ML20080J257

Responds to NRC Re Violations Noted in IE Insp Repts 50-424/83-21 & 50-425/83-21.Corrective Actions: Drawing Change Notice Issued to Correct Thermal Movement Data for Pipe Support V1-1204-199-H008,Rev 1

ML20080J257
Person / Time
Site:	Vogtle
Issue date:	01/16/1984
From:	Foster D GEORGIA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20080J241	List: ML20080J257
References
GN-304, NUDOCS 8402140498
Download: ML20080J257 (3)

Text

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Georgia Power Company 'A

. 333 Piecmont Avenue

. Atlanta. Georgia 30308

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- Telephone 404 526-7726 '

q a :- pt-Ma;Iing Address:

. Post Office Box 4545 At!anta, Gt ;gia 30302 h 0.; ';M 17 A 9 : 12 Georgia Power D. O. Foster the southern eutnc system Vice President and General Manager k,;tle Project January 16, 1984 United States Nuclear Regulatory Commission File: X78G10 Office of Inspection and Enforcement Log: GN-304 Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303

Reference:

50-424/83-21,50-425/83-21 Attention: Mr. R. C. Lewis Gentlemen:

The Georgia Power Company wishes to submit the following information concerning the violation discussed in your inspection report 50-424/83-21 and 50-425/83-21:

Violation 50-424/83-21-01, " Inadequate Design Control for Hanger Vl-1204-199-H008, Rev.1" - Severity Level -IV.

- (l) Georgia Power Company acknowledges the discrepancies identified in the violation (2) Thermal movements specified on the design drawing are incorrect. The thermal movements specified on the design drawing for pipe support

.Vl-1204-199-H008, Rev.1, were based on a preliminary stress analysis using a design temperature of 650 F. After piping layout was com-pleted for all intermediate lines in the safety injection system, it was determined that a maximum operating condition temperature of 170 F should be used for the analysis. A reanalysis using the lower temper-ature was completed on 11/29/83, however; it is the Project's policy not to require revisions to pipe support drawings solely for the purpose of making changes to the thermal movements and any movements less than 1" do not need to be identified. Therefore, a revision to update the thermal movements of pipe support Vl-1204-199-H008, Rev.1, was not immediately made since a change to the hardware did not occur.

(3) The following corrective actions have been taken:

a. A representative sample of other pipe support drawings with thermal movements was reviewed. The design was found to be adequate in all cases, therefore; the discrepancy in the drawing for pipe support Vl-1204-199-H008, Rev.1, is considered to be an isolated Case.

b. -A Drawing Change Notice (DCN) has been issued to correct the thermal movement data for pipe support Vl-1204-199-H008, Rev. 1.

8402140498 840126 PDR ADOCK 05000424 h PDR

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l United States Nuclear Regulatory Commission January--16, 1984 Page 2 (4) To prevent' recurrence of discrepancies between thermal movement data and physical layout, the Bechtel Power Corporation Project Field Engineer has been instructed to review pipe support drawings for discrepancies of the type identified in the violation prior to support ins 6allation.

(5) All corrective actions will be completed and full compliance with applicable requirements will be achieved by January 20, 1984.

Violation 50-424/83-21-02, " Failure to Follow Procedures for Hanger Inspection" -

Severity Level V.

(1) Georgia Power Company acknowledges the violation and all but one of the specific discrepancies identified in the inspection report.

(2) The violation occurred for the following reasons:

a. The discrepancies regarding are strikes and undercuts in the installation of pipe hangers Vl-1202-134-H016, Rev. 3; Vl-1217-235-H001, Rev. 2; Vl-1592-054-H084, Rev. 2; and V1-1901-102-H019, Rev. 3 are due to failure to incorporate revisions to the inspection criteria in construction specification X4AZ01 into the Pullman Power Products procedure for hanger inspection.

b. The discrepancies involving marking requirements of salvaged miscellaneous steel in pipe hangers V1-1202-134-H016, Rev. 3, and Vl-1217-235-H001, Rev.2, are due to inadequate training of inspection personnel.

c. In the case of the pipe not being dead weighted on hanger V1-1217-235-H001, Rev. 2, inspection records show that the pipe was dead weighted on the hanger with no clearance gap at the time of final inspection.

The 3" line supported by hanger V1-1217-235-H001, Rev. 2, was attached to a 12" trunk line which was not permanently supported. Subsequent

-moving of the 12" line during construction activities apparently caused the 3/32" clearance gap.

d. In the case of misalignment of a tube steel weld with the centerline of the embedded plate used in the installation of hanger V1-1901-102-H019, Rev. 3, Georgia Power Company denies that inspection requirements have been violated. Section P.5.6.4-I of construction specification X4AZ01 states that when pipe supports are shown on pipe support assembly drawings by centerline reference only, they should be considered to be

" nominally" centered. Section P.5.6.4-K of the specification states that support steel may be attached anywhere on embedded plates within certain restrictions which are included in that specification section.

- The support member in question was installed in accordance with these requirements and within applicable restrictions. The fact that the centerline of the support member is drawn in alignment with the center =

line of the embed plate in drawing Vl-1901-102-H019, Rev. 3, is

. coincidental.

(3) ~The following remedial actions will be taken relative to the reasons given above:

T United States Nuclear Regulatory Connission January 16,.1984' Page 3

a. Nonconformance Reports will be written to identify and resolve all the specific discrepancies (arc strikes, undercut, material marking)

~. identified with the pipe hangers previously mentioned in this-response.

Pullman Power. Products procedure IX-50 for hanger inspaction will be revised.to agree with inspection criteria-in construction specification X4AZ01. Specifically the revision will allow the cumulative length

-of-1/16" undercut for not more than 50% of the total weld and arc strikes will be allowed if properly blended into surrounding material.

b. .The Pullman Power Products procedure for materials identification will be. revised to require that color-coding be used to distinguish between

'ASME and AISC salvaged miscellaneous steel and other material in lieu of uniquely marking each individual piece. Unique identification of individual-pieces is not necessary to meet ASME Boiler and Pressure Vessel Code requirements.

c. Pullman Power. Products procedure X-19 for system close-out will be revised to require a second_ verification of pipe clearances during sub-system

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walkdown prior to system turnover to ensure that clearances have not been adversely affected by pipe movement during construction activities

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subsequent to final QC acceptance.

(4):=Inadditiontotheprocedurerevisionslistedabove,all-QCinspectionpersonnel involved with piping systems will be trained to the new procedure requirements.

This training and proper implementation of revised procedures.should prevent

.the recurrence'of discrepanceis of the type identified in the violation.

(5) . All corrective actions will be completed and full compliance with applicable requirements will be achieved by March 30, 1984.

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

Your trul ,

. O. Fos er '

. . DOF/REF/cc xc: U. S. Nuclear Regulatory Commission ,

Attn: Victor J. 3tello, Jr., Director Office of Inspection'and Enforcement

. Washington, D. C. .20555 xc: R. J. Kelly 'D. E. Dutton J. A. Bailey L. T. Gucwa

R. E. Conway. W. F. Sanders 0. Batum' M. Malcom G. F. Head R. H. Pinson H. H. Gregory, III G. Bockhold J. T. Beckham B. M. Guthrie C. W. Hayes P. D. Rice J. L. Vota

D. N. MacLemore R.-A. Thomas E. D. Groover-i e, - . ~n - _

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