ML20053D866

Responds to NRC 820419 Ltr Re Violations Noted in IE Insp Repts 50-443/82-02 & 50-444/82-02.Corrective Actions:Design Specs & Appropriate Drawings in Process of Being Revised to Properly Define Required Code Boundary Limits

ML20053D866
Person / Time
Site:	Seabrook
Issue date:	05/19/1982
From:	Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20053D864	List: ML20053D866
References
SBN-276, NUDOCS 8206070395
Download: ML20053D866 (3)

Text

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SMN STAM Enginee ing Office:

IPUBLIC SERVICE Companyof NewHampshw e 1671 Worcester Road Framinahani, Massachusetts 01701 (617) - 872- 8100 May 19, 1982 SBN-276 T.F. B 4.2.7 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Richard W. Starostecki, Director Division of Resident and Project Inspection Re f erenc es : (a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated April 19, 1982, " Combined Inspection Nos. 50-443/82-02 and 50/444/82-02" Su bj ec t : Response to Inspection Nos. 50-443/82-02; 50-444/82-02

Dear Sir:

In response to the violation, which you reported in Reference (b), PSNH offers the following:

NRC Notice of Violation: (443/82-02-02) 10 CFR 50, Appendix B, Criterion IX and the Seabrook Station PSAR require that special processes, including welding and non-destructive testing, be controlled using qualified procedures in accordance w!th applicable codes. The applicable editions of the ASME Boiler and Pressure Vessel Code, Sections III and IX, specify respectively (1) magnetic particle examination (MT) of weld edge preparation surfaces in material two inches thick or more and (2) welding procedure qualification for impact required material less than 5/8 inch thick, using a test coupon representing the minimum thickness to be welded.

Contrary to the above, as of March 19, 1982, welding had been accomplished on containment piping penetrations (sleeve to end plate closure) with (1) MT not performed on the weld edge preparation of certain two-inch thick end plates and (2) a welding procedure (IT12-III-1-OB-12) not qualified to the minimum thickness listed in its thickness range for impact required material.

This is a Severity Level IV Violation (Supplement II).

8206070395 820601 PDR ADOCK 05000443 G PDR

. - United States Nuclear R gulstory cozmicsion M:y 19, 1982 Attzntion: Rich':cd W. Staroitscki P;g2 2

Response

Corrective Action Taken and Results Achieved Due to the dif ferent provisions of ASME Codes, year and addenda, utilized as a basis for design, shop fabrication, and installation (i.e., the 1971 code for design, the 1974 code for shop fabrication, and the 1977 code for installation) inappropriate Nondestructive Examination (NDE) and impact test requirements for material and fabrication of the affected components were specified by the designer.

The design specifications and appropriate drawings are presently in the process of being revised to properly define the required code boundary limits and classification.

Impact tests will be performed as required by code and weld procedures are in the process of being properly qualified to the required code provisions.

Total corrective action is scheduled to be completed by July 15, 1982.

Notice of Violation: (443/82-02-04) 10 CFR 50, Appendix B, Criterion III and the Seabrook Station PSAR require that the appropriate quality standards be specified and the applicable design criteria be translated into drawings and procedures.

The applicable editions of the ASME, Boiler & Pressure Vessel Code,Section III, Table XVII-2452.1-1 and AWS Code Dl.1, Table 2.7 specify minimum fillet weld sizes for joining members.

Contrary to the above, as of February 26, 1982, the design criteria for fillet weld sizes specified on several UE6C Drawings (e.g.: F104038) governing pipe whip restraint installation were incorrect in detailing undersized welds with respect to either ASME,Section III or AWS requirements. Installation of certain pipe whip restraints (e.g. :

PW-203-5) to incorrect weld criteria had been completed and accepted by quality control inspection peraonnel.

This is a Severity Level IV Violation (Supplement II).

F.e sponse :

Corrective Action Taken and Results Achieved As a result of this inspection, UE6C initiated an engineering review of all pipe whip restraint drawings and analysis. This review resulted in the following determinations:

a) Fillet weld sizes were based on stress requirements only and AISC and ASME minimum weld size requireme nte had not been introduced.

b) Forty-two undersize fillet welds had been specified in the design d rawi ngs . Thirty-seven configurations of pipe whip restraints are involved, from a total of one hundred and twelve pipe whip restraints.

United States Nuclear Regulatory Commission Mxy 19, 1982 At t'ent io n : Richard W. Starostecki Pigs 3 UE&C, the designer, has initiated Engineering Change Request (ECA) NO.

19/0289A which listed the welds identified above and requested that the installation contractor reinspect the one hundred and twelve pipe whip restraints to determine if the weld sizes met the minimum weld size criteria of ASME and AISC. Non-conforming welds will be identified and c or rec ted .

The reinspection is expected to be completed by May 31, 1982.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY Y

W. P' 51 o Vice President COMMONWEALTH OF MASSACHUSETTS)

)ss MIDDLESEX COUNTY )

Then personally appeared before me, W. P. Johnson, who, being duly sworn, did state that he is a Vice President of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Public Service Company of New Hampshire and that the statements therein are true to the best of his knowledge and belief.

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A. 6L L/ Ldg[endre , Or. Notary Public My Commission Expires August 5, 1988

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