ML20062E662

Responds to NRC Re Violations Noted in IE Insp Rept 50-354/82-05.Corrective Actions:Contractor Installation Drawing SM-131 Will Be Revised & Installed Hangers Reinspected

ML20062E662
Person / Time
Site:	Hope Creek
Issue date:	06/14/1982
From:	Martin T Public Service Enterprise Group
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062E659	List: IR 05000354/1982005 ML20062E662
References
NUDOCS 8208100220
Download: ML20062E662 (5)

Text

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. s Thomas J. Martin Public Service Electric and Gas Company 80 Park Plaza Newark, N.J. 07101 201/4304316 Vice President Engineering and Construction June 14, 1982 Mr. R. C. Haynes, Administrator U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Mr. Haynes:

NRC INSPECTION REPORT 50-354/82-05 NO. 1 UNIT HOPE CREEK GENERATING STATION Your letter, dated May 13, 1982, transmitted the above referenced Inspection Report which contained a Notice of Violation citing two violations by W-H Constructors, Bechtel's HVAC contractor at Hope Creek. The following response is provided in accordance with the Notice of violation:

I. As of April 28, 1982, no effective method was in use by W-H Constructors to indicate expansion anchor bolt torquing inspection status.

Corrective Steps Taken and Results Achieved Our statement to your inspector has been confirmed that the method used by W-H to indicate expansion bolt (EAB) inspection status is the EAB Inspection Report. Torque paint is used 3a a construction status indicator only and is applied following QC inspection. W-H will re-inspect EABe to verify the accuracy of previously com-pleted EAB Inspection Reports. Discrepancies found (if any) will be appropriately documented and corrections will be made to EAB Inspection Reports, as required.

Corrective Steps Taken to Preclude Recurrence W-H QC personnel have been provided with additional training in the proper methods for inspection and documentation of EAB installations.

l l To avoid further confusion, torque paint is being controlled and applied only by W-H QC personnel.

l 8208100220 820802 ~

l gDRADOCK 05000354 PDR

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Mr. R. C. Haynes 6/14/82 Date of Full Compliance W-H QC will complete re-inspection activities by June 25, 1982.

W-H held QC training sessions on May 28, 1982.

W-H QC assumed control of torque paint on May 28, 1982.

II. As of April 28, 1982, as-built installations of two HVAC ductwork supports differed from approved design drawing requirements.

Corrective Steps Taken and Results Achieved W-H has initiated Nonconformance Report No. 35F, stat-ing that Hanger No. 1 on W-H Drawing SM-131 was not in-stalled in accordance with the Bechtel Design Drawing C-9131-1. SDDR No. 35 submitted to Bechtel requesting approval of the deviation has been dispositioned

" Accept As-Is."

Investigation has found that Hanger No. 4 on W-H Draw-ing SM-131 is installed in accordance with the Bechtel Design Drawing P-9131-1. It was noted, however, that W-H Drawing SM-131 is in error relative to Bechtel Design Drawing P-9131-1. W-H has initiated Nonconform-ance Report No. 43F to document the discrepancy. W-H Installation Drawing SM-131 will be revised to reflect actual as-built conditions and to agree with the design drawing.

W-H will review a sample of their erection drawings to determine if similar discrepancies exist. W-H is also re-inspecting all hangers installed and accepted by QC to date to assure that other discrepancies between as-built conditions and design drawings do not exist.

Corrective Steps Taken to Preclude Recurrence The failure of W-H to install supports in accordance with approved design drawings was due to misinterpreta-tion of Bechtel Field Change Notices by W'-H personnel.

A meeting was held on April 2, 1982, between senior W-H

Mr. R. C. Haynes 6/14/82 site personnel and Bechtel QC and Field Engineering to clarify the use and applicability of Bechtel design documents. W-H has instructed their QC personnel in the proper interpretation of design drawings when performing inspections. Inspection personnel were instructed to preplan inspection activities to ensure that the correct Bechtel design drawings and applicable change notices are available and understood by the in-spector. Instruction to document and report uny in-stallation which does not conform to the Bechtel design drawing was also included in the training sessions.

Date of Full Compliance W-H will complete review of erection drawings by June 25, 1982.

W-H QC personnel will complete re-inspection, and documentation activities by June 25, 1982.

W-H completed their QC training sessions on June 4, 1982.

In addition to the above specific responses to the viola-tions, the following supplemental information is relevant:

l Prior to the date of the findings, we determined that prob-j lems existed with implementation of W-H Constructor's QA I Program. Deficiencies noted which are similar to those de-scribed in the Notice of Violation are being addressed on a generic basis with W-H by Bechtel.

On April 14, 19, and 26, 1982, the NRC Resident Inspector was apprised of the nature of the problems and the actions i initiated by Bechtel. NRC's Chief of Reactor Projects l Section 2A attended the_ meeting of the 26th. On the morning of April 30, 1982, the Resident Inspector advised PSE&G of l the two violations, which were formally presented at the L exit interview later that day. The inspector discounted our statement at the exit interview that these specific findings-merely reiterate those types of problems already identified specifically by us with W-H's implementation of their QA programs.

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Mr. R. C. Haynes 6/14/82 Our understanding of your enforcement policy is that licensees would be afforded sufficient opportunity -to cor-rect problems identified by us without being cited by your inspectors. Thus, these citations appear contrary to the NRC's intent to encourage licensee initiative for self-identification and correction of problems as stated in the Federal Register of March 9, 1982.

Very truly yours, CC: Office of Inspection and Enforcement Division of Reactor Construction - Inspection Washington, D. C.

NRC Resident Inspector - Hope Creek P. O. Box 241 Hancocks Bridge, NJ 08038 i

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. e STATE OF NEW JERSEY)

) SS: COUNTY OF ESSEX

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THOMAS J. MARTIN, being duly sworn according to law deposes and says:

I am a Vice President of Public Service Electric and Gas Company, and as such, I find that matters set forth in our letter dated June 14, 1982, concerning NRC Inspection Report 50-354/82-05 are true to the best of my knowledge, information, and belief.

M I/]

' THQMAS J. AltrIN Subscribed and sworn to before me on this 154 aay of h24*E.- , 1982 U

M Ylu Notary Public of New Jersey My Commission expires on '/R.k /8J/7[ I EN1/5