ML20059N655

Forwards Responses to H Myers Requests of 900719,0806,13 & 16 Re Seabrook Welds

ML20059N655
Person / Time
Site:	Seabrook
Issue date:	09/12/1990
From:	Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:	Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
References
CCS, NUDOCS 9010170093
Download: ML20059N655 (9)

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'o UNITED STATES

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(,.....f Sep'tember 12', 1990

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=The Honorable Morris K. Udall, Chairman Committee on Interior and Insular Affairs

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Dear Mr. Chairman:

l Enclosed, at the request of Dr.l Henry Myers of your staff, are _ responses 3 to his requests of July.19, August 6,: August 13, and August 16, 1990, i

concerning Seabrook welds.

Sincerely, AsMk /

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Dennis, K. -; Rathbun,: Director Congressional < Affairs Office'of Governmental:and:-

Public Affairs-l

Enclosures:

As Stated l

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ATTACHMENT j

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i RESPONSE TO DR. H. MYERS' REQUESTS'0F. JULY 19 AND AUGUST-6 & 16, 1990 i

a Request'1 (July 19, 1990): (excerpted)

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'Since'DR #527',-which among other things-reported identification of 25 " code rejectable". items, does not state that it wasl issued to identify primarily*

j documentation and film quality discrepancies,Lwhat is-the basis:for the follow-

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ing underlined statement'in the quoted excerpt from the New Hampshire Yankee:

9 March 12 memorandum?

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f"The DR was issued to identify primarily" documentation / film quality

,l discrepancies..."

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<a Also','ifthe.listofDR#527weldswas.notavailabletotheJ11censeeonMarch12,

'1990(as-notedabove,the_NRCresponsestomy)requestforthis'11stindicated i

that the licensee did-not have it on March'12,=what was the basis for the_ con-clusion, implicit in the March 12 memorandum; that'DR #527's 25 " code rejectable"

.l discrepancies did not encompass hardware;deficienciesLin construction which

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grepresented a significant breakdown of the quality: assurance program conducted a

in accordance with the' requirements of' Appendix B?'

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Response

L A.

Statement Basis The basis for the underlined statement-in the above question is'the same d

'as-that for the licensee position that the 25 " code rejectable" discrepan-j cies did not encompass hardware deficiencies. 'Part'of that basistis docu-1 mented in the subject March 12, 1990:New Hampshire-Yankee (NHY) memorandum as follows:

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"If there had been any hardware problems identified, it would have resulted.in a P-H NCR..."

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I This statement'is corroborated by the followingiNRC; Independent Review.

h Team (IRT)statmentinNUREG-1425(p.2-3)concerningthe:YAEC: radiograph review process.

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"Ifweldqualitywasdefective.anonconformancereport(NCR).hadiio

~be' issued-per P-H Procedure XV-2."-

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Thefactthat.noNCRswere.initiatedby. Pullman-Higgins(P-H)asadirect.

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result of the discrepancies categorized in DR 527: supports the-licensee's' i

t position that hardware problems had.not.been identified. A subsequent..re-view of the YAEC RT: INTERPRETATION listing of the weldsicategorized on DR 527 verified that none of the documented discrepancies were weld qualityt w

defects requiring weld repair.

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Another part of the basis _for the statements and' position documented in:

H the YAEC memorandum in question.was the. licensee' understanding that the' 1

term." code-rejectable" did not differentiate between weld quality and film' 1

quality deficiencies. As discussed in the response to Request III.B'of

'l Dr.'Myers memorandum dated July.13,c1990,Lthe licensee had commented-in

l 1984 at a Systematic Assessment of Licensee Performance (SALP) meeting.

aboutNRCmisinterpretationof'thephrase"Coderejectable(25)"as'itwas used in DR 527.

In a letter dated April 25,~1984 to the NRC, the licensee l

attempted to clarify an incorrectistatement.in the SALP report by noting i

that:

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"This section infers that, licensee: review of-final code accepted j"

radiographic film packages approved by the piping and support con- -

tractor resulted in code rejectable indications.("at least 25") which' will require field weld repair. ; Licensee review in fact did result 1

in repair of one-(1) field weld.: The remaining radiographic film-i deficiencies'did not; impact hardware. however, software shortcomings; did require editorial correction or-enhancement.for microfilmability."

As was explained in the responsetto previous Congressional requests related to DR 527 the one' code' rejectable indication requiring: field weld' repair was actually-documented on DR 544"and;resulted in the issuance of' Pullman-Higgins NCR 5773.

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. Quality Assurance Adequacy

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Typically, hardware deficiencies identified on a'DR represent. proper quality' i

assurance-program functioning,:not a.significant quality assurance breakdown.

1 Further, there was no quality assurance breakdown in this case."

Over the course-of the SALP assessment period from July,1-through December 31,11983,'

as noted above, licensee review of Pullman-Higgins-film had: identified!only..

one actual hardware deficiency; 1.e., the subject field weld of DRf 544 which

.was subsequently: repaired, re-radiographed and: finally accepted byfYAEC.

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Therefore, the licensee had documented, t 1984, in a -letter made.publict with the final SALP report, the fact that DR'527 hadJidentified.only-radiographic film deficiencies.or paperwork discrepancies which did not impact hardware. The NHY memorandum of March 12, 1990 reiterates that 1984 licensee-position. As.has'been confirmed by recent' review of the;..

YAEC PT INTERPRETATION list,ino weld quality deficiencies'were identified;

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with the issuance ofLDR;527, and the licensee position.regarding the non-reportability of the discrepancies relative to the criteria of 10'CFR;.

50.55(e) is: valid. 'When weld' quality problems were identified (as was.the.

caseforonewelddocumentedinDR544),!a10CFR50.55(e)reportability-evaluation was. conducted in' conjunction with'the NCR review (e.g., NCR

5773forDR544).

j NRC Independent. Review Team inspection efforts to evaluate the effectiveness of licensee compliance with the reporting requirements of 10 CFR.50.55(e),

for the overall YAEC film review-program and findings are documented in-NUREG-1425, Section.17. 'IRT inspection findings related to DR 527'in.this J

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regard are also documented in NUREG-1425. (p.14-3).- The:IRT,Lin considering the NHY memorandum of March 12,.1990 and other: relevant information, con-1 cluded that h 10 CFR 50.55(e). review of the DR 527 deficiencies would have l

resulted in a determination that the identified conditions?were not

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reportable. :Such~ nonreportability means.that there are'no significant' breakdown,in any portion of the' quality assurance program conducted in l

accordance'with 10 CFR 50. Appendix B.-

Also it is correct that an NRC inspector was toldlin 1990 by: cognizant licensee personnel-that these licensee personnel did not know the where.

abouts of a' list ofJDR'527 welds.. This list was not,a required'QA.recordi

-and the licensee;did not.make it a. permanent record.. A-copy of thellistr was found by the NRC Inspector.in a resident office SALP file, where it had been placed at the-option of the NRC resident-inspector.;'

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. Request 2 (August 6, 1990): (excerpted)-

What does it mean when welds for which YAEC acceptances are indicated by signa-tures on the RIR's are subsequently listed on a YAEC Deficiency Report? In i

this case (YAEC DR 527), the same person signed both the DR and RIR.

Response

I It means that the individual discrepancy associated with any particular weld radiograph or Radiographic Inspection Report-(RIR) was corrected by Pullman-Higgins and evaluated and accepted by YAEC prior to the issuance of the defi.

ciency report (DR). Such was the case for-the specific examples noted by Dr. Myers in his question.with respect to DR 527. Dr. Myers' memorandum of August 6, 1990, in a preface to the question noted above, documents an NRC' staff response to Request 3a & b of his "Seabrook Welds (XIII)'Ememorandum of May 29, 1990, as follows:

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"As is discussed in the response to Request 1, the final acceptability of a radiograph and of the weld it represents was verified by YAEC reviewer signature or initials on the Radiographic Inspection Report (RIR) for safety-related welds. Thus the deficiencies' identified in the subject deficiency reports (DRs) did not have.to be. correlated-(in the-DRs them-

' i selves) with the welds to which they applied, because an unacceptable radiograph would not have had its associated RIR signed off by,YAEC."

The remainder of the above paragraph follows..

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" Interviews with YAEC QA personnel involved in the NDE Review Group acti-vities revealed that a decision was'made not to correlate eachideficiency i

with the affected weld so that YAEC could elicit generic corrective action from Pullman-Higgins rather than provide a detailed list of items to be corrected."

l While these particular. responses were written prior to the discovery by the NRC staff of the existence of a YAEC'RT INTERPRETATION listing enumerating the weld i

discrepancies associated with DR 527, they remain valid.' Interviews with cog-nizant YAEC QA personnel further revealed that the: discrepancies categorized and tabulated on DR 527 had been identified over a period of time.- Even though some of these discrepancies had already been corrected by Pullman-Higgins before DR 527'was issued', the general nature of such discrepancies was still charac-q terized by the different categories of deficiencies on the DR. This.was'done, as was documented above, "so that YAEC could elicit generic corrective action from Pullman-Higgins."'

As documented in the NRC staff response to previous requests from Dr. Myers and furtherdiscussedinNUREG-1425(e.g.,p.3-4),controlledspeedletters(CSLs)'

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-were sometimes used to direct Pullman-Higgins to take corrective action on radiographic deficiencies, particularly film defects.

Paperwork and editorial discrepancies associated with the RIRs provided additional examples of the types O

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J of-problems handled without the issuance of.a DR or deviation notice (DN).

Regardless of the means utilizrj L,v YAEC to-initiate the required corrective action by Pullman-Higgins, the finai acceptability of a radiograph and of its-J associated Radiographic. Inspection Report was verified by the YAEC reviewer, signature or initials on the RIR.

Thus. the YAEC sign-off dates.for'the weldsolisted by Dr. Myers in the preface

-to the above question represent the dates when the corrective action taken'by Pullman-Higgins was accepted by YAEC review.- An examination of the RIRs.for four of these five welds reveals the discrepancy noted on the YAEC RT L

-INTERPRETATION-list for.each weld was, in fact, corrected prior to YAEC re-viewer signatory' acceptance. "In the case of.the fifth weld (i.e., RC-12,. F0102),

no -discrepancy was noted:on-the YAEC; RT INTERPRETATION listing.. It appears -

1 that the Congressional. staff may have confused an informational radiograph-taken on a shop weld'on the RC-12-01 pipe line with field weld.RC-12, F0102, which the YAEC RT-INTERPRETATION list indicates was accepted by:YAEC without; need for correction by Pullman-Higgins.-

In summary..four of the welds raised as ~ examples in this' question ' represent cases where the RIRs,were.indeed signed off by YAEC prior to the issuance of DR-

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527. :In each case, the corrective action was completed prior to YAEC acceptance of the radiographic package-and' sign-off of the RIR. 'The' tabulation and con-i sideration of these particular deficiencies (even though they had already been' corrected) in the DR 527' discrepancy categories was acceptable because, as stated above, generic corrective action was expectedlof Pullman-Higgins.

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' RESPONSE.TO DR.L;MYERS; REQUEST x x x 11 (L (8/13/46 ) s' g

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h; b-l 1,4s ihas L been explained previous!'y-bo th fin (meetingsban'd inn 1

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response to'otherfreguests f or :in f ormation, ;:the b Y AEC. review; wi

,of 1 P-H r adiographs - wasi i pa r t,. of_

t'6el ; V AEC: LOA ' Burveil1 ance <i-i J

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program and con sequen t'l y? wa s no ti considered anE audi-ts.o fs. P-H7 gj

. rad iog r a phy :. a s.: y od4 lh'a ve f cha ra c tEr1:ed.i tti. (Thi's (prog f a'mj was es tablished. inigenera 1 icomp liance wi th : 1,Q'jCFR, 50l Append iv:00.,

w;i t hin ' ;._the3 fframework ; ot? the ;OA Survei l l an ne q, prog rainf :asl

]j described ~ in 1 t hel FS AR. T he.11007."scopel ~o f? ; t he asd_ rvei l l an ce) '

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reviews, o f f.in'a l' P-H iwe id lr;ad iographjf_i;t ms;.kas :volu,n ta}y? Un tilr if

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^ i L1984 -L when : thef100Y.J scope - o f ~; thisK surveil. lance. activityi.was ;

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f ccenducted by4'the,Independen t. Review LTeam.; proY1desiaS coherent;

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' program.

This report'has-been prov i'ded[ toh the :- Congress iona li.

q staff.. Add i tiona l l y.,:-dOring.our f 'si te mee tinglonJ Augus ti.28'iand 7:-

29,'1990 we discussed " th'is.ma t ter f in [dedth7aridlthe.NRC/ s ts f fl~

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a Request 3(August 16.-1990):>

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l Please provide the following:

1.

The inspection report relating to the inspection conducted'of the Seabrook

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pipe inspection program.during September-November, 1980.. (The reference to this inspection in NUREG-1425, page 2-3, does not.specify.the Inspection Number.):

2.

IAL80-55(datedDecember 22,1980).

(SeeNUREG-1425,p.'2-3.)

3.

Licensee's November 9f 1982' response to NOV issued as a result of inspection l

conducted during June-July 1982.

(While NUREG-1425 does not indicate the Inspection ~ Number for this inspection, it was probably Inspection 443/82-06. )- (See NUREG-1425, p. 2-3. )

4..

NUREG-1425 (p. 2-4) contains a reference to a December 1982 licensee re-l sponse'to "a notice.of violation." Please provide this; response.if:it is different from the response referred to-in. Item 3.above.

Response

The NRC Region I inspections of the pipe fabrication program.(September-November j

1980) referred to on page 2-3 of NUREG-1425 are documented in inspection reports

.(irs) 50-443/80-11 and 80-12. These irs, along with Immediate Action Letter.

IAL 80-55 and related-licensee and hRC correspondence,-have been forwarded separately.

The licensee's response-to the Notice'of~ Violation (issued in conjunction with

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IR 50-443/82-06) regarding the interpretation of radiographic film' discussed on page 2-3 of NUREG-1425 was previously provided as an attachment:to Response 1-to Dr. Myers' Requests dated June'7,1990 (XVIII). This response also is the.

I same document requested by Item 4: above. The' actual;date of the licensee re

• 3 sponse letter forwarding the corrective. action to the subject Notice of Violation is September 27, 1982.- The NRC-acknowledgement letter to this licensee correc-tive action-response is dated November 8, 1982. Both of these letters, with-all attachments, and with a licensee supplemental. response dated: November.22, 1982 and an NRC acknowledgement letter dated January 4,1983, have been for--

warded separately.

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1 CONGRESSIONAL CORAESPONDENCE SYSTEM

.l DOCUMENT PREFARATION CHECKLIST This checklist is to be submitted with each' document.(or group of Qs/As) sent for entering into the CCS.

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BRIEF DESCRIPTION OF DOCUMENT (S) _ h b ' dlc/s /[

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TYPE OF DOCUMENT Correspondence Bearings'.(Qs/As) 3.

DOCUMENT' CONTROL Sensitive - (NRC only)

Non-Sensitive-4.

CONGRESSIONAL COMMITTEE and SUSCOMMITTEES'(if applicable)

Congressional Committee-

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Subcommittee ~

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SUBJECT CODES r

t (a).

1 (b)-

(c)

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SOURCE-CF DOCUMENTS (a) 5520_ (document name (b) d ean.

(c)

. Attachments' s

(4) ~

Rekey (e) other-

7.. SYSTEM Loo DATES i

/o[/o /vd Date oCA sent document te cc8 (a)

(b)

Date CCS receives documentJ (e).

Date returned to OCA-for additional; i:..formatiion-

. (d)

Date resubmitted by OCA to ces (e)

Data entered into CCS by-L

- (f)

-Date OCA-notified that document'!

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COMMENTS i

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