ML20054L005

Responds to NRC Re Violations Noted in IE Insp Rept 50-410/82-03.Corrective Actions:Training Program Detailing Responsibilities in Completing Field Requisitions Conducted

ML20054L005
Person / Time
Site:	Nine Mile Point
Issue date:	06/18/1982
From:	Rhode G NIAGARA MOHAWK POWER CORP.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20054L004	List: IR 05000410/1982003 ML20054L005
References
NUDOCS 8207070059
Download: ML20054L005 (4)

Text

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Lv Y NIAGARA n uMOHAWK NIAGARA MOHAWK POWER CORPORAT10N/300 ERIE BOULEVARD WEST, SYRACUSE, N Y.13202/ TELEPHONE (315) 4741511 June 18,1982 U.S. Nuclear Regulatory Comission Region I Attention: fir. R. W. Starostecki, Director Division of Project and Resident Prograns 631 Park Avenue King of Prussia, Pennsylvania 19406 Re: Nine Mile Point Unit 2 Docket No. 50-410 l

Dear lir. Starostecki:

Your Inspection Report No. 50-410/82-03 dated May 19, 1982 identified an apparent violation in Appendix A resulting from an inspection conducted at the Nine Mile Point Unit 2 construction site. Niagara Mohauk's response to this itea is enclosed.

Very truly yours, NIAGARA 110HA POWER CORPORATION Gerai R Senior Vice President l

PEF /kub Attachment cc: R. D. Schulz, Resident Inspector r

8207070039 820630

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NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT UNIT 2 DOCKET N0. 50-410 Response to Notice of Violation Identified in Item B of Appendix A of the NRC Inspection Report No. 50-410/82-03 dated May 19, 1982 The apparent violation was identified as follows:

B. 10 CFR 50, Appendix B, Criterion IV states, " Measures shall be

- established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix."

The Nine Mile Point Nuclear Station, Unit 2 PSAR, Appendix D adopts the Stone & Webster Engineering Corporation Quality Assurance Program Manual.

The Stone & Webster Engineering Corporation Quality Assurance Program Manual, Revision C, states in part, in Sections 4 and 7, respectively:

" Sellers who perfom Category I work shall be required to have quality assurance programs consistent with applicable provisions of Appendix B,10 CFR 50. These provisions shall be imposed on their suppliers, as appropriate."

" Field purchase orders for Category I items shall be placed only with approved Category I sellers."

Contrary to the above, safety related field purchase orders, 13247A and 12550 for structural steel, did not impose 10 CFR 50, Appendix B. Furthermore, a safety related order for structural steel was placed with Interstate Steel on April 13,1982, field purchase order #14144, in spite of the fact that Interstate Steel was not on the approved Category I sellers list issued April 1,1982.

This is a Severity Level V Violation (Supplement II).

The following is provided in response to this item of nonconfomance:

Purchase Order No. NMP2-FP0-14144, Interstate Steel, was issued on April 8, 1982. SWEC Quality Rating List (QRL), Revision 98, dated April 1, 1982, did not list Interstate Steel as a Category I seller. This was due to the fact that the previous QRL listed Interstate Steel as expiring as a Category I Seller as of March 16, 1982.

A supplemental letter to the QRL dated March 18,1982 (received March 22, 1982 at the site), listed Interstate Steel as being reapproved as a Category I Seller with a new expiration date of March 16, 1983.

Although Interstate Steel was not listed in the body of SWEC QRL, Revision

. 98, the supplemental letter of March 18, 1982, was in effect and provided objective evidence that Interstate Steel is rated as a Category I Seller.

Interstate Steel will be listed in the QRL in an upcoming revision.

In regard to imposing the requirements of Appendix B to 10 CFR 50 into Field Purchase Order (FPO) Nos.13247A and 12550, a review was conducted and revealed that even though FP0 Nos.13247A and 12550, placed with Interstate Steel, did not reference Appendix B to 10 CFR 50, all quality requirements were met by the Seller.

To prevent this from happening in the future, SWEC has issued a memorandum and conducted a training program detailing the responsibilities in completing Field Purchase Requisitions. The Purchasing Department also has developed standard wording which will be included in Category I FP0's detailing the requirements of Appendix B to 10 CFR 50. Additionally, SWEC FQC has reinstructed its personnel as to what criteria must be met when reviewing purchase requisitions.

STATE OF NEW YORK )

) ss:

COUNTY OF ONONDAGA )

GERALD K. RH0DE, being duly sworn says: i I ara Senior Vice President of Niagara Mohawk Power Corporation. I have read the foregoing letter and attachment, and the information contained in the letter and attachment is true to the best of rny knowledge, information and belief.

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Mst'w '

Gerald Mhode Sworn to before me on this /E" day of June 1982 N*t12 $% d

@ tar Public HAZIL J. CARIUCK Notary Public in the State or New Yor6 QuaMied in Onon. Co. No. 4s244ti0 My Comanssion Lapires March 30,19 9 */

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