ML20064F104
| ML20064F104 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/02/1982 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20064F096 | List: |
| References | |
| SBN-397, NUDOCS 8301060251 | |
| Download: ML20064F104 (3) | |
Text
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PUBLIC SERVICE suom sum Engineedng Omce:
Companyof NewHampshre 1671 Worcester Road Framinoham, Massachusetts 01701 (617) - 872 - 8100 December 2, 1982 SBN-397 T.F.
B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. T. T. Martin, Director Division of Engineering and Technical Programs
References:
(a ) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated November 3, 1982, " Inspection 82-12,"
T. T. Martin to W. C. Tallman
Subject:
Response to Inspection No. 82-12
Dear Sir:
In response to the violation which you reported in Reference (b), PSNH offers the following:
NRC Notice of Violation (443/82-12-02):
A.
10CFR50, Appendix B, criterion VI requires that measures be established l
to control the issuance of documents such as instructions, procedures, and drawings. These documents shall be distributed to and used at the location where the prescribed activity is performed. The FSAR, Paragraph 1.7.1.6 requires that the Document Control System provide assurance that procedures, specifications, drawings, and instructions, including changes which prescribe activities affecting quality are distributed to the locations where quality-related activities are performed.
'Ihe UE&C Engineering Change Authorization (ECA) of mrch 19, 1982, Number 190297B, provides for change of ASME code designation from NC, Class II, to Class MC, Subsection NE, for end plate to pipe and through pipe to end plate containment boundaries. The UELC letter of April 16, 1982 and its reissue of May 28, 1982 states that the ASME classification for penetration / plate and plate / pipe welds will be changed to Class MC, Subsection NE.
These letters also summarize the effect of the code designation change on the weld and base material nondestructive examination requirements.
The Pullman Power Products Document Control Procedure VI-1, Paragraph 1.1, directs that documents, including revisions, are distributed to and used by personnel at the location where the activity is being performed.
r301060251 830103 PDR ADOCK 05000443 0
Unit d StatOc Nucicer Regulctcry Commiccion December 2, 1982
. Attention:
Mr. T. T. Martin Page 2 Contrary to the above, on September 28, 1982 the Drawing ISO-SL-X35-01, Revision 4, and field instructions applicable to both the containment penetration / plate and plate / pipe welds for the safety-reltted containment penetration X35 were not changed as required to comply with ASME III, Class MC, Subsection NE.
This is a Severity Level IV violation (Supplement II).
Response
Corrective Action Taken and Results Achieved:
Upon notification from Yankee that ECA 190297B had not been incorporated in erection documents / aids, P-H reviewed potentially affected items / documents to determine its impact. Affected items were statused and Stop Work Orders issued as necessary. Affected documents were revised as required by the subject ECA and the respective Stop Work Orders rescinded. Those items not in compliance with the ECA requirements are being controlled by a P-H initiated NCR.
The original situation occurred due to an inadequate review by P-H personnel of an ECA that lacked concise instructions. Responsible personnel within the P-H document review cycle have been instructed to solicit advice / guidance regarding the disposition of documents which contain instructions which are unclear to the reviewer.
As a follow-up to the revision control problems identified as a result of a self-analysis by the piping contractor, and as further substantiated by a joint YAEC-UEEC audit a plan for interim and long-term remedial action is underway.
Inmediate actions include:
1.
P-H personnel have developed a priority list of isometrics they wish to install in the immediate future.
2.
Stop Work Orders issued on 11/22/82 to cease installation of piping and supports.
3.
Engineering personnel, augmented by qualified QA and UEEC Engineering personnel initiated round-the-clock review of backlogged ECAs and UEEC drawing revisions.
4.
As the Engineering review identifies acceptable items, the Stop Work Order will be updated to show the items released for installation activities.
Long-term actions include:
1.
Based on the results of the Engineering reviews and projected design changes, P-H will take the necessary actions to adequately staff their Engineering Department to process changes in a timely manner.
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. United States Nuclear Regulatory Commission December 2,1982 Attention:
Mr. T. T. Martin Page 3 e
2.
A program to address work previously completed will be prepared.
This program is in-place and will remain until it can be determined that the long-term corrective actions will prevent a recurrence of this situation.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY b
J. DeVincentis Project Manager DEG/fsf i
I
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