ML20203C474
| ML20203C474 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/10/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-859, NUDOCS 8604210170 | |
| Download: ML20203C474 (20) | |
Text
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f Georgia Fbwer Company gpg Fbst Ofhce Box 282 Waynesboro, Georgia 30830 t
Telephone 404 554-9961 Ent. 3360 404 7244114, Ext. 3360 k
L c ' 15 a 9 : 5 9 Georgia Power
- o. o.ro.i.r 2J ' " '
Vice Presdent
\\bgtie Project l'e 5* d'"" **rl'A' SWIWM April 10, 1986 United States Nuclear Regulatory Commission File:
X7BD102 Suite 2900 Log:
GN-859 101 Marietta Street, N.W.
Atlanta, GA 30323 L
Reference:
Vogtle Electric Generating Plant - Unit 1, 50-424, NRC Report No. 50-424/85-62 l
Attention:
Mr. J. Nelson Grace Enclosed are Georgia Power Company's responses to Inspector Followup Items 424/85-62-02 through 424/85-62-13 regarding i
Appendix E. Material Control.
Appropriate support documentation is on file and available for your inspection.
j This response contains no proprietary information and may be i
placed in the NRC Public Document Room.
Very truly yours, M._
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D. O. Foster t
ANN /DOF/deg cc:
Tee Attachment 1 8604210170 860410 PDR ADOCK 05000424 G
PDR I
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l Attachment I l
cc:
U.
S.
Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Victor J.
Stello, Jr., Director U.
S.
Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C.
20555 J. W. Thompson U.
S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 28014 Ms. Melanie A. Miller Division of Licensing Licensing Branch #4 Washington, D.C.
20555 Senior Resident Inspector U.
S. Nuclear Regulatory Commission Plant Vogtle Electric Generating Plant l
B. W.
Churchill Shaw, Pittman, Potts & Trowbridge 1800 M Street, Northwest I
Washington, D.C.
20036 l
J.
E. Joiner Troutman, Sanders, Lockerman & Ashmore Candler Building 127 Peachtree Street, N.W.
l Atlanta, GA 30303 D.
C. Teper Georgians Against Nuclear Energy 1253 Lenox Circle Atlanta, GA 30306 i
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Page Two cc:
William M. Hill NRC-IE (EWS-305)
Building East West / South Towers 4340 East-West Hwy.
Bethesda, MD.
20555 W. H. Hankin Suite 2900 101 Marietta Street. N.W.
Atlanta, GA 30323 R. E. Conway J. T. Beckham, Jr.
R. A. Thomas D. E. Dutton D.
S.
Read W. T. Nickerson D. T. King K. Wiedner P. D. Rice R. H. Pinson C. W. Whitney J.
A.
Bailey F.
B. Marsh J.
L. Vota C. W. Hayes I
S.
H. Freid W.
C. Ramsey e
R. T. Oedamer J.
S. Hempstead W. M. Wright R. W. McManus M. H. Googe J. Starnes (INPO)
O. Batum Document Control Project File RR Reading File (Letter Only)
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Page One IIFI 424/85-62-02 Inspector Followup Item. The scope of Appendix E is inconsistent with the contents, paragraph 6.a.
The scope of Appendix E states, "The scope addresses permanent plant materials, parts and equipment at VEGP (Vogtle Electric Generating Plant) fron receipt through issue to contractors for installation and storage / maintenance to transfer to Georgia Power Company (GPC) Nuclear Operations".
This scoping statement appears inconsistent with the text of Appendix E in that many areas of material control are not discussed.
A specific example is that welding filler material does not appear in this appendix.
Also, it appears that Appendix E does not address all material control requirements after issue from warehouse storage.
These areas appear to be evaluated in individual modules.
Until this scoping statement is clarified, this is identified as Inspector Followup Item 424/85-62-02.
Response
The scope statement for Appendix E was clarified in a revision of Appendix E on February 7, 1986.
The clarified scope statement now reads
"[ Appendix E] includes activities associated with initial receipt and storage of equipment, material at the jobsite from receipt through issue of contractors for installation.
It also includes activities associated with equipment maintenance from receipt, through erection and installation, until transfer to GPC Nuclear Operations".
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Page Two The scope of Appendix E includes material control activities associated with the initial receipt and storage up to issue to the contractors.
Procedure MD-T-12, receipt inspection and storage / issue of pipe, pipe components, and weld filler material, gives details for inspection, storage, and issue of welding filler material and is referenced in Section E4 of the appendix.
The control of welding filler material after issue to the contractors is discussed in individual applicable modules where it is utilized in an associated program or process (e.g.,
Module 4, Mechanical Equipment and Piping or Module 8, Structural Steel).
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b, Page Three IFI 424/85-62-03 Inspector Followup Item, Audit matrix and finding matrix of Appendix E fail to include all violations and findings germane to materials control, paragraph 6.b.
The audit matrix and finding matrix of l
Appendix E fails [ sic] to include all violations and audit findings germane to materials control which have been identified at VEGP.
The tollowing are examples of L
perceived problems:
r Violation 424/79-07-02, Electrical preventive maintenance end rotation of Spray Pump Motors and Safety Injection Pump Motors.
Violation 424/81-07-02, No record of EMSL inspections of Reactor Pressure Vessel and Boric Acid Transfer Pump for 9/80 and 3/79.
Violation 424/82-16-01, Failure to perform periodic maintenance of equipment within specific maintenance period (this'is listed under inspection).
Violation 424/82-19-01, Protection of valves.
Violation 424/82-29-01, Failure to control the storage and preservation of electrical equipment.
Violation 424/84-11-01, Failure to follow procedure for protection of electrical equipment in control room.
Until the audit matrix and finding matrix are reviewed and an evaluation made to include /not include these violations, this is identified as Inspector Followup Item 424/85-62-03.
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Response
Readiness Review assembled an independent team separate from the original Appendix E team and performed another review to evaluate the appropriateness of the items listed in the audit and findings matrices in section E5.
The team also evaluated GPC Level I (most severe) QA audit findings and the NRC violations to determine whether additional findings would appropriately be listed in the audit and finding matrices in section E5.
Each of these reviews confirmed the general accuracy of the matrices but did identify a few items which were judgements as to where they belonged and a few that were inappropriately assigned.
Each of these items was reevaluated and, if appropriate, placed in the audit or finding matrix for Appendix E.
The identified findings added to the matrices were evaluated for impact on the conclusions reached in the appendix.
None of these additional items altered the' conclusions reached in Appendix E.
The scope, methodology, and results of the evaluation were presented in our conference of January 18, 1986 and revised audit and finding matrices were included in the February 7, 1986 revision of Appendix E.
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Page Five IFI 424/85-62-04 Inspector Followup Item.
W.
C.
Ramsey letter to D.
O.
Foster addresses Structural Steel, paragraph 6.c.
The transmittal letter to Mr.
D.
O.
Fostor from Mr.
W.
C.
Ramsey dated October 30, 1985, states in part that problems experienced by other near term operating license utilities regarding structural steel are considered in this appendix.
The inspector's review of this appendix identified that structural steel is rot included in this appendix.
Until this apparent wording error can be clarified, this is identified as Inspector Followup Item 424/85-62-04.
Response
The transmittal letter to Mr. D.
O.
Foster from Mr. W.
C.
Ramsey contained unintended wording resulting from a text processing error.
This was corrected in the February 7,
1986 revision of Appendix E.
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Page Six IFI 424/85-62-05 Inspector Followup Item. Readiness Review Finding El is classified as level III which is inappropriate, paragraph 6.d.
Readiness Review Finding El identified four equipment / material items out of a sample of 34 for which there was no documented evidence to show that GPC Construction Engineering had evaluated them to determine whether the items were to be entered into the EMSL or whether these items were to be exempted from the EMSL.
This finding was classified as a Level III finding by the Readiness Review Team.
This finding appears to be a Level II finding since Level II is defined as a violation of licensing commitments or engineering requirements with no safety concerns.
Until this apparent misclassification can be corrected, this is identified as Inspector Followup Item 424/85-62-05.
Response
Originally no levels were assigned by the Readiness Review Teams.
However, one of the l
lessons learned in the program was the value of categorizing findings into groups L
according to significance to assist both the Readiness Review Team and other involved parties in evaluating total situation.
An understanding of the cause of a finding is part of the results of the project's evaluative efforts.
Upon completion and acceptance of projects actions, the Readiness Review Team categorizes the findings according to predefined levels.
Generally, if a commitment is being implemented through a formal project document or proceduralized progam, any failure to comply identified in findings are categorized as " failure to follow project procedures" (Level III).
We have reevaluated the categorization of finding El and believe the current categorized level to be consistant with the categorizations of
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Page Seven findings in the Readiness Review Program.
Additionally, we have reviewed the appendix considering categorizations of finding El as Level II and concluded that the overall 3
conclusions of the appendix or the response l
and the resolution to finding El would not
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be invalidated.
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7 ds Page Eight IFI 424/85-62-06 Inspector Followup Item. Storage requirements for electrical equipment conflicts with ANSI standards, paragraph 6.e.
1 ANSI N45.2.2-1972, Packing, Shipping.
I Receiving. Storage, and Handling of Items for Nuclear Power Plants. Section 2.7.2, i
states that instrumentation, electrical I
equipment, and batteries, shall be stored in l
Level B storage areas.
Appendix E.
Section l
E4.3.1, General Storage Requirements states that instrumentation, electrical equipment, and batteries will be stored in Level C storages.
The inspectors verified that the proper level of storage was actually maintained for the equipment onsite.
However, until storage procedures are
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changed to reflect the correct requirements, j
this will be identified as Inspector i
Followup Item 424/85-62-06.
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Response
The electrical construction specification, X3AR01 Section Ell defined storage requirements in a list and a clarifying introductory paragraph.
In preparing Readiness Review Appendix E, the clarifying i
paragraph was inadvertantly not included, l
Without this paragraph, the list gives incorrect storage requirements.
Although not required, a field change request (FCR) revising X3AR01 was issued on January 8, 1986 to avoid possible future discrepancies when extracting requirements from the specification.
A copy of this FCR was l
provided to the NRC inspector prior to the l
January 10, 1986 exit meeting.
The text of l
the program description portion of Appendix E.
Section E4, was corrected in the February l
7, 1986 revision to match the clarification l
to X3AR01, Section Ell.
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Page Nine IFI 424/85-62-04 Inspector Followup Item, Weatherproof and outside storage are specified for like materials, paragraph 6.f.
Appendix E.
Section E4.3.1, General Storage Requirements, states that conduit and cable trays are to be stored in both Level C and Level D Storage.
Until conflict in storage requirements is resolved, this is identified as Inspector Followup Item 424/85-62-07.
Response
Appendix E, Section E4.3.1, General Storage Requirements was intended to state
" Weatherproof (Level C)... bolting material and hardware for conduit and cable trays" rather than " conduit and cable trays".
This was corrected in tl.a February 7, 1986 revision of Apperdix E to clarify the ambiguity regarding etorage requirements for conduit and cable tray.
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Page Ten IFI 424/85-62-08 Inspector Followup Item, Conflict in number of audits, paragraph 6.g.
Appendix E.
Section E5.1. states the following:
The Georgia Power Company (GPC) conducts regularly scheduled audits to verify compliance with project commitments.
Audit findings and recommended corrective measures are reported to the management of the audited organization.
The audit results are also reported to GPC management and the GPC Quality Assurance (OA) organization tracks the acceptability and timeliness of the response.
Georgia Power Company has conducted 55 audits relating to material control.
The audits, summary descriptions of the findings, and the categorization of each finding are presented in the audit and finding matrixes at the end of this section.
The 38 GPC audits resulted in the identification of 97 findings during the period from 1977 through the first quarter of 1985.
Category Total Findings Receiving 4
Storage 78 Maintenance 7
Documentation 11 Total 100 There are apparent conflicts in this section in that one statement says that GPC has conducted 55 audits and another statement says that they have conducted 38 audits.
This section also states that there were 97 findings; however, the total findings column sume to conducted and total findings can be resolved, this is identified as Inspector Followup Item 85-62-08.
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Page Eleven
Response
Audits and findings listed in the Appendix E matrixes were rereviewed.
Corrected tables providing a categorization of findingn by activity have been provided.
These were submitted in the February 7, 1986 revision of Appendix E.
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Page Twelve IFI 424/85-62-09 Inspector Followup Item, INPO findings are inconsistent, paragraph 6.h.
Appendix E.
Section E5.3. INPO Evaluations, has a conflict similar to the one in (g) above in that the text of the section states that five findings were identified while the Total Findings column sums to only four.
Until this apparent conflict in the number of total findings can be resolved, this is identified as Inspector Followup Item 424/85-62-09.
Response
Four findings were related to the 1984 INPO evaluation.
These are discussed in Appendix E, Section E5.3.
The text was corrected to eliminate the statement that there were five findings.
This change was made in the February 7, 1986 revision of Appendix E.
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L Page Thirteen IFI 424/85-62-10 Inspector Followup Item, Summary of Section E5, Audits, states that 120 findings were identified, paragraph 6.1.
Appendix E.
Section E5.6, Summary, states that there were 120 total audit findings.
However, when the Total Findings columns from Sections E5.1 to E5.5 are summed, the result is 139.
Until this apparent conflict in the number of total findings can be resolved, this is identified as Inspector Followup Item 424/85-62-10.
Response
The conflict between the total audit findings listed in Section E5.6 and the sum of the Total Findings columns for Sections E5.1 through E5.5 has been eliminated.
The findings resulting from each organization's audits, inspections, or evaluations are listed where the audit, inspections, or evaluations are discussed.
Thece changes were made in the February 7, 1986 revision of Appendix E.
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Page Fourteen IFI 424/85-62-11 Inspector Followup Item, Equipment Maintenance Storage List (EMSL) of Safety Injection Pumps and Motors contain errors, paragraph 6.J.
The inspectors selected the EMSL cards for Safety Injection Pump Motors to evaluate the preventive maintenance performed on this equipment.
These logs contain discrepancies which should have been identified and evaluated by the Readiness Review Team.
A specific example is that the EMSL card for the "B" Motor, tag number 1-1204-P6-004-M01, has been listed as train "A"
since 10-31-83.
Also, there were questions concerning documented records for preventive maintenance from early 1979 until 10-28-81.
However, during subsequent inspections, GPC was able to produce record documenting maintenance on these pumps during this period.
Until the mislabeling is clarified for the "A" and "B"
pumps and the records reviewed to assure preventive maintenance was performed correctly, this is identified as Inspector Followup Item 424/85-62-11.
Response
On these documents, the key piece of information uniquely identifying the equipment is the tag number.
This information on the EMSL cards for the train "A" and "B"
safety injection pump motors was correct.
Based on an evaluation of the maintenanco cards and the instructions provided to the inspectors on checking the the tag number, it was concluded that preventive maintenance was performed on both pumps as indicated on the individual EMSL cards.
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Page Fifteen Copies of the EMSL cards corrected to indicate that pump. motor, tag number 1-1204-P6-004-M01, was the train "B" motor were provided-to the inspector prior to his January 10 1986 exit.
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Page Sixteen IFI 424/85-62-12 Inspector Followup Item, Improper classification of violations for records, paragraph 6.k.
The inspectors noted that the audix matrix contains listings of violations concerning records which were perceived to be applicable to Appendix D rather than E.
A specific example is that violations 424/79-13-03 and 424/83-13-03 appear to be more applicable to Records than to Materials Control.
Until this apparent misclassification can be clarified, this is identified as Inspector Followup Item 424/85-62-12.
Response
Inspector followup item 424/79-13-03 and violation 424/83-13-03 were reevaluated as a part of the evaluation described in response to IFI 424/85-62-03 resulting in their reassignment to Appendix D.
A revised Appendix D, Document Control Finding Matrix was provided in the Appendix D supplement dated February 11, 1986.
The supplement also included an assessment of the impact of inclusion of the violation on appendix evaluation and conclusions.
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.$ t Y Page Seventeen IFI 424/85-62-13 Inspector Followup Item, Regulatory Guide 1.28 not included, paragraph 6.1.
Paragraph E3.1, Commitments, does not list Regulatory Guide (RG) 1.28, Quality Assurance Program Requirements, as being applicable to the VEGP Materials Control Program.
It appears that RG 1.28 is applicable to this program.
Until an evaluation can be performed by the licensee to determine RG 1.28 applicability, this is identified as Inspector Followup Item 424/85-62-13.
Response
As stated in FSAR Section 1.9.2.8.2, the VEGP quality assurance program (QAP) is in conformance with Regulatory Guide 1.28 (formerly safety guide 28) June 7, 1972 which invokes ANSI N45.2-1971 or an acceptable standard for the nuclear quality assurance program (10 CFR Appendix B).
The applicable QAP requirements of Appendix B to 10 CFR 50, Criteria VII, VIII, and XIII were addressed in the implementation matrix as items 692.01, 692.02 and 692.03 respectively.
In accordance with our letter of October 3,
1985 (GN-711), Section 3.1 of Appendix E provided in the February 9, 1986 revision states: "In addition to the specific commitments identified in this appendix, appropriate quality assurance requirements and commitments (or exceptions and alternatives thereto, as stated in the FSAR) are applicable to the project activities described in this appendix.
The applicable requirements of these commitments were considered in assessing the project activities described in this appendix."
0429B/097-6 L