ML20127E733
| ML20127E733 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/07/1985 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-601, NUDOCS 8506240633 | |
| Download: ML20127E733 (4) | |
Text
.
Georg a Power Corrpany Roote 2. Box 299A Wayresboro. Geor@a 30830 Telect me 404 554 9061. Ext 3360 404 724 8114. Eat 3300 b
13 e 7_. 5 3 Georgia Power D. O. Foster
,,51S V,ce Pres det and Promet c
General Manager the sounero electnc s:, stem Vogtfe Project May 7, 1985 United States Nuclear Regulatory Commission File:
X78G10 Office of Inspection and Enforcement Log:
GN-601 Region II - Suite 2900 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/85-12, 50-425/85-12 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 50-424/85-12 and 50-425/85-12.
Violation 50-424/85-12-01, " Failure to Follow Procedures for Hanger Installation and Inspection" - Severity Level IV.
The violation identified six pipe support installations with deviations from the requirements of the design drawings and/or the manufacturer's instructions.
Compliance with these documents is required by Pullman Power Products procedure IX-50, " Pipe Support Field Installation and Fabrication Procedure".
The specific discrepancies identified are:
l a.
Support V1-1202-207-H002, Rev. 1:
Pipe clamp improperly installed, lack of adequate thread engagement by clamp lock-nuts, loose double-nuts on upper end of clamp, rod strut lock-nut not installed per manufacturer's instruction.
b.
Support V1-1203-093-H010, Rev. 2:
All-around weld only completed on two sides.
l l
c.
Support V1-1202-220-H021, Rev. 1:
Loose lock-nut.
d.
Support V1-1213-006-H005, Rev. 1:
Two travel-stop pins were missing for the spring hanger.
e.
Support V1-1203-091-H011, Rev. 1:
Rod threads were upset adjacent to upper and lower lock-nuts, preventing proper adjustment of the spring hanger.
f.
Support V1-1202-216-H036, Rev.
1:
Lock-nut not installed per manufacturer's instruction.
8506240633 850507 PDR ADOCK 05000424 G
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a Paga Two g-Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:
.1.
Georgia Power company acknowledges the violation as identified in the NRC inspection report.
2.
An evaluation was performed by Pullman Power Products - (PPP) to determine the cause of the discrepancies identified in the violation.
The-evaluation resulted in the following conclusions:
a.
The discrepancies involving loose nuts, missing travel stop
- pins, and improper clamp installation in supports V1-1202-207-H002, Y1-1202-220-H021, and V1-1213-006-H005 are attributed to unauthorized disassembly of previously QC-accepted supports rather than faulty QC inspection.
The supports were apparently temporarily removed by craft personnel of another contractor working in the area due to interference with other construction activities.
Normally, other contractors will contact PPP before disassembling previously QC-accepted work and this has not been a significant problem.
In these cases, however, FP was not contacted.
It should be noted that supports which have been QC-accepted are marked by PPP with a green tag, b.
The discrepancies in supports V1-1202-207-H002, V1-1203-091-H011, and V1-1202-216-H036 involving inadequate installation of lock-nuts are attributed to inadequate l
procedural controls.
Pullman Power Products procedures IX-32,
" Installation of Mechanical Shock Arrestors," and IX-50, " Pipe Support Field Installation and Fabrication Procedure," which address lock-nut installation, did not provide clear instructions to craft and QC personnel in the performance of this work.
c.
Relative to the omission of welds in support VI-1203-093-H010, both the welder and the inspector involved were interviewed i
during the evaluation.
The interview concluded that the welder a
failed to perform the all-around weld due to his misinterpretation of the drawing.
The inspector displayed L
an adequate understanding of drawing and procedure requirements i
during the interview and attributed the discrepancy to an oversight on his part.
Based on the results of the interview and the fact that internal PPP surveillances have not detected recurring problems of this type, the discrepancy identified in support V1-1203-093-H010 is considered to be an isolated case of human error.
L l
2.
All of the specific discrepancies identified in the NRC inspection report were documented in Deviation Reports to ensure adequate and timely resolution is effected.
In addition, Georgia Power Company (GPC) will conduct a special thirty-day surveillance of I-PPP pipe support installation activities.
The surveillance will i
Pag; Threa be conducted by GPC quality control personnel and will give specific attention to unauthorized disassembly of installed supports, welding, lock-nut installation, and QC inspection as well as other areas of support installation.
The results of the surveillance will be evaluated and corrective actions will be taken as appropriate.
4.
To prevent further violations, Pullman Power Products procedures IX-32 and IX-50 are being revised to clarify instructions for the installation of lock-nuts.
In addition, a new procedure, IX-86, is being developed for use in conjunction with procedure IX-50 to specifically address the installation of struts.
The new procedure and the revisions to the existing procedures will be reviewed for approval by design engineering.
Pending approval and issuance of the procedures, final inspections of support installations involving lock-nuts have been postponed.
Pullman Power Products will conduct " gang box" meetings with its craft personnel to stress the seriousness of unauthorized disassembly of QC-accepted installations.
In addition, a letter will be issued to other site contractor organizations enlisting their cooperation and help in preventing future unauthorized disassembly of pipe supports.
Additional preventive measures may result from the special surveillance to be conducted by GPC Quality Control.
5.
Remedial corrective actions (dispositioning of Deviation Reports and reinstruction of craft personnel) are expected to be completed by May 31, 1985.
Approval and issuance of revised procedures IX-32 and IX-50 and new procedure IX-86 is expected to be completed by June 14, 1985.
Georgia Power Company expects to complete the special surveillance of PPP pipe support installation activities by July 3, 1985.
Complete documentation of the surveillance, including the results and appropriate corrective actions, will be available for USNRC review.
This response contains no proprietary information and may be placed in the NRC Public Document Room.
Yours truly,
'. Foster REF/D0F/tdm
~
Page Four xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
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