ML20127F545

Responds to NRC 850221 Ltr Re Violations Noted in Insp Repts 50-424/85-02 & 50-425/85-02.Corrective Actions:Pullman/ Kenith-Fortson Procedures Being Revised to Include Controls Re Drawing Change Distribution

ML20127F545
Person / Time
Site:	Vogtle
Issue date:	03/21/1985
From:	Foster D GEORGIA POWER CO.
To:	Olshinski J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20127F533	List: IR 05000424/1985002 ML20127F545
References
GN-564, NUDOCS 8505200483
Download: ML20127F545 (3)

Text

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Georgia Power Cong,y '

$, Route 2. Bcx 209A Waynesboro. Georgia 30830 Te!ephone 404 55L9961. Ext. 3360 404 7258114. Ext 3360 85 Ma 27 t.- 9

o. o. rost., Georgia Power nd Project d

V ',%5j,*"lge Vogtte Project gg ,

March 21, 1985 United States Nuclear Regulatory Commission Office of Inspection and Enforcement File: X78G10 Region II - Suite 2900 Log: GN-564 101 Marietta Street, Northwest Atlanta, Georgia 30323

Reference:

50-424/85-02, 50-425/85-02 Attention: Mr. John A. Olshinski The Georgia Power Company wishes to submit the following information concerning the violation identified in your inspection report 50-424/85-02 and 50-425/85-02:

Violation 50-424, 425/85-02-01, " Failure to Establish Adequate Measures to Control Drawing Change Distribution" - Severity Level V The violation identified the use of construction aid drawings by craftsmen in the installation of HVAC duct supports which were not the same revision as the corresponding controlled design drawings. An informal program for updating the construction aid drawings was not providi.ng adequate control. Georgia Power Company offers the following response pursuant to the criteria of 10 CFR 2.201:

1. Georgia Power Company acknowledges the violation as identified in the NRC inspection report.

2. Due to the complexity of HVAC design drawings for duct support details, it was considered impractical for craft personnel l to work directly from the design drawings without aid. To i

remedy the situation, Pullman /Kenith-Fortson (P/K-F), the HVAC contractor, developed Work Installation Packages (WIP's) for each support which contained construction aid drawing details and a refereace sheet which identified the applicable design drawings for each aspect of the support installation.

The WIP was not intended to replace the design drawings, but to serve as a convenient construction aid for the craftsmen. Controlled design drawings are available for review by the craftsmen.

8505200483 850405 PDR ADOCK 05000424 G PDR

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Page Two Since the WIP is prepared in advance, it is the responsibility of P/K-F HVAC engineers to review it immediately prior to issuance to the craftsmen to ensure that the latest information is reflected. Upon completion of the support installation, P/K-F engineers again check the WIP to determine if design changes have occurred while the WIP was in the possession of the craftsmen. In the event a design change has occurred which affects the installation, remedial action is initiated to correct the support. The program included no provision to update WIP's for revisions to typical details in . design drawings while the WIP's were in the possession of the craftsmen; however, a design change to a particular support to accomodate specific field conditions is immediately added to the affected WIP upon approval. The specific control s described above are not adequately reflected in P/K-F procedures.

3. A review was conducted of the installation of HVAC duct support DS-A-113120-156, the latest revisions of design drawings AX2D67WO85 and AX2D67WO71, and the -associated WIP, which

.were cited in the NRC inspection report. It was determined that the' changes made in Revision 5 of . the drawings had no impact on the particular details used in the installation of support DS-A-113120-156. Since quality control inspections of HVAC duct support installations are . conducted using the-latest controlled design drawings and do not use the WIP's, no further. remedial actions are considered necessary.

4. To prevent further violations, P/K-F procedures are being revised to include controls to ensure that the latest design information is distributed to and used at the location where the prescribed activity is performed.

5. The corrective actions described in paragraph 4 above are expected to be completed by April 30, 1985. Full compliance with applicable regulatory requirements will be achieved at that time.

This response contains no proprietary infomation and may be placed in the NRC Public Document Room.

Yours ruly,

. IFos'te REF/D0F/tdm

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Page Three Exc: -U. S. Nuclear Regulatory Commission Document. Control Desk Washington, D. C. 20555 R. J. Kelly. J. A. Bailey G. Bockhold R..E. Conway 0. Batum. P. D. Rice-G.-F.' Head H. H. Gregory C. S. McCall-(0PC)

'J. T. Beckham W. T. Nickerson E. L. Blake, Jr.

R. A. Thomas ~ D. R. Al tman .

(Shaw, et. al.)

D.:E. Dutton D. L. Kinnsch (BPC) J. E. Joiner W. F.-Sanders (NRC) J. L. Vota (W)

- (Troutman, et. al . )

R.'.H. Pinson L. T. Gucwa .D. C. Teper (GANE)

B. M.-Guthrie- C. E. Belflower L. Fowler (LEAF):

E. D. Groover- F. B. Marsh (BPC) T. Johnson (ECPG)

R..W. McManus 4

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