ML20053D765
| ML20053D765 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/12/1982 |
| From: | Dise D NIAGARA MOHAWK POWER CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20053D758 | List: |
| References | |
| NMP-4390, NUDOCS 8206070298 | |
| Download: ML20053D765 (3) | |
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M Y NIAGARA RuMOHAWK upp_4390 NIAGARA MOHAWK POWER CORPORATION /300 ER:E BOUlVARD WEST SYRACUSE, N Y.13202/ TELEPHONE (315) 4741511 kkty 12, 1982 l
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bl1. Thomas T. Martin, Director Division of Enginecrbtg and Teclutical Programs United States Nuetear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Re: Docket No. 50-220 l
Inspection Report No. 82-03 l
Dear tit. Martin i
1 Thu refers to the routine safety irtspection conducted by bit. G. Meyer t
I of your of fice on [Ltrch 1-5, 1982, of activities authorized by NRC Licertse No. OPR-63 and to.the discussions of your findings held by bit. Meyer with bit. T. Roman of our staf f a,t the conciasion of the inspection.
ITE51 A 10 CFR 50, Appendix B, Criterion XVI, states, "bleasures shall be established to assure that conditions adverse to quality, l
such as... nonconformances, are promptly identified and j
corrected."
The Quality Assurance program, as implemented in FSAR, Thir-l teenth Supplement, paragraph 16.2, states, " Conditions adverse
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to quality, such as deviations, nonconformances,..., etc.,
are to be identified and appropriate corrective action is to be taken in accordance with established procedures."
Contrary to the above, the required corrective action programs did not ensure effective corrective action to licensee identified problems in the implementation of maintenance, as evidenced by the following examples:
Step 5.6.10 of APN-13, " Procedure for Control of Station Corrective Repair and h!aintenance", Rev. 1, blarch 10, 1980, specifies that Work Request (WR) forms shall have Quality Control (QC) verification signatures.
Licensee Audit Report 80-19 dated December 1980 identified three examples of WR's with no QC verification signatures. On blarch S, 1982, this condition adverse to quality was uncorrected in that WR 5331 dated blarch 14, 1981, did not have the re-quired verification signature.
l 8206070298 820601 PDR ADOCK 05000220 Q
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IR 82 Procedure APN-13 step 5.6.8 specifies that WR's are to indicate whether or not an operability test is required.
Licensee Audit Report 80-19 dated December l
1980 identified thirteen examples of WR's which had no indication of whether or not an operability test was required.
On March 4, 1982, this condition adverse j.
to quality was uncorrected in that nine exampics of similar nonconformances in a sampic of sixteen WR's completed in 1981, and sixteen similar nonconformances in a sample of 20 WR's completed in 1982, were identi-fled.
Step 5.6.11 of APN-13 specifies that the Station Shift Supervisor (SSS) must sign on the WR that the repaired equipment is accepted for service prior to placing the l
equipment back in operation.
Licensee Audit Report 80-19 dated December, 1980, identified seven examples of WR's on which the repaired equipment was put back into service 4
prior to or without the verification signature of the SSS.
On March 4, 1982, this condition adverse to. quality was uncorrected in that on WR 17109 dated November 20, 1981, the safety-related equipment was placed back into service on November 21, 1981, without the required SSS-signoff on the WR.
The signoff was not donc until December 9,1981.
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RESPONSE
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Tite Niagara Maltawk Power Corporation's Quality Asswtance Program, as implemented in e.ccordance toi. tit the FSAR, Titirteetttit Supplement,Section XVI,-
is.in full compliance taltit 10 CFR 50, Appendix 8, Crlterion XVI. Tite TItirteentit Supplement to Final Safety Analysis Report section 16.3 states:
"Malfunetions, deficiencies, or nonconformances are reported in accordance witit procedures. Tite mecitanies for implemertting tite deficiency and cortective action system are tite responsibiLLty of tite Quality Assurance Ocpartneutt.
TItis implementation is accomptisited by means of establisited procedures witicit require:
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(a) That tite reported condition is identified and evaluated with regard to the need for corteetive action.
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(b) That the cause of the condition is determined and that ptompt cortective action is implemented.
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(c) That determination of cortective action is made by cog-nizant and responsible personnel.
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Page 3 1R 82-03 (d)
That follow-up action is taken to provide implementation, verification, and closure of de documentation by be apptopsiate Quality Assurance Department Supervisory pet-sonnci.
In compliance with the FSAR de Quallty Assurance Departnertt follows QA Procedure 16.40.
The scope of QA Procedure 16.40 is:
"This procedure delineates ne cortective action systems used by de Quali.ty Assurance Departmertt for reporting and following up on quality-related ptoblems."
In accordance with QA Procedure 16.40, ne Niagara Mohawk Powet Corpora-tion's response to the Work Request nonconformance was obtained. When n e response date uns passed, QA Department initiated section 5.4.3 (Unacceptable or Delinquent Responses). Titis resulted in an escatalwn, which was to inform de Vice President of Nuetcar Generation.
The result of he escalation nzo uat Niagara Mohawk Power Corporation aus able to establish he completion date of. lane 1,1982, for corrective action. The corteetive action will be to revise APN-13 including ue estab-lishment of an independertt inspection group.
Upon issuance of he revised ptocedure, Niagara Mohawk Power Corporation will train affected station per-sonnci in de revised ptocedure.
Vert) truly yours Niagara Mohawk Power Corporation tb D. P. Dis e Vice President Engineering SG/jm b
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