ML20137Z872

Notice of Violation from Insp on 850603-14

ML20137Z872
Person / Time
Site:	Seabrook
Issue date:	10/03/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137Z860	List: ML20137Z854 ML20137Z872 ML20137Z900
References
50-443-85-15, NUDOCS 8510080395
Download: ML20137Z872 (6)

Text

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APPENDIX A NOTICE OF VIOLATION Public Service Company of New Hampshire Docket No. 50-443 Seabrook Station, Unit 1 Construction Permit No. CPPR-135 As a result of the Construction Team Inspection conducted on June 3-14, 1985, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified:

A.

10 CFR 50, Appendix B, Criterion III states in part, " Measures shall be established to assure that... the design basis,... for those structures, systems, and components to which this Appendix applies are correctly translated into specifications, drawings, procedures and instructions".

Contrary to the above, as of June 6, 1985, the seismic installation criteria for the instrument tubes crossing a seismic boundary were not translated into the licensee's instrument tubing installation specifica-tion.

As a result, instrument tubing runs FW-I-3, IA-2960 and IA-2963 were installed without adequate seismic anchor displacement considera-tions.

This is a Severity Level IV Violation (Supplement II).

B.

10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented... procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these... procedures...".

Paragraph 5.1.6.2 of Seabrook Administrativo Procedure No. ASP-3, "Non-conformance", Revision 2, dated May 15, 1985 requires the contractor to submit the original NCR form to engineering for processing.

Contrary to the above, as of June 11, 1985, two NCRs (Nos. 93/667 and 93/666), which documented installation nonconformances of two seismic Category I installations, were not submitted to engineering for process-ing.

This happened because these NCRs were incorrectly voided by the lead QC inspector due to his misinterpretation of seismic requirements.

As a result, the non-conforming conditions for instruments SI-FI-918 and SI-FI-922 were left uncorrected.

This is a Severity Level IV Violation (Supplement II).

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c Appendix A 2

C.

10 CFR 50, Appendix B, Criterion I, and Section 17.1.1.1 of the Seabrook Station FSAR require the establishment and clear delineation of the duties, for both performing and quality assurance functions including those delegated to contractors for safety-related activities.

UE&C Procedure QA-1 (Revision 15) delineates the responsibilities of the Architect-Engineer (A/E) to assure the control of quality related activ-ities from engineering and design standpoints, as well as the responsibil-ities of the Construction Manager to manage and coordinate construction and contractor efforts within the delegated scope of quality related work.

Within the scope of quality related work are the design activities for safety-related pipe supports.

UE&C Specification 248-51 (Revision 17) states that, with respect to pipe support installation, "All hangers (piping supports)... shall be located with respect to the as-built location of the installed piping... taking into consideration the variation necessary to accommodate thermal growth" and also specifies the general installation requirements for hangers, as further defined by the design drawings.

Engineering Change Authorization (ECA) 05/102323A, which authorized installation of an Instrumentation and Control (I&C) Support to pipe hanger M/S 251-SG-13 by UE&C, required addition of stiffener plates to M/S 251-SG-13 by Pullman Higgins Company.

Contrary to the above, as of June 3, 1985, the control of delegated quality related activities from engineering and design standpoints, as well as the responsibilities of the Construction Manager to manage and coor-dinate construction efforts for the pipe support design and installation activities were inadequate as evidenced by:

(1) The Pipe Support No. 157-SH-2B (2-way restraint) on the RHR piping System No. RH-157-1-601-8" was located without taking into.considera-tion the variation necessary to accommodate thermal growth.

As a result, this support was designed and installed with zero clearance between the piping and top member of the support.

(2) The Pipe Support No. 157-SG-17 (2-way restraint) on the RHR piping System No. RH-157-1-601-8" was located without taking into considera-tion the variation necessary to accommodate thermal growth.

As a result, this support was installed with zero clearance between the piping and the top member of the support, when a 1/16" clearance was required in the design drawing.

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Appendix A 3

l' (3) The I&C Support authorized by ECA 05/102323A was installed by UE&C, i.

accepted and turned over to testing without either adding the required stiffener plate by Pullman Higgins to the pipe hanger M/S 251-SG-13 or assuring that the required stiffener plates will be added by Pullman Higgins to the pipe hanger at some future date.

This is a Severity Level IV Violation (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, Public Service Company of New Hampshire is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending

-this response time.

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APPENDIX B Licensee Weaknesses The inspection team identified items of concern which have been characterized as weaknesses.

An item of weakness does not constitute noncompliance with regulatory requirements, rather it is related to effectiveness of a program, activity or organization.

References are to paragraphs in Inspection Report 50-443/85-15.

1.

Instrumentation Tubing Program (Paragraph 8)

A weakness was identified in the licensee's instrumentation tubing design, installation and Quality Control (QC) activities as evidenced by:

a.

Delay in issuing the required guidance for maximum slope require-ments; b.

The tubing installation exceeding the maximum slope requirements specified; c.

Lack of understanding of maximum slope criteria by QC and craft; and, d.

QC inspectors not inspecting for maximum slope requirements.

j 2.

Design Change Program (Paragraph 5)

A weakness was identified in the design change controls as evidenced by:

a.

Discrepancies. in NCRs and ECAs, such as, lack of evident technical justification for " accept-as-is" dispositions, lack of "affected" documents being identified, and inaccurate problem descriptions and disposition write-ups being approved, and b.

Lack of review to ensure that all design change control requirements of an existing site procedure (AP-15) were reviewed and applied to a new procedure (ASP-3) for design change controls.

3.

Welder Qualification Records (Paragraph 7)

A weakness was identified in the licensee's welder qualification records program as evidenced by the fact that the records did not adequately document necessary information such as material thicknesses and mode of metal transfer (GMAW only) used in qualification.

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APPENDIX C Licensee Strengths The inspection -team noted specific features of the licensee's programs /activ-ities which have been characterized as strengths.

A strength is a positive attribute or feature which exceeds regulatory requirements or an innovative feature which contributes to the safety or effectiveness of plant activities.

1.

Site Management The overall Seabrook Station Site Management is considered to be a licen-see strength.

The management recognized need for change and improvement in several areas and instituted several new programs and changes. At the time of this inspection, these new programs and changes were in place and recognized to be contributing positively to the overall quality, safety and efficiency of site activities.

Examples of such changes and programs are:

Consolidating all management on site Assigning overall site engineering responsibility to the Director, Engineering and Licensing Establishing Independent Review Team, PAPSCOTT Program and Change Document Tracking System Providing positive management support to safety and quality Providing positive support for site housekeeping and cleanliness programs The use of site probability safety analysis in determining the root causes of failures and developing the bases for Technical Specification Establishing measures to adopt good practices from other sites and to preclude occurrence of identified bad industry experiences at the site Establishing an employee allegation resolution program for the prompt resolution of site allegations.

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Appendix C 2

2.

The site QA function is effective and considered to be a licensee strength because of the following:

Effective implementation of an audit program Effective QA Trending Program Responsive and effective corrective actions Active interface with the Independent Review Team 3.

United Engineers and Constructor's Welding Engineering Efforts is con-sidered to be strength as evidenced by the following examples:

Continued use of portable electrode ovens has resulted in minimal instances of heat affected zone underbead cracking and consequent repair Institution of fillet gap rules for NF supports (JS-IX-6 paragraph 8.8.1)

Clear definition of preheat rules based on maximum thicknesses Zero undercut rules for D1.1 welding Special testing conducted for single and multiple pass 3/32" elec-trode welds on varying thicknesses for DI.1 welding QC identifying symbols on D1.1 weld joints Detailed tests on flare bevel joints The consistent use of prudent engineering measures and requirements that exceeded the applicable industry code requirements; and The measures to add conservatism in the areas where the code require-ments were judged to be less conservative.

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