ML20210T606
| ML20210T606 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/25/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-1087, NUDOCS 8610090099 | |
| Download: ML20210T606 (5) | |
Text
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Waynesboro, Georgia 30830 Telephone 404 554-9961, Ext. 3360 404 724-8114, Ext. 3360 k
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gggil A 8 ; 2u Georgia Power ste couthem electic systern Vogtle Project September 25, 1986 United States Nuclear Regulatory Commission Region II File: X78G10 Suite 2900 Log:
GN-1087 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
50-424/86-59, 50-425/86-26 Attention: Mr. Roger D. Walker The Georgia Power Company wishes to submit the following information concerning the violation and deviations identified in your inspection report 50-424/86-59 and 50-425/86-26:
Violation 50-424/86-59-01, " Failure to Procure HVAC Systems That Were Fabricated, Installed, and Inspected In Accordance With Procedures and Drawings" - Severity Level IV.
Georgia Power Company acknowledges all but one of the discrepancies identified in the USNRC inspection report.
A special review team com-prised of cognizant Georgia Power Company (GPC) and Pullman /Kenith-Fortson (P/K-F) personnel was appointed to evaluate each of the specific discre-pancies identified by the USNRC inspectors.
All but one of the discre-pancies were confirmed.
Pressure transmitter PDT-2524A, lo'cated 23 inches from the front. of air handling unit A-1542-N7-001-000, was found to be installed within the tolerance allowed by general notes drawing CX5DPM008.
As part of the evaluation, broadness reviews were conducted to determine the extent of the discrepant conditions.
These broadness reviews reinspected an additional 33 duct and damper bolted connections (approximately 1000 bolts), 47 tubing supports (16 of which were mounted to equipment), eight damper actuator mountings, three fan and fan support installations, and ten duct supports.
Additional discrepancies of the type identified by the USNRC inspection were found in the areas of tubing supports mounted to equipment and fan / fan support mounting.
No other discrepancies like those identified by the USNRC inspection were found.
Of the 16 equipment-mounted tubing supports covered in the broadness review, seven were loose.
It appeared initially that damage to the tubing may have caused the supports to loosen but no correlation to l
tubing damage or equipment vibration could be established.
A complete evaluation of HVAC air handling unit tubing supports is required.
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Page Two The review team confirmed that six bolts are required to mount the fan for air handling unit A-1542-N7-001-000 to its support which had only four mounting holes.
A review of the equipment installation package for this unit showed that the vendor drawing specifying six mounting bolts was not referenced.
In the broadness review, all three similar fans / supports supplied by the same vendor and installed in the plant were examined. The same discrepancy was found on all three units.
All of the discrepancies identified in the broadness reviews and in the USNRC inspection were identified in Deficiency Reports and/or Maintenance Work Orders to ensure they are adequately resolved.
Some of the discrepancies can be attributed to craft error and inspector oversight. However, many of the discrepancies, especially those involving loose or missing bolts, are more likely the result of impacts from heavy construction and testing activities subsequent to installation and inspec-tion.
Discrepancies of this type should be corrected during periodic maintenance.
In the case of the air handling unit fan mounting, the bolting discrepancies are attributed to incomplete equipment installation package drawing lists and to incorrect support assemblies as supplied by the vendor.
The discrepancies involving duct and duct support dimen-sions are attributed to inspector oversight and/or isolated errors in design change documents.
The results of the broadness reviews and the dispositions of the Deficiency Reports are available at the site for USNRC review.
Considering the number of components and attributes inspected by the USNRC inspectors and the review team to identify the discrepancies, the occurrence rate is very low and compares with that observed in the Readiness Review assessment of HVAC systems.
Georgia Power Company does -not consider these conditions. to be indicative of a deficiency of a programmatic nature in the installation and inspection of HVAC systems.
(A possible. exception would be in the case of the tubing supports following an engineering evaluation.)
To prevent further discrepancies of the type identified in the USNRC inspection report, Georgia Power Company will take the following actions:
1.
All air handling unit tubing supports will be reinspected and all loose connections will be corrected.
The results of the reinspection will be evaluated by engineering to identify potential impacts and to determine if any additional corrective actions are required.
2.
All HVAC mechanical equipment installation packages for air handling unit fans will be reviewed and drawing lists will be corrected as required.
3.
P/K-F craft and inspection personnel will be retrained in the re-quirements of procedure JP 14.2.
The training will emphasize HVAC installation and inspection requirements in the areas of bolting, jam nut and thread engagement, oversized and slotted holes, and dimensional controls.
o Page Three All corrective actions described in this response are expected to be completed by November 1,1986.
Deviation 50-424/86-59-02, 50-425/86-26-02, " Failure To Procure Explo-sion-Proof Fan Motors As Connitted" The original design intent was to provide explosion-proof battery room vacuum exhaust fan motors as indicated in FSAR Sections 9.4.5.2.1 and 9.4.5.5F.
During the design evolution process, engineering determined that explosion-proof motors were not required since the battery rooms are maintained at lower than 2% hydrogen concentration by volume.
How-ever, engineering neglected to request an update to the FSAR to reflect the new design.
Bechtel engineering is currently preparing a FSAR Change Notice for submittal to the project licensing organization.
The change notice is expected to be submitted by September 30, 1986, and will propose that the FSAR be revised to reflect the as-built conditions.
Following receipt of the change notice, Project Licensing will evaluate the re-quested change for impacts to the project's licensing position and safety analysis.
If acceptable, the change notice will be incorporated into an FSAR amendment and submitted to the USNRC for approval.
Cases of failure to update the FSAR in conjunction with design changes were also identified during the Independent Design Review as part of the Vogtle Unit 1 Readiness Review Program.
In response to these
- findings, engineering procedures for the identification and resolution of design changes having impacts on licensing commitments were reviewed and found to be adequate.
Responsible engineering personnel were retrained in the requirements of these procedures.
A followup memorandum reminding project engineering personnel of the importance of following established design change control procedures, and of timely incorporation of changes into the FSAR when required, will be issued by. October 15, 1986.
Georgia Power Company will provide the USNRC with a supplement to this response upon completion of a review of the FSAR Change f?otice by Project Licensing.
The supplemental information will provide the j
final corrective action relative to the battery room vacuum exhaust i
fan motors and is expected to be submitted by October 31, 1986.
Deviation 50-424/86-59-03, 50-425/86-26-03, " Failure To Install Electri-cally Interlocked and Alanned Control Room Doors As Connitted" In the existing design, two sets of doors with a vestibule between, i
acting as an air lock, are provided at each of the entrances to the l
control room and associated spaces.
To minimize leakage, all control l
room access doors are equipped with self-closing devices that shut the doors automatically following the passage of personnel.
The three sets of doors to the control room are monitored by the plant security system and provide controlled access to the control room.
It is not a security L
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Page Four requirement to interlock these doors.
Alarms to annunciate the opening of the doors af ter changeover to emergency operation do not provide additional access control to the control room.
The air exchange rates
_(inleakage and outleakage) considered in the toxic chemical analysis and control room dose analysis were determined ? based on the existing design. Therefore, the as-built condition is considered adequate.
Revision 9 of control building floor plan d'r'5 wing AX1D11A04 showed the two sets 'of doors at the control room entrances to be electrically interlocked and the set of doors at the emergency exit to be locked and alarmed.
Revision 10 of the drawing (issued August 11,1982)- removed the interlock and alann requirements.
The original input for the FSAR was taken primarily from information or, other plants of similar design and then modified to incorporate the specifics of the Vogtle design.
This process failed to recognize that the door interlock and alarm features had been removed from the Vogtle desi,gn.
Bechtel engineering is currently preparing a FSAR Change Notice proposing that FSAR Sections 6.4.2.2.J and 6.4.2.4.E be revised to reflect the as-built conditions.
The change notice will be subject to Project Licensing review and approval as described in the response to Deviation 50-424/86-59-02, 50-425/86-26-02.
Also, any FSAR amendment will require USNRC approval.
Bechtel engineering has ~ initiated a review of selected portions of the FSAR to ensure consistency between the implemented design and that described in the FSAR.
Actions to prevent recurrence are the same as those for the other deviation.
Georgia Power Company expects to inform the USNRC of the final resolution of this deviation and of the results of the FSAR review in r
a supplement to this response by October 31, 1986.
These responses contain no proprietary information1 end may be placed in the USNRC Public Document Room.
Your]truly,.
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b.'O.F t REF/D0F/tdm (Distribution on Page Five)
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U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
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P. D. Rice C. E. Belflower C. C. Garrett (OPC)
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