ML20106E336

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Responds to NRC Re Violations Noted in Insp Repts 50-443/84-17 & 50-444/84-07.Corrective Actions:Rev B to Design Change ECA 19/100008A Issued on 841201,incorporating Rev to ASME Code Case Edition N237-1
ML20106E336
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 02/07/1985
From: Devincentis J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
SBN-760, NUDOCS 8502130282
Download: ML20106E336 (3)


Text

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SEABROOK STATION Engineering Office h h WNew M February 7, 1985 New Hampshire Yonkee Division SBN-760 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 Pro' ject and Resident Programs

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated January 7, 1985, " Combined Inspection Nos. 50-443/84-17 and 50-444/84-07", S. J. Collins to R. J. Harrison

Subject:

Response to Combined Inspection Nos. 50-443/84-17 and 50-444/84-07

Dear Sir:

It was reported in the subject Inspection Report that one of our activities was not conducted in accordance with commitments in the FSAR.

In response to the reported FSAR deviation, we offer the following:

FSAR Deviation The Seabrook FSAR, in Section 1.8, specifies conformance to the provisions of USNRC Regulatory Guide 1.84 for use in Balance of Plant design applications. Regulatory Position C.3 of Regulatory Guide 1.84 states that ASME Code Case editions that have been superseded by revised code cases are no longer endorsed by USNRC regulatory guidance, as of the date of approval of the revised version of the code case. Furthermore, UE6C Specifications (e.g.,

248-43) list those code cases approved for use at Seabrook.

Contrary to the above, a design change (ECA 19/100008A) directed the use of a code case edition (N237-1), which had been superseded more than one year prior to the design change approval date. Also, Specification 248-43 was not revised to list the newer edition of the code case being adopted by the design change.

This resulted in not only a deviaticn from Regulatory Guide 1.84 and conflicting design criteria in the specification and ECA, but also the unauthorized waiver of a nondestructive examination of certain welds affected by Code Case N237.

This deviation is applicable to Docket Nos. 50-443 & 50-444, 85021302 m 300. hd W 03874. TW W3)474%21 gDR ADOck o h $3

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' United States Nuclear Regulatory Commission

' Attention:

Mr. Richard W. Starostecki, Director Page 2

' Corrective Action The revision of this code case (N237-0) which was approved for use at Seabrook, as indicated in the FSAR (Table 1.8-2), has been included in Revision B of the design change (ECA 19/100008A) issued December 1, 1984 To assure control of ASME Code Cases in the design change process, the following actions will be taken:

o Administrative' Procedure No.15, " Project Design Changes", has been revised to require Yankee Atomic Nuclear Services Division review and approval of ASME Code Cases adopted for use.

o All effected Engineering personnel will be instructed to conform to Regulatory Guides 1.84 and 1.85 and FSAR commitments.

o' In addition, we are currently reviewing the previous practice regarding the use of code cases on both the BOP and NSSS Systems to ensure compliance with regulatory requirements and FSAR commitments.

We expect these activities to be completed by June 28, 1985.

Verytr7y

ours,

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JJ. DeVincentis, Director Engineering' and Licensing cc: Atomic. Safety and Licensing Board Service List

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aM. Cilliam S. Jordan,.III Diano Curran Harmon, Weiss & Jordan 20001 S Street N.W.

Brentwood Board of Selectmen Suite 430 RED Dalton Road Washington, D.C.

20009 Brentwood, New Hampshire 03833 Robert G. Perlis Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representativq of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus. Esquire Rye, NH 03870 116 Lowell Street F.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 Rampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Fevear Town Hall Designated Representative of South Hampton, NH 03642 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Naapton Falls, NH 03644 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH 03670 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 Regulatory Commission Jo Ann Shotwell Esquire Aasistant 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 Roston,.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)

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