A02476, Responds to NRC Re Violations Noted in IE Insp Rept 50-423/82-04.Corrective Actions:Nonconformance & Disposition Rept Issued,Support Plate Accepted as Is & Courses Rescheduled

Responds to NRC Re Violations Noted in IE Insp Rept 50-423/82-04.Corrective Actions:Nonconformance & Disposition Rept Issued,Support Plate Accepted as Is & Courses Rescheduled

ML20054J720
Person / Time
Site:	Millstone
Issue date:	06/07/1982
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20054J713	List: A02476, Responds to NRC Re Violations Noted in IE Insp Rept 50-423/82-04.Corrective Actions:Nonconformance & Disposition Rept Issued,Support Plate Accepted as Is & Courses Rescheduled IR 05000423/1982004
References
A02476, A2476, AEC-MP3-273, NUDOCS 8206290489
Download: ML20054J720 (4)

Text

,

'"* "'

• Selden Street, Berlin, Connecticut N EJ M M M ES 5

22l%"*Z"f"" IMrEnE CONNECTICUT 06101

• 2': ,,'."T310! % " ~ ~ (2m) 666-6911 L L J lr;=Ol'2'.lllC June 7, 1982 Docket No. 50-423, AEC-MP3-273 A02476 U. S. Nuclear Regulatory Commission Mr. R. W. Starostecki, Director Projects Branch #1 Division of Project and Resident Programs Region I Oftice of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406

Reference:

(1) R. W. Starostecki letter to W. G. Counsil, I.E.

Inspection 50-423/82-04, dated May 6, 1982.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 IE Inspection No. 50-423/82-04 On March 1-31, 1982 and April 1-9, 1982, a routine safety inspection of selected areas of Millstone Nuclear Power Station, Unit No. 3 was con-ducted by your Mr. J. C. Mattia. As a result of that inspection, Re-ference (1) was transmitted to us for our response and contained essen-tially two parts: Appendix A, Notice of Violation and IE Inspection Reporr No. 50-423/82-04.

Pursuant to the provisions of 10CFR2.201, Northeast Nuclear Energy Company hereby is submitting a response to the Notice of Violation. The provided format includes a recap of the Appendix A violation followed by the corrective and preventative actions taken or to be taken.

APPENDIX A, ITEM A On March 10, 1982, the RHR pump alignment plates were being leveled by grinding the support plate which is contrary to the requirements speci-fied in Design Drawing EV-52A, Revision 5, and its associated design change E6DCR number F-J-6640. Furthermore, during this grinding the support plate thickness was reduced below the minimum of 1.537 inches allowed by ASTM A6.

8206290489 820622 PDR ADOCK 05000423 O PDR

Corrective Action Nonconformance and Disposition Report number 1236 was issued March 16, 1982 for grinding the support plate beyond the tolerances allowed in ASTM A6. The disposition was to accept as is. The justification was:

"The drawing specifies 1 " through the plate and the reduction of thickness enounts only to 1.23 percent of the thickness. This reduction does not impair the structural integrity of the support structure.

Review of the calculation indicates an-ample factor of safety."

Preventive Action Specification 914 has been changed by Engineering and Design Coordi-nation Report F-P-7758 to allow construction to remove uneven material to produce good surface to surface contact on support structures.

APPENDIX A, ITEM B As of April 1, 1982, the Stone and Webster Field QC Department was not providing indcetrination and continuing education of personnel in ac-cordance with Quality Assurance Procedure No. 2.1, QA Department Continu-ing Education System, Revision A, issued on September 6, 1978. The-following are examples:

(1) Section 5.3 requires that approved CE courses shall be presented in accordance with the monthly forecast, unless changed in writing.

Contrary to this, a total of six CE courses that were scheduled were neither held nor deleted or rescheduled. These are listed below.

Course No. Course Title Month Scheduled 28-JBC-0161 S&W Standard NQA Program 1-74A Dec. 1981 63-J0E-0600 Nonconformance & Disposition Rpt. Nov. 1981 63-JFE-0650 Engineering & Design Coordination Nov. 1981 Report 28-SCF-0050 Principles of Quality Concrete Oct. 1981 28-KEB-0900 Guide to Training Coordinator Jan. 1982 Responsibilities 28-SAG-0080 MS-3 Containment Feb. 1982 l

l I

k_

Corrective Action Stone & Webster agrees that the six courses listed were not changed in writing as required by the procedure. However, these courses were changed via telecon between the site and the Boston office.

Three of the courses had been rescheduled and have been presented. (28-JBC-0161, 63-J0E-0600, 63-JFE-0650)

One course has been rescheduled for presentation in June 1982.

(28-SAG-0080)

Two courses have been recalled for revision. When these courses are revised they will be reviewed for presentation to the Millstone site. (28-SFC-0050, 28-KEB-0900)

Preventive Action In the future, Stone & Webster will comply with the requirements of QAD 2.1.

(2) Section 5.4.1 states that copies of attendance reports shall be kept at the CE presentation location. Contrary to this, three courses were held at the site in October 1981. The attendance reports were not available during this inspection period. The course was presented by someone from the S&W Boston office. The specific courses were as follows:

Course No. Course Name 28-FCE-0030 Magnetic Particle Testing 28-FCE-0020 Liquid Penetrant Testing 28-IEE-0500 Visual Weld Inspection

Response

An Attendance Report for the above courses was prepared by the instructor at the time the courses were presented. The courses were for Nondestructive Testing (NDT) certifications which are presented by the NDT Division from Boston. All NDT Certification Records including Attendance Reports are maintained by that Division in Boston in accordance with the requirements of the Quality Assurance Directive (QAD) 2.5. Attendance Reports are inputed, by the NDI Division, into the IS-228 computer (Computerized Training Records System). A copy of this computer report for Millstone III will be maintained at the site to meet the requirement of QAD 2.1.

s

,n 4

=- ~

1 . .

6 We trust the above information satisfactorily responds to the violations cited by your inspector.

i j Very truly yours,

! NORTHEAST NUCLEAR ENERGY COMPANY i

t i W.' C. Counsil 4

Senior Vice President

! cc: E. J. Brunner 4

t i

i I e l-1 I

i s

i 4

9 i

i 4

f i

i R

4 l

1 e

f i.

- - . _ . _ . . . _ _ . . ~ . _ _ . , _ _ . _ . - - _ _ _ , _ _ _ _ _ _ . _ . _ . , _ _ _ - _ - _ . _ . _ _ , _ . _ , _ . _ . - . . _ _ - . _ , . _ . - - . .._ _ .