ML20106E748
| ML20106E748 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/23/1984 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| SBN-724, NUDOCS 8410300103 | |
| Download: ML20106E748 (5) | |
Text
,t SEABAOOK STATION
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1671 Wareemer moed hominghom Mouachveens 01701 (417). E72 8100 Pub 5c Service of New Hompshire October 23, 1984 SBN 724 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, Locket Nos. 50-443 and 50-444 (b) USNRC Letter, dated August 29, 1984, " Construction Appraisal Team Inspection 50-443/84-07", R.W. Starostecki to R.J. Harrison (c) PSNH Letter, dated September 28, 1984, " Response to Construction Appraisal Team InapacH on 50-443/84-07",
J. DeVincentis to R.W. Starostecki
Subject:
Response to Construction Appraisal Team Inspection Executive Summary
Dear Sir:
In Reference (c), we stated that we planned to forward, in the near future, a response to the Executive Summary of your Construction Appraisal Team Inspection.
Attached is our response wherein we conclude all potential program weaknesses have been addressed.
Very truly yours, ghnDeVincentis, Director M.ngineering and Licensing JDV/JM/adi Attachment cc:
Atomic Safety and Licensing Board Service List 8410300103 841023 PDR ADOCK 05000443 0
PDR 1000 Elm St.,P O Box 330. Manchester, NH 03105. Telephone (603) 669 4000 TWX 7102207595 1
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. R. : S taros tecki SBN-724 Page 2 1.
Hardware is being installed and inspected while design changes continue.
This iterative design has significantly affected the - installation and It ap' ears that the full impact of
. inspection work thus far completed.
p changes and revisions have not been properly assessed by the engineering organization for their potential impact on procured and installed hard-While these changes may not be significant from the design stand-ware..
point, they may have significant impact on procured and installed hardware.
Response
-Project management established a formal Change Control Program in April, 1984. The Program is implemented by a Change Control Team comprised of representatives of Construction, Operations, Start-up, and Engineering.
The purpose of the program is to restrict des'.gn changes to those required to assure systems, structures and equipment are installed properly and will function safely and reliably during operation.
The program identifies sources of changes and mandates the expeditious completion of required changes.
A key aspect of the Change Control Program is an evaluation of the impact of proposed design changes on procured and installed hardware. The Change Control Program in place at Seabrook assures proper coordination of engineering and construction activities on all design changes.
L
R. Starostecki SBN-724 Page 3.
2.
A communication problem between the applicant's various management, engineering and construction groups (utility, engineering, contractors, and QA/QC personnel) was identified. Throughout the inspection period, numerous discussions and meetings were held to provide the NRC Construc-tion Appraisal Team (CAT) an understanding of the installation of seismic cable tray supports and the procurement classification, seismic design philosophy, and seismic qualification of the cable tray system. No con-sistent methods for control of design, procurement and installation were presented to NRC CAT inspectors by the applicant's representatives.
Response
Comprehensive improvements in the 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.
Responsibilities for all project functions are now located on site. The consolidation of the complete project team in one location, for the first time, has been a major enhancement of communication between groups.
Project procedures utilized to conduct day to day activities have been evaluated by project management and streamlined significantly.
Furthermore, the number of contracting organizations on the project has been substantially reduced. The reduction of interfacing organizations has enabled us to further simplify and streamline project procedures.
The specific problems associated with the installation of seismic cable tray supports were addressed in our letter to Mr. R.W. Starostecki, SBN-718 dated September 28, 1984, which addresses the violations of Construction Appraisal Team Inspection 50-443/84-07. Methods for control of design, procurement and installation of cable tray supports are consistent with requirements.
Previously identified concerns regarding interf acing and communication between project groups have been resolved. Lines of authority and responsibility have been clarified and continued improvement is evident.
v R. Starostecki SBN-724 Page 4.
3.
Weaknesses involving piping support installations have been previously identified by NRC Region I.
Many of these weaknesses have existed for some time. The NRC CAT inspectors noted similar programmatic weaknesses with regard to installation activities in the mechanical construction area.
Response
The responsibility for piping and pipe support installations which were previously fragmented between participating organizations have been assigned to one organization. Construction management authority and direction has been assumed by the owner, thus providing one source of direction and sole accountability. The Quality Assurance and Quality Control responsibilities on the project have also been integrated ender the same concept of singular responsibility. These changes, along with communication enhancements dis-cussed in Item 2, alleviate the potential for the programmatic weaknesses and concerns previously identified.
In summary, the project reorganization and management action taken will' minimize the potential weakness identified in the area of piping and pipe supports. We are committed to continued management emphasis in this area in order to eliminate further reoccurrences of identified concerns.
1
.. 21111am S. Jordan, III Dian3 Curran
,Harmon, Weiss & Jordan 20001 S Street N.W.
Brentwood Board of SelectJnen RED Dalton Road Suite 430 Brentwood, New Hampshire 03833 Washington, D.C.
20009 Robert G. Perlis Office of the Executive Legal Director Edward T. Meany U.S. Nuclear Regulatory Ccamission Designated Representative 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 Monceheter, 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 3. Tanner 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. Fevear Town Hall Designated Representative of South Hampton, NH 03642 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Nampton Talls, NH 03844 Selecteen's Office 10 Central Road Mrs. Sandra Cavutis Rye, NH 03670 Designated Representative of the Town of Kensington Carole T. Kagan, Esq.
RFD 1 Atomic Safety and Licensing Board Panel East Kingston, NH 03827 U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire Assistant Attorney General Mr. Angie L ehiros 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 (Attnt Toa Burack)
Senator Cordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 70 Colline Street (Attnt Herb Boynton)
SEabrook, WH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 Town of Exeter 10 Tront Street Emeter, NH 03833 w.
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