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SEA 8 ROOK STATION.S* 1*__,, Omos-1671 Worcesser Roadhominoham, mseachveetts 01701

(417) - 872 - 8100Put2c Serv 6ce of New Hampshire

August 10, 1983

SBN-543T.F. B4.2.7

United States Nuclear Regulatory CommissionRegion I631 Park AvenueKing of Prussia, PA 19406

Attention: Mr. Thomas T. Martin, DirectorDivision of Engineering and Technical Programs

Ref erence s : (a) Construction Permit CPPR-135 and CPPR-136, DocketNos. 50-443 and 50-444

(b) USNRC Letter, dated July 7, 1983, " Inspection No.50-443/83-07", T. T. Martin to R. J. Harrison

Subject: Response to Inspection No. 50-443/83-07

Dear Sir:

The results of the subject inspection which are documented in Reference(b) point to a lack of management control by NISCO, the installationcontractor. As a result of this inspection, increased licensee attention,meetings between NISCO management and YAEC QA, and increased Yankeesurveillance activities, NISCO initiated a Stop Work Order (#4031-001) onJune 8, 1983. While work activities were halted, NISCO conducted trainingsessions for supervisory, craft, and quality assurance personnel to reinforce,

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the proper application of their quality assurance program. The Stop WorkOrder was subsequently rescinded on June 10, 1983.

Additionally, NISCO replaced the Site Quality Assurance Manager with anindividual more suitably experienced in an effort to prevent recurrence of thetypes of problems previously identified.

Increased Yankee surveillance has determined that the retraining efforts

were beneficial and that NISCO personnel are now cognizant of, and complyingwith, Project requirements.

In response to the three violations reported in Reference (b), we offerthe following:

8309210288 830912PDR ADOCK 05000443G PDR

1000 Elm St., P.O. Box 330, Manchester, NH 03105 Telephone (603) 669-4000 TWX 7102207595

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* United State Nuclear Regulatory Commission August 10, 1983Attention: Mr. Thomas T. Martin Page 2

NRC Notice of Violation (443/83-07-03):

A. 10CFR50, Appendix B, Criterion XIII requires that measures beestablished to control the handling, storage and preservation ofequipment in accordance with work and inspection instructions. TheSeabrook FSAR, Paragraph 17.1.13, requires each organizationcontracting for construction activities to define appropriatehandling and storage instructions. The Westinghouse NSSS componentstorage criteria dated Ma'cch 1976 provides that reactor vesselinternals shall be stored indoors under ANSI N45.2.2 Level "B"conditions until the components are placed into operation. ANSIN45.2.2 Level "B" requires protection from the effects oftemperature extremes, humidity, and weather during handling andstcrage.

Contrary to the above, on May 23, 1983, the inspector observed waterrunoff to be dripping through the upper core support structure.Holddown bolts of control rod guide tube extensions which had beenremoved for split pin replacement were observed to be in contactwith rags soaked in water of unknown quality. Furthermore, stepswere in progress to disassemble the upper core support structureoutdoors without protection required by Level "B" conditions.

This is a Level IV Violation (Supplement II).

Response:

Corrective Action Taken and Results Achieved:

At the time this violation was identified, the reactor internals were instorage in a prefabricated building. In order to accomplish requiredrework , the roof was removed and replaced several times to permit crane

j access. Although the internals were covered with poly, rain entered the'

building and wetted some of the loose parts. A combination of rain andhigh temperatures created condensation during the period that roof wasbeing removed and reinstalled. Although NISCO employees took reasonableprecautions, some parts were inadvertently wetted.

The wetted rags were removed, the internals dried, and rewor'k activitieswere stopped until the required Level "B" storage level was accomplished.

NISCO Procedure ES-4031 has been revised (5/26/83) to incorporatecontrols which are required when parts of the storage structure must beremoved to facilitate equipment installation activities.

NISCO conducted training sessions which stressed the importance ofmaintaining required levels of equipment protection.

Corrective action was achieved on June 10, 1983.

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United States Nuclear Regulatory Commission August 10, 1983Attention: Mr. Thomas T. Martin Page 3

NRC Notice of Violation (443/83-07-01):

B. 10CFR50, Appendix B, Criterion V requires that activities affectingquality be accomplished in accordance with documented instructions.

The Seabroo'k FSAR, Paragraph 17.1.1.5, requires that acti~itiesaffecting quality of safety-related structures be defined ininstructions.

Paragraph 4.1.1.3 of NISCO Specification ES 147 provides thatProcess Control Sheets (PCSs) be utilized as instructions to controland document safety-related noncode work. Paragraph 5.4.1 of ES 147further provides that work shall be accomplished in accordance withthe PCS.

Contrary to the above, on May 23, 1983, the inspector observedthermal sleeve guide to thermal sleeve plug welding (a portion ofthe reactor vessel internals) in progress while the PCS requiredmachining, dowel pin insertion, and pin welding.

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

Response:

Corrective Action Taken and Results Achieved:

Although an Engineering Change Authorization (ECA) permitted a revisedinstallation method, the NISCO Process Cont rol Sheets (PCSs) had not beenrevised to reference the NISCO Revision Request and the ECA. The PCS wasimmediately corrected.

NISCO conducted retraining sessions for management and craf t covering theproper control and use of Process Control Sheets.

Corrective action was achieved on June 10, 1983.

NRC Notice of Violation (443/83-07-02):

C. 10CFR50, Appendix B, Criterion VI requires that meaaures beestablished to control the issuance of documents sucn asinstructions, procedures, and drawings. These documents shall bedistributed to and used at the location where the prescribedactivity is performed. The Seabrook FSAR, Paragraph 1.7.1.6,requires that the Document Control System provide assurance thatprocedures, specifications, drawings, and instructions includingchanges which prescribe activities affecting quality are distributedto the locations where quality related activities are performed.

The NISCO Specification ES 147, Part 5.0, requires that aSupplemental Process Control Sheet (PCS) be prepared, approved, andissued in the same manner as the original PCS where additional

operations are identified. The supplemental PCS is to be attachedto and referenced by the original PCS.

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* United States Nuclear Regulatory Commission August 10, 1983Attention: Mr. Thomas T. Martin Page 4;

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Contrary to the above, on May 24, 1983, the inspector noted that therevision to the PCS for use .in the work area affecting the thermal,

sleeve guide to thermal sleeve plug welding only provided for,

j' referencing other documents and was not accomplished by issuance ofa revised Process Control Sheet.4

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

! Response:

Corrective Action Taken and Results Achieved:

NISCO took immediate action to reissue the Process Control Sheet so thatit complied with the requirements of internal procedures.

To prevent recurrence, NISCO craft and management personnel wereretrained regarding the correct application of process sheets.

'Corrective action was achieved on June 10, 1983.

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Very truly yours,+

YANKEE ATOMIC ELECTRIC COMPANY

|John DeVincentisProject Manager *

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cc: Atomic Safety and Licensing Board Service List

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. William S. Jcrd;n, III, Esquira Ms. Oliva L. Toth*

Harbon & Weiss Designated Representative of1725 I Street, N.W. Suite 506 the Town of BrentwoodWashington, DC 20006 R.F.D. 1 Dalton' Road

Brentwood, NH 03833,

Roy P. Lessy, Jr., EsquireOffice of the Executive Legal Director Edward F. MeanyU.S. Nuclear Regulatory Commission Designated Representative ofWashington, DC 20555 the Town of Rye

155 Washington RoadRobert A. Backus, Esquire Rye, NH 03870116 Lowell StreetP.O. Box 516 Calvin A. CanneyMancehster, NH 03105 City Manager

City HallPhilip Ahrens, Esquire 126 Daniel StreetAssistant Attorney General Portsmouth, NH 03801

Department of the Attorney GeneralAugusta, ME 04333 Dana Bisbee, Esquire

Assistant Attorney GeneralMr. John B. Tanzer Office of the Attorney GeneralDesignated Representative of 208 State House Annexthe Town of Hampton Concord, NH 038425 Morningside DriveHampton, NH 03842 Anne Verge, Chairperson

Board of SelectmenRoberta C. Pevear Town HallDesignated Representative of South Hampton, NH 03842the Town of Hampton FallsDrinkwater Road Patrick J. McKeonHampton Falls , NH 03844 Selectmen's Office

10 Central RoadMrs. Sandra Gavutis Rye, NH 03870Designated Representative ofthe Town of Kensington David R. Lewis, EsquireRFD 1 Atomic Safety and Licensing BoardEast Kingston, NH 03827 U.S. Nuclear Regulatory Commission

Washington, D.C. 20555Jo Ann Shotwell, EsquireAssistant Attorney General Mr. Angie Machiros

Environmental Protection Bureau Chairman of the Board of SelectmenDepartment of the Attorney General Town of NewburyOne Ashburton Place, 19th Floor Newbury, MA 01950Boston, MA 02108

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Maynard B. PearsonSenator Gordon J. Humphrey 40 Monroe StreetU.S. Senate Amesbury, MA 01913Washington, DC 20510(Attn: Tom Burack) Senator Gordon J. Humphrey

1 Pillsbury Street

Diana P. Randall Concord, NH 0330170 Collins Street (Attn: Herb Boynton)SEabrook, NH 03874

Richard E. Sullivan, MayorDonald E. Chick City HallTown Manager Newburyport, MA 01950Town of Exeter10 Front Street

Exeter, NH 03833

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