ML20064B378

Comments on NRC Rept (NUREG-1425), Welding & NDE Issues at Seabrook Nuclear Station. Rept Does Not Resolve Important Questions Raised by Authors Earlier Inquiries on Subj. Expresses Concern on Rept Treatment of Util 100% Review

ML20064B378
Person / Time
Site:	Seabrook
Issue date:	08/09/1990
From:	Erin Kennedy, Kerry J, Kostmayer P, Markey E, Mavroules N CONGRESS (JOINT & ROTATING COMMITTEES, ETC.)
To:	Carr K NRC COMMISSION (OCM)
Shared Package
ML20064B375	List: ML20064B378
References
RTR-NUREG-1425 NUDOCS 9010160276
Download: ML20064B378 (8)

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as e een,isc mets August 9, 1990 The Honorable Kenneth Carr chairman United states Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Chairman We are writing about the NRC staff report, Waldiner and Nondestructiva 1Eraninatien Tanuma at sambreak Nuelaar Station, NUREG-1425. We appreciate the substantial effort that has gone into preparation of this report. At the same time it is our opinion that the NRC staff report does not ' resolve important questions raised by our earlier inquiries on the matter..

of particular concern is the report's treatment of the postulated Yankee Atomic Electric Company (YAEC) 1004 review of Pullman-Miggins radiographs. As demonstrated in an attachment to this letter, NRC staff have provided differing , explanations of the nature and duration of this review.

The 100% radiograph review was an activity affecting.the quality of safety-related piping; as the NRC staff report stated, this additional overview was "needed to - be performed in order to identify deficiencies missed by the piping contractor." As an activity necessary to provide assurance of weld quality, the 100%

review should therefore have been conducted in accord with the ComMasion's Appendix B. quality assurance regulations specified in 10 CFR $0, Yet the NRC staff report and other documents make clear that this review did not comply with these regulations.

Compount.ing the confusion is that NRC staff, in contradiction to its own findings of fact, would have us concludo the review was a non-nandatory, extra layer of assurance of quality, and thus an activity ne.t subject to Appendix B..

In sun,.the Commission's assurance of weld safety, stated at the tino of issuance of the seabrook Full Power operating License, relied upon a purported 100% review conducted-in apparent violation.

of the Commission's regulations. Moreover, documents provided to Congress indicate that until December 1983, NRC management responsible for Seabrook did not even know of the existance of this critical activity affecting quality.

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r Congress of the En(ttb 6tates i saspason, as acets August 9, 1990  !

The Honorable Kenneth Carr Chairman' United States' Nuclear Regulatory Commission Washington, D.C. 20885

Dear Mr. Chairman:

We are writing about the NRC staff report, Walding and ,

Mondantructiva Examination Tamuas at Enabreak Nuelaar Station, l NUREG-1425 We appreciate the substantial effort that. has gone into preparation of this report. At the same time it. is our opinion that the NRC staff report does not resolve important questions raised by our earlier inquiries on the matter.

of particular concern is the report's treatment of the postulated j Yankee Atomic Electric Company (YAEC) 1004 review of Pullman-  ;

Higgins radiographs. As demonstrated in an attachment to this letter, NRC staff have provided differing. explanations of the nature and duration of this review.

s The loot radiograph review was an activity affecting the quality of safety-related pipingi as the NRC staff report stated, this i additional overview was "needed - to be performed 'in order to identify deficiencies missed by the piping contractor " As an activity necessary to provide assurance of weld quality, the 100%

I review should therefore have been conducted in accord with the  ;

' commissionis quality assurance regulations specified in 10 CFR 50, Appendix B. Yet the NRC staff report- and other documents make ]'

clear that this review did not comply' with these regulations.

Compounding the confusion is that NRC staff, in contradiction-to its own findings of fact, would have us conclude the review was a non-mandatory, extra layer of assurance of quality, and thus an activity not subject to Appendix 5.

1 In sum, the commission's assurance'of weld safety stated at the t ti=a of issuance of the seabrook Full power oper,ating License, -'

relied upon a purported 100% review conducted in apparent violation of the Commission's regulations. Moreover, documents provided to-Cengress indicate that until December 1983, NRC management responsible for seabrook did not even know of the existance of this -

critical activity affecting quality. 1

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, The Monorable Kenneth Carr 1 August 9, 1990  !

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, our staffs have prepared tho' attached questions that need to be  !

i fully addressed in order to resolve our continuing concerns. . We  :

i would appreciate answers no later than September 6, 1990.  ;

l Thank you for your attention to this matter.

Sincerely,.

P e s . en y un Edward [.'Markk g John F. Ker g

l 7 Nicholas Mavroules )

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2 QUESTIONS I. Is it the Commission's position that the YAEC 100% review was an activity affecting quality? If so, under 10 CFR 50, Appendix 3 of the Commission's regulations, what documentation of this review is required to be maintained?

II. Is it the Commission's position that the Seabrook . licensee -

failed to comply with NRC regulations by not conducting its 1004. radiograph review in accord with the requirements.of,10 1 CFR 50, Appendix 37 9 I

l' III. With respect to the 1004 film review performed by the seabrook-  ;

licensee's agent, the Yankee Atonio Electric Company (YAEC),  !

the NRC' staff has provided inconsistent descriptions of the  ;

review's duration, nature and regulatory significance. I Attached to this letter is-a listing of character;.sations of i this review. t Since the NRC has relied upon the existence of the 100% YAEC j

, review for assurance of weld quality, please provide a ,

coherent and comprehensive description of the YAEC review's. '

purpose and duration,. documents subject to this review, review procedures, record keeping requirements, and procedures for handling deficiencies.

l IV. The following questions seek the data upon which rests the

• judgement that the YAEC 100% review did in fact identify deficiencias not detected by the senior Pullaan-Higgins -

reviewers.

A. of the welds approved by the senior Pullman-Higgins >

reviewer at the time of approval, which ones were the subject of subsequent repairs as a result of defects identified by the YAEC overview?-

B. NUREG-1425 (p. 14-2) contains a table indicating. the  !

! number of weld packages reviewed by YAEC during the years 1979 through 1986. Please provide a listing of the dates -

on which each of the welds reviewed during the years 1981 through 1984 was initially approved by the then current ,

senior Pullman-Higgins reviewer. (This information should be readily available from the source of the data on which the NUREG-1425 table was based. If this data is not available, what is-the basis for the numbers in.  ;

the " Weld-quality rejects" column?)  ;

C. NUREG-1425 (p.14-3), in reference to Deficiency Report.

(DR) #527, "... none of the discrepancies involved weld-quality defects." )

Congressional staff have evidence that at least two welds f l in the DR $527 list were the subject of weld repairs  !

subsequent to issuance of DR $527. What is the

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evidentiary basis for the NRC conclusion that none of the l DR #527 discrepancies involved weld-quality defects?  ;

D. NURIG-1425, Appendix 8, p. 7 contains the following j statementt ,

! The team reviewed all of the surveillances '

listed above whose subject is 'RT Review" to determine the nature of the overview of RT film l l Performed by YAEC. l Please list the welds referred to in the surveillance. I reports to which the foregoin statement refers. Please  !

provide, in addition, descri ions of. corrective actions  !

with regard to weld or ra iograph deficiencies taken  !

with respect to these welds. l t

V. NURIG-1425 (p. 1-4) statest i The IRT leader met routinely with licensee f

representatives to keep them apprised of the team's activities, plans, and findings.

l Is it standard practice for a leader of an NRC independent regulatory review to keep the licensee apprised of the review- ,

teams's activities, plans, and findings while the investigation was in progress? What -is the basis for confidence that such discussion of activities, plans and  ;

findings with licensee officials did not' compromise the NRC i assessment? Is such conduct routinely ' within the scope of

• what the commission regards as an indecari dent regulatory review?

VI. NUREG-1425 (p. 1-4) lists principal individuals contacted by NRC staff who participated in the seabrook weld assessment.

Please provide transcripts (other than the Waspler transcript ,

included in NUREG-1425), memoranda and other documents which provide a record of the substance of conversations with the listed individuals. ,

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! i ATTACHMENT Statements concerning the duration and nature of the postulated  !

Yankee Atomic Electric Company (YAEC) 1004 review of pullman- l Higgins radiographs. I

1. A January 4, 1984 memorandum from R.W. Starostocki to T.E.-

j Murley states:

1 A key operation in providing assurance of QC field i

activities is the YAEC surveillance program.

I specifically, YAEC NDE personnel had been and still do  ;

i conduct 100% review of contractor. accepted radiographs. 1 e

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2. Contradicting Item 1 above is, the report of the 1984 CAT ,

l Inspection (IR 84-07), conducted in April and May 1984, which j i states that a 100% review did ngs occur prior te vault storage I

of radiographs

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In the area of nondestructive examination, the NRC CAT l inspectors reviewed samples of radiographic film in final storage in the vault. As th e annliennt 's nremram does 7 net nrevida for review of radnocrranha by the annlicant 's i NDE crGan12ation nrior to their sterasa in the vault, [

samples of film were selected that had been reviewed by

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l the applicant's organisation, as well as film.that had <

not been reviewed prior to vault storage. No deficiencies were identified with the radiographs that had received the applicanh's review; however, deficiancian were identified by the NRc c1T inanaction with the radiographs which had neV baan reviewed by the I annlicant. (Underline added.)

3. On February 28, 1990 William Russell- (in his capacity as Region I Administrator) sent a memorandum to Thomas Murley (then Director of the office of Nuclear Regulation) which t stated:

.... after the allager (Wampler) departed the site, the ,

licensee performed a 100% check of the radiographs (Enclosure 8, pages 91 and 92) and required re-radiographing and rework as appropriate for any weld, regardless of who had previously reviewed it.

4. The Commission's May 18, 1990 response to Senator Kennedy's March 12 letter stated the following with regard to the YAEC film reviews -

The staff agrees that the 100% radiography review by the licensee is not clearly documented in NRC inspection reports so the reader is able to independently and unequivocally determine that it-was done.

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The Commission's May la, 1990 response to senator Kennedy's- (

March 12 letter also stated the following with regard to the -!

YAEC film review The licensee, on, the basis of its findings recorded in Deficiency Reports, deemed it . prudent to do. an.

l independent 100% review. The licensee implemented this i

decision on May 14, 1984, in FQA Manual procedure No. 5, ,

1 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 l completed the radiographic reviews.

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6. NRC staff's June 29, 1990 response to Items 2a & b in Interior-Committee staff's June 7 inquiry statest

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It (i.e. DR 037 issued in January 1980) shows YAEC 100%

- film review practice very early in the process of; radiographic flim package turnover from pullman-Higgins i to YAEC. I

7. NUREG-1425 (p. 2-3) states t

Thus, concurrent with the start of radiographic- -

' examinations of piping in 1979, YAEC began an overview of all P-H pipe weld film with the intent to reduce the 100-percent overview when evidence in p-N's ability to 9 properly identify and correct deficiencies had- been obtained. The overview continued throughout the piping 3 i installation and appeared to have resulted in YAEC performing radiographs. a 100 percent overview of all P-H pipe weld

8. NUREG-1425 (p. 2-5) statest The team concluded that the 100-percent overview  ;

performed by the licensee's agent, YAEC, was an effective  !

program for radiographic film interpretation, in that it -

i successfully found and required the contractor to correct missed deficiencies.  ;

9. NUREG-1425 3-5 statest The team concluded that the YAEC surveillanca program was active throughout construction, generally identifying and obtaining corrective action for the problems identified.

(Underline added.)

10. NUREG-1425 (Appendix 8, p. 7) states:

The DR' [037) documents that YAEC required no followup -

action because all film- is reviewed 100%." This information supports information received by the team k

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• o POO from cognisant personnel that YAEC reviewed'100 percent of the P-H film frc:n the beginning of construction.

11. NUREG-1425 (Appendix 8 p. 9) states:

The team's review indicated that YAEC was involved, on almost a daily basis, in the review of P-H film.

13. Congressional staff review has turned up no documentary evidence that, prior to December 1983, the NRC was aware of a YAEC 100% review of P-M radiographe. . NRC's July 16 response to Itens lg and 3 in the Interior Committee staff's June 19 memorandum (which requested NRC information as to when the NRC learned of the 100% review) stated:

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 quality records. This date is based upon documentation in a January 4, 1984 Region I nemorandum (previously provided) documenting. NRC awareness of the YAEC 100% radiographic review and upon reference in the resident inspector SALP office files to Deficiency Report (DR) 527 issued on December 7, 1983 with the supporting "YAEC RT INTERPRETATICN" listing.

It is possible that the NRC knew before December 1983 that YAEC was reviewing all film as it was received.

However, we have not found any record of NRC cognitance of the 100% review prior to December 1983. (Underline added.)

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CONGRES8IONAL CORRESPONDENCE SYSTEN DOCUMENT PREPARATION CNBCRLIST This checklist es/As) sent forisentering to be submitted into thewith 008.each document (or group of 1.

BRIaP DESCRIPTION OF DOCUMENT (0) b 1 /Mnrseu /de ula M'rv-

3. TYPE OF DOCUMENT /Correspon/(desseg e yr e , At w er> l> / u Beariage (Qs/As)

3. DOCUMENT CONTROL 8ensitive (WRC Caly) F Wea-Sensitive

4. '

CONGRESSIONAL COMMITTER and SUSCOMMITTR38 (if applicable)

Congressional Committee Subcommittee

5. SUSJECT CODE 8 t

(a) _

(b)

(c) i

6. SOURCE OF DOCUMENTS (a) 5520 (document anse (b) V Scan. (c) Attachments (d) Rakey (e) Other-

7. SYSTEM LOG DATES (a) /O[e /4 0 Date OCA sent doeunent to 008 (b)

Date CC8 receives document (e) _

Date returned to OCA for additional information (d) _

Data resubmitted by OCA to 008 (e) -

Date entered into 008 by

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(f) _ _ _

Date OCA actified that document is in CCS

8. COMMENT 8 A(MA fML dvl O : Mk &YE4 r

us i rm