ML20080H411

Responds to NRC Re Violations Noted in IE Insp Rept 50-443/83-07.Corrective Actions:Nisco Craft & Mgt Personnel Retrained Re Correct Application of Process Sheets

ML20080H411
Person / Time
Site:	Seabrook
Issue date:	08/10/1983
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
ML20080H401	List: ML20080H411
References
SNB-543, NUDOCS 8309210288
Download: ML20080H411 (5)

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. SEA 8 ROOK STATION S* 1*__,, Omos-1671 Worcesser Road hominoham, mseachveetts 01701 (417) - 872 - 8100 Put2c Serv 6ce of New Hampshire August 10, 1983 SBN-543 T.F. B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs Ref erence s : (a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated July 7, 1983, " Inspection No.

50-443/83-07", T. T. Martin to R. J. Harrison

Subject:

Response to Inspection No. 50-443/83-07

Dear Sir:

The results of the subject inspection which are documented in Reference (b) point to a lack of management control by NISCO, the installation contractor. As a result of this inspection, increased licensee attention, meetings between NISCO management and YAEC QA, and increased Yankee surveillance activities, NISCO initiated a Stop Work Order (#4031-001) on June 8, 1983. While work activities were halted, NISCO conducted training

, sessions for supervisory, craft, and quality assurance personnel to reinforce the proper application of their quality assurance program. The Stop Work Order was subsequently rescinded on June 10, 1983.

Additionally, NISCO replaced the Site Quality Assurance Manager with an individual more suitably experienced in an effort to prevent recurrence of the types of problems previously identified.

Increased Yankee surveillance has determined that the retraining efforts were beneficial and that NISCO personnel are now cognizant of, and complying with, Project requirements.

In response to the three violations reported in Reference (b), we offer the following:

8309210288 830912 PDR ADOCK 05000443 G PDR 1000 Elm St., P.O. Box 330, Manchester, NH 03105 Telephone (603) 669-4000 TWX 7102207595

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• United State Nuclear Regulatory Commission August 10, 1983 Attention: Mr. Thomas T. Martin Page 2 NRC Notice of Violation (443/83-07-03):

A. 10CFR50, Appendix B, Criterion XIII requires that measures be established to control the handling, storage and preservation of equipment in accordance with work and inspection instructions. The Seabrook FSAR, Paragraph 17.1.13, requires each organization contracting for construction activities to define appropriate handling and storage instructions. The Westinghouse NSSS component storage criteria dated Ma'cch 1976 provides that reactor vessel internals shall be stored indoors under ANSI N45.2.2 Level "B" conditions until the components are placed into operation. ANSI N45.2.2 Level "B" requires protection from the effects of temperature extremes, humidity, and weather during handling and stcrage.

Contrary to the above, on May 23, 1983, the inspector observed water runoff to be dripping through the upper core support structure.

Holddown bolts of control rod guide tube extensions which had been removed for split pin replacement were observed to be in contact with rags soaked in water of unknown quality. Furthermore, steps were in progress to disassemble the upper core support structure outdoors without protection required by Level "B" conditions.

This is a Level IV Violation (Supplement II).

Response

Corrective Action Taken and Results Achieved:

At the time this violation was identified, the reactor internals were in storage in a prefabricated building. In order to accomplish required rework , the roof was removed and replaced several times to permit crane j access. Although the internals were covered with poly, rain entered the building and wetted some of the loose parts. A combination of rain and high temperatures created condensation during the period that roof was being removed and reinstalled. Although NISCO employees took reasonable precautions, some parts were inadvertently wetted.

The wetted rags were removed, the internals dried, and rewor'k activities were stopped until the required Level "B" storage level was accomplished.

NISCO Procedure ES-4031 has been revised (5/26/83) to incorporate controls which are required when parts of the storage structure must be removed to facilitate equipment installation activities.

NISCO conducted training sessions which stressed the importance of maintaining required levels of equipment protection.

Corrective action was achieved on June 10, 1983.

United States Nuclear Regulatory Commission August 10, 1983 Attention: Mr. Thomas T. Martin Page 3 NRC Notice of Violation (443/83-07-01):

B. 10CFR50, Appendix B, Criterion V requires that activities affecting quality be accomplished in accordance with documented instructions.

The Seabroo'k FSAR, Paragraph 17.1.1.5, requires that acti~ities affecting quality of safety-related structures be defined in instructions.

Paragraph 4.1.1.3 of NISCO Specification ES 147 provides that Process Control Sheets (PCSs) be utilized as instructions to control and document safety-related noncode work. Paragraph 5.4.1 of ES 147 further provides that work shall be accomplished in accordance with the PCS.

Contrary to the above, on May 23, 1983, the inspector observed thermal sleeve guide to thermal sleeve plug welding (a portion of the reactor vessel internals) in progress while the PCS required machining, dowel pin insertion, and pin welding.

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

Response

Corrective Action Taken and Results Achieved:

Although an Engineering Change Authorization (ECA) permitted a revised installation method, the NISCO Process Cont rol Sheets (PCSs) had not been revised to reference the NISCO Revision Request and the ECA. The PCS was immediately corrected.

NISCO conducted retraining sessions for management and craf t covering the proper control and use of Process Control Sheets.

Corrective action was achieved on June 10, 1983.

NRC Notice of Violation (443/83-07-02):

C. 10CFR50, Appendix B, Criterion VI requires that meaaures be established to control the issuance of documents sucn as instructions, procedures, and drawings. These documents shall be distributed to and used at the location where the prescribed activity is performed. The Seabrook 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.

The NISCO Specification ES 147, Part 5.0, requires that a Supplemental Process Control Sheet (PCS) be prepared, approved, and issued in the same manner as the original PCS where additional operations are identified. The supplemental PCS is to be attached to and referenced by the original PCS.

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United States Nuclear Regulatory Commission August 10, 1983 Attention: Mr. Thomas T. Martin Page 4 i

Contrary to the above, on May 24, 1983, the inspector noted that the revision to the PCS for use .in the work area affecting the thermal

, sleeve guide to thermal sleeve plug welding only provided for j' referencing other documents and was not accomplished by issuance of 4 a revised Process Control Sheet.

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

! Response:

Corrective Action Taken and Results Achieved:

NISCO took immediate action to reissue the Process Control Sheet so that it complied with the requirements of internal procedures.

To prevent recurrence, NISCO craft and management personnel were retrained regarding the correct application of process sheets.

Corrective action was achieved on June 10, 1983.

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Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY l

John DeVincentis Project Manager

• i ALL/pf cc: Atomic Safety and Licensing Board Service List I.

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• . William S. Jcrd;n, III, Esquira Ms. Oliva L. Toth Harbon & Weiss Designated Representative of 1725 I Street, N.W. Suite 506 the Town of Brentwood Washington, DC 20006 R.F.D. 1 Dalton' Road

, Brentwood, NH 03833 Roy P. Lessy, Jr., Esquire Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus, Esquire Rye, NH 03870 116 Lowell Street P.O. Box 516 Calvin A. Canney Mancehster, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Department of the Attorney General Augusta, ME 04333 Dana Bisbee, Esquire Assistant Attorney General Mr. John B. Tanzer Office of the Attorney General Designated Representative of 208 State House Annex the Town of Hampton Concord, NH 03842 5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Pevear Town Hall Designated Representative of South Hampton, NH 03842 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Hampton Falls , NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH 03870 Designated Representative of the Town of Kensington David R. Lewis, Esquire RFD 1 Atomic Safety and Licensing Board East Kingston, NH 03827 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jo Ann Shotwell, Esquire Assistant Attorney General Mr. Angie Machiros Environmental Protection Bureau Chairman of the Board of Selectmen Department of the Attorney General Town of Newbury One Ashburton Place, 19th Floor Newbury, MA 01950 Boston, MA 02108 ,

Maynard B. Pearson Senator Gordon J. Humphrey 40 Monroe Street U.S. Senate Amesbury, MA 01913 Washington, DC 20510 (Attn: Tom Burack) Senator Gordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 70 Collins Street (Attn: Herb Boynton)

SEabrook, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 Town of Exeter 10 Front Street Exeter, NH 03833 i

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