ML20082P442
| ML20082P442 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/06/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91142, NUDOCS 9109100331 | |
| Download: ML20082P442 (23) | |
Text
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New Hampshire 17g ,
T,d c. reis.osoum President and Chief Executive Officer NYN 91142 September 6,1991 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
References:
(a) Facility Operating License No. NPF 86, Docket No. 50 443 (b) PubMe Meeting Iletween New Ilampshire Yankee and the NRC conducted on June 21, 1991.
(c) NHY Letter NYN 91100 dated June 26,1991, " Request for Inspection Report and Clarification of Radiograph Quality iss u es," T. C.
Feigenbaum to T. T. Martin.
(d) NRC Letter dated June 27, 1991, Response to NHY Letter NYN-91100 dated June 26, 1991, T. T. Martin to T. C. Feigenbaum.
(c) NRC Notice of Violation hegarding Inspectiou Report 50-443/91 12, dated June 28, 1991.
NHY Letter NYN-91106 dated July 8. 1991, " Reply to Notice of (f)
Violation Regarding Inspection Report 50-u3/v1 12", T. C. Feigenbaum to T. T. Martin
Subject:
Pullman Higgins Weld Radiograph Reinterpretation Program Gentlemen:
On September 4,1991, a conference call was held between New Hampshire Yankee (NHY) and NRC Region I to discuss the status of the' weld ra.fiograph reinterpretation efforts. During the call, the NRC requested that New Hampshire Yankee submit a written description of the program for the reinterpretation of a certain populstion of Pullman-Iliggins radiographic fGm to assure compliance with ASME Code requirements. This letter transmits the NHY program for performing this reinterpretation. This letter also confirms New Hampshire Yankee's intention to complete this Pullman-Higgins radiographic film reinterpretation effort as detailed in the attached Program Description.
I 9109100331 910906 ;
PDR ADOCK 05000443 f p PDP O New Hompshire Yankee Division of Public Service Company of New Hampshire
- e. . e x 3 . Seabrook, NH 03874
- Telephone (603) 474-9521 * { ('
_09 % 96
United States Nuclear Regulatory Commission Sr ptember 6,1991 Attention: Document Control Desk Page two Should you have any questions regarding this matter, please contact Mr, Neal A.
i Pillsbury, Director of Quahty Programs at (603) 474-9521, extension 3341.
Very truly yours, ffpg ile Ted C. Fei enbaum Enclosure TCF:EWD/ss cc: Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of Reactor Projects U.S. Nucicar Regulatory Commission Washit.gton, DC 20555 Mr. Ebe C. McCabe, Chief Reactor Projects Section U.S. Nucleac Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Thomas T. Martin, Regional Administrator Region 1 475 Aller. dale Road King of Prussia, PA 19406 Mr. William Bateman Regional Operations Staff Chief Office of the Exceutive 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 0387t 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 .
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New Hampshire Yankee
' Septensber 6,1991 1
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ENCLOSURE TO NYN 91142 ,
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- New Hampshire Yankee September 6,- 1991
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PROGRAM DESCRIPTION FOR THE REINTERPRETATION OF PULLM AN-HIGGINS R ADIOGRAPHIC FILM T
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PROGRAM DESCRIPTION
- FOR Tile REINTERPkETATION OF PUl.lA1 AN HIGGINS R ADIOGR APHIC Fil.M I
'A. BACKGROUND This program was developed in response to the following:
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.. NRC Inspection Report 50 443/91 12;
. Preliminary 'results of NRC Inspection Number 50-443/91-27; and,
- . . Telephone conversations between the NRC and NilY that occurred on August 30, 1991 and Sept' ember 4,1991, i.
NRC Inspection Report 50-443/91 12, dated June 28,1991 l Reference (e)l, described the review of thirty two (32) weld radiograph sets performed by Pullman Higgins. The NRC
-: concluded that six (6) of the radiographic record sets-were unacceptable with respect to compliance with the ASME Code ~ requirements for radiographic film. In a letter dated July
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8, 1991,- (NYN 91106) [ Reference (f)), N11Y responded to and _ disputed the Notice of Violation. However, in- an effort to be conservative and fully responsive, as well as to eliminate any doubt regarding the physical quality of the welds, NilY also committed to a series of corrective actions. - Specifically,- NilY committed to:
. -Reradiograph 'the six (6) subject welds;
. Review the film in accordance with existing program requirements; and.
. Include-the new radiographs .diographic inspection reports in the N11Y records management system as a supplement to the previous!y existing Code compliance radiographs for these welds.
_ During the current refueling outage, NIIY.has reradiographed the six (6) welds cited in the NRC Notice of Violation. Note that NilY had previously committed to teradiograph one of these field welds, (1 CS-318 02 F0202), due to a self-identified anomaly regarding
. comparative film density. NHY reported this anomaly to the NRC in a letter dated June
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. l 10,.1991 (NYN 91092). The following is a list of the six (6) field welds which were rcradiographed. ;
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Weld-Identification Numbtrr Reason for Retadiocraohv l
1-CS 355 05-F0501 Notice of Violation
}
1 CS 355-01 F0109 Notice of Violation 1-CS 355 08-F0801 Notice of Violation 1-CS 355-01-F0102 Notice of Violation i 1
1 CS 302-04-F0404- Notice of Violation
- 1-CS 318 02 F0202 Notice of Violation and comparative film density anomaly.
NHY reviewed the radiographic film in accordance with the current requirements of NHY' programs and procedures. The results confirm the acceptable physical weld quality for -
all six (6) welds. These results also agree with the conclusions drawn by the original I ' reviewers during construction and the more recent reviews conducted by NHY in June 1991.
4 These new radiographs and radiographic inspection reports have been included in _the NHY Records Management System as supplements to the existing Code compliance radiographic records for these welds.
During the. weeks of August 19 and 26,1991, the NRC conducted Inspection 91-27.
The :NRC inspection scope included a review of additional Pullman Higgins field weld radiographic film packages as well as a tesm inspection of the NHY Weld Records 4
Reverification Program. The field weld radiograph inspection initially reviewed the radiographs for fifty-eight (58) randomly selected, safety related, Pullman-Higgins field welds
- over all time. During the second week the NRC reviewed an additional, randomly selected; 4
l population of thirty-five (35) safety related field welds performed by Pullman Higgins prior
- to J uly .1, .1982. At the August 30, l'991 inspection exit, the NRC informed NHY that' their a- radiograph review had revealed 'one (1) additional non-compliance with the' ASME Code 4
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- acceptance criteria, and that this weld would be included with the six (6) previous welds-cited in the June 28,1991 Notice of Violation [ Reference (e)], The non compliance involved failure to meet Code density requirements associated with radiographic film for Pullman-Iliggins field weld 1 CS 318-02-F0205. During the ongoing two-week NRC inspection, NHY reradiographed field weld 1 CS-318 02 F0205. NilY reviewed and accepted the radiographs per the requirements in existing NHY programs and procedures. The NRC also reviewed the current radiographs for field weld 1 CS 318-02-F0205 as well as the reradiography results associated with ten (10) other radiograph sets. These included the four (4) missing radiograph sets that were identified by NHY prior to and during the conduct of the Weld Records Reverification Program, in addition to the radiograph sets from the six (6) Notice of Violation welds, as previously discussed. The NRC found the reradiography results pertaining to these eleven (11) Pullman-Higgins field welds to be in compliance with Code j; - requirements. In summary, these welds are identified as follows:
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Weld Identification Number R eference i -- 1-CS 355 05-F0501 NRC Inspection Report 91-12 1 CS 355 01 F0109 NRC Inspection Report 91-12 l
1-CS 355 08 F0801 NRC Inspection Report 91-12 1-C'S 355 01 F0102 NRC Inspection- Report 91-12 i 1-CS 302-04 F0404 N,' C Inspection Report 9112
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1-CS 318-02-F0202 ~- NRC Inspection Report 91-12
{ 1-CS-318-02 F0205 - Preliminary results of NRC Inspcction 9127 1 CS-328-02-F0204 NYN-91023 1-CS 360 08-F0801 NYN 91092 and NYN-91093
- - CBS-1201 07-F0701 NYN 91105 4
'1 FI 188-01-F0150c NYN-91130 i.
Based on the one (1) non-compliance identified.during the conduct of NRC Inspection 91-27, in combination with the six (6) welds from-Inspection 91-12, the NRC expressed a 2
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., u concern with Pullman Higgins radiographs performed prior to July 1,1982. At the inspection exit and-in subsequent-telephone conversations, the NRC requested that NHY analyze the seven (7) welds found to be unacceptable, for common factors and to develop a self inspection ~ program for the welds that met these factors. This Program Description addresses the NHY analysis that derived the common factors, the population of welds with these factors, the proposed review method, and resolution methods to be utilized, B, SCOPE The following defines the population of welds to be reviewed as part of the NHY weld . radiograph reinterpretation effort, The subject population is based on a common factots and generic implications analysis of each of the welds for which the NRC identified concerns regarding radiographie film quality during their review of radiographic film for inspections conducted in May, June and August 1991. The review- and analysis included a heightened focus on the seven (7) Notice of Violation welds and the results of an already-on going NHY reinterpretation of film for welds that either closely approximate or are {
l bounded by the common factors criteria identified in the following paragraphs. These specific welds were identified in Section A of this Program Description.
As of September 4,1991, the review of the weld radiograph packages for those welds of concern to the NRC revealed that the welds had the following relevant factors in common.
l For all Welds of Concern-r The welds of concern are predominantly located in the Chemical and Volume Control Sy;iem (CS), and are ASME Code Class 2.
For the Seven (7) Notice of Violation Welds All of the welds are of three (3) inch nominal pipe size.
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. Six of the welds are transition welds (i.e., pipe spool to valve), and one is a pipe spool to an elbow without a transition.
. The radiographic technique umized for all of the welds was double wall exposure, double wall viewing utilizing source side penetrameters.
. All of the radiographs were accepted by Pullman-liiggins Level 11 (or Level lit, in one instance) reviewers, without the benefit of a second, independent Pullman-Higgins Level ill review. The review by the Pullman-Higgins Level 11 (or 111) was also accomplished prior to September 27, 1982, the date when the Scabrook Project committed to an additional Level 111 Pullman-Higgins review of film packages before sending the completed weld packages to the 100 percent Yankee Atomic Electric Company (YAEC) review process for final acceptance.
. The concerns raised by the NRC regarding the seven welds pertained to radiographic film quality; six regarding 4T sensitivity, and one regarding comparative film density.
No physical weld quality issues were identified.
Based on the above listed commonalities and the aforementioned results of some specific reinterpretations of welds that meet or approximate these specific common factors criteria, NHY has chosen the following criteria to define the population of welds to be reviewed as part of the radiographic film reinterpretation effort.
. Any Pullman-Higgins field weld, that requires radiography in order to meet the ASME Code, that is three (3) inch nominal pipe size and smaller, where the initial Pullman-Higgins Level 11 (or III, where the only Pullman-Higgins review was performed by a Level Ill) review signature occurred prior to October 1,1982, and where the double wall exposure, double wall viewing radiographic technique was ued with source side penetrameters, excluding any welds previously accepted by the NRC, 5
As of September 6,1991, NHY has identified a total of 152 Pullman Higgins field welds which appear to satisfy the aforementioned criteria. These welds are currently being reviewed to ensure that both the criteria and the listing of welds correctly envelope the NRC and NHY concerns. Therefore, it should be noted that this total is subject to change after all reviews of the subject weld population have been completed. Thirty-five (35) of these 152 field welds have been previously reviewed by the NRC and found to be acceptable.
Therefore, there are 117 field welds which require radiographic reinterpretation under this program. Attachment A to this Program Description provides a listing of the 152 welds comprising the scope of this review program. This Attachment also indicates the weldt previously found acceptable by the NRC and provides references to the applicable NRC inspections reports.
C. REVIEW METHOD NHY will conduct a 100 percent reinterpretation of the radiographs for the subject weld population currently identified as 117. This reinterpretation will reevaluate the Code acceptability of each weld and its radiographic film in accordance with NHY procedure 11230, " Level Ill Review of Radiographic Film ' This reinterpretation and reevaluation will be conducted in two distinct phases. First, in an effort to be fully responsive and conservative, on September 3,1991, NHY initiated a thorough reinterpretation and common factors analysis of the indicated population of radiographs. This analysis is being conducted by three (one YAEC and two Stone & Webster Engineering Corporation) Level 111 certified examiners in accordance with the criteria discussed above. These reviews will provide early identification of any common factors of concern and will identify any radiographs or weids of potential quality concern in order to better coordinate any potential reradiography with other work currently being performed as part of the refueling outage. NHY anticipates that this NHY analysis will be completed tay September 11, 1991.
The se,:ond phase of the reinterpretation effort is to be conducted by an independent Level 111 reviewer, C.J. Hellier, of Hellier Associates, Incorporated. This reinterpretation 6
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will include 100 percent of the subject population of welds, and it will result in Mr. Hellier's l 1
documented position regarding Code acceptability for each of these welds and their '
- associated radiographs. Mr. Hellier will be assisted by two other Level til certified reviewers, but the final determination on Code acceptability for each weld will be his own.
If, as a result of this review, it is determined that either the quality of a weld or its radiographic film is not in accordance with Code requirements, the subject weld will be j identified as requiring corrective action. This radiographic reinterpretation began on !
September 6,1991, and it is anticipated that it could be completed by September 12, 1991, 1
-D. CORRECTIVE ACTIONS !
If anomalies regarding either weld quality or radiographic film quality are identified during the conduct of the reinterpretation of radiography, NIlY will implement appropriate j corrective actions to resolve each anomaly. While the exact type of corrective action (s) will l nced to correspond to the nature and extent of the ir ,,maly, potential corrective actions j include the following:
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. Reradiograph the subject field welds, review the resultant film in accordance with this program and the current NHY procedural requircruents, and include the resultant radiographs and radiographic inspection reports in the NHY Records Management System; or
. Specify and justify other corrective actions where necessary.
NHY intends to complete the above film reinterpretations and, where possible, the corrective . actions prior to September 16, 1991. In the July 8,1991 letter, (NYN 91106)
[ Reference (f)], NHY committed to provide the results of any corrective actions taken or planned in response to the NRC Notice of Violation [ Reference (e)] on September 15, 19_91.
The date of submittal bas been subsequently extended to September 16, 1991. As part of the September 16, 1991 report, NHY will include the results of this reinterpretation program and any corrective actions taken or pending as a result of implementing this program.
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ATTACHMENT'A - PAGE 1.of 131
.OTHER- -
CS - PIPE -TO VALVE . NRC RPT ' NRC ~NUREG
'91-12 : INSPECT. 1425-
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302-04-F0462 . 3"-.
P-V80 302-04-F0403 c 3" P-V117 ..X '
302-04-F0404 3" P-V117 -X .-.
303-05-F0502 3" P-V628 'X -
303-05-F0503 3". P-V628 X 303-05-F0504 3". P-V627 ,
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303-05-F0505 3" P-V627 318-01-F0102 . 3" - P-V321 318-01-F0103 3" P-V321 318-02-F0202 3* - P-V325 X .
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340-01-F0102 - 3" P-V251 !
340-01-F0104 3" :P-V195 340-01-F0105 3" P-V195 355-01-F0102 ' 3" P-V140 X' 355-01-F0103 - 3" P-V140 l 355-01-F0104 3" -P-V182 X 355-01-F0105 3* P-V182 1
- 355-01-F0106 3"- - P-V138 355-01-F0107 3" P-V138 355-01-F0108 3" P-V141 355-01-F0109 3" P-V141 'X
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ATTACIDIENT A PAGE 3 of 13 OTHER CS - PIPE Oil FITTING TO NRC RPT NRC NUREG -
91-12 INSPECT, 1425._
COMPONENT 360-12-F1202 3- E-Ht Exchanger E, 377-04-F0401 5" P-CSTK1 378-03-F0301 3" P-CSTK1 l
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ATTACIC4ENT A 'PAGE 4 of.'.137
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CS - PIPE TO TEE. ETC. .NRC RPT NRC NUREG 91-12 INSPECT. 1425 k
301-05-F0503 3* P-E 301-06-F0601 3 P-E -
301-06-F0602 2* P-R 302-01-F0103 3" P-E 302-03-F0301 3* P-T 302-03-F0302 3*- P-T X 302-05-F0502 3* P-E 303-03-F0301 3* P-E X 303-03-F0303 3* P-E 303-04-F0401 3* P-T 303-05-F0501 3* P-E 318-01-F0101 3" P-E 324-01-F0104 3* P-T 324-02-F0201 3* P-T 327-01-Fol04 r P-E 327-01-F0105 3" P-E 327-02-F0201 3* P-E 327-02-F0202 3* P-E 327-02-F0204 3* P-E 327-02-F0205 3* P-E 328-01-F0102 3* P-E 328-01-F0103 3* P-E 328-02-F0203 3* P-E 328-02-F0205 3* P-E 328-03-F0301 2* P-R 332-02-F0202 2* P-R 355-01-F0101 3* P-E
ATTACHMENT A OTifER '
tJRC HPT f4RC FJUREG CS - PIPE TO TEE. ETC.91-12_ INSPECT, 1425 ,
355-01-F0113 3" P-E X 355-02-F0204 3" P-E 355-03-F0304 3" P-E X 355-04-F0404 3" P-E 355-05-F0501 3" P-E X 355-06-F0602 3" P-E 355-06-F0603 3" P-E 355-07-F0703 3" P-E X 355-09-F0905 3" P-E X P-E 355-09-F0906 3" 356-01-F0104 3" P-E 356-01-F0105 3" P-T 357-05-F0504 2" P-T 360-03-F0301 3* P-E 360-03-F0303 3" P-E X 360-04-F0401 3" P-E X 360-04-F0402 3" P-E 360-07-F0702 3" P-R 360-12-F1201 3* P-E 363-01-F0103 2" P-R 3" P-E X 366-02-F0203 366-32-F0205 2" P-T 366-02-F0206 3" P-E 378-01-F0102 3" P-E 432-03-F0303 3" P-E
ATTACHMENT'A PAGE 6 of 13
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OTHER' CS - PIPE TO PIPE PJRC RPT NRC NUREG 91-12 INSPECT. 1425 .
302-01-FD102 3" P-P X 302-01-F0104 3" P-P X 302-03-F0305 3" P-P X 303-03-F0202 3" P-P 303-04-F0405 3" P-P 318-04-F0402 3" P-P 324-02-F020't 3" P-P 327-01-F0102 3" P-P 327-01-F0103 3" P-P 327-02-F0203 3" P-P 327-02-F0210 3" P-P 327-02-F0211 3" P-P 328-01-F0101 3* P-P 328-02-F0201 3" P-P 355-01-F0111 3* PP 355-02-F0202 3" e .- X 355-02-F0203 3" P-P 355-03-F0303 3" P-P 355-05-F0502 3" P-P 355-05-F0503 3" P-P 355-06-F0601 3" P-P X 355-08-F0809 3" P-P 355-09-F0902 3* P-P 355-09-F0903 3" P-P.
355-09-F0910(BMR) 3" P-P 360-03-F0302 3" P-P 360-04-F0403 3" P-P
ATTACHMEiBT A ' PAGE 7.of'13 OTHER -
CS - PIPE TO PIPE NRC RPT NRC NUREG-91-12 INSPECT. 1425 364-03-F0307 - 3* P-P 365-02-F0201 2" P-P 366-02-F0204 3" P-P X .
378-03-F0304 3" P-P 432-03-F0304 3" P-P- X 1
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OTHER RC - P!PE TO VALVE NRC RPT NRC NUREG .
91-12 INSPECT. 1425 1-RC-97-Oi-F0f 05 3* P-V459 X (BMR) 1-RC-97-01-F0106 3" P-V459 1-RC-97-03-F0301 3- P-V460 1-HC-97-03-F0304 3" P-V81
ATTACIDfEWT A- PAGE 9 of.13
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OTHER RC - PIPE TO PIPE NRC RPT .NRC NUREG. '
91-12 INSPECT. 1425 .
1-RC-97-03-F0309 3"- P-NOZZLE 1-RC-97-02-F0204 3" - P-P i
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OTHER PJRC RPT NRC fl0 REG HMW PIPE TO PIPE 91-12 INSPECT. 1425 P-P X 1-RMW-1102-05-F0506 3"
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ATTACIDfENT A PAGE 11 of 13 OTHER .
SB - PIPE TO ELBOW NRC RPT NRC NUREG 91 INSPECT. 1425 1-1307-07-F0701 3* P-E 1-1304-01-F0103 3' P-P 1-1304-02-F0201 3" P-P 1-1307-08-F0801 3' P-P
ATTACEMEhT A PAGE 12 of.13 OTHER ^
Rif - PIPE TO FITTING ' NRC HPT NRC NUREG 91-12 INSPECT. 1425 ,
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