ML20151L701
| ML20151L701 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/27/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NON-00217, NON-217, NUDOCS 8808040111 | |
| Download: ML20151L701 (5) | |
Text
e Georg a Power Company 233 P:edmont Avenue i
Atlanta, Georg'a 30308 Telephone 404 526-65;6 Madmg Address-Post Offico Box 4545 At'anta, Georga 30302 b
Georgia Power I"*' 5 M" * '"h W "
Nuclear operations Department NON-00217 July 27,1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REVISED REPLY TO A NOTICE Or VIOLATION Gentlemen:
Georgia Power Company (GPC) hereby submi ts the enclosed revised response to NRC Inspection Report 50-424/88-13, which concerns the inspection conducted by Mr. W. P. Kleinsorge of the NRC Region II staff e i April 18-22 and May 2-5, 1988.
This revised response is submitted as a result of discussions between Mr. J.
A.
Edwards of GPC and Messrs.
W. P. Kleinsorge and C. A. Patterson of the NRC on June 29, 1988.
This revised response wercedes our letter NON-00153 dated June 22, 1988.
The enclosure to this letter contains a transcription of the NRC violations and GPC's response.
Please contact this office if you have any questions.
Sincerely,
&f.. Us WY W. G. Hairston, III Senior Vice President, i
Nuclear Operations KP/gww
Enclosure:
NRC Viclation 88-18-01 and Revised GPC Response c:
(see next page) 88080401ii 880727 P"'
ADOCK 05000424
/ ' ll L
Georgia Power A U. S. Nuclear Regulatory Commission July 27,1988 Page Two c: Georgia Power Company Mr. P. D. Rice Mr. G. Bockhold, Jr.
Mr. J. P. Kane-Mr. J. E. Swartzwelder GO-NORMS /V0GTLE-NORMS U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)
Mr. J. F. Rogge, Senior Resident Inspector - Operation, Yogtle 1047m l
1 j
ENCLOSURE PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSING NPF-68 NRC NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE VIOLATION 50-424/88-18-01 "Ti tle Ten Code of Federal Regulation Part 50, Appendix B,
Criterion V requires that activities affecting quality to be prescribed by documented drawings and procedures of a type appropriate to the circumstances and that those activities be accomplished in acceptance (SIC) with those drawings and procedures.
The Final Safety Analysis Report (FSAR) Section 6.5.1.3.E states in part "the ESF filter systems are designed to seismic Category 1 requirements."
American Air Filter (AAF) letter dated April 1,
1988, appropriate to all the Engineered Safety Feature (ESF) air filter housing units in both units states in part:
"To meet the seismic qualification, the angle clips should be bolted to the Lase channels with Type A-449 high strength bolts, or equivalent, pretensioned to meet the friction connection require-ment."
Type A-449 bolts have a minimum required tensile strength of 2.05 KIPS Square Inch (KSI).
The following procedures are appropriate to the installation of ESF air filter housing 2-1561-N7-001.
Procedure JP-513 "Installation and Inspection of High Strength Bolts", Paragraph 5.4 requires that bolted contract (SIC) surfaces have burrs removed and shall be free of dirt, oil, loose scale, pits or other defects that would prevent solM seating or sound bearing of component parts.
Paragraph 6.2.2.d.1 requires that washers shall be installed under the bolt head and nut when the hole enlargement exceeds 1/8".
Bechtel Power Company (BPC) drawing 2X4AJ07-325-7, Section "B-B",
specifies 3/4-10 bolts.
The following were identified as appropriate for Heating Ventilation and Air Conditioning (HVAC) Nuclear Safety-Related, Seismic Class 1,
Duct Support No. 2-132-88 depicted on Field Change Request (FCR) No.
FCRB-5367F and on the following BPC Drawings No. AXD67WO41 Revision 1.
Drawing AXD67WO41 Details for Type 301, specifies dimension "D"
(the distance between the center line of the duct section and a 5x5x3/8-inch square tube) to be 1-foot 0 inches maximum (12-inches maximum),
a.
Contrary to the above, procedures and drawings were not, of a type, appropriate to the circumstances, to assure that proper bolting materials would be correctly installed, to comply with the commitments of the FSAR, as evidenced by the following:
Drawing 2X4AJ07-325-7 Section "BB" specified "3/4-10 Hardware (by AAF)" with no specification of bolt type, or torque (pretension) requirements.
The omission resulted in the Unit One ESF air filter housing assemblies being
)
installed with snug tight (not pretensioned) unmarked bolts (presumed j
A-307 with a tensile strength of 60 KSI).
The Unit Two ESF filter housing assemblies were installed with snug tight (not pretensioned) i high strength bolts.
)
l NON-C0216 E-1 JUL 2 71988 i
ENCLOSURE (continued)
NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE b.
Contrary to the above, activities affecting quality were not accom-plished in accordance with procedures, in that the installing craftsmen failed to install ESF air filter housing units and HVAC duct support in accordance with drawings and procedures, and the QC inspectors accepted those discrepant conditions.
Specific examples are listed below:
1.
Relative to the ESF air filter housing assembly No. 2-1561-N7-001:
(a) Bolted contract (SIC) surfaces were not free of defects (interfering filet welds) that prevented solid seating and sound bearing of the component parts.
(b) Washers were not installed under the bolt heads over the slotted holes.
(c) A 5/8-inch diameters bolt was used when a 3/4-inch diameter bolt was required.
2.
Relative to HVAC duct Support No. 2-132-88:
The actual "D" dimension is 14-1/2-inches.
The conditions cited in A and B above have existed in some part since April 24,1984.
The licensee has had at least 14 opportunities to discover portions of the cited conditions.
This is a Severity Level IV Violation (Supplement II)."
RESPONSE TO VIOLATION 50-424/88-13-01 Admission or denial of alleged violation:
The violation occurred as stated.
Reason for the violation:
The violation occurred due to a procedural inadequacy in that the drawings and procedures referenced in this report for Unit 1 did not specify the proper bolting material or torque requirements for ESF air filter housing.
These requiroments were not supplied by the vendor.
Corrective steps which have been taken and the results achieved:
The corrective measures which have been taken are as follows:
1.
A deficiency card that was wri. ten on April 8,
1988, to oocument the instc11ation of improper bolting material for ESF filter housing resulted in the initiation of six Maintenance Work Orders (MW0s).
The MW0s (five of which have the field work completed) were initiated to accomplish the following:
NON-00216 E-2 JUL 2 71988
[-
ENCLOSURE (continued)
NRC NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE Replacement of the A-307 type bolts with the stronger and appropriate diameter A-325 type bolts.
Installation of appropriate washers for high strength joints.
Adherence to the proper tension requirements for the A-325 bolts.
2.
An engineering evaluation was completed on April 8,1988; it concluded that the mounting conditions extant would maintain the seismic integrity and function of the HVAC filtration units.
With the unit's operability unaffected, no compensatory measures were recommended, but the evaluation did state that the mounting bolts were to be replaced in a
timely manner to achieve the original design configuration.
This resulted in the initiation of the six MW0's cited above.
Corrective steps which will be taken to avoid further violations:
It is anticipated that the aforementioned corrective steps will preclude a recurrence of this violation.
Date when full compliance will be achieved:
Full compliance will be achieved on August 15, 1988 when the installation of the A-325 type bolts are completed in accordance with the remaining MW0.
NON-00216 E-3 JUL 2 71988