ML20098G305
| ML20098G305 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/28/1984 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| SBN-718, NUDOCS 8410040331 | |
| Download: ML20098G305 (13) | |
Text
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SEABROOK STATION
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1671 Worcewer Rood fhamingham Mouachvietts 01701 (617). 872 0100 Put2c Service of New Hampshire NEW HAMPSHIR2 YANKEE DIVISION September 28, 1984 i
SBN-718 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
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Latter, dated August 29, 1984, " Construction Appraisal Team Inspection 50-443/84-07", R. W. Starostecki to R. J. Harrison
Subject:
Response to Construction Appraisal. Team Inspection 50-443/84-07
Dear Sir:
We have attached our responses to the violations reported in the subject inspectv>n.
We plan to forward, in the near future, a response to your Executive Summary wherein ycu delineated " program weaknesses that imply management deficiencies".
Very truly yours,
/
John DeVincentis, Director Engineering and Licensing Attachment cc: Atomic Safety and Licensing Board Service List Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 8410040331 840928 PDR ADOCK 05000443 G
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1000ElrnSt..P.O Box 330 Monchester.NHO3105 Teiephone(603)669-4000 TWX7102207595 0
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' William S. Jordan, III Dians Curran Harmon, Weiss & Jordan Brentwood Board of Selectmen 20001 S Street N.W.
RED Dalton Road Suite 430 Brentwood, New Hampshire 03833 Washington, D.C.
20009 Robert G. 9erlis Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Wanhington, 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 03301 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 Carole F. Kagan, Esq.
RFD 1 Atomic Safety and Licensing Board Panel East Kingston, NH 03827 U.S. Nuclear Rogu13 tory Commission
'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 Town Manager's Office Senator Gordon J. Humphrey Town Hall - Friend 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)
SEabrnok, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 Town of Exeter 10 Front S6reet
'Exeter, NH 03833 t
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.l.
Contrary to 10CFR50 Appendix B, Criterion II, and the Seabrook Station Final Safety Analysis Report'(FSAR), Section 17.'.
1.2, the applicant's
. quality assurance-program has not effectively provided control over activities involving seismic cable tray support installations. The
~ applicant's programs have not assured that these installations are in accordance with the applicable design documents. This condition appears
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-to exist _because design activities are no't appropriately coordinated with engineering and construction organizations (Section II.B.1).
RESPONSE
~ Comprehensive' improvements in project. organization have been underway
'since~ March 1984. The project organization has been integrated within a clearly defined structure which. establishes singular responsibility for each project function.. This new management direction has successfully irproved communications between engineering and construction.
?As part of the reorganization, all electrical installations are performed by direct force account of labor and no longer by construction management
=of'aEcontractor. The elimination of the construction management interface has also" contributed to improved communication.
- Engineering will specifically define all design requirements for installation and inspection of all seismic cable tray supports.
Design requirements for all seismic cable tray supports will be organized into an explicit, systematic package consisting of the following documents:
1 ;
- 1.
El'ectrical System Drawings (sectional views)
.2.
- Electrical Support Drawings (unique support configuration)
J3.
Plan and Elevation Drawings (axial bracing supports) 4.
. Cable Tray Notes'and Details (Drawing 300229)
- 5.. " Bill:of' Material" (Drawing 300220)
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6.
Engineering Change Authorizations (All seismic cable tray supports will'be inspected by Quality Assuranc( to the above referenced document package to assure installations are in
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accordance with the design requirements.
The engineering program described is~ currently in place.
Issuance of document packages is scheduled to commence January 1985.
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2.
Contrary to 10CFR50, Appendix B, Criterion III, and the Seabrook Station FSAR, Sectior.17.1.1.3, design control has not been maintained as - the applicant has:
-2.a.1 Fsiled to properly review design changes relative to instrument tubing installations in a manner commensurate with the original design review. This is illustrated by a number of instances in
-which deviations from specified slope criteria have been authorized by the construction manager, rather than the responsible design organization (Section II.B.5).
~ RESPONSE Deviation from specified slope criteria can no longer be authorized by the construction manager.
ECA 05/1206A has been voided to reflect this.
Specification for Instrumentation Installations (9763-006-46-1) will be revised to include specific slope criteria that will address the majority of instances where the present minimum slope of 1/4" per foot cannot be achieved.
Deviations from the revised criteria that are required for construction will be addressed in accordance with our design control procedures that meet the requirements of 10CFR50, Appendix B.
Documentation of safety-related construction activities conducted after ECA 05/1206A was approved on April 23, 1984, will be revised to assure
'that all deviations-from the slope criteria ar's identified, dispositioned and properly documented. This review is expected to be completed by December 21., 1984.
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2.
Contrary to'10CFR50, Appendix B, Criterion III, and the Seabrook Station FSAR, Section 17.1.1.3, design control has not been maintained as the applicant has:
.2.a.2 Failed to ensure that materials specified for foundation attachments'for the Primary Component Cooling Pumps were similar to those used in the Seismic Analysis (Section III.B.4).
RESPONSE
The anchor bolts specified for the Primary Component Cooling Water Pumps were designed to be consistent with the results of the Seismic Analysis.
UE&C.is responsible to design the anchor bolts using results of seismic analysis perfoceed by the vendor. The~UE&C evaluation of the vendor seismic-report revealed an overly conservative approach in deteomining anchor bolt loads. The vendor had summed absolutely the components of anchor reactions due to earthquake acting simultaneously in three orthostnal' directions..This resulted in unrealistically high anchor bolt
-loads. 'UE&C chose to utilize the SRSS (Square Root of Sum of the Square) method of combining seismic ~ anchor reaction components to determine anchor bolt loads. This resulted in lower anchor bolt loads than those calculated byzthe vendor and allowed the use of ASTM-A36 steel bolting material.
The anchor bolt locations for the PCCW Pumps is the same as specified by
.the' vendor. The vendor's seismic qualification analysts was used to calculate anchor bolt loads. _'Therefore, the integrity of the PCCW Pump foundation is maintained, and the vendor's seismic qualification remains valid.
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2.
-Contrary to 10CFR50, Appendix B, Celterion III, and the Seabrook Station FSAR, Section 17.1.1.3, design control has not been maintained as the applidant has:
.2.b-Not properly translated design drawings into fabrication and installation drawings in the area of rebar details around openings. Vendor rebar detailing errors have occurred and have not been identified during the drawing review or construction process (Section IV.B.1).
RESFONSE We have reviewed the rebar detailing inconsistencies identified by the l-NRC Construction Appraisal Team and have concluded that the structural adequacy has not been adversely affected by the inconsistencies.
A program has been implemented to review additional vendor rebar drawings
'on a sampling basis to assure.that the vendor drawings are consistent with the design drawings. We expect this program to be completed by December 31, 1984.
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-Contrary to 10CFR50,' Appendix B, Criterion III, and the Seabrook Station
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FSAR, Section 17.1.1.3, design control has not been maintained as the u
applicant has:
.2.c Not properly' considered design loading conditions for four hot leg restraints and one cross-over les restraint. The seismic loading from an attached pipe support had not been considered as a separate loading case without other pipe breaks
' (Section IV.B.2).
RESPONSE
- Seabrook ' primary coolant loop is provided with hot leg and cross-over leg
' restraints in each of the four loops. These restraints are massive steel structures designed to resist very heavy pipe whip loads.
During the course of plant design, pipe supports were attarAed to four hot leg and one cross-over les restraint. Since the loads were small, they were inadvertently not documented'in the design calculations. A preliminary review of these cases where loads were not accounted for was made subsequent to.the NRC Construction Appraisal Team audit, and the result showed that the' integrity of the restraints is maintained. The loading condition for these and all future load cases will be properly documented in calculation sets to avoid similar occurrences. However, these calculation sets will not be updated until the NRC responds to our request (SBN-703) for exemption from Ceneral Design Criteria 4 regarding postulation of Reactor Coolant System pipe breaks. This exemption will eliminate-the~ requirement for the primary coolant loop restraints.
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3.
. Contrary to 10CFR50, Appendix B, Criterion V, and the Seabrook Station
'_FSAR, Section 17.1.1.5, the applicant has failed to effectively perform
' instructional and procedural activities in that several pieces of ASME III." safety-relatst" equipment were installed without instructions, procedures and quality control documentation. _ In addition, the procedure regarding the handling and installation of safety-related equipment did not contain _ adequate guidance or instructions to ensure appropriate
- qualitative and quantitative acceptance criteria and documentation.
RESPONSE ~
The violation occurred due to a conflict between the FSAR and UE&C specifications. UE&C Specification 263-2 has been revised, via an Engineering Change Authorization to correctly reference the equipment contained in Tables 3.21 and 3.22 of the Seabrook FSAR. Fullman-Higgins' Procedure IX-09 will be similarly revised to reflect UE&C requirements.
Additional changes to the P-H procedure require that installation records include documentation of alignment, indication whether alignment is initial or final, referencing of calibrated equipment utilized and reference to the installation instructions u ed.
Corrective action will be completed by December 31, 1984.
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4.
Contrary to 10CFRLO, Appendix B, Criterion X, and the Seabrook Station FSAR, Section'17.1.1.10..the program for inspection of activities affecting quality was not effectively implemented in that inspection programs have not assured that high strength structural steel bolted-connections have the proper tension (Section VI.B.2).
In addition, structural' steel shop' weld inspections were found to be deficient with respect to the specified acceptance criteria (Section C.B.7).
RESPONSE
Structural Steel Bolted' Connections Inspection of htructural Steel Bolts for installation preload was performed using the following approaches:
'1.
Visual inspection to assure that the bolts were properly tightened.
- 2.. Bolt torque verified based on a random and independent torquing of installed bolts.
A program has been initiated to determine the design adequacy of the existing installation by determining the actual preload in the bolts identified by the NRC Construction Appraisal Team as having low torque values. This program will also attempt to identify the cause for the relaxation of the tension. Appropriate corrective action will be taken, if required, to meet the design / code requirements.
This program wf;l be completed by March 31, 1985.
Structural Steel Welds Twenty (20) structural steel welds identified by the NRC Construction Appraisal Team as deficient have been evaluated. The connections were determined to be adequate taking no credit for-the area of the deficient weld.
A program has been initiated to review all other similar connection welds. We expect to complete our total evaluation by March 31, 1985.
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5.
Contrary to 10CFR50, Appendix B, Criteria XV and IVI, and the Seabrook Station FSAR, Sections :L7.1.1.15 and 17.1.1.16, the applicant's program has. failed to. assure that nonconforming conditions have been properly-identified. 1 Reviewed, resolved and evaluated for corrective action in accordance.with documented procedures in that:
'5.a
?rhe program for inspection of construction activities failed to identify a number of : cable installations that did not meet established criteria for physical independence of redundant-electrical divisions. Most of the deficiencies identified invol' red cables and control panels transferred to "startup" jurisdiction.
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The~ concerns identified in the Main Control Board (MCB) by the NRC Construction Appraisal Team were in areas of ongoing' fleid modification work and have been' corrected while completing the work or will be corrected when the modification package is ccmpleted.
-Additional training sessions covering separation criteria will be conducted to-instruct inspectors to look for separation violations and to
. identify those that are not part of ongoing modification work.
YAEC QC will conduct a final inspection of the MCB for separation
- violations at the time of conditional Acceptance Turnover.
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a-5.
Contrary to 10CFR50, Appendix D, Criterin KV and XVI and the Seabrook Ltation FSAR, Sections 17.1.1.15 and'17.1.1.16, the applicant's program has. failed to assure that nonconforming conditions have been propeely identified, reviewed, resolved and evaluated for corrective action in accordance with documented procedures in that:
5.b Nonconforming conditions on piping and pipe supports / restraints were documented on informal reports or menoranda,-and on Engineering Change Authorizations. In addition, nonconforming conditions on pipe support / restraints were improperly corrected / resolved cut Support Rework Orders and Engineering Change Authorizations.
RESPONSE
A review of applicable Pullman-Higgins (P-H) procedures determined that they contain adequate instructions relative to the reporting of deficient conditions.
Since P-H will now be performing the as-building of piping-installations, deficiencies will'be marked on the drawings and will eliminate the use of speed-memos.
Engineering will review the drawings and determine the adequacy of as-built conditions.
An NCR was initiated to document the incorrect attachment location which had been originally reported in a memo, and the situation has been satisfactorily resolved.
Corrective action in the above items was completed on September 18, 1984.
P-H is evaluating the zero-gap relative to cold-springing. The gap was veelfied and recorded on the erection drawing. Corrective action for this item will be completed by December 31, 1984.
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,4-5.,
Contrary to 10CFR50, Appendix B, Criteria IV and XVI, and the Seabrook Station FSAR, Sections 17.1.1.15 and 17.1.1.16, the applicant's program has failed.to assure that nonconforming conditions have been properly identified, reviewed, resolved and evaluated for corrective action in accordance with documented procedureu in that:
5.c Corrective measures were taken in order to maintain proper torque on Hilti concrete expansion anchor bolts. However, a significant number of mechanical and electrical anchor bolts were found to be below the miniram specified torque values (Section IV.B.4).
- RESPONSE The NRC Construction Appraisal Team Report indicates that 92% of the Hilti Kwik-Bolts they inspected meet QA torque check values. We have considered the reduction in. torque for the remaining 8% of the bolts and
-have concluded that our existing Hilti anchor installation procedure is adequate.
Due to the non-homogeneous nature of the concrete materials it is
, impractical ~to maintain the minimum specified torque values for 100% of the bolts.
The affect of preload on anchor bolt performance has been examined in two
.(2) Independent tests which have been submitted to the NRC.
The results of these tests are as follows:
1.
Teledyne Report #TR3501-1, Revision 1, Summary Report - Generic Response to USNRC IE Bulletin Number 79-02, Base Plate / Concrete Expansion Anchor Bolts.
This test demonstrates that cyclic loading does not decay the ultimate capacity of non-preloaded expansion anchors.
2.
Hanford Engineering Development Laboratory Final Report USNRC Anchor Bolt Study, Data Survey and Dynamic Testing, NUREG/CR-2999 HEDL-MISC 7246.
This test demonstrates there is no significant difference in anchor deflections under dynamic loads at 50 percent and 100 percent preload.
These tests support our conclusion that the initial setting of the anchor to a torque' equal to 1.5 to 1.7 times the maximum allowable design load ensures the load carrying capability of the Anchor System. We therefore consider our procedure for installation of Hilti Kwik-Bolts to be adequate.
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5.
-Contrary.to 10CFR50 Appendix B, Criteria XV and XVI, and the Seabrook Station FSAR, Sections 17.1.1.15 and 17.1.1.16, the applicant'c program has failed to assure that~ nonconforming conditions have been properly identified, reviewed, resolved and evaluated for corrective action in accordance with documented procedures in that 5.d Measures were not taken to identify nonconformances and take corrective action to provide for control of cable identification and markings in accordance with FSAR commitments and specification requirements.
~RgSPONSE As the result of a YAEC Management Action Request, UE&C contacted each supplier of cable to the Seabrook Project. Vendors responded with a listing of: cable by reel number, length, footage range and serial number. This data will be utilized for comparison with future shipments. Cable with duplicate markings has been identified and controlled under UESC NCR No.74/2551A.
Cable pull slips.have been marked to notify installers when overlapping footage marking exists.
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YAEC surveillance personnel will continue to monitor these controls on a continuing basis and will keep the NRC site inspector cognizant.
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