ML20079C668

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Program Description for Reverification of Pullman-Higgins Field Weld Records
ML20079C668
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 05/13/1991
From:
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20079C666 List:
References
PROC-910513, NUDOCS 9106250036
Download: ML20079C668 (27)
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Text

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1 PROGRAM DESCRIPTION FOR THE REVERIFICATION OF PULLMAN-HIGGINS FIELD WELD RECORDS 1

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l 9106250036 910614 PDR ADOCK 05000443 P PDR

TABLE OF CONTENTS l

A. BACKGPOUND B. SCOPE

1. ASME SECTION III PIPING
2. ASME SECTION III SUPPORTS
3. ANSI B31.1 POWER PIPING 4 ASME SECTION VIII UNFIRED PitESSURE VESSELS
5. RADIOGRAPH REVIEW AND APPROVAL C. HETHOD
1. WELD TAbUIATION
2. RADIOGRAPH PACKACE INVENTORY
3. FIELD WELD LIST AND RADIOGRAPH COMPARISON D. PERFORMANCE MEASUREMENT AND REPORTING
1. REPORTS TO THE NRC
2. NHY NQG SURVEILLANCE
3. NES MANAGEMENT OVERSIGHT
4. PERFORMANCE MONITOPING E. ATTACHMENTS A -- ASME SECTION III PIPING SYSTEMS O

B -- RADIOGRAPH REVIEW PROCESS C -- RADIOGRAPH RECORDS FLOW PROCESS D -- ASME SECTION III CIASS I SYSTEMS E -- REVERIFICATION TASK PROCESS F -- NES QUALIFICATIONS C -- MILESTONE SCHEDULE

May 13, 199.

I PROGRAM DESCRIPTION A. BACltGROUND This program was developed in response to the March 19, 1991 NRC Region 1 letter requesting that New Hampshire Yankee (NHY) '.. conclusively show whether the code required radiographs and RIRs (Radiograph Inspection Reports) were fully processed, and retained, for Pullman Higgins field welds...".

The NRC requested NHY to accomplish the following:

1. Re review the Seabrook as-built isometric drawings and identify all Pullman Higgins (P H) field welds for which radiography was a requirement established by Code (e.g. ASME, B31.1).
2. Determine whether New Hampshire Yankee has the required radiographs and RIRs for all welds identified by the above review, and whether those records attest to independent YAEC (Yankee Atomic Electric Company) determination of acceptability. If they do not, please explain why not.
3. During the above review and determination, if any additional incomplete records are noted, assess the individual and generic causes and safety implications, and take appropriate compensatory and/or corrective-actions.

4 Report the results of this effort to the NRC within about one week o' its completion, retaining auditable records of the effort on-site for reference.

In response to this request, (NYN-91050 dated March 25, 1991) NHY stated that we would perform the actions as requested by the NRC by August 31, 1991.

Subsequent to submitting NYN-91050, the NRC requested and NHY provided a formal briefing which outlined the program for conducting the field weld reverification effort. This transcribed briefing occurred on April 10, 1991 at the NRC offices in Rockville , Maryland. On April 30, 1991 NRC Region 1 requested that NHY prepare and submit _ a written description of the program for conducting the reverification of P-H field welds requiring radiography by Code.

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The following sections, B.1 through B.4, provide the weld reverification program code basis, engineering background and weld reverification scope statements for each of the four major subcategories of welds performed by P-H that reside within the scope of the NRC request. Section B.5 describes the manner in which code requirements for radiography review were met and documented for the Seabrook project by Pullman Higgins and Yankee Atomic Electric Company.

Sections C.1 through C.3 provide the methodology to determine that NHY has the required radiographs and Radiograph Inspection Reports including requisite approvals. Section D.1 provides the reporting mechanism (s), if necessary, to inform the NRC, on a timely basis , of identified anomalies. Sections D.2 through D.4 delineate the additional NHY and Nuclear Energy Services Quality Assurance oversight and the completion schedule for this effort.

B. SCOPE The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BSPV) Code and American National Standards Institute (ANSI) provide the criteria for radiographic non destructive examination. These codes and standards were applied to the design and construction of Seabrook Station as required by 10 CFR 50.55a. This section mandates the use of Section III of the ASME B&PV Code for safety related systems. The Seabrook Final Safety Analysis Report (FSAR) outlines the application of these requirements to systems, components and structures for Seabrook Station. The FSAR states that the Piping and Instrumentation Diagrams (P& ids) indicate the code class boundaries for piping systems, Attachment A lists the ASME Section III systems for Seabrook.

B.1 ASME SECTION III PIPING Code Requirerrent ASME Section III specifies individual requirements for Code Class 1, 2 and 3 piping systems in respective subsections. By code class the respective subsections of the Code are as follows:

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Code class Subsection Title 1 NB Class 1 Components 2 NC Class 2 Components l

I 3 ND Class 3 Components l

Each subsection provides specific criteria for welding and non-destructive examination. From the code applicable to Seabrook (1977 Edition, Winter 1977 Addenda) the following table delineates the applicable non-destructive examination by code class . The table also indicates the subsection of the Code specifying the requirement. This table was included in the United Engineers and Constructors (UE6C) specification for P-H installation cf piping.

NDE Requirements #or Field Installation of Piping at Seabrook per the 1977 Edition of ASME Section III with Addendas through Winter 1977.

Applicable ASME 111 EXAMINATIONS ASME Code Type Of Welds Code Class 21 PT** MT** _ RT Para 1.

X* X* X NB-5222 Circumferential 1 X NC-5222 2 X - - X Butt Weld 3 X >2'NPS >2*NPS (1) ND 5222 Joints 2.

Branch Piping 1 X X* X* >4*NPS NB 5242 Butt Welded 2 X <4'NPS <4*NPS 74'NPS NC 5242 3 X >2'NPS >2*NPS (1) ND-5242 Joints 3.

Branch Piping 1 X X* X* >4*NPS NB 5243 Corner Welded 2 X $4*NPS 54'NPS >4'NPS NC-5242 Joints and Oblique 3 X >2'NPS >2'NPS (1) ND 5242 Piping Connections 4.

Fillet and Socket 1 X X* X* -

NB-5260 Welds (excluding 2 X X X -

NC-5260 Name Plate Welds) 3 X >2'NPS >2*NPS - NC-5222***

  • Examine the external and accessible internal weld surfaces and adjacent base material for at least 1/2' on each side of the weld.

(Footnotes continued on next page.)

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    • Liquid Penetrant examination shall be conducted on non magnetic material only. Magnetic Particle examination shall be performed on material that can be magnetized.- For materiel that can be magnetized, Liquid Penetrant examination may be used only when part geometry or space restriction prevents Magnetic Particle examination.

Materials and fabrications shall be examined per the requirements of the applicable purchasing specification.

      • As illustrated in Figure ND 4427-1, (1) As a standard practice for the non destructive examination of Class 3 piping systems, Seabrook used Liquid Penetrant or Magnetic Particle examination as allowed by code.

The scope of ASME Section III piping requiring radiographic examination by code was limited to Class 1 and 2 systems as designated on the P& ids.

Enrineerinr Background UESC, as the Architect-Engineer, developed the Engineering documents which established the configuration of the plant. For piping systems these documents included Piping and Instrumentation Diagrams (P& ids) and isometric drawings.

The UE&C isometric drawin6s retain Engineering design information pertinent to

'arge . sections of piping systems.

To facilitste the installation and construction process, P-H developed a series of isometric drawings representing smaller segments of the piping contained on a UE&C isometric drawing. In 1984 these P-H isometric d.avings were-subsequently converted to UE6C drawings.

In 1986 NHY issued P& ids which superseded the UE&C P& ids. The hHY design or 'D' level P& ids note the portion of a pipe line represented by the UE6C (P H) isometric drawing The 'D' level P&ID refers to each line and segment number.

The UE&C (P-H) isometric drawings depicted the line segments and tracked the field welds shown on that drawing. Specifically, the field weld numbers were identified by 1. ne , segment and a sequential number. In the event that a field weld was deleteo, that field weld number was not used again. New field weld numbers were assigned starting with the next available number. Therefore,

! collectively these isometric drawings correspond to the system configuration shown on the NHY P& ids and collectively they establish the appropriate basis for identifying all field welds.

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- . . - - . . - . . ~ . - - . - - - - - - . - . - - -_.. -_._ - -

Durt is construction, changes to the piping systems were documented,-

reviewed and approved and tracked per procedures. Engineering Change

'Authoriz.tions and Non Conformance Reports were two of the typical forms of design chcnge ~ documents used at Seabrook during construction. These design change documents were incorporated in revisions to the drawings, as required.

Seabrook used a tracking system (Change Document Tracking) to indicate which of these design change documents had not been incorporated on the respective

' drawings that they affected. Change Document Tracking (CDT) also reflects design modifications that. have occurred since the completion of construction.

Therefore, the NHY P61Ds , UE6C isometric drawings and the associated design change documents represent the as-built condition of ASME III piping systems.

The as-built process verified the actual as constructed plant. A part of this process' also verified that the requisite non-destructive examination had been completed for each field weld. This verification was done by reviewing the non-destructive examination reports and other quality records that had been previously completed and transmitted to the site records vault. For field welds requiring radiography, the Radiographic Inspection Report was the non-destructive examination report used for this verification effort. This total process enabled P H to certify that the system was constructed per the ASME Code and to submit the Code required N-5 Code Data Report. For each isometric drawing P H developed l

a records package. P Il submitted these packages and other quality records (e.g. ,

NDE - reports) to the site document control center. For radiography, P-H transmitted the radiographs to YAEC for review. YAEC then transmitted radiographs back to P-H for transmittal to the .. site document control center.

Attachment B provides a flow chart for the typical radiograph review process and Attachment C provides a flow chart for the radiograph records transmittal i

l process. Upon submitting the N-5 Code Data Report, P-H completed their l contractual-installation and verification responsibilities for that system.

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Weld Records Reverification Procram Scope Therefore, in summary, the appropriate basis for the P.H field weld records reverification for ASME Section III piping:1s defined by the following:

f A. NHY P6 ids I

B. UE6C Isometric Drawings

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C. Unincorporated Design Change Documents Di N-5 Code Data Report 5

_ _ _ ._ _ _ . _ _ ~

B.2 ASME SECTION III SUPPORTS Code Pecuirement ASME Section III requirements for supports are contained in subsection NF

' Component Supports'. From the 1977 Edition, through Vinter 1977 Addenda, Code Paragrapn NF 5212, the requirements for non-destructive examination are as follows:

(A) All full penetration butt Nelded joints, full penetration tee joints, corner joints, and full fillet welds in primary members as defined in NF-1211(b) shall be radiographed. When radiography does not yield

. meaningfel examination results, ultrasonic examination shall be performed. In addition, the weld and adjacent base material for at least 1/2 inch (13 mm) on each side of the joint shall be examined by either the magnetic particle or liquid penetrant method.

(B) When the requirements of ( A) above cannot be met, the welds including the adjacent base material for at least 1/2 inch (13 mm) on each side of the weld shall be examined by either the magnetic particle or liquid penetrant method.

(C) All other welds shall be visually examino to the acceptance standards specified in NF-5360.

Only ASME Section III Class 1 supports require radiographic non-destructive examination. Attachment D lists the ASME Section III Class 1 systems. Seabrook also adopted Code Case N-413, ' Minimum Size of Fillet Velds for Linear Type Supports', for ASME Section III supports.

Ennineerine Backrround As stated previously in Section B.1 on ASME Section III piping, UE6C developed isometric drawings. These UE&C isometric drawings identify and locate the Class 1 supports in their relative position to the piping system. UELC also designed the supports which are represented on UE6C pipe support detail drawings.

Similar to the piping process, P-H also developed pipe support installation drawings from the UELC pipe support detail drawings. These support drawings were l

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used in an manner analogous to the P-H piping isometrics. Each P-H support installation drawing identifies the field welds and weld joint type. The field weld numbers were identified by support number and a sequential number. Change 2 l to these supports were accomplished per approved design change documents consistent vith the practices described in Section B.1. The as building process also applied to ASME supports. The N-5 Code Data Report and records package included supports as part of the scope.

Weld Records Reverification Pronram Score Therefore, appropriate basis for the P-H field weld records reverification for ASME Section III Class 1 supports is defined by the following:

A. NHY PLIDs B. UE&C Isometrics C. Support Drawings D. Unincorporated Design Change Documents E. S-5 Code Data Report B.3 ANSI B31.1 POWER PIPING

. Code Reautrement ANSI B31.1 Power Piping applies requirements to piping systems other than ASME III systems. From the applicable code, 1977 Edition, Winter 1977 Addenda, the code requirements for radiographic non destructive examination are as follows:

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l Pit t tr. servlee cera t tier e er4 w en De st rvrt ive lieste et t ru Systees With Tempetetvres beteoen 350'F ond 750'T Systene With it.e19eive Arid At All hree Of Welde ittp r o t ur e s ove r M0't. f ressuree Nor 102) P$10 All Oroere htt Wolde (Citth ered RT for Wil over l'. FT 97 for over l' Nf8 with Vieuel f er ela eises eris  !

ter. git udir.el er P1 foe NPS 2' etd thickheet over 3/4'. thistmesese. I less. Vieuel f et oli elete with thickt.eet 3/4' or lose.

Welded Bretich cotor.ections RT fct Nf'8 ove r 6 * . 57 for 1tou t over 4' kP5 Vieuel for ell elsee and t$ lee Indireted le trench KT st P1 f or WP8 a' er er.d thickmese of 1> tench t ht e emo e c e s .

Sise). See Neto 10 1ees. cver 3/4*. Vieuel fer all siste with 1, ranch thickmese 3/4* or lese.

1 Fillet. $ocket Weide. PT or KT for all elsee Vieuel f.t ett oisee and Vieu l for oli elsee er.d end thickr4eesse. thi t e.r.e e i o s . thletteeees, Deposited Weld Pietal ao leinforcement (it.eindir.g at actose hele I.ede).

Enrineerinr. Backcround P H used isometric installation drawings for B31.1 piping systems similar to the ASME Section III piping isorcetrics. Wald numbers, were assigned and tracked by isometric. The change document process and controls and submittals of records to lhe site document control center were also applied in a similar manner.

Weld Records Reverifiention Procram Scoce Therefore, tho' appropriate basis for the PH field weld records reverification for ANSI B31.1 piping is defined by the following:

A. Design Tertperature B, Design Pressure C, UE6C Isormtric Drawings D. Unincorporated Design Change Documents 8

~~ _ . _ . _ - . _ _ _ _ _ _ , . . - _ - - . _ _ _ _ _ . _ . _ _ _ _ . _ . _ . _ _ , ~ . . . _ _ _ . .

s n.4 MSME

_ 1ECTION V17L.HFJJ]t_ED PRESSURE VI)JK11 Code Peautretrent ASME Section Vill, Unfired Pressure Vesselt, specified the requirements i for the roanuf acturing of unfired pressure vessels. Similar to other Sections of the Code, Section Vill provides criteria indicating radiographic non-destructive examination requirements. From the applicable code, 1977 Edition, Winter 1977 Addenda, the code requircruent s for radiographic non destructive examination are defined in ASME Section V111, Subsection W 51 and W 52.

fnrineerinr. Backcround P li's contractual responsibilities at Seabrook were limited to erection and installation of mechanical equipment, Section Vill vessels were manufactured and Code stamped by other contractors and installed by P il .  !)u r i n * . the construction process there were occasions where Section VI!! repairs were necessary. Non Conformance Reports (NCR) tracked the resolution and disposition of the required repairs through review and approval. When approved, the NCR became the authorized design change document to affect the repair, in sorne instances those repairs required field welding to the base metal of the Section Vill vessel. In these instances the NCR specified the repair procedure, type of welding to be performed and the requisite method of non destructive exarnina t i on. Radiograph examination was specified by Engineering contingent upon the specific repair to be effected. There field welds were performed to correct non conforming conditions identified during the installation process and the NCRs becarte the design change documents used to authorize repai n, Veld Records Reverification Prorram Geone t

Therefore, the appropriate basis for the P il field weld records reverification for ASME Section Vill unfired pressure vessels is defined by the following:

A. NCRs on Section VIII Vessels 9

B.5 PADINARILRE_V1FJ1AtEMYA!,

The appl 1 cable codes require that qualified and certified individuals review and approve the results of required non-destructive examination by radiography. The ASMC BP6V Code Section 111 only requires that one individual, cert ified as a Level 2 radiograpu reviewer (to SNT-TC 1A), is required to review and approve a radiograph. The ASME Code requi en that the contractor record, on a review forrn accompanying the radiograph, the interpretation and disposition of the material examined, At Seabrook, P il used the Radiograph Inspection Report (RIR) as the f o rto for recordir.g the examination results . In response to a YACC/NRC tinding, P ll added a r e qui rerte nt f or additional radiography review.

After this point in t i rte , PH had two qualified and certified individuals reviewing each f ilta package in addition to the code requirements for the installation contractor, the Authorized Nuclear Inspector (ANI) ensured contractor compliance with Code requirertents by reviewing a sample of each aspect of the contractors non-destructive examination program. At Seabrook, the AN1's radiograph review was noted by signing the RIR form.

In addition to code requiretrents, Yankee Atomic Electric Company (YAEC),

perf orrted Quality As.surance surveillances t o entut e that P H's programs stet the Seabrook Project Quality Assurance Program requirertents. Surveillances typically involve a sartpling of a p r o gr art.m a t i c p r oc e s, s . For radiograph review, this surveillance at first res.ulted in an unwritten, and then subsequently in 1984, resulted in a written procedural step to review 100% of the nuclear, safety related P.H field weld radiographs. The YAEC radiograph review was indicated by signing or initialing and dating the RIR or the jacket of the radiograph file package Upon reviewing and approving the field weld radiogt aph film psckage, P.

H forwarded the package to YAEC for their review and approval. The YAEC review and approval, as shown on Attachment B, was over and above the requirements of the applicable code. Following the YAEC review and approval, P H transmitted the film package and the original RIR f or permanent storage in the site records vault. P H retained a copy of the PIR for subsequent processing in connection with the N-5 Code Data Report to be performed once the system in question was c ortpl e t e d . The scope of the PH field weld reverification for radiograph packages is defined by the following:

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A. Radiograph Inspection Report Forms B, signatures Indicated on The RIR Form C. Film Corresponding To The RIR Form l

C. MITHOD The program for reverification is defined by the 'NHY Project Specification for Verifying Completeness of Radiographic Records', the resulting contract, and the procedures prepared and approved, or to be prepared and approved, for the Project. The result of the process will be a precise, accurate, controlled and independently performed reverification that all PH field welds for which radiography was required by the applicable codes, were in f act , radiographed and approved as required by code, and also were reviewed and approved by YAEC, and that the required documentation and film are retained as permanent plant records.

Attachment E provides a flow chart which summarizes the reverification tasks.

C.1 )[ED TABUhATION The weld tabulation ef fort (Task 1) is designed to provide a list of field welds requiring radiegraphy in order to meet code. Engineering design documentation (drawings and change documents) and the N-5 Code Data Reports are the basis for developing this list. NES Procedure 83A5643, ' Procedure For The Review Of Drawings * , provides the controls f or developing the list of field welds l requiring radiography.

l Af ter assembling the Engineering design documentation and the N 5 Code Data Reports, the Field Engineer reviews each isometric or support drawing and the unincorporated design change documents. The Engineer records the following data:

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A. Unit B. System l C. Line Member D. Isometric or Support Drawing Number E. Drawing Revision Level F. Applicable Construction Code, and G. All Field Velds 11

, , , , , - - r n - - . - . - - - r-- ,, - -

a_ - - ,-4r ,n - -, ~

. _ - _ - - - - - - - - - - - - - - - - - _ - ~ . - - - - _ - . -

The Tleid Engineer determines and records the field welds listed as requiring radiography. The Field Engineer subsequently applies the applicable code crit eria for non destructive examination to field welds not listed as requiring radiography. The Field Engineer records the reason for not requiring radiography for each field weld where applicable. For field welds where the reason for not requiring radiography cannot be determined, the Field Engineer submits the data sheet and support docunentation to the NES Project Manager for review. The Project Manager reviews each data sheet. Indeterminate field welds are documented on a NilY Request for Engineering Services (RES) and forwarded to NilY Engineering for resolution. NNY Engineering returns completed RESs to NES indicating the non destructive examination requirement and the source t,f the requirement, Upon completing an entito system the NES Project Manager forwards copies of the data sheets to NHY. The total data sheets for ea-h system provide the input necessary to generate a list of field welds requiring radiography by Code.

C.2 ]%Dl @RAPl! PACKAGE INVENTORY The Radiograph Package Inventory (Task 2) is designed to provide a list of field welds for which radiograph films and RIRs are retained in the site records vault. This task will also record the signatures of the individuals and organization reviewing the radiographic film. NES procedure 83AS642, ' Procedure For The Review of Radiographs' provides the controls for this task, l The Document Reviewer shall review each field weld film package which consists of the RIRs and radiographs film. From the RIRs the Document Reviewer will record the following information on a data sheet; l

l A. Unit l

E. System, Line Number, Drawing Number C. Veld Number D. Veld Revision Level E. Date Of Exposure F. Applicable Construction Code C. Station Numbers 11 . Veld Statir- Status I. Approval Name(s) And Date(s) ( P -il) l 12

J. ANI Name And Date K YAFC Nane And Date in instances where informatioti is not on the Rlk, the data cheet it left blank.

From the film in the package the Document Reviewer will record for each film the following information on a data sheet:

A. Station Number B. Date of Exposure C. Systein/Line/ Drawing Nunber D. 'a'e l d Numbe r The Document Reviewer will verif y that the RIRs and f11tts for accepted stations are retained in the package. This verification task step _d oes not involve reinterpretation of the film. The Document Reviewer completes the dat a sheet by indicting any nissing views, approvals or film and subsequently forwards the data sheet to the NES Project Manager. The Project Manager reviews the data sheet for completeness. Indeterminate radiograph records are documented on a Corrective Action Req 0est (CAR) and forwarded to the NHY Nuclear Quality Group (NQC) for resolution. Ths. SQC returns completed CARS to NLS indicating the resolution of the indeterminate records. Upon completing an entire system the NES Project Manager forwards copies of the data sheet s to NHY. The data sheets for each system provide the input necessary to generate a list of field welds for which radiographs are retained in the on site records vault.

C.3 ZHLD VELD kljiT AND RAD 1QQ_RAPH COMPMIMt{

The comparir.on of the list of field welds requiring radiography (Task 1 output) with the list of field welds f or which radiography exists (Task 2 output) will provide a single list which indicates that radiographic records are retained for field welds which require radiography by code. NES procedure 83A5641,

  • Proceuure For The Review Of Radiographic Records' provides t.he controls for this task.

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As the data sheets for each system are completed, from the Task 1 and ?

ef forts, the Project Manager combines the data into a single list which retains the following information:

A. Field welds requiring radiography where the film packages exist.

B. Field welds requiring radiography where the film packages do not exist or there are deficiencies in the film package records C. Field welds not requiring radiography where film packages exist D. Field welds not requiring radiography and film packages do not exist .

As each system is completed, the Project Manager submits an interim report to N1W. This report will include the list descril>ed above and any indeterminate items which require resolution by a RES or CAR. The Project Manager will prepare the applicable docunent and transmit it to N1lY for resolution. N1W Engineering or NQC will provide a resolution to the indeterminate condition.

D. PERFORMANCE MF.ASUREM?NT AND rep 0RTING D.1 ]LEPOUS TO TI!E NRC N1W has developed a procedure which delineates the special NRC reporting requirements for the Reverification of Pullman liiggins Field Weld Records project. This procedure, entitled 'Speciel Reporting Requirements for Reverification of Pullman lii E6i ns Field Weld Radiographic Records Project,'

provideo the special, additional requirements and responsibilities for processing and doctuu nting potential anomalies and reporting anomalies identified during this proj ect . This procedure ensures consistent implementation of the special reporting requirements as requested by the NRC at a public meeting on April 10, 1991. A summary of the evaluation and reporting methodology using this procedure is presented below.

During conduct of reviews associated with implementation of the Nuclear Energy Services (NES) ' Procedure For The Review Of Drawings' and ' Procedure For The Reviev Of Radiographs', the NES Project Manager inay identify indeterminate 14 l

items which require further clarification. These indeterminate items are I documented using the NHY established mechanisms of the Request for Engineering Services (RES), or a Corrective Action Request (CAR). The RES is utilized to document items requiring engineering evaluations while the CAR is utilized to document items regarding missing or incottplete records, Upon identification of an indeterminate item, 'ho NES Project Manager forwards an RES or CAR to the NHY 1RT Manager for review. The NHY 1RT Manager subsequently forwards the RES to the NHY Engineering Department, and the CAR to the NHY Nuclear Quality Manager for disposition. Since all RES's and CARS associated with this proj ec t are the highest priority, the NHY Manager of Engineering or the NHY Nuclear Quality Manager must approve disposition within 7 working days of the RES' or CAR's initiation date.

Following approval by the NHY Manager of Engineering or NHY Nuclear Quality Manager, the RES or CAR is forwarded to the NHY 1RT Manager who determines if the disposition of the item requires NRC notification. Notification will be provided anytime 1) the quality of one or inore welds is deterrained to be unacceptable based upon the reverification of weld documentation (f.e., weld fails to meet code and/or regulatory requirements upon a reanalysis of the code required final acceptance veld documentation); or 2) one or more quality records, needed to demonstrate the < 2de and regulatory coupliance of a weld, cannot be located or is found to be unacceptable based upon the reverification of weld documentation. Evidence of Yankee Atomic Electric Company (YAEC) review of final Pullman Hi B6i ns, Safety Related, field welds documentation is considered to be

, a weld acceptability requirement for the purpose of this reverification effort.

t All RES' and CARS which require NRC notification are immediately forwarded to the NHY Regulatory Compliance Manager who determines whether the anomaly and ,

RES cr CAR disposition requires a one or four hour report to the NRC in accordance with 10CFR50.72. If a one or four hour report is not required, the NHY Regulatory Compliance Manager provides a telephone notification 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 time the NHY 1RT Manager determines a notification is j

necessary.

Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the NHY 1RT Manager's determination, the NHY Regulatory Compliance Manager will submit a written report regarding the deficiency to the NRC. .This report will include a description of the deficiency, a justification 15

for continued operation, and a description of any short or long term cortective actions nece sitated by the anomaly. Notwithstanding this report, the NHY Regulatory Cotop11ance Manager will determine whether it is necessary to subsequently submit a 1,1censee Event Report pursuant to 10CFR$0.73, regarding the anomaly.

In addition to the aforementioned telephone and 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> written reports, starting in May 1991 and continuing through the completion of the project, NHY will submit a monthly written report to the NRC. This report will include a description of the progress to date of the Reverification of Pullman-Higgins Field Weld Records project, a discussion of any deficiencies identified, and corrective actions implemented or planned.

At the completion of the Reverification of Pullman-Higgins Field Weld Records project, NHY will submit the NHY Reverification of Pullman Higgins Field Welds Records Report to the NRC. This report will include the following:

  • A listing of Pullman-Higgins field welds requiring radiography by code
  • A determination whether NHY has the radiograph inspection reports and radiograph film for Pullman-Higgins field welds requiring radiography by code.
  • A deter:nination whether these weld records attest to independent Yankee Atomic Electric Cotepany determination of acceptability.
  • A determination if necessary, of individual and generic causes and safety implications for any incomplete records that may be found.
  • And, if necessary, the co:npensatory actions completed or scheduled.

NES's report to NHY will also be provided with the NHY Reverification of Pullman-Higgins Field Weld Records Report.

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D.2 El[LEQ9_kMZ114#!G5 The NHY Nuclear Quality Group will be performing three separate surveillance activities for the reverificat ion of P -il field welds requiring radiography by code The thtee surveillances are as follows:

A. A program surveillance to ensure that the prograin as outlined will

' conclusively show whether the code required radiographs and RIRs were fully processed, and retained for Pullatan liiggins welds. '

The program curve 111ance will specifically address the adequacy of the procedures, scope and starting point f or each of the respective tasks described previously in Section C.

B. The scope of the second surveillance applies to the Task I weld tabulation activities being perf ormed by NES. The NHY NQG will sample 20% of the field welds om each of the isometric and support drawings previously reviewed by NES. This surveillance review will be performed on a periodic basis and address the procedural requirements outlined in NES Procedure 83A5643, ' Review Of Drawingn* .

The surveillance will a l e. o include the appropriate and t in.e l y resolution of indeterminate field welds identified on RESs.

C. The scope of the third surveillance applies to the Task 2 radiograph package inventory being performed by NES. The NHY NQG will sample 20% of the radiograph packages , by system, reviewed by NES. The surveillance review will be performed on a periodic basis and address the procedural requirements outlined in NES Procedure 83AS462,

' Review of Radiographs' The surveillance vill also include the appropriate and timely resolution of indeterminate field weld records identified on the CARS.

D.3 EES HMAGKtg;N1 OVERSIGHT NES oversight includes a Quality Assurance Audit of the activities being performed on site. It also includes the bi weekly site visit by an officer of I NES to personally monitor the status and progress of the project. The NES QA Audit is tentatively scheduled for the week of May 13, 1991. Audit activities 17 f

will include a samplitig of cortpleted work to ensure compliance with procedures. 1 At tachment F summarizes the qualifications of the NES personnel assigned to this l 1

proj e c t .

D.4 PERFORMANCE MONIT0lGER In addition to steasuring compliance to program requirements. N!!Y vill monitor the performance of the program by tracking and trending key parameters.

These paratteters include:

A. The NHY turnaround tirne for indeterminate items identified on RESs and CARS.

B. The preparation of document packages to support the Task 1 field weld tabulation, C. Tracking and trending the rate at which Task 1 isometric and support drawings are completed.

D. Tracking and trending the Task 2 Radiograph package inventory.

E. Tracking and trending the development of the Task 3 final list which will provide a ready reference to the field welds requiring radiography and their corresponding field weld radiograph record packages; and.

l F. Progress made towards completing the project per the established milestone schedale (Attactument G) .

In addition to the milestone schedule, the sequence for completing the field weld reverification program starts with the ASME Section III piping systems. Within category the piping system reviews will be sequenced by Code class. The four systems with Class I segments (Attachment D) will be completed first. These systems will be followed by the Class 2 and then the Class 3 systems. Upon completing the ASME Section III piping, the Class 1 supports will be reviewed. After completing the support reverification, NES will reverify the ANSI B31.1 piping segments and will finish with the review of NCRs to determine any repairs that may have required radiography per ASME Section VIII.

18

l Attachnent A E

MME_BECTION III PIPING _SYSTFMS

1. Auxiliary Steam
2. Containttent Air Handling
3. Containment Air Purge
4. Containment Building Spray
5. Containment Or. Line Purge
6. Component Cooling
7. Combustible Gas Control B. Condensate
9. Charging (Chemical Volwtc and Cont rol) 10.. Diesel Generator
11. Demineralized Water
12. Fire Protection
13. Feedwater
14. Instru:nent Air
15. Main Steam
16. Main Steam Drains
17. Nitrogen Gas
18. Reactor Coolant
19. Residual Heat Removal
20. Reactor Make Up Vater
21. Resin Sluice
22. Service Air
23. Steam Blowdown
24. Spent Fuel
25. Safety Injection
26. Sampling
27. Service Water
28. Vent Gas
29. Vaste Gas
30. Vaste Liquid

Attacliment B RADIOGRAPil REVIEW PROCESS Normal process that Radiograph weld. Res!xxx wcld meets code .as shown Rep.a g

> hh& is acxrpcable above dotted line.

v aify W u h m.

i Aarpt

+ /

Repair defects & . levelII review of 3 Permanent surage rennn, write irpair #c #F film forweld -> g ceder or NCR quahry n

__________ v

' Reshoot ducction,b Reject P4IIevelIII Acczp_

renen to reviewer with repair order, ovemew or NCR v \

Reviews performed at Seabrock YAECoverview -> Raurn so reviewer that are over and above code re-quirernents are shown below the Aarpt I

dotted line. Y P m so P-II

Attachment C RADIOGRAPil RECORDS FLOW PROCESS l'-il performs the radiography h

I' il interinets and reviews the film i

t P-il transmits the Illit and film to YAI!C h

YAl!C interprets and reviews the film h

YAIIC transmits the Illit and film to P il v

P-il transmits Illit's and film to the records vault (SI3YDCC) h SilYDCC personnel verify the transmittal h

YAI!C verifies the transmittal including signatures and package completion.

YAl!C files Illit's and film by system, isometric and field weld number in the site recoids vault.

l l

+

At t nehn ent D A$}{g_E1QI1ON III CLA_SS 1 SYSTDil

1. Charging (Chemical Volu:re and contiol)
2. Reactor Coolant
3. Residual Heat Removal
4. Safety Injection l

. l 1

Attachment E REVERIFICATION TASK PROCESS i

l TASK 1 TASK 2 Assemble documentation package NES document reviewer reviews each weld record package NES engineer reviews design drawings and unincorporated NES document reviewer design change documents records weld record package data k u NES engineer records field weld data and requirement NiiS project manager rev ews data sheets for radiography h

NES project manager reviews weld data sheet indeterminate weld record nformation is documented on k a Call and transmitted to NilY Indeterminate welds are documented on an llES and h transmitted to NilY NES project manager transmits h copies of data sheets to NilY NES project manager transmits copies of data sheets to NilY TASK 3 NES project manager compares weld data list (Pask 1) and weld record list (Pask 2) h NES prepares a single list of field welds and associated radiograph records i

y*

t A.1.13n]atien t i M LOMkiflGM10M NilY developed a project Specification for Verifyltig Cortpl e t e ne s, s of Radiographic Records. This, specification was the basis for Requests fot Quotations from three vendors on the NHY Approved Vendors List. I roiti this process NHY contracted with Nuclear Energy Services (NES) to perforra the work scope described in Section C of this Program Description. NHY actains, a s, a prnvisioti of the contract, the right of refusal for NES personnel proposed for this project. NHY has reviewed the qualifications of each of the NES personnel assigned to this effort. This review included the following:

A. Education and professional qualifications; B. Relevant work experience; C. A reference check with previous supervisors, clients, or co woikers; and D. NHY Fitness For buty qualification.

This information was previously transtuitted to NRC Region 1 and war. NRC reviewed on site a second time during the week of April 29, 1991.

NHY and the NRC have found the NES individuals, assigned to this project ,

well qualified to perform their assigned tasks and responsibilities. Their collective educational and professional qualifications include the following:

A. Mettbership on the AMSE Section X1 Working Group on inspection of Systems and Components; B. Extensive training on all forms of non destructive examination; C. SNT TC 1A qualification on certain forms of non destructive e xattina t ion ;

D. Lead Aeditor Certification per ANSI N4S.2.23; and E. , asive work experience with weld records review atid associated engineering documentation.

, bo

,. l At t aclurent G MILESTONJ_SCHEDULI April 22, 1991 -

Weld Tabulation Started i l

April 25, 1991 -

Radiograph Review Started May 13, 1991 - Weld Tabulation and RIR Review Comparison Starts May 30, 1991 - NHY Written Report #1 To fGC Region 1 June 28, 1991 -

Weld Tabulation and RIR Review Completed June 28, 1991 - NHY Written Report #? To NRC Region 1 July 5, 1991 - Weld Tabulation and RIR Review Comparison Cortpleted July 31, 1991 - NES Subreits Final Report To NHY July 31, 1991 - NHY Written Report //3 To NRC Region 1 August 30, 1991 - NHY Written Report #4 To NRC Ref. ion 1 Final Report and Sunatary

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