IR 05000443/1979008

IE Insp Repts 50-443/79-08 & 50-444/79-08 on 790904-07. Noncompliance Noted:Failure to Provide Details of Procedure for Reaudit of Open Items & Provide Details in Surveillance QA Procedure

ML19260D348
Person / Time
Site:	Seabrook
Issue date:	11/01/1979
From:	Gage L, Gallo R, Mcgaughy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19260D344	List: IR 05000443/1979008 ML19260D345 ML19260D346 ML19260D347
References
50-443-79-08, 50-443-79-8, 50-444-79-08, 50-444-79-8, NUDOCS 8002080405
Download: ML19260D348 (10)

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F U.S. NUCLEAR REGULATORY COMMISSION

0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-443/79-08 Report No. 50-444/79-08 50-443 Docket No. 50-444 CPPR-135 License Nc. CPPR-136 Priority Category A

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Licensee:

Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 Facility Name:

Seabrook Station, Units 1 and 2 Inspection at:

Seabrook, New Hampshire and Yankee Atomic Electric Company in Westborough, Massachusetts Inspection conducted:

September 4-7, 1979

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II l h4 Inspectors N-

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J. Mattia, Rpctor Inspector da'te' sighed g4 Of A n /il79 R. Gallo, R,eactor Inspector date ' signed

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L. Gage,* Reactor Inspector date signed C

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P. Kolt4y, Rea r Inspector d6te' signed

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Approvedby:pr.

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ll 1[79 R. W. McGaughy, Chief, Projects Section, dat'e signed RC&ES Branch Inspection Summary:

Inspection on September 4-7, 1979 (Report Nos. 50-443/79-08 and 50-444/79-08)

Areas Insoected:

Routine, unannounced inspection by four regional based inspectors of construction activities.

The inspection involved the review of the QA program of various organizations involved with the Seabrook Station.

The inspection involved 96 inspector-hours by four regional based inspectors.

Results:

Of the one area inspected, two apparent items of noncompliance were identified in the area inspected (Infraction - fai'ure to provide details in YAEC procedure for reaudit of open items, Paragraph 3.c; failure to provide details in UE&C surveillance QA procedure for when to verify that prompt corrective action was taken, Paragraph 4).

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DETAILS 1.

Persons Contacted

_Y d ee Atomic Electric Company F. W. Bean, QA Engineer

• B. B. Beckley, Manager of Nuclear Projects (Manchester)

• D. L. Covill, QA Engineer W. J. Gagnon, QA Engineer D. Groves, QA Engineer (Westborough)

• J. H. Herrin, Construction Manager

• J. Mcdonald, Jr., QA Engineer (Westborough)

• W.J. Miller,QAManager(Westborough)

W. Peterson, QA Engineer (Westborough)

R. P. Pizzuti, Construction Manager (Westborough)

• T. M. Sherry, Director of Construction (Westborough)

• J. W. Singleton, Field QA Manager United Engineers and Constructors T. P. Vassallo, QA Supervisor N. A. Vitale, QA Supervisor L. R. Wade, QA Administrative Assistant Pittsburgh Des Moines W. Stiger, Site QA Superintendent Perini Power Corporation P. Antonich, Assistant Supervising QA Engineer P. Bruce, Supervising QA Engineer W. Dileo, Project Manager G. Meyers, Liaison Engineering F. Smith, Chief Auditor

• cenotes those present at the exit interview.

2.

Yankee Atomic Electric (YAEC) OA Audits (Units 1 and 2)

The inspectors reviewed audits conducted by the YAEC (Westborough) QA organization of the various Seabrook site organizations involved in safety related activities, to determine if the audits were conducted in accordance with YAEC QA Manual Procedures 8.1 and 9.1.

The inspectors reviewed the following audits:

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a.

YAEC Audits of UE&C Site Activities SA 227 CS 044

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SA 192 CS 034

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SA 184 CS 031

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In Audit Report SA 184 CS 031. UE&C was cited for permitting concrete sampling from concrete portions that were not widely separated.

UE&C site QA Supervisors concurred with the audit results and committed to take corrective action.

However, the subsequent UE&C answer to the formal audit report, from their home office, indicated that the audit finding was in error:

ASTM-C172-71, had not been properly interpreted by the auditors.

The inspector pointed out that the UE&C site QA supervision had not properly interpreted ASTM-C172-71 either, and he questioned whether the UE&C site QA had adequate training / experience in the application of the ASTM specification.

This item is considered to be unresolved pending a review of a YAEC investigation of UE&C site QA credentials, by a NRC inspector during a subsequent inspection (443 & 444/79-08-01).

b.

YAEC Audits of UE&C Home Office Activities SA 175 UE 07

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SA 140 UE 06

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SA 111 UE 05

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In Audit Report SA 140 UE 06, UE&C was cited for accepting a particular vendor's testing manual without requiring a specified minimum test temperature.

In addition, UE&C was requested to review all other vendor manuals to check if their calibration procedures address the uncertainty (error) requirements of calibration.

UE&C responded by agreeing to:

(1) request that the particular vendor revise his testing manual, and (2) review all other vendor manuals (by May 31, 1979) for calibration-error requirements.

The inspector requested YAEC to provide evidence that UE&C had satis-factorily accomplished these commitments.

YAEC was not able to provide such evidence at this time.

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This item is considered to be unresolved pending a review of the YAEC followup to the UE&C commitments, by an NRC inspector during a subsequent inspection (443 & 444/79-08-02).

c.

YAEC Audits of Perini Power Constructor and Also Internal Audits Of YAEC Activities SA 172 CS 028

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SA 185 CS 032

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SA 108 PG 02

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SA 212 PG 03

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The inspector reviewed the method of verification of correction of items identified during the aforementioned audits.

The inspector found that the verification system used by YAEC varied from one audit to another.

In one case, a note on a computer printout that corrective action had been verified was used; in another case, an item was identified in a subsequent audit as being " closed out," but no information was provided to allow the inspector to determine how the verification of the corrective action had been accomplished.

Specific items identified by the inspector as having inadequate docu-mentation to verify that corrective actions had been taken included:

Audit SA 172 CS 028, items 0053 and C055.

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Audit SA 185 CS 032, items 0109, 0110, 0111, 0113, 0114, 0116, and 0117.

Failure to provide a written record of the verification of corrective action is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVIII, and the Seabrook PSAR, Section 17.1.18 (443 & 444/79-08-03).

d.

YAEC Audits of Pittsburgh Testing Lab (PTL) Site Activities SA 186 CS 033

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SA 186 CS 039

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SA 194 CS 036

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The inspector found that for two of the above audits (039 and 036) the PTL responses (PTL Letter Codes #380 and 365) to the audit findings were transmitted to YAEC by UE&C (Note:

PTL is a subcontractor to YAEC), two to three months after PTL submitted them.

YAEC 0A stated that this has been a common problem and had been identified by them.

This also has been discussed with UE&C and corrective action has been initiated. The inspector reviewed a Yankee " Notes of Conference,"

adted August 27, 1979 (Code No. QA-Y-017), where recent discussions had been held on this subject.

The inspector informed the licensee that this item is considered unresolved pending review by NRC that corrective action has been instituted (443 & 444/79-08-04).

e.

YAEC (Westborough) Audits of YAEC Field QA Activities SA 086 F0 02

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SA 115 FQ 03

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The inspector noted that in Audit SA 115 F0 03 there were no deficiencies found by YAEC Auditor, but there were two findings which were categorized as an observation. The observations were recommendations to the audited o qanization to revise a " form" and change a " procedure." The licensee letter, dated July 24, 1978, which transmitted the report to field QA organization stated that there were no deficiencies, therefore, no response was required.

The inspector asked if the recommendations were followed by the field QA organization.

YAEC QA stated that they did not know since it was not a requirement, that the field QA make the recommended changes.

The inspector stated that the YAEC QA Procedure did not define what an observation was in terms of an audit finding.

The licensee produced a YAEC OA memorandum, dated June 1, 1977, which defined three audit findings ("Nonconformance, Deficiencies, and Obser vation") categories.

The inspector was informed by the QA Manager that the "nonconformance" category of audit finding was no longer used by them. The inspector informed the YAEC QA that these categories of audit findings and their definitions should be incorporated in their QA procedure. This item is unresolved pending review by the NRC and revised YAEC QA Procedure (443 & 444/79-08-05).

f.

YAEC Audits of Fishbach-Boulos-Manzi Site Activities SB 479 (dated April 15,1979)

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SA 220 CS 042 (dated July 25,1979)

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During this review, no items of noncompliance were identified.

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g.

YAEC Audit of Pullman Power Products Corporation Site Activities SA 145 SC 18 (dated October 18, 1979)

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During this review, no items of noncomplian;e were identified.

3.

Perini Power Constructors Quality Assurance Program Implementation Units 1 and 2 The inspector reviewed the Perini Power Constructors Site QA Program to verify conformance with PSAR commitments, NRC requirements, and site speci-fications.

The inspector reviewed the Perini Program in the following areas:

site audits, home office audits, corrective action system, noncon-formance control system, and QC inspection procedures and records.

Procedures and specifications reviewed during this inspection included:

UE&C Specifications QAS-1, Revision 4; l-1, Revisicn 4; and,13-2,

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Revision 4.

Perini OA Procedures (QAP's) 10.1, 10.4, 10.5. 15.0, 16.0, and 18.0.

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a.

During this review, the inspector noted that the installation of water stops was addressed in UE&C Specification 13-2 and was identified as an inspection point in QAP 10.5, Exhibit A.

The inspector, however, noted that the installation instructions for the water stops were identified only in vendor documentation without direct reference in Perini Procedures.

Construction Procedure FCCP-2, Revision 3, Interim Procedure Change No.1, was issued by Perini to formally reference the vendor instructions for water stop installation.

The inspector had no further questions on this matter at this time.

b.

The inspector also reviewed site audits for June, July, and September, 1979.

Audits were scheduled and conducted in accordance with QAP 18.0.

Items identified by the Perini auditor were tracked and corrective actions verified in accordance with QAP 15.0.

The inspector also reviewed Perini Home Office Aedit QAD-1 of April 9-10, 1979, of site activities.

No items of noncoTipliance were identified.

c.

The inspector examined the control of nonconformances by Perini.

The inspector also reviewed Nonconformance Report Nos. 40, 41, 56, 57, 59, 60, 61, 70, 74, and 75, for compliance with QAP 15.0.

The inspector reviewed the Perini system for trend analysis as specified in QAP 16.0, and reviewed Trend Analysis Report Nos. 1 through 4 and Corrective Action Request Nos. 4 through 8.

No items of noncompliance were identified.

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d.

The inspector reviewed concrete lift documentation packages for confor-mance to the requirements of QAP 10.4 and 10.5.

Lift packages examined included:

1-CMG-10

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1-CM-521

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1-CM-5M

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Minor administrative discrepancies identified during this review were treated in accordance with QAP 15.0.

No items of noncompliance were identified.

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e.

The inspector reviewed cecords of safety related soils activities for service water trench and cooling towers, including surveillance reports 338, 441, 979, 545, and 615, dated from December 5. 1978 through August 7, 1979.

No items of noncompliance were identified.

UE&C Quality Assurance Surveillance Activities (Units 1 and 2)

The inspector reviewed the following UE&C surveillance reports to verify compliance with their QA Procedure QCP-10-1, Revision 2:

Report No.

Date Type of Activity 637 8/17/79 Batch Plant Operation (Perini)

629 8/14/79 Batch Plant Operation (Perini)

613 8/3/79 Batch Plan, Operation (Perini)

587 7/13/79 Batch Plar t Operation (Perini)

519 5/21/79 Batch Plant Operation (Perini)

490 4/20/79 Batch Plant Operation (Perini)

590 7/17/79 Installation of Rebar (Perini)

531 5/31/79 Installation of Rebar (Perini)

484 4/17/79 Installation of Rebar (Perini)

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291 9/28/78 Document Control (PDM)

540 6/7/79 Followup af Surveillance #291 (PDM)

314 10/30/78 Field Receiving Inspection (PDM)

374 1/9/79 Field Storage (PDM)

437 3/7/79 Document Control (PDM)

The inspectors found the following conditions:

a.

Report 490 (4/20/79) noted that item No. 6.1.l(b)--inspection of batch plant equipment for material buildup--was noted as acceptable in batch plant log, but was found to be unacceptable.

Report 637 (8/17/79)

noted the same incongruities.

b.

Report 519 (5/21/79) noted that item No.10.4--verification that each size of shipped aggregate is properly sampled--was not performed as required.

Report 629 (8/14/79) noted the same condition.

c.

Report 484 (4/17/79) noted that item No. 8.1.3a--verification that rebar is being properly stored in intermediate storage areas--was unsatisfactory.

Reports 531 (5/31/79) and 590 (7/17/79) noted the same condition.

d.

Report 291 (9/28/78) noted that seven drawings found in Unit 1 reactor pit were not the latest revision.

UE&C QA organization did not verify that prompt corrective action was taken by PDM until 6/7/79 (Surveillance Report #540).

e.

Report 314 (10/30/78) noted that the field receiving report for liner plates for containment ring #4 of Unit 1 was not filled out for the release of these liner plates to construction even though work was being performed on them. UE&C QA organization did not verify that prompt corrective action had been taken on this finding by PDM until their surveillance on 6/7/79 (Surveillance Report #5'D).

f.

Report 374 (1/9/79) noted that 13 items were not stored properly by PDM.

The surveillance report stated that all items were to be corrected by 1/19/79.

UE&C OA organization did not verify that prompt corrective on 7/25/79 (Surveillance Report #597)gs by PDM until their surveillance action had been taken on these findin

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The UE&C Site Surveillance QA Procedure (QCP-10-1) does not specifically require that the followup surveillance to determine that prompt and effective corrective action has been taken on discrepant items or conditions previously found, nor does it require that 0A verify or assure that the corrective action taken will preclude repetition.

The inspector considered the above examples to be contrary to the requirements of 10 CFR 50, Appendix B, Criteria XVI (443 & 444/79-08-06).

5.

Review of PDM (Corporate) Audits of Site Activities (Unitt 1 and 2)

a.

The inspector reviewed the PDM (corporate) audits of the site activities to determine that the audits were conducted as scheduled and that corrective action taken for audit findings were adequate and timely.

The following audits were reviewed:

Audit 78-503 (September 6, 1978)

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Audit 78-104 (February 28, 1979)

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No items of noncompliance were identified.

b.

The inspector also reviewed a random sample of site inspection records for containment construction activities to determine that required quality control ir.spections were performed.

The records reviewed:

Field receiving inspection records to 13th containment ring.

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Field receiving inspection records for receipt of Nelson Studs

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(Report #11, dated August 21,1979).

QC Material Storage Inspection Report, dated August 30, 1979.

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No items of noncompliance were identified.

6.

YAEC Site Surveillance of Pullman Power Products (Units 1 and 2)

The inspector reviewed the YAEC quality control surveillance of Pullman Power Product reports for the period June 21, 1978 - January 4, 1979.

No items of noncompliance were found.

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7.

YAEC Site Serveillance of Fishbach-Boulos-Manzi Activities Units 1 and 2 The inspector reviewed the licensee's field ouality assurance master check list titled, " Embedded Rigid Steel Conduit and Plastic Ducts," Revision 1, dated June 28, 1979.

The inspector verified that the licensee performed surveillance inspections of embedded steel conduits and plastic ducts since March 29, 1979, with the last report dated August 31, 1979.

No items of noncompliance were identified.

8.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, or items of non:cmpliance.

Unresolved items identified during the inspections are discussed in Paragraph 2.

9.

Exit Interview

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The inspector met with licensee and contractor representatives (denoted in Paragraoh 1) at the conclusion of the inspection on September 7,1979.

The inspector summarized the scope and findings of the inspection as in this report.

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