ML20141N225

Responds to Violations Noted in Insp Repts 50-424/85-52 & 50-425/85-37.Corrective Actions:Planners Will Be Instructed to Identify Maint Work Orders That Require Addl Preplanning Detail During Work Planning Process

ML20141N225
Person / Time
Site:	Vogtle
Issue date:	02/11/1986
From:	Foster D GEORGIA POWER CO.
To:	Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-790, NUDOCS 8603040514
Download: ML20141N225 (3)

Text

I Georg a Power Corppany Post Off.ce Box 282 Waynesboro, Georgta 30830 Telephone 404 554-9961. Ext,3360 404 724-8114. Ext 3360 D. O. Foster

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• GeorgiaPower V!ce Pres dert o 55 y, g,q,c,  % r, m , - -

av February 11, 1986 United States Nuclear Regulatory Commission Region II File: X78G10 Suite 2900 Log: GN-790 101 Marietta Street, Northwest Atlanta, Georgia 30323

Reference:

50-424/85-52, 50-425/85-37 Attention: Mr. Roger D. Walker l The Georgia Power Company wishes to submit the following information concerning the violation identified in your inspection report 50-424/85-52 and 50-425/85-37:

Violation 50-424/85-52-01, " Failure to Provide Adequate Maintenance Procedures for Work on Safety-Related Equipment Appropriate to the Circum-stances" - Severity Level IV

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The violation identified a failure to adequately prescribe mainten-ance activities relative to the preplanning, review, and execution of Maintenance Work Orders associated with the disassembly and reassembly of the Unit 1 chemical and volume control system centrifugal charging pumps. 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 is attributed to the failure to fully implement procedures governing the Maintenance Work Order process.

3. The NRC inspection report describes corrective actions implemented by Georgia Power Company prior to resuming work on the three Mainten-ance Work Orders (MW0's) cited in the violation. The following additional corrective actions were taken and are not included in the inspection report:

a. A controlled copy of FEC0 N-17-BF was added to MWO 18511852.

The uncontrolled copy previously used was compared to the controlled copy to verify that they were identical.

9603040514 860211 4 DR ADOCK 050 2.Eoi

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b. MWO's 18511088,16511851, and 18511852 were reviewed by repre-sentatives from operations, engineering, maintenance, and quality control to ensure that all necessary controls were properly observed and that completed documentation accurately reflected the work actually dane.

c. Proper approvals were obtained and decumented for the waiver of the QC hold point in NW0 18511852.

4. The following actions are being taken to prevent further violattens:

a. During the work planning process, t5e planners will be in-structed to identify Maintenance Work Orders (MW0's) that require additional pre-planning detail. After this identifica-tion the planner will direct the MWO package to the maintenance supervision responsible for the work performance. The foreman will review the package and identify any additional requirements or restrictions. The work package will then be returned to the planner for completion of the interdiscipline review cycle.

The additional " identification" in conjunction with enhanced communication between the planner and foreman will improve any pre-determinable planning actions, and provide an iaproved channel of communication for necessa ry support as problems are identified during the work performance. Additional emphasis will be placed on communications bitween the worker and the foreman on problems and resolutions that arise during the work process.

The work criteria for this additional " identification" will evolve based on experience and feedback obtained during the program organization, however the initial guidelines will be based on the following criteria:

(1) Degree of difficulty of the task (2) Uniqueness of the task (3) Applicability of the procedure to the task The early involvement of the snaintenance foremen in the work planning process has been added to desktop instructions for the control and tracking of MWO's. Startup Manual procedure SUM-22 already contains general requirements which will accomodate these enhancements,

b. Procedures which prescribe the methods for waiving QC hold points are currently being reviewed for adequacy and clarity.

Revisions will be made as necessary. Quality control personnel will be retrained in the requirements for waiving a hold point.

c. Maintenance personnel will be retrained in procedural require-ments. The importence of agreement between verbal instructicns and procedural requirements will also be stressed during the training.

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d. The enhancements established in the MWO work planning process  ;

described above will be carried over into the operations  ;

maintenance program.

5. All corrective actions relative to the violation are expected to be completed by March 1, 1986.

This response contains no proprietary information and may be placed in the NRC Public Document Room.

\

Yours truly '

, t D. O. Foster I

REF/DOF/tdm xc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 R. J. Kelly J. A. Bailey D. L. Kinnsch (BPC)

G. F. Head 0. Batum F. B. Marsh (BPC)

J. T. Beckham G. Bockhold C. S. McCall (OPC)

R. E. Conway C. E. Belflower D. A. Bartol (W)

J. P. O'Reilly H. H. Gregory E. L. Blake, Jr.

R. H. Pinson E. D. Groover (Shaw, et. al.)

P. D. Rice L. T. Gucwa J. E. Joiner B. H. Guthrie C. W. Hayes (Troutman, et. al.)

D. E. Dutton G. A. McCarley D. C. Teper (GANE)

R. A. Thomas R. W. McManus L. Fowler (LEAF)

D. R. Altman W. T. Nickerson T. Johnson (ECPG)

NRC Sr. Resident D. S. Read f

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