ML20044A647
| ML20044A647 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/12/1990 |
| From: | NRC |
| To: | Erin Kennedy SENATE |
| Shared Package | |
| ML20044A644 | List: |
| References | |
| CCS, KENNEDY-900312, NUDOCS 9007020010 | |
| Download: ML20044A647 (5) | |
Text
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Responses to Questions Raised by Senator Kennedy in His Letter. of March-12,'1990 QUESTION'l.
($1ven the inadequacy of-the Comission's. response to.my -
February 27requestwhenmeasuredagainstthestandardset.by-}
these requirements, I ask that you provide-me with certain additional -quality assurance information concerning. Seabrook-as.
1 soon as possible.
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If the "100% check" by= !'an todependent third part'y" of "all RT film stored onsite" actually occurred in the; cited timeframe (1984-85), why is this not mentioned in inspection. reports prior to February,1990?'
ANSWER E
lf The staff agrees *. hat the-100% radiography review by the licenseeeist not clearly documented w NRC inspection reports so that the reader is able to independently and unequivocally determine that'it was done..
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~ Inspection _ Report 50-443/84-07,Section V, discusses the " Welding'and i
Nondestructive Examination" inspection results'inigeneral. One paragraph from o
this section of the report is quoted below:
900702001o voosie PDR COMMS NRCC L
CORRESPONDENCE PDC L
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QUESTION 1. (Continued) I "During the inspection of NDE activities, the NRC Construction Appraisal.
Team (CAT) inspectors reviewed samples of radiographic film in final storage in the vault; The NRC CAT inspectors reviewed a sample of film which was reviewed by the applicant's NDE organization as well as film which had not been reviewed prior to. vault storage. No significant problems were identified involving film that _was reviewed by the' l
applicant's HDE organization. However, several irregularities were '
identified involving film that had not been reviewed by the applicant..."
(underline added for emphasis).
The-CAT inspectors specifically documented a differentiation between the radio-t graphic film which had been reviewed by.the applicant and that which had not, to highlight the fact that the radiographic review process' would have repre-sented a concern to the CAT had it'not-been for theiapplicant's review process.
If the film in which the irregularities were identified by the CAT inspectors-1 had been final accepted radiographs, enforcement actions:in this area would have.
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been justified. Instead,< the CAT recognized that the licensee's program reouired l
the noted YAEC review of all safety related vendor and site generated radio-graphs. Hence, this grea o' insp6ction was not listed as one where either f
potential enforcement actions or significant weaknesses were identified.
In other words, the fact that the YAEC NDE Review Group was conducting a review of all RT film stored onsite was a basis for the findings and conclusions in the CAT inspection.
In retrospect, this aspect of the CAT report could have been stated more clearly.
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OVESTION1.(Continued) i With respect to_the third party NDE review, the report of inspection 85-31, conducted October 21 through December 6, 1985 states:
"The inspector discussed the licensee's third party review of nondestructive examinations for different fabricators onsite and also the licensee program for review of radiographic film for vendor supplied I
uelds. The-third party review involved a random selection of welds j
inspected by liquid penetrant, magnetic particle and radiography. The licensee implemented this program until approximately \\pril 1984 when-it l
was discontinued because additional problems were not being found and very little activity requiring NDE remained to be completed.
"The inspector also reviewed the results of the licensee's overview of v
radiographic film for vendor supplied welds. To date, the licensee has-performed an overview of virtually'all vendor supplied radiographic film.
Where problems were found, such as geometric' unsharpness failing_ to meet the ASME Code, radiography was reperfonned onsite and repairs were made, if necessary.
"The inspector found all areas of review acceptable. No violations were identified."
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-l QUESTION 1.(Continued) I It should be noted that in the quoted section of the report the resident inspector discusses two distinct programs: (1) the licensee's third party review of nondestructive examinations for different fabricators on site and also (2) the licensee's program for review of radiographic film for vendor and-fabricator welds, the 100% review program. The. distinction ' etween the two b
=i programs was that although. both included th'e review of radiographic film, the j
first program also entailed the perfomance of "infonnation only" NDE (it was not required by cur regulations or the governing codes), under the direction of the licensee on a random selection of welds. This additional NDE, which also included liquid penetrant and magnetic particle examinations, was for "information only" for the licensee to determine the adequacy of their I
contractors' NDE operations.
As stated in the quote, the licensee implemented this program until l
approximately April 1984, when it was discontinued because additional problems' were not being found and very little activity requiring NDE remained to be completed. The 100% review of all safety related radiographs continued well past April 1984 until all radiographic packages.were turned over to the licensee and reviewed. Since the CAT inspection connenced in late April' 1984, it is probable the program of informational NDE was no longer being l
performedbythelicenseewhentheCATinspectionwasconductEd.However,the-u review of radiographic film was still in progress, as addressed by the CAT I
inspection report.
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- QUESTION 1.(Continued) {
Inspection Report 50-443/84-07 looked at'the licensee's 100% radiographic review program early in the implementation phase. Later, Inspection Report i
50-443/85-31 examined the process near the completion of construction. Taken together, the reports indicate that the NRC was aware of the licensee's efforts to assure code quality radiography'and-that.a review program was implemented by the licensee. The licensee, on the bas'is of its. findings recorded in i
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Deficiency Reports, deemed it prudent-to'do an independent 100% review.
The licensee implemented this decision on'May 14, 1984, in FQA Manual, Procedure No. 5, QEG NDE Review Group..which contained provisions to review all safety-related vendor and site generated radiographs.
Based on the previous inspections of the review program, the staff is confident that the licensee completed the radiographic reviews.
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