ML19309B719

Responds to NRC 800111 Ltr Re Violations Noted in IE Insp Repts 50-443/79-09 & 50-444/79-09.Corrective Actions:Revised Perini Procedure QAP-15-0 to Require Corrective Action Determination on Each Rept

ML19309B719
Person / Time
Site:	Seabrook
Issue date:	02/01/1980
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19309B715	List: ML19309B719
References
SBN-115, NUDOCS 8004070106
Download: ML19309B719 (3)

Text

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MN Companyof New MempeNro SEASROOK STATION V(N Ensinomine omoe:

20 Twnpike Road westborough, MA oissi February 1, 1980 SBN-ll5 T.F. B 4.2.7 U.S. Nuclear Regulatory Commission Region I

• 631 Park Avenue King of Prussia, Pennsylvania 19406 Inspection 50-443/79-09 and 50-444/79-09 Dated January 11, 1980 Gentlemen Pursuant to receipt of your correspondence regarding the results of the subject inspection, we offer the following reply:

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

nonconformances are promptly identified and corrected. . .the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

The licensee's PSAR for Seabrook Station, Units 1 and 2, states, in part, in paragraph 17.15: "Each organization is required to perform their respective quality related activities covered by this program in accordance with documented instructions, procedures, or drawings."

Paragraph 5.2c of the Perini Power Contractors, Inc. Quality Assurance Procedure 15.0, Revision 1, Reporting of Nonconformances, states, in part:

"The Perini Project Engineer. .shall. . . review Nonconformance Report for . . .

corrective action statement. . .", and Paragraph 4.3 of QAP 16.0, Revision 2, Corrective Action, states in part: "The method for reporting conditions requiring corrective action measures, obtaining the disposition and recording implementation of the disposition shall be through the use of the Corrective Action Report (CAR) .

The CAR shall be utilized in such a manner to indicate and/or record evidence of the following: (1) The nonconformance has been evaluated and determination of the need for corrective action has been established. (2) The cause of the nonconfomance has been established. . ." and Paragraph IV.C'of UE&C Quality Assurance procedure QA-16-1, Revision 6, Corrective Action, states, in part: " Field Quality Assurance. . .

reviews and approves each contractor's procedures for effective corrective action 8004070ld ,

, f U.d. Nuckar Regul0 tory Commiccitn Pag) 2

-S1N-115 system. . .As a part of its surveillance actions, Field QA monitors the implementation of these procedures."

. Contrary to the above, on November 15, 1979, NCR Nos. 408 and 436 which identify a total of 196 omitted reinforcing bars in concrete placement number 1-EV-24-RCA made August 3, 1979 for the equipment vault wall were not identified for corrective action, by either Perini or UE&C and no CAR was provided to determine 'need for corrective action.

This item is an infraction.

Response - Corrective Action Taken and Results Achieved Immediately after the infraction was noted and while the inspection was in progress, Perini took immediate action to correct the problem. On November 11, 1979, Interim Procedure Change No. S to Perini Procedure QAP-15-0 (Reporting of Nonconformance), Revision 1, was issued. This change required the Perini super-visor of Quality Engineering to make a determination on each nonconformance report as to whether corrective action is required.

Simultaneously, UE&C's QA Superintendent issued Corrective Action Request (CAR) #023 to Perini which included recommendations for corrective action. In response to CAR #023 the following action occurred:

1.0) Perini QA inspectors are now using both UE&C design drawings and Bethlehem detail drawings to perform reinforcing steel installation inspections. Instructions to use both UE&C and Bethlehem drawings for rebar checkout were issued via inter-office memo 516A on 11/30/79.

During discussions between UE&C and Perini Engineering and Quality Assurance personnel it was emphasized that both UE&C design drawings and Bethlehem detail drawings must be used to check out scheduled place-ments; however, in the event approved Bethlehem drawings are not available at the time of placement, a checkout of the scheduled placement will be made in accordance with UE&C design drawings and alternate documents as approved by UE&C for the specific placement.

All Perini Field Engineers responsible for pre-placement rebar check-out have been instructed to utilize UE&C construction drawings and Bethlehem Steel rebar detail drawings for the placement and all inter-secting walls and slabs.

2.0) Perini QA procedure QAP 10.2 - Reinforcing Placement Inspector - already requires that drawings used to check rebar installation be documented on the placement report. QA Inspectors have been reinstructed to identify

_ _ drawings used to perform inspections, including Engineering Change Approvals and Site Approved Changes of the particular placement area and including intersecting walls and/or' slab areas.

3. 0) A formal, documented training session for QA Inspectors responsible for

' rebar placement inspection was conducted on 11/26/79 from 0830 to 1030.

CAR 023 was reviewed and it was emphasized that rebar inspection must be performed and documented, using UE&C design drawings for the particular placement area and intersecting walls and/or slabs, as previously iden-

.tified in Item 1.0.

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.U.S. Nuclear Regulttsry Commiccion

'Pcge 3

.- SBN-ll5 All Perini Field Engineers have been instructed not to sign off the concrete check out card without fully checking all necessary drawings.

4.0) Perini QA Inspectors were instructed via inter-office memo 516A not to sign-off the concrete preplacement card unless all required drawings -

both UE&C and Bethlehem - are available in site and used during rebar placement inspections, with the variation as identified in Item 1.0.

Perini will be furnished a continuously updated list of UE&C and Bethlehem drawings by UE&C Power Engineering to be used for installation and inspection of rebar in order to assure that all drawings, which relate to any particular pour, have been used.

5.0) Supervision has been informed that checkout of rebar will require both UE&C drawings and Bethlehem drawings. No placements are to take place until Engineering and Q.A. have completed the check out using both drawings.

UE&C has increased their surveillance activity for rebar inspection with satisfactory results.

Full compliance will be achieved on February 29, 1980.

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

Very truly yours, yk John DeVincentis Project Manager JDV: tan

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