ML20116E573
| ML20116E573 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/17/1985 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP2L-0388), (NMP2L-388), NUDOCS 8504300329 | |
| Download: ML20116E573 (6) | |
Text
.
9 M Y NIAGARA
.)
HUMOHAWK NIAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST SYRACUSE. N.Y.13202/ TELEPHONE (315) 4741511 April 17,1985 (NMP2L 0388)
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 March 15,1985, and the accompanying Inspection Report No. 50-410/84-21.
In your transmittal letter for the above Inspection Report, you identified the need for management action in verification of implemented corrective actions in response to identified deficiencies. Also, you mentioned the need to accelerate the rate of closure of previously identified Nuclear Regulatory Commission deficiencies.
To address a potential problem of excessive open items, we have assigned the responsibility of closing these items to a senior member of our Project Management Staff. Also, we have assigned additional personnel to work on reducing the present number of open items. Management will monitor the progress in this area and take additional action, if necessary.
Very truly yours, 1
n Vice Preside' Nuclear Engineering & Licensing GG/ca xc: Director of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 R. A. Gramm, NRC Resident Inspector Project File (2) 8504300329 850417 PDR ADOCK 05000410 G
\\
)I O
g
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. 50-410/84-21 Violation 1:
10 CFR 50, Appendix B, Criterion III and the Nine Mile Point, Unit 2 Y, '
Preliminary Safety Analysis Report, Appendix D.3.4. require that design documents specify the appropriate quality standards and that design changes be subject to design control measures commensurate with the original design. Stone and Webster Engineering Corporation Procedure EAP-3.6 requires that the Quality Assurance category of drawings and specifications be reviewed against the Quality Assurance category documented within Final Safety Analysis Report section 3.2 for consistency. The Nine Mile Point Final Safety Analysis Report sections 3.2 and 9.1.4 specify that the Refueling Equipment Platform be a Quality Assurance Category I item.
Contrary to the above, on January 4,1985, it was determined that inadequate design control measures have been procedurally implemented by Stone and Webster Engineering Corporation, as Engineering and Design Coordination Report C91328 was issued which documented that the Refueling Equipment Platform was a Quality Assurance Category II structure.
This is a Severity Level IV Violation (Supplement II).
The following is submitted in response to the violation:
[
~
Cerrective Acticns:
The Quality Assurance Category of the Refueling Equipment Platform has been reevaluated, and it has been determined that the platform should be Quality Assurance Category II Seismic.
Niagara Mohawk Power Corporation has submitted a letter dated April 10, 1985, to the Nuclear Regulatory Commission detailing the change to the Final Safety Analysis Report with appropriate justification. Engineering and Design Coordination Report C91541 has also been generated to show the proper designation.
In order to detennine if improper categorization has been extensive, a random sample of 300 Quality Assurance Category I, II and III Engineering and Design Coordination Reports was selected from a population of approximately 35,000 This sample had two (2) Engineering and Design Coordination Reports which were assigned Quality Assurance Category II where Category I was required. Based on MIL Standard 105 D, the interpreted results are: a 95% confidence level that 96.66% or more of the 35,000 Engineering and Design Coordination Reports were assigned a Quality Assurance Category designation equal to or higher than that required.
The two improperly categorized Engineering and Design Coordination Reports in the sample were corrected.
One of these two Engineering and Design Coordination Reports involved a General Electric designed item.
In order to assure that General Electric Quality Assurance categorization of design documents is appropriately translated into Stone & Webster Quality Assurance categorization, the appropriate Engineers will be instructed regarding the difference between Stone and Webster and General Electric Quality Assurance categorization of design documents.
Additionally, a surveillance of previously issued Stone and Webster design change documents relative to General Electric design documents will be performed.
k Preventive Actions:
To enhance the program for controlling Quality Assurance category designation on design changes, Nine Mile Point Unit 2's Project Procedure,.PP-16, will be revised to require the Quality Assurance category affixed to a design change be reviewed against Final Safety
- Analysis Report Section 3.2.2 as is required for the original design document by EAP 3.6.
Schedule:
Full compliance will be achieved by May'10, 1985.
Violation 2:
I-10 CFR 50, Appendix B,-Criterion III and X'and the Nine Mile Point Unit'2 Preliminary Safety Analysis Report,-Appendix D.3.4 and D.3.11 require that design control measures be established to provide the necessary level of. design review and that inspection be performed'to verify the i
installation conformance to the design drawings.
Stone and Webster Engineering Corporation procedure EAP 5.4 requires that drawings be reviewed for technical adequacy. Stone and Webster Engineering Corporation procedure QAIP N20P413LFA001 requires that heating, ventilation and air conditioning support inspections be conducted to verify conformance to the design drawings.
Contrary to the above, on January 10, 1985, it was determined that the design drawings for support DSA-1360 depicted inconsistent design information and the installed tension brace of support DSA-1360 exceeded the angular tolerance identified by the design drawings.
This is a Severity Level IV Violation (Supplement II).
The following is submitted in response to the violation:
Corrective Action:
Engineering and Design Coordination Report C45112 was issued to modify the dimension letter designation for DSA-1360, as well as specifying the installation tolerances for the tension braces. The change to the letter designation affected only one other duct support, DSA-1370, which was also modified by Engineering and Design Coordination Report C45112 Engineering and Design Coordination Report C03243 was issued to clarify that engular tolerances apply only to those duct supports with angles specified on the drawings.
Engineering and Design Coordination Report's C45115 and C91831 were also issued to address dimensional requirements and installation tolerance for other duct supports utilizing similar design detail.
u
The inspection plan for Category I supports (QAIP N20P413LFA001) was revised to reflect the requirements of the noted Engineering and Design Coordination Reports. An inspection of the accessible hanger applications using these types of details has been performed to verify i
the applicable F, G, H, J, and K dimensions. The results of the Field Quality Control inspection are documented on Nonconformance and Disposition Report 11501 Disposition of the Nonconformance and Disposition Report will address hangers that were inaccessible at the time of reinspection.
Preventive Action:
The corrective actions above and the actions necessary for closure of the Nonconformance and Disposition Report are considered appropriate preventive measures for this deficiency.
Schedule:
Disposition of Nonconformance and Disposition Report 11501 will occur by April 21,1985 (0405G)
. - -