ML20077L556
| ML20077L556 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/25/1983 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20077L553 | List: |
| References | |
| 7083, NUDOCS 8308090472 | |
| Download: ML20077L556 (4) | |
Text
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'\\A, N3 Wife NIAGARA MOHAWK POWER CORPORATl0N/300 ERIE BOULEVARD WEST. SYRACUSE. N.Y.13202/ TELEPHONE (315) 474-1511 July 25, 1983
{7083)
Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Comission Region I Division of Project and Resident Programs 631 Park Avenue l
King of Prussia, PA 19406 Re: Nine Mile Point Unit 2 Docket No. 50-410
Dear Mr. Starostecki:
Your Inspection Report No. 50-410/83-05 dated June 15, 1983, identified two apparent violations resulting from an inspection conducted at the Mile Point Unit 2 construction site.
Very truly yours, 6C,hDMMt C.v.Manon Vice President Nuclear Engineering & Licensing CVM/TL:ja Enclosure xc: Mr. R. Gram, Resident Inspector 8308090472 830002 PDR ADOCK 05000410 G
PDR,
NIAGARA M0 HAWK PCdER CORPORATION NINE MILE POINT - UNIT 2 DOCKET N0. 50-410 Response to Notice of Violation Attached to NRC Inspection Report No. 50-410/83-05 The first apparent violation was identified as follows:
A.
10 CFR 50, Appendix B, Criterion XVI states in part that measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
)
ITT Grinnell Industrial Piping, Inc. procedure QCI 10.1.5, Category I, Deviation Report Root Cause Analysis, dated September 20, 1982, states in part that the QA Manager or his designee will evaluate deviation reports for nonconforming trends and will issue a Corrective Action Report when a trend is identified.
Contrary to the above:
1.
Trend analysis did not identify repetitiveness requiring action for 15 deviation reports written from February 11, 1983 to February 24, 1983 for undersize or undercut hanger welds under the jurisdiction of the ASME Boiler and Pressure Vessel Code.
2.
Corrective Action Reports were not issued by the QA Manager or his designee as a result of numerous repetitive nonconformances identified by trend analyses done from October 1982 through February 1983.
3.
Deviation reports were not analyzed for nonconforming trends by the QA Manager or his designee for the months of March or April 1983.
This is a Severity Level IV Violation (Supplement II).
The following is submitted in response to this item of nonconformance:
1
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'As c rr:ctive action to item 1, ITT Grinnell has issu:d Cerrcctiva Acticn Reports #592 and 593. Their Corrective Action Reports identified the 15 Deviation Reports cited ill addition to other similar Deviation Reports of undersize and undercut hanger welds. Tne corrective and preventive action for Corrective Action Reports #592 and #593 will be provided by ITT Grinnell in accordance with its Quality Assurance Manual by July 29, 1983.
In regard to items 2 and 3, ITT Grinnell will take the following corrective actions:
A review of all Category I nonconformances dated from October 1982 to June 1983 will be performed. This review shall identify any repetitive nonconforming trends. These trends will be evaluated and documented in accordance with the ITT Grinnell Quality Assurance Program. This will be completed by September 30, 1983.
Increased emphasis on the requirement to perform trend analyses by ITT Grinnell Quality Assurance has begun to show a marked improvement.
In addition, the appointment (on June 27,1983) of a new full time Quality Assurance Manager is expected to provide further improvement.
The second apparent violation was identified as follows:
8.
10CFR50, Appendix B, Criterion V states in part that activities affecting quality shall be prescribed by drawings and shall be accomplished in accordance with these drawings.
Contrary to the above, flare bevel welds for two tubing supports were not in accordance with Drawing Nos. 12177-BZ-410-ME-1 and 12177-8Z-410-MG-1 with regard to length and centers.
This is a Severity Level V Violation (Supplement II).
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' The following is submitted _in resp nst to this item of nonconformance:
Stone & Webster Engineering Corporation drawings 12177-BZ-410-ME-1 and 12177-BZ-410-MG-1 require flare bevel welds 3" long on 9" centers symmetrical about the center line of a 12" long embedment plate.
The intent was that the 3" welds be provided at each end of the 12" plate. Johnson Controls, l
Incorporated interpreted the weld symbol and performed the welding to consist of 3" long welds in the center of the plate and 1-3/4" - 2" welds located towards the end o,f each plate.
As the corrective action, Johnson Controls, Incorporated Engineering will review those Installation / Fabrication Planner Packages which have been released to construction for fabrication and determine which packages are to be reinspected.
Inspection reports will be generated for each item reinspected. Those stitch (intermittent) weld items determined not to be meeting the design requirements will be reworked or submitted to Stone &
Webster Engineering Corporation for engineering evaluation. These actions will be completed by August 15, 1983.
In order to prevent recurrence, the following Johnson Controls, Incorporated procedures have been revised:
a)
QAS.- 1101-NMP2 - Visual Weld Inspection b)
QAS - 1005-NMP2 - Installation / Fabrication Procedures (Category I) i l
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