ML20083C854
| ML20083C854 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/15/1983 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8312270065 | |
| Download: ML20083C854 (5) | |
Text
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1671 Worcemer Road hominohom, Mossochviews 01701 (617). 372-8100 Pub 6c Service of New Hompshire December 15, 1983 SBN-598 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 November 16, 1983, " Combined Inspection Nos. 50-443/83-15 and 50-444/83-12", R. W. Starostecki to R. J. Harrison
Subject:
Response to Combined Inspection Nos. 50-443/83-15 and 50-444/83-12
Dear Sir:
In response to the violation which was included in the subject Inspection Report, we offer the following:
NRC Notice of Violation (443/83-15-01):
10CFR50, Appendix B, Criterion III requires that materials and processes essential to the safety-related functicns of components be reviewed for suitability of application, as a design contr.ol measure. The Seabrook Station FSAR, in Section 17.1.1.3, further specifies that the appropriate corrective action be taken for deficiencies in the design process that adversely af fect safety-related structures and components. As delineated in both the UE&C Nuclear Quality Assurance Manual and the QA Program Topical Report, design changes are subject to the same design controls, including interfacing and analysis, that applied to the original design.
Contrary to the above, as of October 13, 1983, the design control measures applied to revisions of the UE6C Pipe Support Standard Notes and Details (i.e., Engineering Change Authorizations 25/2573A and 73/3566B) failed 8312270065 831215
((k PDR ADOCK 05000443 G
'Q 1000 Elm St.. P.O. Box 330. Manchester, NH 03105 Telephone (603) 669-4000 TWX 7102207595 1
I
8 United States Nuclear Regulttory Commission December 15, 1983 Attention:
Mr. Richerd W. Starostecki, Director Page 2 to provide adequate review for the suitability of application of welding processes to the particular component configuration and failed to subject these pipe support design changes to the same interfacing and analysis controls that had been applied to similar structural configurations These . failures have caused the incomp ete application of corrective action to a l previously identified constructicn deficiency and have resulted in as-built pipe supports configured and welded to incomplete design criteria. This is a Severity Level-IV Violation (Supplement II).
Response
Corrective Action Taken and Results Achieved: Meetings with YAEC Engineering and UE&C Welding and Materials representatives were' conducted to discuss the identified violation. Drawings were reviewed and a sample of installed supports assessed. The design was reviewed for presently installed supports, and those scheduled for installation that utilize Knife Plate Connections. Although it was determined that specific connections are highly restrained, each configuration is such that the joint behavior most closely represents a standard clip angle. This is based on the fact that the filler plate is attached with a vertical and wraparound weld in lieu of an all around weld. Since the knife plates are, in general, 3/8" and 1/2" plate, the heat input due to welding, and resulting weld shrink, are considered minimal. r# o prevent recurrence of the identified condition, the following actions T 3 are being taken: 1.- Welds are being re-inspected to check for. indications of Lamelar tearing. 2. Wraparound weld lengths are being measured.- 3. NCRs are being reviewed for any deficiencies against Knife Plate Connections. 4. Instructions have been issued to UE&C site engineering personnel regarding the welding and NDE requirements for Knife Plate Connections. 5. A Technical Bulletin has been issued to UE&C home office engineering personnel regarding Knife Plate Connections. Corrective action vill be completed by December 23, 1983. Comments on Unresolved Item 50-443/83-15-05: The referenced Inspection Report (at Pages 9 and 10) discussed the licensee action on two 10CFR21 reports submitted to the NRC. These 10CFR21 reports were brought to our attention in a previous Inspection Report (dated ~ August 25, 1983), and via correspondence from Project contractors. The ensuing evaluation of one of the 10CFR21 reports for reportability under
United States Nuclear Regulatory Commission December 15, 1983 Attention: Mr. Richard W. Starostecki, Director Page 3 10CFR50.55(e) was not conducted in a manner consistent with previous reporting practices. The following summary of our program for evaluation of identified conditions for 10CFR50.55(e) reportability is provided to support our assertion that the non-acceptable situation described in the referenced Inspection Report was an isolated case and that evaluations and reporting are being conducted in a manner consistent with NRC guidance. Please note that at this time we feel our 10CFR21 reporting obligations are also being fulfilled by the program summarized-below. Program for Evaluation of Identified Conditions for 10CFR50.55(e) Reportability (Summary) Identified conditions are evaluated by YAEC and its contractors for reportability or potential reportability under 10CFR50.55(e). Identified conditions which are evaluated are typically detailed in one or more of the following document types: o Nonconformance Reports o Nonconformance Review Board Response Forms o YAEC Deficiency Reports Blue Sheet Information Requests o o Vendor 10CFR21 Reports o Westinghouse Letters o UE&C Letters o Vendor Letters o NRC Bulletins, Circulars or Information Notices o NRC Inspection Reports o YAEC Audit Reports o Other Audit Reports i Existing procedures and guidelines establish time limits for contractor reportability recommendations and YAEC evaluation and reporting of these, i l Existing procedures and guidelines also disseminate 10CFR50.55(e) and interpretations of 10CFR50.55(e) to support contractor reportability recommendations and YAEC evaluations that satisfy the intent of the regulation. The YAEC Project Manager and/or his staff provides a final review of other YAEC evaluations. This final review lends consistency to the reportability threshold, and the scope of information that IP reported to ~ Region I. YAEC has also begun an audit program to review identified conditions which its contractors have deemed non-reportable or potentially reportable. The YAEC Seabrook Project Department initiates and documents all telephone reports to Region I, and disseminates summaries of these, and assures that timely written reports are filed via its Correspondence Status l Report. l t
t United States Nuclear Regulatory Commission December 15, 1983 Attention: Mr. Richard W. Starostecki, Director Page 4 The YAEC Project Manager submits Interim Reports prior to the time that the corrective action har been specified, reviewed or fully completed. The YAEC Project Manager submits Final Reports when the corrective action completion has been verified by the YAEC Construction Quality Assurance Group. In summary, I feel the existing program is conducive to proper reportability evaluations, and timely reportius to Region I. Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY L M 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 l
William S. Jordan, III, Esquire Brentwood Board of Selectmen Harmon & Weiss RED Dalton Road 1725 I Street, N.W. Suite 506 Brentwcod, 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 03842 5 Morningside Drive Hampton, NH 03842 Anne Verge, Chairperson Board of Selectmen Roberta C. Pevear Town Hall Designated Representative of South Hampton, NH 03842 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 03870 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 - Frien Street U.S. Senate Amesbury, Ma. 01913 Washington, DC 20510 (Attn: Tom Burack) Senator Gordon J. Humphrey 1 Pillsbury Street Diana P. Randall Concord, NH 03301 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 J}}