ML20207S424
| ML20207S424 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/09/1987 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mangan C NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 8703190425 | |
| Download: ML20207S424 (2) | |
See also: IR 05000220/1986007
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6
NAR 0 91987
Docket No. 50-220
Niagara Mohawk Power Corporation
ATTN: Mr. C. V. Mangan
Senior Vice President
301 Plainfield Road
Syracuse, New York 13212
Gentlemen:
Subject:
Inspection No. 50-220/86-07
This refers to your letter dated November 5,1986, in response to our letter
dated September 2, 1986.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
Sincerely,
or!:Dri.91 red Pf:
/
JacqueP.Durr
/
Stewart D. Ebneter, Director
[#
Division of Reactor Safety
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E. Lempges, Vice President, Nuclear Generation
J. A. Perry, Vice President, Quality Assurance /
T. Perkins, General Superintendent, Nuclear Generation /
W. Hansen, Manager of Quality Assurance /
T. Roman, Station Superintendents /
J. Aldrich, Supervisor, Operatio rs /
W. Drews, Technical Superintepdent /
Troy B. Conner, Jr. EsquJre v
John W. Keib, Esquire v
Director, Power Division
Public Document Room (PDR) /
Local Public Document Room (LPOR)
Nuclear Safety Information tenter (NSIC)
NRC Resident Inspector
State of New York /
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OFFICIAL RECORD COPY
RL NMP1 - 0001.0.0
01/15/87
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NIAG ARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST. SYRACUSE. N Y.13202/ TELEPHONE (315) 4741511
November 5,1986
NMPIL 0112
Dr. Thomas E. Murley
Regional Director
U.S. Nuclear Regulatory Commission
Region I
'-
631 Park Avenue
King of Pruisia, PA 19406
Re: Nine Mile Point Unit 1
Docket No. 50-220
Dear Dr. Murley:
Niagara Mohawk hereby subniits a response to Inspection Report No. 50-220/86-07
regarding the modification outage inspection conducted at our Nine Mile Point
Unit i facility sad Corporate office on June 2-13, 1986.
The attached
response addressa the four violations and three weaknesses contained in the
inspection report.
The tosMetion report cover letter also provided your understanding of our
aethities and schedules related to the upgrading of our engineering assurance
procedures and our evaluation of AC and DC emergency bus loads. The following
clarification is provided with resl,ect to those items.
Your letter indicated
that we would complete an evaluation of the total loads on the AC and DC
emelgency buses by June 1987. Our intention was to complete a documentation
program of DC loads by that date.
There has been no significant increase in
tne load on the DC system. Minor increases have resulted due to the addition
of control circuits cnd two oil pumps for the emergency diesel generators.
However, the DC capacity has increased by fifty percent which is sufficient to
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accommodate the additions indicated above as well as future additions. A
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study was performed regarding the Class 1E AC power distribution system and
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submitted to the Commission on September 27, 1982.
That study evaluated loads
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on the emergency bus and included a tabulatio7 of the same.
The results
demonstrated inc adecuacy of the system.
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N:vember 5, 1986
Page 2
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The schedule to complete our documentation program is as follows:
1.
Identification: and Documentation of AC and DC loads - June 30, 1987
2.
Develop procedures for both AC and DC loads such that it will be in
place for evaluation of load addition - prior to 1988 refueling and
maintenance outage.
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We have reviewed the engineering assurance procedures with respect to
correctness of reference and incorporation of reference to Topical Report
NQA1. Design guidelines with respect to pipe supports will be developed prior
to designing modifications to be installed during the 1988 Refueling and
Maintenance Outage.
In addition, in accordance with our letters of August 15,
1986 and August 31, 1986 to Mr. W. F. Kane, a long term review of procedures -
is being developed as part of the response to recent allegations made by an
I&C technician at Nine Mile Point Unit 1.
.
Sincerely,
~~
NIAGARA M0 HAWK POWER CORPORATION
.
Senior Vice President
MGM:bd
Enclosure
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NINE MILE POINT UNIT 1
NIAGARA M0 HAWK POWER CORPORATION
RESPONSE TO INSPECTION REPORT NO. 50-220/86-07
Notice of Violation Item A
10CFR50, Appendix B, Criterion III " Design Control" states in part, that "....
The design control measures shall provide for verifying or checking the
adeauacy of the design, such as by the performance of design review, ...." and
that "... Measures shall also be established for the selection and review for
suitability of application of materials, parts ... that are essential to the
safety-related functions of the ... systems ..."
Contrary to the above, on June 4,1986, the inspector identified that one part
of the safety related ADS Modification (relays wired in series with adjustable
resistors) had not been design verified, nor had it been included in the
safety evaluation of the modification.
In addition, the inspector identified
that the adjustable resistors (ASEA Cat #5245004-332) to be used in
conjunction with the 55V AC relays, in the ADS modification, were of
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insufficient power rating to perform their safety function.
Response
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The safety evaluation did not specifically make reference to the resistors and
relays.
In general, safety evaluations address the criteria outlined in
10CFR50.59 with respect to the overall effect on system safety function but do
not necessarily address the " nuts and bolts" of the modification.
Reference
to applicable design drawings could have been included. Detailed information
regarding the adjustable resistors and 55V AC relays was included in the
design verification package.
However, the insufficient power rating of the
resistors was not addressed during design verification process.
Short term corrective action consisted of delet(89 the subject relay and
resistor from the modification. This was accomplished under Drawing Change
Request LG012.
Long term corrective action will include improvement of our design
verification process as indicated in our response to Weakness Item b and
adherence to procedure ND-140, " Minor Design Changes to Modifications."
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N3tice cf Violation Item 8
Nine Mile Point Unit 1 Technical Specification 6.8.1 requires the
establishment and implementation of written procedures and administrative
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policies which meet or exceed the requirements and recommendations of Section
5.1 of ANSI N18.7-1972. Section 5.1 of the ANSI N18.7 requires that
modifications be designed and performed in accordance with applicable codes,
basis, design requirements, material specification and inspection requirements.
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Contrary to the above, the following activities were not accomplished in
accordance with prescribed design requirements:
1.
Drawings for the modification of Emergency Condenser drain piping supports
N0. 05-SCRI-3, 05-SCRI-6, and 05-SCRI-7 show an addition of a plate welded
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on both sides in each support using a 2" long fillet weld. The plates
were found to be installed using welds shorter than the specified length
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by approximately 1/4" to 3/8".
2.
Isometric drawing No. C-26843-C (Sheet 5) for the modification of
Emergency Condenser drain piping specifies the distance between the
centerline of EC steam pioing No. 39-12-B and the elbow for drain piping
No. 39-1-BL as 10", and the distance between the 1" coupling and support
No. 39-SR-3 on drain piping No. 39-1-A as 3'-4 1/2".
Inspection of drain
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piping installations in the above cases indicated the as-built
measurements are l'-0" and
l'-2", respectively.
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3.
Detail "D" of drawing No. F-39831-C for modification of Emergency
Condenser steam piping anchor 39-Al required the use of A490 bolts between
two of the anchor braces and the wall embedded plate.
The connections
were installed using a mixture of A325 and A490 bolts.
4.
Administrative Procedure AP-6.0, Section 5.4.3, requires that work on
modifications shall not commence prior to the issuance of a Modification
Work Request and' referenced documentation.
The support for electrical
conduit to hydrogen purge valves No. 201-32, 201.2-03 and 201.2-32 was
found to be cut and dismantled from its support to an existing brace on
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the piping anchor No. 39-Al which required removal.
The removal of the
conduit support was performed without a modification work request and
required documentation.
Further, Niagara Mohawk Power Corporation's Quality Assurance Program Topical
Report invokes the requirements of ANSI N45.2.5 (1974 Edition) for
installation and inspection of structural steel.
Contrary to the above, the following activity was not accomplished in
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accordance with the prescribed inspection requirement:
5.
Paragraph 5.4 of ANSI N45.2.5 requires that bolts extend at least two
threads beyond the face of the nut. Three of the four anchor bolts
installed according to detail
"E" of drawing N0. F-39831-C for
modification of Steam Condenser anchor 39-Al, were found to have less than
the minimum required two threads beyond the face of the nut.
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Responst
1.
The contractor's Quality Control had accepted the fillet welds on drain
pipe supports Nos.: 05-SCRI-3, 05-SCRI-6, 05-SCRI-7 prior to the NRC
Inspector's findings.
Niagara Mohawk procedures require system walkdowns
on completed work prior to acceptance for service.
However, Niagara
Mohawk Quality Assurance had not yet performed their final walkdown of
these supports at the time of the NRC inspection.
Typically, after
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turnover of completed work, Quality Assurance performs final walkdowns to
assure acceptance to specifications. Because of the NRC Inspector's
timing, this action had not yet been completed.
The following corrective action has been taken.
The weld deficiencies
cited were later properly identified on Drawing Change Requests.
Calculations were performed using this shorter weld length.
These were
reviewed and approved by Niagara Mohawk Design Engineering as not
affecting the structural integrity of the support.
This information is
currently being incorporated onto as-built drawings.
2.
Corrective action taken with respect to the dimensional discrepancies
identified by the NRC is as follows:
a.
Drawing Change Request (DCR) was issued.
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b.
Pipe Stress analysis model was rerun with the changes.
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The reanalysis showed all stresses to be within allowable limits and was
completed prior to final acceptance of the system for operation. This
information is currently being incorporated onto as-built drawings.
3.
Design drawing No. F-39831-C specified that A490 bolts be used for the
connection between two' braces and the wall embedded plates of pipe support
39-Al.
Prior to the NRC inspection, our Structural Engineering Department
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had identified during a field walkdown that a mixture of A325 and A490
bolts were used. The corrective action taken was to replace all A325
bolts with A490 bolts prior to startup.
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4.
This item relates to the dismantling of a conduit support without a
Modification Work. Request or referenced documentation.
The conduit hanger
in question was supported from a section of anchor 39-Al which required
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removal as part of a modification on the Emergency Condenser System, for
which a Modification Work Request had been initiated. The dismantling of
the conduit hanger was necessary in completing the modification to anchor
39-Al and therefore, was within the scope of the Modification Work
Request.
However, no reference documentation was initiated for the
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purpose of tracking and ensuring that the hanger was remounted. The
Electrical Department was notified and the hanger was reinstalled prior to
plant startup.
In addition, isolation valves 201-32, 201.2-03 and
201.2-32 were all stroke time tested in accordance with surveillance test
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N1-ST-R8 prior to startup.
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5.
Engin:ering DCR N1Yl83M4043LG041 addrsssed thm condition that tha bolt was
flush with the nut base on 3 of 4 anchor bolts on support 39-Al.
Subsequent to the NRC inspection, corrective action of an analytical
nature was taken to ensure that structural integrity was maintained,
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assuming the bolt strength was reduced to account for 2 threads lost from
nut engagement. Calculation S14-39-Al shows that support 39-Al is
adequate for original design loading.
Long term corrective action is described in response to Weakness Items A, B
and C of this report.
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Nitice cf Violation Item C
Criterion VI of Appendix B to 10CFR50 requires the establishment of measures
to control the issuance of documents such as procedures and drawings,
including changes thereto, which prescribe all activities affecting auality.
It also requires that these measures assure that documents including changes,
are reviewed for adecuacy.
Section 6.0 of Nine Mile Point Nuclear Station
Quality Assurance Program reiterates the same requirements regarding the
issuance and review of documents including changes thereto.
Contrary to the above, the drawing for the modification of Emergency Condenser
drain piping supports No. 05-SCRI-3 and 05-SCRI-6 inaccurately depicted the
existing support-configurations such that installation of the modifications
could not be performed as specified on the drawings. Field design changes
were performed to modify the supports without properly processing the
changes. The changes to the modified installations were neither documented
nor incorporated in the respective drawings.
Response
The configuration of the two supports is similar.
The inaccuracy described
above is in regard to the orientation of a structural angle on each support.
Corrective action included issuance of DCR N1Y83M4043 LG044.
These changes
will be incorporated onto the as-built drawings.
The structural design
calculations are not affected by this inaccuracy.
Long term corrective action is described in response to Weakness Items A, B
and C of this report.
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Notice ef Violation Item D
Criterion X of Appendix B to 10CFR50 requires the identification of specific
hold points in appropriate documents when mandatory inspection hold points which
require witnessing or inspection are required.
Section 10.0 of Nine Mile Point
Nuclear Station Quality Assurance Program reiterates the same requirements for
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the identification of inspection hold points.
Section 3.6 of the Functional
Specification for the Emergency Condenser Modification invokes the requirements
of the Structural Welding Code (D1.1) of the American Welding Society (AWS).
Contrary to the above, hold points were not established, and in-process
inspection was not performed for fit-uL of structural attachments to base plates
for piping supports No. 39-SR2, 39-SR6 and 39-SR7.
The connection of the
structural attachments to the base plates required "all-around" welds which made
it impossible to perform verification of fit-up between the parts joined af ter
completion of the welds. Section 3.3 of AWS Dl.1 welding code requires that the
fit-up be inspected prior to completion of the weld.
Response
Our interpretation of Section 3.3 of AWS Dl.1 Structural Welding Code is that it
does not require fit-up inspection but does require that parts joined by fillet
welds be brought into as close contact as practical but not separated by more
than 3/16".
It also requires that fillet weld sizes be increased by the amount
of separation when it exceeds 1/16".
It is general practice to establish hold
points for welds that are' difficult, as determined by the engineer. The welds
described above were not considered to be difficult, because they are fillet
The contractors procedure entitled " Seismic Support / Restraint Installation for
Safety Related Work," has a Quality Control Inspection Signoff for AWS D1.1-77
acceptance criteria.
Ther'e were no specific hold points by OC for AWS D1.1-77
welding code criteria. Niagara Mohawk Power Corporation believes that the
combination of construction drawing requirements, employment of qualified
welding procedures and qualifiedo experienced welders appropriately assured
adequate structural welding practices, along with final visual inspection by
Flagg Quality Control. Niagara Mohawk Power Corporation Quality Assurance has
also inspected the restraints in question to ensure physical integrity and
conformance to design.where appropriate.
Niagara Mohawk Quality Assurance has developed and approved a surveillance
checklist including AWS Section 3 attributes that will be used on future
restraint / support work when evoking the AWS D1.1 welding code. The checklist
will be used on a sampling basis when reviewing contractor welding activities.
Use of the checklist will help assure that contractor activities are conducted
in compliance with code requirements or appropriate corrective action will be
taken.
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WQakness Item A
Contractor Quality Assurance
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Several deficiencies were identified during the inspection of the Emergency
Condenser piping modifications. When these deficiencies are viewed
collectively, they indicate an apparent weakness in the contractor's quality
assurance inspection program. Further, examination of Niagara Mohawk
surveillance reports of construction activities performed by the contractor
indicated that several deficiencies were identified during these inspections
and were subsequently corrected by the contractor.
It did not appear,
however, that the Niagara Mohawk surveillance program was sufficiently
effective in addressing the root cause of these deficiencies to prevent their
recurrence.
Response
The Niagara Mohawk Quality Assurance surveillance program identified several
deficiencies in the contractor's Quality Assurance Program during nodification
activities on the Emergency Condenser Piping Replacement Project during the
1986 Refueling and Maintenance Outage. When assessed collectively, these
deficiencies do appear to identify weaknesses in the contractor's Quality
Assurance Program.
In order to enhance the methods previously employed by
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Niagara Mohawk Quality Assurance in assessing the contractor's progran
effectiveness, Niagara Mohawk will revise the Quality Assurance surveillance
procedure to require Niagara Mohawk identified installation contractor
deficiencies to be addressed directly via Nonconformance Reports / Corrective
Action Reports (NCR's/ CAR's).
Provisions in the Niagara Mohawk Quality
Assurance surveillance program will provide for ongoing assessment of the
identified deficiencies by the Quality Assurance Program Manager.
The
activities described will allow for more effective ongoing assessment of
installation contractor's Quality Assurance Programs. Revision of the Niagara
Mohawk Quality Assurance surveillance procedure will be completed by December
31, 1986.
Niagara Mohawk procedures require system walkdowns on completed work prior to
acceptance for service. Based on these walkdown results, Niagara Mohawk has
assured satisfactory adherence to specifications on work completed during the
1986 Refueling and Maintenance Outage. An overall review of the performance
of contractors who performed safety related work during the 1986 Refueling and
Maintenance Outage verifies that the extent of program weaknesses was not
widespread, but was unique to one contractor.
After review, Niagara Mohawk
Quality Assurance believes that the root cause of the problems identified on
the Emergency Condenser Piping Replacement Project was the lack of adequate
program implementation on the part of the contractor.
It appears that the
contractor's written program was adequate, but that training of personnel to
program requirements and program implementation need to be improved.
Niagara
Mohawk Quality Assurance recognizes that more aggressive action must be taken
in the future to correct installation contractor program problems when they
are identified in order to prevent repetitive findings.
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Waakness Item B
Desian Verification Process
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The design verification process is not clearly described in the procedures.
Specific deficiencies include:
Inadeauate guidance specifying when a modification does or does not
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require a design verification;
Inadequate definition of the scope and depth of the design verification
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review;
Inadequate guidance regarding the types of documents tha* should be
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reviewed during the design verification; and,
Inadequate definition of what should be. included in the design
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verification report.
Response
The inspection report discussed several deficiencies identified by members of
your staff in our design verification process and associated procedure. As
discussed in your report, Niagara Mohawk had already performed a
self-appraisal of its design verification activities in support of
modifications installed daring the Nine Mile Point Unit 1 1986 Refueling and
Maintenance Outage.
The self-appraisal identified several areas for
improvement. These deficiencies along with those identified by members of
your staff will be evaluated by Niagara Mohawk for resolution.
The corrective
action resulting from this evaluation will be implemented in a timely manner
to support design verification efforts associated with modifications currently
planned for the Nine Mile Point Unit 1 1988 Refueling and Maintenance Outage.
If the need arises to perform a multi-disciplined design verification prior to
full implementation of the corrective action resulting from our internal
review, it will be done in accordance with established procedures. Special
attention will be paid to those areas identified by our self-appraisal and
your inspection report to ensure the design verification process is
accomplished in the proper marcer.
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Wakness Item C
Procedure for Modification and Addition
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Your procedure for Modification and Addition, AP 6.0, has certain weak areas.
These deficiencies include:
Lack of clarity regarding when SORC approval is required. The current
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procedure is ambiguous with regard to the need for S0RC approval for the
modification final design.
A deficiency regarding the interf ace between corporate and site
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personnel.
Currently the procedure specifies that the design organization
shall meet with site personnel to review the preliminary design.
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Additional corporate site interf ace measures such as preliminary design
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installation walkdown to identify possible interferences, and to avoid the
need for numerous design change requests would improve this interface.
Inadequate specification for placing the necessary marked up drawings in
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key areas such as the Control Room, Technical Support Center, and the
Emergency Offsite Facility, during the interim period from the turnover of
the system to the completion of the final updating of the controlled
copies of the as-built drawings.
Response
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Site Administrative Procedure AP6 is currently under review to identify or
resolve deficiencies based on experience gained during the 1986 Refueling and
Maintenance Outage. The weaknesses identified above will be addressed during
this review process.
Thit revision will be completed such that deficiencies
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of these types will not be repeated for modifications planned for the 1988
Refueling and Maintenance Outage.
Specifically AP6 will be revised to include, but not limited to:
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1.
Clarification as to when SORC approval of modification final design is
required.
2.
Provide instructions for Engineering and Site Technical Department to
perform plant walkdowns prior to and during modification installations.
3.
Provide instructions and identify the responsible department for
maintaining controlled marked-up P& ids and electrical drawings. These
drawings shall be kept in the Control Room, Technical Support Center and
the Emergency Offsite Facility during the period from system turnover to
the final updating of controlled copies.
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