ML20055D036
| ML20055D036 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/29/1990 |
| From: | Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| References | |
| CCS, NUDOCS 9007030127 | |
| Download: ML20055D036 (12) | |
See also: IR 05000443/1982006
Text
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- .o# Io, UNITED STATES
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!\ 3 f. < 'i NUCLEAR REGULATORY COMMISSION
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.j W ASmNG TON. D. C. 20555
% ' , ',', . June 29,1990
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The Honorable Morris K. Udall, Chairman
Committee on Interior and Insular Affairs
United States House of Representatives
Washington, DC 20515
Dear Mr. Chair. man:
Enclosed, at the request of Dr. Henry Myers of your staff, are responses
to his requests of June 7 and 8, 1990, concerning Seabrook welds.
Since ely, e
bnN ..
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Dennis K. Rathbun, Director
Congressional Affairs
Office of Governmental and
Public Affairs
Enclosures:
As Stated
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cc: The Honorable Don Young
FULL TEXT ASCll SCAN
90070soi27 90062+
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U noocx osoooo s
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ATTACHMENT 1
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u w0NSE TO DR. H. MYERS' RE0 VESTS OF JUNE 7 & 8, 1990
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Request 1 (June 7, 1990):
Please provide prior to COB, Friday, June 22 process sheets, Radiographic In-
spection Reports, and Weld Repair Orders pertaining to the following welds:
CBS 1206-01 F0105
CBS 1202-07 F0708 ;
CS 369-10 F1006 i
SI 204-02 F0202* :
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- NOTE: The original field weld number (F1006) identified in Dr. Myers' memor- l
andum was subsequently corrected to the field weld number shown. I
Response: l
The weld packages, including the process sheets, the Radiographic Inspection i
Reports for the final accepted welds, and referenced nonconformance reports and
supporting documentation have been provided separately.
1
The five welds identified above were the subject of NRC NDE Van inspection, as (
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documented in NRC Region I inspection report (IR) 50-443/82-06, a copy of which
has already been provided to Dr. Myers. With regard to weld CS-369-10 F1006, a
rejectable linear indication identified in the radiographs resulted in the
issuance of an NRC Notice of Violation. Attached to this response is an ex-
corpt of the licensee's letter responding to IR 50-443/82-06, as it relates to
that violation. Because the weld in question was removed, the related records -
provided to Dr. Myers were the isometric drawing illustrating the replacement
welds and the nonconformance report and supporting documents showing quality
control and final acceptability of the weld replacement.
Also, as documented in the attached discussion of licensee corrective action,
Pullman-Higgins initiated a " secondary review of radiographs" in response to
the violation. This has not previously been highlighted in the NRC response to
Congressional staff questions regarding the levels of review of radiographs by
Pullman-Higgins. ,
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'. Psu Remm L..% (seew eym) 9 naeraio4a/e2
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(enuet a awwy coma. .cte i, e..uyas we.t;.4
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, 1. WitC Notice of Y1olations (&&)/8246-1Q)
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10CTR50. Appendia B, Criterion IX, requires that nondestructive testing
( be controlled and accomplished la accordance with applicable codes and
specifications.
N11 san-Higgias procedure, IE-AT-1-W7 7. Revision 3
tavokaa
radiography.the ASME Section III Code NC 5320 for acceptance criterior for
ASME Sectica III Code, NC 3320, states that the f ollowing
types of discontiauties are unacceptable: Incoeplete fusion or lack of
penetration.
Contrary to the above, on June 29, 1982, field weld CS-369-10 F1006 vae
reesamined by radiography and found to contain tacomplete fusion.
This is a Severity level IV violation (fupplement II).
Response
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Corrective Aetica Takes and Raoults Achieved
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field well P1006 plus sin taches of pipe en either side of the weld was
reeeved, the veld re-stayed, enseined with ultrasonic's and then i
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' cross-sectioned in the area of interest. The following results were
notedt
1. Single wall a-rey revealed the original indication plus some
additional areas. This information was used to mark the veld prior
to secticalog.
2. The ultrasonie inspection results were not useful due to
(- interference from weld root geometry.
3.
The cross-sectioned weld revealed a slag imelustee approstaately
half way up to the veld. Its orientation la the veld would have
lined it up adjacent to the edge of the root beed as it was observed
ta the radiograph takaa.
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Although this occurrence to considered se teolated f acident, the
following actions are betag taken to preveat recurrence
1.
N11ase-Magias will re-review 108 of the previously accepted
radiographe of similar veld geometry.
1.
N11aaediggins will retrata file laterpretere as necessary to
sesure their capability to correctly review radiographs.
3.
N11aan-Magias will provide a secondary review of radiographs prior
to turning them over to the Owner.
It is expected that chose corrective actions will be completed by
Decembe r 31, 1982.
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Attachment 1 2
Request 2a & b (June 7, 1990):
a. Prior to issuance of DR 527 on December 7, 1983, what Deficiency Reports
or other documents describing weld package deficiencies (other than DR
211) did YAEC issue based on <ts review indicating such deficiencies as
failure to submit acceptable film, reader sheet data that was inaccurate j
and/or incomplete, and/or indications of inadequate radiographic tech- i
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niques?
b. Prior to issuance of DR 527 on December 7, 1983, what Deficiency Reports
or other documents describing deficiencies (other than DR 211) did YAEC l
issue based on its review indicating the existence of rejectable weld de-
facts that had not been identified as rejectable by Pullman-Higgins re- .
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viewers?
Response:
i As discussed in the response to Request 1 of Dr. Myers' memorandum of May 29, l
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1990, YAEC radiographic review group activities were governed by YAEC Field
Surveillance Procedure No. 3 during the time frame noted in the above requests.
A copy of this procedure, along with some examples of surveillance reports, ;
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was provided to Dr. Myers.
Review of surveillance reports issued arior to December 7, 1983 identified five
documents which appear responsive to tie above requests. Two of these are sur-
ve111ance reports 489 and 580, one is Pullman-Higgins nonconformance report
NCR-217 (referenced on one of the surveillance reports), and two are deficiency
reports DR-037 and DR-241. The only identified weld quality deficiency re-
l sponsive to request 2b above is associated with surveillance report 580. An
additional weld defect is discussed in NCR-217; this was identified by Pullman-
Higgins NDE personnel and relates to the YAEC review process only by referral
from surveillance report 489. All of the above documents were forwarded sepa-
rately.
l
It should be recognized that YAEC surveillances for radiography (RT) and film
in-process surveillance reports document identification of RT deficiencies be-
fore the complete QA review by Pullman-Higgins personnel. Such surveillance
reports, by their in-process nature, are not deficiencies identified by YAEC
after having been missed,by Pullman-Higgins.
DR-037, based on a surveillance conducted on December 31, 1979, called for cer-
tain welds to be re-radiographed. However, DR-037 documented no requirement
for YAEC surveillance follow-up of the corrective action (i.e., the re-RT). s
The
on the reason DR to for be the decision
"all film not to 100%"
is reviewed follow-up(the corrective
emphasis added). action was stated
In effect, the
responsible YAEC QA engineer was indicating that there was no need to check on
whether Pullman-Higgins had conducted re-radiography because that check would
be accomplished when he reviewed the final film for this weld. Such review, as
stated, was accomplished on a 100% basis.
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Attachment 1 3
Based upon Dr. Myers' interest in any documented evidence that a 1005 review of
radiographs by YAEC personnel had been accomplished, the above quote documented i
on DR-037 in January 1980 is noteworthy. It shows YAEC 100% film review prac- l
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tice very early in the process of radiographic film package turnover from I
Pullman-Higgins to YAEC. NRC awareness of the 100% YAEC review is described in
a NRC Region I Director, Division of Project and Resident Programs, January 4, i
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1984 memorandum to the NRC Region I Administrator (copy attached). These docu-
ments are evidence of licensee use and NRC consideration of the 100% RT review l
by YAEC.
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MEMORANDUM FOR:
T. E. Murley, Regional Administrator, Region !
FROM: ,
R. Resident
W. Starostecki.
Programs
Director, Division of Project and 1
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SUBJECT: !
NRC FOLLOW.up - SEABROOK NDE fat.51FICAT10N
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On May 4,1983 Region I was notified, by Public Service Company of -!N '
in accordarce with 10 CFR 50.55(e), of the questionable performance of ,
and weld surf ace nondestructive examinations (NDE) by one contractoi
Prior to any determination of falsification, the licensee's internal inv
tion revealed that NDE procedures had been violated. This information was i
sufficient to cause the contracter to terminate the subject technician and
place on hold all 2,399 nondestructive examinations performed by the ind
until re-examination and disposition could be performed. It is ncted that ,
although only 33fi of the suspect NDE work was performed on safety related
welds, the licensee decided to evaluate all 2,399 cases
Mr. David Merrill, and emphalited to him the need for a thorough and complete ,
already taken steps in this matter. Additional meetings were( ~
both P$NH and YAEC to discuss tne performance in general of the subject
contractor.
As part of our effort we have been reviewing a number of licensee-initiated
QI effort we were able to conclude that there was no ma
However,
them fully informed IE staffand empressed advised, their interest by telephone and my staff has kep
ty remo dated December 21, 1983 IE requested certain actions relattve to the
anticipated the IE concerns since we also had the same
However, it is disheartening to note that telephone dis
documentation several months after we have conducted meetings with the ifcons
and on-site inspections on the topic. In an environment where resources are
public
prepare more hearing. I question the motivation to divert inspect
paper' in light of the fact that the information is already
available
shortly. and documented. More recent inspection effort will be documented
.
Review, by resident and regional inspectors, independently, of the audit
program, in entstence at the time of the incident indicated that the program
was being conducted in accordance with NRC requirements and F5AR commitme
The contractor NDE staff organization 411y reports to the contractor Field Q
Manager. Contractor QA auditors, located on-site, and licensee (thru their
agent - Yankee Atomic Electric Company, YAEC) auditors conduct periodic audits
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Mese to T. E. Murley m 0 * NH
of the contractor NDE program. A key operation in providing assurance of gg
field activities is the YAEC survet11ance program. Soecifically YaEC N0t
personnel had been and still do conduct 100% review of contractor accepted
radiographs. Also, YAEC QA inspectors condwet both random and scheduled sur-
veillances of field NDE work. An example of this activity is appended to the
subject invntigation report, in that a YAEC survetilence report documents an
earlier identified violation of the conduct of a liquid penetrant enemination
by the of fending NDE technician. In this cas*, the work was nonsafety-related
and corrective action consisted of reconduct Of the examination and verifica-
tion that the technician was knowledgeable of the procedural requirements. ]g
should also be noted that the original NOE f alsification problem was teentified
by the contractor when another NDE technician identified a concern with the
of fending technician's acceptance of a weld. Followup of that concern through
the contractor's program led to the 10 CFR 50.5$(e) report.
The re examination of previously accepted work is not considered te be reaviced
for an ef fective aucit program. Yet in this case, which involved random and -
periodic falsification, it appears that a re-emamination prog
the corrective actions, the licensee has instituted a sample NDE re-examination
program. Although this action is beyond any regulatory requirement and beyonc
the norm of NDE activities observed in the nuclear construction industry the
licensee did institute this effort and we strongly encouraged the initiative
at senior management levels.
Subsequent to the identification of the NDE fe*esification, the ileensee committed
to the following actions relative to oversight of NDE activities. These commitments
are docueented in Inspection Report 50 443, 444/83-06, and were discussed
during a June 7,1983 meeting,
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-- A sample re-inspection of other contractor NDE technician work with '
results confirming that the problem was restricted to the one individual.
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-- Increased contractor supervisory field checks and independent auditing. '
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-- Increased licensee surveillance of NDE activities on all
shifts. l
-- Establishment of a licensee program for "information only" NDE to be :
performed by an independent contractor to verify that ongoing NDE work has
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been and is being satisfactorily performed and correctly evaluated.
While the current NDE audit program may he more prescriptive and better
directed to the ide'ntification of NDE prt,blems, we do consider the former
NDE audit program to have been consistent with existing QA guidance and to
have been effectively implemented by the licensee,
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Memo to T. E. Mur),y 3
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The evaivation of an suspect areas was completed by the liceniet on necee3er i
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15, 1983. The re examinatton process identified 94 welds with rejectable
tedicationi. NRC Region I technicians conducted an inspection of the 14:enge,i g
re*enamination program in Ncvember.1983, independently examinirg a sample of
accepted welds anc evaluating the disposition of others. No adverse ficciegs
resulted from that inspection. Af ter review of the Final 50.55(e) stepert,
. dated Ce:ene' 21, 1983, a further inspection is planned to evaluate, in
detail, the status and disposition of each of the questioned melds. kcaever, it
appears f *om the inferration available that the licensee is adecuately accressing i
all hard.are concerns and with the firai repair or replace'nent of the rejectec
9a welds, nc hardware proolems will remain.
le addition to the concerns for hardware and program adequacy, as discussed )
above, a further Region I concern regarding management knowledge and involve- !
ment in this issue, particularly the f alsification aspects, was addressed by an i
NRC irvestigation conducted by 01. The final report, which has been issued to ,
the Region and also transmitted to the Department of Justice for their review, !
confiers falsification by one technician, but finds no managerial wrongdoing. 1
or conspiratorial cover-up activities. The falsification by the technician went I
beyond his conduct of certain nondestructive evaluations and involved apparently ,
forged and false certification of past NOE empleyment and false statements of I
educational level. l
While it e.ay be argued that a more thorough background check would have uncovered
that certain of the individual's prior certification claims were false, we find
no technical or regulatory reoutrement for such a rigorous background check. In
this case the personnel qualification and certification practices of the
American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1A
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were followed in that the subject technician had " proof of prior certification"
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(albeit falsified) and was given General, Specific and Practical Examinations
at Seabrook to demonstrate his ability to perform the NDE work he nould be
assigned in f act, the contractor went beyond these recommended practices by
I contacting tie individual's last employer (US Testing working for Florida Power
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and light c: the $t. Lucie project) to verify his employment and certification, '
) which were substantiated. It is interesting to note that had US Testing or Fp6L
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conducted a similar verification with the previous employer, they would have
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determined t, hat the technician was terminated for cause at Pittsburgh Testing
Labs for falsifying radiographs.
i The above discussion illustrates the lack of specific regulatory guidance in
l the area of personnel certification. Currently at $eabrook, the subject contractor
l has a program for verifying an NOE employee's entire resume with regard to
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claims of prior certification. This program has been backfitted to all
! technicians. This is being acceeplished because the subject problem occurred
I at Seabrook, and not because of any regulatory requirement,
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Meno to 1. E. Murley
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21, 1983 letter from
Of the listing provided in the enclosure to the) fications. However, it December t to this
Mr. DeYoung, Circular No. 80 22 is the most relevant licy. The
IE informat en
appro-
problem on tot subject of Confirmation of Emoloyee Qua 1
is silent as to what constitutes an acceptable
priate (ie: t confirmation. employme
procedures reflected a reasonable attempt at past employmen 1
Based upon NRC inspections and investigation efforts and up known hardware or
t of no
NDE work, Based
tive action programs, we conclude there is currently further in-
programmatic problem at Seabrook with regard to the conduc 7
on the licensee's sin supplemental and Final 50.55(e) Report, ,
4
spection will be conducted to evaluate and close this issue. l
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In ey view, current information ind.icates a situation whichlicensee does not wa
te have
enforcenent action. The problem was licensee identified and appears
been adequately corrected, both programmatic iand hardwara iss
lated by the
initiated actions. No technical or regulatory requirement
A not positive result of the entire incident was to was vo
i rid the nu l
licenses.
construction ef fort at leabrook of an individual of dquestionable to 3
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While enforcement action is not recommended, we de IE
recognize the
highlight the lack of NRC guidancee other onnuclearthe sub '
technician may currently be working as an NDE technician at som
site. if
A copy of this letter is being provided te IE Headquarters tion,
no
our position with regard to the counterproductive impact d
of e
but also to provide a background and basis for the generic
for further guidance in the area of certification and backg ,
professional employees.
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Richar . Starostocki, Director
Division of Project and Resident ,
Programs
cc:
J. Ameirad, Director. Enforcement Staff
W. Naas, !g!!
J. Taylor,
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Attachment 1 4
Request 2e (June 7, 1990):
c. Following issuarce of DR 211 on July 16, 1982, what actions were taken by
YAEC and/or Pullman-Higgins to identify the generic implications of tne DR
211 deficiencies vis-a-vis previously approved weld packages? What find-
ings and/or reports resulted from any such actions?
Response:
Besides the specific corrective measures involving Radiographic Inspection Re-
port corrections and re-radiography of welds, as required, the following generic
corrective action proposed by Pullman-Higgins is documented on page 3 of DR
211:
-- "Two people shall review all paperwork and film to verify completeness. A
Level II and Level III."
-- "A more conservative approach shall be taken on reviewing film and asso-
cisted paperwork."
The time frame for Pullman-Higgins initiation of such corrective action was
consistent with the licensee response to the RT violation identified in NRC IR
50-443/82-06 (see the response to Request 1). That NRC inspection was completed
on July 2, 1982; DR-211 was issued c.. July 16, 1982. We consider the separate
NRC inspection and YAEC surveillance findings to be probable factors in the
Pullo n-Higgins commitment to provide a second level of RT film review.
With regard to reports resulting from the findings of DR-211. YAEC surveillance
report 3383 documents a follow-up corrective action surveillance by the same
YAEC OA engineer who identified the original deficiencies. Microfilm copies
(the best record copies available) of DR-211 and surveillance report 3383 were
forwarded separately.
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Attachment 1 5 l
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Request 2d & e (June 7. 1990):
d. Did the YAEC 1005 review, conducted subsequent to issuance of DR 211, en-
compass all weld packages transmitted by Pullman-Higgins to YAEC prior to j
issuance of DR 211? What documents describe the procedures used in any '
such review and the results obtained therefrom?
e. Did the YAEC 1005 review, conducted subsequent to issuance of DR 527, en-
compass all weld packages transmitted by Pullman-Higgins to YAEC prior to j
issuance of DR 5277 What documents describe the procedures used in any '
such review and the result: ootained therefrom?
Response:
As discussed in the response to Request 1 of Dr. Myers' memorandum of May 29,
1990, before implementation of YAEC "QEG NDE Review Group" Procedure No. 5 in
May 1984, YAEC radiographic reviews were governed by YAEC Field Surveillance
Procedure No. 3. A copy of Procedure No. 3 with some example surveillance re-
ports (along with Procedure No. 4 and an explanation of the use of the Master
Checklists during surveillances) was provided to Dr. Myers with the response.
DR-211 was issued in July 1982 and DR 527 was issued in December 1983. There--
fore, the basic procedures and documents used in the reytew of radiographic
film packages transmitted to YAEC prior to the issuance of these DRs were the
surveillance procedure and documents noted above and sent to Dr. Myers in re-
sponse to his requests of May 29, 1990.
With regard to the 1005 review, YAEC reviewers were examining film packages as l
they were turned.over from Pullman-Higgins for record vault storage. Such a
review was not a " weld 1ackage" (i.e., process sheets and all relevant QA weld
records) check, but ratier an RT film and Radiographic Inspection Report (RIR)
review. As has been documented in previous responses to Dr. Myers, this radio-
graphic review was accomplished as a 1005 review as the radiographs were signed
off by Pullman-Higgins and turned over to YAEC. If YAEC did not accept certain
weld radiographs, the YAEC reviewers would not sign the RIR for the rejected
radiographic stations. That would require Pullman-Higgins corrective action ,
(e.g., weld repair, weld re-RT, documentation corrections, etc.) and resub- l
mittal of the new radiographs er corrected documents for re review by YAEC. l
If YAEC had accepted a film package when turned over and had signed off sig-
nifying such acceptance on the RIR, there was no need for YAEC to re-review l
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those film packages based upon subsequent DRs. The exception to this was the
handling of Deviation Notice DN-090 regarding geometric unsharpness (Ug) prob- l
1 ems identified subsequent to YAEC review and acceptance of certain radiographs.
As discussed in the response to Request 4 of Dr. Myers' memorandum of May 29, i
1990, DN-090 will be addressed in the report of the NRC Independent Regulatory l
Review Team established to review pipe welding issues at Seabrook. l
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Attachment 1 6
With respect to the specific questions above, no YAEC re-review of all film
transmitted to YAEC orior to the issuance of the DR-211 and DR-527 was required
subsequent to the issuance of these DRs. The only records requiring re-review
as a result of these DRs would be film which was reshot or film records cor-
rected as a result of the specific deficiencies identified by YAEC in the DRs
themselves.
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Attachment 1 7
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Request 5 (entire request of June 8, 1990):
(paraphrased) Please provide:
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-- Management Action Requests 001, 004, 011. 012 and 018
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-- Immediate Action Requeets 001 and 004 %
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-- Stop Work Notification 3,12/03/81, Pullman-Higgins
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-- Thirteen (13) nonconformance reports (numbers listed) which appear to per- l
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tain to weld rod material issues
Response:
All of the documents requested above have been forwarded separately.
- As documented in NRC Systematic Assessment of Licensee Performance (SALP) Re-
port 50-443/85-99 issued on May 28, 1985: "the utilization of 'Immediate Action
Requests' and ' Management Action Requests' by the QA staff has elevated certain
- trablems which appear to have generic implications to a level of management
--
wnere corrective action will receive higier attention." This SALP report l
covered the July 1, 1983 to December 31, 1984 which appears to be of particular
interest to Congressional staff based upon the focus of several previous ques-
_
= tions and requests. Ih ths NRC assessment of piping systems and supports, the
following statements are documented in this SALP report: i
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"It is noted, however, that with regard to completed and finally inspected
- hardware, very few problems were identified. In fact, in the welding and
NDE areas, independent examinations by NRC inspectors rev:aled generally
high quality work and effective licensee overview of the final radiographic
- film packages." .
.A copy of SALP Repcrt 50-443/85-99 has been forwarded separately.
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ATTACHMENT 2
S,UPPLEMENTAL INFORMATION TO DR. H. MYER$8 REQUESTS OF
MAY 22. MAY 30 & JUNE 6. 1990
1. Request II of Dr. Myers' memorandum of May 22, 1990 asked that an allega-
tion that deficiencies exist with regard to the radiographic record of
cooling tower piping welds be addressed. The NRC response to this request
stated that the allegation was not substantiated, but that NRC inspection
of related weld records was continuing.
NRC inspection of the applicable weld records is now complete. -Specific '
records documenting the acceptable com>1etion of two base metal repairs
(BMRs) on one of the 'T' pipe pieces tiat represented the subject of the
allegation were not found. A liquid penetrant examination (PT) record i
provided evidence of acro') table inspection of certain base metal weld end i
preparations. While it appears that the questioned BMR activities were
conducted on these weld end preparations vor the replacement welds, there
was no documented evidence in the quality records package to correlate the
identified PT report directly to the B m s in question.
In order to complete the quality records for the welds affected by the
missing BR documents, the licensee conducted magnetic particle testing
(MT) on two iiold welds in the cooling tower on June 17, 1990. These
examinations were witnessed by NRC inspectors. No weld defacts or un-
acceptable weld indications were identified.
An NRC inspector reviewed the records provided as a result of the conduct
of this MT examination ~and determined that weld quality was confirmed and
that complete record adequacy was now provided. The conclusion reached
with respect to the allegation was not changed by the identification of
incomplete records or by the subsequent licensee MT and its results.
2. Request 1 of Dr. Myers' memorandum of May 30, 1990 states that the Radio-
graphic Review Sumuaries (YRT-2) were specified to have been controlled
per YAEC Procedure No. 11 and asked for a copy of Procedure No. 11. Pro-
cedure No. 11, entitled " Records," defines the requirements for control
and transmittal of QA records from the YAEC Quality Assuran::e Group to the
Seabrook Document Control Center. However, the YRT-2 forms and the YRT-1
Radiographic Review Requests were not considered QA recoMs and were not
retained or microfilmed for the document control files.
This apparent discrepancy was discussed with licensee QA personnel, who
indicated an error on their part in not revising the QEG NDE Review Group
Procedure No. 5 delineating the reouirement for handling the YRT 1 & 2
forms as QA records. While it was' originally intended that these forms
be treated as QA records, this need was obviated by the fact that evidence
of the YAEC 100% radiographic review program was provided by YAEC signa-
ture or initials on the Radiograph Inspection Reports and film packages.
Thus, the use of the YRT forms was reduced to an administrative control
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Attachment 2 2
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function within the QEG NDE Review Group. Evidence that the YAEC NDE Re-
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view Group did use these forms was provided by unofficial copies procured
from individual YAEC employee files and transmitted to Dr. Myers at his
request.
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However, it appears that a procedural provision to handle the YRT forms as
QA' records was neither followed nor revised when the decision w6s made ,
' that these documents did not require retention. While the NRC agrees that i
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the YRT forms did not require retention es OA records, the discrepancy i -
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seems to have violated procedural controls. This matter will also be !
addressed in a future NRC inspection report.
3. To complete his files on RC loop field welds, Dr. Myers' memorandum of
June 6, 1990 requested quality records related to the reactor coolant (RC)
system loop welds. Additionally, previous questions from Dr. Myers on RC
loop welds had sought'information on the completion of welding for certain
field welds.
NRC inspection of RC loop field welding began with the licensee initiation
of this work in 1981. Several 4RC inspection reports dccument NRC witness
of RC loop piping installation, field welding and repairs. One of these ,
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inspection reports (IR 50-43/81-13) was totally dedicated to the inspec-
tion of such activities. That report contains a chronological listing of
the dates of welding on several RC loop field welds. Although this listing
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does not address subsequent repair activities, it does provide supplemental
information which appears to be responsive to previous requests from Dr.
Nyers.
Additionally, NRC IR 50-443/81-13 documents NRC inspection of RC pipilig
weld records, in-process radiographs, and welding techniques, as well as s
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NRC consideration of the defect rates observed in the RC loop welding and
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of the metallurgical aspects associated with multiple cycle repairs. Be-
cause of Congressional interest in the RC loop welding and the above items
relative thereto, a copy of IR 50-443/81-13 was provided separctely. Also,
the NRC Systematic Assessment of Licensee Performance (SAlp) for. July 1,
1980 to June 30, 1981 documented the following related to the licensee's
performance in the area of piping and hengers:
"At the end of the assessment period-detailed procedurm. were being
finalized and an intensive training program conducted in preparation
for commencement of the Class 1. RCPB loop pipe welding installation
utilizing a machine-orbiting, pulsing gas tungsten are welding pro-
cess. The imposition of hold points for several informationa radio-
graphic shots, bayond code requirements, to be taken during the loop
welding not only illustrates licensee and contractor attention to
quality considerations, but also characterizes the overall improve-
ment in quality emphasis which has been noted to occur over the last
six months of this Cycle 2 assessment period."
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Attachment 2 3
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It was noted that the planned use of informational radiography in th* RC
loop welding process was considered a positive development in the licensee
preparations for the reactor coolant pressure boundary (RCPB) field welding.
NRC cognizance of such radiography being conducted "beyond code require-
ments" was also documented. A copy of the SALP Report from which the
C above quote was taken was provided separately.
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