ML20070T372

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Forwards Response to Info Requested in NRC Re Weld Radiographs
ML20070T372
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 02/26/1991
From: Feigenbaum T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20070P788 List:
References
NYN-91029, NUDOCS 9104040132
Download: ML20070T372 (7)
v • d • e


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03r27/3996 80132 PMt REG.LATORY SEWlCES 1 603 474 9588 0083 P.B2 ATTACHMENT 7 New Hampshire Teel C. Felg eoben Yankee ~. -

CWet tish ob NYN. 91029 February 26,1991 Mr. Thomas T. Martin Reglonal Adminlitrator Unlied States Nuclear Regulatory Commission Region 1 473 Allendelt Road Klag of Prussia, PA 19406 Referteces: (a) Facility Operettag IJcense No. NPP.86, Docket No. $0 443 (b) USNRC Reglos ! Letter dated February it. 1991, ' Request for Information on Radiogtspb Records' C. W. Hehl I- T. C, I cigtnbaum (c) NitY Lettet NYN 91023, dated Tsbrusty 8.1991 ' Additional NHY Responst to 010 Rcquest for Information*, T. C. Telgenbaum to L. J.

Nortos

$ubject: Respopst to Requtst for Information Centlement Ecelosed please find New Hampitlec Yankees' response to the information requested in USNRC letter dated Tebruary 22,1991 (Referents (b)),

Should you have any questions negerdlag this mattet pleast contact Mr. Nsal A.

Pillsbury, Dltector of Quellty Programs at (603) 474 9321, extsaston 33A i

Very tt y yours, 69 A. */ c ^5W C

Ted , Folgem TCF:ALL/ tad Nea Hampshire Yonkee DMston of P#ic Service Cornpony of New Hompshire P O. box 300

  • 5eobrook, NH 03574
  • Tetephone (603) 474 9521 9104040132 910322 PDR COMMS NRCC CORRESPONDENCE PDR

C2/37/1991 80133 t+ff MOULATORY SEWlCES 1 603 G74 9533 4483 P.03 United States Nuclear Regulatory Consission Pobruary 26, 1991 Attentlos: Mr. Thomas T. Martin Pass two l

cc: Document Conttel Desk United Stats: Nuclear Regulatos) Commission Washington, DC 20$$$

Mr. Oordon E. Edison, St. Project Manager Project Dlitetorate 13 Dittslen cf Reactor Projtelt U.S. Nuclear Regulatory Commission Washington, DC 20$$3 Mr Charles W. Hthl, Director Divisloc of Resetor Projects U. S. Nuclear Regulatory Ccmmisaloa, Reglos !

47f Allendale Road Kleg of Prussla, PA 19406 Mr. Hos! Dudley NRC Scalor Roaldent Isspector P.O.-Bc 1149 Scabrook, NH 03874 1

1 1 .

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02,27/1991 10833 tNY Rf314TDRf SEMCES 1 (43 674 9531 c413 P,04 4

$Y $0kh I h- $$kl$

Febretty 16.19h ENCLOSURE 1 TO NYN 91079

.m _ . _ _ . - _ _ _ _ _ _ _ __ __ _ . _ . _ _ _ . _ _ _ _ - _ _ - . _ _ _ _ _ _ _ - _ _ _

82/2W1991 10:33 tHf RE0J.A70RY SEINICEg i EC3 474 9521 d413 P.05 i

, Renest Ngul

. Tbt outr.ber of Pullman.Higgles wcld radlegraphs retrieved from the flies tecidset to post-construction follow.up on neld adequacy questices, and the number of Pelless.Higgles weld tsdlographs wbleb were mot rettlesable during tble effort.

A11Ms11 A. There have beco 1174 occasions whers P.H weld redlugraphlt film pechages bass been rettlend from the N}IY storage vault lecident to post. construction follow.sp on wcld adequacy questions. Slocs certeln pattests weic estrieved on multiple occaslots, it has ocesi determloed that at 15:st 920 separate and distir.ct radiographic packages heve been tetrieved and subsequcelly serlfled as a result of this effort.

These numbers were determloed as follows:

NUREO 1425 (locludes Wampler log). 276 Correctise actions perfctmed as described la NHY CAR 91001. 137 .

Congresslocal lequiries (estlmsted to be 300) requestleg Weld Process sheets and Radiographic f aspe ctiert Reports through the NRC.

76 ($ss Note 1)

Addllleeslly, NHY bas orbitrarlly selected, from P.H ' Records Receivlog Check Lists',

a somber of weld receeds for tbs yests 1981 through 1984. These were the years of most laterest to the congressional loquiries as these years

  • sts prior to YAEC formally specifying their 100%

!!!m review in a written procedurs. As of 2/22/91.

Ibc weld redlographs for these pipe welds were verifled to os lo the NHY records vault with proper evidence of YAEC review. .1Q1 ,

Total 1174 (Su Note 2)

Note: 1.

Tbc sombar 300 wu not used in tbla calculation because - set all documceted congres letal Inquirles are avstlable to NHY, and a number of thest requists were redundant. NHY bs!! aves that 76 c.caservatively understates abs actual number.

Note: 2. Tbc number of redlograph packego rettlesals (1174),laclude many duplicate resitws of the umc prekages. NHY bas further cross checked the weld numbers locluded la tbli set of 1174 and has determined that there are at least 920 separate -

and distinct sadlographic potkages within tbls population of 1174 racilographic film set verifications.

5. One (1) la the n'urober of Pullman.Higgins Tleic! weld radiograph sets not found to t' be retricssble during these efforts. P.H redlegraphs for P.H weld number CS 328 02.P0204 were not located during the document research phase of an on.golag l congresalocal lequiry. NHY wrots CAR 91001 to document and resolve this occurrence. CAR 91001 was enclosed In Rsistsace (c).

1

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02/27/1991 10:34 tN t' RE3.LATORY !4WICES 1 603 474 9531 d413 P.06 C. Also not leeluded in these numbers sie entensive NRC ladependernt vertflentloa Inspections soeb att Construction Appeelsel Team Report (CAT) 32 00 *bleb rey!ewed

. 29 F H s5lds, CAT 34 07 wkleh railswed 180 P.H welds, and VAN g$.19 which revlewsd 79 Pell wclds.

The abovs sad meriy othcr NRC laspeettons were cet ' post. construction' rettissels and therefore were not lacluded la out tabulation.

LtMLst No -_2-The numbet of Pullmon.Higgins weld redlographs which should be on file.

P e teenne The total number of radiograph sets whleh should be un fils la the number of NHY records la the vault (4177), plus the ces missing radiogespb sat for C 32102 F0204, plus any additional redlegraph sets wbleb should be to the file but an not. NHY believen that the number of radlegraph sets In this latter category is sero bassd on the gestric implications tsview discussed in the rssponsa to Rogusst No. 3 below.

It is believed that the number of radicaraph sets abould be 4178 to order to acct the oppilcible A5ME Code and P.H contractual commitments for Seabrook Station. Thle number cac also be derived from the Icforttation which was ptrylosely provided to tbc NRC and then subsequently summtilted in tbc table on page 14 2 to the NRC's NUREG 1425

(*Weldleg and Noodestructive Examinatico issues at $ctbrook Nuclear Station').

An empirit ,1 verificetion of thl number would requits a retlew of all as bullt Isometric drawings si record. NHY believes that this type of verification would be both time consumit g sod sanecessary based on the results of the extecalve ladependent verifications conducts J to date.

Atnut M The technical ba:Is for your conclusion that the missing radiograph for Fictd Weld C3 328 02 F020416 en laulated occurreccc with no discatanble generic impliestions (reference your Isitor NYN 91023 to NRC (010) dated February 6,1991).

Reneense NHY la confidtet that the slagle known instance of a missing radiograph set, fut C$.325

' 02 P0204, is an isolated occurrence with no discernable seastic implications based on the generle Irnplicatloon review described la CAR 91001 [caclosed in Reference (c)] and the telque circumstances favolved with this one redtograph set.

. As part of the CAR 91001 generic Impilc4tions review, NRY checked radlographs for an additler.sl 157 piptog wolds. These welds wert selected for revlow because they eahibited ecoditlocs potentially similar to C5 328 02.F0204, i.e., NCRs wars written and/or repalt was needed. The selectica of these welds was based on a scarch of computer data base NCR 2

03 47/1991 80:34 t+ft REO.A.ATORY SEGVICEQ 1 6C3 474 952a G483 P.07 information and a rav!aw of th6 P.H Weld Repair Order (WRC) log (a non.QA plannlag and scheduling control dottment), In partlsular, thest welds were selected !! tbty had NCRs with 3 or most repatra noted la the comptier data base or the P.H WRO log Identified these welds as having 3 or more satries or 3 or more repalf cycles.

For cach of these 1$7 lastances NHY vertfled that a radlograph set was available la the NHY vault and that the set had been rerlowed by YAEC.

NHY believes that tbc circurnstauces involved le the processing of the radiograph for CE.

328 02.F0204 have no discerneble generic implications based on the following:

1. The Wtld F0204 was incorree.tly marked as F0209 cm the piplag Isometric drawing after F0204 was tsdiographed.
2. F0204 was incorrectly deleted fiorn the pfples Isomett!c subsequent to the radiographic examlestion belas pertoimed and accepted (as F0204). As e result, a F.H examloer might have determined that the radiograph was ao longer needed and that there ws: to ased to ased tha radiograph to YAEC foi review and subsequent littelion In the records Vault.
3. F0204 was re established en the piples isomettlo appionlmatel) 2 years after the nedlegraphic examination for F0204 was perfo med. In particular, the piping Isoroctric drawing was revised to delete F0209 and re establish P0204 probably in response to N.5 data report picparation. At that time, a review of the weld history package would have ludicated that the ws!d jolet was cornpleted and accepted because a P.

H Radiographic lespection Report (RIR) was available in the package. Thus, documentatico to prove that the redlegraphic examlantion was performed was available then as it is now.

The inferrestion provided above describss a unique act of citetustances. As a result of this inforrostico, NHY considsta this occurrence to be an isolated one with no discernable generic Implications.

3 TOT?t. P,07

, je neg~

ATTACHMENT 8 2

[M e 4 U NIT 8 0 6fAft4 D NUCLEAR MEQULATORY CCMMISSN>N MtoloN 1

          • , 08 ALLaNDAL ROAD KINO oF Phy0BIA. PaNN8YLVANIA 1HM Docket: 50-443 GAR 0 5 981 Public Service Company of New Hampshirs ATTN: Mr. Ted C Felgenbaum President and Chief Executive Officer New Hampshire Yankee (NHY) Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject:

Request for AdditionalInformation on Welds Based on NRC redew of your February 26,1991 response (NYN 91029) to our February 2; 99. request for information, we request that New Hampshire Yankee (NHY) 4 provide, by March 11,1991, the following additional written information on weld radiographs, o The basis for NHY confidence that required radiographs were made for (Pullman-Higgins) field welds, with satisfactory results and radiograph retention as required.

  • Clarincation of the number of(Pullman Higgins) radiographs audited / examined incident to responses to post construction inquiries concerning weld adequacy.

The basis for this request is the NYN 91029 assertion that e 6me consuming review of all as-built Isometric drawings of record would be required to verify the Pullman Higgins radiographs which should be on file. That raises a question of whether NHY (and their agents Pullman Higgins, the authorized nuclear inspector, and Yankee Atomic Electric Company) ever determined that all required radiographs were made, found acceptable during constmetion, and were present in the vault. Clarification of the numbers of radiographs retrieved in response to post construction questions is being requested because it is still not j clear to us which sample sets retrieved involved re examination of the same radlography.

Thank you for your attention to this matter.

' Slocerely,

\m4I.% h (/

9 les W. Hehl, Director Divisico of Reactor Projects 1 . - .

.geann

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