ML20058N509

Forwards Responses to H Myers 900614,19 & 26 Requests Re Plant Welds

ML20058N509
Person / Time
Site:	Seabrook
Issue date:	07/16/1990
From:	Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:	Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
References
NUDOCS 9008140173
Download: ML20058N509 (9)

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July 16,1990 i

L The Honorable Morris K. Udall, Chairman Committee on Interior and Insular Affairs United States House nf Representatives Washington, DC 205H

Dear Mr. Chairman:

Enclosed, at the request of Dr. Henry Myers of your staff, are responses to his request of June 14, 19, and 26, 1990, concerning Seabrook welds.

Sincetely, .

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i ll Dennis K. Rdhbun, Director Congressional Affairs Office of Governmental and Public Affairs inclost.res:

As Stated cc The Honorable Don Young FULLTErr ASCllSCAN 0$Y l

9003140173 900716 DR ADOCK0500gg3

ATTACHMENT RESPONSE TO OR. H. MYERS' RE0 VEST OF JUNE 14,19, AND 26,1990 Request 1 (entire request of June 14,1990):

(para >hrased) A listin with Pullman-Higgins (gsign-ott P-H) of several datesreactor and alsocoolant (RC) system with nonconformance welds, correlate report (NCR) numbers and NCR issuance dates, has been provided. The following three questions apply to this listing:

1. Will the ongoing NRC inspection make a comparison, which is similar to I that leading to the foregoing list, based on a review of other welds in the RC system and other safety-related piping systems such as the Safety injection System? If not, why not?

2. Which of the foregoing NCRs resulted from YALC reviews? To the extent r these NCRs resulted from YAEC reviews, what YAtc deficiency reports or other records document such YAEC findings?

3. Will the ongoing NRC inspection review the foregoing NCRs to assess, with respect to deficiencies leading to these NCRs, the adequacy of determina-tions of root cause, the adequacy of determinations of generic applicabil-ity and the adequacy of corrective action? If not, why not?  ;

Response

! Response to questions 1 and 3 above have been provided separately.

With regard to question 2, NRC review of the nonconformance reports listed above '

reveals no evidence that any of these NCRs resulted from YAEC reviews. One NCR i

(No. 8006) was initiated as a result of a review of a field weld package by the

( Authorized Nuclear Inspector (ANI). However, the remainder of the NCRs appear j

tohavebeeninitiatedasaresultofPullman-Higgins(P-H)identificationof the documented nonconforming conditions.

l Two of the above NCRs (Nos. 6109&6509) were voided after internal P-H review.

The remainder of the NCRs appear to represent problems identified during the P-H records review process. This impression is substantiated by the documented oescription of each nonconformance, and by the tact that fifteen of the above NLRs were initiated by the P-H QA Records Supervisor. The others were initi-ated by other P-H personnel, but pertain to discrepancies similar to the ones identified by the Records Supervisor. Also, all of the listed NCRs were initi-ated in 1984, prior to the major turnover et QA records to YAEC for review. A general discussion of the program for records review and document control rela-tive to the P-H welding /NDE processes and N-5 program is documented in NRC in-spectionreport(IR) 50-443/90-0/, a copy of which has already been provided.

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it appears that, with the exception of the one AN1-identified process sheet discrepancy, the remainder of the problems identified on the NCRs listed above i were found and addressed by the Pullman-Higgins QA/QC program.

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3 Request 2 (questions 1. 2 & 3 of June 19,1990):

1. (paraphrased) In my May 29 memorandum I requested that i be provided the procedures that, prior to implementation of Procedure #5 in May 1984, governed the YAEC 100% radiograph review. The May 29 request encompassed procedures that mandated the review.

Whether or not a specific procedure governed the YAEC 100% review prior to May 1984, I assume the ongoing NRC inspection will provide information:

(Several questions tollow)

Response

Response to questions la through if and 2 have been provided separately.

Questions lg & 3 19 A statement as to the approximate date on which the NRC learned of the TALC 100% review and a discussion as to whether and during what time period the NRC assessed the adequacy of this review.

3. As of this date, I am unable to locate an NRC document, issued prior to IR 90-80 on February 7,1990, which refers to a YAEC 1001 review.

It the NRC staff knows of any such reference, please provide it to me prior to COB, Friday, June 22.

Response

NRC Region I was aware in December 1983 of the licensee's intent to review 100% of the radiographs transmitted to the document control vault as qual-ity records. This date is based upon documentation in a January 4,1984 Region I memorandum (previously provided) documenting NPC awareness of the YAEC 1001 radiographic review and upon reference in the resident inspector SALP office files to Deficiency Report (DK) 527 issued pn December 7 1983 with the supporting "YAEC RT INTERPRETATION" listing. Itispossible that the NRC knew betore Deceder 1983 that YAEC was reviewing all film as it was received. However, we have not found any record of NRC cognizance of the 100% review prior to December 1983.

An NRC assessment of the adequacy of the YAEC review program was performed curingtheSystematicAssessmentofLicenseePerformance(SALP) conducted for piping systems and supports on February 14, 1984. This is documented in the fina) SALP report issued on May 17, 1984 as a YAEC " customer re-view" of ASME final code accepted radiographic film. Furthermore, the NRC Lonstruction Appraisal Team (CAT) inspection conducted over the period I

April 23 - May 25,198a reviewed several radiographic film packages, the CAT inspection report, 50-443/84-07, issued on July 18, 1984 documents the following:

"No significant problems were ioentified involving film that was re-viewed by the 6pp11 cant's NDE organization. However, several irregu-larities were icentified involving film that had not Lyet] been re-

- viewed by the applicant."

If the film in which the irregularities were identified by the CAT inspec-tors had been accepted final radiographs, enforcement actions would have been pursued. Instead, the CAT recognized that the licensee's program required the noted YAEC review of all safety-related vendor and site gene-rated radiographs. In documenting the ditterence between the radiographic film which had been reviewed by the applicant and that which had not, the CAT inspectors specifically high11gnted the fact that the radiographic review process would have represented a regulatt?y concern had it not been for the applicant's review process. Hence, this area of inspection was not listed as one where eitier potential enforcement actions or signifi-cant weaknesses were identified. Such inspection logic and the resulting tindings and conclusions represent an additional NRC assessment of the adequacy of the YAEC 100% radiographic review program.

Additional documentation of an NRC assessment of the YAEC radiographic review process can be found in other NRC inspection reports (irs). As an example, IR 50-443/83-19 for inspection conducted f rom November 28 -

December 1, 1983 included a review c' the reactor pressure vessel (RPV) safe end radiographs. The NRC inspector reviewed radiographs that had been rejected by YAEC despite a differing position tendered by Westinghouse as the RPV supplier, and the NRC concurred with the YAEC findings. Other component radiographs were also reviewed, resulting in additional assess-ment of the quality of tile YAEC review. An example is IR 50-443/85 31 tor an inspection conducted from October - December 1986. Documented in this AR is the statement tnat:

"lo date, the licensee has perforined an overview of virtually all vendor suppliec radiographic film. Where problems were found, such as geometric unsharpness failing to meet the ASME code, radiography was re-performed on site and repairs were made, it necessary W inspector reviewed a sample of film during this inspection, which also provided a measure of the NRC assessment of the YAEC radiographic review program.

OtherNRCinspections(e.g.,IR 50-443/85-19 conducted in July 1985) used tne NRC NDE Van to independentfy radiograph welds. Such inspections vert-tied the adequacy of the licensee's radiographic program and compared site file film to NRC radiographs in an assessment of the licensee's overall NDE quality control program.

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Another assessment of licensee performance in this area was conducted during the SALP appraisal on February 19, 1985. In the SALP report, issued on May 28, 1985, the following evaluation was documentec:

"It is noted, however, that with regard to completed and finally in-spected hardware, very few problems were identified. In fact, in the welding and NDL areas, independent examinations by NRC inspectors l revealed generally high quality work and effective licensee overivew of the final radiographic film packages."

In assessing the overall performance in the area of piping during this ,

January 1 - December 31, 1984 SALP )eriod, it was noted that significant improvement had been achieved and t1at the licensee had demonstrated "ade-quate control over their self-identified construction problems." One of the areas evidencing such licensee control was the YAEC 1001 radiographic review process.

Further, in the previously mentioned Region I internal memorandum of January 4,1984, it was noted that:

"A key operation in providing assurance of QC field activities is the YAEC surveillance program. Specifically YAEC NDE personnel had been and still do conduct 2001 review of contractor accepted radiographs."

t this memorandum not only arovides the requested reference to an NRC docu-ment acknowledging the YAEC 1001 radiographic review effort, but also assesses this program in the context of NRC followup of the previously -

reportedNDEfalsificationproblem,(i.e.,the"Padovano" case). It should be noted that the above quote discusses the 100% review in reference to the "YAEC surveillance program." As has been discussed in previous re-sponses to Dr. Nyers' requests, prior to the im)1ementation of the YAEC  :

NDE Review Group procedure No. 5 in May 1984, tie YAEC radiographic review process was controlled as a surveillance activity. Thus, even though sur-veillances were not normally 100% inspection efforts the above NRC quota-tion illustrates the YAEC intent to conduct such fil reviews on a 100%

basis some time before the existence of the procedur ' requirement to do 50.

The inspection reports identified in the response to this request have l.

been provided previously, l

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, i HeQuest 3 (question 4 of June 19.1990):

(excerpted) On May 22, I asked that you provide prior to COB, Wednesday, May 30 the Radiographic Inspection Reports for the cooling tower welds where the main "T" connects to the spray headers and for the six welds closest to this connec-tion. As of this date, I have not received the requested Radiographic inspec-tion Reports; please provide them prior to COB, Friday, June 22 or, in the event such documents are not available, an explanation as to why they are not available.

Response

In response to Dr. Myers' request of May 22, 1990 on the allegation concerning deficiencies in the radiographic record of the cooling tower piping welds, Nonconformance Report UE&C NCH $66, enclosing the requested Radiographic In-spection Reports, was forwarded separately. Attachment 2 to a June 26, 1990 NRC memorandum responding to subsequent requests from Dr. Myers also was for-warded to convey supplemental information relative to the NRC follow-up on this issue.

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c Request 4 (entire request XXV of June 26. 1990):

(excerpted) Your June 26 response to Seabrook Welds XV states that Revision 2 of NCR 6781 addresseh the 2b1 review item. While Revision 2 does in fact address the item with a statement to the effect that the 25% review had been initiated and was approximately 80% complete, it does not, as far as I can de-tect, include the review required by NRC 5781, Revision 1. In fact, Revision 2 (issued on May 24, 1984, more than two months after the due date of the 25%

review) indicates that the review had not been completed as of the date of issuance of Revision 2.

If the NRC staff has located document (s) describing the 25% review required by '

NCR 5781, please provice me such documents (s) prior to COB, Friday, June 29, or in the event you cannot provide the document (s) by this date, please inform me of the reasons for the inability to do so.

Response

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Revision 2 of NRC 5781 documents the following:

" Item 3: This NRBKt item requested a review of 25% of the Process Sheets for the KC system that were processed during the same time frame as RC-049, t0103.

P-H QA Records has initiated a review of all Process Sheets for the RC '

primary loop. This task is approximate 1yT1 complete."

WhiletheNonconformanceReviewBoardResponseForm(NRBRF)forNCR5781,Re-vision 1, required a review of 25% of the process sheets for the RC system.

Pullr'an-Higgins (P-H) QA personnel initiated a review of all process sheets.

(The underlined emphasis was part of the exact NCR wording"7 NCR 5781, Revision 2, was issued on April 12, 1984 at which time the pages containing the above quotation were provided. Dr. Myers' reference to a May 24, 1984 date is the date the Nonconformance Review Board accepted the disposition of this NCR. A review of the signature blocks on NCR 5781, Revision 2, indicates that the Engineering / Construction and QA/QC representatives on the review board actually signed off on the disposition on April 12, 1984, showing that they had for the1r review and consideration the quoted status of the P-H review process.

Therefore, what is documented in NCR 5781, Revision 2, is a statement that, as of April 12, 1984 P-H QA personnel had reviewed 80% (i.e., more than three times what was required) of all RC loop process sheets. Included with this statement is the chronological report of activities concerning field weld RC-49-01, F0103 as directed by the NRBRF disposition of Revision 1 of the NCR.

The last chronological entry for final RT acceptance by the P-H NDE Level 111 technician was dated April 11, 1984. Since Revision 2 to the NCR was issued on the following day, it appears that P-H waited for this final RT acceptance prior to 1ssuing Revision 2 to the NCR so that it would be included in the

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chronological report. That would explain why the supplemental information, to i include the process sheet review status, was not submitted as requested by l March 16, 1984 I Furthermore, while concerning

" report of activities the NCR 5781, Revision 1,fteld weld, it required Pullman-disposi the noted Higgins to "teview 25% of the process sheets f or the RC system." No require-ment for a " report" of this review effort is discussed. Such a provision calling for a document " review" without a rewiting formal " report" would not i be unusuel. This is because any discrepanci w or deficiencies identified as a '

result of such a rnview would be required, by ?.h3 P-H deficiency /nonconfortnance program, to be addressed and corrected on a e.se-by case basis.

The disposition to Nevision 1 to NCR 5781 specified that the P-H review of the RC system process sheets include as a minimum a review of:  ;

i A. Minimum wall requirements B. Original WPS for the weld joint ,

C. Repair WPd for the weld joint While a definitive statement of the results of such a review would have assisted the current understanding of what occurred in that time trame in 1984, a report  ;

of the type requested by Dr. Myers was not required and it was not expected that one would be prepared. Pullman-Higgins was conducting a records review (the scope of which was. delineated as noted ahve in Revision 1 to NCR 5781) to search for discrepancits similar to the ones identified on the >rocess sheet for Field Weld RC-49-01, F0103. This fact was sufficient for tie Nonconformance Review Board to accept the di: position to Revision 2 of the NCR because any ,

discrepancies identified woulo have to be 6ddressed and corrected.

It should also be noted that, in the NRC followup of an allegation documented in IR 50-443/85-17, the fiele weld process records for RC-49-01 F0103 were reviewed. Atthesametime,NRCreviewofNCR5781toincludedevision2was conducted. No deficiencies were identified as a result of this review. Also, subsequentNRCVaninspection(reference: IR50-443/85-19) included radiography .

of F1 eld Weld RC-49-01, F0103, and identified no problems. This weld was specit1ca11y selected for independent van inspection by the NRC because of the problems documented with this field weld in NCR 5781 and its revisions.

The above inspection report ref erences have been previously provided.

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