ML20065E776

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Responds to NRC Re Violations Noted in IE Insp Rept 50-220/82-10.Corrective Actions:Safety Evaluation & Procedures for Reactor Vessel Recirculation Nozzle safe-end Replacement Reviewed by Site Operations Review Committee
ML20065E776
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 08/18/1982
From: Lempges T
NIAGARA MOHAWK POWER CORP.
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20065E723 List:
References
NUDOCS 8210010165
Download: ML20065E776 (3)


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M Y NIAGARA RUMOHAWK NIAGARA MOHAWM POWER CORPORATION /300 ERIE BOULEVARD WEST. SYRACUSE N Y.13202/ TELEPHONE (315) 4741511 August 18, 1982 blt. Thomas T. Martin, OLtector Division of Engineering and Technical Progtams United States Nuclear Regulatort) Commission Region 1 631 Park Avenue Khtg of Prussia, PA 19406 RE: 00cket No. 50-220 Inspection Report 82-10

Dear Alt. Alvttin:

This refcrs.to the routine safetij wpection conducted bi Dr. P.K. Eapen j

of your office on June 21-25, 1982, at the inne blite Point Nuclear Station Unit H1 and at our Corparate Offices of activities authorized bi NRC Licertse j

No. OPR-63 and to the discussions of gotut findings held bi Dr. Eapen at the j

conclusion of the inspection, and to a subsequart telephone discussion betecen bit. D.L. Caphton of your of fice and bit. T.J. Perkins on Juttj 1, 1982.

ITDI A Technical Specification 6.5.1.6.a in conjunction with Technical Specification 6.8.1 requires the Site Operations Review Committee to review all procedures tecommended in Appendix A of Regulatory

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Guide 1.33, November 1972.

Appendix A of Regulatory Guide 1.33, November 1972, includes procedures for the repair and replacement of major equipment.

Contrary to the above, in June, 1982, several procedures (CWI-1399K-1 series) for removal and replace ent of recirculation nozzle safe-ends and associated piping were.s t reviewed by the SORC.

RESPONSE

The safety evaluation and ptocedures outlining the overall methodologtj for the Reactor Vessel Reeltculation Nozzle Safe-End Replacement teche reviciced bi the Site Operations Review Committee (SORC) prior.to commence-j ment of teork.

Presentti), SORC is reviewing.the conttolling work procedures pertaitting to on-site work in connection with the reeltculation st stem j

repairs tehich are the Cotttrolled Work Insttuctions (CWl's) for work in.the plant per NNI Insttuction 1399K-SO-20.

Changes to apptoved ptocedures 8210010165 820924 PDR ADOCK 05000220 G

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Page 2 ITEM A RESPONSE (corttinued) and CWl's are also being reviewed in accordance with Section 6.8 of the i

Technical Specifications.

AdministAative practices and ptocedures at the site are being revised to assure that att ptocedures which come within the scope of Technical Specifications 6.5.1.6 and 6.8.1 will be subject to apptopriate review.

The Niagara Mohawk Power Conparation Nine Mlle Point Nuclear Station l

is now in fatt compliance wi.th Technical Specifications 6.5.1.6a and 6.8.1.

Changes to AdministAative Procedwtes will be made by August 31, 1982.

SAFE ENO CUTTING CPERATION in addition, as requested in Paragraph 5 of your 7/19/82 letter, the following information is ptovided:

1 An investigation into the causes of the mistocation of the nozzle cut on MIS recirculation suction nozzle has found the following causes/ circumstances:

a.

Neuport News Industtial Corporation's Quality Assurance P.togram required imptovement in numetous areas as documented in NMPC QA Non-conformance Report 82-33. As stated in NCR 82-33, the NNI QA Program exercised inadequate conttot or lack of insttuction and/or Ltaining in regards.to NNE's shop ttavelers hold points and instructions for consttuction, technical and QA/QC personnet.

b.

The actual shim block that was designed to be used in the cutting ptocess was not available for use during mock-up training.

A substitute shim block was used.

This fact introduced a factor of unfamitxarity on the fitst cutting evolution in the drycell.

The cutting machine drive air motor used in the mock-up training c.

was a different model and, therefore, size than.the air motor used on the nozzle cut.

This caused a work stoppage in the drycett because the cutting tool would not etcar the ait motor as it travelled around the machine.

This work stoppage occurred before the cutting toot touched the nozzle / safe-end material.

d.

The ptocedure did not have adequate controls on the reverification of cutting tool alignment after the toot had been relocated or removed.

It was assumed that the only time the tool would be removed from the machine was after it had commenced pipe penetration.

No credLt was given for changing worn or damaged toot kits, operational problems or equ,ipment ptoblems.

Nia actions:gara Mohawk Power Corporation has taken the following corrective a.

NMPC QA has taken measures to ensure that the NNI QA/QC ptogram has been upgraded to the apptopriate level of quallty.

This.is evidenced by the following imptovements in the NNI ptogram:

1.

NNI developed supplemental training ptograms to include att craft, craft foremen, and NNI personnet on site. This staining includes CUT sign-offs / hold points, tagging require-ments, and pwtpose of CW1's.

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Page 3 SAFE ENO CUTTING CPERATION (continued) 2.

An incrcase in NN1 QC inspector participation in att wark in the drycett.

3.

A consttuction supervisor or field engineer is providing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage of dryceit operations and also briefing and debriefing craft personnet.

b.

The cutting ptocedures have been revised to ensure that.the location and the operation of the cu,tting equipment is maintained at the required quality level.

To ensure this, the following sops have been added:

1.

. A log is maintained.to document ali shims instatied and removed from the cutting machine.

2.

Whenever the cu,tting operation cannot be performed in accordance with the conttot requited bij the controll.ing document, the cutting operation shalt be stopped immediately.

3.

Whenever.the cutting tools are removed from the machine, or the machine set-up is adjusted, the Cos.sttuction Supervisors shall record the event in the Log, notift) NMPC, reverift),

and have QA/QC reveriftj that the toot has been replaced in the ptoper cut location.

Verij truttj tjours, f,<

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to utw Thomas E. Lempges Vice President -

Nuclear Generation mbn 1

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