ML20073R001
| ML20073R001 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/30/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NYN-91088, NUDOCS 9106040237 | |
| Download: ML20073R001 (10) | |
Text
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,e New Hampshire el Ted C. Feigenbovm hh hu. dent end Ch<el becutive Olbter NYN 91088 hiay 29,1991 United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Attention:
hit. Thomas T. hiartin, Regional Admini.trator
References:
(a)
Facility Operating License No. NPF 86, Do:Le. No. 50 443.
(b)
Transcribed Pablic hiceting lictween New Harupshire Yankee and the NRC conducted on April 10, 1991.
(e)
N!!Y Letter NYN 91076 dated hiay 13, 1991, ' Transmittal of the Frogram Description for the Reverification of Pullman liiggins Field Weld Records *, T. C. Feigenbaum to T. T. hiartin.
S ubje ct:
hiay 1991 Status Report for the Program for the Reverification of Pullman-liiggins Field Weld Records Gentlemen:
In the April 10,1991 Public hiceting between New Hampshire Yankee (NilY) and the NRC [ Reference (b)], and as provided in the NilY Program Description for the Reverification of Pullman liiggins Field Weld Records, transmitted to the NRC on hiay 13,1991 [ Reference (c)], NilY agreed to preside the NRC with a monthly written report of the progress of the Reverification of Pullman-liiggins Field Weld Records Program.
Accordingly, enclosed please find the status report foi the month of hiay 1991.
Should you have any questions regarding this matter, please contact hir. Neal A.
Pillsbury, Director of Quality Programs at (603) 474 9521, extension 334?
Very truly yours,
- hff, wb~
'l ea C.1-eigenbaum TCF:J ES!!es Enclosure 9106040237 9 ) (N O i
PDR ctDOO: 05000443 p
PDR New Hornpshire Yonkee Division of Public Service Company of Nw Hampshire
-A 0
078 e.o. Box 300. seabrcet, ns 0387d 1eiephone 1603) 474 932i Il t
- -United States Nuclear Regulatory Commission May 30,1991 Attention:
Mr. Thomas T. Martin Page two ec:
Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ebc C. McCabe, Chief Reactor Projects Section U S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Kenneth E. Brockman Office of the Executive Director for Operations U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Mr. Noel Dudley NRC Senior Resident lospector P.O. Box 1149 Seabrook, Nll 03S74 Mr. Phil Joukoff United States Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Mr. Frank Forgione, Special Agent Office of the laspector General United States Nuclear Regulatory Commission MNBB 6715 Washington, DC 20555 4
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iiMDocumEnt Control Desk'; lj United States Nuclear Regulatory Commission Washington, DC 20555
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.9 New llatnpshire Yankee-May 30 -1991 ENCLOSURE 1 to NYN-910$f8 M AY 1991 STATUS REPORT FOR THE REVERIFICATION OF PULLM AN-HIGGINS FIELD WELD RECORDS
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bl AY 1991 STATUS RE'. ORT FOR THE NEW ll AMPSHIRE YANKEE PROGR AM FOft THFt REVERIFICATION OF PULLMAN lilGGINS FIELD WEl.D RECORDS A.
INTRODUCTION The following provides the status of the New llampshire Yankee Reverificatica of Pullman Higgins Field Weld Records Program as of May 29, 1991._ This program is being implemented in accordance with the program description submitted to the NRC on N ay 13 1991,.This status report presents the program's progress and performance, weld record anomalies identified as a result of this program, and corrective actions implemented to address these anomalies.
B.
PROGRESS B.1 Weld Tabulation On April 22, 1991, Nuclear Energy Servicts (NES) personnel starter' the Task 1 weld tabulation' effort.
This effort is designed to provide a list of field welds requiring
. radiography in order to meet cod.
As provided in the program description, the. basis for
- this ist is engineering design documentation (drawings and-change documents) and the N.
5 Code Data Reports. As of May 29, 1991, DES has processed a total of 608 of the 3100 (approximately 20 percent) document packages for this effort.
The progress for each.
eategory of field weld which requires radiography by code is presented below.
1 To ensure the task's scheduled completion date of June 28, 1991, NES supplemented the project staff wi;h an additional engineer. This NES engineer began working on the weld tabulation portion of tie project on May 21,1991. His qualifications are commensurate with those af the other NES personnel working on this project in-the same capacity.
l B.1.a ASME Section til Pinine As of May 29, 1991, NES bas processed 60S document packages for ASME Section ill piping. This encompasses a I rge part of both the Charging System (CS) [or Chemical and Volume Control System (CVJS)), and the Reactor Coolant System (RC). The following provides the number of isometric drawings reviewed for these two systems t date.
System Isometrics Reviewed CS 444 RC 164 608 1
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w B.1.N ASME Section til Surnorts As of May 29, 1991, none of the ASME Section til Support document packages have been reviewed.
B.I.e - ANSI-D31.1 Pinine As of May 29, 1991, none of the ANSI B31.1 Piping document packages have been -
reviewed.
B.1.d ASME Section Vill Unfired Pressure ' Vessels As of May 29,-1991, none of the - ASME Section Vill Unfired Pressure -Vessel
- document packages have been reviewed.
During the weld _ tabulation effort described above, a total of five Requests for Engineering Services (RES) were generated. As described in the program description, an RES is the mechanism for identifying and responding to potential anomalies generated as part of the weld -tabulation effort. Examples of the issues identified in these RESs include:
type of weld not identified on the isometric drawings; questions regarding the do ign change documents posted in the Change Document Tracking system; and references to v :Id process sheets for Non Destructive Examination requirements. N11Y has responded to ill of these RESs and has determined _ that they do not contain anomalies which are report able to the NRC pursuant to the pt gram description. NHY is correcting any minor administrative discrepancies identified in these RESs.
B.2
, Radiocraph Packace Inventerv On April 29, 1991, NES-personnel began the Task 2 Radiograph Package Inventory.
This task is designed - to provide a list of field welds for which radiograph films and Radiograph inspection Reports (RlRs) are retained in the site records vault. This task also records the signature of the individuals and organization reviewing the radiographic film.
As of May "c9,1991, NES has reviewed RIRs and radiograph fil.n for 1676 welds.
This encompasses the CS, RC, and Residuai Heat Removal (RHR) systems, and a portion
-of the Safety injection (SI) system, and repre_sents_approximately 40 percent of the RlRs to be reviewed. NHY is on schedule to complete this task by June 28, 1991. The following provides the number of Radiograph inspection Reports (RIR) reviewed for these systems to date.
System Number of RIRs Reviewed CS-718 RC 336 RHR 334 S1 2ESS 1676 2
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During the radiograph review process described above, a total of fifteen Corrective Action Requests (CAR) were generated. - As described in the program description, the CAR j
.is the mechanism for identifying and responding to potential weld record anomalies generated j
as part of the radiograph review effort. The weld record anomalies identified to date all pertain to administrative deficiencies. None of these deficiencies affect the physical quality
-of the we ds. NHY has completed the initial investigative action for the fifteen CAR's and l
concluded that thirteen of the fifteen do not contain anomal:es which are reportable to the NRC pursuant to the program description. The following examples typify the nature of these minor administrative deficiencies:
legibility of radiographic film data; minor adtpinistrative data mismatches between RIRs and radiographic film ( e.g.,
numbers transposed); and questions regarding radiographic technique.
NHY is correcting minor administrative-discrepancies identified by these tiirteen CARS and annotating the radiographic film package with a reference to the respective CAR. Sectica C.1 of this report summarizes the two CARS which resulted in reports to the N'tC.
B.3 Field Weld List and Radiocranh Comparison The comparison of the list of field welds requiring radiography (Task I output) with the list of field welds for which radiographic records exist (Task 2 output) will provide a single list whict. indicates that radiographic records are retained for field welds which require radiography by code.
As of May 29, 1991, NES has performed this comparison for 372 of the 480 document packages for the CS system. This comparison indicated that for one field weld,1 CS 328 02 F0204, the requisite radiographic film was unavailaHe, This is the same weld which was identified before this program was implemented. NHY provided a report regarding this documentation deficiency to the NRC in a letter dated February 8,1991 (NYN 91023). This comparison did not identify any additional documentation deficiencies which were reportable i
to the NRC. NHY is on schedule to complete this task-by July 5,1991.
C.
PERFORM ANCE MEASUREMENT AND REPORTING C.1=
Reports to the NRC
]
As of May 29, 1991, NHY has determined that two weld documentation anomalies were reportable pursuant to the Program Description for the Reverification of Pullman-Higgins Field Weld Records. These anomalies pertain to a lack of administrative information on some of the radiographic film for field welds 1 CS-318 02-F0202 and 1-RC 13 02 F0203.
In accordance with the reporting requirements delineated in the program description, telephone' notifications regarding these anomalies were made to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the determination that they were reportable. Additionally,72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> written reports regarding these two anomalics were provided to the NRC on May 17,1991 (NYN 91080), and May 20, 1991 (NYN 91082), respectively. These written reports established that the identified weld record anomatics do 'nat compromise the integrity of these welds or other Seabrook Station welds. It was also established that these record deficiencies do not compromise the integrity-of the systems in which these welds are located, thus they do not produce any reduction in the protection provided for the health and safety of the public. The following provides a summary description of these records anomatics, cause of the deficiencies, and corrective actions implemented.
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Description of Anomalies -
Pullman Hiuins Field Weld 1-CS.318 02-F0202 As stated in NHY letter NYN 91480, dated May 17, 1991, Pullman liiggins field weld 1 CS 318 02 F0202 is a circumferential butt weld on a three inch diameter section of piping in the Chemical and Volume Control System (CVCS)
This section of the CVCS system is ASME 111,- Class 2, and Safety Class 2.
This weld connects a _ valve (V 325) to the piping and-is also adjacent to a reducer. This weld is located in the letdown leg of the CVCS system downstream of both the Regenerative (Tag number E 2) and Letdown (Tag number E 4) Heat Exchangers. This weld is physically located in the Primary Auxiliary fluilding
- which is outside the Containment Building. (Reference NIIY P&lD 1-CS-D20722). This field weld was radiographed in 1981 in accordance with the Non Destructive Examination (NDE) tequirements contained in the 1977 Edition of ASME Section III up through and including the Winter 1977 Addenda (the code applicable to Seabrook Station).
The weld records package for weld 1-CS 318 02 F0202 contains a Radiograph inspection Report (RIR) and the radiographic film. The RIR indicates that the radiograph views for all stations of this weld are of acceptable quality. The RIR also contains the approval signatures of the Level !! Pullman-liiggins reviewer, Authorized Nuclear inspector (ANI), and the Yankee Atomic Electric Company (YAEC) reviewer. Additionally, another Level 11 Pullman Higgins reviewer subsequently reviewed this RIR.
At the tirne this radiograph was reviewed, the ASME Code approval process included the Level 11 Pullman-(liggins reviewer and the ANI.
YAEC provided a review in order to satisfy Ouality Assurance Program requirements. Level !!! Pullman-Higgins review was added to the review process at a later point and therefore is not a requirement for this field weld.
As required by ASME V including paragraph T-236, NilY maintains the Radiograph inspection _ Report (RIR) and the radiographic film for this weld.
The RIR and the radiographic-film for two of this weld's three stations (stations 0 and 1), contain the code required information and approvals. As identified in NHY Corrective Action Request (CAR)91-005, the radiographic film for station 2 lacks-the identification of the exposure date, system /line/ isometric number, weld number, and manufacturer's identification.
The only i
information contained on this film is-the station number. Therefore, the film for station 2 does not meet the code requirements. This anomaly has now been corrected as stated below.
NHY Nuclear Quality Group personnel have verified that the radiographic film for
- station 2 is in fact that of weld F0202. Comparison of the film for station 2 with that of stations 0 and 1, indicates unique weld profile is present on all the film for three stations.
Specifically, at the time this radiograph was taken there was a spool identification-tag tack welded to the pipe near this location which is oriented in a position that provides a unique
' identifier common to all three stations. Additionally, this weld is located near a reducer which also can be identified on the film for all three stations.
This radiographic film comparison was performed by a NHY Level !! RT reviewer on May 9,1991. This conclusion was independently verified by a YAEC Level !!! reviewer on May 21,199L l
NHY Nuclear Ouality Group personnel have also verified that the film reviewed for weld F0202 is the only film available for this weld. Review of the weld process sheets indicates that only one repair was made to this weld before the weld was radiographed. This 4
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repair was on the root pass (first weld layer) of the weld. A visual examination of this pass detected a flaw which required a _ repair. No other repairs were made prior to or after radiographic examination. As_ a result of the above reviews, NHY has determined that the
. station 2 film is of Pullman Higgins field weld 1 CS 318 02 F0202.
Pullman Hiccins Field Weld 1 RC-13-02 F0203 As' stated in NHY letter NYN 91082, dated May 20, 1991, Pullman Higgins field weld 1-RC 13 02-F0203 is a circumferential butt weld on a twelve inch diameter section of piping in the Residual Heat Removal (RllR) system, This section of the RHR system is ASME 111, Class 2, and Safety Class 2.
This weld is located adja:ent to check valve CBS V 55 in line 1209-02, which is the RHR Pump 8A supply from the Refueling Water Storage Tank. This weld is-physically located in the RHR Vault Number 1, in the Primary Auxiliary Building which is outside _ the Containment Building. (Reference NHY P&lD 1 CBS D20233). This field weld was radiographed in 19S1 in accordance with the Non Destructive Examination (NDE) requirements contained in the 1977 Edition of ASME Section 111 up through and including the Winter 1977 Addenda (the code applicable to Seabrook Station).
The weld records package for weld 1 RC 13-02 F0203 contains a 'ladiograph inspection Report (RIR) and the radiographic film. The RIR indicates that the radiograph views for all stations of this weld are of acceptable quality. The RIR. also contains the approval signatures of the ' Level 11 Pullman Higgins reviewer, Authorized Nuclear Inspector (ANI), and the Yankee Atomic Electric Company (YAEC) reviewer.
At the time this radiograph was reviewed, the ASME Code approval process included the Level !! Pullman-Higgins reviewer and the ANI.
YAEC provided a review in order to satisfy Ouality Assurance Program requirements. Level 111 Pullman-Higgins review was added to the review process at a later point and therefore is not a requirement for this field weld.
As required by ASME'V, including paragraph T-236, NHY maintains the Radiograph inspection Report (RIR) and the radiographic film for this weld, The RIR and the radiographic film for one of this weld's four stations (station 3 0), contains the Code o
required information and approvals. As identified in NHY Corrective Action Request (CAR) 010, the radiographic film' for stations 01,1-2, and 2-3 lack the identification of the exposure date, system /line/ isometric number, weld _ number, and manufacturer's identification.
The only information contained on these films is the station number. Therefore,_the film for these three stations does not meet the code requirements. This anomaly has -now been corrected as stated below,-
NHY Nuclear Quali_ty Group personnel have verified that the radiographic film for stations 01,12, and 2 3, are in fact that of _ weld F0203.
The radiographic technique utilized.for this weld allowed a portion of the film for each station to overlap onto the adjacent stations' area of interest. Ccmparison-of the film for all four stations indicates that there are unique identifiers (e.g., unique weld profile; and code allowable inclusions) in the overlapping portions of each stations' film. Therefore, the film for all four stations are contiguous, and are of weld _1-RC 13-02 F0203.
This radiographic film comparison was performed by a NHY Level 11 RT reviewer on May 17, 1991.
This conclusion was independently verified by a YAEC Level ill reviewer on May '21,1991.
J NHY Nuclear Quality Group personnel have also verified that the film reviewed for weld F0203 is the only film available for this weld. Review of the weld process sheets 5
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l indi ates that no repairs were made to this weld before or after the weld was radiographed.
As a result of the above reviews, NHY has determined that the films for stations 0-1,12,.
.and 2 3 are of Pullman Higgins field weld 1-RC-13-02 F0203.
Cause of Deficiencies NHY has reviewed the records deficiencies for these two Pullman Higgins field welds and has determined their cause to be personnel error on the part of Pullman Higgins NDE personnel. The Pullman Higgins NDE personnel apparently neglected to place the required field weld identification tags on the radiographic films for the subject stations when the film was developed, Identification of radiographic film as required by code was an explicit provision of the Pullman Higgins Radiographic Procedure 1X RT-1.W77.
Corrective Actions NHY has determined that the appropriate short-term corrective actions for the two records deficiencies are to: 1) permanently identify the code required information on the films which are missing this information; and 2) reference the CAR on the film packages for i
these welds. -These corrective actions are specifically allowed for by the Code (T 236), and t
l once completed they will ensure compliance with the code. NHY completed these correctise l-actions for both 1-CS-318 02 F0202 and 1-RC-13-02-F0203 on May.17,1991, j'
If similar anomalies are found during the conduct of the balance of the Weld Records l
Reverification Project, long term corrective actions will include the evaluation of such l-anomalies, as a group, for generic implications and possible additional corrective actions.
C.2.
NHY NOG Surveillance The NHY Nuclear. Quality Group (NOG) is performing three separate surveillance activities for the reverification effort. These and their progress as of May 29,1991 are provided below, The first NHY-surveillance is to address the adequacy of the-procedures, scope and starting point for the weld tabulation, radiograph package inventory, and field weld list and l-radiograph comparison efforts described above. This surveillance will be performed in June I
and the results will be provided in the next monthly report.
The second NHY surveillance is to sample 20 percent of the field welds from each l.
of the isometric and support drawings previously reviewed by NES as part of the Task 1 l-weld tabulation effort. This surveillance addresses the procedural requirements outlined in-E NES Procedure 83A5643, " Review of Drawings." As of May 29, 1991, NHY Nuclear Quality Group personnel are in the process of performing this surveillance for the CS system. It is expected that this surveillance for the CS system will be completed by June 7,1991.
The third NHY surveillance is to sample 20 percent of the radiograph packages, by l
. system, that NES has reviewed as part of the task 2 effort. This surveillance addresses the l
procedural requirements outlined in NES Procedure 83A5462, " Review of Radiographs." As of May 29,1991, NHY Nuclear Quality Group personnel are in the process of performing 6
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t this surveillance for the CS system. It is expected that this surveillance for the CS system will be completed by June 7,1991.
C.3 NES Manacement Os e h t
NES also provides management oversight regarding the activities being performed by the NES personnel as part of the reverification of weld records project. On hiay 10, and May 21,1991, an officer of NES visited Seabrook Station to monitor the status and progress of the project.
Additionally, on May 16, and May 17, 1991, NES performed a Quality Assurance Audit of the activities being performed on site. This audit included a sampling of completed wnrk to ensure compliance with procedures. Although the audit report is still in progress, the sampling indicated that completed work does comply with procedures. The results (,f this : Jit will be presented in a subsequent monthly report.
- C.4 Performance Mo. 8.orine NHY also monitors the performance of the reverification of weld records program by tracking key parameters. The performance of these parameters is addressed in the respective sections of Part B of this report.
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