ML20127A513
| ML20127A513 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/04/1985 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-576, NUDOCS 8506210161 | |
| Download: ML20127A513 (3) | |
Text
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April 4, 1895 tvsa cneer,cso m Vogde Project United States Nuclear Regulatory Commission Office of Inspection and Enforcement File:
X78G10 Region II - Suite 2900 Log:
GN-576 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/85-03, 50-425/85-03 Attention: Mr. Roger D. Walker The Georgia Power Company wishes to submit the following information in response to the violation identified in USNRC inspection report 50-424/85-03 and 50-425/85-03.
Violation 50-424, 425/85-03-01
" Failure to Adequately Accomplish Corrective Action" - Severity Level IV The violation identifies a failure to incorporate Drawing Change Notice (DCN) 22 into pipe rack design drawing M01G-S93, Revision 6 and considers this, in combination with additional rework / rewelding and documentation changes in progress, to be an indication of failure to take adequate corrective action relative to NRC violation 84-30-01.
Georgia Power Company's response to violation 84-30-01 is dated December 27,1984(Log: GN-500).
Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
1.
Georgia Power Company acknowledges the violation but wishes to clarify information presented in the NRC inspection report.
Violation 84-30-01 identified, in part, a failure to incorporate DCN-R #12 into Revision 5 of drawing M01G-593.
As corrective action, project field engineering revised M01G-593 to incorporate DCN-R #12, which required 5/16 inch fillet welds on pipe racks R0002 and R0003, and also reviewed DCN's incorporated into Revision 5 to ensure accuracy.
A review of DCN-R #12 now reveals that it was actually written against Revision 3 of M01G-S93.
Engineering failed to recognize this fact while addressing violation 84-30-01 since a review was not made of DCN's incorporated into Revision 4.
Subsequent to the issuance of DCN-R #12. DCN-R #22 was also issued against Revision 3 of M01G-593 to change the 5/16 inch fillet welds to 1/2 inch.
Both DCN-R #12 and DCN-R #22 were incorporated
@ kMkf 24 PDR 5 t=~o l e
into Revision 4 of M01G-S93.
Since DCN-R #22 was the later of the two, Revision 4 properly showed the fillet welds to be 1/2 inch.
Revision 5 to M01G-593 continued to show the welds as 1/2 inch, but Revision 6 erroneously changed the fillet welds back to 5/16 inch as corrective action to violation 84-30-01.
The conclusion is that drawing M01G-S93 was actually correct at the time violation 84-30-01 was identified, but Georgia Power Company erred by not adequately reviewing the situation before taking action.
DCN-R #41 and DCN-R #42 have been issued against Revision 6 of M01G-S93 to change the fillet welds on pipe racks R0002 and R0003 back to the proper size of 1/2 inch.
Bechtel correcpondence PFE-4350, dated January 16, 1985, transmitted a corrective action plan to reduce residual stresses in some pipe rack welds, and did indicate that beam #13 on rack R0003 was successfully reworked per Deviation Report (DR) PP-4866.
The rework per the DR was to remove weld cracks and was successfully completed in accordance with the welding requirements of the current design drawing at that time (Revision 6 of M01G-S93), which required 5/16 inch fillet welds.
Since the issuance of DCN-R #41 and DCN-R
- 42, the welds are being reworked to increase their size to 1/2 inch.
This work is being done in accordance with centrolled procedures and does not nullify the work addressed in PFE-4350, 2.
Violation 85-03-01 was caused by a failure to adequately review the circumstances surrounding the incorporation of DON-R #12 into drawing M01G-593 before the drawing was changed in response to violation 84-30-01.
3.
DCN-R #41 and DCN-R #42 have been issued to restore the size of fillet welds in pipe racks R0002 and R0003 to 1/2 inch.
The piping contractor is currently reworking existing 5/16 inch welds as required.
These latest DCN-R's will be incorporated into Revision 7 of M01G-S93.
4.
To prevent further violations, project field engineering personnel have been instructed to conduct more thorough reviews of cited discrepancies to ensure that adequate corrective action is taken.
5.
All corrective actions are complete and full compliance with applicable regulatory requirements relative to this violation has been achieved.
This response contains no proprietary information and may be placed in the NRC Public Document Room.
Yours r y,j
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D.'O. Foste l
REF/00F/tdm L
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U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 R. J. Kelly J. A. Bailey G. Bockhold
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R. E. Conway
- 0. Batum P. D. Rice i
G. F. Head H. H. Gregory C. S. McCall (OPC)
J. T. Beckham W. T. Nickerson E. L. Blake, Jr.
t R. A. Thomas D. R. Altman (Shaw, et. al.)
i D. E. Dutton D. L. Kinnsch (BPC)
J. E. Joiner i
W. F. Sanders (NRC)
J. L. Vota (W)
(Troutman, et. al.')
R. H. Pinson L. T. Gucwa D. C. Teper (GANE)
B. M. Guthrie C. E. Belflower L. Fowler (LEAF)
E. D. Groover F. B. Marsh (BPC)
T. Johnson (ECPG)
R. W. McManus l
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