ML20133B111

Suppls Response to Violations Noted in Insp Repts 50-424/85-36 & 50-425/85-36.Corrective Actions:Procedure IX-50, Pipe Support Field Installation & Fabrication, Revised & Sample Reinsp Program Completed

ML20133B111
Person / Time
Site:	Vogtle
Issue date:	09/20/1985
From:	Foster D GEORGIA POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
GN-707, NUDOCS 8510030025
Download: ML20133B111 (3)

Text

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E Georg;a Power Corppany Route 2. Bct 099A Waynesboro. Georg a 30830 Telephone 404 554-9961. Eit. 3360 404 724 8114. Est 33GO 7

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,, A. gg ,.gm DreIe7 September 20, 1985 United States Nuclear Regulatory Connission File: X7BG10 Office of Inspection and Enforcement Log: GN-707 Region II - Suite 2900 101 Marietta Street, Northwest Atlanta, Georgia 30323

Reference:

50-424/85-36, 50-425/85-36 Attention: Mr. J. Nelson Grace The Georgia Power Company wishes to submit the following supplemental information to our response (GN-571, dated April 2, 1985) to USNRC Inspection Re 50-424, 425/84-36, and to our letters of June 14, 1985 (GN-641)and portAugust 28, 1985 (GN-697) on the same subject.

Violation 50-424, 425/84-36-03 identffled a failure in Pullman Power' Products (PPP) procedures to provide or reference required manufacturer instructions for the installation of spring hangers and pipe clamps. As a result, PPP personnel installed and inspected pipe support components without details of. the manufacturer's ' instructions.

In its original response (GN-571), Georgia Power Company (GPC) indicated that PPP procedure IX-50, " Pipe Support Field ' Installation and Fabrication", would be revised to include appropriate installation and inspection information from manufacturer instructions and that a sampling s

program would be established to detennine the acceptability of previously installed pipe supports requiring the use of manufacturer instructions.

Revisions to procedure IX-50 were completed and issued on April 1,1985.

The sample . reinspection program has also been completed and the results are summarized below.

1. The population of pipe supports (requiring the use of manufacturer

. instructions) installed and inspected prior to the correction of PPP's procedure were identified and listed. The list consisted of approximately 3300 supports.

2. Using standard statistical sampling techniques designed to provide a representative sample of the entire population, fifty-nine supports were randomly selected from the list for reinspection. As indicated in our letter of August 28, 1985 (GN-697), this random sample resulted in a larger than expected number of non-safety-related supports. In order to obtain the most accurate repr%entation of PPP's quality control' program, additional random samples were taken of safety-related supports and the non-safety-related supports were' thrown out of the sanple for reinspection.

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3. Pullman Power Products quality control inspection personnel reinspected the fif ty-nine supports in the sample against the criteria of the new revision of PPP procedure IX-50.

4. Of the fifty-nine supports reinspected, only four (slightly less than 7%) contain discrepancies which could be attributed to either inadequate procedural information or inspection error; however, additional discrepancies were found in twenty-one of the fifty-nine supports which are attributable to unauthorized disassembly or tampering subsequent to inspection and acceptance by PPP inspectors.

5. All discrepancies identified-during the reinspection were documented in Deviation Reports to ensure they are brought into compliance with procedural requirements.

Unauthorized disassembly was determined; to be the primary cause of discrepancies identified in NRC Violation 50-424/85-12-01 (Reference GPC's response dated May 7, 1985; GN-601). The results of the reinspection described above reinforces the need for a complete reinspection of safety-related pipe supports utilizing non-welded fasteners upon construction completion. It was concluded, however, that PPP's QC inspection program provides reasonable assurance of pipe support quality apart from unauthorized disassembly.

To ensure the quality .of pipe supports prior to plant operation, the following actions have been taken:

1. ' Pullman Power Products has been directed to develop a program to provide for a complete reinspection of . safety-related pipe supports subject to unauthorized disassembly or alteration upon completion of construction activities and to incorporate the program into appropriate procedures.

2. Pullman Power Products has also been directed to revise their pipe support installation acceptance procedure to include the use of torque-seal paint (or an equivalent) by their inspection personnel as visable evidence of final inspection of nuts, locknuts, and similar fasteners. . This marking .will assist in controlling and detecting unauthorized disassembly or alteration of the fasteners.

It is Georgia Power Company's policy to take disciplinary action against any individual who disassemblies or alters any permanent-plant item without authorization. In the area of pipe supports, Georgia Power Company endorses disciplinary actions taken by Pullman Power Products in any situation where sufficient evidence exists to identify the individual (s) involved.

This response, which completes our actions relative to NRC Inspection Report 50-424, 425/84-36, contains no proprietary information and may be placed in the NRC Public Document Room.

Your truly D.' . Foster:  ;

REF/DOF/tdm

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.Paga Thre2 xc: U. S. Nuclear Regulatory Commission Document Contr31 Desk Washington, I,.C. 20555 R. J. Kelly -J. A. Bailey G. Bockhold R. E. Conwny O. Batum P. D. Rice G. F. Head . H. H. Gregory C. S. McCall (OPC)

J. T. Beckham W. T. Nickerson E. L. Blake, Jr.

R. A. Thomas D. R. Altman (Shaw, et. al.)

.D. E. Dutton D. L. Kinnsch (BPC) J. E. Joiner Sr. Resident-(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 G. A. McCarley

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