ML20116E154
| ML20116E154 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/15/1985 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP2L-0387), (NMP2L-387), NUDOCS 8504300196 | |
| Download: ML20116E154 (14) | |
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N3F##fe NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST. SYRACUSE, N.Y.13202/ TELEPHONE (315) 4741511 April 15,1985 (NMP2L 0387)
Mr. R. W. Starostecki, Director U. S. Nuclear Regulatory Comission 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 as attachment I is our detailed response to the Notice of Yiolation dated March la,1985, and the accompanying Inspection Report No.
50-410/84-18 covering the special inspection conducted by Mr. J. P. Durr of Region I on December 3-14, 1984.
Attachment II provides our response to program weaknesses identified in Appendix B to your March 14, 1985, transmittal letter for the above mentioned Inspection Report.
Very truly yours, l
C Vice President
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Nuclear Engineering and Licensing l
l CVM/GG/phd (0896H) xc: Director of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 R. A. Gramm, NRC Resident Inspector Project File (2) 8504300196 B50415 PDR ADOCK 05000410 G
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~2 Attachment I NIAGARA M0 HAWK POWER CORPORATION NINE MILE P0 INT UNIT #2 DOCKET NO. 50-410 Response to Notice of Violation attached to NRC Inspection Report No. 50-410/84-18 Violation 1:
10 CFR 50, Appendix B, Criterion XIII, required in part, that, " Measures shall be established to control the... preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration". The Stone and Webster document Construction Site Instructions 20.13, Paragraph 4.2.4, also requires that supervisors and contractors provide adequate protection of materials and equipment in
-accordance with Stone and Webster Specification No. NMP-2-SM01.
Specification SM01, Paragraph 1.9.6 requires that equipment be protected from dust, dirt, and moisture.
Contrary to the above, on or before December 3, 1984, the following equipment was left unprotected from dust, dirt, and moisture and, in some cases, critical parts were covered with construction dirt and debris:
(1) the high pressure core spray diesel genarator cooling water heat exchanger, 2CHS*E9, was inspected and found with 2" of water standing in the tube side compartment.
It was revealed that this heat exchanger had no provisions for storage maintenance.
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(2) the following listed valves were left exposed to construction dirt and debris:
the residual heat removal system hand control valve 2RHS*HCV-54B and the high pressure core spray system hand control valve 2CHS*HCV-120 were found with the valve stem operators and packing glands covered with construction debris.
the main steam safety relief valve discharge piping vacuum breakers 2SW*RV 11-118 [ correct designation is 2SVV*RVV101-ll8]
and 201-218 were uncovered and exposed.
the high pressure core spray system motor operated valve 2CHS*M0V.101 was-infiltrated with construction dirt.
.the reactor water cleanup system motor operated valve 2WCS*MOV
'113 was infiltrated with construction dirt.
(3)
.the high pressure core spray flow elements, 2CHS*FE105, instrumentation taps were uncapped.
(4).
the containment penetration, Z14, was not properly protected and had been infiltrated with dirt and weld spatter.
This is a Severity Level.IV violation.
(Supplement II)
TheTfollowing is submitted in' response to this violation:
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Corrective Actions:
(1)
The standing water was drained from the High Pressure Core Spray Diesel Generator Cooling Water heat exchanger, 2CSH*E9. This heat exchanger was fabricated utilizing inhibited admiralty brass tubing (ASME Section II SB 111 Alloy 443). This material is highly resistant to dezincification in moving or stagnant water.
Therefore, the extended submergence of the admiralty tube material would not result in a metallurgically unacceptable condition.
The Stone and Webster Storage and Maintenance specification (SM01) has been revised by Engineering and Design Coordination Report F02014 to include storage and maintenance requirements for the subject heat exchanger. Additionally plant safety related heat exchangers were reviewed for adequate storage and maintenance instructions.
This review identified one additional safety related
- heat exchanger, (21CS*El,) that did not include appropriate storage and maintenance requirements. No standing water was found in this heat exchanger. Engineering and Design Coordination Report F02066 was generated to include the necessary SM01 Storage and Maintenance requirements.
(2)a) The cited conditions of the High Pressure Core Spray System Hand Control Valve, 2CHS*HCV-120 and the Residual Heat Removal System Hand Control Valve, 2RHS*HCV-548, were identified and corrected on ITT-Grinnell Inspections Report IPC 3145 and IPC 3146, respectively.
b) The Main Steam Safety Relief Valve Discharge Piping Vacuum Breakers 2SVV*RVV 101-118 and 201-218 have been covered as documented on ITT-Grinnell Inspection Report 85-04-03846.
c) The High Pressure Core Spray System Motor Operated Valve 2CSH*MOV 101 was reinspected and brought to an acceptable condition,'as documented on ITT-Grinnell Inspection Report IPC-1458.
d) The Reactor Water Cleanup System Motor Operated Valve 2WCS*M0Vll2 was reinspected and brought to an acceptable condition, as documented on ITT-Grinnell Inspection Report IPC 1457.
(3)
The High Pressure Core Spray Flow Element, 2CHS*FE105, Instrumentation Taps were capped and their present conditions are in accordance with specification P301C. This condition was documented on ITT-Grinnell Inspection Report 85-04-03845.
(4)
The Containment Penetration, Z14, was reinspected and brought to an acceptable condition, as documented on ITT-Grinnell Inspection Report IPC-3144.
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2 Preventive Action:
Nigara Mohawk has consolidated, upgraded and formalized the control of the protection of permanent plant equipment with the issuance of Construction Site Instruction 20.16, entitled, "The Protection of Permanent Plant Equipment". This procedure gives the preventive maintenance organization the additional responsibility for monitoring the protection of permanent plant equipment, during and after installation,
-for all organizations on site.
It is intended to more clearly identify methods to protect installed permanent plant equipment, and to establish methods for identifying and correcting protection deficiencies in a timely manner.. The Preventive Maintenance Manager has been 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.
Additionally to ensure that all revisions of the Vendor / Manufacturer instructions manuals that have been sent to Nine Mile Point Unit #2 have
-been reviewed and incorporated into SM01, Site Engineering Group Preventive Maintenance Engineers are conducting a manual review of the instruction manuals document record cards on Category 1 Equipment.
Based-on this review any discrepancies noted will be incorporated into SM01 by Engineering and Design Coordination Reports.
Schedule:
Full compliance will be achieved by September 2, 1985.
Violation 2:
10 CFR 50, Appendix B, Criterion V, requires that, " Activities affecting quality shall be prescribed by... drawings... and shall be accomplished in accordance with these... drawings".
Johnson Controls, Inc. Procedure No. QAS-1005-NMP2, Revision 12, Fabrication and Installation Procedure (Cat. I), paragraph 5.7.3., states, in part, "The installing craftsman will install supports, hangers, tuberack, etc, in accordance with the drawing requirements and this procedure." Johnson Controls, Inc.
Procedure No. QA8-1101-NMP2, Revision 8, Paragraph 5.2.1, required that,
" visually inspect all welds to assure compliance with the applicable approved drawing..."
Drawing No. 12177-BZ-493H and J show Part No. 4, a 4"x4"xl/4 angle, attached with 1/4" fillet welds.
Contrary to the above, on or before December 3,1984, the 4"x4"xl/4" angle brackets, part No. 4 on drawing No. 12177-BZ-493H and J, were installed with the edges ground below the 1/4" thickness such that a full section fillet weld could not be produced.
The welds were accepted undersized by quality control inspectors, s
This is a Severity Level IV violation.
(Supplement II).
The following is submitted in response to the violation:
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5 Corrective Actions:
__ The undersized fillet weld identified on BZ-493H was reinspected by 1
Johnson Controls Quality Control on December 12, 1984. This condition was. addressed on Johnson Controls ISR 9530 and subsequent Nonconformance u
and Disposition Report _JC-38?. The disposition of the Nonconformance and
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. Disposition Report was to " Accept-as-is."
The original inspection for E C-493J was performed by Johnson Controls Quality Control and documented as acceptable on the weld data report. On December 12, 1984 Johnson Controls reaffirmed their original acceptance position following a field check of the noted condition.
-Support BZ-493F was also reinspected and determined to be unacceptable on ISR 10626.
Nonconformance and Disposition Report JC-490 was issued for-this nonconformance, and dispositioned " accept-as-is".
In addition, Stone and Webster Engineering has performed a review of instrument support stands to identify those which by drawing required flush welds across the full dimension of the angle. As a result of this review and the Nuclear Regulatory Commission concern, drawings for a total of sixteen supports including the abova supports have been revised to shorten the required leg length.
Johnson Controls Quality Control performed a review of documentation or=
reinspection as required to determine the acceptability of the affected supports to.the latest design criteria as depicted on the revised drawings. 'All were found acceptable to the revised criteria.
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-4 Preventive Action:
Johnson Controls Procedure QAS-1101 was revised to provide additional acceptance criteria for visual inspection of fillet welds. Appropriate Quality Control Inspectors have been trained to the new criteria of the QAS-1101.
Schedule:
Full compliance has been achieved.
(0413G)
Attachment II NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT UNIT #2 DOCKET N0. 50-410 Response to Notice of Program Weakness attached to NRC Inspection Report No. 50-410/84-18 Item 1 There are several indications that the engineering design controls are not being effectively implemented and this area is considered weak based on the following indicators.
[a]
failure of Stone and Webster Engineering Corporation to properly incorporate a Nonconformance and Disposition Report' disposition on design drawing EC-37-AH and highlight the affected section of EC-32L (page 11).
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[b]
inadequate control by Stone and Webster over small bore pipe support attachment points to embed plates on EC-37-AH (page 13).
[c]
lack of Niagara Mohawk verification / tracking of design change directives issued to Stone and Webster and General Electric (page 17).
[d]
nona'ccomplishment of training of the engineering staff (page 14)..
The following is submitted in response to this Notice of Weakness:
[a&b] The Nuclear Regulatory Commission concern has been reviewed and drawing EC-32L, Rev. 3 has been reissued, showing the spacing " clouded" to indicate revision. A survey of 10 structural drawings involving over 40 Engineering and Design Coordination Reports was conducted and all documents were incorporated correctly with the appropriate "cloudings".
Niagara Mohawk believes that the concern about proper incorporation of Nonconformance and Disposition Report 6206 is the result of a problem with an unclear disposition and not an incorporation problem. The Nonconformance and Disposition Report has been superseded and redispositioned, in part to clarify that the entire embed plate is restricted per the Nonconformance and Disposition Report 6206 disposition (with the one exception noted below). Stone and Webster engineers have been reinstructed to be very specific in future diractions to minimize unclear dispositions.
The disposition of.Nonconformance and Disposition Report 6206 also called
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for hard marking the embed plate "no attachments are allowed - Ref:
Nonconformance and Disposition Report #6206." Prior to Nonconformance and Disposition Report 6206 being issued to the field for implementation of this original disposition, Stone and Webster Field Quality Control identified that a small bore pipe support (BZ-416EG) had been attached in accordance with Advance Change Notice 10972, which was approved prior to the initiation of Nonconformance and Disposition Report 6206.
Consequently, the attachment was now in conflict with the Nonconformance and Disposition Report 6206 disposition. As noted above, the Nonconformance and Disposition Report has been superseded and redispositioned, in part to " accept as is" the single attachment.
Stone and Webster Construction or Field Quality Control inspection would have identified the conflict between the Advance Change Notice and s
Nonconformance and Disposition Report disposition since both could not be implemented or accepted. Further tracking of attachments to embed plates is accomplished through load attachment sheets which are provided to Structural Engineering for verification of load acceptability.
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[c]
The three identified Niagara Mohawk letters examined by the inspector t
have been investigated and it has been verified that those design 1
changes were properly dispositioned by Stone and Webster in accordance r
with Niagara Mohawk directives. While it is felt that present programs l
i are adequate to ensure Niagara Mohawk design change directives are
-implemented, it is recognized that a tracking system that ties back to 1
and closes out the "open" initiating Niagara Mohawk correspondence would be a desirable enhancement to the tracking system.
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In order to establish a more formalized tracking mechanism, Niagara Mohawk Project Engineering will maintain a tracking log of all formal l
engineering letters sent to Stone and Webster requesting design changes.
(Design changes as used herein means changes that require revisions to conceptual, or production documents, or requires the addition, modification, or deletion of plant hardware). The log will track closure of each letter in that it will verify that a formal respbnsehbsbeenreceivedfromStoneandWebsterdispositioningthe 1
Niagara Mohawk request.
If Stone and Webster agrees to implement the change, it will also verify that either the implementing documents (Engineering Change Notice, Engineering and Design Coordination Report, etc.) have'been specifically identified or that the change has been entered into an established, verifiable tracking system that will ensure its eventual and timely implement'ation. This tracking log will apply to alldesignchangerequestsibitiatedonorafterMay1,1985.
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[d]
A series of training sessions are scheduled to complete engineer training in the courses listed in the Nine Mile Point Unit #2 Site Y
3
) Engineering Group Training Matrix as mandatory or required.
Specifically, those engineers who have been on site for more than one year and have not completed all required training will be identified and will be scheduled'to attend the next training sessions on the subjects they missed. This will be done by the newly assigned Site Engineering Group Training Coordinator, who will. assure that this, and future training of Site Engineering Group engineers is appropriately provided.
o In conclusion, while the engineering design controls have been effectively implemented, changes to strengthen controls are always considered.
In the cases cited above, the programs in place provided the controls necessary to assure that there was no detrimental effect on the plant hardware. Actions to strengthen controls were taken as noted and will continue to be taken to ensure a quality plant.
Item 2 The inspection revealed that a previously identified area of noncompliance, document control, still is weak although some corrective actions have been imposed (page 16).
The following is submitted in response to this Notice of Weakness The Project is developing and implementing an enhanced Document Control Program to further improve efficiency and control. A comprehensive Document Control Plan has been developed, approved and istued that defines the basic concepts of the Document Control Program.
Implementing procedures are being developed to further define specific requirements. Key elements of the plan include:
1.
Standardization of Document Control procedures.
2.
Increased surveillance of Document Control stations.
3.
Automation of systems used for control of distribution.
4 Simplification of the Document Control system.
5.
Acquisition of additional space, staf f and equipment.
6.
Transfer of responsibilities for uncontrolled documents from Document Control to Administrative Services.
- e Full implementation of the Nine Mile Point Unit #2 Document Control Plan will provide an. effective, efficient Document Control system at Nine Mile Point Unit #2 that assures.a high level of confidence in the prompt distribution and updating of controlled documents for construction and inspection ~ activities.
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