ML17037B871

Letter Regarding a Breakdown in the Graver Tank & Manufacturing Company'S QA Program and an Enclosed Report Providing a Description of the Deficiency, Analysis of the Safety Implications, and Corrective Action Taken

ML17037B871
Person / Time
Site:	Nine Mile Point
Issue date:	02/06/1978
From:	Rhode G Niagara Mohawk Power Corp
To:	Robert Carlson NRC/IE, NRC Region 1
References
Download: ML17037B871 (10)

Text

REGULA T'OR Y INFQRNA TIQN DISTR I BUT I'QN SYSTEH (RIDS)DISTRI6UTIOh'OR INCOMING MATERIAL 50i410 RECg CARLSON R T QRGS RHQOE G K DQCDATES 02/06/78 NRC NIAGARA MOHAWK PWR DATE RCYDS 02/13/78 DQCTYPE!I.ETTER NOTARIZED I NQ COPIES RECEIVED SUBjlE('T i LTR 0 ENCI.1 FINAl, DEFICIENCY REPT INCL.UDING CORRECTIVE ACTIONS RE BREAKDOWN IN THE GRAVEN lANK 8 MANUFACTURING CO'lS QUALITY ASSURANCE PROGRAM CQNCEANING CONDITION 1NVOLYING FIELD ERECTION IOF UNXT 2 CONTAINVENT LINER~Pl.ANT NAME CANINE NILE POINT" UNIT'2 REVIEWER INITIAL!5 JH DISTRIBUTOR INITIAL i*w**+4w**~*WAN*aw DISTRIBUTION OF THIS NATERIAL IS AS FOLLOWS-*a4eew>*4*wAaa*4~a CONSTRUCTION DEFICIENCY REPORT (10CFR50,55(E), (DISTRIBUTION CODE BOOED)FOR ACTIONS ASST DIR'VASSALLU+wLTR ONI.Y BRANCH CHIEF VARGA+4LTR ONLY PR TR ONLY L I C A S 8 I i S E R V I C E 0*L." T R lQ N I'INTERNAL!, E)(TERNALI G FT-Br+W I S, E~~W/P.EACl.GQSSICK 8 STAFF<<LTR ONLY HQYD*ALTR'ONLY HEl TEVES*+W/ENCL KN?GHT**L.TR ON[,Y TEDESCQ~*LTR IGNI,Y STANDARDS l)EYe<>4/ENCL LPPR I 8 ,'OSWEGO'Yw~W/ENCL TICWAH/ENCL NSIC*ak/ENCl ACRS CAT B*~b/16 LTRS NRC PDRa*W/ENCL VELD~*LTR~ONLY HIPCa*y/ENCL DEYQUNG*A'W/ENCL R, NATTSQN**LTR ONLY ROSSa+LTR ONLY EISENHUT~~LTR ONLY SEYFRIT/IEwwH/ENCL I.DISTRIBUTION!

LTR 40 ENCL, 28 SIX(~1Pt5P CONTROL NBRI 780460032 t'I 0~'h lt t ti I f N 4 II 1 Nl ll~it I'u t I)'4 it-I 2'N ll t LI'N W 4,';I IN Ny.4~tg P 4 II Y If 4'I I I I I\, Ig 1r 4 44 I f g 1 tt,dt tl l~o" lt I I'At 4',tt H*lt NN tlMll9mltIJatlÃB FNF gP Lm'W NIAGA A Pl U MOHAWK NIAGARA MOHAWK POWER CORPORATION/300 ERIE BOULEVARD WEST, SYRACUSE, N.Y.13202/TELEPHONE (315)474-1511 February 6, 1978 Office of Inspection and Enforcement Region I Attention:.Mr.,R.T.Garison, Chief Reactor Construction and Engineering Support Branch U.S.Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406'<~ling~~i S~p~i 1918 CI1 O 8 Re:.Nine Mile Point Unit 2 Docket No.50-410

Dear Mr.Garison:

On December.23, 1977, your staff was.advised of a breakdown in the Graver Tank&Manufacturing Company's Quality Assurance Program.This condition involved field erection of the Nine'ile Point Unit 2 containment liner.As indicated in.our January 24, 1978 letter, attached is a final report providing a description of the deficiency, and analysis of the safety implications and the corrective action taken.This report is submitted in accordance with Section 50.55(e)(3) of the Commission's regulations.-

Very truly yours, NIAGARA MOHAWK POWER CORPORATION I 7 Geral.K.Rhod , Vice President System Pro)ct Management PEF/szd~o46OO32 Attachment Xc:.Ernst Volgenau Inspection

&Enforcement Branch U.S.Nuclear Regulatory Commission Washington, D.C.20555 Boaq 0/

I~~go g Stone.&Webster'.s Field Quality Control group in accordance with their Quality Verification of Graver's Quality Program issued seven unsatis-factory Inspection Reports and two Nonconformance and Disposition Reports during a five week period ending December 15, 1977.A review of these reports revealed the following deficiencies:

A..Contrary to 10CFR50 Appendix B Criterion VI (DOCUMENT CONTROL)work,was being performed utilizing a procedure, for temporary attachment removal that,had not been approved by Stone and Webster Engineering.

B.Contrary to 10CFR50 Appendix B.Criterion IX-(CONTROL OF SPECIAL PROCESSES) a welding procedure was beingused that was not qualified.

for the application (i.e., welding was being performed on cladding thinner than specified in the procedure).

In addition, required, nondestructive testing was not being performed to verify defect removal prior to welding.C.Contrary to 10CFR50 Appendix B Criterion X (INSPECTION), Graver's Quality Control group was not documenting their inspection (review and acceptance) of repair welds performed as a result of removal of temporary attachments.

D.Contrary to 10CFR50 Appendix B.Criterion XVI (CORRECTIVE ACTION), measures were not initiated to correct conditions identified by Stone and Webster Field Quality Control above as being adverse to quality.After.they had been instructed to do so by Stone and.Webster Engineering, Graver did.not document their inspection of repair welds, use the procedure identified by Stone and Webster as applicable for clad'less than 1/16" thick, and they did not follow their procedure for temporary attachment removal as approved.II.SAFETY ANALYSIS The primary containment clad material and its function are described in Section 5.0 of the Preliminary Safety Analysis Report.The clad forms an integral, part of the base material of the primary containment liner.The clad surface is designed to.provide corrosion protection of the base material and preclude.contamination.

from the suppression pool water.The cladding is not required for.the design strength or leak integrity of the primary containment liner.The weld repair cavities did not expose the carbon steel base metal.Therefore, this, does not result in a safety hazard to Nine Mile Point Unit 2.The weld repairs do not jeopardize the corrosion resistant performance of the clad or the primary containment liner design requirements.

E~f III.CORRECTIVE ACTION The following actions have been taken to correct the deficiencies identified in Section I: A.A procedure for temporary attachment removal has been reviewed and approved as of November 22, 1977.B.Stone.and Webster has reviewed the applicability of welding procedures.

for clad surface weld repairs.The appropriate welding procedure in question was found acceptable as it was in accordance with the ASME code required by purchase specification.

Also, clad surface weld repairs were all liquid penetrant inspected and accepted.C.The procedure for temporary attachment removal provides for the initiation of a temporary weld data sheet to,document the weld procedure used and Quality Assurance sign-off.D.On January 4,.1978, a meeting was held at Stone and Webster'Cherry Hill Operations Center with Graver Management.

to discuss these'eficiencies.

As a result of this meeting, the following actions have or will be taken: 1.Graver has prepared a supplement to the Nine Mile Quality Assurance Manual which,has been reviewed and accepted.It is anticipated that this supple-ment will be issued shortly.This supplement establishes a system to assure that conditions adverse to quality such as audit, findings, deficiencies, deviations from procedures, failures, malfunctions and nonconformances are identified, corrected and documented.

The procedure will require a response from the affected party and will also require periodic management review of corrective actions.

z r 2.Graver will be supplementing itsgQuality Assurance activities by adding a permanent Quality Assurance representative to the Nine Mile field crew.In addition to his defined Quality Assurance responsibilities, he will provide an additional~intertace>with<Stone and Webster Field Quality Control.~~~"<"~0 3.As of January 16, 1978, Graver has assigned a Quality Assurance Management individual to the Nine Mile site on a temporary basis.This individual will review the activities at the site and, report to Graver management on the progress of Quality Assurance and site activities.

4.The appropriate Construction Interface Procedure will be revised to reflect a workable Inspection Report and Nonconformance

&Disposition Report interface between Graver and Stone and Webster.Stone and Webster Field Quality Control will increase their surveillance of the Graver Quality Assurance Program and report to Stone and Webster Project Management and Niagara Mohawk on the progress, and effectiveness of Graver's Quality Assurance site activities.

RECEIVEO OOCOHEHT CON IROL GEST 19tGFB 15 PQ 200 U.S.NRC OISTRIBUTION SERVICES BRANCH