ML20154B265
| ML20154B265 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/21/1986 |
| From: | Mangan C NIAGARA MOHAWK POWER CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| (NMP2L-0624), (NMP2L-624), NUDOCS 8603040267 | |
| Download: ML20154B265 (2) | |
Text
r M V NIAGARA il u MOHAWK NIAGARA MOHAWK POWER CORPORAT10Nj 300 ERIE DOULEVARD WEST, SYRACLSE. N Y.13202/ TELEPHONE (315) 474-1511 February 21, 1986 (NMP2L 0624)
Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Reactor Projects 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starosteckt:
Subject:
Nine Mlle Point Unit 2 Docket No. 50-410 Status of Response to Notice of Violation In Niagara Mohawk's May 4, 1984 response to examples C.2, C.3 and G.2 of Inspection Report No. 83-18, Niagara Mohawk committed to incorporate Advance Change Notices (ACN's) into affected documents within 60 days af ter issuance.
Procedure changes were initially made as committed.
However, in order to improve efficiency and control, several revisions have been subsequently made to the procedures governing ACN's as follows:
1.
The "60 days from the date of issuance" rule was revised to "60 days from the end of the month in which the ACN was initiated".
Reason: A computerized list of open ACN's is issued to each discipline on the first day of each month.
This change was made to allow engineers adequate time to incorporate or approve the ACN's.
2.
Approval of ACN's can be documented using an "ACN Approval Cover Sheet".
Reason:
The ACN Approval Cover Sheet documents all necessary approvals and brings the ACN to the same level of approval l
as an Engineering and Design Coordination Report (ELDCR).
ACN's which have been approved with an ACN Approval Cover Sheet are incorporated into affected documents using the same incorporation criteria that apply to E&DCR's.
D603040267 060221 PDH ADOCK 05000410 tg 0
PDH g6 Dl
/ '
3.
ACN's that fall under the ASME N-5 Stress Reconclilation Program are approved in accordance with the N-5 schedule rather than the 60 days rule.
Reason: ACN's are reviewed and approved during Stress Reconcil-lation in order to complete the ASME N-5 certification.
In many cases, depending on the N-5 schedule, this approval may occur much earlier than required by the 60 days rule.
However, for those cases where the N-5 review occurs af ter the 60 days, an unnecessary duplicate effort would be required.
These changes in procedures have been made in accordance with our program requirenents to improve the effectiveness and efficiency of our program and to enhance the controls on ACN's.
Presentl.y the project is in the final stages of construction.
At this point in the construction, other changes in the review and approval of ACN's are being made in order to support the construction schedule for completion and turnover of systems for testing.
Stone and Webster has implemented an ACN Approval Completion Plan Schedule that prioritizes the ACN review and approval to support the following:
0 ACN's associated with ASME N-5 Stress Reconcillation Program have the highest priority and will be reviewed and approved in accordance with the N-5 Program schedule as described in item 3 above.
O ACN's associated with the other Category I systems have the second priority and will be reviewed and approved at least 30 days prior to fuel Load but not necessarily in accordance with the "60 day" rule.
O ACN's associated with Category II/I systems will be reviewed and approved prior to Fuel Load but not necessarily in accordance with the "60 day" rule.
Very truly yours, C. V. Mangan Senior Vice President CVM/TL/cla (1418H) xc: Olrector of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 R. A. Gramm, NRC Senior Resident inspector NMPC Project file (2)
.