ML20125D351

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Requests Evaluation & Concurrence to Implement Revised Program for Field Fabrication & Installation of Class 2 & 3 Pipe Support by 850628.Detailed Comparison Between Proposal & Existing Program Encl
ML20125D351
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 06/10/1985
From: Johnson W
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Knighton G
Office of Nuclear Reactor Regulation
References
SBN-817, NUDOCS 8506120326
Download: ML20125D351 (8)
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Wendell P. Johnson Vice President Put2c Service of New Hampshire NEW HAMPSHIRE YANKEE DIVISION SBN- 817 T.F. B4.2.7 B7.1.2 United States Nuclear Regulatory Commission Washington, DC 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) Seabrook Station FSAR Section 3.2.2, " Quality Group Classification"

Subject:

Pipe Support Program Dear Sir We request your evaluation and concurrence to implement a revised program for the field fabrication and installation of Class 2 and 3 pipe support. This proposed program would require that the supports be designed, procured, fabricated installed, and examined in accordance with the rules of ASHE Section III, Division I, Subsection NF of the 1977 Edition and all addenda there to, up to, and including, the Winter 1977 addenda.

A detailed comparison between our proposal and the existing program relative to Subsection NF, is provided in Attachment 1. As indicated therein, this proposed program would provide for a system of third party surveillance and audit inspection in lieu of in-line inspection hold points and would not require executing NF-2 Data Reports or Code Symbol Stamping.

This attachment also indicates that a statement would be provided with the N-5 Data Report since a NF-2 Data report would not be executed.

In regards to third party inspection activities, our authorized Nuclear Inspection Agency (ANIA) has developed a survelliance, audit, and limited certification program which is to be used if our proposed pipe support program is implemented. We have included a copy of our ANIAs program for your information (See Attachment 2). Systems listed in Attachment 3 shall receive additional third party surveillance inspection (e.g. increased frequency of nurveillance inspection ). These systems were selected from thirty (30) Safety Class 2 and 3 systems evaluated by our engineering staff. During this evaluation, consideration was given to, among other things, system operation, failure mode, envrionmental conditions, and design margin to determine which supports should receive the additional third party survie11ance inspection.

We are presently developing, in conjunction with the ANIA, a surveillance frequency plan. }

D 3 P.O. Box 700

  • Seabrook,NH03874
  • Telephone (603)474 9521

~ ** -' iPagi 2 United Statcs Nucl00r R:gulctory Cramicolon Mr. George W. Knighton The Jurisdictional Authority (i.e., State of New Hamphsire) is familiar with the proposed pipe. support program and has indicated that a _ state special

. waiver, relative to the proposed program, will be issued upon written notification of your concurrence.

In conclusion, the proposed pipe support program, as described, meets the requirements of 10CFR50, Appendix B, and is technically acceptable. Our QA/QC program descriptions, included in FSAR, Section 17.1, regarding the three levels of QA would remain unchanged if the proposed program was implemented.

Further, the proposed program will provide adequate assurances that the pipe supports will be designed, procured, fabricated, installed and examined in accordance with the rules of Subsection NF.

We request your concurrance of the proposed pipe support program by June 28, 1985. If your should require any additional information/ clarification, please do not hesitate to contact our Mr. G. F. Mcdonald at (603) 474-9521 (Extension 2098).

Very truly yours,

%9 . Mm W. P. Johnson Vice President Enclosure cca Atomic Safety and Licensing Board Service List United States Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Attn: Mr. Richard W. Starostecki, Director m

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William.S. Jordan, III Donald E. Chick

- Diane Curran Town Manager Harmon, Weiss & Jordan Town of Exeter 20001 S.' Street, N.W. 10 Front Street Suite 430~ Exeter, NH ~ 03833 Washington, D.C. 20009 Brentwood Board of Selectmen '

- Robert G. Perlis RED Dalton Road Office of the Executive Legal Director Brentwood, NH 03833 U.S. Nuclear Regulatory Commission ,

Washington, DC 20555 Richard E. Sullivan, Mayor  !

City Hall Robert A. Backus, Esquire Newburyport, MA 01950 116 Lowell Street P.O. Box.516 Calvin A. Canney City Manager Manchester, NH 03105 ,

City Hall Philip Ahrens, Esquire 126 Daniel Street

Assistant Attorney General Portsmouth, NH 03801 Augusta, ME ' 04333 '

Dana Bisbee, Esquire Mr. John B. Tanzer- Assistant Attorney General Designated Representative of Office of the Attorney General the Town of Hampton 208 State House Annex 5 Morr.ingside Drive Concord, NH 03301 Hampton, NH 03842 Anne Verge, Chairperson Roberta C. Pevear Board of Selectmen Designated Representative of Town Hall the Town of Hampton Falls South Hampton, NH 03827 Drinkwater Road Hampton Falls, NH 03844 Patrick J. McKeon Selectmen's Office Mrs. Sandra Gavutis 10 Central Road E Designated Representative of Rye, NH 03870 the Town of Kensington RFD 1 Carole F. Kagan, Esquire East Kingston, NH 03827 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire Washington, DC 20555 Assistant Attorney General ,

Environmental Protection Bureau Mr. Angi Michiros -

Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Newbury Boston, MA 02108 ~ Newbury, MA 01950 ,

Senator Gordon J. Humphrey Town Manager's Office  !

U.S. Senate Town Hall - Friend Street Washington, DC 20510 Amesbury, MA 01913 (ATTN: Tom Burack)

Senator Gordon J. Humphrey Diana P. Randall 1 Pillsbury Street 70 Collins Street Concord, NH 03301 Seabrook, NH 03874 (ATTN Herb Boynton)

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ATTACHMENT #1 PIPE SUPPORT PROGRAM COMPARISON

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Total # of supports CL 2 and CL 3 for piping approximately 4500 Total f of supports CL 2 and CL 3 for Inst. and control approximately 1500 Existing Criteria (ASME III NF) Proposed Design ASME III ASME III.

Procurement ASME III ASME III Fabrication ASME III ASME III Installation ASME III ASME III Examination ASME III ASME III ANI Involvement ASHE III Surveillance and Audit

-Data Reports ASME III Statement on N5*

Stamping- ASME III None ISI ASME Section XI ASME Section XI

  • Statement attached to N5 Data Reports indicating design, procurement, f abrication, installation, and examination performed in accordance with ASME III NF confirmed by ANI Surveillance and Audit.

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",, ATTACID1ENT #2 Sheet 1 of 3 j I 1

-GROUP I I Lumbermens Mutual Casualty Company

  • American Motorists Insurance Company American Manufacturers Mutual Insurance Company
  • American Protection insurance Company

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Special Inspection Services Section,1020 Plain Street, Marshfield, MA 02050 617l837-6326 PROPOSED SURVEILL ANCE & AUDIT PROGRAM CLASS 2 & 3 COMPONENT SUPPORTS - ASME DATA REPORT & CODE SYMBOL STAMPING EXCEPTION Surveillance and audit activities shall be performed in accordance with ANSI N626.0 and SISS Quality Assurance Manual requirements.

The attached proposed " surveillance and audit" program defines the methqd of conducting and documenting the surveillance and audit functions. We welcome any comments, and revisions to the program will be made and resubmitted to the Project Quality Assurance Manager for acceptance.

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R. D. Norris 3/ca/sc Date Lumbermens Mutual Casualty Co.

Regional Manager LCE SISS / Northeast

  • - .* , ATTACHMENT #2 Shret 2 of 3 SURVEILLANCE AND AUDIT PROGRAM SEABROOK STATION 1.0 PURPOSE -

The purpose of this program is to define the requirements for the surveillance and audit activities to be performed on the class 2 and 3 component supports which will be field fabricated and installed without ASME Code Symbol stamping and ASME Code Data Report execution.

2.0 RESPONSIBILITY The ANIS shall be responsible to cudit the fabricators and installers quality assurance progrsm in accordance with the SISS Quality Assurance Manual and ANSI N626.0 requirements.

The frequency of the audit shall be at least twice per year.

The Lead ANI shall be responsible to implement this program and to monitor its effectiveness. He shall coordinate the surveillance activities and be responsible to distribute surveillance reports to the site contractors and to the Project Quality Assurance Manager. Any conditions of un-acceptance or non-conformance shall be documented by the site ANI's, and submitted to the Lead ANI for further processing and resolution.

The Site ANI's shall be responsible to perform surveillance inspections and program monitoring in accordance with SISS Quality Assurance Manual requirements. Surveillance activi-ties shall be documented, using the " Quality Program Monitor-ing Report", form ZA 8043, (Exhibit A]

3.0 SURVEILLANCE CRITERIA AND OBJECTIVES -

The objectives of each surveillance activity is to verify compliance of the following:

A) Proper implementation of fabricators / installers Quality Assurance Program Manual and supporting procedures.

B) That fabrication / installation inprocess work meet the acceptance standard requirements of the Code and inprocess procedures.

4.0 SURVEILLANCE PERFORMANCE Once per shift, one traveller / work package for each con-tractor shall be subject to ANI surveillance. The ANI shall erform and document p' Quality Program Monitoring Report",each surveillance form ZA 8043. activity, using the The ANI shall inspect and/or verify any fabrication /

installation activity that he feels is necessary to assure that the quality levels are being achieved, and all elements of the program are being implemented, t

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. , ' ATTACHMENT #2 Sheet 3 of 3 Surveillance and Audit Program Seabrook Station - Page 2 The ANI shall incorporate final "as built" verification of the component supports into final "as built" inspections of the piping systems.

Prior to execution of the piping system N-5 ASME Data Report, the ANI shall assure that the component supports of each system meet the requirements of the Code and Design Specification. A limiting certification defining Component Support Compliance to Code (with exception) shall be mutually agreed upon, and included into the N-5 Data Report.

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