ML17055C342
| ML17055C342 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/02/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055C341 | List: |
| References | |
| 50-220-86-07, 50-220-86-7, NUDOCS 8609080180 | |
| Download: ML17055C342 (12) | |
Text
APPENDIX A NOTICE OF VIOLATION Niagara Mohawk Power Company Nine Mile Point Unit No.
1 Docket No.
50-220 License No.
DPR-63 As a result of the inspection conducted on June 2-13,
- 1986, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following viola-tions were identified:
A.
10 CFR 50, Appendix B, Criterion III "Design Control" states in part, that The design control measures shall provide for verifying or checking the adequacy of the design, such as by the performance of design review,
..." and that "...Measures shall also be established for the selection and review for suitability of application of materials, parts...that are essential to the safety-related functions of the...systems Contrary to the above, on June 4,
- 1986, the inspector identified that one part of the safety related ADS Modification (relays wired in series with adjustable resistors) had not been design verified, nor had it been included in the safety evaluation of the modification.
In addition, the inspector identified that the adjustable resistors (ASEA Cat 85245004-332) to be used in conjunction with the S5V AC relays, in the ADS modification, were of insufficient power rating to perform their safety function.
This is a Severity Level IV violation (Supplement I).
B.
Nine Mile Point, Unit 1 Technical Specification 6.8. 1 requires the establish-ment and implementation of written procedures and administrative policies which meet or exceed the requirements and recommendations of section
- 5. 1 of ANSI N18.7-1972.
Section
- 5. 1 of the ANSI N18.7 requires that modifica-tions be designed and performed in accordance with applicable
- codes, basis, design requirements, material specification and inspection requirements.
Contrary to the above, the following activities were not accomplished in accordance with prescribed design requirements:
2.
Drawings for the modification of Emergency Condenser drain piping supports No. 05-SCRI-3, 05-SCRI-6, and 05-SCRI-7 show an addition of a plate welded on both sides in each support using a 2" long fillet weld.
The plates were found to be installed using welds shorter than the specified length by approximately 1/4" to 3/8".
/
Isometric drawing No. C-26843-C (Sheet
- 5) for the modification of Emergency Condenser drain piping specifies the distance between the centerline of EC steam piping No. 39-12-B and the elbow for drain piping No. 39-1-BL as 10", and the distance between the 1" coupling and support No. 39-SR-3 on drain piping No. 39-1-A as 3'-4~".
In-spection of drain piping installations in the above cases indicated the as-built measurements are 1'-0" and 1'-2" respectively.
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Appendix A 3.
Detail "D" of drawing No.
F-39831-C for modification of Emergency Condenser Steam piping anchor 39-Al required the use of A490 bolts between two of the anchor braces and the wall embedded plate.
The connections were installed using a mixture of A325 and A490 bolts.
4.
Administrative Procedure AP-6.0, Section 5.4.3, requires that work on modifications shall not commence prior to the issuance of a Modification Work Request and referenced documentation.
The support for electrical conduit to Hydrogen purge valves No. 201-32, 201.2-03 and 201.2-32 was found to be cut and dismantled from its support to an existing brace on the piping anchor No. 39-Al which required removal.
The removal of the conduit support was performed without a modification work request and required documentation.
- Further, NMPC's guality Assurance Program Topical Report invokes the requirements of ANSI N45.2.5 (1974 Edition) for installation and inspec-tion of structural steel.
Contrary to the above the following activity was not accomplished in accordance with the prescribed inspection requirement:
5.
Paragraph 5.4 of ANSI N 45.2.5 requires that bolts extend at least two threads beyond the face of the nut.
Three of the four anchor bolts installed according to detail "E" of drawing No.
F-39831-C for modification of Steam Condenser anchor 39-A1, were found to have less than the minimum required two threads beyond the face of the nut.
The above citiations are a Severity Level IV violation (Supplement I).
C.
Criterion VI of Appendix B to 10 CFR 50 requires the establishment of measures to control the issuance of documents such as procedures and
- drawings, including changes
- thereto, which prescribe all activities affecting quality. It also requires that these measures assure that documents including changes, are reviewed for adequacy.
Section 6.0 of Nine Mile Point Nuclear Station guality Assurance Program reiterates the same requirements regarding the issuance and review of documents including changes thereto.
Contrary to the above, the drawing for the modification of Emergency Condenser drain piping supports No. 05-SCRI-3 and 05-SCRI-6 inaccurately depicted the existing support-configurations such that installation of the modifications could not be performed as specified on the drawings.
Field design changes were performed to modify the supports without properly processing the changes.
The changes to the modified installations were neither documented nor incorporated in the respective drawings.
This is a Severity Level V violation (Supplement I).
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D.
Criteri,on X of Appendix B to 10 CFR 50 requires the identification of specific hold points in appropriate documents when mandatory inspection hold points which require witnessing or inspection are required.
Section 10.0 of Nine Mile Point Nuclear Station guality Assurance Program reiterates the same requirements for the identification of inspection hold points.
Section 3 '
of the Functional Specification for the Emergency Condenser Modification invokes the requirements of the Structural Welding Code (Dl.1) of the American Welding Society (AWS).
Contrary to the above, hold points were not established, and in-process inspection was not performed for fit-up of structural attachments to base plates for piping supports No; 39-SR2, 39-SR6 and 39-SR7.
The connection of the structural attachments to the base plates required "all-around" welds which made it impossible to perform verification of fit-up between the parts joined after completion of the welds.
Section 3.3 of AWS Dl. 1 welding code requires that the fit-up be inspected prior to completion of the weld.
This is a Severity Level V violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending this response time.
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APPENDIX B LICENSEE STRENGTHS The inspection team noted specific features of the licensee's programs and activities which have been characterized as strengths.
A strength is a
positive attribute or feature which exceeds regulatory requirements, or an innovative feature, which contributes to the safety or effectiveness of plant activities.
A.
Your newly implemented procedures and program for the control of design and modification activities are comprehensive, well thought out, and effective.
Your Technical Support Group's site contacts play an i'mportant role in the coordination and control of modification activities.
The Planning Coordinator and Outage Coordinator are key members of the outage management team and help ensure p'olicies and procedures are followed.
Your newly established program to assign Construction Services Personnel to coordinate contractor work appears to be a valuable and necessary addition to the overall modification control process.
B.
Your gA audits of licensee performed modification activities are compre-hensive and thorough.
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APPENDIX C
LICENSEE WEAKNESSES The inspection team has identified items of concern which have been character-ized as weaknesses.
A weakness does not constitute noncompliance with regulatory requirements, rather it is related to effectiveness of a program, activity or organization that if left uncorrected could lead to problems and/or noncompliance.
A.
Contractor ualit Assurance Several deficiencies were identified during the inspection of the Emergency Condenser piping modifications.
When these deficiencies are viewed collectively, they indicate an apparent weakness in the contractor's quality assurance inspection program.
- Further, examination of NMPC sur-veillance reports of construction activities performed by the contractor indicated that several deficiencies were identified during these inspec-tions and were subsequently corrected by the contractor.
It did not
- appear, however, that the NMPC surveillance program was sufficiently effective in addressing the root cause of these deficiencies to prevent their recurrence.
e B.
Desi n Verification Process The design verification process is not clearly described in the proce-dures.
Specific deficiencies include:
Inadequate guidance specifying when a modification does or does not require a design verification; Inadequate definition of the scope and depth of the design verifica-tion review; Inadequate guidance regarding the types of documents that should be reviewed during the design verification; and, Inadequate definition of what should be included in the design verification report.
C.
Procedure for Modification and Addition Your procedure for Modification and Addition, AP 6.0, has certain weak areas.'hese deficiencies include:
Lack of clarity regarding when SORC approval is required.
The current procedure is ambiguous with regard to the need for SORC approval for the modification final design.
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A "deficiency regarding the interface between corporate and site person-nel.
Currently the procedure specifies that the design organization shall meet with site personnel to review the preliminary design.
Addi-tional corporate site interface measures such as preliminary design installation walkdown to identify possible interferences, and to avoid the need for numerous design change requests would improve this inter-face.
Inadequate specification for placing the necessary marked up drawings in key areas such as the Control Room, Technical Support Center, and the Emergency Offsite Facility, during the interim period from the turnover of the system to the completion of the final updating of the controlled copies of the as-built drawings.
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