ML20107F024
| ML20107F024 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/31/1984 |
| From: | Johnson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| SBN-722, NUDOCS 8411050194 | |
| Download: ML20107F024 (12) | |
Text
A Wendell P. Johnson Vice President Putse Service of New Hampshire NEW HAMPSHIRE YANKEE DIVISION October 31, 1984 SBN-722 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter, dated August 31, 1984, "New Hampshire Yankee Division Present Role in Seabrook Construction",
W. P. Johnson to G. W. Knighton (c) PSNH Letter, dated September 25, 1984, " Amendment 53 to-March 30,1973, Application to Construct and Operate Seabrook Station Unit 1 and Unit 2", W. P. Johnson to G. W. Knighton (d) USNRC Letter, dated October 16, 1984, " Organizational Changes to Public Service Company of New Hampshire in the Seabrock FSAR", G. W. Knighton to R. J. Harrison
Subject:
Response to Information Requests Regarding New Hampshire Yankee Division Implementation
Dear Sir:
In Reference (b), we submitted annotated Operating License Application (FSAR) pages which reflected the implementation of the New Hampshire Yankee Division of Public Service Company of New Hampshire.
Subsequently, the Operating License Application was formally amended (Amendment 53) to incorporate the material previously submitted in Reference (b).
In Reference (d), you requested information to support your preliminary finding that "the changes are generally acceptable and that the QA program continues to be in accordance with 10CFR50 Appendix B".
8411050194 841031 PDR ADOCK 05000443
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I P.O. Box 700 Seabrook,NHO3874. Telephone (603)474-9521
United States Nuclear Regulatory Commission Attention:
Mr. George W. Knighton, Chief Page 2 Attached to this letter are our responses to your information requests which were included in Reference (d). Some of our responses are in the form of annotated FSAR pages which are also attached. The annotated FSAR pages will be incorporated in the next OL Application Amendment.
Very truly yours, Y
W. P.
ohnson Vice President Attachments cc: Atomic Safety and Licensing Board Service List COMMONWEALTH OF MASSACHUSETTS)
)ss MIDDLESEX COUNTY
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.Then personally appeared before me, W. P. Johnson, who, being duly sworn, did state that he is a Vice President of Public Service of New Hampshire, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Public Service of New Hampshire and that the state ents a
therein are true to the best of his knowledge and belief.
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A. L Yefen(re, Jr.
Notary Public My Commission Expires August 5, 1988 D
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William S. Jordan, III-Diano Curran
.Harmon, Weiss & Jordan Brentwood Board of Selectmen 20001 S Street N.W.
RED Dalton Road Suite 430 Brentwood, New Hampshire 03933 Washington, D.C.
20009 Robert G. Perlis 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 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 Hampton Falls, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Cavutis 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 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)
SEabrook, NH 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport HA 01950 Town of Exeter 10 Front Street Exeter, NH 03833
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'4 P 1 cf 2 SBN-722 Attachment' ATTACH E s
Responses to Questions / Comments Renardine New Hampshire Yankee Division Implementation 1.
Describe in more detail the interface responsibility between the Quality
' Assurance organization of Yankee Atomic Electric Company (YAEC)
Construction Department and the organizational units within the
'following:: 1) New Hampshire. Yankee Division (NHYD)', 2) United Engineers t
- and Constructors (UE&C), and 3) Westinghouse Electric Corporation (WRD).
Response
- FSAR Figure 17.1-1 (attached) has been annotated to fully identify the
~
integrated Quality Assurance organization which is under the authority of the YAEC Director of QA and the YAEC QA Manager. A new Figure 17.1-1A (attached) has been developed to provide a composite illustration of the
- Quality Assurance interfaces existing on the Project. Also FSAR Pages 17.1-6 (attached) and 17.1-8 (attached) have been annotated to provide a discussion of the Quality Assurance interface.
2.
Identify organizational positions within NHYD and YAEC with stop work authority and describe the extent-this authority is documented and transferred to personnel of PSNH, YAEC, UE&C, and WRD.
Response
The authority to order that work be stopped on any operation found being performed contrary to approved procedures, specifications, instructions, oor drawings rests with the YAEC Quality Assurance Manager (QAM) and personnel reporting to him. This is specifically documented in Section 17.1.1.1 of the FSAR.- This authority is transferred to personnel of PSBH, YAEC, UE&C, and Westinghouse since Quality Assurance personnel of each organization report to'the YAEC QAM. The stop work authority of project participants is further described in their corporate Quality Assurance manuals.
L
- 3.
Since Mr. E. A. Brown and G. F. Mcdonald are on YAEC payroll, describe any authority and responsibilities they have outside the Seabrook Project j
and identify appropriate percentage of time devoted to outside activities.
Response
Mr. E. A.~ Brown and Mr. G. F. Mcdonald are assigned exclusively to the Seabrook Project as are numerous Yankee Atomic Electric Company employees who are involved in Engineering, Quality Assurance, and Startup.
P f
m.
- ~
P 2 cf 2 SBN-722 Attachment 4.
-Describe those provisions for resolving disputes regarding quality arising.from a difference of opinion between QA/QC personnel and other department _ personnel within PSNH, YAEC, UE&C and WRD.
Response
FSAR Page.17.-1-1-(attached) has been annotated to include the following wording regarding the resolution of quality disputes:
~ Quality disputes between PSNH, YAEC, UE&C, and Westinghouse which cannot be resolved at the working level are brought progressively to the attention of increasingly higher levels of line management of each organization with ultimate resolution, if required, by the PSNH Chairman and Chief Executive officer.
i t
9 E____
SB 1 & 2 Am2nd;ent 53 FSAR Auguct 1984 YNSD is supplying Seabrook Station with supporting nuclear expertise in the following speci fic areas:
Mechanical Engineering Electrical Engineering Instrument and Control Engineering Systems Engineering Welding In-Service Inspection Nuclear Engineering Accident Analyses Transient Analyses Reload Analyses Ilealth Physics Dose Assessment NRC Licensing Meteorol.ogy Fuel Fabrication Fuel Procurement Fire Protection l
Vendor QA Auditing 5%
Engineering and Operational QA Emergency Planning l
63 Environmental Engineering The Seabrook Station and Nuclear Support Services Staffs supply the additional l
necennary expertise to support and operate the station.
A combination of administrative controls, the setting of specific responsibilities for each 53 organization, and open communications paths between organizations are used to annure a safe and efficent working relationship between the support organiza-tions.
13.1.1.5 Construction and construction / Operation Interface n.
Construction Phase The New Hampshire Yankee (NIIY) division of Public Service Company of New llampshire is responsible for the construction of Seabrook Station.
The overall responsibility for all activities associated with Seabrook Station resides in decending order with the PSt.Il President and Chief Executive Officer, the NHY President and Chief Executive Of ficer, and the NHY Senior Vice President, who is itesig-nated as management official in overall charge of the construetion of the station.
The N!!Y entity is dedicated to the complotion of thin construction project.
An integrated project organization has been established, working under the direction of the NilY Senior Vice President, to ensure e f fective project management control.
This integrated organization in comprised of the Director of Construction and his staff, the Director of Engineering and Licensing and his staf f; the Vice President of Nuclear Production and his staf f; and the Vice President in charge of Administrative Services is responsible for I
interfacing with YAEC Quality Assurance Departm 13.1-13 i
53 g
w-SB1&2 Amendment 53 FSAR August 1984 F
CHAPTER 17 i
QUALITY ASSURANCE 17.1 QUALITY ASSURANCE DURINC DESIGN AND CONSTRUCTION 17.1.1-Yankee Atomic Elec tric Comoany 17.1.1.1 Ormanisation a.
Authority. Re soonsib ilit ie s. and Du t ie s The Public Service Company of New Hampshire (PSNH) retains overall responsibility for Quality Assurance, and has delegated to the Yankee Atomic Electric Company (YAEC) the responsibility for the development, execution, and administration of the quality assurance
~
program which involves quality-related activities during the design, procurement, construction, and preoperational testing' phases for safety-related structures, components and systems.
Yankee Atomic Electric Company has established the organisational structure shown in Figure 13.1-2 for the design, procurement and ll g
construction phases of the Seabrook (SB) Project. This figure 44 "
i
(,
s shows the lines of authority and communication as it' relates to the Seabrook organisation. Figure 17.1-14 depict / the overall intercompany project quality assurance 4organisationSeheet. showing i
g the major organisations involved and how they interrelate. For O
( additional details, reference Section 13.1 of this FSAR.
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Westinghouse Electric Corporation-Water Reactor Divisions (WRD),
YAEC has delegated to the Engineer-Constructor, United Engineers &
Constructors Inc. (UE&C), and to the nuclear steam system supplier, r%
~
administration and execution of large portions of the quality assurance program associated with the design, procurement and installation of ' safety related structures and equipment, as defined in Tables 17.1-1,_17.1-2 and 17.1-3.
UE&C and WRD and their vendors and subcontractors who are responsible for safety-related components and structures, are required to have quality assurance programs l
consistent with the requirements of 10CFR50, Appendix B, and of th Prog ram.
g 4g The responsibilities of YAEC management are outli ned below 4 Persemgf Quality disputes between PSNH, YAEC, UE&C, and Westinghouse which cannot be resolved at the working level are brought progressively to the attention of increasingly higher levels of line management of each organization with ultimate resolution, if required, by the PSNH Chairman and
+
Chief Executive Officer.
<j 44 n
17.1-1
~
SB 1 & 2 Amendment 53 FSAR August 1984 i
qualifications and performance of personnel are evaluated annually.
The training program is described in the Seabrook Station Assurance Ma nua l.
The Quality Assurance Department is staf fed with personnel knowledgeable and qualified in the following:
e 1.
SNT-TC-1 A Levels kl and III 2.
Quality Assurance for mechanical equipment 3.
Quality Assurance for ciectrical equipment 4.
Quality Assurance for instrumentation and control equipment
~
5.
Quality Assurance for construction activities.
~
i Personnel qualification)s to review design and procurement documents and QA Programs and to perform. audits are reviewed annually at which time a determination is made for the need for further train-ing.
Responsibilities' and duties are assigned to personnel having qualificationk required for the assignments.
The QAM, and personnel
- I reporting to him, have the authority to order that work be stopped 49 on any operation they find being performed contrary to approved procedures, specifications, instruc tions, ~ or drawings.
The NHY Construction Director reports to the Senior Vice President of NRY and is responsible for managing all fleid personnel, thus ensuring that all construction-related activities are properly comple ted.
The Construction Director is charged with the responsi-bility for completing the fleid construction activities in accor-(
dance with corpora te guide lines, ;-- j--' 7 ' -- - - ' - ' ' ' - :,
project objectives, engineering drawings, specification, ins t ruc-tions, and procedures.
The Construction Director is responsible for performing the full range of management func t ions, including organizing, staffing, d irec ting, leading and controlling the work of the assigned field personnel and contractors, as well as serving as the focal point for all groups involved with the construction-related work at the jobsite, both within and outside New Hampshire Yankee.
The Director of Engineering and Licensing reports to the Senior Vice President (NHY) and is responsible for providing direction and selected review of all project engineering, design, and NRC licensing work performedi for ensuring that the project engineering organization receives consistent direction and guidance, ensuring consistent and acceptable quality throughout the engineering organizationi and for evaluating the impact of regulatory changes to the project.
SS 17.1-4
S SB 1 & 2 Amendment 53 FSAR August 1984 The UE&C organization is described in Topical Report No.
UEC-TR-001.
The WRD organization is described in the Westinghouse WRD Quality Assurance Plan (WCAP-8370).
gg The interface between YAEC and UE&Ch :'it; _..,.. _- t is shown in l
3 l/g/ /jH___ Figure, '.: 1.
The YAEC Construction Quality Assurance Manager M
has atrecq --
'" "^'
" " " regarding l
M quality-related activities. YAEC reviews and concurs with all 49 l3 5
quality-related procedures, programs, plans, etc. that are generated 1 Q,
by the AE (UE&C). YAEC reviews and concurs with the Westinghouse 44 QA Topical Report and reviews department procedures in the process l
of auditing Westinghouse performance.
O tj The contractors are responsible for the review and approval of h '*-
their supplier and subcontractor quality related documents. The g
adequacy of the contractors' reviews are verified by YAEC audit and/or surveillance either at contractors' facilities' or at the
- fl h
facilities of supplier and subcontractors. Audit and/or surveil-Np lance of contractors (AE) and suppliers is performed by YAEC home office personnel. Surveillance of subcontractors at the construc-k tion site is performed by the YAEC QA representatives assigned to 4L the site. Audit at the construction site will be performed by N 8h YAEC home office QA personnel.
.0fkg b.
_ Responsible Management Levels t 'n Public Service Company of New Hampshire, has overall responsibility l
for quality assurance on the Seabrook Project. The Chief Executive 53 Officer of PSNH has delegated to YAEC the responsibility for establishment and implementation of the Quality Assurance Program.
He, or his staff, maintains cognizance of and evaluates the Program activities in the following manner.
1.
Review and approval of the YAEC Quality Assurance Program as i
described in the Seabrook Station Quality Assurance Manual.
2.
Participates in major QA decisions and program changes.
3.
Receives copies of all YAEC audit reports (internal and external) pertaining to the Project. Monthly he receives the Status of Outstanding Items indicating the status of audit findings.
4.
Participates on a quarterly basis in selected external audits by YAEC to assess YAEC performance in contractor activities.
As an alternate to participating in the audit, they may review YAEC external audit reports. The diversity of audits 17.1-6 l
t
SB 1 & 2 Amendment 53 FSAR August 1984
(
b of safety related equipment is performed by either UE&C or Westing-Q' house under the provisions of their topical reports and QA Programs.
j These are reviewed and concurred upon by YAEC personnel. Compliance l
g- @3 to the aforementioned is assured via a system of audits performed 53 by YAEC Home Office personnel who also review the UE&C and Westing-O}
house in-house departmental procedures. UE&C and WRD, and their g%* $(
components or structures, are required to have quality assurance
- b. s vendors and subcontractors who are responsible for safety-related w
g programs consistent with the requirements of 19CFR50 Appendix B, and of this Program.
genj-Q)g The UE&C and WRD quality assurance programs are extensions of the Eku YAEC program and as such have been reviewed and accepted by YAEC.
The structure of the UE&C quality assurance organization is Q*[tt.
described in the UE&C Quality Assurance Program (Topical Report No. UE&C-TR-001) and referenced in Section 17.1.2 of this FSAR.
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),
The structure of the WRD quality assurance organization is described a
k$,j in the Westinghouse NES Divisions' Quality Assurance Plan Topical s
g.
f Report (WCAP-8370) and referenced in Section 17.1.3 of this FSAR.
3
)g Both Topical Reports have been reviewed and approved by the Nuclear Regulatory Commission.
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F Conformance to approved requirements and close' liaison between the Project "--.2 (programs is assured through
$ p,gg k g and between their quality assurance organizations.g of YAEC,IWRD and UE&C 4
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l YAEC maintains control of contractor and internal quality-related -
53 g
activities principally by means of an audit and surveillance g
program which. involves audits, surveys, investigations and reviews by the YAEC Project staff, Engineering, Quality Assurance, and
. Site Quality Assurance.g 17.1.1.2 Quality Assurance Program In order to assure overall implementation of the quality assurance requirements, YAEC has developed a Program which covers quality-related activities during design, purchasing, fabrication, constructien, and preoperational testing which affects those structures, systems and components that are necessary to assure the 'integri::y of the reactor coolant pressure boundary,' the capability to shut down the reactor and fgt:grface be$.sJttM. WC, uffe gnd WAD s defIcl Q E
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con trs/ ol-t1c' $uali?fssesi,ee Q<am.
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