ML20066F794

Forwards Summary of Oversight of Pullman-Higgins Welding & Radiographic Film Testing in Response to Lj Norton 901106 Request for Info

ML20066F794
Person / Time
Site:	Seabrook
Issue date:	01/11/1991
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF THE INSPECTOR GENERAL (OIG)
Shared Package
ML20066F797	List: ML20066F794
References
NYN-91002, NUDOCS 9101240170
Download: ML20066F794 (25)

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New Hampshire Y-h bd C. Feigenbowm Prevdent and Cw.1 Esecutwe Omcer NYN 93N'?

J ariunty 11, 1991 Mr. Leo J. Noiton Assistant inspector General for Insestigations Office of Inspector Gcoert.1 United State. Nuclear Regulatory Commission Washington, D.C.

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Rderences:

NRC Lettet dated Nove mber 6,1990; Leo J. Norton te Ted Feigenbaum

Subject:

Response to Request for Info:mation

Dear Mr. Norton:

The referer ced letter indicates a desire on the part cl your of0cc to more clearly understand the Yadee Atomic Electric Compeuy's review of the Pullman Higgins welci radiographs at,d requested associated documentation. The enclosed material is submitted in response to that reques.t. Enclosure 1 is an attempt to place the Pullman Higgins weld issue, particularly the weld rejection rate issue, into proper perspective and into the context of the overall quality progrem at beabrook. We believe a true understanding of the facts will lead to the conclusion that Pullman Higgins welding was closely monitored by Public Service Company of New Hampshire, YAEC and United Engineers and Constructors; that Pullman.

Higgins welding was held to conservative standards tbst met er exceeded ASME Code and reguhtery icquirements; and thet tbt rigorous implementation of a multi layered quality program ensured the technical acceptability of the flual product. Enclosures 2 through 20 provide the specific documents requested in your letter as well as other material that may be relevant to your insestigation, if you have any questions on this material or this issue in general, please do not hesitate to call Mr. Nest Pillsbury at (603) 474 9521 extension 3341.

Very truly yours, g'f M $

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Ted C. Feigenbaum TCF:JBH/act/ss!

9101240170 910111 s

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New Hampshire Yonkee Division of Public Service Company of New Homphire 2/0020 P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521 6

United States Nuclear Regulatory Commission January 11, 1991 Attention: Mr. Leo J. Norton Page two cc:

Mr. Thomas T. Martin Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, NH Hj74 Mr. Gordon Edisca, Project Manager Project Directorate 13 United States Nuclear Regulatory Commist,lon Division of Reactor Projects Washington, DC 205$5 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555

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LIST OF ENCLOSURES I

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1.

Summary of Oversight of Pullman Higgins Welding and Radiographic Film Testing.

2.

YAEC Memorandum dated June 21, 1983; J. W. Singleton to All,

Subject:

Controlled Speed Letters, YAEC Controlled Speed Letter #089 dated November 30, 1983.

3.

YAEC Surveillance Reports (78) related to radiography.

4.

Five Typical Audit Reports Dealing With Radiography. 1980 through 1984 5.

Data Request by Theodore Barry and Associates (TBA) for The Scabrook Prudence Audit performed for the State of Connecticut Department of Public Utility Control.

History of Weld Reject Rates.

6.

Extract from Management Performance Evaluation for Wolf Creek Ger.erating Station, Cover Sheet and p. 253.

7.

Extract from Seabrook Project Management Prudence Audit (PLG 0447) by Pickard Lowe and Garrick, Inc. dated July,1986. Backup Document, Section 3.6.

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Letter from Stephen B. Comley, Executive Director, We The People of The United States, Inc to Samuel Chilk, Secretary, USNRC dated May 8,1989, 9.

Extracts from Official Transcript of Proceedings Before the U.S. Department of Labor, Case No, 84 ERA 13; Joseph D. Wampler vs Pullman Higgins Company, March 19,

1984, 10.

Portsmouth Hearld Clippings, March 18, 1984 and March 21, 1984.

11.

Pullman Power Products, R. T. Status Sheet, f

12.

Memorandum dated January 10, 1984:

W. J. Taylor (UEAC) to J. J. Corcoran (P H),

13, R. T. Reject Rates, Decernber 29, 1982.

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Extracts from Transcript of Department of Labor Proceeding: Richard Cram vs -

Pullman Higgins, May 8,1984, 15.

Brand Examination Service and Testing Co. (Bestco) Report #58023 for NHY, 16.

UE&C Inc. Handwritten Report on Review of Radiographs, i

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LIST OF ENCLOSURES (continued) 17.

W. Hinz hiemo and draft dated May 10, 1983.

18.

YAEC Memorandum dated July 14, 1981, W. J. Gagnon to R. E. Gyll;ette and YAEC Metaarandum dated August 7,1981 J Nay, Jr. to R. E. Guillette.

19.

Construction Appraisal Team Inspection 84 07 dated August 29, 1954,

20. to Chairman Carr's December 19 response to Kostmayer et al.

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New Hampshire Yankee January 11, 1991 O.

l ENCLOSURE 1 TO NYN 91002

SUMMARY

OF OVERSIGHT OF PULLMAN HIGGINS WELDING AND RADIOGRAPHIC FILM TESTING O

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latroduction

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The purpose of this report is to briefly place the allegations made by Mr. Joseph Wampler regarding the quality and rejection rates of welds performed by the project's piping contractor, Pullman Higgins (P H), into the context of the overall program at Seabrook for ensuring a quality final product. Recerctly, in response to congressional concerns, the NRC published the results of their own comprehensive re examination of this issue in a report enthled, Weldintand Nondestructive Examination Issues at Seabrook Station. July 1990, (NUREO 1425).

This assessment was the product of a review performed by an NRC In;pection Review Team led by NRC Senior Management and composed of NRC staff and private sector experts in the field. After a four month investigation, it concluded that the

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multi level system of quality assurance imposed on P H by the Seabrook project ensured that the final proilucts were technically acceptable pipe welds.

Through this report, New' Hampshire Yankee (NHY) hopes to provide -additional licensee perspective on the issue.

It. will demonstrate that the managements of Public Service Company of New Hampshire (PSNH), Yankee Atomic Electric Company.(YAEC), United ll l

Engineers & Constructors (UE&C), and P H took early actions to discover, understand and to resolve welding program concerns and that, ultimately, the multiple layered and highly conservative quality procedures and standards adopted by PSNH and YAEC casured that the piping system welds were all technically acceptable. The report will also specifically discuss

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toe YAEC practice of reviewing the final weld acceptance P.H radiographic film for ASME OV)

Code welds and describe the objective evidence available to substantiate that it was done.

The sperit'ic information requested by the Office of the Ingector General in his letter of November 6 to New Hampshire Yankee (Reference 1) is provided as Enclosures 2 through 20 and referred to as appropriate in the narrative, 11.

Quality Assurance Structure The Seabrook project was initiated by PSNH in the early 1970's. PSNH initially retained a 50% ownership share in both units and sold the remaining shares to other New England utilities. Under a Joint ownership Agreement for the project, PSNH had " sole discretion" n

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with respect to all aspects of the design and construction of the plant.

Very early on, however, PSN!! selected YAEC to assist in project and engineering macagement because of YAEC's exterience gained during tie.esign and construction of four other nuclear power plants. UE & C was selected as the architect / engineer and constructios manager. UE &

C would be responsible for engineering, procurement, direction of construction contractors, scheduling, cost managemeut and other services. YAEC, in addition to assisting PSNH in managing and ~ overseeing UE & C and all the other contractors, was assigned detailed management of quality assurance arid other functions.

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JUn'derfthe:Jconstruction management. approach - utilized byf PSNH':for J Seabrook, the' l

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J 45 fconstructionfmanaged l e. UE & C.' contracted for the services:of established -contractors in-

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.thelvariousLapplicable/ construction disciplinesi The contractor selected to = install piping and 1

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yj Tsupports at Seabrook~ was Pullman Higgins (P.H);. PH.was an entity. formed as a result of p.

a Joint': Venture between Pullman Power Products:and J. C. Higgins.

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.'As ! mentioned above, PSNH. delegated the establishment 4 and implementatita of the? quality W,

assurance program to YABC although PSNH maintained licensee responsibility for the quality'

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~ of construction; YAEC'r, policy for-quality assurance, as described in the Preliminary Safety.

t (AnalysisL Repott (PSAR), involved the following:three levels of control, j

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q OualityJ control indors <and ccastructors on = the activities 1they 4

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Level;14

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perform and by U 4 C -en site receiving inspection' and storage. = This m

includes reviews, inspections and tests.-

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. Level-2 _.

Surveillance;of design, ' abrication and construction activities, including '

j 1 Level 1 quality:contro Contractors previde this level for the desij;n f t}

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Land procurement shase.

7A - a 1vides a surveillance level on all site-tactivities-under;.iis Prqurn. GT 0; C provides additional surveillance j

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-ontsitecconstrwtlon of st, sares)c y

hv level.31.z fAu'dits biYAEC OCA. Department.Westboro of activities perfor:ned by:

? Level l1' and j 2' organizations.-

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SYAEC will: provide 'the third ' level for!all activities. I At cach ' level, the indivif.al or-

?l fgroup ' responsible-for reviewing, inspecting, auditing or' otherwise 'verif ng that an -

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? activity has ;been correctly performed will:.be ladependent of the'individ 1 or group tresponsible-for: performing the specific activity. : The degree of control at each level-d

--will reflectithe nmportance of the activity to: plant safety;and-reliabilityJ(Reference -

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@4 iPullman,Higginsthadytheir;own OA/OC orpnization funder ;the local direction of 'the = P H

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i, VFieldiOA" Manager (FOAM)

The P H -FO AM's programmatic. and procedural a'uthority..

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,.flowedifrom( PullmaniPower Productsc -In' this. structure, P H thad -the responsibilityLto 3

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' provide' the Level 1 condols for its' welding processesi Under the ASME Code, this meant, 1

inipart; that;they2e6

uired 'to provide ASNT Level II' review ot' film for weld quality.=

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.If the P2H:'ASNT Level !! accepted a weld, lt could be presented to the Aiuborikd Nuclear j

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Inspector (ANI).. lf rejected, P.H could either repair thel defects or write a Nonconformance w

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, Report (NCR)Las app;8 cable. UE & C, as the engineer of record, had the responsibility to-1

disposition the NCR. It could 'either direct the necessary repairs, order a. retest, or after '

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- evaluation determine (thatfthe weld 'in; question-wasi acceptable "as is '

YAEC Quality L

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J Assurance?was only-)commlited in: the. PSAR to provide' control Levels 2 and 3 over this

_. process,,'t.e. surveillances -and~ audits,.and not -another one hundred percent complete layer -

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of..reinspeetionssor[re cxaminations.

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(III P2H Weld Quality Improvement; Initiatives 1

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. [YAEC QLand UE&C closely moultored the quality ofl welds and rejection rates'on. welds-m 1

e' performedEby! P H from; the 4beginning _ of telt service :on (the : project. In June,1980, the '

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}c rejectioni rate fordradlographed" safety related' welds performed.by-Pullman Higgins was K

LidentifiedlasL38E for :new ! welds"and 50% for weld repairs (Reference 3). = Because. the~'

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. dAmerican' Society for Nondestructive-Testing Recommended' Practice (ASNT-TC-1A)cer% forth the?minimuat capabilities that qualify personnel to perform

.i snon' destructivetinspections-: examinations and tests as me11 as the education j

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~-and!experiJnce regulrements.- There.are three ASNT. levels-of qualification:

1 Level I ;uevel II and Level III with Level III'being the highest.

Level II is L

,g Hs the: rainImum, required ?to review and interpret radiographic film.

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population;6f/ safety.related'we!ds.(leiL ASME Code)fwas:still small, YAEC:OA' had > some:

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non saf ty i related,'(NNS)[ welds,1 performed by: various. P H welders,Tradiographed Land:

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'k evaluated a'sf part of its: assessment.of 'overall: welding programLadequacy. NNS: welds would u

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normally-only requite < visual and hydrostatic examination' to. determine acceptability. The-a I results idhntified areas where welding and radiography, techniques and/or controls-:could be-1 m

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Theme l factors prompted the PSNH Site Manager to' write UE.& C (Reference 3) to suggest

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steps that could :be-taken-to improve -P H welding. It Is.important to note here that the" l

i LPSNH Sl'c. Manager'sl expression of concernhwas not that:there was a potential-forethe_ end t

dprobuct quality lto.be compromised.8 t He: understood that the strict,~ conservative standards:

J s.h Lof the quality ssurance program would not allow that to. happen. lHe also knew that YAEC j

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jhad-aircadj? moved beyonditheir PSAR' commitment that required'only surveillances and 1

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audit'slof P H = 4to' a 100% review;of radiographic" film and documentation (see Section q

t Vil)J.His concern wasjover thed.ipact that high; rejection; rates andtrework would have on:

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cost"and schedi;ec ' As he states in' Reference 3:-

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?Wejrecognize. thatlthe end Eproduct.will be-top : quality.:

This L:ls our-A acceptanceistandard forl quality ast.urance and no' thing less;wlit be. tolerated.

- However; withi theFamount"of rework required;to achieve ac' eptable?qualit'y.

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' based onithelweld,ing performance, we have: experienced to date, we:are treallyi

. facing. a} major cost factor,which?ls" forcing Lthe: welding scosts to increaset y

,. i'Mr.'Wampler.~himself: stated, under. oath...atia Department of Labor-

proceeding, that he'was notiaware of any film review violations. -See

transcript pages 219-220- ofyEnclosure 9.-

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f Purthermore with the limited manpower situatior., particularly welders, this will y

also have a negative impact on schedule perfctmance "

h UE &, C's reply in July,1980, (Reference 4) indicated they were aware of the need for Improvement-and, in fact, had already been having discussions with P H on how best to make them. UE & C then outlined a plan to improve weld quality. The plan emphasized a significant upgrade of the training and supervision of welders.

An offsite school was established at which P.H welders could improve their technique. The instructors at this school were given feedback from P H welding supervisors on the most frequently occurring

-welding technique difficulties being experienced at Seabrook so new welders could be trained to r.old them and the proficiencies of current welders could be improved.

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IV NRC Assessments 3

The NRC noted their concerns with the piping contractor in the Systematic Assessment of

. Licensee Performance (SALP) report for the period 1/1/80 through 12/31/80. In their report, the NRC concluded that performance in the category " Piping and Hangers" was below average. The corrective actions that PSNH-had undertaken with respect to the " unusually

- high radiographic reject rates', were specifically cited ilthough, because of their recent implementation, the NRC deferred judgement on their e ffectiveness. By the end of 1981 P H had completed about one quarter of the total weld'. that they would ultimately perform and'the rejection rates for both new and repair we'ds had come down substantially to about

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7 (the generallyfaccepted industry norm of about 25 percent. - This improvement was reflected M

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i ilnithe SALP for;the period 17/1/60 through 6/30/81 which cite'd licensee and ~ contractor d

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C fattention to quality (and= the overall improvement in quality emphasis and placed Seaicok's' t

p (Piping [H' anger' Program in SALP Category 2.

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.. :In the nextL SALP report, which covered the period'from 8/1/81 until 7/31/82 (Reference 5),

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'the NRC ' lowered the project's grade in the category of Piping-Sys! cms' and Support from J a 2:to a 3..

It reiterated soine of the violations noted by' th'e Construction Appraisal Team's i

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[.(CATj June,71982 reporti-:- The: rejection' rate 'of welds-during this period also increased

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- s. lightly,; Significantly,Chowever,' the - SALP report.did recognize that Lit T

processiproblems-ln;this area,~;which were well documented in-the CAT report, the YAEC -

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' oaf program continued :to ens'ure the-adequacy' of the final product.~

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'IThroughitheinext-threv SALP periods,Lthe NRC remained critical of the Piping Syst' ems and:.

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_g JSupport program lat Seabrooli, aw'arding the; project ai'3'-in the two freports coveringithe;

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f perio' 1through 1983-(References l6 and 7), and a '2' in l'984.:(Reference 8), In=cach-case, d

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/howeve'r, the NRCcalso -cited the licensee's OA programx as a strength.

In' the report for-W l198_4 the NRC specifically cited the non mandatory YAEC film review, which'by April;;1984'-

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Jha'd been formally proceduralized.

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Weld Rejection Rates L.1 -

Table 1 provides a summary of the rejection rates reported by P H to UE&C for new and repaired welds from 1979 through the end of 1983. The P M rejection rates are som? times referred to as " unadjusted" rates. They were subject to adjustment by UE&C cither after a.UE&C locpection of the film and/or the actual weld determined the weld to be acceptable or by application of UE&C's own criteria for deteamlning rejection rates (see Enclosure 11).

The P H ' unadjusted rejection rates therefore are higher. The data in this table depicts the PIH unadjusted rates covering the period through July,1983 and is extracted from an August 1983 memorandum from the UE & C welding engineer to the UE'& C project manager (Reference 9); the remaining data comes trom a recent review of the records.

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-J The weld rejection rates came down in 1981 as PSNH, YAEC and P-H al.1 took steps to 4

increase.' the effectiveness of training 'and supervision. The overall annual weld rejection rate for new welds and weld repairs in that year was right at the industry norm of-25 percent. In 1982, the rate increased to about 28% for new welds and 36% for repairs. The industry wide' shortage-of pipefitters and welders and the resultant difficulties it encountered in attracting and' retaining skilled craft labor were the largest contributors to this increase.

The rejection rate was still near Ae industry norm, however, because of aggressive L

management actions to improve welder -performance and weld qually.

These actions included-the establishment of an offsite welding school which resulted in an increased pool t

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iof 'sMlledUwsiders, Land an.on site training facility:that enabled welders alrehdy: working on

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-i bi f (the project to improve -thele technique; enhance thelr'quallfications and thus-be able to' work toLeode requirements and. acceptance crlt'eria on all aspects of the projects's piping. By-the

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y beginning of 1983,;the rejection rates were significantly reduced-and consistently-held below j

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.o Ini fact during the four months of -Mr -Wampler's employment at d

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Seabrook _ from the: cod:ofDAugust.1983 until January 3, 1984,7 the ' rejection rate for -new Y

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Other d'ssessments

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In addition to the NRC's: SALP reports;-the: Construction-Appraisal: Team. Inspection,and l

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-tbe-1 pro ect's-own self initiated studies,E there are three. prudence audit reports,that-d, J;?

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documente'd close examinations of 'the construction project.as.aiwhole and provide relevant

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r comments'on(theqquality of final construction. :They are the Plckard, Loweiand Garrick.Inc, j

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.(PLG)i-; Management-Prindence-Audit (Reference 10)' performed int 1985 for counsel to PSNH, l

Il M he Challenge-Consultants Inc. L Study of the: Seabrook Project ;(Reference (11)-published lIn

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. 1986' for'several^ of Seabrook's Lminorityjowners, and;-the-Theodore Barry and LAssociates'J

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j (TBA)' Retrospective Audit of the Seabrook' Nuclear Project (Reference 12) for;the ' State of' l

i Connecticut Department of Public Utllity Control in:1987.

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s Th'e PLG' Audit was performed for PSNH counsel as part of a rate case procceding

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' PLOfevaluated the management actions of PSNH and its principal contractors for the period

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from 1972 toimid 1984.

This was an ' extremely comprehensive. audit, covering most aspects of the project and the decisions and actions of management, Its report includes more than

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y 40 volumes'of narrative and backup material. In the report s Executive Summary,-PLG made'

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. these1 comments about-Quality Assurance Management:

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- By. all..: indicators to. PLO - and,-- more importantly,. to the Nuclear Regulatory 1

Commission, the, end result of the Seabrook project quality assurance program...the quality-of the-project itself..is excellent.

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-(Page 4.120 h Reference 10)

. Amongithe strengths identified by PLO in the YAEC quality assurance program were its direct survellFance-over site activities and its extensive audits of-project activities, which contributed to the excellent quality results achieved. -(Page 1.121 of Reference-

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The Challengeistudy was.also:a ccomprehensive evaluation of-management performance at '

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- Seabrook, D With respect to the.pipefitter shortage during the period when P H was active, 01

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Challen i

Seabrooke.has reviewed the history of the bpefitter-shortage and:has concluded tha management took - a nnumber i o actions :to minimize - the-- potentialE for o

imanpower'shortagese While.these actions-did inot solve the shortage entirelys-- they --

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As soon ~ as piping installation began, the Project Management Group made plans forcan off site weld,ng school to train welders.. The.

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welding school resulted in a significantiv increased = pool of qualified welders and an-

? improvement in weld rejection ratesc Furthermore, the Project Management Group

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Ecstablishec Jan on site training facility :to upgrade welders already working, on 4he project to.cnable~ them touwork tobcode and quality assurance levels on all aspects 1~;

,,.of the pro 3ect's piping. /The training effort at Seabrook:was timely and extensive.

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. lThese progiams were very effective.in producing a:large number of qualified welders and-in :upstading the' welders already. on site;. We concluded 1 hat the establishment

of-the weiding school and-other training pro rams-was e. noteworthy response to a -

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[Its* con $1usion fonLthe overall qualityfot the final project Lwere similar._ to -those of the-PLG

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--The-quality assurance program -throughout the duration of the Seabrook Project has a

been exceptionally strong. -The quality program was well defined and the enforcement of its provisions has been strong, (Page 10 of Reference 11)

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The:TBA audit was commissioned-by thelConnecticut Department of Public Utility Control r

toldetermine~ the extent' to which costs of participa, ion by The'. United Illum'inating Company j

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.and,' later, the Connecticut Light. &- Power Company. in the construction of Seabrook Unit

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v 1 and 2 should be locluded'in the rate base. -TBo leveled criticism at the project over what j

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y Othey believed were inefficiencies in the performence of the OA~ function, and felt that cost j

expenditures in supper' he project' F 'upby of '.;A conservatism were excessive. Yet

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TBA.Lconcededy thatith; Qa -philosophy was one of. "high conservatism. highlighted by '

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-. Yankee's? layered -OA - oversight; approach," ~ (Page - V 112 of--Reference 12) Their overall r

.(conclusion'6n Quality Assurance was -that Seabrookjwas a quality built plant, j

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... t YAEC 100% Review T VII,

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.Asi discussed:'above, YAEC 'survelliance programs' identified shortcomings.in tL: P.H

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e techniques employed in performingiradiography, film tadim.:

hic ' process relathe to s

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7procesc.ag, and radiograph interpretation early in the pipi'ng' Installation process. The YAEC ~

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.OA surveill'ance and audit process originally only required and contemplated a sample review

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.of 3ocumentatlorn arui radiographs.

Because of the -small' population' of radiographs and

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- associa$didocurnensation being provided -to them 'by P.H during late 1979 and early 1980,1

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i (100%fsampilng' was easily attainable and considered to be prudent during the initial stages.

-i

' YAEC. OA,ltherefore, reviewed every film package (radiographs and documentation). as it.

j

.t was delivered. This early review, however, identified shortcomings in the P.H radiograph e

'rirocees promptirig_YAEC'OA:to continue to review each and every film package through the.

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11980f and 1981 time-frame., Although corrective actions to improve the welding qualhy and iraillographic process 'were implemented and produced - some L positive results during this--

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(pe'r'od,;YAEC ' decided to maintain its 100% review policy.

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iThe 100% reviewLcontinued as a prudent practice without a written procedure unti!E1984

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/wlien af ormaUwritten procedure (Pr'ocedure' 5, NDE Review Group) was instituted, Thist f

1

YABC rirocciture'lrequlied P)H's) submittal of all

radiographic.filmipackages to YAEC for-j o

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1

>cxaniination _pflor td :transmitial t'o' th = records vault -

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!t lIniltsireview of thetradlographic' film, the strict tolerances and guidelines contained in the;=

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l.UEl&EC; design ~ specification $ continued to1be' interi,reted Land henforced -In in :sometimes.

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! contested (butEconsistently c'onservative ma'aner by YAEC OA) ;Some ofIthese conservative:

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demands we're considered to'bc excessive requirements'by P.H and were the source of much yj y

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' discussion,= particularly;after restartLof the project-in 1984, as P H. struggled to maintain thet d

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. newly committed-completion schedule..~One require:nent considered potentially excessive by -

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P H and New linmpshire Yankee managsment was.the 100 percent Level III film review-by Jboth-P H-and YAEC...T'he new project management team considered a recommendation that' s

P illonly review a. percentage of the film. That recommendation was rejected (Refeimcc

-13)'-

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Early in 1985,' an' additional effort was initiated by YAEC which entailed a re inventory of D

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' allLradlographic film 1 packages In' the. records vault, its-purpose was to provide additional a

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assurance hat = all welds requiring < radiography had in fact been reviewed by YAEC including l

ithelradiographic film packages submitted prior to the 1984L establishment of a formal

, procedure.E This inventory practice continued until all radiographic packages.wcre filed as L

iinali acceptableLO A ' records..Its completion is documented in a memorandum from the-.

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YABC 'Assisiant GA Manager to the' OA Manager (Reference 14).

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Objective evidence lthat LYAEC Ot\\ personnel did 'in fact review all film packages, over and 4

, (above therP H"and ' Code-inspector review; includes-the ~ signatures 1and/or initials of the

.p i

.pYAEC reviewers on =the -Radiographic Inspection Reports indicating concurrence of film 3 package acceptability E(documentation and' film).

The YAEC reviewers also signed or l

m cinitialedMe outside envelope of each film package. This evidence of review is stored as at

~

i ifirial OA record in' the SM sok records vault.

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Other significant. objective evidence, that attests to the fact that YAEC was performing a

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7 100% review of-radiographic film before the establishment of the formal procedure in 1984, his in the form 'of a memorandum from the 'P H Level Ill examiner (Enclosure 17) who i

~

_ preceded Mr Wampler. That May,1983 document, which deals with an investigation of an-NCR, cites the YAEC film review as a standard part of the radiography program and has,

~ as an attachment, a: handwritten flow chart of the entire process, inclurng the YAEC review.

l

.It is also of interest to-note that in sworn testimony during the Department of Labe-proceedings, Mr. Wampler himself appears to repeatedly demonstrate his' awareness of the

'incyltab'llity of the YAEC 100% ireview'of radiographic test film, Pertinent portions of that y

flestimo'ny are cited-in Enclosure 9.

An August 1984 report of an NRC Construction Appraisal Team inspectlen (cover sheet.nd relevantipage provided as. Enclosure 19). that occurred in _ April and May of that year c co'ntains a statement.that warrants explanation.. It sald'that "... the applicant's program does not provide 'for a, review of radiographs;by the applicant's NDE organitation prior to their

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. storage in thc vault _..." This statement was generated by the fact _that when construction of 2

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iSeabicok was_:-temporarily halted in April,1984, both reviewed and unreviewed radiographic l

p

. file wern stored separately in the records vault for safekeeping pending the project's restart.

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The CAT inspectors therefore found the YAEC backlog, i.e. film reviewed by P H but-not g-p (yetlby; YAEC, in the vault-and apparently understood that ta mean that there was not a

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14 A

program _for YAEC review of all film.

As discussed above, there was, in fact, such a d

program in existence.

The -NRC ' has already provided a succinct discussion of their awarenes; of the YAEC '100% review which is included in Attachment 2 -of Chairman Carr's Decembe-19, 1990 response to a Congressional inquiry. (Cover sheet and Attachment 2 provided a Enclosure 20) 0 Vill Conclusion The issue of the quality and rejection rates of P H radiographed welds can be summarized as folltws. PSNH, YAEC, UE & C and the NRC all had concerns about the rejection rates Land these concerns were identified before P H had done any substantial amount of ASME Code work, important acti were taken early to improve (be situation, including the extensively proactive measures taken in onsite end-offsite welder training. These actions were ultimately effective and by the end of the proj ect, even when subjected to the conservative acceptance standards insisted upon by YAEC, the overall rejection rates were well within the industry norms'for a project such as Seabrook. Because of licen:ee and NRC early identification of these potential problems, YAEC began and continued a policy

.of reviewLg all P H radiographic film.

This step was consistent with the licensee's

~ conservative, defense in depth philosophy of quality assurance, a quality that was consistently c

' by the NRC and other entities who bad cause to review the project. It is interesting to note that 15

'even the criticism leveled at the~ project by TBA_ endorsed-this v'ew. They charged that-the -

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%j muliiple layers of quality-assurance were excessive and rat cost effective but echoed the 4

NRC in their conc'lusion that Seabrook was a quality built plant.

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&g REFERENCES

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$4 1,

2 Letter dated November 6,1990; Nuclear Reguistory Commission (Leo J. _ Norton) to -

~

hew Hampshire,Yankeey(Ted'Peigenbaum) c.

y Se'abrookf1 and:2 Preliminary Safety Analysis Report, Section 17,1

2c 1

L3;'

> Letter dated June 20,1980;" Public Service Company.of New. Hampshire (J. H. Herrin) q Jto1 United Engineers & Constructors loc, -(J. F. Vought)'

1 4

Letter dated July:8,1990; United Engit eers 'and' Constructors Inc. (J. F. Vought):to

~

zPublic Service Company-of New Hampshire (J. :H.LHerrin)

'5; NRC ? letter to PSNH dated December 28, 1982;

Subject:

= Systematic _ Assessment of

~

J f,.

' Licensee Performance:

E

~

Ed

'NRC!!etteth to 'PSNH ! dated August '17,- ~1893,

Subject:

Systematic Assessment 1of Licensee Performance =

07?

- NRC letter t.o.PSNH-dated May 1771984;

Subject:

Systematic Assessment of Licensee -

Performance (SALP):and Public_ Service Companyfof New Hampshire Response dated--

April-25bisa4 a

38, 1NRC letter to PSNH dated May 28, 1985;

Subject:

Systematic A"e '. ment of Licensee j

f],

Performance (SALP) y 4

E9" CMemoiandum dated August l1,' 1983; ;R.: A. Kountz' (UE_:& LC)' to W J.: Taylor (UE.

i&L C),L

Subject:

iSeabreek Station -Units:1'and12 Radiographic Reject Rates

-a N

10;.

! Seabrook! Project Management. Prudence 9 Audit _(PLO.0447)Jby Pickard, Lowe -and LGarrick, Incydated Julyi1986.

4 2

-i.'.,,,, /,

- ; 11',

istudho,f the SeabrookcProject, Conducted:by Chat! cage Consultants, Inc., November 11986-i

1. N ' lRetrospectiselAudit of thejSeabrook Nuclear Project.For The State of Connecticut M

-Departmentsof Publicl Utility 1 Control,lSeptember 1987 a

1 L13l

" Memorandum dat'ed Decemberd0,- 1984;-GJRJOram to Distribution;

Subject:

~

7 P.H -

8 tand!QA Construction ~ Procedures J(see Item 41).

[14 i Memorandum dated June; 27,-1985; y

Unacceptable. Radiography. Status

. R. P ~ Orippardi ;to,G. F. McDonaldj -Stibject:

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TAB',E 1 j

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' PULLM AN HIOGINS R ADIOGR Al', HIC TESTING REJECT R ATES x,

=

= MONTHLY 'R ATES AND YEARLY RECAPS 1979 NEW WELDS.

R EPAIRS -

TOTALS 18/

i

- 7 =~ 38.9%

$/

1' = 20.0%

-23/ 8 = 34.8%

-.L.@-

010180 to 013180 15/ 6 = 40.0%

5/ 3 = 60.0%

20/ 9 = 45.0%

-02 01 80 'o 02 28 80?

11/ 2 = 18.2% '

2/

50.0 %

13/ 3 = 23.1%

0340180 to 03 3180 13/ - 9 = -69.2%

6/ 3 = 50.0%

19/ 12 - 63.2 %

04 0180 to 04 30 80 17/ 2 = 11.8%

2/

2=

100 %

19/ 4 = 21.1%

05 0180 to 05 3180 '

14/ 10 71,4 %

6/ 3 = - 50.0%

20/ 13 = 65;0%

06 0180 to'06 30 00'

'8/! 1= 12.5% -

13/ 5 = 38.5%

- 21/ - 6 a 28.6 % -

07 0180 to-07 3180' h % = 30.0%

10/ 3 = 30.0%

30/ 9 = 30.0%

08 0180 to 08 3180 -

23/

1=

4.3%

1/

0=.

0%

24/ I = 4.2%

-(^\\ :

's)09 0180.to 09 30 80 15/- 6 = :40.0 %

6/ 2 = 33.3%

21/ 8 = 38.1 % -

I

'_l0 0180 to 10i3180 n/ _ 4 = 20.0%

11/ 2 = ' 18.2%

'31/ 6 = 19.4%.

,110180-to 1130 80 25/ 9 = 36.0%

8/ 5 -- = = 62.5 %

33/ 14 =. 42,4%

12 0180 to-12 3180 12/. 3 = = 25.0% -

3/ 2: = 66.7%

15/ 5 = L 33.3%

.1980 : RECAP 193/ ',9 = 30.6%

73/ 31 = 42.5% '

. 266/. 90 = 33.8%

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TABLE 1

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PUllM AN HIGGINS R ADIOGR APHIC TESTING REJECT R ATES MONTHLY R ATE AND YEARLY RECAPS

' jf.Ej.

NEW WELDS REPATRS TOTALS t

010181 to 013181 32/ 7 - 21.9 %

1/

0-=

0.0%

33/ 7 = 21.2%

.02 0181 to 02 28 81 22/ 11 = 50.0%

3/ - 1 = 33.3%

25/ 12 = 48.0%

> 03 0181-to 03 3181 45/ 15 = 33.3%

1/ 3 = 27.3%

56/ 18 - 32.1 %

04 0181:to 04 30 81

'69/-11 = 15.9 %

16/ 6 = 37.5%

85/ 17 - 20.0 %

' 05 0181 to 05 3181 34/

3=

8.8 %

22/ 5 - 22.7 %

56/ 8 - 14.3 %

' 06 0181 to 06 30 ~81

-17/

1=

5.9%

10/ 4 = 40.0%

27/ 5 = 18.5%

07 0181 to 07 2181 48/ 9 = 18.8%

13/ 2 = 15.4%

61/ 11 - 18.0 %

- 08 0141 to 08 3181 -

63/ 12 - 19.0 %

20/ 3 = 15.0%

83/ 15 = 18.1%

09 0181;to 09 30 81 58/ 13 = 22.4%

16/ 4 = 25.0%

74/ 17 = 23.0%

(

)'10 0181 to._10 3181 74/ 23 = 31.1%

22/ 7 = 31.9%

96/ 30 = 31.3%

%.J

!110181 to'1130 81 56/ 14 = 25.0%

12/

1=

8.3%

68/ 15 --22.1 %

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- 12 181 jo 12 3181 68/ 27 = 39.7%

7/ 3 - 42.9 %

75/ 30 = ~ 40.0%

1981 ' RECAP 586/146 = 24.9%-

153/ 39 = 25.5%

- 739/185 = 25.0%

=1982 NEW WELDS _

REPAIRS TOTALS 010182 to 01' 3182 62/ 25 = 40.3%

19/ 6 = 31.6%

81/ 31 = 38.3%

02 0182-t'o- 02 28 82 84/ 21 = 25.0%

18/ 12 = 66.7%

102/ 33 - 52.4 %

03 0182 ~ to103;3182 78/ 17 =' 21.8%

23/ 7 = 30.4%.

'101/ 24 - 23.8 %

04 0182 to:04 30 82 125/ 27 = 21.: %

18/ 7 = 38.9%

143/ 34 = 23.8%

1 05 0182 'to.05 3182--

till 42 - 37.8% -

35/ - 9 = 25.7%

146/ 51 - 34.9 %

. 06 0182 to' 06 30 82

145/ 37 =. 25.5%

52/ 22 = 42.3%

197/ 59 = 29.9'b

'07 0182 to 07 3182 145/ 33 22.8 %

.56/ 22 = 39.3%

201/ $5 - 27.49; 7N 03 0182 to 08 24 82 107/ 30 = 28.0%

38/ 16 = 42.1%

145/ 46 = 31.8%

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PULLM AN HIGGINS R ADIOGR APHIC TESTING' REJECT R ATES -

= ;

MONTHLY RATES AND YEARLY-RECAPS -

y

{

NEW WELDS -

REPAIRS TOTA LS

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d E l08 25 82.tu 09 25 82 170/. 65 < = 38.2%

50/c15 = 30.0%

220/'80 - 36.4 %.

~

w g~, [ 09l26'.82 to110 26 82:

108/ '32 = 29.6%~

61/ 17 = :' 27.9% -

169/ 49 - 29.0 % -

i (10 27 82:tollb27 82:-

131/ 28 J=

21.4 %

55/ -19 = 34.5%

186/ 47 - 25.3 %

a

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_,4c11i28 82 to'12223 82--

=

125/ 8 - 32.0 %

28/ 12

• 42.9 %

53/ 20 = 37.7%

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[:1982 RECAP- ~

1291/365 = i 28.3 %

453/164 - 36.2 %

1744/529 = "30.3% -

a I:

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--12 28183Sto 013b831 (110/ 18 = 16.4% J 98i 24 =' 24.5%

- 208/- 42 = 20.2%

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4 02 0183 sto. 02e28483 -

97/ 20. = 20.6%

26/ - 7. - 27.0%

123/;27-_

22.0 %

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^J l03 0183 'to!03;3183s 99/ 21 i = -21.2%

23/ 13.0% -

122/c24 = Ji9.7%f 4

ci (d4 0183Lto:04 30.83:

167/ ' 4 = 6.0%-

34/ 10 =129.4%

.101/- 14 = -13.9%L

.72/ 141 = 19.4% x 210/ 35 = :-16.7%

'~

105 01s83' to!05 3183 L

=138/?21. = 15.2%

e 0,

,106 0183 -to106a30_83)

- 111/? 15 i = c 13.5%

27/ -31 = - 11.1%

138/ _18 = 13.0%;

a w<

h W07 01.'83ftoi07 3183; 116/16 = i5.2%

12/. L 2 =,16.7%,

128/? 8.L = 6.3%

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Wl LO8:0183 Lt'_o;08 31;83;,'

129/; 20 E-115.5% :

6/1: 1C = n16.7% -

"135/ 21L = 115 A%

w i

E (09 01183 to '09 30 83..

79/ 11 : = E13.9W 8/ 12 = :25.0%.

L 87/ 131= E14.9%.

}

2 kl0!did11t'oE10 31283 148/e16 : = -10.8% -

l22/ 2 -- 9.0 %

170/ 18 l = 10.6%l

.}

l'

' T:1101Mtoill 30 83 x

! 120/ 18 '=115.0%

19/- 4 = - 21.1%

139/.22 = 15.8%

112 01f 83ito.12 3183 86/19 ~ '=' 10.5%

23/ ^ 3 = = 13.0% -

109/:12. - :11.0 %

il

-I g{,,, ;j1983 RECAP -

1300/179 = 113.8%

370/ L75_ = - 20.2% -

1670/254L= 15.1%;

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