ML20207S424

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-220/86-07

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

Text

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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 /

OFFICIAL RECORD COPY RL NMP1 - 0001.0.0

01/15/87 i)I

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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

DPR-63

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

i accommodate the additions indicated above as well as future additions. A

l 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

on the emergency bus and included a tabulatio7 of the same. The results

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demonstrated inc adecuacy of the system.

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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. ,,,-

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 <-

insufficient power rating to perform their safety function.

Response -

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

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establishment and implementation of written procedures and administrative

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.

i 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

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N0. 05-SCRI-3, 05-SCRI-6, and 05-SCRI-7 show an addition of a plate welded

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 -

l piping installations in the above cases indicated the as-built

. measurements are l'-0" and l'-2", respectively.

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

l 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 -

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

turnover of completed work, Quality Assurance performs final walkdowns to

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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.

! 4. This item relates to the dismantling of a conduit support without a

Modification Work. Request or referenced documentation. The conduit hanger

i in question was supported from a section of anchor 39-Al which required

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

l 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

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201.2-32 were all stroke time tested in accordance with surveillance test

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

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nature was taken to ensure that structural integrity was maintained,

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

Section 3.6 of the Functional

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the identification of inspection hold points.

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

welds with carbon steel.

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 -

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

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Desian Verification Process

The design verification process is not clearly described in the procedures.

Specific deficiencies include:

- Inadeauate guidance specifying when a modification does or does not

require a design verification;

- Inadequate definition of the scope and depth of the design verification

review;

- Inadequate guidance regarding the types of documents tha* should be

reviewed during the design verification; and,

- Inadequate definition of what should be. included in the design

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

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

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

personnel. Currently the procedure specifies that the design organization

, shall meet with site personnel to review the preliminary design.

l Additional corporate site interf ace measures such as preliminary design

installation walkdown to identify possible interferences, and to avoid the

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need for numerous design change requests would improve this interface.

- Inadequate specification for placing the necessary marked up drawings in

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

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this review process. Thit revision will be completed such that deficiencies

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:

i 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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