ML20195H940
| ML20195H940 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/22/1988 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NON-00153, NON-153, NUDOCS 8806290022 | |
| Download: ML20195H940 (5) | |
Text
...
.a 3
A no At:anta. Geoga 30308 Telephone 404 526 6526 o 1 Off 4545 Atlanta. Geof g+a 30302 Georgia Power Nuclear Operations Department f!v sNrun eiscrc SC!cm NON-00153 June 22, 1988 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Hashington, D.C.
20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits the enclosed information in response to NRC Inspection Report 50-424/88-18 which concerns the inspection conducted by Mr. H. P. Kleinsorge of the NRC Region II staff on April 18 - 22 and May 2 - 5, 1988.
A copy of this response is being orovided to the NRC Region II office for review.
The Notice of Violation accompanying the subject inspection report also applies to Unit 2.
The response for that Unit will be provided by Vogtle Project under separate cover to the NRC.
In the enclosure, a transcription of the NRC violation precedes the GPC response.
Should there be any questions in this regard, please contact this office at any time.
Sincerely, id
?. Nas
^M-H. G. Hairston, III Senior Vice President, Nuclear Operations KP/stl
Enclosure:
1.
Violation 88-18-01 and GPC Response c:
(see next page) 0l f \\
8806290022 880622 PDR ADOCK 05000424 O
DCD I
1,.
O Georgia' Power d
-U. S. Nuclear Regulatory Commission.
June 22, 1988 Page Two c: Georaia Power Comoany Mr. P. D.-Rice Mr. G. Bockhold, Jr.-
Mr. J. E. Swartzwelder Mr.-L. T. Gucwa 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, Vogtle e
(
0989m L
ene
1 ENCLOSURE 1
PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSING NPF-68 NRC NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE l
VIOLATION 50-424/88-18-01 "Title 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 1
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 base channels with Type A-449 high strength
- bolts, or equivalent, pretanstoned to meet the friction connection requirement."
Type A-449 bolts have s minimum required tensile strength of 105 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 solid 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 Clacs 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 comitments 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 A-307 with a tensile strength of 60 KSI).
The Unit Two ESF filter housing assemblies were installed with snug tight (not pretensioned) high strength b(.,lts.
NON-00153 E-1 JUN 2 2 909
~
ENCLOSURE (continued)
NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE b.
Contrary to the
- above, activities affecting quality were not accomplished 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 50-424/88-18-01 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.
l These requirements were not supplied by th.i vendor.
1 Corrective.?teps which have been taken and the results achieved:
The corrective measures which have been taken are as follows:
A deficiency card that was written on April 8,
1988, to document the installation 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:
- 1) Replacement of the A-307 type bolts with the stronger and appropriate diameter A-325 type bolts.
NON-00153 E-2 M 2 2 P99 l
1 ENCLOSURE (continued)
NRC NOTICE OF VIOLATION 88-18-01 and GPC RESPONSE
- 2) Installation of appropriate washers for high strength joints.
- 3) Adherence to the proper tension requirements for the A-325 bolts.
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 con ~.pliance will be achieved on August 15, 1988 when the installation of the A-325 type bolts are completed in accordance with the remaining MW0.
e I
l l
NON-00153 E-3 i
JLN 2 2 S88 i
i