ML20138R941

Responds to Violations Noted in Insp Repts 50-424/85-40 & 50-425/85-31.Corrective Actions:Pullman Power Products QA Supervisor Will Monitor Hold Over Temp Verification Logs Weekly to Assure Proper Completion

ML20138R941
Person / Time
Site:	Vogtle
Issue date:	11/01/1985
From:	Foster D GEORGIA POWER CO.
To:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-729, NUDOCS 8511190281
Download: ML20138R941 (5)

Text

4 Georgia Power Company Post Office Box 282 h

Waynesboro, Georgia 30830  !

Telephone 404 554-9961 Ext. 3360 & .

404 724-8114, Ext. 3360 , ',

D. o. Foster GeorgiaPower Vice President and Project Ine southern electnc system General Manager Vogtle Project November 1, 1985 United States Nuclear Regulatory Commission E i Region II File: X78GITF Suite 2900 Log: GN-7$E la ta, eorg a 3b323

]

Reference:

50-424/85-40, 50-425/85-31 [

Attention: Mr. Roger D. Walker The Georgia Power Company wishes to submit the following information concerning the violations identified in your inspection report 50-424/85-40 and 50-425/85-31:

Violation 50-424/85-40-03, 50-425/85-31-03; " Failure to Follow Procedures for Control of Welding" - Severity Level IV The violation identified two cases of failure by the Vogtle Electric Generating Plant piping cohtractor, Pullman Power Products (PPP), to adequately control field weiding operations. The first case involved erroneous recording of welding material stationary holding oven temperatures for three ovens at the welding materials distribution center (WMDC). The second case involved the issuance of welder technique sheets from the WMDC without adequate backpurge information for weldments to be made on stainless steel piping. 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. The violation relative to erroneous recording of holding oven temperatures resulted from the failure of a single individual to perform his assigned duties in accordance with established procedures. The issuance of outdated technique sheets resulted from the failure to purge superseded technique sheets from the WMDC following a revision to incorporate backpurge information for stainless steel weldments.

3. The following corrective actions have been taken:

a. A single individual was responsible for recording the stationary holding oven temperatures cited in the violation. Temperatures were entered in the welding materials holding oven temperature verification -log when, in fact, the three ovens in question 8511190291 851101 PDR ADOCK 05000424 i G PDR Itc/ a

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. Pag; Two had been turned off the day before the erroneous temperature recordings were - made. Pullman Power Products evaluated the circumstances surrounding the discrepancies and concluded l that the~ erroneous temperature recordings were the result  !

of willful falsification of quality records by the responsible l Quality Assurance Engineer. This individual was subsequently terminated from employment. As indicated in the NRC inspection report, 'the welding materials were removed from the subject  :

holding ovens at the ' time they were turned off. A review was conducted of the' other holding ovens in the WMDC and log entries made by personnel other than the one terminated and no - evidehce was found to indicate a problem existed beyond that identified in the violation.

b. Superseded WPS Technique Sheets were purged from the WMDC.

In addition, a checklist is being prepared, and will be maintained for use by WMDC personnel, to indicate the current revisions of WPS technique sheets.

4. To prevent further violations, the PPP QA Supervisor will monitor holding oven temperature verification logs on a weekly basis to assure proper completion and control. A designated PPP Quality Assurance Engineer will monitor technique sheet issuance on a weekly basis to ensure only the latest information is issued to welders.

In addition, the Georgia Power Company Welding Section will monitor PPP activities relative to the control of WPS technique sheets

-and recording of holding oven ' temperatures. This monitoring will continue until an acceptable level of confidence is reached in i the effectiveness of PPP's corrective actions. l It should be noted that Georgia Power Company's policy regarding deliberate malpractice is well documented. All PPP WMDC personnel have been reminded of this policy and warned that willful falsification of quality docur: ants will result in termination from employment.

5. All corrective actions relative to this violation are expected to be completed.by November 15, 1985.

Violation 50-424/85-40-04, " Failure to Protect Permanent Plant Equipment"

- Severity Level IV The violation identified three Nuclear Service Cooling Water (NSCW) pump motors which were found unprotected from moisture in that the internal heaters for the motors were not energized. The violation also noted that preoperational maintenance forms attached to maintenance work orders for the three pumps indicated that energization of the pump ,

- motor heaters was. not applicable. The NRC inspection report details concludes that these discrepancies establish that preventive maintenance inspection procedures were inadequate to prevent damage or deterioration of equipment.., Georgia Power Company offers the following response pursuant to the' criteria of 10 CFR 2.201:

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1. Georgia Power. acknowledges the violation with the following clarifications:

The maintenance work orders cited in the Notice of Violation (18503926, 18503914, and 18503952) were for mechanical maintenance operations only. Therefore, the "not applicable" indication for

' heater energization was correct. Verification of internal heater operation.=is performed during electrical maintenance procedures.  !

The last electrical maintenance checks performed on the three NSCW pump _ motors in question were documented on plant maintenance work orders 18504630 (pump P4-001),18506730 (pump P4-003), and 18506356 (pump P4-005). The preoperational maintenance forms attached to these work orders require energized space heaters or heat trace tape to protect motor windings from excessive moisture.

Plant maintenance work order 18504630 for NSCW pump P4-001 was completed on - August 6, 1985, and indicates the space heater for the pump motor was energized as required. Work orders 18506730 and 18506356, for pumps P4-003 and P4-005 respectively, were completed on August 12-13, 1985, and properly reported that the heaters for those pump motors were not energized. Based on the information- obtained from these work orders,. it is estimated that power to the heaters was lost between August 6, 1985, and August 12, 1985.

Plant maintenance work orders can not be closed until they are signed-off by Quality Control following a review of the documentation to ensure that applicable quality program requirements are addressed.

Maintenance . work orders 18506730 and 18506356 were in the review / evaluation process at the time of the NRC inspection and had'not been signed-off by Quality Control.

Startup Manual procedure SUM-22, " Maintenance Work Orders", requires that discrepancies identified during the performance of maintenance activities be documented in Deficiency Reports, which will ensure the discrepancies are evaluated and corrected.

Based on the information provided above, it is Georgia Power Company's position that the Nuclear Operations plant maintenance program complies with applicable ' quality program requirements and that procedural controls were in place to identify the discrepancies cited in the violation and ensure they were corrected. The violation resulted from a combination of the following factors:

a. The NRC inspector identified the discrepancies before the maintenance work order cycle was completed.

b. Plant maintenance personnel failed to explain to the NRC inspector the division of plant maintenance activities into mechanical and electrical disciplines.

c. Plant maintenance personnel performing the work prescribed in maintenance work orders 18506730 and 18506356 failed to comply with specific maintenance program procedural requirements.

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2. Plant maintenance personnel performing the work prescribed in maintenance work orders- 18506730 and 18506356 found that the temporary _ power cables which energized the heaters in the three pump motors had been cut, apparently as a result of construction activity in the area. The maintenance personnel reported the cut cables to the responsible test supervisor. Thinking that the test supervisor would correct the problem, the maintenance personnel failed to identify.the cut cables in a Deficiency Report as required by Startup Manual procedure SUM-22. As a result, the motor heaters were de-energized at the time of the NRC inspection.

The fact that the pump motor heaters were not energized was, however, documented on the maintenance work orders or on the attached preoperational maintenance forms. Since the discrepancies were identified in the maintenance work order packages, it is expected that Quality Control's review prior to work order close-out would have resulted in a resolution.

3. The NRC inspector identified the de-energized ' motor heaters on August 22, 1985. On August 23, 1985, plant maintenance work order 18507894 was initiated to conduct megger tests of the motor windings of NSCW pumps P4-001, P4-003, and P4-005 to determine -if any damage

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resulted from space heater de-energization. The megger tests yielded satisfactory results and power was restored to the space heaters for the three motors. Maintenance work orders 18506730 and 18506356, which had identified that the motor heaters for NSCW pumps P4-003 and P4-005 were not energized, remained open until megger testing was - completed. Since the megger tests showed that no damage had occurred -to the motors, further identification of the discrepancy in a Deficiency Report was unnecessary at this point.

4. To prevent recurrence, corrective actions relative to motor heaters found to be de-energized will be added as a preapproved disposition to Startup Manual procedure SUM-23, "Predispositioned Deficiency Reports". Plant maintenance personnel will be directed to take immediate corrective action when motor heaters are found to be de-energized during maintenance activities. Corrective action will include megger testing of affected motor windings, restoration of power to the heaters, and documentation of the actions on a predispositioned deviation report.

5. All corrective actions relative to this violation are expected to be completed by December 20, 1985.

These responses contain no proprietary information and may be placed in the NRC Public Document Room.

Yours truly,

/ -

. O. Fos'ter i REF/DOF/tdm

.- . . . l Page Five xc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 R. J. Kelly J. A. Bailey G. Bockhold R. E. Conway 0. Batum P. D. Rice G. F. Head H. H. Gregory C. S. McCall (OPC)

J. T. Beckham W. T. Nickerson E. L. Blake, Jr.

R. A. Thomas D. R. Altman (Shaw, et. al. )

D. E. Dutton D. L. Kinnsch (BPC) J. E. Joiner Sr. Resident (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 G. A. McCarley u s