ML20044A643
| ML20044A643 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/18/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Erin Kennedy SENATE |
| Shared Package | |
| ML20044A644 | List: |
| References | |
| CCS, NUDOCS 9007020008 | |
| Download: ML20044A643 (8) | |
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,g UNITED STATES g 4-f NUCLEAR REGULATORY COMMISSION t.
WASHINGTON, D. C. 20566 '
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E May 18, 1990
- CHAIRMAN k
4 The-Honorable EdwardLM.. Kennedy United Strtes' Senate Washingtoh, D.C.
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Dear Senator Kennedy:
I am responding: to yoursletter of March-12, 1990, which included several questions concerning the construction welding program at the Seabrook. station.
Enclosed are the staff's responses to those
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questions as well as staff comments on three points that you-raised in your letter.
You also questioned the staff's ability to draw conclusions on the seriousness of Mr. Wampler's specific. concerns.
I addressed.this question ~in my March 15, 1990. letter to you.
The Nuclear Regula-tory Commission was aware of concerns regarding the adequacy of' weld radiographs early in the construction process.andcconducted 3
numerous inspections of welding, nondestructive examination, and-the: licensee's quality assurance program.-
These. inspections established the= basis.for the.taff's recommendation that Seabrook i
could be operated safely.
As you are aware, the staff.is conducting 'a special inspection to reexamine-the adequacy of the construction welding-program in response to concerns and questions expressed by your staff and other Congressional staff members.
I will providefyou a copy of the inspection report as soon as it is completed, i
I trust this reply responds to your concern.
Sincerely, g*Y.
'Kenneth M. Carr
Enclosures:
As stated 1
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g 4 NRC Staff Comments on Three-Points Raised in1 Senator Kennedy's March 12, 1990 Letter COMMENT 1:
"Pleace be advised that a review of the Russell Memorarwn by my staff reveals that a number of statements nade in support of the above conclusion are not substantiated by the documents provided. and that some of these statements conflict with other credible sources of information. Among the questionable statements are the following:
Our assessment is that a 20% reject rate of rad' iographs during the first-review by a Level III examiner is not-unusual.
While finding no qualified source to corroborate this statement. -
I have found several expert sources who have stated that a 20%
reject rate is in fact uwsual and indicative of serious problems with the NDE program, the welds themselves, or both.':'
ANSWER The initial NRC statements concerning the reject rate were based on the following:
(1) The known historical weld reject rate based on radiography at the Seabrook Station, which is discussed :in our Systematic Assessment of Licensee Performance (SALP) for the period of January 1 through December 31, 1980, and the remedial actions that were being taken as discussed in the NRCa inspection Report 50-443/82-06, paragraph 6.3.8.
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, (2) The collective experience of our. own NDE Level III examiner and the engineering welding technical specialists that have inspected multiple ll 1
nuclear planc construction sites over the past ten to fifteen years, j
(3) The understanding that Mr. Wampler was part of the first level review of weld radiographs ' conducted by Pullman-Higgins (i.e., the first level 0
review by the ASME installation contractor).
There has been some confusion over the exact nature of Mr. Wampler's function as a Level III Peviewer within the Pullman-Higgins organization.
It now appears that Mr. Wampler was,~in fact, performing a so-called second level review on behalf of the piping contractor. As a result of our. ongoing reexamination of this issue by an NRC Independent Regulatory Review Team, we found that Pullman-Higgins stated that, as part of its corrective action to Yankee Atomic Electric Company Deficiency Report (YAEC DR) 211, dated 16 July 1982, "Two people shall review all paperwork and film to verify completeness. A i
Level II'and I.evel III." Although the NRC team has not completed its review, it now appears that Pullman-Higgi_ns instituted a second. level. review by_ its i
level III reviewer in July 1982, about 13 months before Mr. Wampler was hired.
Thus, subsequent infonnation has clarified Pullman-Higgins'- intent.
Subsequent to our initial response, a review of our Region I records by the NRC technical specialists referred to above indicated that in the 1982-1983 period the weld rejection rates based on radiography ranged from seven to nine percent at one plant-and 24 to 52. percent at three other plants. Our infonnation does not indicate the so-called level of review to which these l
rejection rates are applicable.
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3 The central point at issue was the staff's perspective on whether a 20% reject rate at the Seabrook site was, in and of itselt, of safety significance. Of l
4 course, it is true that a high weld reject $on rate could indicate a somewhat higher likelihood that defective welds crald pass undetected through various i
successive reviews. However, the.techtical staff continues to believe that weld rejection rate, standing alone, is of very limited relevance in assessing overall plant safety as impacted by piping welds.
While a low weld rejection rate may be desirable from the licensee's economic point of view, the essential safety ouestion is whether all final welds in the plant have i
acceptable weld quality and appropriate quality records. This requirement dictates that where necessary, defective Welds would have been repaired or supporting records would have been corrected as needed. The staff continues
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to believe that appropriate corrective actions were taken at Seebrook.
COMMENT 2:
"Further, after the alleger departed the site, the licensee performed a 100% check of the radiographs (Enclosure 8, pages 91 and 92) and required a re-radiographing and rework as appropriate for any weld, regardless of who had' previously reviewed it."
The documentary evidence cited in support of this statement does not in-fact substantiate it. The referenced document, IR 90-80, merely states "... as documented in CAT IR 84-07 and discussed' in IR 85-31, the licensee conducted an independent third party i
review of all RT film stored onsite..."
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. L However,-IR'84-07 appears to lack any-reference to "an independent third party review of all RT film stored onsite":and
!R 85-31 does.not say'that the nameless " third party" performed a 100% check of. radiographs;' rather, IR 85-31 states:.
t The. third party review involved a random' selection of.
1 welds inspected by liquid penetrant, magnetic. partible, and-radiography.
ANSWER 1
il The staff's coments concerning' this matter 9.e reflected in the response to'
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Question 1 (see Enclosure 2).
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COMMENT 3.
" Inspection Report 50-443/83-22 (Enclosure 11', pages 4 and 5)... documented acceptable completion-of the last two NCRs generated by the examiner [i.e. Wampler]; Further, the reporting j
inspector concluded that' the concerns of-the Level III examiner l
1 were being properly handled by his successors based on a mi sampling. inspection.
The referenced report does not document 'acceptablei completion of the two NCRs generated' by Mr. Wampler--it -
merely mentions them,.and no mention is made of the 16 NCRs Wampler told the resident inspector he was preparing'at the l
time of his firing. Moreover, Mr. Wampler's successor l
f 5-reported for work the day the above cited investigation ended, making it impossible for the reporting inspector to verify legitimately that this gentleman was. ' properly' j
t handling,Mr. Wampler's concerns."
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ANSWER You are correct that-Inspection. Report 50-443/83-22 does not document acceptable completion of NCRs 5689 and '.5773 as stated in >the Merch 15,1990 response. The inspection report describes the NCRs as "dispositioned," which l
meant that the plan to resolve the noncomformance had been reviewed'and accepted by the engineering and quality assurance organizations. The final j
resolution is documented in'the NCRs themselves. which were provided to your staff (C. Paine) on April 4, ;1990. -
As stated in the answer to Question 6 of your February 27, 1990 letter, "The
.3 inspector reviewed two-Nonconformance Repbrts-which had been generated by Mr.,
Wampler, and spot checked'his in-process records'... The.Nonconfonnance Reports =
reviewed by the inspector were properly processed 'and numbered 5689 and 5773..'.
3 recent records search by the licensee only revealed one other nonconfonnance report written by Mr. Wampler in his short tenn of employment of= approximately 7
four months." The inspection verified that the turnover process from the i
previous Level III examiner was being controlled. The original statement by Mr. Wampler was that there were approximately 16 NCR's to be written; an: exact number was'not piovided.
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, r A review of Mr. Wampler's 16 potential nonconformance reports was not performed t
during the 83-22 inspection,L since. by his own words, they did not yet' exist as NCRs. Nor was it NRC's intent to review in their entirety all of the docu-mentation associated with the departing NDE Level III technician.
It was the ntent.to review his concern which, as stated to our inspector, was how I
L in-process issdes would be handled at the time of his termina'. ion. This was a question of continuity between Mr. Wampler and his successor. Again, as stated in the response to Question 6 of your February 27, 1990 letter and Inspection Report 50-443/83-22, the inspector examined the coordination being effected to transfer functions, records, and any existing open items which needed to be tracked. The inspector verified that the turnover process was controlled to the extent that he had confidence the regulated aspects were assured of being l
completed.
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Although the paragraph describing the resident inspector's review of
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Mr. Wampler's concerns. is a brief paragraph in' Inspection Report 50-443/83-22, the inspection performed was sufficient to' convince the senior resident inspector that Mr. Wampler's in-process concerns-were being adequately addressed. The actual inspection represents several hot.rs of effort and the l
L brief paragraph describing the results of that effort is consistent with our practice where no concerns are noted.
It is the inspector's recollection that the documentation was appropriately controlled, management was cognizant of i
the process and the need for oversight, and there was a'high confidence that the process would properly track and disposition any deficiencies or incomplete l
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, radiographic records in the transition from one Level III examiner to the 1
n er.t..The-inspector did not have to interview the new Level III' examiner in order to' determine the acceptability of the transition controls since during the course of the inspection documented in IR 83-22, he interviewed the Pullman-Higgins first shift NDE supervisor and dealt directly with the Pullman-Higgins Field QA Manager.
The 0A Manager was not.only responsible for the accountability of-quality records and nonconformance report control, but also served as the senior site manager in charge of nondestructive examination of welding activities and thus was responsible for the work of,the subject NDE Level III examiners. Through interviews with the Field QA Manager andi.other Pullman-Higgins personnel involved in' radiography, the NRC inspector was able to determine that the quality records and ln-process work packages, the handling
-of which represented the concern of the former Level III examiner, were being adequately contro'lled during the transition process.
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