ML20082M255

Responds to NRC Re Violations Noted in IE Insp Rept 50-410/83-12.Corrective Actions:Training Sessions for All Certified Electrical Inspectors Held & Only Mandatory Hold Points Will Be Identified as Hold Points in Insp Plans

ML20082M255
Person / Time
Site:	Nine Mile Point
Issue date:	11/17/1983
From:	Dise D NIAGARA MOHAWK POWER CORP.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20082M254	List: ML20082M255
References
7731, NUDOCS 8312060073
Download: ML20082M255 (3)

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N!seatM NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOUJVARD WEST, SYRACUSE, N Y.13202/ TELEPHONE (315) 4741511 i

November 17, 1983 (7731)

Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Project and Resident Programs 631 Park Avenue King of Prussia, PA 19406 Re: Nine Mile Point Unit 2 Docket No. 50-410

Dear Mr. Starostecki:

Your Inspection Report No. 50-410/83-12 dated October 4,1983, identified an-apparent violation and a deviation resulting from an inspection conducted at the Nine Mile Point Unit 2 construction site. Niagara Mohawk's response is enclosed.

Very truly yours,

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D. P. Dise Vice President Quality Assurance DPD/TL:ja xc: Mr. R. A. Gramm, Resident Inspector 8312060073 831201 PDR ADOCK 05000410 G PDR

NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT - UNIT 2 DOCKET N0. 50-410 Response to Notice of Violation and Notice of Deviation Attached to NRC 4

Inspection Report No. 50-410/83-12 The apparent violation was identified as follows:

. 10CFR50, Appendix B, Criterion X states in part that inspection of activities affecting quality shall verify conformance to documented instructions. The 4

Nine Mile Point Unit 2 PSAR, appendix 0.3.11 further states that the results of inspections shall be documented.

4 Stone & Webster QS-10.52, QAd-10.18, QAD-14.1 and Inspection Plan N20E061AFA025 require that inspection personnel be present during cable installation activities, that the results of their inspection be documented in an inspection report, and that cable routing conforms to the cable ticket routing.

Contrary to the above, as of September 7, 1983:

1. An inspection was performed on rework to cable 2RHSAGC024 for which ,

no inspection report was documented.

2. The rework to cable 2RHSAGC024 resulted in the cable being installed in cable tray sections which were not defined in the cable ticket as proper cable routing.

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

The following is submitted in response to this item of nonconformance:

The cable in question (2RHSAGC024) was moved approximately 2 feet to facilitate. installation of another cable. At the time of the rerouting of cable 2RH5AGC024, inspection personnel were present but the documentation of their inspection was not performed.

The cable has since been reinstalled in the correct tray, and the inspection was performed on September 14, 1983 (Inspection Report No.

E3007539). Other partial pulls in heavily congested areas have been visually examined for similar rerouting of cables.

To prevent recurrence, the following actions have been/will be taken:

i 1. Training sessions for all electrical inspectors that were certified at the time to perform cable pulling inspections other than PGCC (Power Generation Control Complex) were held. (The nature of cable

, installation in the PGCC area does not warrant additional training for the inspectors.) This training session emphasized that during in-process inspections for cable pulls, any cable which has to be rerouted'in order to accomplish the cable pull will be noted on the inprocess inspection report.

. 2. The inspection plan for cable installation (N20E061AFA025) will be revised. A note will be added to the inspection plan to remind the inspectors, upon completion of the previously inspected partial pulls, to go back to the beginning of the last raceway where the cable was coiled or beyond that, if necessary, to ensure that subject cable (s) are still routed correctly in accordance with the latest issue of the cable pull ticket and as indicated earlier on the partial pull in-process inspection report. This change will be made by November 30, 1983.

The deviation was identified as follows:

FSAR Chapter 1, Table 1.8-1, states that Niagara Mohawk Power Corporation complies with Paragraph C of Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)," which in turn endorses ANSI N45.2-1977 " Quality Assurance Requirements," as an adequate basis for complying with the quality assurance program requirements of Appendix 8 to 10 CFR Part 50, as supplemented in the Regulatory Guide. ANSI N45.2 states, "If mandatory inspection hold points, which require witnessing or inspecting by the purchaser's designated representative and beyond which work shall not proceed without consent of the purchaser's designated representative, are required, the specific hold points shall be indicated in appropriate documents. Such consent shall be documented prior to the continuation of work beyond the designated hold point."

Contrary to the above, as of Septen,ber 16, 1983, Quality Control (QC) inspectors witnessed or inspected cable installation without documenting written consent prior to continuation of work beyond the designated hold points specified in the QC inspection plans.

The following is submitted in response to this deviation:

The corrective measures outlined below are planned /being taken to correct the condition:

1. Only mandatory hold points (specification required) will be identified in the inspection plans as hold points. Non mandatory hold points, already existing in the inspection plans, will be classified otherwise.

2. Stone & Webster Field Quality Control is reviewing installation specifications, in addition to E061A, to establish the required mandatory hold points as delineated in ANSI N45.2. After the review is completed, the release of the designated hold points will be j documented prior to the continuation of work beyond the hold point.

The corrective actions 1 and 2 outlined above will be completed by December 30, 1983.

( In the interim period, until corrective actions 1 and 2 above are completed, Stone & Webster Engineering Corporation Field Quality Control inspectors have been directed to observe the specific mandatory hold point in Specification E061A for the actual cable installation.

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