ML20081L193
| ML20081L193 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/28/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NYN-91101, NUDOCS 9107020446 | |
| Download: ML20081L193 (11) | |
Text
,
e New Hampshire Y
Ted C. Feigenbovm President and Chief Executive Officer NYN 91101 June 28,1991 United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Attention:
Mr. Thomas T. Martin, Regional Administrator
References:
(a)
Facility Operating License No. NPF 86, Docket No. 50-443.
(b)
Transcribed Publi: Meeting Between New Hampshire Yankee and the NRC conducted on April 10, 1991.
(c)
NHY Letter NYN-91076 dated May 13, 1991, " Transmittal of the Program Description for the Reverification of Pullman Higgins Field Weld Records", T.C. Feigenbaum to T.T. Martin.
(d)
NHY Letter NYN-91088 dated May 30,1991, "May 1991 Status Report for the Program for the Reverification of Pullman Higgins Field Weld Records / T.C. Feigenbaum to T.T. Martin.
Subject:
June 1991 Status Report for the Program for the Reverification of Pullman-Higgins Field Weld Records Gentlemer in the,';'ril 10, 1991 Public Meeting between New Hampshire Yankee (NHY) and the NRC [Referenct (b)], and as provided in the NHY Program Description for the Reverification c'
Pullman Higgins Field Weld Records, transmitted to the NRC on May 13,1991 [L :ference (c)l, NHY agreed to provide the NRC with a monthly written report of the proy.ress of the Reverification of Pullman Higgins Field Weld Records Program.
Accordingly, enciased please find the status report for the month of June 1991.
gm Should you have any questions regarding this matter, please contact Mr. Neal A.
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Pillsbury, Director ol Quality Programs at (603) 474 9521, extension 3341.
Mg Very truly yours,
.N o n.
f cx o ed C. Fei. nbaum eo
$,3 TCF:JES p
rg Enclosure Z
New Hampshire Yankee Division of Public Service Company of New Hompshire
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[]} g tj P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474 9521 3,
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a United States Nuclear Regulatory Commission June 28,1991 Attention:
Mr. Thomas T. Martin Page two cc:
Mr. Gordon E. Edison, Sr. Project Manager Project Directorate I-3 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ebe 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 inspector P.O. Box 1149 Seabrook, NH 03874 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 Inspector General United States Nuclear Regulatory Commission MNBB 6715 Washington, DC 20555 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555
4 New Hampshire Yankee June 28,1991 ENCLOSURE 1 to NYN-91101 JUNE 1991 STATUS REPORT FOR THE REVERIFICATION OF PULLMAN HIGGINS FIELD WELD RECORDE
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i JUNE 1991 STATUS REPORT FOR THE NEW HAMPSHIRE YANKEE PROGRAM FOR THE REVERIFICATION OF PULLM AN-HIGGINS FIELD WELD RECORDS A.
INTRODUCTION The following provides the status of the New Hampshire Yankee Reverification of Pullman Higgins Field Weld Records Program as of June 25, 1991. This program is being implemented in accordance with the program description submitted to the NRC on May 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 l
address these anomalies.
I L
B.
PROGRESS l
B.1 Weld Tabulation On April 22, 1991, Nuclear Energy Services (NES) personnel started the Task I weld tabulation effort.
This effort is designed to provide a list of field welds requiring radiography in order te, meet code. As provided in the program description, the basis for this list is engineering design documentation (drawings and change documents) and the N.
5 Code Data Reports. As of June 25, 1991, NES has processed a total of 1884 of the 3100 (approximately 60.7 percent) document packages for this effort.
The progress for each category of field weld which requires radiography by code is presented below, it is estimated that this task will be completed by July 12, 1991.
To ensure completion by this date, NES supplemented the project staff with an additional engineer.
This NES engineer began working on the weld tabulation portion of the project on June 17, 1991. His qualifications are commensurecte with those of the other NES personnel working on this project in the same capacity.
B.I.a ASME Section ill Ploing As of June 25, 1991, NES has processed 1852 document packages for ASME Section
!!! piping. The Condensate, Diesel Generator, and Service Water systems, are the only ASME 111 systems which have not yet been reviewed.
B.I.b ASME Section Ill Supports i-i l-As of June 25, 1991, NES is in the initial stages of reviewing the ASME Section 111 l
Support document packages.
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B.1.c ANSI B31.1 Pinine As of June 25, 1991, NES has processed 32 of the 54 (approximately 59 percent)
ANSI B31.1 Piping document packages.
B.I.d ASME Section Vill Unfired Pressure Vessels As of June 25, 1991, none of the ASME Section Vill Unfired Pressure Vessel document packages have been reviewed,
.During the portion of the weld tabulation effort conducted in the month of June, a total of two Requests for Engineering Services (RES) were generated. As described in the program description, an RES is the mechanism for identifying and responding to pottntial anomalies generated as part of the weld tabulation effort. Examples of the issues identified in these RESs include: welds not identified on the isometric drawings; clarification of a typographical error on an N 5 data package; and references to weld process sheets for Non.
Destructive Examination requirements.
NHY has responded to these RESs and has determined that they pertain to administrative issues with no impact on weld quality.
Therefore, these issues are not reportable to the NRC pursuant to the program description.
B.2 Radiocraoh Packare 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 (RIRs) are retained in the site records vault. This task also records the signa'ure of the individuals and organization reviewing the radiographic film.
As of June 25, 1991, NES has reviewed RIRs and radiographic film for 3586 welds.
This represents approximately 85.3 percent of the RIRs to be reviewed. It is estimated that this task will be completed by July 5,1991.
As described in the program description, the CAR is the mechanism for identifying and responding to potential weld record anomalies generated as pe of the radiograph review effort. During the portion of the radiograph review process conducted during the menth of June, a total of five Corrective Action Requests (CAR) were generated. Two additional-CARS pertaining to the field weld list and radiograph package inventory comparison were also generated. These two CARS are discussed in Sections B.3 and C.1 of this report. The wcld record anomalies identified as a result of the radiograph review all pertain to administrative deficiencies. None of these deficiencies affect the physical quality i
of the welds. NHY has completed the initial investigative action for four of the five CAR's and concluded that they do not contain anomalies which are reportable to the NRC pursuant to the program. description. NHY is in the process of performing the initial investigative actions for the remaining CAR. The following examples typify the nature of the minor administrative deficiencies identified in the CARS: legibility of radiographic film data; minor administrative data mismatches between RIRs and radiographic film (e.g..
numbers l
j transposed); questions regarding required approvals on RIRs and film availability. NHY is l-2
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correcting minor administrative discrepar.cies identified by these CARS and annotating the
- radiographic film package with a reference to the respective CAR.
As described in the May 1991 Status Report for the Reverification of Pullman-Higgins Fidd Weld Records Pr ogr a m,- NHY paviously initiated fifteen CARS during the May reporting period. As of June 25,1991, corrective actions have been formulated for all fifteen CARS, and verification of implementation of these corrective actions has been performed for tourteen of the fifteen.
B.3 Field Weld List and Radiocrat,h Comfarison 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 preside a single list which indicates that radiographic records are retained for field welds which require radiography by code.
As of June 25, 1991, NES is in the process of performing this comparison for the Reactor Coolant, Residual Heat Removal, and Safety injection systems, and the balance of the Chemical and Volume Control system. The comparisons reviewed to date indicated that for one field weld,1-CS 360-08 F0801, the requisite radiographic inspection report and radiographic film was unavailable. This records anomaly was documented in a CAR. NHY provided a report regarding this documentation deficiency to the NRC in letters dated June 10, 1991 (NYN 91092), and June 11, 1991 (N YN-91093).
Section C.1 of this report summarizes this CAR. It is estimated that the field weld list and radiograph comparison task will be completed by July 26, 1991.
C.
PERFORMANCE MEASUREMENT AND REPORTING C.1 Renorts to the NRC During the month of June, NHY determined that two weld documentation anomalies were reportable oursuant to the Program Description for the Reverification of Pullman-Higgins Field Weld Records. The first anomaly regards the lack of radiographic film and the radiographic inspection report for weld 1 CS-360-08 F0801. The second anomaly pertains to the radiographic film for 1-CS-318-02 F0202, for which the comparative densities, of the
,3enetrameters to those of the weld area of interest, exceed the density limi:ation ranges specified by the Code. This anomaly was identified after conducting an t stensive review and evaluation of the radiographic film for this weld to respond to issues raised by an NRC inspection.
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 anomalies were provided :o the NRC on June 10,1991 (NYN-91092), and June 11,1991 (NYN-91093). These written reports established that the identified weld record anomalies do not comoromise 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 3
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w e
I 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 anomalies, cause of the deficiencies, and corrective actions implemented.
D scription of Anomalies f
fullman-liiezins Field Weld 1-CS-360-08-F0801 As stated in NHY letters NYN 91092 and NYN-91093, dated June 10, 1991 and Jun-11, 1991, respectively, Pullman Higgins field weld 1-CS-360-08-F0801 is a circumferential butt weld on a four inch diameter section of piping in the Chemical and Volume Control System-(CVCS). Thi This weld connects a 90,s section of the CVCS is ASME !!!, Class 2, and Safety Class 2.
long radius elbow to a section of piping. This weld is located in the letdown line of the CVCS downstream of the Regenerative Heat Exchanger (Tag number CS E 2) and upstream of the Letdown Heat Exchanger (Tag number CS E 4).
This weld is physically located inside the Containment Building between valves 1 CS V149 and 1 CS V150 (Reference NHY P&lD 1-CS B20722).
A currently available Quality Assurance (OA) document, the Pullman-Higgins Field Weld Process Sheet, demonstrates that this field weld was radiographed in 1981 in accordance with the Non Destructive Examination (NDE) requi ements contained in the 1977 Edition of ASME Section til up through and including the W.'nter 1977 Addenda (the Code applicable to Seabrook Station).
The weld records package for weld 1 CS-360 08 F0801 has not yet been located and may be misplaced or discarded, it is currently believed that the RIR and the radiographs for this w tid 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 l
Seabrook 'fankee Document Control Center (SBYDCC) for final vault storage. Based on the l
above, the lack of weld record documentation.or 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 I
documentation regarding this weld and have concluded that the lack of the RIR and radiographs for this weld does not call into question t'.ne quality of this weld. Review of the weld process sheets for 1-CS 360-08-F0801 indicate that this weld was completed on L
March 27,1981, and on 'this same date, an external visual examination of this weld was performed. The attributes of this visual examination included weld reinforcement, undercut, are strikes, removal of purge dams, presence of 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 have determined that the initials of the Level 11 and the 'ANI indicate that the procedures had been completed and the radiographic film showed the weld to be of acceptable quality.
Other currently available QA documentation also L
demonstrates that the radiographic records for this weld were reviewed as part of the Seabrook Station as built verification process.
The available quality record demonstrates the process sheet was initialed by a Pullman-Higgins Level !! reviewer and an Authorized Nuclear Inspector (ANI). The ANI 4
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whose initials are on the weld process sheet, has reviewed the weld process sheets for iield weld 1.CS 360 08 F0801 and affirmed tbat his initials were affixed after he had reviewed the radiographic film and had determined the weld to be acceptable.
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 RIR 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.
Corrective Actions NHY has determined that the appropriate corrective actions for this records deficiency are to: 1) complete a radiographic examination of field weld 1 CS-360 08 F0801t 2) review the film ia 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 refuelit.g 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 Pullman-Hincins Field Weld 1-CS-318 02 F0202 As provided in NHY letter NYN 91092, dated June 10, 1991 Pullman Higgins 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 is ASME III, Class 2, and Safety Class 2.
This. weld connects a valve (1 CS-V325) to the piping and is also adjacent to a reducer. This weld is located in the letdown leg of the CVCS downstream of both the Regenerative (Tag number CS-E 2) and Letdown (Tag number CS-E-4) Heat Exchangers. This weld is physically located in the Primary Auxiliary Building which is outside the Containment Building. (Reference NHY P&lD 1 CS B20722). This field weld was'radiographed in 1981 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 packap,e for weld 1-CS 318 02-F0202 contains a Radiograph lospection Report (RIRi and the adiographic film. The RIR indicates that the radiograph views for all stations ( f this well are of acceptable quality. The RIR also contains the.
approval signatures of ihe Level ',1 Pullman Higgins reviewer, Authorized Nuclear Inspector (ANI), and the Yankte Atomic ' lectric Company (YAEC) reviewer. Additionally, another d
Level 11 Pullman-Higgins reviewer subsequently reviewed this RIR.
At the time this S
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I radiograph was reviewed, the ASME Code approval process included the Level 11 Pullman-Hig' gins reviewer and the ANI.
YAEC provided a r: view 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.
A review of the radiographic film for this weld was conducted on June 7,1991 to evaluate issues previously raised by a NRC Lesel til RT reviewer as a result of an inspection conducted on M ay 29 and 30, 1991.
This evaluation con fir me d that the required 4T sensitivity was achieved in the necessary penetrameters in the films for all stations of this weld. Additionally, the density through the body of the penetrameters meet the requirements of ASME Section V, paragraph T-234. The weld area of interest in each film also meets a density requirements of the same Code provisions. This review also revealed, however, that the comparative densities, of the penetrameters to those in the weld area of interest, exceed the minimum / maximum density limitation ranges specified in ASME Section V,
paragraph T 263.2. Specifically, the densities through the weld area of interest are 2.50 to 3.52 H&D. This technique shortcoming does not in itself preclude the ability to make an evaluation of the weld for unacceptable indications per the radiographic acceptance standards of NC 5320. As stated above, the densities in the weld area of interest are within the Code requirements of 2.0 to 4.0 H&D. Additionally, the sbarpness and contrast of the radiographs are such that unacceptable indications would not be masked.
Review, evaluation and inte,pretation of the weld area revealed no Code rejectable indications. These findings are consistent with the findings of previous evaluations and the findings provided on this weld's RIR. The June 7,1991 evaluation was performed by a Level !! RT reviewer and three Level
!!! RT reviewers, all of whom are emplo)cd by NHY or YAEC.
Furthermore, the process sheets for this weld document that a post weld visual examination of the internal and external weld surfaces was performed for this weld on October 22, 1981.
The internal examination attributes were for oxidation, concavity, convexity, undercut, and unconsumed insert, and in all instances were found to be acceptable for this weld. The external examination attributes included weld reinforcement, arc strikes, undercut, transition, purge dam removal, and suitability for NDE, and in all instances were found to be acceptable for this weld.
Cause of Deficiency NHY has reviewed the identified records deficiency and has determined its cause to be personnel erre r on the part of Pullman Higgins and subsequent independent NDE resiew personnel. The NDE review personnel apparently neglected to compare the penetrameter density range wi h that of the weld arer. of interest density range to ensure that they were t
in compliance with the minus 15% and plus 30% criteria provided in the Code.
This oversight appears to be due to the fact that both the penetrameter and the weld area of interest exhibited the acceptable Code required densities.
Corrective Actions NHY has determined that the appropriate corrective actions for this record deficiency are to: 1) complete a radiographic examination of field weld 1 CS-318 02-F0202; 2) review tac film in accordance with our present program requirements; and 3) include the radiograph 6
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and the required radiographic review forms in the NHY records management system. When completed, actions 1, 2, and 3 above will etante compliance with the Code.
NHY will complete these corrective actions during the refueling outage currently scheduled to begin on July 27, 1991.
l If similar anomalies are found in the future, long term corrective actions will include i
the evaluation of such anomalies, as a group, for generic implications and possible additional corrective actions, C.2, NHY NOG Surseillance The NHY Nuclear Quality Group (NOG) is performing three separate surveillance l
activities for the reverification effort. These and their progress as of June 25,1991 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 the future.
The second NHY surveillance is to sample 20 percent of the field welds from each l
of the isometric and suppe ! drawings previously reviewed by NES as part of the Task 1 l
weld tabulation effort. This surveillance addresses the procedural requirements outlined in NES Procedure 83A5643, " Review of Drawings." As of June 25, 1991, NHY Nuclear Quality Group personnel are in the process of performing this surveillance for the Chemical and Volume Control Systerr., Residual Heat Removal system, and the Reactor Coolant system.
l The third NHY surveillance is to sampic 20 percent of the radiograph packages, by l
system, that NES has reviewed as part of the Task 2 effort. This surveillance addresses the procedural requirements outlined in NES Procedure 83A5462, " Review of Radiographs." As of June 25, 1991, NHY Nuclear Quality Group personnel are in the process of perfortning this surveillance for the Chemical and Volume Control System.
NHY is in the process of assigning additional Nuclear Quality Group personnel to the aforementioned surveillance efforts. With these additional resources, it is estimated that these surveillances will be completed by July 31, 1991.
C,3 N,ES Manacement Oversicht NES also provides management oversight regarding the activities being performed by the NES personnel as part of the reverification of weld records project, On June 7, and June 18,1991, an officer of NES visited Seabrook Station to monitor the status and progress i
of the project, i
i On May 24,1991, NES issued Audit Report NOA 3204 for the Quality Assurance l
Audit conducted on May 16, and 17,1991. This audit pertained to the activities being I
performed by NES on site, and it included a sampling of completed work to ensure i
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compliance with procedures. The audit report concluded that the NES procedures for the review of radiographs and drawings provide adequate controls for this project and that these procedures have been effectively implemented.
C.4 Performance Monitorin.g NHY also monitors the performance of the rescrification 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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