ML20128P093
| ML20128P093 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/16/1985 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20128P076 | List: |
| References | |
| SBN-791, NUDOCS 8506030458 | |
| Download: ML20128P093 (2) | |
Text
.
ENCLOSURE 4 m
SEA 3 ROOK STATION UI Engineering Office April 22, 1985 Pubec Service of New Hampshire April 16, 1985 Now Hampshire Yonkee Division SBN-791 T.F. B7.1.2 Unit'ed States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Dr. Thomas E. Murley Regional Administrator
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated March 13,1985, " Systematic Asses sment of Licensee Performance (SALP); Report Numbers 50-443/85-19 and 50-444/85-99", T. E.'Murley to R. J. Harrison
Subject:
Systematic Assessment of Licensee Performance (SALPT Report Numbers 50-443/85-99 and 50-444/85-99
Dear Sir:
Pursuant to receipt of the subject report and as discussed at the assessment meeting held March 21, 1985, we hereby submit our comments relative to specific performance issues.
In regard to concerns raised relative to cable tray supports, specifically additional bracing requirements and design modifications (hardware changes), the following program has been developed collectively by Engineering, Construction, and Quality Assurance. Each cable tray support including bracing and hardware changes will be a unique design. A preliminary schedule of cable tray support activities by building area and location has been developed and is in the final stages of development. Each cable tray support will be 100% inspected by certified personnel for configuration verification. Additionally, other characteristics of each cable tray support, i.e., anchor bolt acceptability, weld acceptability, material acceptability, will be confirmed by a combination of sof tware and hardware verifications by certified personnel.
Other issues in the electrical equipment and cable area with a potential for rework and retrofit inspections are being pursued in a similar manner.
The adoption, interpretation, and use of ASME Code Case N-302 on the project, as discussed, does not compr'omise quality nor have hold points for fit-up inspection be'en eliminated. Code Case N-302, which is endorsed by in Regulatory Guide 1.84, was adopted and implemented by the project 8506030458 850528 PDR ADOCK 05000443 G
PDR P.O. Box 300 + Seobrook.NHO3874 Telephone (603)d7dG21 i
)
United States Nuclear-Regulatory Commission April 16, 1985 Attention:
Mr. T. E. Murley, Regional Administrator Page 2 February >'84.
The Code Case provides alternate rules in lieu of the provision of Code Subparagraph NX4231.1. In essence, the Code Case requires
. qualified welders and welding operators to condition the starting and stopping ends of all tack welds that are to be incorporated into the final weld or completely remove defective tack welds. This function precludes the necessity to perform an independent visual examination of tack welds. The Code Case was only adopted for component supports by the project. Fit-up inspections were and continue to be performed by either qualified field engineers, welding
' supervisors, or QC inspectors. The inspection is so noted on the process sheet and erection drawing. In addition to the aforementioned, QC inspection personnel are required to perform daily surve,111ance of fit-up operations as well as 10% mandatory QC inspection hold point f or fit-up operations. Due to staffing ratio's, approximately 95% of fit-up inspections have been performed by certified QC personnel.
It is our contention that the current program, as revised based upon Code. Case N-302, has not compromised quality or violated Code provisions.
In the area of plant licensing and as discussed at the SALP evaluation meeting:on March 21, 1985, an inconsistency was recognized in the trend performance categorization summary of Facility Performance Section 2 and.
Performance Analysis Section 9..The trend categorization of improving indicated in Section 9 was in fact confirmed to be correct. Based upon an improving trend in the functional area and the fact that the NRC Project Manager has been reassigned on a full-time basis to the Seabrook Project, we are confident that future evaluations of plant licensing activities will receive a Category I rating.
If you have any questions or comments, please feel free to contact us.
Very truly yours, John DeVincentis Director of Licensing & Engineering JDV/mec
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