ML20076F192

Responds to NRC Re Violations Noted in IE Insp Repts 50-443/83-02 & 50-444/83-02.Corrective Actions:Craft Personnel Reindoctrinated,Qc Personnel Will Monitor safety- Related Supports & Site Contractor QA Audited

ML20076F192
Person / Time
Site:	Seabrook
Issue date:	05/02/1983
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20076F173	List: ML20076F192
References
SBN-505, NUDOCS 8306010449
Download: ML20076F192 (6)

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% 'd I SEABROOK STATION S e x i., Orm :

1671 Worcestw Rood Put2c Service of New Hampshire M"8k'" *d""' 01701 (617) - 872 3100 May 2, 1983 SBN- 505 T.F. B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Re fere nc es : (a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50--443 and 50-444 (b) USNRC Letter, dated April 4,1983, " Combined Inspection Nos. 50-443/83-02 and 50-444/83-02," R. W. Starostecki to R. J. Harrison

Subject:

Response to Inspection Nos. 50-443/83-02 and 50-444/83-02

Dear Sir:

Attachment A to this letter delineates corrective action for the violations reported in the subject inspection which you forwarded in Reference (b).

Attachment B to this letter eddresses your concerns regarding the implementation of management control systems that permitted the violations of the subject inspection to occur.

Very truly yours, ANKE 'IOMIC ELECTRIC COMPANY

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oh DeVincent Project Manag ALL/pf Attachments cc: Atomic Safety and Licensing Board Service List 1000 Elm St., P.O. Box 330 Manchester, NH 03105 Telephone (603) 669-4000 . TWX 7102207595 8306010449 830525 PDR ADOCK 05000443 G PDR

O O ATTACHMENT A CORRECTIVE ACTIONS FOR REPORTED VIOLATIONS NRC NOTICE OF VIOLATION (443/83-02-01)

A. 10CFR50, Appendix B, Criterion X and the Seabrook Station FSAR, Section 17.1.1.10, require that the program of inspection established to assure quality work operations include, as necessary, process monitoring and the imposition of inspection hold points. For ASME Section III piping fabrication and component erection operations, Pullman Procedure VI-5 requires the mandatory use of Field Process Sheets in the area where the work is being performed and prohibits work from proceeding past a designated hold point without inspection and sign-off. Pullman Procedure IX-39 requires the preparation and use of instruction / checklists to control activities affecting equipment installation.

Contrary to the above, on January 20, 1983, fabrication of a weld end preparation (field weld F0304 on component cooling line, CC-838-03) for ASME Section III piping had been performed without the required Field Process Sheet available in the area of the work and had proceeded past designated hold points without inspection and sign-off. On February 4, 1983, the seal piping heat exchangers for RHR pumps 8A and 8B were found disassembled and partially reassembled without evidence that instruction / checklists had been used or were even prepared to control this equipment installation activity.

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

RESPONSE

Corrective Action Taken and Results Achieved t

To control further processing of the weld end preparation, the installation contractor (P-H) initiated NCR 4165. Additionally, a Corrective Action Request was prepared resulting in the re-indoctrination of affected craf t personnel regarding the requirement for process sheets and the honoring of inspection hold points. This retraining was completed by April 7,1983.

The partial disassembly / reassembly of the RHR pump heat exchangers occurred during the setting of the pumps early in 1979. At that time, YAEC issued a "stop work" order since no instructions had been prepared for the movement of the pumps from the warehouse to their designated location in the equipment

, ~ vault. The order was lif ted when sufficient instructions were promulgated.

Subsequently, during the summer of 1979, P-H issued their Procedure No. IX-39 entitled Handling, Installation, Testing, and Inspection of Safety-Related Equipment. This procedure requires the use of process sheets for equipment i installation and any necessary disassembly / reassembly. The pumps, to date, have not yet been completely installed.

YAEC, UE&C and P-H management, and the resident NRC inspector have held discussions regarding P-H's apparent inability to effectively control certain

. phases of their contract responsibilities. As a result of these discussions and site management reorganizations, UE&C now has the responsibility of

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V preparing process sheets for P-H use and is also responsible for the effective uJe of inspection hold points. YAEC is closely monitoring the effectiveness of this recent reorganization and will keep the resident NRC inspector apprised of the program's effectiveness.

NRC NOTICE OF VIOLATION (443/83-02-02)

B. 10CFR50, Appendix B, Criterion XV and the Seabrook Station FSAR, Section 17.1.1.15, require that the measures established to control nonconforming items include documentation, review, and disposition. The FSAR also presents pictorially in Figure 3.7(B)-31 a typical supported cable tray system used as a model for the seismic design of the tray supports. UE&C Drawing No. M300229, Sheet T5, details this typical tray support system for installation purposes, to Irelude provisions of a sliding fit connection, accounted for and required by the seismic analysis. Bo th 10CFR50, Appendix B and the FSAR require that installation activities conform to applicable drawings.

Contrary to the above, as of February 4,1983, several cable tray system supports, installed to the criteria of Drawing No. M300229, Sheet T5, were found to be in nonconformance with the sliding fit detail in that each connection had been rigidly bolted. The unauthorized use of bolts, which adversely affects the required sliding motion, had been neither documented nor reviewed. Subsequent review resulted in the disposition that the bolts must be removed.

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

RESPONSE

Corrective Action Taken and Results Achieved UE&C prepared ECA No. 03/2001A confirming that the floor to ceiling type supports were designed and analyzed with slip connections at the ceiling and that any nuclear safety-related support of this type with bolts on the sides of the boot fittings shall have the bolts removed. The installation contractor's QC group has prepared a listing of the affected supports and will monitor the modifications which will be accomplished in conjunction with scheduled construction activities.

YAEC QA will verify the progress of the required rework through the Future Verification Program.

NRC NUTICE OF VIOLATION (443/83-02-03)

C. 10CFR50, Appendix B, Criterion XVII and the Seabrook Station FSAR, Section 17.1.1.17, require the maintenance of records which document safety-related activities. The FSAR also subscribes to ANSI N45.2.9 and imposes the requirements therein upon all site contractors. ANSI N45.2.9, Section 5.7, states that lost records should be reconstructed in accordance with appropriate procedures. Further, Pullman-Higgins' (P-H)

Procedure XV-2 specifies that a Nonconformance Report shall be initiated in the event safety-related inspections are not adequately documented.

O O Contrary to the above, as of February 4,1983, records documenting the installation and inspection of RHR pump 8B had been reconstructed by P-H personnel to replace lost records, without the existence of a procedure governing such reconstruction and without initiation of a Nonconformance Report. This resulted in a document package which was both-incomplete and incorrect with respect to the record of this safety-related activity.

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

RESPONSE '

Corrective Action Taken and Results Achieved

UE&C initiated, and transmitted to all site contractors, ECA No. 10/0108B which states that quality assurance records shall not be altered, changed, modified, reconstructed, or corrected without proper written justification and that they shall be prepared in accordance with an approved procedure which provides for appropriate review or approval.

, Subsequently, YAEC QA audited site contractors to verify the degree of compliance with the ECA instructions and to determine the extent!of the noted condition. No other examples of records reconstruction were found. Those contractors who needed additional instructions in their procedures are i currently making the necessary revisions.

Required instructions should be in place by June 30, 1983.

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W ATTACHMENT B 1

MANAGEMENT CONTROL SYSTEMS x

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'~ In addition to the remedial actions taken on specific itemsf of . violation identified it. the subject Inspection Report, the following escalated W ~

management actions were taken prior to or concurrent with the.NRC notification q

of the violations: 3 -4 - N N 's -

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1. A YAEC~Immediate Action' Request, similar to the Immediate-Action Letter ) -

concept utilized by the NRC, was transmitted to

the senior corporate ] x executive officer of the contractor found.to be in violation of x _,

' designated hold point controls. Contractor, management personnel reacted to this request in a timely fashion, and increased management attention was applied with favorable results.

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2. A task force consisting of Licensee, YAEC, Construction Management, and

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Contractor personnel was mobilized to evaluate the process sheet system of control and to verify the validity and' effectiveness of designated hold points.

3. Management meetings were held with all site' contractors to stress the importance of inprocess inspection points and re-emphasize that.dtN1sted manag4 ment actions are mandated for all bypassed hold point' violations.

Additionally, each contractor was requested to immediately evaluate the 'N effectiveness of their inspection hold point programs. \,

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4. UE&C has formed an on-site Engineering Group having the responsi5111ty l for the design and engineering of all atipects related to the install,ation of piping and associated supports. Their4 harter also includes b ,

responsibility for the preparation of process sheets utilized 'for x-  %

piping / hanger installation. k ,

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5. UE&C has transferred a significant number of engineering person 3el;tol,the.? %, J, site to facilitate the flow of information between the architeEt.Magineer ,

l' and affected contractors. This action permits, ready access to, attrent w g

construction conditions by personnel responsible for responding i to e C - '

contractor concerns.  ;,, s-Licensee corporate management will continue to provkle aggressive and positi s N management actions to assure that programmatic andNhIrtallation activities arm) '

I. effective and are being properly implemented. ,4 ,

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• • • *I Q R V U ASLB SERVICE LIST Roberta C. Pevear Rep. Deverly Hollingworth Designated Representative of Coastal Chamber of Commerce the "'own of ifampton Fall.s 209 Winnacunnet Road Drinkwater Ro?d Hampton, NH 03842

~ llampton Falls, Ul! 03844' William S. Jordan, III, Esquire Mrs. Sandra Gavutis

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Designated Renresentative of I

Harmon & Weiss the Town of Kensington 1725 I Street, N.W.

RFD 1 h Suite 506 East Kingston, NH 03827

'i Washington, DC 20006 Edward J. !!cDermot t . Esquire E. Tupper Kinder, _ Esquire Sanders and McDermott Assistant Attorney" General r.

Office of the Attorney General Professional Association 408 Lafayette Road s

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208 State House Annex Hampton, NH 03842 1 Concord, NH 03301 Jo Ann Shotwell, Esquire 1

Roy P. Lessy, Jr. , Esquire Assistant Attorney General s . Office of tt'e Executive Legal Director Environmental Protection Bureau

. T' ' Uy . Nucleai Regulatory Commission Department of the Attorney General 4 .j , Washingtont DC 20555_

One Ashburton Place, 19th Floor y

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Boston, MA 02109 RobertL A. Backus, Esiguirs '\ Ms. Olive L. Tash 116 Iowell,6treet s Designated Reoresentative of P.O. Box,516 , { ,'(

Manchester, NH '03105L  %

the Town of Brentwood R.F,D. 1, Dalton Road C* ' ' Drentwood, NH 03833

, Philip Ahrens, Esquire I Assistant Attorney General Edward F. Meany Department of the Attorneh General Designated Representative of Augusta, ME 04333

\. the Town of Rye O  ; 155 Washington Road i .. ' ' Rye, NH 03870 David L. Lewis 'N '

Atomic Safety and;Li. censing Calvin A. Canney Board Panel N  % City Manager U.S. Nuclear Regulatory 3 Commission ,"

City Hall Rm.E[)t-439 \ ,. 7 7(A

• 126 Daniel Street

, Washington, PC 20355 i 4  ; " Portsmouth, NH 03801 4

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Mr. John B.; Tanzer, , \ i; '

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