ML20064C082
| ML20064C082 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/29/1982 |
| From: | Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20064C066 | List: |
| References | |
| SBN-348, NUDOCS 8301040305 | |
| Download: ML20064C082 (3) | |
Text
f ENCLOSURE 4 ssAam* STATION IPUE5LIC SERVICE
- .g
. omc.:
Companyof New Hampshes 1671 Worceder Road Framingham, Massachusetts 01701 (61: 1 - 872 - 8100 7
October 29, 1982 SB N-348 United States Nuclear Regulatory Cotmission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Richard W. Starostecki, SALP Board Chairman Director, Division of Project and Resident Programs
References:
(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) Systematic Assessment of Licensee Performance (SALP) Report and Meeting of September 29, 1982
Subject:
Response to SALP Board Report
Dear Sir:
As discussed at the September 29, 1982 SALP meeting and as provided for in the transmittal letter of the subject report, we hereby submit our comments relative to same.
Our evaluation of the report indicates that all areas of the report, with the exception of Functional Area 3, can be appropriately addressed in our response to Functional Area 9; hence, our comments are restricted to these two areas.
Piping Systems and Supports, Functional Area 3 As identified in the SALP report, licensee management has been, and continues to be, committed to achieving improvements in the performance in this functjonal area as well as all others.
In addition to the positive actions taken prior to the recent CAT inspection, which appears to be the majcr weighting factor in the evaluation of this functional area, licensee management vigorously continues to pursue courses of action to improve performance in all pro met activities.
Recent a
actions of note in Functional Area 3 are as follows:
YAEC Management has directed the piping contractors corporate management to become actively involved in the audit proces s.
All of the contractors' audit personnel have been instructed to investigate to the fullest and address previous audit findings to verify that timely and effective corrective action g'
.'s 8301040305 821228 y
PDR ADOCK 05000443 cg G
E.
e Unitad States Nuclear Regulntory Cramissien October 29, 1982 Attention:
Mr. Richard W. Starostecki Page 2 has been achieved. Relative to weld monitoring, the piping contractor corporate audit staff performed ~ a special audit of this activity and associated controls.
This special audit resulted in no items of noncompliance.
YAEC audit personnel also performed a verification audit of weld monitoring activities which also indicated that satisfactory corrective action has been achieved in this area of process control.
As a result of ongoing management meetings between the piping contractor and the licensee, the contractor has instituted organizational changes in both the Construction and QA Departments.
Organizational changes include the establishment of a position of an assistant site QA Manager, the addition of NDE Level III personnel, and the addition of NDE supervisory personnel.
Other changes include the reassignment of several personnel to supervisory and management positions, the most notable being in the areas of Construction Managemant and Field Engineering.
YAEC Corporate and Field QA personnel are continuing escaJated audit and surveillance activities to assure that all proposed or implemented corrective actions are effective and ongoing.
YAEC Management personnel will continue to meet periodically with P-H Corporate Management personnel to emphasize the necessity of continued and effective corporate support for the project.
Project Management Effectiveness, Functional Area 9 In line with the SALP Board's evaluation in the functional area, we have recognized that continuous assessment and review processes are necessary to assure that FSAR commiteants are completely and adequately translated iner the actual construction and inspection documents used in the field to const the plant.
In additir,n, we recognized that strong project and quality management programs ware necessary to assure implementation of these commitments by all perticipating organizations.
In this vein, and in line with the Board's recommendation, we summarize below, actions that have been ongoing relative to the aforementioned assessment and review process.
j Early in 1981, we initiated a program starting with tue development of a
]
matrix which identified FSAR commitments and their relationship to engineering documents such as System Design Specifications, Component and Installation Specifications, and all applicable project documents.
These documents were i
then reviewed to assure that the essential FSAR commitments were included.
In mid 1981, the matrix was expanded to include the applicability of FSAR
)
commitments to site contractors' Construction and QA procedures. Starting in I
the last quarter of 1981, a comprehensive review of site contractors programs and procedures was initiated to assure that the applicable FSAR commitments were included in their Construction and QA/QC implementing t rocedures.
Upon completion of this review, each contractor was audited to verify that program implementation included the applicable FSAR commitments.
This assessment, review, and audit process is ongoing and will be periodically evaluated for effectiveness.
1
Unit'ed Stetso Nucisar Regulaccry Commission October 29, 1982
' Attention:
Mr. Richard W. Starostecki Page 3 As agreed to at the SALP meeting, a future meeting with NRC personnel will be scheduled early in 1983 to discuss, in detail, the verification l
programs in place to assure that FSAR, program, and engineering criteria have l
been, and currently are being, translated into construction and inspection documents and are being implemented.
If you require additional information or have any comments, please feel I
free to contact us.
Very truly yours, l
/
i r
h l
W. P.j' o uson
(
i Vice, President v
GFM/fsf i