ML20127N963
| ML20127N963 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/17/1985 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| SBN-829, NUDOCS 8507020263 | |
| Download: ML20127N963 (5) | |
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9 SEABROOK STATION Engineering Office Pub 5c Service of New HampWike New Hampshire Yankee Divh June 17, 1985 SBN-829 T.F. B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Samuel J. Collins, Chief Projects Branch 2 Division of Reac tor Projects Re fe rence s :
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated May 8,1985, " Inspection Report No. 50-443/85-01," S. J. Collins to R. J. Harrison
Subject:
Response to Inspection Report No. 50-443/85-01
Dear Sir:
Our response to the violations reported in the subject inspection is provided in Attachment A, included herewith. The corrective action completion dates are also provided therein.
Very truly yours, John DeVincentis, Direc tor Engineering and Licensing Attachment cc Atomic Safety and Licensing Board Service List Director, Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 8507020263 850617
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PDR ADOCK 05000443 O
PDR I k l
P.O. Box 300. Soobrook. NH 03874. Tolophone (603) 474-9521
i 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 1
Robert A. Backus, Esquire Newburyport, MA 01950 116 Lowell Street P.O. Box 516 Calvin A. Canney Manchester, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street 1
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 Morningside 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 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 Machiros 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 Collina Street Concord, NH 03301 Seabrook, NH 03874 (ATTN: Herb Boynton)
I
8 SBN-829 Page 1 of 3 4
ATTACHMENT A A.
NRC Notice of Violation 443/85-01-04 10CFR50, Appendix B, Criterion III and the Seabrook Station FSAR, Section 17.1.1.3, require that design basis requirements, including specific values or ranges of values chosen as the bounds for a specific system design, be correctly translated into the appropriate drawings. They also require the control of design interfaces, to include coordination among participating design organizations.
10CFR50.55a(c) requires that components that are part of the reactor coolant pressure boundary (RCPB) meet the Class 1 requirements of Section III of the ASME Boiler &
Pressure Vessel Code, except as provided in subparagraph (c)(2), (c)(3) and (c)(4) of 10CFR50.55a. The FSAR in Figure 5.1-1, Sheet 1 (detail "L"), which also represents UE6C Drawing F805002, illustrates the general design of those flow restrictors serving as the ASME Section III Class 1/ Class 2 boundary for the intent of meeting the RCPB exception provided by 10CFR50.55a(c)(2)(1).
Contrary to the above, as of November 14, 1984, the date of the latest revision (Rev. 9) of UE&C Drawing F805002, a nominal 3/8" flow restrictor (0.375" I.D.) was illustrated in Detail "B" without specification of the bounds (i.e., maximum tolerance) required for the RCPB exception provided by 10CFR50.55a(c)(2)(1) to be invoked. The failure to control the design interface between the NSSS designer and the A/E in this particular case, resulted in a drawing detail which represented a nonimal drilled hole size, whereas a maximum allowable hole size was actually required, for the flow restrictors. This failure also resulted in certain flow restrictors being drilled beyond acceptable design limits.
This is a Severity Level IV Violation (Supplement II).
Response
In addition to addressing the above violation, the following also addresses the specific issues raised in your cover letter transmitting the aforementioned inspection report.
The subject restricting orifice was sized so that in the event a break should occur downstream of the orifice, during normal reactor operation, the reactor could be shutdown and cooled down in an orderly manner assuming nake-up by the Reactor Coolant Make-Up System. This also allowed the piping outboard of the orifice to be Class 2 [i.e., not Class 1 per 10CFR50.55a(c)(2)(1)].
Although inadvertently omitted on the design documents transmitted to UE&C, the hole size of 0.375", specified on Westinghouse (W)
Drawing 1099E03 was intended to be the maximum hole size for all such restricting orifices used to transition between Class 1 and Class 2 c ri te ria.
Therefore, there has been no evolution in the W design or changes in the design bases which have caused hole tolerance to become critical.
e SBN-829 Page 2 of 3 ATTACHMENT A (continued)
In order to determine if the hole sizes could be increased (e.g., determine if nominal hole sizes acceptable) }[ performed a Seabrook specific analysis which took into account such plant-specific parameters as actual piping configuration, pressurizer heater capacity and actual pump performance based on pump vendor test curves. The results of this analysis has been incorporated into plant design and where applicable, the documents were revised appropriately.
}[ has also indicated that, notwithstanding the violation of 10 CFR 50.55a(c)(2)(i), excessive flow across the orifices following a break, whether due to improper sizing, manufacture or installation, would
. not constitute a safety concern because this condition is bound by.
existing accident: analysis.
The aforementioned orifice problem was discussed with }[ and the conclusion of their discussion was that this tolerance problem was an isolated occurrence. However, since - this involves the NSSS A/E interface
}[ is performing a review of its fluid systems flow diagrams to confirm that there are no other critical tolerance that should have been communicated to UE&C (i.e., not a systematic issue).
It should also be noted that the project is perfoming an ongoing evaluation of the NSSS - A/E interface.
Corrective Ac tion All Class 1 to Class 2 transition orifices have been installed, inspected and corrective actions taken, where necessary, to make the installation comply with }[ requirements. Therefore, no further corrective action relative to the flow restricting orifices is required.
B.
NRC Notice of Violation 443/85-01-02 10 CRF 50, Appendix B, Criterion XV and the Seabrook Station FSAR, Section 17.1.1.15, require that the measures established to control nonconforming items in order to prevent their inadvertent use include, as appropriate, identification and notification to'af fected organizations.
Nonconformance Report (NCR) 82/397A identit.es a deficiency in certain installed instrument air flex hosing and specifies corrective action, to include replacement of the hoses under controlled and QC sample-inspected conditions. The NCR also requires that the specified corrective actions be taken "by construction (when the instrument ait flex hose is in their possession) and by the STD '(when the instrument air flex hose is turned over to them)." Additionally, Preoperational Test Program Instruction, TPI-01, requires that the Construction Management to the Startup Test Department (STD) include an Incomplete Items List (IIL) of all known incomplete and deficient items at the time of turnover, including all open NCR's.
SBN-829 Page 3 of 3 ATTACHMENT A E
(continued)
Contrary to the above, as of January 22, 1985, the Boundary Identification Package (BIP) CS-M-5, containing two valves (RC-LVC-459 and 460) for which NCR 82/397A was applicable, was turned over from Construction Management to the STD without the required NCR corrective action listed as incomplete item on the IIL. Also, as of March 22, 1985, the instrument air flex hoses for these two valves had not yet been replaced per the disposition to the NCR and no documented evidence was available to identify these valves as nonconforming or to assure that corrective action per the NCR would be completed.
This is a Severity Level IV Violation (Supplement II).
Response
NCR 82/0397A (Revision A) failed to specifically identify all the af fected valves (i.e., NCR provided a generic problem resolution). This resulted in the valves, cited in your violation, not being tracked to ensure completion of corrective actions. Accordingly, correc tive action is required to resolve this violation.
Corrective Ac tion Nonconformance Report No. 82/0397A was revised and reissued specifying the valves requiring hose replacement. An attachment to this NCR lists the solenoid tag number, valve tag number, building, local / rack mounted and number of green hoses.
In regards to Valves RCV-459 and -460, a work request was generated on March 3,1985 to replace the flex hoses.
Corrective action for RCV-459/460 to be completed July 1,1985.
Corrective Action to Preclude Further Violation In order to preclude recurrence of generic NCRs, the following actions were taken:
1.
A training workshop was held on April 20, 1985, with STD, QA, Systems Completion and Engineering, to discuss and clarify the Nonconformance Report.
2.
A memorandum, restating UE&C Engineering Management Policy, was generated to provide direction to project personnel for dispositioning NCRs. The memo states that all NCR dispositions must provide specific, trackable and verifiable directions to contractors performing the work (i.e., generie NCR dispositions are unac ce p table ).
3.
Procedure ASP-3 is being revised to indicate that generically dispositioned NCRs are unacceptable.