ML20207B463

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Responds to Violations Noted in Insp Repts 50-424/86-31 & 50-425/86-15.Corrective Actions:Procedure 13011-1 for RHR Sys Filling & Venting Revised,Incident Rept Procedure Developed & Personnel Retrained
ML20207B463
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 07/02/1986
From: Foster D
GEORGIA POWER CO.
To: Reyes L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-979, NUDOCS 8607180045
Download: ML20207B463 (4)


Text

Georg;a Power Company h

R Post Off,ce Box 282 U

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Waynesboro, Georg:a 30830 Te4ephone 404 554 9961. Ext. 3360 404 724-8114. Ext 3360 GeorgiaPower D. o. Foster Vace Pres. cent

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Vogt:e Project

>t United States Nuclear Regulatory Commission Region II File: X78G10 Suite 2900 Log:

GN-979 101 f1arietta Street Atlanta, Georgia 30323

Reference:

50-424/86-31, 50-425/86-15 Attention: Mr. Luis A. Reyes Georgia Power Company wishes to submit the following information relative to the violations identified in your inspection report 50-424/

86-31 and 50-425/86-15:

Violation 50-424/86-31-01, " Failure to Establish Appropriate Procedures to Properly Control the Filling and Venting of Safety-Related Systems"

- Severity Level IV Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.

The violation is attributed to three basic causes:

1.

Failure to communicate effectively at the working level in the sequencing of valves during the filling and venting operations.

2.

Failure to use appropriate approved procedures to control the filling and venting operations.

3.

Failure to establish appropriate policies relative to the use of verbal instructions in the performance and control of filling and venting operations.

The events and contributing factors surrounding the RCS overfilling occurrences and the specific discrepancies identified in the USNRC inspec-tion report have been reviewed and have either been corrected or have l

been identified in controlled documents such as deficiency reports and i

audit findings to ensure they are properly addressed.

This review has concluded that the everfilling occurrences have had no detrimental effects on safety-related equipment.

T, prevent further occurrences of the type identified in the viola-tion, the following corrective actions and program improvements have been completed or are in progress:

I f 8607180045 860702 i

PDR ADOCK 05000424 7M I O

PDR

Page Two I

1.

Through training sessions, shift briefings, and internal corres-pondence, test supervisors and Operations personnel have been i

reinstructed in the importance of effective comrrunications,

j avoidance of operator errors, and the use of appropriate proce-dures to control work activities.

2.

Procedure 13011-1 for filling and venting the RHR system has been revised to address the sections of piping between valves 8701A and 8701B (Train A) and 8702A and 8702B (Train B).

l 3.

Startup Manual Procedure SUM-37, " Initial Test Program Conduct l

of Shift Operations," has been revised to establish policies to limit the use of verbal instructions in the performance of work activites involving safety-related equipment.

4.

A new Startup Manual Procedure (SUM-39, " Initial Test Program Incident Reports") has been developed to establish a report to management for occurrences (like the RCS overfills) that were previously not required to be reported.

The procedure includes provisions for determining the root cause of reported incidents and for prescribing appropriate corrective actions.

The Initial Test Program Incident Report, in conjunction with other reporting procedures, provides a basis for management monitoring and evaluation of the effectiveness of corrective actions described in this response.

5.

Appropriate training will be conducted for personnel responsible for implementing the procedure revisions and additions described above. Training is expected to be completed by July 31, 1986.

Georgia Power Company Quality Assurance conducted a special un-announced audit of activities and corrective actions associated with the two RCS overfill incidents identified in the USNRC inspection report as well as several other similar incidents which occurred during the period from February 25, 1986, through May 5,1986.

The audit resulted in the issuance of two Audit Finding Reports which identify programmatic weaknesses contributing to the reviewed incidents.

Quality Assurance will monitor and evaluate the effectiveness of corrective actions relative to the Audit Finding Reports.

The audit report, dated May 14, 1986, is available at the plant site for USNRC review.

The Nuclear Operations Independent Safety Evaluation Group also conducted an evaluation of the RCS overfill incidents and reached conclu-sions similar to those of the quality assurance audit.

Violation 50-424/86-31-08, " Failure to Follow Procedures for Protecting Installed Equipment / Components" - Severity Level IV Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.

The violation is attributed to a failure to effectively implement the provisions of specification X3AR01, Section E8.7.1.5, which requires that signs be posted or suitable barriers be installed where cable trays

Page Three are located in such a way that they may be used as walkways or working platforms.

An inspection and evaluation was conducted of cable tray section i

IBE502TRAA and the cables installed in the tray.

The damage to the tray was confirmed to be as described in the USNRC inspection report.

l It was determined that no damage occurred to the cables. The tray section was replaced and grating was installed in the area around the tray to prevent it from being used as a walkway.

A walkdown inspection was performed of cable tray installations in the Unit 1 Containment.

Minor damage including slanted siderails and sagging bottoms was noted in nineteen tray sections. These discrepan-I cies were identified in Deviation Report ED-13477.

Engineering's evalua-tion of Deviation Report ED-13477 determined the damage to the nineteen tray sections does not adversely affect the function of the cable trays and does not require rework.

Cables installed in the damaged tray sec-tions were also inspected and found to be undamaged.

Georgia Power Company is presently obtaining warning signs to be placed throughout the power block area to prevent the use of cable trays as work platforms and walkways.

Barricades will also be installed in locations where the improper use of cable tray would be convenient for personnel working in the area.

During the installation of warning signs and barricades, inspections will be conducted throughout the power block area for damaged tray or cable.

These inspections will be conducted in accordance with Construction Field Procedures ED-T-02 and ED-T-07.

A procedure awareness flyer has been distributed to electrical construction personnel on the correct procedure for obtaining access to cable trays for work operations.

An article was also placed in the plant newspaper explaining specification restrictions on the

m. -; of cable tray for walkways or work platforms.

An internal memorandum was issued to Georgia Power Company Construction Civil and Mechanical disci-plines announcing the installation of warning signs to protect cable trays and detailing the methods for obtaining access to cable trays for work operations.

Beginning in July 1986, the Vogtle electrical contractor, Cleveland Consolidated, Inc., will conduct monthly surveillances of cable tray installations to identify, resolve, and prevent trash accumulations.

The corrective actions and preventive measures described above are expected to be completed by July 31, 1986.

These responses contain no proprietary information and may be placed in the USNRC Public Document Room.

Your trulyg j

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STf/

D. O. Foster REF/D0F/tdm

Page Four g,4 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)

R. H. Pinson G. Bockhold C. S. McCall (0PC)-

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

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

D. E. Dutton E. D. Groover NORMS 1

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