ML20024H165

Forwards Rept of Weld Record Anomaly for Field Weld 1-CS-318-02-F0202

ML20024H165
Person / Time
Site:	Seabrook
Issue date:	05/17/1991
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NYN-91080, NUDOCS 9105290178
Download: ML20024H165 (6)

Text

New Hampshire Yankee NYN 910SO hiay 17,1991 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Document Control Desk

References:

(a)

Facility Operating License No. NPF-86, Docket No. 50 443.

(b)

Transcribed Public hiceting lietween New llampshire Yankee and the NRC conducted on April 10, 1991.

(c)

NiiY Letter NYN 91076 dated hi ay 13, 1991,

• Transmittal of the Program Description for the Reverification of Pullman liiggins Field Weld Records'. T. C. Feigenbaum to T. T. h1artin.

S ubject.

Report of Weld Record Anomaly For Field Weld 1 CS-318-02 F0202 Gentlemen:

In the April 10,1991 Public hiceting between New llampshire Yankee (NilY) and the provided in the NilY Program Description for the NRC [ Reference (b)], and as Reverification of Pullman liiggins Field Weld Records, transmitted to the NRC on hiay 13, 1991 [ Reference (c)], NilY agreed to provide the NRC with a written report of any weld record anomalies within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the determination that a r e po r t is required.

Accordingly, enclosed please find a " Report of Weld Record Anomal) for Field Weld 1-CS 318 02-F0202" This report relates to a records anomaly which NilY determined on hiay 14, 1991, was reportable pursuant to the program description.

As provided in the Enclosure, the identified anomaly is related to a single weld piece of record in that it pertains to a lack of administrative information on one radiographic film, NiiY has evaluated this records anomaly and has determined that it does not adversely affect or call into question the physical quality of weld 1 CS-318 02-F0202 or other Seabrook Station welds. Corrective actions to address this anomaly will be completed by M ay 17,1991. The Justification for Continued Operations contained in the Enclosure has been reviewed by the Station Operation Review Committee (SORC).

Should you have any questions regarding this matter, please contact M r. Neal A.

Pillsbury, Director of Quality Programs at (603) 474 9521, extension 3341.

Very truly yours, fyh dr Ted C. F genbaum l

TCF:J ES/ tad 1

Enclosure 9105290178 910517 1

PDR ADOCK 05000443 h[O{

P FDR g

New Hampshire Yankee Division of Public Service Company of New Hampshire f

1 P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474-9521 1

United States Nuclear Regulatory Commission May 17,1991 Attention:

Document Control Desk Page two ec:

Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 1-3 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ebe C. McCabe, Chief Reactor Projects Section U.S. Nuclear Regulatory Commission Region I d75 n:lendale Road King of Prussia, PA 19046 Mr. Th imas T. Martin, Regional Administrator Region 1 475 Allsudale Road King 01 Prussia, PA 19406 Mr. Kenneth E. Ilrockman Office of the Executive Director for Operations U.S. Nucacar Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Mr. Noel Dudley NRC Senior Resident inspector P.O. Ilox 1149 Seabrook, Nil 03874 Mr. Phil Joukoff United Shtes Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 P

Frank Forgione, s~ccial Agent Viice of the inspector General United States Nuclear Regulatory Commission MNilB 6715 -

Washington, DC 20555 l

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New llampshire Yankee May 17,1991 ENCLOSUllE 1 R EPOllT OF WELD it ECORDS ANOM ALY FOlt FIELD WELD 1 CS.318-02-F0202

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REPORT OF WEl.D RECORD ANOM AI.Y FOR FIEl.D WEl.D l-CS 3tN 02 F0:02 1.

Introduction In the April 10, 1991 Public Meeting between New llampshire Yankee (NHY) and the NRC, and as provided in the NilY Program Description for the Reverifi:ation of Pullman liiggins Field Weld Records, transmitted to the NRC on May 13, 1991, N!!Y agreed to provide the NRC with a written report of any weld record anomalies within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the determination that a report was required.

Accordingly, the following is a report of an identified records deficiency. NilY determined that this anomaly required NRC notification on May 14,1991, at 12:30 P.M.

The identified deficiency is solely related to weld records in that it pertains to a lack of information on one piece of radiographic film. NilY has evaluated this records deficiency and has determined that it does not adversely affect or call into question the physical quality of weld 1-CS-318 02-F0202 or other Seabrook Station welds at this time.

The following provides the code requirements, a description of the identified deficiency, cause of the deficiency, corrective actions which are to be implemented, and a justification ic r continued operation regarding the identified deficiency.

II.

Code Heauirements_

Section V of the ASME Boiler and Pressure Vessel Code, entitled

• Nondestructive Examination" provides the code requirements for information which is to be maintained on radiographic film. Specifically, paragraph T 236 entitled " System of Identification," states that

• [a] system shall be used to produce permanent identification on the radiograph traceable to the contract, component, weld or weld seam, or part numbers as appropriate, in addition, the Manufacturer's symbol or name and the date of the radiograph shall be plainly and permanently included on the radiograph. This identification system does not necessarily require that the information appear as radiographic images."

111.

Description of the Deficiency Fullman Higgins field weld 1-CS-318 02-F0202 is a circumferential butt wcld on a three inch diameter section of piping in the Chemical Volume and Control System (CVCS).

This section of the CVCS system is ASME 111, Class 2, and Safety Class 2.

This weld connects a valve (V 325) to the piping and is also adjacent to a reducer. This weld is located in the

-letdown leg of the CVCS system downstream of both the Regenerative (Tag number E-2) and l

Letdown (Tag number E-4) lieat Exchangers. This weld is physically located in the-Primary Auxiliary Building which is outside the Containment Building. (Reference N11Y P&lD l-CS D20722).

This field weld was radiographed in 1981 in accordance with the Non l

Destructive Examination (NDE) requirements contained in the 1977 Edition of ASME Section III up through and including the Winter 1977 Addenda (the code applicable to Seabrook Station).

The weld records package for weld 1-CS 318-02-F0202 contains a Radiograph inspection Report (RIR) and the radiographic film. The RIR indicates that the radiograph views for 1

all stations of this weld are of acceptable quality. The RIR also contains the approval signatures of the Level 11 Pullmamiliggins reviewer, Authorized Nuclear Inspector (ANI), and the Yankee Atomic Electric Company (YAEC) reviewer.

Additionally, another Level 11 Pullman fliggins reviewer subsequently reviewed this RIR. At the time this radiograph was reviewed, the ash 1E Code approval process included the Level 11 Pullman Higgins reviewer and the ANI.

YAEC provided a review in order to salic.fy Qualit) Assurance Program requirements. Level !!! Pullman-liiggins review was added to the review process at a later point and therefore is not a requirement for this field wek.

As required oy ASME V including paragraph T-236, N H '.

.intains the Radiograph inspection Report (RIR) and the radiographic film for t his 4 ?.

The RIR and the radiographic film for two of this weld's three stations (stations 0 aaa 1), contain the code required information and approvals. As identified in NHY Corrective Action Request (CAR)91-005, the radiographic film for station 2 lacks the identification of the exposure date, system /line/isomeiric number, weld number, and manufacturer's identification.

The only information contained on this film is the station number. Therefore, the film for station 2 does not meet the code requirements.

NHY Nuclear Quality Group personnel have verified that the radiographic film for station 2 is in fact that of weld F0202. Comparison of the film for station 2 with that of stations O and I, indicates unique weld profile is present on all the film for three stations.

Specifically, at the time this radiograph was taken there was a spool identification tag tack welded to the pipe near this locetion which is oriented in a position that provides a unique identifier common to all three stations. Addition lly, this weld is located near a reducer which also can be identified un the film for all three stations.

This radiographic film comparison was performed by a NHY Level 11 RT reviewer on May 9,1991.

NHY Nuclear Quality Group personnel have also verified that the film reviewed for weld F0202 is the only film available for this weld. Review of the weld process sheets indicates that only one repair was made to this weld before the weld was radiographed. This repair was on the root pass (first weld layer) of the weld.

A visual examination of this pass detected a flaw which required a repair. No oth)r repairs were made prior to or after radiographic examination. As a result of the.bove reviews, NHY has determined that the station 2 film is of Pullman-Higgins field weld 1-C5-318 02 F0202.

I V, Cause of Deficienev I

i NHY has reviewed the identified ree deficiency and has determined its cause to bc l

personnel error on the part of Pullruan liiggins NDE personnel. The Pullman-Higgins NDE l-personnel apparently neglected to place the required field weld identification tag on the radiographic film for this specific station when the film was developed. Identification of radiographic film as required by code was an explicit provision of the Pullman liiggins Radiographic Procedure 1X-RT-1-W77.

V.

Corrective Actions NHY has determined that the appropriate short term corrective actions for t his records deficiency are to: 1) permanently identify the code required information on the station 2 film for weld 1-CS-318 02-F0202; and 2) reference the CAR on the film package for this wcld. Actions 1 and 2 above are specifically allowed for by the Code (T-236), and once 2

' com leted they will ensure compliance with the code. NHY will complete these corrective actions by May 17, 1991.

If similar anomatics are found during the conduct of the balance of the Wild Records -

Reverification Proj ect, long term corrective actions will include the evaluation of such anomalies, as a group, for generic implications and possible additional corrective actions.

2 VI.

Justifiention for Continued Oncration The foilowing provides a Justification for Continued Operation (JCO) of Seabrook Station for the time period between the determinstion that the aforementioned weld records deficiency required NRC notification and the time that corrective actions for the deficiency are implemented. This JCO demonstrates that the identified weld records deficiency does not produce any reduction in the protection provided for the health and safety of the public.

As provided in Section III above, NilY has conclusively determined that radiographic film is available for all three stations of Pullman-liiggins field weld 1 CS-318 02-F0202.

As indicatsd on this weld's Radiograph inspection Report, the radiograph film at all three stations indicates that this weld is of acceptable quality.

Based on this, there are no outstand <ng ouestions regarding the quality of this field weld and thus no outstandinn questions reg arding the integrity of the Chemie;l Volume and Control System. Additionally, the CVCS system has been extensively tested during preoperational and startup testing.

Moreov", this system - has been cperating for the past year.

Throughout testing and cr m

m. no problems with this weld have been identified. Since the identified records does not compromi3e the integrity of Seabrook Station, there is no reduction in

(,'

tion provided for the health and safety of the public.

.co

..t W has Iso performed a safety evaluation -for this JCO and has determined that an t..vevie% safety question does not exist. Specifically, since the identified records deficiency dies nos.ompromise the integrity of the CVCS system, it does not increase the prob:b!!ity or co..,quences of accidents or malfunctions previously evaluated in the Final Safety Analysis Report (FSAR). The mere presence of a records deficiency does not introduce a new failure mechanism nor does it modify the plant in any manner so as to create the possibility of a new accident or malfunction occurring. This record deficiency does not provide any means for an increase in the dose from any previously analyzed accident us it does not make any changes to the plant or its design basis. The margin of safety as defined in the basis for any technical specification will not be reduced by this records anomaly since it does not compromise the integrity of the CVCS.

Based on the foregoing, the identified records deficiency does not present an unreviewed safety question and it does not compromise the integrity of Seabrook Station.

TI.us, this records anomaly does not reduce the protection provided for the health and safety of the public.

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