ML20207J323
| ML20207J323 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/19/1986 |
| From: | Rice P GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-1245, NUDOCS 8701080389 | |
| Download: ML20207J323 (4) | |
Text
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Geonya Power Company Post 01ce Box 292 Wagenboro, Georg a 3063]
h Tdephone 404 554-961. E4 3%G
, q *, t1 404 724 8114 E A 3%
/
.s u COfgla NWCf P. D. Ra Vce Pmsden:
.n, ls, em December 19, 1986 United States Nuclear Regulatory Commission Region II File:
X78G10 Suite 2900 Log:
GN-1245 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/86-95, 50-425/86-45 Attention:
Mr. J. Nelson Grace The Georgia Power Company wishes to submit the following information concerning the violations identified in your inspection report 50-424/86-95 and 50-425/86-45:
Violation 424/86-95-01, 425/86-45-01, "PFE Failed to Follow Procedures for Processing FCR's and Incorporating DCN's into Design Drawings" - Severity Level IV.
Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.
Two examples were identified in the Notice of Vio-lation and are addressed below:
1.
Field Change Request (FCR) Not Properly Incorporated Into Vendor Manual - FCR number EFCRB-15409 was converted tc a Design Change 1
Notice (No. DCN-S-4).
When the vendor manual, AX3AJ11B-24 (Rev.
2), was revised to incorporate outstanding design changes, the revision block indicated that DCN-S-4 had been incorporated.
How-ever, through oversight by the responsible engineer, the change was not incorporated into Revision 3 of the manual text.
A thorough review was conducted of vendor manual AX3AJ11B-24 (Rev.
- 3) for unincorporated design changes.
Three additional changes I
were identified that were not properly incorporated.
Revision 4 of the vendor manual was issued on August 12, 1986, to correct all discrepancies identified in the review.
In addition, special I
splice design FCR's were reviewed for potential impacts on installed hardware.
This review concluded that splices installed between issuance of the omitted design changes and their incorpo-ration were not impacted, l
The responsible engineer was apprised of the identified discrepan-cies and admonished as to the importance of proper incorporation of changes into design documents.
Corrective actions relative to this example of the violation have l
been completed.
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Paga 2 USNRC Log: GN-1245 2.
Use of NA/NA FCR's.In Generic Applications - Discrepancies in this example of the violation are attributed to inadequate implementa-tion of the project procedure for processing FCR's.
Project engi-neering conducted a review of construction specifications to deter-mine the extent of the discrepancy.
This review identified thirty-six open NA/NA FCR's that did not specify a unique component or installation.
Project engineering evaluated the thirty-six discrepant NA/NA FCR's and determined that, in each case, the generic change was accept-able for potential past and future hardware applications and that each should be converted to a specification change.
In fact, the specifications. had already. been revised in some cases to incorpo-rate the change.
The NA/NA FCR's that failed to identify a unique application were superseded by new FCR's which indicate that a specification change is required.
To prevent recurrence, responsible engineering personnel were. rein-structed in the procedure requirements for processing NA/NA FCR's.
Corrective actions relative to this example of the violation have been completed.
Violation 424/86-95-02, 425/86-45-02, " Failure to Provide Training for Electrical-Engineering and QC Staff on the Use of Raychem Products" Severity. Level IV.
Georgia Power Company acknowledges the violation relative to engineering j
personnel but denies that contract QC inspectors were not adequately trained.
Besides the lack of formal specific training in the use of Raychem products, the discrepancies identified in the violation are attributed to a failure by project engineering personnel to obtain concurrence from Raychem before approving design changes to Raychem documents and equipment.
Raychem has_ conducted splice kit design training, which included three-way and four-way splice design, for appropriate engineering personnel.
In addition,-an evaluation was performed of previously issued NA/NA FCR's deal-
[
ing with special splice configuration.
This evaluation identified eight i
FCR's which did not meet Raychem requirements.
FCR number EFCRB-18072 was issued to void.the eight discrepant FCR's and Change Control Package (CCP)
F10140E was issued on September 16, 1986, to correct the discrepancies.
Relative to -inadequate instructions to craft and QC' personnel, the Raychem manual AX3AJ11B-24 has been enhanced to provide information such as minimum sleeve lengths, shim lengths, and applicable hardware restrictions for special splice designs.
Splicing material restrictions, overlap
[
requirements, and other special instructions are also specified.
I i
To prevent recurrence, Construction Specification X3AR01-E9 has been revised to require that special splices not covered by manual AX3AJ118-24 be specified in FCR's verified and approved by engineers who have successfully
Page 3 USNRC Log: GN-1245 completed Raychem's special products training.
This approval is in addition to the standard FCR approval requirements.
Training records for the approv-ing engineers will' be maintained in site training files.
A special design instruction guide (AX3AJ11B-39) is available to aoproving engineers to assist them in assuring design adequacy.
Responsible engineering personnel were also reinstructed in project requirements for obtaining proper concurrence prior to approving changes to a vendor's documents or equipment.
Relative to the training of contract QC personnel, Georgia Power Company has an established program for assuring that contract inspectors are quali-fied to perform their assigned duties.
Contract inspection personnel are required to successfully pass a certification examination which addresses heat-shrinkable material and to complete an appropriate amount of on-the-job training before they are certified to conduct inspections. Although Georgia Power Company's QC cable termination training and qualification program did not require specific training in Raychem products, it did assure that inspectors were knowledgeable in the application of heat-shrinkable material and could properly read and understand supplier technical material.
Georgia Power Company considers these provisions adequate to prepare inspection personnel for the evaluation of cable splice installations using Raychem l
products.
To substantiate this confidence, Georgia Power Company electrical engi-neering conducted a reinspection of 149 cable splices previously accepted by QC. The reinspection identified only two errors that were attributable to QC inspection.
An evaluation determined these two instances to be isolated cases, which reinforces Georgia Power Company's position as to the adequacy of contract inspector training and qualification.
Although the previous training / certification requirements are considered adequate, Georgia Power Company has enhanced its program by adding specific Raychem training to cable termination certification requirements.
All per-sonnel presently employed in termination inspection have received this training.
Corrective actions relative to this violation have been completed.
Violation 424/86-95-03, 425/86-45-03, " Inadequate Inspection of NSCW Cable Splices" - Severity Level IV.
Georgia Power Company acknowledges the violation as identified in the USNRC inspection report.
The specific discrepancies identified in the USNRC inspection report are attributed to isolated cases of human error.
As indicated in the response to Violation 424/86-95-02, 425/86-45-02, GPC electrical engineering evalu-ated a sample of 149 QC-accepted cable splices.
Based on the results of this evaluation, Georgia Power Company concludes that a programmatic defi-ciency does not exist in the area of quality control inspection.
Pagg 4 USNRC Log: GN-1245 The specific discrepancies identified in the USNRC inspection report and the GPC engineering evaluation have been documented in deficiency reports as required to ensure proper evaluation and disposition.
Engineering and ven-dor evaluations have determined that application of heat-shrinkable material over identification marking is acceptable.
Heat will be reapplied to im-properly heated installations following completion of ESFAS testing.
To prevent recurrence, additional training has been provided for appro-priate craftsmen, QC inspectors, and engineers.
Corrective actions relative to this violation will be completed prior to Unit I fuel load.
These responses contain no proprietary information and may be placed in the USNRC Public Document Room.
Yours truly,
_ >des P. D. Rice CWH/PDR/jl xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 4
H. G. Baker D. R. Altman L. T. Gucwa J. P. O'Reilly J. A. Bailey C. W. Hayes G. F. Head G.
Bockhold G. A. McCarley R. E. Conway J. F. D'Amico R. W. McManus R. H. Pinson W. D. Drinkard Sr. Resident (NRC)
B. M. Guthrie C. C. Garrett (OPC)
J. E. Joiner (TSLA)
R. A. Thomas D.
Feig (GANE)
NORMS
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