ML20077H172
| ML20077H172 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/03/1991 |
| From: | PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20077H169 | List: |
| References | |
| NUDOCS 9107050265 | |
| Download: ML20077H172 (5) | |
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,- I New Hampshire Yankee July 3,1991 ,
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ENCLOSURE 1 REPORT OF WELD RECORDS ANOM ALY FOR FIELD WELD 1-CBS-1201-07 F0701 ,
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9107050265 910703 PDR~ ADOCK 05000443 P pop
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REPORT OF WEl,D RECORDS ANOM Al,Y FOR FIEl,D WEl,D l CllS 120107-F0701 1
- 1. Introduction l In the April 10, 1991 Public Meeting between New llampshire Yankee (N11Y) and 11 NRC, and as provided in the NilY Program Description for the Reverification of Pullman liiggins Field Weld Records, transmitted to the NRC on May 13, 1991, NilY agreed to provide the NRC with a written report of any weld record anomalies within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the determination that a report was required. Accordingly, the following is a report of an identified records deficiency. NIIY determined that this anomaly required NRC notification on July 2,1991.
The identified deficiency . is a lack of the Radiographic inspection Report (RIR) and radiographic film for Pullman liiggins field weld 1-CBS 1201-07 F0701. NilY has evaluated this record deficiency and has determined that it does not adversely affect or call into question the physical quality of weld 1 CBS-1201-07-F0701 or other Seabrook Station welds at this time. The following provides the couc requiremer.ts, a description of the identified deficiency, cause of the deficiency, corrective actions which are to be implemented, and a justification for continued operation regarding the identified deficiency.
II, Code Reautrements American Society of Mechanical Engineers (ASME),Section III, Subse, tion NCA 4134.17,
" Quality Assurance Records", and American Nationals Standard Institute ANSI N45.2.9 - 1974, entitled " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," state that radiographic review forms and radiographs are to be retained for the lifetime of a nuclear power plant.
Ill. Description of the Deficiency Pullman-liiggins field weld 1 CBS 120107-F0701 is a circumferential groove weld on a fourteen inch diameter section of piping in the Containment Building Spray (CBS) System.
This section of the CBS -System is ASME 111, Class 2, and Safety Class 2. This weld
-connects a 45 long radius elbow to a section of piping, This weld is located in the line between the Refueling Water Storage Tank (TK 8) and the suction side of the "B" train Containment Building Spray Pump (CBS-P-98). This line also provides a source of water for the "B" train Safety injection Pump (SI-P 60) and the "B" train Residual lleat Removal Pump (RH-P 8B). The weld is physically located inside the tank farm between the Refueling Water Storage Tank (RWST) and the bermed wall. A currently available Quality Assurance (OA) document, the Pullman liiggins Field Weld Process Sheet, demonstrates that this field weld was radiographed in 1983 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).
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The weld records package.for weld 1 CBS 1201-07-F0701 has not yet been located and may '
be misfiled or inadvertently - discarded. It is currently believed that the RIR and the radiographs: for this weld were never transmitted by Pullman Higgins to Yankee Atomic Electric Company (YAEC) OA/NDE personnel for review and that the records were never transmitted to the Seabrook Yankee Document Control Center (SBYDCC) for final vault storage. Based on-the above, the lack of weld record documentation for this weld does not meet the record retention requirements of ASME NCA 4134.17 and ANSI N45.2.9.
NHY' Nuclear - Quality- Group (NOG) personnel have reviewed the 'available engineering documentation regarding this weld and have concluded that the lack of the RIR and radiographs for this weld does not call into question the quality of this weld. Review of the weld' process sheets for 1 CBS-1201-07 F0701 indicates that .this weld was completed on February 11, 1983, and on February 16, 1983 an .:xternal visual examination of this weld was performed. The attributes of this visual exami.iation included weld reinforcement, undercut, are strikes, removal of purge dams, presence af joint and welder identification, and suitability
- of the NDE performed. Nuclear Quality Group review of the field weld process sheet and the related Pullman-Higgins procedures ha(e determined that the initials of the Level !! r.no the ANI indicate that the procedures had been completed and the radiographic film showed the weld to be of acceptable quality. Other currently available O A documentation also demonstrates that the radiographic records for this weld were reviewed as part of the Pullman-Higgins N 5 as built Seabrook Station records verification process.
Additionally, this weld was ultrasonically tested in 1983 and deemed to be acceptable. The .
results are documented on the Pullman Higgins' Field Weld Process Sheet.
IV. Cause of Deficiency NHY has reviewed the ~ identified records deficiency and has determined its cause to be personnel error on the part of Pullman Higgins records management personnel. The Pullman-Higgins records management personnel apparently misfiled or inadvertently discarded the radiograph and the RlR prior to. the transfer of records to YAEC for review and failed to transmit these documents to the SBYDCC for ultimate archival in the Seabrook Station records management system.
-V. Corrective Actions NHY has. determined that the appropriate corrective actions for this records deficiency are to: 1) complete a radiographic examination of field ucid 1.CBS 120107-F0701; 2) review the film in accordance with our present program requirements; and 3) include the radiograph .
and the required radiographic review forms in the NHY records management system. When completed, actions 1, 2 and 3 above will ensure compliance with the Code. NHY will
-complete these corrective actions during the refueling outage currently scheduled to begin -
on July 27, 1991.
If similar- anomalies are found during the conduct of the balance of the Weld Records Reverification Project, long term corrective actions will include the evaluation of such anomalies, as a group, for generic implications and possible additional corrective actions.
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VI. Justification for Continued Operation ;
-The following provides a Justification for Continued Operation (JCO) of Seabrook Station ;
for the time period between the determination that the aforementioned weld record deficiency required NRC notification and the time that corrective actions for the deficiency are
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implemented. This JCO demonstrates that the identified weld records deficiency does not produce -any reduction in the protection provided for the health and safety of the public.
As provided in Section Ill above, N}lY has conclusively determined that the radiographic ,
film for field weld _1 CBS 120107-F0701 existed and was read by qualified reviewers and the weld was determined to be of acceptable quality as indicated on the weld process sheet.
The desigt pressure and design temperature of this section of the Containment Building Spray (CBS) Systern piping are 53 psig and 280'F respectively. ASME Code Case N 240, as endorsed by Regulatory Guide 1.84 eliminates the requirements to perform an integrity test of line segments connected to the atmosphere. However, with consideration of the Code Case this portion of the containment spray line was successfully tested for physical integrity i on February 3,1986. This test subjected the weld and piping out to the first isolation valve -
(CBS-V 5) to a test pressure of approximately 18.1 psig from the standing water in the Refueling Water Storage Tank. The integrity test utilized the RWST Technical Specification minimum value of 477,000 gallons which yields a standing head of approximately 41.9 feet.
Records of this test are available 'at Seabrook Station. There are no records of any discrepancies that would cause the integrity of field weld 1 CBS 120107-F0701 to be questioned. This portion of the CBS System between ,the outlet of the RWST and the bermed wall is currently in service at approximately 79 F and 18.1 psig and has been in service since the issuance of the operating license.
Based on the above, there are no outstanding questions regarding the quality of this field weld and thus no outstanding questions regarding the integrity of the Containment Building Spray System or any systems which utilize the common suction line- from the RWST, Additionally, the CBS System was extensively tested during preoperational and startup testing.
Moreover, this system has been operating at normal plant temperatures and pressures for the ,
past year. Throughout testing and operation, no problems with this weld have been
! identified. Therefore, since the identified records deficiency does not compromise the
! integrity of the CBS System, nor affect the operation of Seabrook Station, there is no reduction in the protection provided for the health and safety of the public.
l NHY has -also performed a safety evaluation for this JCO and has determined that an l unreviewed safety question does not exist. Specific;11y, since the identified records anomaly does not compromise the integrity of the CBS System, it does not increase the probability or consequences of accidents or malfunctions previously evaluated in the Final Safety Analysis j- Report (FSAR). The mere presence of a records anomaly does not introduce a new failure-mechanism nor does it modify the plant in any manner so as to create the possibility of a new accident or malfunction occurring. This records anomaly does not provide any means for an increase in the dose from any previously analyzed accident as it does not make any changes to the plant or its design basis. The margin of safety as defined in the basis for any technical specification will not be reduced by this records anomaly since it does not 3
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- compromise the-integrity of the CBS System nor affect the operation of Seabrook Station.
Ilased on the foregoing, the identified records anomaly does not present an unreviewed safety _ question as it does not compromise the integrity of the CBS System, nor affect the operation of Seabrook Station. Thus, this records anomaly does not reduce the protection provided for the health and safety of the public. '
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