ML20214P832

Describes Evolutionary Changes Implemented in Field Change Request/Authorization to Continue Work (Fcr/Atcw) Program, Per 830602 Request.Stated Changes Have Enhanced & Streamlined Subj Program

ML20214P832
Person / Time
Site:	Vogtle
Issue date:	05/21/1987
From:	Rice P GEORGIA POWER CO.
To:	Grace J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GN-1370, NUDOCS 8706040074
Download: ML20214P832 (3)

Text

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d Georgia Fo*er Company Pbst Offica Box 282

Waynestero. Georgta 30830 Telephone 404 554 9961. Extension 3413 404 724-8F4. Extension 3413 m

' P. D. R6ce Georgia' Power

%ce President

. Vogtle Project the southern ekrtre system May 21, 1987 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Attention: J. Nelson Grace File: X7BF08 X7BC06 Log: GN-1370

Reference:

Docket Numbers 50-424'and 50-425 Gentlemen:

On March 2, 1983, Georgia Power Company ' presented to the -USNRC a ~ proposed modification to the Field Change Request (FCR) system which would allow work to continue on minor' changes prior to full engineering ' review and approval by utilization of the Authorization to Continue Work (ATCW) Program. GPC requested NRC approval of the .,

j ATCW Program in a letter, dated May 4, 1983. On June 2, t 1983, the NRC approved the program and requested to be informed by GPC of substantive changes that might' be initiated. Subsequently, on July 5, 1984 and July 25, 1984, GPC notified the NRC of enhancements to the ATCW .

Program. ,

Commensurate with the NRC's request to be informed 11 of substantive changes to the ATCW Program,- GPC wishes

to bring to your attention three evolutionary changes l which have been implemented in our FCR/ATCW Program. Noted I

below are descriptions of the program changes and accompanying justification statements. -

l (1) In our May 4, 1983 letter, we stated, " Quality Assurance will audit the ATCW process on a regular basis and GPC Construction Field Operations and Quality Control will

. perform a joint bi-monthly review of ATCW's to ensure p compliance." ,

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United Statee Nuclear Regulatory Commission

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May 21, 1987 Page'Two.

While QA continues to conduct periodic audits of the 'ATCW process the bi-monthly review of ATCW's by..GPC Construction Field Operations and Quality Control..has been discontinued. The bi-monthly reviews that were conducted showed. that the program was being implemented consistent with the program requirements.

No significant problems associated with the use of

'ATCW's were identified during these reviews. With the . program , functioning- properly over a period of time, it was determined that the bi-monthly review was no longer needed.

(2) In our July 25, 1984 letter, we noted that ATCW/FCR approval would be processed within the same time

,' limit as any other FCR. The required approval time was five working days with a provision allowing j engineering to submit an interim response if the five

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working day. time limit could not be met.

The response time for approval (or rejection) of ATCW/FCR s has been revised to establish a target date ~ of five working - days upon receipt of ATCW/FCR's required to support system turnover. For ATCW/FCR's not required for system turnover, but requiring home T office interface, a target' date of ten working days from date .of receipt -is established. The . ATCW/FCR response time was revised to be more in line with 4, the actual time needed to facilitate a comprehensive

t" review.

.(3) The original ATCW Program prohibited revising ATCW's.

This provision was initially instituted to ensure proper document control. With widespread familiarity of the , program by appropriate Engineering, Quality Control, and contractor personnel, and combined with ongoing QA surveillance and audits of the ATCW Program, we have concluded that the prohibition against revising

/ATCW's was no longer needed.

S. Therefore, to enhance the efficiency of the ATCW

@.. / -

Program, we have recently implemented provisions

• for revising ATCW.'s. The Project Reference Manual

, requires subsequent revisions to ATCW's to be made by authorized design engineers (FPFE). The revision y may be made prior to final approval of the ATCW/FCR by incorporating the change (s) on the original ATCW/FCR y

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Unitcd Stetos Nuclear Regulatory Commission May 21, 1987 Page Three i

form. The FPFE making the change initials and dates the change. A new yellow (field use) copy of the revised original, stamped "0RIGINAL" with red ink, is exchanged for the original copy. The original yellow copy is then destroyed by the FPFE. In-process inspection may be performed to the approved ATCW (including revised ATCW's). Final acceptance of the requested change will be based on the final inspection and subsequent approved FCR.

The changes to the ATCW Program noted above have enhanced and streamlined an ef fective program. If further substantive changes to the ATCW Program occur, GPC will inform the NRC.

Should you have questions concerning these program changes, please advise.

Sincerely,

_S " '

P. D. Rice Vice President and Project Director i

GAM /PDR/sih xc: USNRC - Region II Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 H. G. Baker J. A. Bailey R. W. McManus J. P. O'Reilly G. Bockhold G. A. McCarley R. E. Conway C. E. Belflower Sr. Resident (NRC)

R. H. Pinson J. F. D'Amico C. C. Garrett (OPC)

E. D. Groover D. Feig (GANE) J. E. Joiner (TSLA)

W. D. Drinkard L. T. Gucwa NORMS D. R. Altman C. W. Hayes-

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