ML20077E679

Responds to NRC Re Violations Noted in IE Insp Rept 50-220/83-02.Corrective Actions:Util Engineering Will Only Direct Work to Const Company Through Use of Contract Change & safety-related Work Will Be Done Per QA Program

ML20077E679
Person / Time
Site:	Nine Mile Point
Issue date:	04/21/1983
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20077E629	List: ML20077E679
References
NUDOCS 8307280389
Download: ML20077E679 (3)

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NIAGARA MOHAWK POWER CORPORATION NIAGARA MOHAWK 300 ERIE BOULEVARD. WEST SYRACUSE.N.Y.13202 Aptta 21,1983 tit. Thomas T. Ifartin, Director i

Division of Enginecring and Technicai Programs United States Nucicar Regulatory Comnission Region 1 631 Park Avenue King of Prussia, Pennsylvartia 19406 RE: Docket No. 50-220 Inspection Report M83-02 Dear kit. Martin Titis refers to the routine, safety inspection conducted by i

lit. S. Hudson of your office on February 1 to 28,1983, at Nine bfile Point Unit #1, Scriba, New York, of activities authorized by NRC License 1

No. DPR-63 and to the discussions of your findings heid by bl1. S. Hudson icith FLt. T. Roman of our staff at the conclusion of the inspeetion.

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10 CFR 50, Appendix B, Criteria V, " Instructions, Procedures and Drawings" and the Quality Assurance Program dated July 30, 1979, Section 5.2 require that instructions or procedures for activities j

affecting quality shall include appropriate quantitative or qualitative acceptance criteria.

Contrary to the above, on February 25, 1983, the procedure for the installation of flanges on the recirculation piping decontami-nation connections did not contain appropriate acceptance criteria for gasket material, torquing sequence, or torque value.

RESPONSE

Procedure kfP 44.1 tms totitten for the use of Ltained site bfairttenance personnet, and therefore, ANSI 18.7 - 1972 appl <.es. This standard classifies gasket replacement and tigktetting flanges to stop teaks as.those. types of jobs that may be done tcithout a step-by-step pro-cedure if the job is teithin the skitis nouaily possessed by 8307280389 830719 PDR ADOCK 05000220 G

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_ Pag e 2 IR 83-02 RESPONSE (continued) qualified personnet. The NRC accepts.this as stated in a letter from J.L. Skolds, Region 11, dated Augus.t 18, 1978.

In addition, Piping Code 831.1, Sec.135.2.1 and Sec.135.2.2 along wi.th ASME III N84720 do not indicate.that specifics such as gasket ma.terial,. torquing value or torquing sequence must be ptoceduralized.

Both only instruct (quoting ASMf III) that, "In botting flanged joints,.the contact faces of.the flanges shall bear uniformly on

.the nasket and the aasket shatt be crocertu comoressed in accordance with".the design psiitcipals applicab' e ko tite.ty' e of gasket used.

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All flanged joints shall be made up with reiativeig uniform bolt stress. " "Relatively uniform bolt stress" implies. torquing vaiucs are not requited.

i Further, the " quantitative or quali.tative acceptance criteria" for a blank ftange is Leakage. These flanges wtte be inspeeted during

.the primary system hidtastatic test psior to plant stat. tup.

j Therefore, " quantitative or qualttative acceptance criteria" does exist. Since.the proper gasket material aus used, and.the applicable codes do not requite torquing sequence or torque values.to be pto-1 ceduralized; and since the ANSI Standard and the NRC accept.that a sk.illed craftsman can. torque without step by step procedu.tes, Miagara Mohawk tais not deficient in this area.

Neuport News Ind. Consttaction Co. installed decon tap flanges on

.the five recirculation loops per a safety related work request from Niagara Mohawk Power Corp. NNI's contrac.t for the replacement of i

the recirculation piping, and their quali.ty assurance program does not address the use of NMPC work requests in their system. Consequently, NNI consttuction is not familtat with or Ltained in the use of Adminis-thative Procedure No. APN-13, " Procedure For Conttot of Station Correc-tive Repait and Maintenance", and.there was no notification of NMPC QA per APN-13, Sec. 4.5.1 when work sats performed.

NNI QA and consttuction have been told not to perform non-controlled O!o.tk Instruction work and NMPC Engineering will only dLtect work to NNI.thtough the use of a contract change and safety related work wili be done per.the NN1 QA ptogram.

The decontamination tap flanges have also been reinstalled using NNI's QA ptogram with a complete instattation ptocedure and with NMPC QA hold /wltness points.

Page 3 IR 83-02 ITBt B

.10 CFR 50, Appendix B, Criteria XVII, " Quality Assurance Records" and the Quality Assurance Program dated July 30, 1979, Section 17.6 require that records of inspections and tests shall include the acceptability of the results.

Contrary to the above, on February 18,-1983, no record of the review for acceptability of the piping spring' hanger inspcetion performed l

in April 1981 exists.

RESPONSE

The following corrective action has been taken to rectify the deffciency in our inspection records:

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NMPH1's visuai examination ptocedure includes iogging of the required and actual setting values for hangers.

It has been incorporated into this ptocedure.that if these values are not.the same, and therefore, k

unacceptable, "this condition shall be reported to the plant owners Engineering Department, and disposition shall be documented on the j

applicable data sheets."

i Due to these actions, Niagara Mohawk Power Corporation is ptesentig in fuli compliance.

i Very ttuly yours yya4-

"J'[;Y

Thomas E. Lempges i

Vice President Nuclear Generation TEL/RGR/jm i

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