ML19260D345

Responds to NRC 791105 Ltr Re Violations Noted in IE Insp Repts 50-443/79-08 & 50-444/79-08.Corrective Actions: Measures Taken to Assure Deviations Are Corrected Promptly, Precluding Repetition of Adverse Conditions

ML19260D345
Person / Time
Site:	Seabrook
Issue date:	12/13/1979
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19260D344	List: ML19260D345
References
SBN-110, NUDOCS 8002080389
Download: ML19260D345 (5)

Text

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IPUBLIC SERVICE C-p .yof NewHampehu o SEABROOK STATION Engineering Office:

20 Turnpike Road Westborough, MA 01581 December 13, 1979 SBN-110 T.F. B 4.2.7 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 194u6 Gentlemen:

Inspection 50-443 /79-08 and 50-444/79-08 Pursuant to receipt of your correspondence regarding the results of the subject inspection we offer the following:

A. NRC Notice of Violation 10 CFR50, Appendi:: B, Criterion XVIII, states, in part, that, " . . . Audits shall be performed in accore nee with written procedures. . . . Follow-up action, including reaudit of deficient areas, shall be taken where indicated."

The licensee's PSAR for the Seabrook Station, Units 1 and 2, states, in part, in Paragraph 17.1.18, ". . .The YAEC audit procedure requires that a written report be prepared denoting the areas covered by the audit, the results of the audit and th- area requiring corrective action and reaudit to ensure deficient items found are corrected. . . "

Paragraph 3.1.8.8 of the Yankee Atomic Electric (YAEC) QA Procedure 9.1 states that, " Audit reports requiring corrective action shall be followed up as detailed in YAEC QA Procedure 8.1 (Corrective Action").

Contrary to the above, as of Septenter 6,1979, the YAEC QA Procedure 8.1 does not address the reauditing to ensure that the deficient items found during an audit have been corrected.

This item is an infraction.

Response

Corrective Action Taken and Results Achieved 1944 042 It has been the practice of the YAEC Quality Assurance Department to close 8002080

U.S. Nuclear Regulatory Commission Page 2 SBN-110 out audit deficiencies in one of, or combination of, the following ways:

1. Acceptance of satisfactory written response from the audited organization.

2. Personal verfication that positive corrective action has been taken during subsequent audits.

The Seabrook FSAR which is in the final stages of preparation will include the following statement: "The organization conducting the audit is respon-sible for conducting the follow-up action

• as necessary, to confirm that carrective action is accomplished as scheduled. Follow-up action may be accomplished through written communication, reaudit, or other appropriate means."

Procedure 8.1 of the Seabrook Ouality Assurance Manual has been revised to include the above-mentioned FS AR requirements.

Full compliance will be accomplished as follows:

1. The FSAR is scheduled for submittal on March 1, 1980 but is behind schedule and will probably not be completed until mid 1980.

2. Procedure 8.1 of the Seabrook QA Manual has been revised as of 12/5/79.

B. NRC Notice of Violation 10 CFR 50, Appendix B, Critorion XVI, states, in part, that, ". . . Measures shall be established to assure that conditions adverse to quality, such as. . .

deviations. . .and nonconformances are prcmptly. . . corrected. In the case of significant conditions adverse to quality, the measures shall assure that the. . .ccrrective action (is) taken to preclude repetition."

The licensee's PSAR for the Seabrook Station, Units 1 and 2, states, in pdrt, in Paragraph 17.1.16, ". . .Each organization performing quality related activities covered by this program shall provide measures to control conditions adverse to quality.

The measure shall include procedures defining methods, prompt indentification, correction, determining cause and the prevention of repetition of conditions adverse to quality. . ."

Paragraph E of the United Engineers and Constructors (UE&C) Surveillance Procedure QCP-10-1, states, in part, ". . .The quality assurance engineer shall verify that effective corrective action has been taken on the unsatis--

factory findings of the surveillance. . . . This shall be accomplished by conducting a followup surveillance of the open items. . . ."

Contrary to the above, as of September 7, 1979, the UE&C procedure does not

U.S. Nuclear Regulatory Commission Page 3 SBN-110 address when the reaudits are to be conducted to verify that prompt correc-tive action has been taken and nor does it require the auditors to verify the effectiveness of the corrective action to preclude repetition.

This item is an infraction.

Response

Corrective Action Taken and Results Achieved UE&C Site Surveillance Procedure QCP-10-1 was extensively revised on September 28, 1979 to assure that timely follow-up actions are performed to verify that prompt and effective corrective action has been taken on unsatisfactory conditions identified during surveillance.

The procedure now requires that subcontractors take immediate action to control identified unsatisfrctory conditions, that proposed actions and resolutions be documented within a time frame determined by the UE&C sur-veillant and that the UE&C verification of corrective action is within the time frame specified. The aforementioned actions on unsatisfactory conditions tr: dccamented on a Contractor Notification Report.

Follow-up surveillance is also performed on previously identified unsatis-factory items by adding the items to the scope of the next surveillance of the activity or by making a special surveillance.

The procedure now requires that UE&C Site Quality Assurance supervision review and evaluate the surveillance reports and Contractor Notification Reports monthly for adequacy of the reports, acceptability of results, effectiveness of corrective action, timeliness of resolution, and quality trends.

Full compliance was achieved on September 28, 1979.

C. Actions to Improve Quality Assurance Program Effectiveness Public Service Company of New Hampshire (PSNH) and Yankee Atomic Electric Ccmpany (YAEC) have always felt that the Seabrook Project Ouality Assurance Program has been effective in controlling the quality of plant equipment and structures, yet are keenly aware that an effective program must be dynamic.

Since the inception of the Program it has been odr practice to continually upgrade it to reflect changing activi'tres and methods as well as to make it more clear or complete. During the early stages of plant construction it be-came apparent that to enhance the effectiveness of the Program greater emphasis was required to strengthen the control over some site activities.

We have, accordingly, applied increased efforts to the preparation and revision of procedures, the indoctrination and training of personnel, the use of consis-tent audit / surveillance methods, and the prompt resolution of deficient areas.

I944 044

a UlS. Nuclear Regulatory Commission Page 4 SBN-llO The programs, procedures and imptementing instructions used by YAEC, United Engineers and Constmactors, Inc .porated (UE&C), as well as by site construc-tion organizations, have been, as .11 continue tc bc, upgraded as a result of reviews and as a rustsquence %_ audits /surveilltnce of th<,Ar implementation.

Although changes have been necessary, the number and tvoet of changes were to be anticipated in a project of this magnitude and reflect the effectiveness of the QA program as a whole in assuring the quality required for safe plant operation. Typical of changes made to further improve the effectiveness of the Seabrook Project QA Program are those which have: expedited the resolution of deficiencies, addressed the analysis of identified conditions for trends, applied quantitative and qualitative inspection criteria, generated definitive construction and inspection procedures, provided meaningful indoctrination and training, clarified areas requiring more consistent definition and methods, and provided interfacing in interactive procedures.

Several actions have been taken to expedite the resciation of deficiencies reported by audit / surveillance personnel and to augment the Program in order to handle quality-related problems. These include:

1. The Project Offices and site Quality Control / Assurance (QC/A) organizations, including UE&C and constructors, have been directed to:

a. have proposed resolution of deficiencies, and corrective actions considered, discussed orally with the audit / surveillance personnel who reported the condition. By doing so, delays have been precluded.

b. make reasonable effort to reach agreement during audit / surveillance concerning action to resolve items reported, including the scheduling of the resolution and interim action required.

c. refer promptly to higher management level for resolution of disagree-ments concerning items reported as a result of audit / surveillance.

2. Copies of YAEC reports of audits of construction site organizations are new being sent directly to the audited organizations and copies of auditee responses are now being forwarded directly to YAEC. Initially these trans-mittals were made through the UE&C Project Office.

3. Status indicating systems are being used by YAEC to a greater extent in resolving problem areas. The status of outstanding audit findings is being revi?wed at least weekly, and appropriate action is taken to expedite the resolution of pending items. YAEC has also initiated the use of an Action Item List to indicate the status of outstanding quality related items other than audit findings. Although it is used primarily for items requiring Quality Assurance Department action it includes requests for Projects and Construction Departments actions. It is updated weekly and is reviewed by YAEC Management at Li-weekly quality assurance meetings with the Quality Assurance, Projects, and Construction Managers.

1944 045

U.'S. Nuclear Regulatory Commission

- Page 5 SBN-110 A considerable effort has applied to establish, and sometimes to change, interfacing requirements for site organizations. These have involved both construction activities as well as OC/A activities. To assure the applica-tion of consistent philosophy and compliance with all requirements, continued scrutiny of procedures and a variety of meetings have been necessary, i.e.,

regular progress meetings, and special indoctrination and information meetings.

They have, as appropriate, been attended by PSNH, YAEC, UE&C, and constructor organizations. YAEC holds internal QA meetings bi-weekly and meets with UE&C on QA matters at approximately six (6) week intervals. QA matters are also on the agenda for Project Progress Meetings. Other meetings are being held with constructors as required.

In addition to the relatively routine working relationships established between site organizations, special interfacing has been established for activities such as: central site purchasing, central weld rod procurement and control, single responsibility for equipment storage and maintenance (including in-place storage and maintenance), and for the coordination of civil laboratory testing with construction activities. These have been the subject of special interfacirg meetings and of indoctrination sessions.

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

Very truly yours, h

John DeVincentis Project Manager JDV: tan 1944 046