ML20112C400
| ML20112C400 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/04/1985 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP21-0357), (NMP21-357), NUDOCS 8503210416 | |
| Download: ML20112C400 (5) | |
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N 3l M fd NIAGARA ISONAWK POWER CORPORATION /3OO ERIE BOULEVARD WEST, SYRACUSE, N.Y.13202/ TELEPHONE (315) 4741511 March 4, 1985 (NMP2L 0357)
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:
Enclosed is our detailed response to the Notice of Violation dated January 31, 1984, and the accompanying Inspection Report No. 50-410/84-19.
Very truly yours, C
Vice President Nuclear Engineering and Licensing CVM/GG:cla (0799H) xc: Director of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555 R. A. Gramm, NRC Resf uent Inspector Project File (2) 8503210416 850304 PDR ADOCK 05000410 j
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NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT - UNIT 2 DOCKET NO. 50-410 Response to Notice of Violation attached to NRC Inspection Report No. 50-410/84-19 Violation 1:
10 CFR 50, Appendix B. Criterion X and the Nine Mile Point, Unit 2 PSAR, Section 17.D. 3.11 require that inspections be implemented by Quality Control inspectors to verify the conformance of hardware installations to applicable design requirements.
The following examples of violation of these requirements were identified:
a.
Stone and Webster Engineering Specification P301J further requires that gaps behind pipe support baseplates are to be less than 1/8 inch unless sh'm material is provided.
Contrary to the above, on November 15,1984, final inspected pipe support BZ 60-G-004-S2 was found to have an excessive gap for which no shims were provided, b.
Johnson Controls, Inc. procedure QAS-1101, " Visual Weld Inspection" requires that all welds shall be inspected to assure compliance to the applicable drawings.
Contrary to the above, on November 15, 1984, an undersized fillet weld was identified on final inspected instrumentation tubing support BZ-412J-JD.
This is a Severity Level IV Violation (Supplement II).
The following is submitted in response to the violation:
Correctiv? Actions:
a.
ITT Grinnell will be conducting a reinspection of previously accepted pipe supports per a sampling plan in accordance with Specification P301J to identify excessive gaps behind pipe support baseplates.
These conditions will be documented on appropriate Inspection and nonconformance documentation as required.
The reinspection of Pipe Support BZ60-G-004-S2 has been documented on F10.1B FU 6346, b.
The undersized fillet weld was reinspected by JCI Quality Control and documented in Installation Surveillance Report 8849.
m x Prev:ntiva Actions:
'a.
ITT Grinnell will revise inspection procedure.FQC 4.2-14 to include an attribute on the. checklist form BTDW to verify that baseplate shinning has been accomplished in accordance with specification requirements.
Training of appropriate inspection personnel to the added requirement will be provided.
- b.. The root cause of this violation was the poor judgment by one JCI in-process inspector in not following his approved procedures.
This inspector was retrained and had perfonned adequately since his retraini ng. This inspector left JCI employ in July,1984.
Niagara Mohawk has instituted a program to identify all Category I welds previously accepted by this inspector, for reinspection through document review checklist attributes.in accordance with QAS 1802.
New Weld Data Sheets, to be used for the reinspection only, are being generated for all suspect welds, and will be incorporated into the permanent document package.
Deficiencies will be documented on Installation Surveillance Reports, and corrected in accordance with applicable procedures.
Schedule:
a.
Full compliance will be achieved by April 15, 1985 b.
Full compliance has been achieved.
Violation 2:
10 CFR 50, Appendix B, Criterion XVI, and the Nine Mile Point Unit 2 PSAR Section 17.D.3.17, state that corrective actions are to be implemented to preclude repetition of conditions adverse to. quality.
The following examples of violation of these requirements were identified:
a.
Stone and Webster ~ Engineering Corporation Specification C081A requires-that measures be established to prevent damage to installed instrumentation tubing lines.
NRC Inspection Report 50-410/84-11 unresolved item 84-11-08 previously identified damage to installed instrumentation tubing.
Contrary to the above, on November 23,1984,. it was identified that ineffective measures had been implemented to ensure that installed instrumentation tubing lines are protected from ongoing work activities, in that damage was identified to instrumentation tubing runs R-011, R-012, K090 and K091 at elevation 196 in the Secondary Containment due to the erection of scaffolding on th9 tubing.
- o b.
On April 26,
- 1983, Niagara Mohawk Power Corporation initiated corrective actions to ensure that ITT Grinn211 craftsmen would follow engineering directives for the control of installation activities because-of damage to piping which occurred during fi t-n.
Engineering and Design Coordination Report (E&DCR) V10289 provided instructions for the Main Steam Safety and Relief valve Vent Tee-quencher base stands to be lightly ground to achieve proper fit-up.
Contrary to the above, on November 7,1984, ITT Grinnell construction i
personnel utilized hydraulic rams to perfom the fit-up and subsequently defonned the support shell.
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This is a Severity Level IV Violation (Supplement II).
j The following is submitted in response to this violation:
Corrective Action:
i
- a. _All damaged tubing deficiencies noted by the Nuclear Regulatory Commission have been documented on JCI Installation Surveillance Reports, and will be repaired.
Training Bulletin #7 was reissued a:; Training Bulletin #10 on August 10, 1984, in response to Nuclear Regulatory Commission finding 84-11-08, to readdress the importance of protecting permanent ple.nt equipment.
Further, this issue was discussed at Tool Box Safety Meetings conducted between August,1984 and January,1985 b.
ITT-Grinnell initiated Nonconformance and Disposition Report IG-4990 to document the hardware deficiency, and the Nonconformance and Disposition Report has been dispositioned " accept as is".
Preventive Action:
a.
In addition to the -training conducted for NRC finding 84-11-08, a memorandum has.been issued to all site personnel advising them of the care required when working near the instrument tubing, and warning of disciplinary action if anyone is found damaging the tubing.
A new Construction Site Instruction (CSI) has also been developed and issued as preventive action to compliment the training of personnel.
CSI 20.16, entitled " Protection For Permanent Plant Equipment", is intended to more clearly _ identify methods to protect installed pemanent plant equipment,. and to establish methods for identifying and correcting protection deficienciet in a timely manner.
The Preventive Maintenance Manager is assigned primary responsibility for coordinating this new effort to ensure equipment and areas of the plant are properly protected and maintained in accordance with appropriate standards, specifications and procedures.
~ b.
Th2 General Foreman and fonnan involved have be:n retrained to work within tha guid linas of tha governing documents.
The G5neral Foreman has also received Communication and Direction Training presented by the Stone and Webster Training Group.
. In addition, ITT Grinnell - Construction Foremen and General Foremen,
.and ITT. Grinnell Engineering personnel will receive a training bulletin relative to working within the bounds of Engineering.
instructions with this particular situation as a case in point.
This effort is in addition to continuing emphasis on this subject through the sitewide poster and sticker campaign initiated previously.
Schedule:
a.
Specific deficiencies will be reworked in accordance witii current project schedules.
Training to Bulletin #10 has been completed and training for appropriate personnel to the requirements of CSI 20.16 will be completed by April 15, 1985.
b.
Full compliance will be achieved by March 15, 1985.
(0798H)
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