ML19341D176
| ML19341D176 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/19/1981 |
| From: | Mcgauphy J MISSISSIPPI POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19341D170 | List: |
| References | |
| AECM-81-36, NUDOCS 8103050058 | |
| Download: ML19341D176 (5) | |
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MISSISSIPPI POWER & LibHT COMPANY Helping Build Alississippi EdhhMade5 P. O. B O X 164 0 J A C K S O N, MIS SIS SIP PI 3 9 2 0 5 y/
2b JA MES P. McGAUGHY, JR.
January 19, 1981 A$$iSTANT VK4 PRESIDENT Office on Inspection & Enforcement U.S. Nuclear Regulatory Commission Region II 101 Marietta Street. N.W.
Suite 3100 Atlanta, Georgia 30303 Attention:
Mr. J. P. O'Reilly, Director
Dear Mr. O'Reilly:
SUBJECT:
Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416/417 File 0260/15525/15526 RII:WHM 50-416/80-27; 50-417/80-17 IE Inspection Report of November 24-26, 1980 AECM-81/36 In response to your letter dated December 24,1980, which transmitted the subject inspection report, we submit our responses to the NRC Severity Level V Violations identified in Appendix "A" of your letter.
In response to Violation Item Number 416/80-27-02,
" Control of Temporary CRD System Pipe Supports," our response is provided in Attachment A.
Our reply to Violation Item Number 416/80-27-03,
" Control of CTO Activities" is given in Attachment B.
On January 14, 1981, Mr. Jack Bryant of your office was con-tacted by Mr. T. E. Reaves of my staff concerning the due date of this inspection report response.
Twenty-five days from the date of the Notice of violation would be Sunday, January 18, 1981.
Mr. Bryant confirmed that when the due date fell on a non-working day, that the response would be due on the next working day.
We find no proprietary data contained in the inspection report.
Yougs tr.uly,,
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Attachment cc:
Mr. N. L. Stampley Mr. Victor Stello, Director Mr. G. B. Taylor Mr. R. B. McGehee Div. of Insp. & Enforcement South Miss. Electric Mr. T. B. conner U.S. Nuclear Reg. Comm.
Power Association Washington, D.C. 20555 P.O. Box 1589 Hattiesburg, MS 39401 Member Middle South Utilities System
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'I MIOZIOCIPPI POWER O LICHT COMPANY
~ Director of Office of Inspection & Enforcement'.
AECM-81/36 Page Two i
STATE OF MISSISSIPPI'
' COUNTY OF HINDS Personnally appeared before me, the undersigned authority in and for the jurisdiction aforesaid, J. P. McGaughy, Jr., who being by me first duly sworn, stated on oath that he signcd the above and foregoing on the day and year therein mentioned, and that the information contained therein is true and correct to the best of his knowledge and belief.
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SWORN TO AND SUBSCRIBED before me, this the 19th day of January, 1981.
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Attachment'A'to AECM-81/36'
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Page 1 of 2 RESPONSE TO VIOLATION NUH3ER 416/80-27-02
" CONTROL OF TEMPORARY CRD SYSTEM PIPE SUPPORTS"
- 1.
Admission Or Denial Of The Alleged Violation Mississippi' Power 6-Light concurs with the violation with the
=following clarification.
Mississippi Power & Light was inves-tigating the RCI problem and had issued a nonconformance on August-14, 1980 for Bechtel'to conduct further investigations prior to the original Unresolved Item 50-416f 80-19-01 being issued on August 15, 1980.
These investigations have identi-fied the severity of the problem which reclassified this item as a violation.
2.
The Reason For The Violation The cause has been determined to be an inadequate Quality Assurance program and the lack of proper implementation by the Middle South Energy contractor, Reactor Controls, Inc. (RCI).
Site inspections and a home office audit by our agent, Bechtel, of RCI determined that both design activities and installation acti-vities were being performed in noncompliance with 10CFR50, Appendix B.
3.
Corrective Steps Taken and Results Achieved Upon notification of a noncompliance issued against Reactor Controls Inc. at another site, MP&L issued Corrective Action Request (CAR) 272 on August 14,1980, to Bechtel.
CAR 272 requested Bechtel to investigate and-determine if existing supports were in conformance with design drawings and to determine the adequacy of the support design.
Bechtel immediately performed an audit and determined the supports deviated from approved and issued design drawings.
On August 15, 1980, Bechtel issued Quality Action Request (QAR) F-210 addressing this condition. This activity was concurrent with NRC Inspection 50-416/80-19 conducted August 12-15, 1980.
During this NRC Inspection, two supports were noted which did not meet all the drawing requirements (Unresolved Item 80-19-01).
RCI maintained these supports were temporary.
Bechtel's QAR F-210 identified supports which deviated from approved drawings and requested details on RCI's program which permitted deviations to approved drawings.
Bechtel also issued a Stop Work on August 15, 1980 until these concerns could be resolved.
The investigation for QAR F-210 revealed that the RCI Quality Assurance Program did not provide a mechanism to deviate from approved drawings.
On September 12, 1980, MP&L notified the NRC of a Potentially Reportable Deficiency (PRD-80/56) concerning this problem. The investigation also noted that RCI's QA Program did not addre:
the control of temporary materials.
RCI revised their QA Manuai to include provisions for design changes in the field and control of temporary materials. This manual revision has been
. approved by Bechtel.
However, approval by RCI's Authorized Inspection Agency is still pending.
1
.1
Attachment A to AECM-81/36
?o Page 2 of 2
,f.
Bechtel performed an audit of RC1's design organization to verify the design adequacy of the supports as requested by MP&L's CAR 272.
RCI was unable to provide objective evidence that they had obtained design approvals for issued support drawings. The NRC was notified of this condition on feptember 25,1980 (PRD-80/60).
Bechtel Quality Assurance issued Stop Work #23 until design adequacy could be verified.
RCI has completed an inspection of all "Q" pipe supports and identi-fied all noncompliances to existing drawings.
RCI is presently eval-uating the noncompliances for effect on plant safety.
RCI is presently demobilized at the site until the above noted design verification problem is resolved.
Bechtel had scheduled a reaudit of RCI for January 12-15, 1981, to perform an extensive evaluation and verification of the design adequacy. This audit was postponed, at the request of the NRC Region III, to permit Region III to conduct an inspection of RCI, Inc.
Home Office activities.
Due to the RCI demobilization at the site, further corrective actions to identify temporary material and implement the corrective actions required for installed supports will be resumed only after the design verification problem is corrected.
4.
Corrective Steps Taken To Avoid Further Noncomp'iance The RCI Quality Assurance Program has been revitud to address the control of temporary installations. The RCI QA Program has also been revised to include a method to make field required corrections to supports by use of an Engineering Change Notice (ECN).
The ECN's are controlled and incorporated into the design drawings.
An inspec-tion of all "Q" supports has been completed to identify nonconforming supports.
A Stop Work will remain in effect until the adequacy of the design has been verified.
5.
Date To Achieve Full Conpliance Full compliance has been obtained at this time, since RCI has revised its QA Program to control all temporary installations.
The Stop Work is in effect until the above noted problems are resolved.
Supports that are nonconforming have been documented.
Future work will be in accordance with the revised QA Program including the iden-tification of all temporary installations.
I
1 Attachment B to AECM-81/36 g
Page 1 of 1 A
4 RESPONSE TO VIOLATION NUMBER 416/80-27-03
" CONTROL OF CTO ACTIVITIES" 1.
Admission or Denial of The Alleged Violation MP&L concurs with the violation, which stated that craft personnel were attempting to replace the limit switch housing cover having bent hinges, prior to notification of the CTO Engineer and documentation of the nonconforming condition.
2.
Reason For The Violation The cause has been determined to be insufficient training of CTO personnel, including the craft personnel,as to the requirements for reporting and processing of problems, deficiencies, or potential problems.
3.
Corrective Steps Taken Ac.d Results Achieved Startup Field Report (SFR) SFR-1-M-997 and Condition Report (CR) #5164 were issued to document and obtain resolution to the nonconforming condition.
4.
Corrective Steps Taken To Avoid Further Noncompliance Interoffice Memorandum FS-MI-80/0174 was issued 12/2/80 by the Constructor, reinstructing all CTO engineers and craft personnel in the proper actions to take when problems and deficiencies are encountered.
Reinstruction on the subject memorandum was documented by the signing of a training sheet by each CTO engineer and craft personnel. To provide additional assurance that the training was effective, followup training sessions were conducted on January 14-15, 1981 to emphasize the process by which nonconforming items must be processed. Attendence rosters are on file documenting the additional training for all CTO tugi-neers and craft personnel in attendance on the days training was administered. All absent personnel have been or will be trained in these requirements prior to resuming their duties.
5.
Date To Achieve Full Compliance Full compliance has been obtained at this time.
SFR-1-M-997 and CR #5164 will remain open pending receipt, installation and acceptance of a new limit switch housing cover in accor-dance with existing procedures.