View source for ELV-00830, Responds to Violations Noted in Insp Repts 50-424/89-20 & 50-425/89-24.Corrective Actions:All Open Reas Reviewed & REA-7604 Closed & New Rea Generated to Initiate Engineering Documentation & FSAR Changes

{{Adams
| number = ML20246G886
| issue date = 08/24/1989
| title = Responds to Violations Noted in Insp Repts 50-424/89-20 & 50-425/89-24.Corrective Actions:All Open Reas Reviewed & REA-7604 Closed & New Rea Generated to Initiate Engineering Documentation & FSAR Changes
| author name = Hairston W
| author affiliation = GEORGIA POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000424, 05000425
| license number = 
| contact person = 
| document report number = ELV-00830, ELV-830, NUDOCS 8909010032
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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l-\GeoqpS Ppwer Compary .
313 Piedrnont Avenue '
4~,            Atlanta Georgia 30308'
                                               ,Telephore 404 G26 319$ .
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                                              'Mmhng Addrew i                                          ' 40 inverness corner Parkway '
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                                            ' Bstrningharn. Alabama 35201' Telephore 205 868 55B1 y                                                                                 !% ;dnern nectia .<areni' W. G. Hairston, til Senior Vcc Preuden:
                                           - Nuclear Operabors ELV-00830 l                                                                                    August 24h1989                   1616n i
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                                        ' Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN:' Document Control Desk.
                                        ' Washington, D. C. 20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT REPLY'TO A' NOTICE ~0F' VIOLATION Pursuant to 10 CFR 2,201, Georgia Power Company (GPC) submits' the enclosed infomation_ in' response to Inspection Report 50-424/89-20 and 50-425/89-24,
                                         'which concerns;the inspection conducted by C. Smith of the NRC Region = II
                                        - office' from June 26-30,1989. In the enclosure,-transcription of the violation precedes GPC's response.
Please contact' this office if you have arty questions.
Sincerely, tsl.) lA W. G. Hairston, III WGH,'III/JH/gm

==Enclosure:==

        ,                                            - Violation 50-424/89-20-01, 50-425/89-24-01 and GPC Response c(w): Georgia ~ Power' Company Mr. G. K. McCoy Mr. G. Bockhold, Jr.
Mr. P. D. Rushton NORMS U. S. Nuclear Regulatory Commission Mr. 5. D. Ebneter. Pq1onal Administrator
                                                        . Mr. J. B. Hopkins, Licensing Project Manager, NRR Mr. J. F. Rogge, Senior Resident Inspector, Vogtle i I 8909010032 890824 u i _ ] $R_ ADDCK_0500 $ 4

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             ~
y ENCLOSURE V0GTLE ELECTRIC GENERATING PLANT REPLY ~TO A' NOTICE'0F VIOLATION l
NRC NOTICE OF' VIOLATION 50-424/89-20-01' AND' 50-425/89-24-01 l
                                   "10 CFR SC, Appendix B, Criterion XVI, requires that measures shall be I                                  established to assure that conditions adverse to quality, such as deficiencies, deviations, defective material 'and equipment, and nonconfonnances are promptly identified and corrected. In the case of
: l.                                 significant conditions adverse to quality the measures shall assure that the 1:                                 cause of the condition is _ determined and corrective action taken to preclude L                                  repetition. The identification of the significant condition adverse to L                                  quality, the cause of the condition, and the corretive action taken shall be documented and reported to the appropriate levels'of management. -
1 Contrary to the above, on October 14, 1987, the responsible engineer initiated REA-7604 to address the acceptability of 14 oversized penetration seals installed without subdividers as required by design test data. The ev&1uator was requested to determine if the oversized penetration seals were capable of providing the minimum three hour fire rating as required by the FSAR and to
                                  -make appropriate changes to the FSAR if necessary. No action had been taken to address the concerns of REA-7604 'at the time of the inspection.
L This is a Severity Level IV violation (Supplement 1)."
RESPONSE.TO' VIOLATION 50-424/89-20-01 ' AND' 50-425/89-24-01 l
                                  - Admission' or Denia''of' A11eged' Violation The violation occurred as stated. However, documentation attached to REA-7604 verified the acceptability of this type of penetratun seal : configuration.
Therefore, a condition adverse to quality did not exist. This violation consisted of a failure to document Engineering concurrence with this seal configuration and failure to amend the FSAR to show the use of this configuration.
Reason For The Violation The _cause of this violation was personnel error. In October 1987, during the      ;
approval cycle of REA-7604, Yogtle Unit One was responding to the 1986 Appendix R Pre-Fuel Load Audit. During the audit response, this penetration seal configuration was discussed with NRC personnel and technical issues concerning fire rating were resolved at that time. The REA was not processed since the issues contained in the REA were felt to have been completely addressed. This assumption was in error. Two actions remained and were overlooked since this REA was not processed. The first action overlooked was to document Engineering concurrence with the configuration used. This configuration was accepted by Nuclear Mutual Limited (NML), Georgia Power's Corporate Risk Management Group and the responsible installation contractor          ,
(ICMS). However, no Engineering documentation was placed on file to this            j effect. The second action overlooked was to amend the FSAR to show the use of       !
this configuration.                                                                  l 1
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L                                              ENCLOSURE (CONTINUED)
V0GTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE'0F VIOLATION Corrective Steps'Which Have Been Taken and the Results Achieved
: 1. All open REA's were reviewed for similiar conditions. The review itinicated this was an isolated case.
: 2. REA-7604 was closed and a new REA generated to initiate the Engineering documentation and FSAR changes.
Corrective Steps Which Will Be Taken to Avoid Further Violations 1-    The penetratica seal configuration in question will be evaluated by Engineering, t.1uired documentation generated, and the documentation associated C .n this evaluation will be maintained on file.
: 2. After completion of the evaluation, changes to the FSAR will be initiated to reflect correct penetration seal configuration.
: 3. REA's are being reviewed and will continue to be reviewed periodically by Plant Engineering Support to ensure appropriate action is being taken.
Date' When Full Compliance Will Be Achieved Full compliance will be achieved for number one and two by September 29, 1989.
Number three has been initiated and will be an ongoing effort.
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