ML19257C059

Responds to NRC 791030 Ltr Re Violations Noted in IE Insp Repts 50-443/79-07 & 50-444/79-07.Corrective Actions: Production Splices Reinspected & Inspector Given Training

ML19257C059
Person / Time
Site:	Seabrook
Issue date:	11/20/1979
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17198A032	List: ML19257C059
References
SBN-104, NUDOCS 8001240052
Download: ML19257C059 (5)

Text

.

PUBLIC SERVICE Compumyof New Hampshre SEABROOK STATION Engineering Office:

20 Turnpike Road Westi,eiengh, MA 01581 November 20, 1979 SBN-104 T.F. B 4.2.7 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Pussia, Pennsylvania 19406 Inspection 50-443/79-07 & 50-444/79-07 Dated October 30, 1979 Gentlemen:

Pursuant to receipt of your correspondence regarding the results of the subject inspection, we offer the following reply:

A. NRC Notice of Violation 10 CFR 50, Appendix B, Criteria V, states, in part, that: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings. . . and shall be accomplished in accordance with these instruct. ions, drawings, and procedures. . ."

The liCAnSef's PSAR for Seabrook Station, Units 1 and 2, states, in part, in Paragraph 17.1.5: "Each organization is required to perform their respective quality related activities covered by this program in accordance with documented instructions, procedures, or drawings."

Paragraph 5, Appendix I of the Perini Power Constructors, Inc. Quality Assurance Procedure QAP 10.3, Revision 4, Cadweld Inspection, states, in part: ". . .The assigned QA inspector shall inspect ea;h cadweld splice. .

after splice is made. . .in accordance with Cadweld Splice Acceptance Criteria."

". . .The total void area at each end of a cadweld splice. . .shall be computed in a manner prescribed. . ." The following shall cause the splice to be rejected:

(1) Void areas in excess of the maximum allowed."

1797 084 go (y6L

U)S. Uuclear Regulatory Commission

.. Page' 2

' SBN-104 This item is an infraction applicable to Docket No. 50-443.

Response

Corrective Action Taken and Results Achieved The certification of the subject Perini inspector was withdrawn on August 18, 1979. The thirty-six (36) production splices previously inspected by the subject inspector were immediately re-inspected for possible voids by another qualified inspector and found to be acceptable. Four cadwelder qualification splices inspected by this inspector were satisfactorily tensile tested. The subject splice was humediately rejected and replaced.

The subject inspector was given 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> of additional instruction, (104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> on-the-job training and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> classroom) and required to pass additional written examinations before being considered requalified. The additional training consisted of general cadweld inspection requirements with emphasis on determination of cadweld void acceptance / rejection criteria. The inspectors work will be continually monitored by this supervisor.

On September 22, 1979 all Perini cadweld inspectors attended a four hour training session in cadweld inspection based upon Regulatory Guide 1.10, UE&C Specification WS-4C and Erico Cadweld Manual.

Full compliance was achieved on September 13, 1979.

B. NRC Notice of Violation 10 CFR 50, Appendix B, Criterion V, states, in part, that: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings. . .and shall be accomplished in accordance with these instructions, drawings, and procedures. . ."

The licensee's PSAR for Seabrook Station, Units 1 and 2, states, in part, in Paragraph 17.1.5: "Each organization is required to perform their respective quality related activites covered by this program in accordance with documented instructicns, procedures, or drawings."

Paragraph 4.2 of Perini Quality Assurance Procedure QAP 10.10, Revision 2, Structural Concrete Repair Inspection, states, in part: ". . .This procedure shall be implemented when defects in placed concrete are identified," and, "a defect will be considered as a " Major" if, in the opinion of the Construc-tion Manager, concrete through and around reinforcing steel must be removed in order to alleviate all unsound concrete," and in Paragraph 5.1, it also states that: "After completion of centrete repairs. . . final.ize the Concrete Post Placement Inspection Report in accordance with QAP 10.5."

MR V l/V7 D

II.S. . Nuclear Regulatory Commission

. ,Page 3 SBN-104 Contrary to the above, as of August 16, 1979, quality related activities for major repairs were not covered by the program presented in QAP 10.5, which addresses normal concrete placement, and provides no inspection citeria relating to the removal of unsound concrete, such as verification that rebar was not injured during concrete removal, acceptability of remaining concrete or treatment of the joint prior to final repair.

This item is an infraction applicable to Docket Nos. 50-443 and 50-444.

Response

Corrective Action Taken and Results Achieved The requirements for the inspection and documenting of concrete repairs was incorporated into Revision 3 of Perini Procedure QAP 10.10 on September 6,1979 and forwarded to the Construction Manager for approval. The requirements include a concrete repair report which documented void areas after chipping to sound concrete, the reporting of the dimensions of the area to be repaired, the depth of the void area, and reinspection of any rebar for damage. Designer evaluation is required if rebar is found to be damaged and will be documented on a nonconformance report.

Full compliance will be achieved on November 16, 1979.

C. NRC Notice of Violation 10 CFR 50, Appendix B, Criterion XIII, states, in part, that: " . . . Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspec-tion instructions to prevent damage or deterioration. .. "

The licensee's PSAR for Seabrook Station, Units 1 and 2, states, in part, in Paragraph 17.2.13: " Site contractors are required, through the procurement documents, to perform storage and handling, including in-place storage, in accordance with written procedures which have been submitted to UE&C for review and approval."

UE&C QA Procedure No. 9876-QAS-1, Section 4.12, states, in part, that: ". .The contractor shall establish and document in written procedures his measure to control handling storage and preservation of equipment in accordance with purchase order requirements to prevent damage and deterioration. . ."

Contrary to the above, as of August 15, 1979 the containment contractor's storage procedure CP-02, Revision 0, did not have measures to control the storage of the Units 1 and 2 containment equipment hatches to prevent deterioration.

This item is an infraction applicable to Docket Nos. 50-443 and 50-444.

17n7

/7

U.S.. Nuclear Regulatory Commission

.. ,Page 4 SBN-104

Response

Correctiva Action Taken and Results Achieved Pittsburgh-Des Moines (PDM) Procedure CP-02 was revised on September 14, 1979 (Rev. F) to include measures for the inspection of stored items including containment equipment hatches and schedules for inspection.

The maintenance on the equipment hatches for both units which began on August 14, 1979 was completed on September 20, 1979 and its acceptability has been verified by UE&C through their surveillance program.

Full compliance was achieved on September 20, 1979.

D. NRC Notice of Violation 10 CFR 50, Appendix B, Criterion V, states, in part, that: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings. . .and shall be accomplished in accordance with these instructions, drawings, and procedures. . ."

The licensee's PSAR for Seabrook Station, Units 1 and 2, states, in part, in Paragraph 17.1.5: "Each organization is required to perform their respective quality related activities covered by this program in accordance with documented instructions, precedures, or drawings."

YAEC Field QA Manual Procedure No. 3, Revision 1, states: " Deficiencies discovered during surveillance and not corrected and approved during the surveillance shall be reported by the individual discovering the discrepancy, using the Field QA Deficiency Report Form 3.1."

Contrary to the above, as of August 16, 1979, the YAEC Field QA Organization did not issue a deficiency report for discrepant items uncovered (Report No. 206) during surveillance activities of the piping contractor on May 22, 1979. -

This item is an infraction applicable to Docket Nos. 50-443 and 50-444.

Response

Corrective Action Taken and Results Achieved A meeting of all Yankee Atomic Electric Company Field Quality Assurance personnel was conducted on August 16, 1979 at which time the requirements of the applicable sections of the YAEC Field QA Manual and Procedure were reviewed.

1727 087

+-

e ..U.S. Nuclear Regulatory Commission Page 5 SBN-104 On September 18, 1979, YAEC Field QA Manual and Procedure No. 3 was revised to incorporate specific instructions for the control and reporting of deficiencies and observations.

Full compliance was achieved on Or ')er 1, 1979.

Should you have any questions or comments regarding this response, we will be pleased to discuss them with you.

Very truly y urs, John DeVincentis Project Manager JDV:tla cc: B.B. Beckley W.C. Tallman W.F. Johnson W.J. Miller A.M. Shepard T.M. Sherry G.F. Cole (UE&C) 1797 088