ML20044A648
| ML20044A648 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1990 |
| From: | NRC |
| To: | Erin Kennedy SENATE |
| Shared Package | |
| ML20044A644 | List: |
| References | |
| CCS, KENNEDY-900312, NUDOCS 9007020011 | |
| Download: ML20044A648 (4) | |
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QUESTION 2.
According to a December 21, 1983 " Final' Report" from l-Yankee Atomic Electric Company on the disposition of the 2399 welds' held to be suspect as a result of false NDE reports filed-by a Pullman-Higgins examiner named Padovano 193'" inaccessible J
items 1.ere evaluated and " accepted on-a case-by-case basis by UEAC engineering."
Please provide documents which show the completed record of.
NDE examinations and corrective actions, if any, for.each of these " inaccessible items."
Which of these 193 " inaccessible items can be classified as -
" safety significant"?
Before they became inaccessible, which of these itemsLhad.
been the subject of radiographs? Were-these earlier a
radiographs reviewed for possible defects prior to:
acceptance of these items on a case-by-case basis? Which of l
these inaccessible items were the. subject of radiograph's-L that had been. rejected during the initial level'II or level III reviews. (sic)
Please prov,1de copies ~of the records relating to:the-I case-by-case reviews and acceptance.of'these 193 inaccessible items, i
ANSWER To respond to the first and fourth items, NCR-4490 and'its associated records:
are the documents requested. These documents are included in the weld-package 9007020011 90052e PDR COMMS NRCC q'
CORRESPONDENCE PDC L1
i QUESTION 2.(Continued)
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for 1-RC-09-01 F0102 found in the Attachment.
The Nonconformance Review' Board Response Form (NRBRF) for NCR 4490 dated December 8, 1983, page 2, documents l
that 193 NDE items were evaluated on a' case-by-case basis and accepted by UE&C Engineering per SBU-78143, dated September 13, 1983, and SBU-79774,' dated October 20, 1983.
SBU-78143 and SBU-79774 are both in the weld package beginning, respectively, on pages 3 and 22 of the NRBRF.
L The NCR and associated records are included in the weld package because the weld package is the completed record of. final NDE and corrective actions associated with a specific weld. Additienal weld ' packages can be provided if requested.
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To respond to the second item, 52'of the 193 items concern safety-related-piping and support material; i.e., are governed by the NDE requirements lof ASME Boiler and Pressure Vessel Code,Section III, for Class 1, 2, or 3-components.
It should be noted that not all of these.52 NDE operations were '
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required by the Code for final acceptance. Because some of these items (suspect NDE operations) were perfomed on the same physical item (either component or weld), the 52 NDE. operations concern only 40 physical' items..The 40 physical items are specifically identified on pages 13 through 21 of the 51 page NRBRF.
With respect to the third' item, some background is necessary.
Inaccessibility can result from two different situations.
In some cases, the term means that the physical components could not be reasonably reached for additional
l QUESTION 2.(Continued) examination. The case-by-case review referenced above addresses these components. One significant example of this definition of inaccessibility is weld 1-CO-4081 F0103 listed on page 20 with justification for acceptance "as-is" discussed on page 5 of the NRBRF. The NRC inspection verified that this line was subject to the ASME code required hydrostatic test at a pressure greater than 125 percent of design pressure for the piping in addition to the justification provided on page 5.
Inaccessibility can also mean that the suspect NDE examination cannot be repeated for other reasons.
For example, a surface NDE examination of an in-progress. surface (e.g., a weld cavity).cannot be repeated after the welding is complete and the previous surface has been welded over. The acceptability of the suspect NDE which had become " inaccessible" in this: context can be accepted "as-is" based on final radiography as discussed in the case-by-case review referenced above. Where radiography was the basis of the. acceptability of the suspect NDE, this is referenced in the discussion of: the 40 physical items in the NRBRF as "RT".
Radiography used as the basis of the acceptance of the. surface NDE item most likely was perfomed before the physical-item became inaccessible by the first.
definition and after it became inaccessible by the.second definition. While a comparison of the respective dates was not performed, the use of the term "RT acceptable" in the case-by-case reviews implies the radiography had been accepted and was the basis for final disposition of the item.
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OUESTION2.(Continued) ~
Except for informational radiography that may have been performed in-progress, (the documentation for which was not required to be retained) all of the ASME Code required radiography was performed on the final component (i.e., after
- in-progress work has been completed) and therefore'after the suspect NDE -
examination becante inaccessible by the second definition. Any in-progress informational radiography would probably have been ' reviewed prior to continuing with the in-progress work; however, in all cases where radiography was performed and considered in' the the case-by-case acceptance review of the work, this acceptance would have been done based on acceptance of the final radiography.
The correlation between the 193 suspect NDE operations and radiographs. rejected by initial Level II or III review was not made because it would require review-of the weld packages for each item looking for rejected initial radiographs.
4 If any radiographs had been rejected by initial Lev'el 11 or III examiners, the radiography would have to have been repeated and accepted before.it could be used for disposition of any of these items. The code-required radiographs must evidence and record final acceptability of the weld to the appropriate ASME -
criteria. As documented in my letter to you dated March 15, 1990, all such radiographs have been reviewed.
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