ML20206R748

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Responds to Violations Noted in Insp Repts 50-424/86-20 & 50-425/86-11.Corrective Actions:Const Field Procedure MD-T-12 Revised to Require Identification Marking on Small Snubber Components
ML20206R748
Person / Time
Site: Vogtle  
Issue date: 06/18/1986
From: Foster D
GEORGIA POWER CO.
To: Reyes L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-952, NUDOCS 8607070214
Download: ML20206R748 (3)


Text

Georgia Fbwer Company p

Fbst Office Box 282 Waynesboro, Georgia 30830 Telephone 404 554-9961, Ext. 3360 404 724-8114. Ext. 3360 D. O. Foster i a " " ' 7 l * *b ffeduttyyn elgarcsystem n

Vice President Vogtie Project June 18, 1986 United States Nuclear Regulatory Commission Region II File: X78G10 Suite 2900 Log:

GN-952 101 Marietta Street Atlanta, Georgia 30323

Reference:

50-424/86-20, 50-425/86-11 Attention: Mr. Luis A. Reyes Georgia Power Company wishes to submit the following information relative to the violation identified in your inspection report 50-424/

86-20 and 50-425/86-11:

Violation 50-424/86-20-01, 50-425/86-11-01. " Failure to Follow Procedure for the Marking and Verification of Traceability for Small Component Parts Used in Mechanical Shock Arrestors" - Severity Level IV.

The violation identitie. the failure by Pullman Power Products (PPP) personnel to adequately control small component parts used in the fabrication and installation of mechanical snubbers.

The USNRC inspector observed small components (load pins and studs, bolts, nuts) in the main warehouse, pre-op test area, and the pre-fabrication shop area with no identification to ascertain traceability.

Washers in the pre-fabrication shop area were observed as not conforming to the identifi-cation pa rameters prescribed in PPP Procedure VIII-1.

Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:

Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.

On February 26, 1986, Construction Field Procedure MD-T-12 was revised to require identification marking on small snubber components.

These requirements were reflected in PPP's Site Instruction SI-64.

Small snubber pa rts were released for snubber fabrication and installation begf r.ning on February 3,1986.

Prior to the revision to MD-T-12, these parts were controlled by issuing them in bags tagged with the appropriate pipe support number and a QC acceptance tag.

The procedure revision resulted when it was realized that this method of control was not fully satisfactory.

The USNRC violation resulted from a failure to retrofit the new controls upon componerts issued during the February 3-26 period.

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'O Page Two PPP Procedure VIII-1 established parameters for the identification of hardened washers.

The hardened washers were described as black or grey in color with a distinct resonant sound when dropped on a hard surface.

The washers observed by the USNRC inspector were silver to silver-copper in color.

These washers were accepted as hardened washers by PPP QC because they produced the resonant sound when dropped on a hard floor.

The apparently unhardened washers were of a size that would only fit Pacific Scientific Models PSA-1/2 and PSA-1/4 snubbers.

On March 21, 1986, fabrication and testing areas were searched for small unmarked snubber components (bolts, studs, nuts, etc.).

The components were returned to the GPC main warehouse where those parts that were identifiable as vendor-supplied snubber parts were marked in accordance with procedure MD-T-12.

Components not identifiable as vendor-supplied snubber parts were discarded.

In addition, uninstalled unhardened washers were promptly removed from snubber fabrication areas following the USNRC inspection.

Inspection personnel in the snubber fabrication shop and in the field were directed not to accept snubbers with unmarked parts or with unhardened washers unless safety wire was also installed.

Pullman Power Products conducted a walkdown inspection of snubbers installed prior to March 21, 1986.

Small components which were identifi-able as vendor-supplied snubber parts were marked in accordance with procedure HD-T-12. All other parts were replaced.

Pullman Power Products also reinspected PSA-1/2 and PSA-1/4 snubbers issued for installation prior to March 21, 1986, to ensure that either hardened washers were used or that safety wiring was installed on bolts as required.

Nine snubbers were identified during the inspection with unhardened washers and were identified on a Deviation Report to assure adequate evaluation and resolution.

As indicated earlier in this response, procedure MD-T-12 and Site Instruction SI-64 have been revised to require marking of small snubber parts.

The marking will be performed in the GPC main warehouse prior to issuance to PPP.

PPP Procedure IX-32 has been revised to require PPP QC to verify the marking prior to issuing parts to the craft for installation.

PPP Procedure VIII-l has been revised to delete the identi-fication of hardened washers based on the sound produced when the washers i

are dropped.

Washers must now be identified based on color or specific tagging.

Consistent and effective implementation of these procedure revisions should prevent further violations.

Training of responsible i

personnel in the procedure revisions was conducted during April and May 1986.

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

Your truly

(

i D. O. Foster REF/00F/tdm

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Page Three xc:

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.

20555 J. H. Miller R. A. Thomas L. T. Gucwa J. P. O'Reilly D. R. Altman C. W. Hayes G. F. Head P. R. Bemis G. A. McCarley R. E. Conway J. A. Bailey D. S. Read J. T. Beckham

0. Batum Sr. Resident (NRC)

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P. D. Rice C. E. Belflower J. E. Joiner (TSLA)

B. M. Guthrie J. F. D'Amico D. C. Teper (GANE)

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