ML20012C804

Responds to Re Questions on Weld Radiographs at Plant.Nrc Conducted Insps of Welding,Nde & QA Program During Const & Determined That Plant Could Be Operated Safely

ML20012C804
Person / Time
Site:	Seabrook
Issue date:	03/15/1990
From:	Carr K NRC COMMISSION (OCM)
To:	Erin Kennedy SENATE
Shared Package
ML19324G836	List: ML20012C804
References
CON-#190-10117 OL, NUDOCS 9003230251
Download: ML20012C804 (31)

Text

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[#,...,.'g UNITED STATES f'

NUCLEAR REGULATORY COMMISSION g.

WASHINGTON, D, C. 20MS l..

4 March 15, 1990 CHAIRMAN.

The, Honorable Edward M. Kennedy United States Senate

. Washington, D.C.

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Dear Senator Kennedy:

I am responding to your letter of February 27, 1990, in which you enclosed 15 questions concerning weld radiographs at Seabrook. The staff's responses to t

those questions are enclosed. As you will note, the Nuclear Regulatory l

Commission (NRC) was aware of concerns regarding the adequacy of weld l

radiographs early in the construction process and' conducted numerous inspections of welding, nendestructive examination, and the licensee's quality assurance program. The results of this licensing inspection process supported the staff's recomendation that Seabrook could be operated safely.

I have also received your letter of March 12, 1990, in which you pose addi-tional questions regarding quality assurance at Seabrook. We will respond to those questions in the near future.

l Sincerely,

^%.

Kenneth M. Carr l

Enclosures:

As stated 1

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l RESPONSE TO SENATOR KENNEDY'$ QUESTIONS l

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QUESTION 1.

What was the reason for the removal by Pullman.Higgins of Mr. Joseph 0. Wampler from his position as $ite Level !!!

i radiogrsoh technician at the Seabrook sitet i

ANSWER.

Mr. Wampler believed he had been removed because of his concern over violations l

of requirements pertaining to radiation safety barriers. The Department of I, abor (DOL) informed NRC, by copy of their February 7,1984 letter to l

Mr. Wampler, that they had concluded his discharge was (ue to his inability to maintain a satisfactory working relationship with other management employees "

In the March 20, 1984 settlement Agreement between Mr. Wampler and Pullhian.

I Higgins, Mr. Wampler's personnel records were " amended to reflect that he l

resigned voluntarily for personal reasons on January 3, 1984."

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c-A OutsTION 2.

Did Pullman-Higgins replace Mr. Wampler with another person with p

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Level !!! qualifications? If so, on what date did such a person i

l assume Mr. Wampler's function?

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AN$WER.

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.t ll As stated in NRC Inspection Report 50 443/83 22. the replacement Level !!!

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reported to the site on January 20. 1984, e

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t QU($ TION 3, On what date did the NRC staff learn that Mr. Wampler had found e

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i significant deficiencies in the radiographs?

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ANSWER I

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The NRC first became aware of the issues between the Pullman-Higgins Company and Mr. Wampler on January 5,1984, through a telephone report to the NRC f

senior resident inspector from Mr. Wampler. At that time, the staff understood i

that he was concerned with his termination and violations of radiographic safety practices and that he was further concerned about the completion of approximately 16 reports, which he characterized as noncomformance reports, that he had to write when he was terminated. The staff did not believe then or now thilt Mr. Wampler was expressing a safety concern over an excessive rejection rate of weld radiographs, L

I Subsequently, on or about January 10, 1986, the resident inspector received excerpts from the Mt.rch 1984 transcript of the 00L hearing in connection with a question from a local radio station. The excerpts are pages 64, 65, 74-80, f

which include the discussion of the 20% weld radiograph rejection rate. The information was reviewed to determine whether further follow-up action was t

warranted. Considering the earlier history of greater than 20% (in some cases

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greater than 40%) rejection of Pullman-Higgins weld radiographs and the licensee's ongoing implementation of corrective actions to resolve the prior

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problems associated with Pullman-Higgins weld radiographs, the inspector appropriately determined no further action was warranted at that time on Mr. Wampler's specific concerns.

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t OutlT!M 3. (Continued)'

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On February 23, 1990, during an inspection'of the seabrook Station, our l

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resident. inspector..s provided a copy of the pot hearing testimony' by.the

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p licensee.

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00tlf!0N 4 Ey *Ast means did the NRC learn that Mr. Weapler was finding significant deficiencies in the radiographs?.

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ANSWER,

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i This question is addressed in the response to 0vestion 3 above, d

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Out$f10N L On what date and by what means did NRC Region i staff (incivding

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' resident inspectors at the Seabrook site) obtain the transcript of the March 19, 1984 Department of 1. abor proceeding (84.tk.A.13) o

[4 involving Mr. Wampler?

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~ ANSWER.

P The response to this' question is contained in the response to Question 3.

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j 'A$T!001 6.

What are the identification numbers of ceficiency reports k

l prepared by Mr. Wampler? What are the identification numbers of i

itcensee and/or Pullman Higgins deficiency reports, prepared by persons other than Mr. Wampler, which document Nr. Wampler's findings?

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!$WER.

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i response to a concern expressed by Mr. Wampler that he was preparing Non.

af;ma:ce Reports (NCR) at the time of his resignation and was uncertain how j

ry would be handled, the NRC perfomed an inspection.

The inspection is t

ume:.ted in Inspection Report 50 443/83-22, and the inspector verified that

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1 turnover process from Mr. Wampler, the previous Level 111, was being Ltrolled.

The inspector reviewed two Nonconformance Reports which had been t

ersted by Mr. Wampler, and spot checked his in process records. The original

'tement by Mr. Wampler was that there were approximately 16 NCR's to be tten; an exact number was not provided.

The Nonconformance Reports reviewed the inspector were properly processed and numbered 5689 and 5773.A recent

)rds search by the licensee only revealed one other nonconformance report tten by Mr. Wampler in his short term of employment of approximately four ihs.

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OUESTION 6. (Continued) 2-The NRC believed that Mr. Wampler used the term nonconformance reports in the generic sense in that his reports described deficiencies.

In fact, the i

documents that he was in the process of generating were most likely Repair Drders. The Pullman.Higgins Procedure, Defect Removal and Pepair by Welding, J$-!X-14, was the controlling procedure for the activities that Mr. Wampler was perfoming.

Paragraph 3.3 of the procedure states," Unacceptable conditions identified through application of a recuired NDE method shall be reported by the NDE Technician to the NDE Supervisor, or his designee, on a Repair Order..." The i

usual conditions that were identified by radiographic examination were capable of being repaired within the scope of the installation procedure and would not f

require a Nonconformance Report.

Without weld identification numbers, the staff is unable to identify deficiency reports or other documentation written by others for the approximately 16 non-l t

conformance reports that Mr. Wampler stated he was to prepare.

The staff has spoken to Mr. Wampler and was informed he has a personal log from his work at Seabrook. The staff will interview Mr. Wampler to obtain the weld identifica-tion numbers for the welds of concern and will provide the weld examination report or other documentation which shows the final disposition of these welds.

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,1 QLit$ TION 7.

Did the licensee report Mr. Wampler's findings to the NPC? On what date or dates were any such reports made? What are the

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ider.tification numbers of any such reports submitted to the NRC7 I

I ANSWER.

I The licensee did not report Mr. Warrpler's findings to the NRC, nor do the NRC j

regulations require such reporting.

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4 QUESTION 8.

Did NRC inspectors have contact with Mr. Wampler during the period of Mr. Wampler's employment at the Seabrook site? What was the nature of any such contact? What information did Mr. Wampler provide NRC inspectors in the course of any such contact?

ANSWER.

Documented NRC contacts with Mr. Wampler were by telephone and letter after his resignation. The telephone contact was documented on January 5 6. 1984 and February 3.1984 A letter acknowledging the earlier telephone contact was sent to Mr. Wampler on January 12. 1984 The senior resident inspector recalls talking to Mr. Wampler in the course of his duties as they included inspection or observation of nondestructive testing activities. Other contacts may have occurred prior to his resignation as a result of routine inspection activities, but these are not documented by name, i

l' QUESTION 9.

After NRC staff 'imed of Mr. Wampler's findings concerning the radiographs, what inspections or other reviews were conducted by the NRC to determine whether Mr. Wampler's findings were valid?

ANSWER.

i The answers to Questions 3 and 6 describe the NRC staff's earlier reviews in respect to issues raised by Mr. Wampler.

Following Congressional staff inquiry, the NRC conducted a further review which is described in the memo-rendum from NRC Region I dated February 28, 1990. The NRC has reviewed the welding and nondestructive examination programs throughout the period of construction.

For example, in May 1984, the NRC performed a headquarters-led ConstructionAssessmentTeam(CAT) inspection (50-443/84-07) of the Seabrook construction program, which included a review of Pullman-Higgins radiography.

The CAT inspection reviewed over 1900 Pullman-Higgins radiographic films and, with minor exception, found their welding and radiography programs acceptable.

Inspection Report 50-443/86-52 provides an overview of the NRC's inspection program of the Seabrook Station and lists examples of the numerous inspections of welding and the nondestructive testing program. The NRC also performed independent radiography of piping welds utilizing its Mobile Nondestructive Examination Laboratory and compared our radiographs to the licensee's file film to verify the adequacy of their program. Additionally, random weld radiographs were selected by the Construction Astessment Team, the Mobile Nondestructive Examination Team, and welding specialist inspectors for review for compliance

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OUESTION 9. (Continued) {

with the ASME Code requirements.

The NRC has independently reviewed in excess f

of 2500 radiographs. This number does not include the films reviewed by f

i individual specialist and resident inspectors during the performance of the i

routine inspection program.

i The licensee perfonned a 100% review of the safety related radiographs to f

ensure code corr.pliance. Under the ASME Code program, all required weld examinations and documentation must be completed prior to the code inspector i

(Authorized Nuclear Inspector) approving the completion of the piping syst s for code purposes. Any deficiencies must be resolved and each weld must be i

accounted for in the system. Any radiographs that were missing or anomalies in the documentation would be detected and corrective actions initiated.

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l amounts to three levels or more of radiographic film review: the Pullman-Higgins review, the licensee's review, and the Authorized Nuclear Inspector's l

review.

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Lastly, Mr. Wampler did not allege, in the information the NRC has previously received, that there was ever a weld quality problem er a deficiency in the t

final radiographs. He stated his opinion that the reject rate was excessive.

The NRC was aware of the weld reject rate and was following the issue. Nowhere in the Department of Labor hearing testimony taken on March 19-20, 1984, did he f

i state that he was coerced into doing anything wrong, or that he was aware of safety violations other than crossing radiation barriers established to protect personnel safety during radiography shoots.

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What NRC inspection reports contain discussion of Mr. Wampler's e

findings?

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ANSWER.

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Inspection Report 50 443/83 22, paragraph 2. discusses the resident inspector's

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review of Mr. Wampler's concern regarding the handling of in process documenta.

tion during the transition period between his resignation and the hiring of a j

new Level !!! examiner.

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t QUESTION 11._

Af ter learning of Mr. Wampler's findings (whether before or af ter l

his employment at Seabrook was terminated) did NRC staff seek

.to interview Mr. Wampler with regard to his finding " excessive reject rates" in the course of his review of weld x-rays?

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ANSWER.

i During the course of NRC staff conversations with Mr. Wampler in 1984, his chief concern was with violations of industrial radiography safety and the fact

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he may have been terminated contrary to law for reporting the issue. He was asked directly by the inspector if he had eouipment safety concerns to which he replied, "No."

If he had responded positively to our question concerning i

equipment safety, we would have pursued the issue further.

l As discussed in the response to Question 3, staff learned of the excessive 1

reject rate concern in 1966 and determined that no additional action was

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necessary based on licensee corrective actions. As noted in the response to l

l Question 6 the staff is planning to interview Mr. Wampler to obtain specific l

weld identification numbers.

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i OVESTION 12.

On er about March 19. 1984, did Mr. Wampler or his attorney make l.

a settlement proposal wherein Mr. Wampler would refrain from reporting and/or testifying on the findings of Mr..Wampler's review of x-rays in exchange for a money payment?

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ANSWER.

The transcript (pp. 205, g seq.) of the DOL hearing contains e discussion of negotiations of a settlement agreement between Mr. Wampler and Pullman-Higgins.

Mr. Wampler's attorney denied that there was any offer to fail to report any safety violations (pp. 206,216-18). Mr. Wampler further testified under oath (pp. 219-220) that he was not aware of any violations other than those con-cerning. crossing radiation safety barriers.

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i QUESTION 13.

On or about March 19. 1984, did Mr. Wampler reach a settlement with Pullman.Higgins and/or the licensee?

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-- khat were the terms of any such settlement?

-- Did the terms of any such settlement in any way inhibit or discourage Mr. Wampler from informing the hRC of the findings of his review of the radiographs?

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-- Did the terms of any such settlement provide incentive to l

Mr. Wampler to refrain from informing the NRC of the findings of his review of the radiographs?

i ANSWER.

k A copy of the settlement agreement, dated March 20, 1984, signed by Mr. Wampler; Mr. Woiccak, his counsel; Mr. Davis, for Pullman Higgins; and Mr. Broth, the counsel for Pullman-Higgins is enclosed.

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will not discuss the facts of the case unless ordered to do so by a court, tribunal or agency of competent jurisdiction. It does not prohibit the plaintiff I-from reporting or discussing his findings regarding radiographic records since l

t these findings were not the facts of the case in question.

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Oal'.ar.u e.1 Cartrell 13 the count of St.000.00 ;ayatie to t

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sse exce;t it created to de s: by ecurt, trthr.a1 cr O

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1. 4er.:y of ::=;etent juristic ton.

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Mr. Vat: ler vi.' 1 axecute e. Careral Felease cf all j

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l Mr. Vam:ler vil: c.tr.! raw his a;;ea to the Secretary j

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Se parties ull titue a lc:r.t ;ress reinse and vill i

i have no further es::r.ent to the press regarding this case.

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• Al' an tettyngwal has to de is van artwns the area wnt*.1 the technttians are ; states, ; was t:14 at tr.ts t:Pe to prove that ne instetswat tov 1d vtohta tai terrier. I stesuted tr.e P Alten Power Predvsts Saf ety Precature vnnth stated "no indivtint way cross a terrier with the sewrte espesec."

explate.es to t'e s, three incivtssals that the

.n y n.e a tech.tn.n vevid be a:eenng veutd to.n a toe..hn, swer, as two to tnree hewts, one at est stre the Seurts is ertseed.

)

This 16 a.ss a saf ety vicletten nr 1:*1 cf the New Paesshire Rottatten i

Isfaty Pregram. 7 hts enttre tsnversattre was me justifing my poststen j

as Asttattsn Saf ety Of ficer and the thr ee of them suppetting the violetten.

At the ens of this meenrg 1 was ts.c by I.tshare

• avis to re y,c..ntn an. tha t he, unar. : avis, had n. intenti.s., evolvate tar m aitng j

me es of this cate %svever vt vavid rtstvse a resignattsn on *weegay, i

.anwary 3, 1986, as he vet not going to be in en Triday,0stember 30,l')l).

! 4;st ttf ttres ther. that the thirt O tit technittans had a te,mplatr.t I

abov, t?ts eve,iest tha t t*.ey vantes t t, file with the NR0, Attachment 2.

i 4

• e t e m t 's t 20, ill)

There ws s no

!stes a ten cn this date. Potev6r there vet a letter getti tete-tst ;!, ;i!)

s t a t t e.g t *.a t t*.s t.:t 3werviser anc Ra s te n n Sate:) Mis:er tsvit vts'. ate the ret:nten barriers provides t'ey has it;m t;&ges, its. eter att survey -attr. This letter was aggressed to

.e,

.t we ve r ; sever r e ce tved it.

Januar/ ),

1986 C900 hrs.

In t?.s discussten with Mr. Davis ! vas alleved to speak first.

I 1:!d him ; felt everything towld be verke.i :vt and that the barrier violations were 6t.'.1 a sutjest that r.seded ewr.stentten and that I had no tr.tenticr.

,of res:g.nat.:n.

Pr. *svis statet tu t he had he ard rsn. ors atevt our tit.sstens an: t*at 'e rat so thost s tvt to tar.ttr.a tt re.

ves ter ;nste

!:r ; :reper cent.itt. Cass teg it esention tetween aar.agerert at

.etar.ittans. Attatasent 3.

Per attaca.ent 6, Du t t te / R e s t en s t M h t ie s tf the Jite

• avel ;;!, ! vas part cf ranagement and : 6.no the tecnnistal respns Otlity !:t the CE Depar te.e nt.

I f ee'. I was ter.tnated f:r bring.rg a saf ety violation to the attenti:r.

af -stage rent.

! en retvesting that ry job he rett stited with all back, yay and al'. vance s art that the ter-teatten report not De placed in my persenal rtterd aisc 9e. entien of this action be rede to any prior employer in any vty siase er f orm.

o~=n

[.'

p D. k' mp' r Attst? rents

1. fattatten barrier violations. *=ce-ber 28,1983

!. ' ?.tutner tted vto'.a tions e! P.a gist ion barrt er s

3. Lett:e t! 7ere.ination, Janwary 3, 1986

e. Ette tevel ::: Ostsee/Aesponsth1t'.tes, September 27, 1983

f. 7.3.d.

T K

• f 2 7d, (2)

C f

G.

i QUESTION 14 NRC Inspection Report 50-443/83 18 conducted in mid November 1983, found:

t

" records not yet turned over (primarily piping) vere technically f

acceptable to the extent complete, legible and retrievable although not completely assembl6d in some cases. Review of these records was not complete."

(a) - What do the authors mean in stating that records "were l

technicallyacceptabletotheextent(theywere) complete, legible and retrievable?"

(b) - Does this mean that the inspectors had knowledge that some records were " technically" unacceptable by virtue of being not complete, legible and/or retrievable?

(c) -- If so, how does the existence of " technically" unacceptable records affect conclusions concerning compliance with the record keeping requirements of j

Appendix B?

i

' ANSWER.

i (a) The quoted excerpt from NRC Inspection Report 50-443/83-18 is part of the conclusion drawn from a documentation review of selected records performed by the NRC inspector. The introductory section of the paragraph from which i

the subject quote was taken (i.e., Documentation Review) states the following:

F a

a OUESTION14.(Continued) "The adequacy of the system with respect to preparation, review, control, storage and retrievability was examined. Records are prepared and main.

tained temporarily by the organization responsible for performance of the work. Femanent records are maintained on microfilm by YAEC as part of the Infomation Management System (IMS).

i "The inspector discussed this program with a YAEC representative and examined a draf t of a procedure for the records management system.

Docu.

ments sutaitted to IMS as permanent plant records are reviewed by the Construction Field 0A Group for legibility, content and technical adequacy.

Submittal and review of records is an ongoing process as portions of the work are completed."

i Furthermore, the following statement appeared in the report innediately before the excerpt quoted in the question:

I

" Records which had been turned over to IMS were complete, legible, readily retrievable, technically acceptable and had been subject to repeated review."

The inspector who authored the foregoing quoted sections of the inspection report was distinguishing between records which had been turned over to the IMS and records which had not received their final review. The inspector used legibility, retrievability and " to the extent" completeness as his t

4 M 3710N 14. (Continued)

-3 inspection criteria for the records not yet turned over, because such records, by the fact they are in-process, may require additional docu-mentation of construction work, inspection results, or design change l

implementation to make the records complete. Also, as documented by the inspector, completed records were subject to repeated reviews as required j

by the program of controls for permanent plant records. Thus, the in-process records that were inspected would also be subjected to this review process once they were completed and submitted for turnover. As stated, the inspector's review of documentation for both the completed and the l

in process records identified no concerns with the process or the program.

(b)and(c) l No, this does not mean the inspector knew of unacceptable records.

During f

the construction phase, inspectors are versed in the aspects of 10 CFR 50, Appendix B. as this is the primary basis for prescribing the scope of the quality assurance program. Criterion XVII requires that quality assurance i

records in their final form be identifiable and retrievable. The NPC i

inspects equipment fabrication and installation, including records, at various stages of completion to ensure the process is functioning as required.

In this case, the inspector found in-process records to be technically acceptable with regard to three attributes (with which he found no problems) but pointed out his recognition that some assemblage of records in final form remained to be perfortned.

f.

j

,. o QUESTION 15.

A Construction Assessirent Team (CAT) Inspection (50 443/8407) conducted in May 1984 concluded the following with regard to i

non-destructive examination of welds:

"In the area of nondestructive examination, the NRC CAT inspectors reviewed samples of radiographic film in final storage in the vault. As the applicant's program does not provide for review of radiographs by the applicant's NDE organization prior to their storage in the vault samples of film were selected that had not been reviewed by the applicant's organizations, as well as film that had not been reviewed prior to vault storage. No deficiencies were identified with the radiographs that had received the applicant's review; however deficiencies were identified by the NRC CAT inspection with the radiographs which had not been reviewed by the applicant."

(a)

-- What was the nature of deficiencies identified in radiographs which had not been reviewed by the applicant:

(b) -- What corrective action was taken regarding such deficiencies?

l L

(c) -- What was the root cause of such deficiencies?

(d)

-- Where is the corrective action and root cause documented?

a-

+

i I

[

OtJi$710N15.(Continued),

(e)

- Are these radiographs part of the same set examined by Mr. Wampler?

l

,1 ANSWER.

L (a) As stated in the inspection report, the deficiencies were discussed in the I

subsequent sections of the report. The deficisncies were:

[

i 1.

During the review of the radiographic film for the condensate storage tank (1-C$.TK-48), it was found that the repair radiographs for one j

weld (4H1)weremissing(pageV-5, paragraph 3b.(2)).

l I.

During the review of Dravo radiographs. one weld (weld l

141 8L-1MS-4001-41908) was found to display linear indications which did not meet the specified acceptance criteria (page V-4. paragraph 1.b.(2)).

L 3.

During the review of radiographs, it was found that two welds identified as IF1130D to 1F1130B welds 1 and 2 were radiographed using improper techniques which resulted in improper coverage of the weld l

a rea.

In addition, six welds did not identify the proper repair sequence; therefore, it could not be determined whether the correct weld had been re-radiographed (page V-8, paragraph 7.t.(2)).

f:#

i i.

l' QUESTION 15.(Continued) 3-t i

4 During the review of the Wooley's radiographs, the film displayed evidence of poor processing such as the presence of water, chemical i

stainsandyellowing(pageV-6, paragraph 3.b.(2)).

t t

5.

During the review of General Electric radiographs, it was found that three reader sheets did not have the accept / reject disposition r

checked. One weld did not have complete radiographic coverage (page V.9, paragraph 9.b.)

(b) The licensee documented the above listed findings within their corrective l

action system.

In every case, the licensee issued a Yankee Atomic Electric f

Company Nonconformance Report or a Deficiency Report.

Depending on the i

contractor,, the nature of the deficiency, and the corrective action warranted, the contractor may also have issued their own nonconformance report. Each deficiency was subsequently dispositioned as indicated in 15(d)below.

(c) Every nonconformance report or deficiency report does not merit a root l

cause analysis. A root cause analysis should be performed on con: plex matters for which the cause is not readily obvious and has a significant

{

impact on the process or equipment.

In the case of the first finding, it was the simple matter that the radiographs for one weld could not be f

located. This does not imply the program for radiography suffered a major breakdown that warranted a detailed analysis. The solution in this case was to re-radiograph the weld to replace the missing documentation.

N,.

l

)

4, M

OUESTION15.(Continued) In the remainder of the findings. the licensee was in the process of improving the quality of radiographic film review as evidenced by the 100%

weld radiography overview, and the corrective actions were already in progress for this previously identified problem. As stated in the report, l

the inspector did not find problems with the film the licensee's overview I

program had processed.

(d) The corrective action for the five findings, as stated previously, were all documented on the licensee's nonconformance or deficiency reporting system. The following list provides the finding and the associated corrective action system document number:

FINDING CORRECTIVE ACTION l

• 1 CS-TK-4B YAEC NCR 82-268

• 141-8L-1MS-4001-41908 YAEC DR 654

• 4F1130B/4F11300 YAEC DR 653 UE&C NCR 74/2790

• Wooley RT Browning YAEC DR 662

• General Electric RT YAEC DR 661 Root cause analysis is discussed in paragraph 15 (c) above.

(e) It is unlikely any of the radiographs that were cited in this response were reviewed by Mr. Wampler considering the fact that they all deal with

7. '=..

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t o'

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o i

[

i QUESTION 15.

(Continued)

-S-l l

8 1,

contractors other than Pullman Higgins except for item number 2, which was t.i a Dravo radiograph but was associatsi with a pipe spool that came under l

the jurisdiction of Pullman-Higgins.

j.

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EENT iY: xER;X Telecocier 7:17: 2-27-90 : 4: 25 2022242417.WC J'1!B13 A

s sowAno u. atwwe0y bittb 6tateg 6 enate WASHINGTON. DC 20s to February 27,1990 e

l Kenneth M. Carr, Chainnan

$g U.S. Nuclear Regulatory Commission 1717 H Street NW, wf" Washington, D.C. 20553 w c.

$l

Dear Chaimsan Carr:

M M5 I am writing to inquire about the NRC's disposition of certain allegations, gg which have only recently been brought to my attention, regarding signifi: ant defects In radiographs of safety related welds at Seabrook Nuclear Station. If these E 'd allegations should prove to be substantiated by further NRC review, and if this

-["

review reveals that these deficiencies have not previously been remedied, then 1 2

understand there would be no technical basis for cenifying that the Seabrook plant

• 9, mesta NRC safety requirements.

l Mo In the fall of 1983, a Site LevelIII radiograph technician named Joseph D.

l e m R.

Wampler was employed by the Pullman Higgins Company at the Seabrook l

odj construction site. In March 1984, Wampler claimed that in the course of his review l_

g *g jg of approximately 800 900 radiographs of safety-related welds, he had rejected about l

8 20%, either because the X ray itself was improperly taken and could not be read, or gj J,y because a properly taken radiograph had shown a weld that did not meet the l

l.8 o applicable standards.'

de" 3j$

When Mr. Wampler was separated from his position in January 1984, he filed a Section 210 complaint with the Department of Labor. Wampler believed that l

his termination had resulted in pan from his seeking to enforce radiation safety L

regulations, and in part from his finding of a high incidence of problems in the weld L

radiographs.

A DOL investigator found that Mr. Wampler's termination had not been improper. Wampler appealed, and a hearing was convened befort an Administrntive L

Law Judge on March 19,1984. However, the hearing was apparently terminated, prior to completion, after one day of testimony. The terms of the settlement between Mr. Wampler and his former employer apparently have not been disclosed.

)

o L

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SENT SYt XEROX Telecocier ?O171 2-27-90 t 4: 26 :

2022242417-NRC WF'16B13A

s 4 l

l 1

1 QUESTIONS FROM SENATOR KENNEDY CONCERNING EXAMINATION OF SEABROOK WELD RADIOGRAPHS DY J. WAMPLElt.

LEVEL 111 TECHNICIAN, PULLMAN HIGGINS CO., 1983 1984

1. What was the reason for the removal by Pullman Higgins of Mr. Joseph D. Wampler from his i

position as Site LevelIII raciograph technician at the Seabrook she?

l

2. Did Pullman Higgins replace Mr. Wampler with another person with Level 111 qualifications?

If so, on what date did such a person assume Mr. Wampler's function?

3. On what date did NRC staffleam that Mr. Wampler had found " excessive reject rates,"

approximating 20% in his review of weld x rays?

4. By what means did the NRC ' earn that Mr. Wampler was finding significant deficiencies in the radiographs?

5. On what date and by what means did NRC Region I staff (including resident inspectors at the Seabrook site) obtain the transcript of the March 19,1984 Department of Labor proceeding (84-ERA 13) involving Mr. Wampler?

t

- On what date or dates did NRC staff review this transcript?

Where is any such review documented?

6. What are the identification numbers of deficiency reports prepared by Mr. Wampler?

What are the identification numbers oflicensee and/or Pullman Higgins deficiency reports, prepared by persons other than Mr. Wampler, which document Mr.Wampler's findings?

7. Did the licensee report Mr. Wampler's findings to the NRC?

- On what date or dates were any such reports made?

.. What are the identification numbers of any such reports submitted to the NRC?

8. Did NRC inspectors have contact with Mr. Wampler during the period of Mr. Wampler's employment at the Seabrook she?

What was the nature of any such contact?

- What information did Mr.Wampler provide NRC inspectors in the course of any such contact?

9. After NRC staffIcamed of Mr. Wampler's findings conceming the radiographs, what inspections or other reviews were conducted by the NRC to determine whether Mr. Wampler's finding: were valid?

10. What NRC inspeedon reports contain discussion of Mr Warnpler's fir. dings?

11. After leathing of Mr. Wampler's findings (whether before or after his employment at Seabrook was terminated) did NRC staff seex to interview Mr. Wampler with regard to his finding

" excessive reject rates" in the course of his review of weld x rays?

--w a

er y s vur

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SENT BY: XERCX Telecepter.7017: 2-27-50 :

t. : 28 20222424M W W'Mem

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12. On or about March 19,1984, did Mr. Wampler or his attomey make a settlement proposal i

wherein Mr. Wampler weald refrain from reporting and/or testifying on the findings of Mr.

Wampler s review of x rays in exchange for a money payment?

13. On or about March 19,1984 did Mr. Wampler reach a settlement with Pullman Higgins and/or the licensee?

What were the terms of any such settlement?

i

~ Did the terms of any such settlement in any wayinhibit or discourage Mr. Wampler from informing the NRC of the findings of his review of the radlographs?

- Did the terms of any such settlement provide incentive to Mr. Wampler to refrain from informing the NRC of the findings of his review of the radhgraphs?

e

14. NRC Inspection 50-443/8318 condu:ted in mid November 1983, found:

" Records not yet tumed over tprimanly piping) were technically acceptable to the extent complete, legible and retrievab!c although not completely assembled in some cases. Review of these records was not complete."

(a)

- What do the authors mean in stating that records "were technically acceptable to the extent (they were) complete, legible and tetrievable?"

i (b)

- Does this mean that the inspectors had knowledge that some records were

" technically" unacceptable by virtue of being not complete, legible and/or retrievable?

(c)

--If so, how does the existence of" technically" unacceptab:e records affect conclusions conceming compliance with the record keeping requirements of

'1 Appendix B7

15. A Construction Assessment Team (CAT) Inspection (50 443/84 07) conducted in May 1984 concluded the following with regard to non destructive examination of welds:

"In the area of nondestructive examination, the NRC CAT inspectors reviewed samples of radiographic film in final storage in the vault. As the app!! cant's program does not provide for review of radlographs by the applicant's NDE organization prior to their storage in the vault, samples of film were selected that had not been reviewed by the applicant's organizations, as well as film that had not been reviewed prior to vault storage. No deficiencies were identified with the radiographs that had received the applicant's reviewt however, deficiencies were idennfled by the NRC CATInspection with the radlagraphs which had not been reviewed by the applicant lemphasis added.)"

(a)

- Wha.t was the nature of deficiencies identified in radiographs which had not been reviewed by the applicant?

(b)

- What corrective action was taken regarding such deficiencies?

(c)

- What was the root cause of such deficiencies?

(d)

- Where is the corrective aedon and root cause documented?

(e)

-- Are these radiographs part of the same set examined by Mr. Wampler?

,r--

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SENT cy:

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j r, xiROX Telecenter 7017: ;.2?-H : 4: 27 2022 Hung wi.g a

o q.

2 t

Please find attached a series of queadons regarding the Wampler case. !

believe these quesdons need to be resolved in a manner that fully and convincingly disposes of any threat to pub!!c health and safety that could arise if the potential defects identified by Mr Wampler are substantiated by the NRC's own.

investigation.'

I therefore request that the Commission resolve these questions before I

affirming any decision it may have been planning to make in the near future regarding the authorization of a full power license for the Seabrook Nuclear Station.

Ilook forward to receiving the results of NRC's investigation of this matter.

9 Sincerely.

[

Y Edward M. Kennedy

...... a4'#

1 1

t

Attachment:

15 quesdons I

oc:

Sen. John Kerry L

Rep.Ed Markey Rep.Nicic Mavmules t

/