ML20138P034

Suppls Response to Violations Noted in Insp Repts 50-424/85-43 & 50-425/85-32.Corrective Actions:Special Surveillance Will Be Conducted by QC to Assess Adequacy of Const Equipment Maint Program & Review of Valves Conducted

ML20138P034
Person / Time
Site:	Vogtle
Issue date:	12/10/1985
From:	Foster D GEORGIA POWER CO.
To:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-756, NUDOCS 8512240258
Download: ML20138P034 (3)

Text

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.,,, n. Geo,rg6e Power company J h

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. Wayneeboro, Georgia 30830 '

,4 Telephone 404 554 9061. Ext. 3360 f

404 724 8t* 4 Ext. 3360 f

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n' DEC 17 P 3 : 58 GeorgiaPower j

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t Vice President and Project

- tre southem entre sprem -

t General Manager' l

Vootte Project.

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December 10, 1985 1

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-United States Nuclear Regulatory Commission Region.II?

File: X78610 1

-Su'to 2900 Log:

GN-756 101 Marietta Street, Northwest Atlanta, Georgia 30323 1

Reference:

.b0-424/85-43, 50-425/85-32

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. Attention:. lMr.- Roger D.' Walker l

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' The fGeorgia Power Company wishes to -submit the following additional

information to" supplement our response.(GN-743 dated November 15, 1985) f

- to : the violation. identified in NRC inspection report. 50-424/85-_43 and K

50-425/85-32.

Due.' to. questions raised by our NRC Resident Inspectors Georgia '

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Power Company: recognizes the need to clarify some Jof the information.

provided; in ours earlier response and to provide ~ additional information t'

on long-term corrective actions.

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. :The ~walkdown -inspection prior to dust blowdown operations is not the primary means of providing equipment protection in the construction

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equipment maintenance.programe as = may have -been -inadvertently implied.

i in the < earlier response.

The~ walkdown is merely a final check that j

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the required equipment protection is in place before beginning blowdown ope n,tions.

Therefore the violation relative to the four valves stored

. in the Unit 2 - Containment' is attributable - to a failure to adequately protect the valves in accordance with the equipment' maintenance program i

and a: failure to perform the required area walkdown prior to blowdown activities.

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The followup inspection - conducted November 6, 1985, covered more thanithe four valves cited in the violation.

The inspection covered "i

' general ' maintenance - and storage of valves in the Unit 2 Containment i

with emphasis = on designated valve storage areas.

No discrepancies beyond i

.those cited in the violation were found.

To thoroughly assess.- the adequacy of the construction equipment f

maintenance. program, a special surveillance will be conducted by quality i

control personne1;of equipment protection in' the power-block area.

The

.results of: the - surveillance will' be documented and will be reviewed c

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. and evaluated by construction management.

Additional corrective actions

. hich may result from the~special surveillance will also be documented.

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.~!n the earlier-response, it. was stated that Nuclear Operations i~

" attempted" to conduct.a review of ~ other valves which 'were disassembled l

9 for--flushing purposes.

As -- a clarification to this statement Nuclear i

j0perations ? did conduct a review-of disassembled valves.

This review

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,was _. limited.to 7 valves disassembled for flushing purposes and, since no ;other : disassembled ' valves :were. stored in the plant, no in:iwetion 1

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.for proper storage and protection was.possible.

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. Relative to the Train "A" Remote' Shutdown Panel, the eariter response m

. indicatedcthat Nuclear Operations. was unable to determine the cause yof the panel door being open at the time of the NRC inspection.

Further reviews in this Jarea' have determined that the doors were intentionally i

left open for a time to ensure adequate ventilation to the panel interior, i

e which was being heated by an electric light bulb for moisture protection.

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t To prevent further violations, the following actions are being

implemented

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1.

Georgia. Power Company and Pullman Power Products, the piping contractor. have assigned. personnel to monitor construction field

. storage conditions for valves and other equipment during each shift l

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to ensure that - covers and other protective methods are properly maintained.

Also, the estabitshed requirements for area walkdowns i

-prior to dust.blowdowns have been emphasized to appropriate i

personnel..

I 2.

Nuclear Operations personnel conduct surveillance of designated turned-over equipment as required by Startup Procedure SUM-25 under t

the direction 'of the Shift Supervisor.

The surveillance includes, as a propriate, verification of area cleanliness, air filter clean" ness, : equipment door closure, maintenance of protective coverings.' and work activities in the surveillance areas.

The i

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-frequency of the equipment surveillance is determined by the Shift Supervisor and appropriate test personnel by considering equipment

' ' environment and testing in progress.

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Nuclear Operations is developing an area access control plan which j

. requires joint participation with construction to ensure oculpment i

protection and cleanliness is maintained.

The plan wil' apply i

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to all areas of the plant which are not turned-over to operations and 'are not specifically designated as a controlled area by j

construction.

The plan will be designed to ensure the safety of 6

personnel and the integrity of startup testing activities.

Basically, the plan will provide applicable areas with a Level l

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. I, s!!, or !!! designation.

Level I areas are the most restrictive and require distinct lock-and-key access control and will be marked by appropriate signs.

Keys to Level I areas will be controlled by the Shift Supervisor.

Some' examples of Level I areas are Class 1E large motor or pump areas, Class 1E instrument or control panel areas. DC battery rooms and switchgear rooms, Non-1E vital or l

essential' instrument areas, and high voltage switchgear rooms.

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t Level;II areas will: also be marked by appropriate signs and access'

. ill be controlled i.through conson-keyed locks.. Keys to Level II w

s Lareas will be issued to - the Shift ' supervisor. and : to' Construction t

Area Coordinators. - All other applicable areas' will be ' designated 4

as Level III' areas 'and will: not require marking or. special.Laccess controis. : Compliance" with ' the ? area access control plan, will be Leonitored; under.the. direction. of; the Shift < Supervisor during: each

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p shift.

l LThe special, surveillance tol be ' conducted L by construction E quality l

0-control and the implementation of the area access control plan are -

espected to be completed by January 31. 1986.

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This' supplemental response.- contains 'no proprietary < information j

and may be placed in the NRC Public Document Room.

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Yours'truly

-- j f

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D. O. Foster j

REF/00F/tdm

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ac:

U. 5. Nuclear Regulatory Commission Document Control Desk:

Washington. 0.C. '20555-4 R.iJ.'Nelly O. tatum

6. F.. Head G. Rockhold.

0. L. Kinnsch F.8. Marsh (SPC)

J. T. Beckham C.'.E. Selflower C. 5. McCall f0PC)

'O.'0. Foster H. H. Gregory J.L.Vota(WJ R. H. Pinson-E.' O.. Groover E.~ L. Blake, Jr.

P. D. Rice:

L. T.'-Gucwe (Shaw, et. al.)

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8.'N. Guthrie C. W. Hayes J. E. Joiner D.' E. Dutton' G. A. McCarley (Troutsen,et.al.)

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-R; A. Thomas

'R. W. McManus D. C. Teper (GANE) i D. R. Altman-

'W.~T. Nickerson' L. Fowler (LEAF)'

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J. A.' sailey)

.0, S. Road -

T. Johnson (ECPG) l NRC $r. Residont-4

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