ML20038D023

Responds to NRC 811019 Ltr Re Violations Noted in IE Insp Rept 50-423/81-11.Corrective actions:re-audit Number Assigned & Audit Performed.Work Areas Cleared of Copier Prints & Personnel Trained

ML20038D023
Person / Time
Site:	Millstone
Issue date:	11/19/1981
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20038D019	List: ML20038D023
References
AEC-MP3-249, AO2066, NUDOCS 8112140347
Download: ML20038D023 (3)

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'::::::::.':"l,: :'""~ awwson L L ;  : n :... J . O ll' November 19, 1981 Docket No. 50-423 AEC-MP3-249 A02066 U. S. Nuclear Regulatory Commission Mr. E. J. Brunner, Chief Projects Branch No. 1, Division of Resident and Project Inspection Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406

Reference:

(1) E. J. Brunner letter to W. G. Counsil, IE Inspection 50-423/81-11, dated October 19, 1981.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 IE Inspection No. 50-423/81-11 On August 20-31, 1981 and September 1-25, 1981, the NRC Office of Inspection and Enforcement conducted a routine safety inspection of selected areas of Millstone Nuclear Power Station Unit No. 3. As a result of that inspection, Reference (1) was transmitted to us for response. That transmittal contains essentially two parts: Appendix A, Notice of Violation and IE Inspection Report No. 50-423/81-11.

Pursuant to the provisions of 10CFR2.201, Northeast Nuclear Energy Company hereby is submitting a response to the Notice of Violation, Appendix A, paragraphs A and B. NNECO also hereby requests NRC re-consideration of one of these items as described later, herein.

Appendix A, paragraph A stated that an adverse finding from QA Audit Report No. A40571, which was identified for re-;udit, was not re-scheduled in the audit / survey and inspection cesputer program with an appropriate date and number. A review of the NUSCO audit / surveil-lance followup schedule, dated September 17, 1981, indicated that the adverse finding was closed on May 21, 1981.

8112140347 811203 PDR ADOCK 05000423 G PDR

Corrective and Preventative Action Audit No. A40571 was identified for re-audit by the auditor but the auditor had not identified the re-audit number or date on the NUSCO i Computer Program. The re-audit number is A0610 and was performed l the week of October 19, 1981. All necessary changes have been noted l

on both the audit survey computer program and the findings have been i placed on the audit deficiency follow-up program. To prevent re-occurrence of this violation the NCQA Section personnel have been re-instructed in the requirements of NQA 1.14 and associated computer programs.

Appendix A, Paragraph B stated that two electricians were observed in the engineered safety features building erecting scismic supports on a cable tray using an unauthorized copier print of portions of de-sign drawing EE-34JA.

Corrective Action To ensure all work areas are purged of any uncontrolled Level 1 docu-ments the Superintendent of Construction directed all personnel to do so and remain viligant in this effort to ensure that any over- looked previously, are removed. Additionally Field QC personnel conducted a randam check of various construction work areas to ensure un-controlled design documents were removed.

Preventative Action To prevent reoccurrence in the future, a training course on the re-production of documents and the control of Level 1 documents is currently being presented to all Construction, Engineering and Quality Control personnel. Also, copy machines in the " area" offices were fitted with a permanent decal on the glass stating "This Document is not to be used for Construction" and Notices were posted adjacent to or on all site copy machines prohibiting reproduction of Level 1 documents unless authorized by the Document Supervisor.

In evaluating paragraph B and the assigned severity level, Northeast Nuclear Energy Company finds the severity level IV designation to be too severe. We hereby formally propose that the Staff redesignate this as a level V Violation. We recognize that corrective action in this isolated instance is required to maintain our current pro-cedures that regulate Level 1 drawings used for construction, and we have acted to do so. However, we maintain that our existing procc-dures provide for an additional level of inspection which would ultimately identify any possible isolated cases where unauthorized copies of design drawinga were used in construction. Specifically, Stone and Webster QC performs an inspection of completed construction against control copies of Level 1 drawings and therefore any non con-formances would be identified and corrected.

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Northeast Nuclear Energy Company requests that the NRC inform us of the results of your reconsideration of this matter. We trust the corrective actions describe above satisfactorily respond to the violations cited by your resident inspector.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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W.'G. Counsil Senior Vice President cc: Mr. Ronald C. Haynes Region 1 Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. Harold D. Thornburg, Director Division of Reactor Construction Inspection Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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Then personally appeared before me W. G. Counsil, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said infctmation are true and correct to the best of his knowledge and belief.

1 h. J Notary Public My Commiscon Expire: March 31,1986 If , .