ML20040B274

Responds to NRC 811116 Ltr Re Violations Noted in IE Insp Rept 50-423/81-12.Corrective Actions:Audit of All Site Drawing Stations Conducted & Discrepancies Corrected. Requests That Item B Be Redesigned to Level V Violation

ML20040B274
Person / Time
Site:	Millstone
Issue date:	12/16/1981
From:	Cagnetta J, Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20040B273	List: ML20040B274
References
A02119, A2119, AEC-MP3-256, NUDOCS 8201250341
Download: ML20040B274 (4)

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l December 16, 1981 Docket No. 50-423 AEC-MP3-256 A02119 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 50-423/81-12, dated November 15, 1982.

Centlemen:

Millstone Nuclear Power Station, Unit No. 3 IE Inspection No. 50-423/81-12 On September 28-30, 1981 and October 1-23, 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/

81-12.

Pursuant to the provisions of 10 CFR 2.201, 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 reconsideration of one of these items as described later, herein.

8201250341 820112 PDR ADOCK 05000 0

Violation Appendix A paragraph A stated that on August 29, 1981, Stone & Webster field quality control verified that the completed action to disposition of Non-conformance and Disposition Report No. 0529 was acceptable, when in fact, it was not. Eight previously identified weld defects as-sociated with this N&D had not been corrected as required.

Corrective Action The defects identified on N6D 0529 which had not been corrected have been reidentified on N&D 0991. The N6D has since been dispositioned

" Accept as Is."

Preventive Action The need to completely review all facets of N&D condition and dis-position details prior to closing N&D's has been emphasized with inspection personnel as applicable. Closer supervision of these activitics has been initiated.

Violation Appendix A, paragraph B stated that on October 9,1981, twelve drawings at station Nos. 40, 44, and 58 were not correct and up to date.

Corrective Action The incorrect conditions identified in Inspection 81-12 were promptly corrected in the following manner.

a. (4) Incorrect ELDCR postings were voided from the drawings.

b. (8) Issued ELDCR's were posted as required.

c. (3) E6DCR's filed improperly were corrected.

d. (1) E6DCR not posted was found not applicable,

c. (1) Obsolete revised drawing was removed frem the station.

An audit of all site drawing stations was conducted to insure that all drawings issued have the current revision and changes posted to them.

The audit revealed a 9% error. All discrepancies were promptly corrected.

Preventive Action

a. A log has been developed by document control for all new re-visions and changes, and Field Quality Control is verifying the posting of changes to the appropriate documents.

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b. All drawing stations have been reviewed for drawings no longer required and those identified have been purged from the stations.

c. Drawing stations are being reviewed to consider reducing the number of stations required. Requests for new stations have been denied.

d. Engineering personnel have been instructed to use consistent terminology such as void, modify, supersede, etc., as identified in the engineering assurance procedure 6.5, Paragraph 5.2.2.

Changes not using the correct terms will be rejected.

e. Engineering personnel have been instructed to legibly print and provide consistent location on change documents. The site control personnel have been instructed to review incoming documents for legibility / readability and return those that are not.

l In evaluating paragraph B and the assigned severity level, Northeast

! Nuclear Energy Company finds the severity level IV designation to be too severe. We, therefore, request that the Staff consider l redesignation of this to a level V violation. A level V designation

{ would be more appropriate in this instance because corrective actions i were implemented immediately and Stone and Webster has a requirement j and a procedure to assure that changes or work required by engineering i and design change requests have been completed. All changes are tracked and completion of work is verified by Field Quality Control.

This procedure, Quality Control Instruction FH 3-36.1-02B, has been in effect since March 1, 1978.

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

Very truly yours, NORTilEAST NUCLEAR ENERGY COMPANY i

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W. G. Counsil Senior Vice President 7 M/9t_ /

By: J.'P. Cagnet '

Vic- resident Nu ear and Environmental Engineering

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cc: Mr. Ronald C. Ilayacs j Region I Office of Inspection and Enforcement l U. S. Nuclear Regulatory Commission l 631 Park Avenue

'. King of Prussia, PA 19406

! Mr. James 11. Snlezek, Director i Division of Resident and Regional Reactor Inspection j office of Inspection and Enforcement I j U. S. Nuclear Regulatory Commission

Washington, DC 20555 s

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