhu 10 SURROUNDING AREAS X.2125.00 FSAR
- 6. 5.
- 1. 1.C ESF FILTER SYSTEM DESIGNED TO MAINTAIN 18A X
30 X
DESIGN BASIS A SLIGHTLY NEGATIVE X-FHB POST-ACCIDENT PRESSURE IN 11tB FHE X
EXHAUST SYSTDI FOLIDWING A FUEL HANDLING ACCIDENT.
X X 4015.00 FSAR
- 9. 1.
- 3. 2. 4 AUX. BLDG. EPERG.
SMACNA, 1975 & ANSI 18A X
X 25 X
VENT. SYSTEM - DUCT M510 SECT. 6, 1980 X
LEAK TESTING X
X X 4066.00 FSAR
- 9. 4.
- 5. 2. 1 CONTROL BLDG. SAFETY BATTERY ROOM 18A X
30 X
FEATURE ELEC.
MAINTAINED AT X
EQUITNENT ROOM HVAC SLIGHTLY NEGATIVE X
PRES 5URE X
X 4070.00 FSAR
- 9. 4.
- 5. 3. 2 ELEC. PENETRATION UPON RECEIPT OF A 18A X
3 X
ROOM FILTRATION AND CONTAINMENT X
EXHAUST SYSTEM ISOLATION SIGNAL THE X
ELEC. PENETRATION X
ROOM EXHAUST FILTRATION UNITS ARE ACTIVATED
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Page No.
S Or./05/ HH PLANT V0GTLE UNIT 2 READINESS REVlW PROGRAM COP 9tI1 MENT MATHIX - MODULE 18A
==-===================2=============:
REF. C0 Pet 11NENT COP 9111 MENT COP 9111 MENT DOCUMENT /
FSAR REMARMS NLMBER SOUNCE SECTION SUBJECT FEATURE MODULE DESIGN CONST AMEN
=
======================================================================================
u=
,2r=
X 4096.00 FSAR
- 9. 4.
- 5. 6 CONTROL BLDG. ESF SMACNA 1975 & ANSI 18A X
X 25 HVAC DUC1 WORK LEAK N510, SECT. 6, 1980 X
TESTING X
X X
X 5094.00 FSAR
- 9. 4.
- 7. 4 DIESEL GEN. BLDG.
SMACNA, 1975 & ANSI 18A X
X 25 VENT. SYSTEM N510, SECT. 6, 1980 X
DUC1 WORK LEAK X
X TESTING X
X 5095.00 FSAR
- 9. 4.
- 8. 5 AUX. FEEDWATER SMACNA, 1975 & ANSI 18A X
X 25 X
PUMPHOUSE HVAC N510, SECT. 6, 1980 X
DUC1 WORK LEAK X
TESTING X
X 5096.00 FSAR
- 9. 4.
- 9. 2. 4 MISC HVAC SYSTEMS, SMACNA, 1975 & ANSI 18A X
X 25
_X ELECT. TUNNEL VENT. N510, SECT. 6, 1980
- X SYSTEM, DUC1 WORK X
LEAK TESTING X
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