ML20205S412
| ML20205S412 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/31/1987 |
| From: | Rice P GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GN-1358, NUDOCS 8704070024 | |
| Download: ML20205S412 (3) | |
Text
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Georgia Power Company o
Fbst Office Box 282 W2yntsbora Georgia 30830 Telephone 404 554-9961. Extension 3413 404 724-8114 Extension 3413 M
Georgia Power NeN March 31, 1987 United States Nuclear Regulatory Commission Document Control Desk File:
X78G10 Washington, D. C.
20555 Log:
GN-1358
Reference:
Vogtle Electric Generating Plant - Units 1 & 2 USNRC Inspection Report 50-424/87-11, 50-425/87-07 The Georgia Power Company wishes to submit the following information concerning the violations identified in the referenced inspection report.
l Violation 50-424/87-11-01, 50-425/87-07-01, " Failure to Follow Design Manual for PSAR/FSAR As-Built Changes" - Severity Level IV Georgia Power Company (GPC) acknowledges the discrepancy on which the violation is based but takes exception to the violation in that the discrepancy has already been addressed by GPC in response to an earlier USNRC inspection
- finding, Deviation 50-424/86-59-03, 50-425/86-26-03.
Responsible Vogtle Project pernonnel apparently failed to make the USNRC Inspector aware of this fact and other information during inspection 50-424/87-11, 50-425/87-17.
As indicated in the inspection report, Section 3.4.6 of the Vogtle Project Design Manual requires that substantive differencer between PSAR comrritments and design be identified in the "PSAR Comparison" section of the appropriate design criteria.
However, this requirement is applicable only to the design criteria contained in the Design Manual and only to substantive differences between the PSAR and actual design until such time as the FSAR is issued.
Section 3.4.6 also requires that, after submittal of the FSAR, design changes which impact licensing commitments (such as the FSAR) be identified and resolved in accordance with appropriate procedures in the Vogtle Project Reference Manual.
A comrritment for interlocked and alarmed control room doors was never included in the Vogtle PSAR and, therefore, could not have been addressed in the "PSAR Comparison" section of the affected design criteria.
The discrepancy between FSAR Sections 6.4.2.2.2.J and 6.4.2.4.E and the current design (as reflected in drawing AX1011A04) has already been addressed by GPC in its response to the USNRC concerning Deviation 50-424/86-59-03, 50-425/86-26-03 (GN-1087 dated September 25, 1986, and GN-1158 dated October 31,1986).
Responsible Vogtle Project personnel apparently failed to make the USNRC Inspector aware of these facts during inspection 50-424/87-11, 50-425/87-07.
As a result, the USNRC inspection report does not accurately describe the discrepancy.
The actual discrepancy, which has already been addressed as indicated, is the failure by Vogtle Project engineering to properly update the FSAR to reflect the design change which removed the interlock and alarm features from the control room doors.
8704070024 870331 PDR ADOCK 05000424 O
USNRC Inspection Report 50-424/87-11, 50-425/87-07 File: X78G10 Log:
GN-1358 Page two In conclusion, the net result is that both the violation and the previously issued Deviation identify the same discrepancy.
In its response to the Deviation, GPC explained how the discrepancy occurred and described corrective actions and actions to prevent recurrence.
On this basis, GPC requests that the violation be withdrawn.
Violation 50-424/87-11-02, 50-425/87-07-02, " Failure to Provide Adequate 1
Report of Significant Construction Deficiency" - Severity Level IV Georgia Power Company (GPC) acknowledges the violation.
- However, after careful review of the severity categories prescribed in 1
Supplement II to 10CFR2, Appendix C, and evaluation of the event cited l
in the violation, GPC has concluded that a more appropriate severity classification is Severity Level V - violations that have minor safety or environmental significance.
Since GPC's corrective actions relative to Construction Deficiency Report (CDR) 82-32 were determined to be adequate by the
- USNRC, the violation identifies a
document retrievability discrepancy that has minor safety significance; i
therefore, the severity level should be reduced to Severity Level V.
Georgia Power Company submitted its final report (File: X7BG03-M32, Log: GN-250) to the USNRC for CDR 82-32 on August 15, 1983.
This j
report identified the condition involving ~ design inconsistencies in HVAC duct supports as reportable pursuant to the requirements of 10CFR50.55(e) and 10CFR21 and described GPC's evaluation of the condition and the resulting corrective actions.
The engineering evaluation included a review of approximately 4700 duct support shop drawings, which represented the HVAC duct supports i
fabricated as of September 24, 1982, when GPC stopped work due to the reported condition.
One hundred twenty (120) of these drawings were found to contain design discrepancies (member, weld, and bolt sizes; bracing requirements) which may have affected the ability of the supports to perform their designed function.
This information 1
was provided in the evaluation report primarily as an indication of l
the extent of the reported condition.
Rather than conduct a detailed engineering evaluation of each of the 120 duct supports, GPC elected to consider the condition reportable and to correct the shop drawings and supports.
Corrections were made to the 120 shop drawings by the duct support fabricator (Pullman Construction Industries) under the direction of the architect-engineer (Bechtel Power Corporation) using the normal process for revising vendor drawings.
However, revisions were also made to a large number of other vendor duct support drawings involving relatively insignificant cosmetic discrepancies in addition to the 120 drawings discussed above.
Since the evaluation provided a review of 100% of the potentially affected drawings and since all drawing discrepancies (significant or otherwise) were being corrected, GPC did not prepare a list of the 120 drawings determined to contain the more significant discrepancies.
It was expected that the USNRC,
O USNRC Inspection Report 50-424/87-11, 50-425/87-07 File:
X78G10 Log:
GN-1358 Page three in its review of the CDR, would select its own sample of support drawings from the population (4700) covered in GPC's evaluation.
Nevertheless, at the time the drawing corrections were being made, and for sometime thereafter, the engineering personnel involved in the evaluation could have identified the 120 drawings.
However, due to the time lapse between submittal of the evaluation report and review by USNRC personnel, nearly all of those ergineers have left the project.
A review was conducted of all open CDR's to determine if a condition similar to that encountered with CDR 82-32 existed.
No further discrepancies were identified.
Subsequent to August 1983, when the final report for CDR 82-32 was issued, the Vogtle Project has developed policies and procedures for the tysluation and resolution of CDR's which provide greater emphasis on the packaging and maintenance of supporting docurrenta tion.
The effectiveness of these measures has been demonstrated in the success GPC has experienced in achieving closure of CDR's identified subsequent to 82-32.
Therefore, compliance with applicable regulatory requirements has already been achieved.
These responses contain no proprietary information and may be placed in the USNRC Public Document Room.
Yours truly,
_ 'ks P. D. Rice PDR/CWH/wkl xc: USNRC-Region II Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 H. G. Baker D. R. Altman L. T. Gucwa J. P. O'Reilly J. A. Bailey C. W. Hayes G. F. Head
- 0. Batum G. A. McCarley R. E. Conway G. Bockhold R. W. McManus R. H. Pinson C. E. Belflower Sr. Resident (NRC)
B. M. Guthrie J. F. D'Amico C. C. Garrett (OPC)
R. A. Tnomas W. D. Drinkard J. E. Joiner (TSLA)
E. D. Groover D. Feig (GANE)
NORMS i