ML20087P849

Responds to NRC Re Violations Noted in IE Insp Repts 50-443/83-22 & 50-444/83-15.Corrective Actions:Fbm Will Revise Procedures Re Startup Test Dept (Std).Work Request Is Governing Document for Work Under Std

ML20087P849
Person / Time
Site:	Seabrook
Issue date:	03/21/1984
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20087P833	List: ML20087P849
References
SBN-641, NUDOCS 8404090428
Download: ML20087P849 (5)

Text

r PUEBLIC SERVICE SEABN SMM

..s. u., o s c.:

Company of New: :

..pshi. 6 1671 Worcester Road Framingham, Massachusetts 01701 (617) - 872 - 8100 March 21,1984 SSN-641 T.F. B4.2.7 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:

Mr. Richard W. Starostecki, Director Division of Project and Resident Programs

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated February 17, 1984, " Combined Inspection Nos. 50-443/83-22 and 50-444/83-15", R. W. Starostecki to R. J. Harrison

Subject:

Response to Combined Inspection Nos. 50-443/83-22 and 50-444/83-15

Dear Sir:

In response to the violation which you reported in the subject inspection

[ Reference (b)], we offer the following:

NRC Notice of Violation (443/83-22-03):

10CFR50, Appendix B, Criterion XV and the Seabrook Station FSAR, Section 17.1.1.15, require that the measures established to control nonconforming items include documentation, review, and disposition. The FSAR also presents pictorially in Figure 3.7(B)-31 a typical supported cable tray system used as a model for the seismic design of the tray supports.

UE6C Drawing M300229 details illustrate typical slidiug fit connections as the means of complying with the seismic design model. Specific exceptions to the typical details are authorized (e.g., ICA 23/0052A), but provide for maintenance of the sliding fit gap.

Both 10CFR50, Appendix B and the FSAR require that installation activities conform to applicable drawings.

Contrary to the above, as of January 12, 1984, rework activities, conducted to correct a previously identified generic nonconformance with the required sliding fit design details, failed to identify and apply the needed rework to specific exception conditions (e.g., ICA 23/0052A). This resulted in the failure to document, review,.and correct items nonconforming to the seismic design details of Drawing M300229.

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

8404090420 840403 PDR ADOCK 05000443 G

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r William S. Jordan, III, Esquire Brentwood Board of Selectmen Harmon & Weiss RED Dalton Road 1725 I Street, N.W. Suite 506 Brentwood, New Hampshire 03833 Washington, DC 20006 Roy P. Lessy, Jr., Esquire Office of the Executive Legal Director Edward F. Meany U.S. Nuclear Regulatory Commission Designated Representative of Washington, DC 20555 the Town of Rye 155 Washington Road Robert A. Backus, Esquire Rye, NH 03870 116 Lowell Street P.O. Box 516 Calvin A. Canney Mancehster, NH 03105 City Manager City Hall Philip Ahrens, Esquire 126 Daniel Street Assistant Attorney General Portsmouth, NH 03801 Department of the Attorney General Augusta, ME 04333 Dana Bisbee, Esquire Assistant Attorney General Mr. John B. Tanzer Office of the Attorney General Designated Representative of 208 State House Annex the Town of Hampton Concord, NH 03301

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5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Pevear Town Hall Designated Representative of South Hampton, NH 03642 the Town of Hampton Falls Drinkwater Road Patrick J. McKeon Hampton Falls, NH 03844 Selectmen's Office 10 Central Road Mrs. Sandra Gavutis Rye, NH'03670 Designated Representative of the Town of Kensington Carole F. Kagan, Esq.

RFD 1 Atomic Safety and Licensing Board Panel East Kingston, NH 03827 U.S. Nuclear Regulatory Commission Jo Ann Shotwell, Esquire Assistant Attorney General Mr. Angie Machiros Environmental Protection Bureau Chairman of the Board of Selectmen Department of the Attorney General Town of Newbury One Ashburton Place,-19th Floor Newbury, MA 01950 Boston, MA 02108 Town Manager's Office Senator Gordon J. Humphrey Town Hall - Friend Street U.S. Senate Amesbury, Ma.

01913 Washington, DC 20510 (Atta: -Tom Burack)

Senator Gordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 l-70 Collins Street (Attn: Herb Boynton)

SEabrook, NH 03874

. Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager-Newburyport, MA 01950 Town of Exeter 10 Front Street

-Exeter, NH.03833 l

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b.

United States Nuclear Regulatory Commission March 21, 1984

" Attention:. Mr. Richard W.Starostecki, Director Page 2 i

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Responce:

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, Corrective Action Taken'and Results Achieved:

The licensee offers an explanation to the several concerns stated in the

subject Inspection Report Concern 1 There may be an interface problem between the A/E and contractor.

Response to-Concern 1 The contractor continues to question and identify conflicting information. Further, there are 'many documented instances where the

. contractor 4 identified problems and proposed solutions which form the basis for

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' q many ECAs. The A/E-contractor interface is effective, the change program is controlled, and design changes are verified by the concurrence program.~

i Concern 2 :

I The rework instructions' failed to identify and apply the needed rework to

. specific excepticn conditions.

This concern arose fros'NRC' violation (443/83-02/-02) of April 1983,

?wherein the'NRC questioned the design of a typical floor to ceiling cable tray s'upport as illustrated.in the FSAR with a sliding' gap. UE&C then issued a

~ generic Engineering Change ' Authorization (ECA) 03/2001A t'o give generic

-retrofit instruction to the contractor to rework previously. installed supports

.of this type,:by removing the bolts from the upper boot to give a sliding gap.

Prior;to issuing the generic ECA,' which addressed' 33FN and 33FD fittings, ICA 23/0052A was issued in 10/81,. addressing a similar support (T-14) which substituted a.33DU fitting to resolve an interference.- This ICA included a

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. note to maintain a sliding fit.

The support as installed did not include a

- is11 ding fit.

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Response to Concern.2

'In order to prevent recurrence of this situation, the following actions have been-taken:

1.~. ;The. support addressed by ICA 23/0052A and other similar conditions y

has been' reviewed and. found acceptable without the sliding fit, thus ino hardware changes are : required.

iTo assure that the scope. of work is understood by the contractor, s2.

UE&C established.a program which was implemented in April 1983, to

. review in detail' the more complex generic or retrofit ECAs with the

contractor prior to issue.- This has further strengthened the-t

A/E-contractor; interface.-

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United States Nuclear. Regulatory Commission March 21,1984

' Attention:

Mr. Richard W. Starostecki, Director Page 3 NRC Notice of' Violation (443/83-22-04):

10CFR50, Appendix B,. Criterion:VI and Section 17.1.1.5 of the Seabrook Station FSAR require that' activities affecting quality be controlled by and accomplished in accordance with the appropriate instructions, procedures, or drawings. Seabrook Station Test Program Instruction, TPI-11, requires the issuance of Work Requests to initiate, authorize, and document any rework activities being-conducted on equipment under the control of the Startup Test Depa rtment. TPI-11 also provides for a. program of tracking the work performed t

under Work Request authorization to final work acceptance and closure of the affected incomplete items..

Contrary to the above,. as of December 27, 1983, rework activities were conducted on equipment ur. der the control of the Startup Test Department, in one case without issuance of a Work Request, and in another case without proper written authorization for all the work performed.

In neither case did the TPI-11 program tracking the work identify the existing incomplete-items on the equipment.

'This is a Severity Level IV' violation (Supplement II).

! Response:

L Corrective Action Taken and Results Achieved:

The violation was' caused by:a misunderstanding relative to the scope of work as described in a Startup Test Department (STD) Work Request, which had been initiated to determinate cables'from' Valve CBS-V-5.

In. order to prevent recurrence of this situation, the following actions 3,

j have taken place:

1.

FBM (electrical' contractor) will revise their procedures to make it clear 'that the STD Work 1 Request -is the governing document when work is performed on equipment under STD jurisdiction.

-2.

- An NCR has been. written, and the engineering ~ disposition will define

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lthe work to be performed on Valve CBS-V-5.

- 3..

STD has issued. a meno to the Construction Manager to clarify the program-for accomplishing work on equipment under STD jurisdiction.

. 4.

STD Procedure TPI-11 u(Work Requests) has -been revised to positively

-delineate Work Request. program requirements.

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United' States Nuclear Regulatory Commission March 21, 1984 Attention:

Mr. Richard W. Starostecki, Director Page 4 Corrective action will be completed by April 15, 1984.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY

,L/d e

John DeVincentis Project Manager

_ -cc: Atomic Safety 'and Licensing Board Service List

. Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

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