ML20126H668

Responds to NRC Re Violations Noted in IE Insp Repts 50-321/80-48 & 50-366/80-48.Corrective Actions: Procedures Have Been Implemented to Control Excavation & Earthwork QC

ML20126H668
Person / Time
Site:	Hatch
Issue date:	03/09/1981
From:	Widner W GEORGIA POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20003F045	List: IR 05000321/1980048 ML20126H668
References
NUDOCS 8104200032
Download: ML20126H668 (4)

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3 A (V &,. . i, l 1 C H L',UI POWCT March 9, 1981 '

U. S. Nuclear Regulatory Commission

REFERENCE:

Of fice of Inspe: tion and Enforcenent RII: CEM Region 11 - Suite 3100 50-321/80-48 101 Marietta Street, Nd 50-366/80-48 Atlanta, Georgia 30303 ATTENTION: Mr. James P. O'Reilly Gentlenen:

The following information is submitted in response to inspection Reports S0-321/80-48 and 50-366/80-48, concerning the inspec tion of December 10, 1980. Two apparent violations were identified.

VIOLATION A 30 CFR 50, Appendix B, Criterion V, as implenented by Paragraph D.9.5 of tne Unit 1 FSAR and Paragraph D-4.1 of the Unit 2 PSAR, requires, that " Instructions, procedures, or drawings shall include apprnpriate quantitat ive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished".

Contrary to the above, prucedure CDT-02, which addressed placanent of the backfill around the int ake structure, did out contain apprnpriate criterja for veri fying that placement and compaction of the l'il l materials met design requirements.

Thi's is a Severity Level V Violation.

RESPON$E After a r evi ew and evaluation of the available data concerning the backfill materials around the service water lines adjacent to and slightly south of the intake structure, it was disclos.;d that adequate d..cumen ta t ion

. was not available to verify that placanent and compactJon of fill materials met design requirement s. Theref ore, it was apparent that construction specifications were violated.

Document at ion did reveal numerous densi ty tests and retests of .

backtill operations of all other areas around category I structures. l These tests were performed at depths varying from many f eet below j design site graues tu the genemi elmtaers of design sitt gradcs -

inaicating extensive compaction control of backfill operations through progt essive fill placement and testing.

The criteria in Georgia Power Specification Inquiry, numbers CA 3041 and 3529, were used during the early stage o" construction at the time the intake backfill was perf ormed. Procedure COT-02, which addresses excavation and ea rthwork quality control, was not implenented until l Sept onher 25, 1974 810.4 2 0 000A

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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Page Two March 9, 1981 RESPONSE (Continued)

Change notices were issued against the above inquiry to perform backfill operation around the intake structure; however, the change notice did not contain appropriate criteria for verifying that placement and compaction of the fill materials meet design requirements.

Corrective Steps Which Have Been Taken And The Results Achi eved In Correctina The Above-Stated violation:

Georgia Power Company has prepared plans and specifications (DCR 80-279) detailing the method for correcting the problem.

Corrective $teps Which Will Be Taken To Avoid Further Violations:

To prevent further occurrence HP-6955 has been implemented to control excavation and earthwork quality control.

Date When Full Como11ance Will be Achieved:

Full compliance is estimated to be achieved June 1, 1981, when DCR 80-279 will be virtually complete.

VIOLATION 8 10+CFR 50, Appendix B, Criterion V, as implemented by Paragraph D.9.5 of the Unit 1 FSAR and paragraph 17.2.5 of the Unit 2 FSAR requires in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, and drawings, ... and shall be accomplished in accordance with these instructions, precedures, and drawings".

Pa ragraph G of procedure HNP-809, " Plant Modifications Approval and Implementation" requires that changes to Design Change Requests (DCR) be reviewed and approved by the Plant Review Board (PRB) prior to l being implement ed. Paragraph F of procedure HNP-801, "Nonconformances", requires that a Nonconformance Report be initiated for any item of nonconformance that cannot be handled by means of existing plant procedures, j i

Contrary to the above:

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1. Changes to the DCR for repairs of backfill under the intake structure piping were impl emented orlor to revi ew and I approval by the PRB.

2. Nonconformance reports were not issued to address damaged coating on the RHR and service water pipes, improperly applied protective coating to RHR and service water pipe joints, and attachment of two 2-inch lines to the 10- and 30-inch RHR and service water lines. These nonconforming conditions cannot be handled by existing plant procedure.

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(iCOly!d NO\WI h U. 5. tuclear Regulatory Commission Office of Inspection and Enforcement Page Three

-March 9, 1981 This is a Severity ' Level V Violation.

REPONSE

'in response to statenent 3, Georgia Power Company agrees that changes to the . Plant Review Board (PRD) approved DCR 80-279 were implanented without PRB review and approval.

Technical Specification 6.5.1.6-d requires that the PR8 shall be responsible for review of all proposed changes or modifications to unit systems or equipsent that af fect nuclear safety. HNP-809 details the controls utilized to enforce requirenents imposed by the Technical Speci fications. The intent of HNP-809, Paragraph G.1 was that changes which alter the scope of a DCR or invalidate the existing safety evaluation for the DCR should be reviewed and approved by the PRB prior to implementation. However, HtP-809 dia not explicitly dif ferentiate between changes of scope or changes af fecting safety and those not affecting safety or changing the scope of the DCR. PRB review Of the change to DCR 80-279 was determined to be unnecessary because it did not alter the scope of the DCR and was approved by the I

' AE. This resulted in the violation.

Correc t iv t' Steps Which Have tieen Taken And The Results Achieved:

HNP-809 has been rewritten so that the wurding more exp'icitly reflects the intent of the procedure as discussed above.

Corrective Steps which Will Be Taken to Avoid Further Violations:

No further actions are required to be in full compliance.

Date When Full Compliance Will Be Achieved:

Full compliance was achieved on March 9, 1981,

• In response to statenent 2, that a nonconf ormance report be initiated for any items of nonconformance that cannot be handled by means of exist ing plant procedares, it was determined prior to the inspection that one nonconformance report would be written to cover the repair activities. Due to the nature and complexity of all the repair activities and a thorough review of plant procedures, it was evident that HNP-801 was violated.

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(M S. Nuclear Regulatory Commission Office:of Inspection and Enforcement

! Page four'. l

. March 9, 1981 l RESPONSE (Continued)

Cctrective Steps Which Have Been Taken And The Results Achieved:

! In correcting the above-stated violation, nonconformance reports  !

have been initiated on items stated.

i Corrective Steps Which Will Be Taken 10 Avoid further Vinlationsi  !

i To avoid further . violation, nonconformance reports will bc

initiated on any repair activity which is in nonconformance of documented instructions, plant procedures and drawings.

Date hhm Full Compliance Will Be Achieved:

Actions taken to date constitute sufficient corrective action, we are presently in compliance with the specific requirenents of

, HNP-801.

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, If you have any questions in this regard, please contact this o f fice.

i W. A. Widner states that he !; Vice President of Georgia Power Company and is authorized to execute this uath on behalf of Georgia Power Company, and that to. the best of his knowledge and belief the facts set forth in this letter are true.

4 Georgia Power Company by: ,

W. A. Widner korn to and subscribed before me this 9th day of March 1981.

, ,, Notan Put>hc. G.wgia, state at Large

/ / My Commission Expires Sept. 20.1983 Notary Public REB /mb xc: M. Manry R. F. Rogers, III l

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