ML20082J845
| ML20082J845 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/23/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91130, NUDOCS 9108290031 | |
| Download: ML20082J845 (7) | |
Text
w New Hampshire Y
hh Ted C. Feigenbovm Preddent and Chief Executive Olhcer NYN 91130 August 23, 1991 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
References:
(a)
Facility Operating License No. NPF-86, Docket No. 50 443.
(b)
Transcribed Public Meeting Between New Hampshire Yankee and the NRC conducted on April 10, 1991.
(c)
NilY Letter NYN 91076 dated May 13, 1941,
- Transmittal of the Program Description for the Reverification of Pullman-iliggins Field Weld Recntds", T. C. Feigenbaum to T. T. Martin.
Subject:
Report of Weld Record Anomaly For Field Weld 1-F1188 01-F0150 i
Gentlemen:
In the April 10,1991 PubL Meeting between New llampshire Yankee (NilY) and the NRC [ Reference (b)], and as provided in the NiiY Program Description for the Reverification of Pullman-Higgins Field Weld Records, transmitted to the NRC on May 13, 1991 [ Reference (c)], NilY agreed to provide the NRC with a written report of any wcld 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 is required.
Accordingly, enclosed please find a " Report of Weld Records Anomaly for Field Weld 1-F1 188-01-F0150' This report relates to a record anomaly which NilY determined on August 21, 1991, was reportable pursuant to the program description.
Subsequent to discussions with Region i personnel, NHY is submitting the Justification for Continued Operation for the record anomaly in this letter, As provided in Enclosure 1, t he Radiographic Inspection Report and associated radiographs for Pullman liiggins Field Weld 1-F!-188-01-F0150 have not yet been located and may be misfiled or inadvertently discarded. Other quality documentation demonstrates that an acceptable weld was installed, radiographed, and reviewed by the required, qualified personnel. NIIY has evaluated this records anornaly and has determined that it does not adversely affect or call into question the physical quality of weld 1-F1-188-01-F0150 or other Seabrook Station welds.
In order to correct the record anomaly, this weld will be re-radiographed during the 1991 Seabrook refueling outage, the film will be reviewed in accordance with our present program requirements, and the film will be placed in the records vault to complete the required quality document set. The Justification for Continued Operations for this anomaly contained in Enclosure t has been reviewed by the Station Operation Review Committee (SORC) and deteimined to be acceptable.
t 9108'290031 910823 PDR ADOCK 05000443 i
P PDR rhl i
New Hampshire Yankee Division of Public Service Company of New Hampshire I
P.O. Box 300
- Seabrook, NH O'3874
- Telephone (603) 474 9521
l
, United States Nuclear Regulatory Commission August 23, 1991 Attention:
Document Control Desk Page two Should you have any questions regarding this matter, please contact Mr. Neal A.
Pillsbury, Director of Quality Programs at (603) 474-9521, extension 3341.
Very truly yours, ghWb kW Ted C. Fe) nbaum TCP:J ES/act Enclosure cc:
Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 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. Thomas T. Martin, Regional Administrator Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. William Bateman Regional Operations Staff Chief 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, Nil 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 i
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ENCLOSU R E - 1 REPORT OF WEL D RECORDS ANOM AI..Y FOR FIELD WELD 1-F1-188-01-F0150 -
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REPORT OF WEl,D RECORDS _ ANOM AI,Y FOR FIELD WELD l FI 188-01 F0150 1.
Introduction
- In the April 10, 1991 Public Meeting between New Hampshire Yankee (NilY) and the NRC, and as provided in the NHY Program Description for the Reverification of Pullman-!!iggins Field Weld Records, transmitted to the NRC on May 13, 1991, NHY 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. NilY determined that this anomaly required NRC notification on August 21, 1991.
a lack of the Radiographie Inspection Report (RIR) and The identified deficiency is
)
. radiographic film for Pullman-Higgins field weld 1-F1-188-01 F0150.
NHY has evaluated this record deficiency and has determined that it does not adversely affect or call into question the physical quality of weld 1-FI-188-01-F0150 or other Seabrook Station welds at this time. The following provides the code requirements, 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.
- 11. Code Reuulremenh American Society of Mechanical Engineers (ASME), Section 111, Subsection NCA 4134.17,
'Ouality Assurance Records", and American Nationals Standard Institute ANSI N45.2.9 - 1974, entitled. "Requ3cments 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.
111. Description of the Deficiency, Pullman-Higgins field weld 1 F1188-01-F0150 is a circumferential groove weld on a twelve inch-diameter spare electrical penetration (E-10) outside of the Containment Building. This electrical penetration is ASME 111, MC Class, and the weld is a Category B joint. This weld connects the penetration sleeve to a prefabricated end cap. This weld joint employs a machined in backing ring, which fits inside of the end cap assembly. In some cases, this type of joint configuration does not permit radiographic examination. In accordance with ASME Section III, Subsection NE-52211.1, when the joint detail of a penetration assembly does not permit radiographic examination, ultrasonic examination plus liquid penetrant or magnetic particle examination of the completed weld may be performed. On May 4,1982, NHY issued Engioecting Change Authorization (ECA) 74/1663A, to adopt the above stated ASME Code exception for the electrical penetntions.
A currently available Ouality Assurance (OA) document, the Pullman-liiggins Field Weld
~ Process Sheet, demonstrates that this field weld was radiographed on June 18, 1982 in accordance with the Non Destructive Excmination (NDE) requirements contained in the 1977 1
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Edition of ASME Section lit up through and including the Winter 1977 Addenda (the Code applicable to Seabrook Station). The process sheet also references the above stated ECA, and it is clear that at one point, utrasonic examination was considered for this weld. At a subsequent point the Weld Process Sheet Hold Point for ultrasonic examination was deleted.
1 Furthermore, no other process sheets could be located for this weld which indicate that an I
ultrasonic examination was performed. In addition, magnetic particle examination for this weld was performed on June 16, 1982. The examination results were acceptable with no rejectable indications located.
The weld records package for weld 1.F1-188 01-F0150 has not yet been located and may be l-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 F1188 01 F0150 indicates that this weld was completed on June 8,- 1982, and on June 9,1982 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 OA 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.
IV. Cause of Deficiency l_
NHY has reviewed - the identified records deficiency and has determined its cause to be L
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 racords to YAEC for review and failed to l-transtnit these documents to the SBYDCC for ultimate archival in the Seabrook Station
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- records management system, i:
.V.
Corrective Actions
- NHY has determined that the appropriate corrective actions for this accords deficiency are to: 1) perform a radiographic examination of field weld 1 F1-188-01 F0150; 2) review the
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film in accordance with our present program requirements, and if the weld joint configuration does not preclude radiographic examination, 3) include the radiograph and the required radiographic review forms -in the NHY records management system.
If review of the radiographs indicates that the weld joint configuration precludes acceptable radiographic 2
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examination,- NHY ' with
- 1) perform an ultiasonic examination of -field weld 1 FI 188 01-
-F0150; 2) review the results of the ultrasonic examination in accordance with our present program. requirements; and 3)-include the results of the ultrasonic examination in the NHY
-records management - system.
When completed, the actions described for either the radiographic or ultrasonie examination, will ensure compliance with the Code. NHY will complete these corrective actions during the current refueling outage.
If similar anomatics 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.
i-VI. Justification for Continued Oneration 4
The~ following provides a Justification for Coutinued 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 l_
implemented. This JCO demonstrates that the identified weld records deficiency does not
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_ produce any reduction in the protection provided for the health and safety of the public.
- As provided in Section !!! above, NilY has conclusively determined that the radiographic l
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' film for field weld 1-FI-188-01 F0150 existed and was read by qualified reviewers and the weld was determined to be of acceptable quality as indicated on the wcld process sheet.
l As stated above, field wcld 1-FI 188-01-F0150 is located on a sparc electrical peuttation j
outside ' the Containment Building., This penetration serves as a Containment Building i
pressure boundary. In March of 1986, and again in November of 1989, NHY conducted the
-Reactor Containment Building Integated Leakage Rate Tests, Type A.
During these tests, j
the Containment Building was p'essurized to peaks of 65.015 psia and 65354 psia i
respectively, and, in both casca, it was determined that the observed leakage = rate was acceptable, In addition, in March 1986, NHY conducted the Reactor Building Structural i-Integrity Test.
During this test, _the Containment Building was pressurized to 60.2 psig.
During.the above' stated tests,: there are no records of any discrepancies that would cause
. the -' integrity of field weld-1 F1 188 01-F0150 to be questioned.
-Based on the above, thera are no outstanding questions regarding the quality of this field weld and thus no outstanding questions regarding the integrity o.f this electrical penetration I
_ and the Containment Building. Additionally, as provided above, the Containment Building has been subjected to integiity testing. Throughout testing and operation, no problems with I'
- this weld have been identified. Therufore, since the identified records deficiency does not vpromise the integrity of the Containment Buildhg, nor affect the operation of Scabrook dtation, there is no reduction in the protection provided for the health and safeq af the p s tic.
NHY'has also performed a safety evaluation. for this JCO and.has determined that an
~unreviewed safety question does not exist. Specifically, since the identified records anomaly
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does not ~ compromisc 'the integrity of the Containment Building, it does not increase the j
' probability or consequences of accidents or malfunctions previously evaluated in_ the Final l
Safety Analysis Report (FSAR). The mere presence of a records anomaly does not introduce j
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a new failure mechanism nor doestit 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 an defined i
in the basis for-any technical specification will not be reduced by this records anomaly since it does not compromise the-integrity of the Containment 13uilding nor affect the operation -
of Seabrook Station, 11ased on the foregoing, the identified records anomaly does - not present an unreviewed safety question-asit does not compromise the. integrity of the Containment 13uilding, nor -
~ ffect the operation of Seabrook Station. Thus, this records anomaly does not reduce the a
protection provided for the health and safety of the public.
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