ML20086Q629
| ML20086Q629 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/23/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91196, NUDOCS 9112300271 | |
| Download: ML20086Q629 (11) | |
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$ewHampshire Y
(h Ted C. Feigenbaum Preddent and Chief Executive Officer NYN-91196 December 23, 1991 Director, Office of Enforcement United States Nuc! car Rege'atory Commission Washington, D.C.
20555 Attention:
Document Control Desk Ref erences:
(a)
Facility Operating License No. NPF-86, Docket No. 50-443 (b)
USNRC Letter dated November 25, 1991, " Notice of Violation and Proposed imposition of Civil Penalty - $100,000", T. T. Martin to T. C.
Feigenbaum l
Subject:
Reply to a Notice of Violation Gentlemen:
In a letter dated November 25,1991 [ Reference (b)], the NRC transmitted to New lianapshire Yankee (NilY) a Notice of Violation and Proposed imposition of Civil Penalty for $100,000 regarding three violations pertaining to weld radiographic records at Seabrook Station. Pursuant to the provisions of 10 CFR 2.201, and in accordance with the instructions provided in the Notice of Violation, enclosed please find NilY's responu to the cited i
violations. NilY has arranged for a wire transfer of $100,000 as remittans ( r the civil l
penalty imposed.
As described in the enclosure, NilY has chosen not to contest the cited violations.
NilY also does not seek to mitigate the imposed civil penalty nor to probe the stated bases for the 100 percent escalation. NilY does, however, offer the following dirifications and comment with regard to Violation I, which precipitated the civil penalty.
NilY identified the 47 weld radiograph deficiencies included in Violation I during the conduct of the Weld Radiograph Reinterpretation Program (WRRIP).
This was a comprehensive radiograph reinterpretatico program that NHY implemented in a timely manner following identification of a weld radiograph concern. The scope of this program was based on an evaluation of current and previous weld radiograph concerns for common factors and generic implications. For completeness, the WRRIP reviewed Id0 percent of the subject population of radiographic record packages. NHY chose to implement the WRRIP in an ultra-conservative manner such that any marginally Code acceptable weld raciographic packages were identified as requiring teradiography. These conservatisely identified welds subsequently became the deficiencies cited in Violation I.
NilY specifically chose a
conservative approach so as to eliminate any potential for doubt regarding the Code acceptability of the subject welds. 'This was considered to be the most efficient approach for resolving the remaining weld issues in a timely and conclusive manner.
9112300271 911223 PDR ADOCK OiOOO443 k
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p [',(} g; R 3 New Hampshire Yonkee Division of Public Service Company of New Hampshire I
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P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474-9521
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United States Nuclear Regulatory Commission December 23, 1991 Attention:
Document Control Desk Page two i
NHY agrees that a subset of the 47 weld radiograph pac!: ages did not conservatively demonstrate strict compliance with all filn quality requirements prescribed by the Code. It is the NHY belief, however, that the quality of these welds was not indeterminate as stated in the Notice of Violation. It remains the NilY belief that the film density and sensitivity of all 47 welds were such that the quality of the welds in question could be determined from-the original film records on file.
NHY emphasizes that all of the weld radiograph issues cited by the above violations pertain solely to r.tdiographic records.
None of the deficiencies cited in the violations resulted in a safety problem. Moreover, the quality and integrity of these welds, and the accuracy of the original Pullman-Higgins and Yankee Atomic Electric Company (YAEC) determinations regarding physical weld quality, have been substantiated and reconfirmed
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through the retadiography performed by NHY.
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,
[g Ted C. Fei nbaum STATE OF NEW IIAMPSHIRE Rockingham,_ ss.
December 23, 1991 Then personally appeared before me, the above named Ted C. Feigenbaum, being duly sworn, did state that he is President & Chiet Executive Officer of the New-Hampshire Yankee Division of Public Service Company of New Hampshire, that he is duly authorized to execute and file the fu;egoing infortnation in the name and on the beha'f of New Hampshire Yankee Division of the Public Service Company and that the statements therein are true to the best of his knowledge and belief.
/184 b JY]//
v Tracy Af DeCredico, Notary Public My Commission Expires: October 3,1995 -
Enclosure TCF:J ES f
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Urt d States Nuclear Regulatory Commission December 23, 1991 Attention:
Document Control Desk Page three cc:
Mr. Thomas T. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 1-3 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 r
Mr. William J. Lazarus, Chief Reactor Projects Section 3B U.S. Nuclear-Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406 Mr. Charles W. liehl Director, Division of Reactor Projects U.S. Nuclear Regulatory Commission Region !
475 Allendale Road l
King of Prussia, PA 19406 Mr. William Bateman Regional Operations Staff Chief l
Office of the Executive Director for Operations:
U.S. Nuclear Regulatory Commission 11555 Rockville-Pike Rockville, MD 20852 Mr. Phil Joukoff
. U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA -' 94596 -
Mr. Frank Forgione, Special Agent.
Office of the inspector General U.S. Nuclear Regulatory Commission-MNBB 6715-Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box -1149 Seabrook, Nil 03874.
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4 ILEPl,Y TO A NOTICl? OF VlOI.ATION in a letter dated November 25,19P!, the Nr(C transmitted to New llampshire Yankee (NilY) a Notice of Ylolation and Proposed linposition of Civil Penalty regarding three violations pertaining to weld radiographic records at Seabrook Station. In accordance with the instructions provided in the Notice of Viola 8cn and Proposed Imposition of Civil Penalty, the NilY response to each violation is providt low.
A.
Vlulations The following are the three violations as c'ted in the November 25, 1991 Notice of Violation and Proposed impositk;n of Civil Penalty.
Violation i 10 CPft Part 50, Appendix D, Criterion IX, Control of Special Processes, requires that men.utes be catablished to assure that special processen, such as nondestructive testing, he controlleel and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
Pursuant to tivs requirement. Seabrook Station was constructed in accordance with the requhements of the ASME Boiler and Pressure Vessel Code (Code),1977 Edition up to the Winter 1977 Addenda.
Section til of the Code delineates the requirements for the construction of piping systems, including welded joints and the radiography of welded joints. Article 2 of Section V of the Code, which is invoked by Sec' ion 111 of the code, delineates the requirements for radiography of piping welds. Specifically, Table T 272 of the AShlE Code, requires that 'the minimum radiographic quality. as displayed by a radiographic penettameter for thickness up to and including 0.875," shall be 2 4T. In addition, Paragraph T 263.2(a) of Article 2 of Sechon V requires the density of the area of interest to be within minus 15% to plas 30%
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of the density through the body of the penetrameter and Paragraph T 234.1 requires a minimum density of 2.0 for radiographs made with a gamma source.
10 CPit Part 50, Appendix D, Criterion XVil Quality Assurance Records, requires that nufficient records be maintained to furnish evidence of activities affecting quality. The records shall be identillable and retrievable.
Pullman liiggins Procedure IX RT 1 W7' implemented the requirement for all welds reviewed to ASME Section V and Section 111, Contrary to the above, sufficient records (radiographs) under Pullman liiggins Procedurc IX ItT 1 W77 were not obtained to furnish evidence that all welds met the quality standards rec 9d by ASME Section V an't Section 111, rendering the quahty of welds indeterminah Specifically, final code requited radiographs taken for three of the welds in the early 19u i did not meet the minimum quality level of 2 4T, the radiographs taken in the same period for 40 welds did not meet the seguirem:nts for minus 15 to plus 30 pctcent of the penet.ameter density or the 2.0 trJnimum density requir:ments and the radiographs taktu in the same time frame for four ' welds did not meet either requirement.- This condition enisted until September 1991, when additional radiographs were. taken and found to be acceptable.
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'Ihis is a Severity Level !!! Violation (Supplement II).
Chil Penalty
$100,000 Violation ll A 10 CFR Part 50, Appendix II, Criterion XVil, Quality Assurance Records requires, in part, that sufficient records shall be maintained to furolsh evidence of activities affecting quality, and that these records be identifiable and retrievable.
Contrary to the above, between Decernber 27,1990 and August 1991, radiographi, and their associated records, (namely, the original itsdiograph inspection Reports 'Riit)), for four welds were not identifiable and retrievable, since they had not been retained for the life of the plant. The specific welds for which radiograph packages were missin;; were Welds 1 CS 328 02, F0204; 1 CS 300 08, FOS 01; 1 CBS 120107, F0701; and 1 28-01, l'Ol$0.
This is a Severity Level IV Violation (Supplement II).
Violation 11.H 10 CFR Part $0, Appendix 13, Criterion 11, Quality Assurance Program requires, in part, that the program contain documented procedures and that activities be carried out in accordance with applicable procedures.
The Yankee Atomic C aois Cc,,pany (YAEC) Procedure No. $, entitled, 'OEO NDE REVihW OROUP,' which implements 10 CFR Part $0, Appendir 11, criterion 11, requires a YAEC quality assurance program review of all safety related radiographs.
Contrary to the above, prior to August 1991, no YAUC ypality assurance program review of two radiographic packages was conducted for ' Welds 1 Ril IS101, F0102 and 1 CilS 120101, F0103, in particolar, RIR$ for these welds were not signed by the Y AFC reviewer, as were those for all t uer welds reviewed.
This is a Severity Level IV Violation (Supplement II).
II, ltesponse to Violations Viointion 1 NilY does not contest this violation. Notwithstanding this,,he following clarification is provided regarding the 2 4T sensitivity issue as it pertains to the three (3) weld radiographs rejected by the Weld Radiograph Reinterpretation Program (WRRIP) snlely for sensitivity, and the four (4) weld radiographs rejected for both sensitivity and density con ce r n t,.
As descrioed in NilY letter NYN 91157, deced September 27, 1991, NHY e~eluated the sensitivity concerns for these seven (7) weld radiogrooh packages and concivded that the original Pullman liiggins and YAEC reviews were correct in their determinations that these seven radiographs were a:eeptable per the Code. The WRRIP was specifically designed to be ultra conservative in its determinations so as to eliminate all potential for future questions 2
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and concerns regarding welds and their radiographs at Seabrook Statia The seven (7) rensithity concerns were rejected by the WRRil'since, after close s;rutiny, it was deterrnined by multiple reviewers that these weld radiograla packages exhibited only marginally acceptable 4T sensitivity. !!y the guidelines of the Writ 1P, if a radiograph was snarginally i
acceptable, the weld was conseivatively identified for retadiography. Notwithstanding this, NilY concluded that the original Pullman.lliggins and YAEC determinations regarding the i
Code acceptability of these three weld radiog'aph packages were correct. The essential 4T image quality indicator hole was discernable en the original films in question. Additionally, the teradiography performed as part of the 'YRRIP substantiates and conllerns the original determinstions as to the Code acceptability of the physical welds.
Vlointion llA j
NilY does not contest this violation.
,Wulytion ll l.t NilY does not contut this violation.
C, Reasons for the Ylolatlous
.U211LLle.tL1 As described in NilY letter NYN.91157, dated September 27, 1991, NilY has
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- hv.. d for Generic implications, the 44 weld sadiograph packages that were rejected due to film density concerns as a result of the WRRIP, and the one (1) weld radiograph package also rejected for deusity concerns as a result of NRC Inspection 9121. This investigation revealed a shortcoming in the original Pullman liiggins and YAEC <eview process. This shortcoming is specific to the interpretation of radiographs performed on three (3) inch nominal pipe sire welds that utilized 11.4 double wall exposure, dcuble waH viewing, source side penetrameter radiographic technique, that is discussed below.
The 44 weld radiographs addressed by this violation were all performed using the double wall exposure, double wall viewing, source side penetrameter radiographic technique.
This technique is accepted by the Code for welds on three and one half (31/2) inch outside i
diameter and smaller piping. By its nature, lt is extremely difficuh to accomplish all the Code film quality requirements using this particular technique. This technique is described as being particularly difficult in the llellier Report #91912F, Revision 1, which was attached to the NilY letter NYN.91151, dated September 17, 1991. The effective composite through-wall thickness that the radiation passes through to' reach the film, radically changes as a function of the distance away from te pipe center, as depicted on the film. The larger the effective composite through wall thickness, the more the radiation will be attenuated.
This will cause a gradual transition of film dentity. These difficulties are exacertved with
.he three (3) inch nominal pipe sire since the composite thickness that the radiation must travel through varies more so than Mth smaller diameter pipe utilleing the same technique.
IIence, it is the double wall exposure,. double wall viewing, source side penetrameter technique, utilized on three (3) inch nominal pipe size welds, that presents the greatest demands on the reviewer's interpretive skills.
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This radiographic technique also requires even more extculve interpretation when it is used on three (3) inch nominal pipe sire, heavy wall schedule 160 pipe. Specifically, with this sire pipe it is necessary for the reviewer to interpret the weld area on the rrdiographic film withoui the benefit of refetcace boundary markers being present on the film in depict the edges of the weld area of interest. The radiographs do have.a O' or 9p* marker to indicate the center of the weld area of interest.
For the 44 subject welds, the original Pullman.lliggins and YAEC reviews did examine the entire weld area of interest. Ih, wever, the lack of boundary markers and gradual transition of film density at the outen fringes of the weld imposed by this technique created special challenges for the reviewers, it w n within these small fringe areas where the WRRIP identified film densities that were not in strict compliance with the Code requirements, Notwithstanding these film density deviations, none of the 44 subject weld rat iograph film packages indicated any evidence of a physical l
weld integrity concern.
As discussed below, this wn subsequently confirmed through t e r adiogr aphy.
NilY conclu sd that the root cause for these 44 welds not meeting Code film density requirements is attr table to the differences in film density at the edges of the wold area of interest under ca.dnation. These film density differencer, are enused by the unique challenges of this particular technique. A contributing cause is, in tetrospect, the extent to which density readings were taken to identify this condition.
As discussed in Section B above, NilY evaluated the sensitivity concerns for the seven (7) weld radiograph packages identified by the WRRIP and addressed by Violation 1, and concluded that the original Pullman.lliggins and YAEC reviews were correa in their deterr,inations that these radiographs were acceptable per the Code. The esscutial 4T image quality indicator hole was discernible on the original radiographic films. Additionally, the teradiography performed as part of the WRRIP substantiates and confirms the original determinations as to the Code acceptability of the physical welds.
Violation lid NilY reported the four (4) missing weld radiographic records packages to the NRC in tha following correspondence: weld 1.CS.328-02 F0204,- NilY letter NYN 91023 (dated Febiuary 8,1991); weld 1.CS 360 08 F0801, NilY letters NYN 91092 (dated June 10, 1991),
and NYN 91093 (dated June 11,1991); weld 1.CBS.120107 F0701, NilY letter NYN 'il105 (dated July 3,1991); and weld 1 Fl.188 01.F0150, NilY lettu NYN 91130 (dated August 23, 1991). As described in these letters, NilY has determined the root cause for the four (4) missing radiographic records packages to be personnel error on the part of Pullman.lliggins records management personnel.
The Pullman liiggins records management grsonnel apparently misfiled or inadvertently discarded these four (4) radiographic packages prior to the transfer of records to YAEC for review and failed to transmit these documents to the Seabrook Yankee Document Control Center (SBYDCC) for ultimate archival in the Seabrook Station records management System.
Also as described in NilY letter NYN.91134. dated August-30, 1991,-- the NilY Reliability and Safety Engineering Group performed a root cause analysis of all of the weid record anomalies identified during conduct.of-the Weld Record Reverification Program
_ (WR R P). A Kepner Tregoc analysis was utillr.ed as it was the most appropriate method for determination of cause and potential generle implications. This analysis concluded that due to a lack of any trends and the small number of problems, the anomalies did not result from 4
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a deficie nt Pullman liiggins records management program, it also concluded that the anomalies were considered isolated incidents.
Violation 11 R NilY reported the two (2) weld radiographic records packages cited in Violation 11.11 (1 Ril 15101.F0102 and 1 CllS 120101.F0103) that did not receive YAEC review and approval to the NRC in NilY letter NYN 91051, dated March 28, 1991. The root cause of these two anomalies is personnel crror on the part of the Pullman liiggins records management personnel.
The Pullman liiggins records management personnel apparently neglected to transfer these two (2) radiographic packages to YAEC for review and approval before these documents were placed in the SilYDCC for ultimate archival in the Seabrook Station records management system.
L D.
Corrective Actions That llave fleen Taken and the Results Achieved Violation 1 tJpon identification, NIIY expeditiously implemented corrective actions to address the weld documentation issues cited in Violation I.
The first of these corrective actions was to analyre, for common factors and generic implications, the radiograph quality concerns identified by NRC Inspections 9112 and 9121, and to design and implenant an inspection program for 100 percent of the welds that met the identified common factors.
NilY submitted this common factors and generie implications analysis to the NRC in NilY letter NYN 91142, dated September 6,1991.
As described in this lettrt, the Weld Radiograph Reinterpretation Program (WRRIP) was designed to ultra conservatively reinterpret weld radiograph packages which met the following common factors criteria:
Any Pullman liiggins field weld, that required radiography in order to meet the AShtE Code, that is three (3) inch nominal pipe. sire and sinalier, where the initial Pullman liiggins Level 11 (or III, where the only_ Pullman liiggins review was performed by a Level 111) review signature occurred prior to October 1,1982, and where the double wall exposure, double wall viewing radiographic technique was used with source side penetrameters, excluding any welds previously accepted by the NRC.
As dest.sbed in NilY letter NYN 91151, dated September 17,1991, NilY implemented the WRRIP and reported the results to the NRC, it was the WRRIP that identified the 47 weld radiographic packages cited in Violation 1. -This letter alt.o transmitted the results of bounding analyses which confirmed that the film quality concerns were limited to the set of radiographs for Pullman liiggins field welds that satisfied the aforementioned common ft ctors criteria.
The second set of corrective actions pertained.to the 47 individual welds conservatively identified by the WRRIP and subsequently cited in Violation 1.
N11Y reradiographed all 47 of the subject welds immediately following identification.
These radiographs were interpreted by qualified NiiY, YAEC and Stone & Webster Level 11 and l
111 reviewers and were found to be acceptable per the Code.
These new radiographs 5
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i substantiate and confirm that the orl inal welds were in full compliance with the Code.
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Additionally, the new rediographs also comply with the film quality requirements contained in the Code.
These new radiographs have also been independently reviewed by llellier Associates, Inc., l.cVel 111 RT certilled personnel who also conclude that the welds and their radiographs fully comply with the requirements of the Code. These new radiographs and l
their radiographic inspectP.n reports, as completed by the NilY, YAEC, Stone & Webster t
and independent llellier Associates, Inc. Level 111 RT certified personnel, have been included in the NilY Records Management System.
The completion of the corrective actions described above both bound and resolve the concerns regarding the 47 subject welds, and, therefore, NilY concluded that there are no remaining unresolved film quality concerns for field welds requiring radiography by Code.
liased on these conclusions, NilY further concluded that the Pullman.lliggins field weld concerns raised at Scabrook Station have been fully examined and resobed.
Violations 11, A and ll.fi NilY has implemented corrective actious to address the fous (d) missing radiographic records packages and the two (2) radiographic records packages that did not receive YAEC review. The first of these corrective actions was to design and implement the Weld Record Reverification Program (WRRP). NilY transmitted the Program Description for the WRRP to the NRC in NilY letter NYN 91076, dated May 13, 1991. The WRRP was designed to accomplish the following Rereview the Seabrook Station as built isometrie drawings and identify all Pullman.
liiggins field welds for which radiography was a requirement established by Code.
Determine whether NilY has the required radiogrephs and Radiographic inspection Reports (RIRs) for all welds identified by the above review, and whether those records attest to independent YAEC determination of acceptability.
During the above review and determination, if any additional incomplete reconds are noted, assess the individual and generic causes and safety implications, and take-appropriate compent,atory and/or corrective actions.
As described in NilY letter NYN.91134, dated August 30, 1991, in addition to the lettens transmitting the interim report on the progress of the WRRP, NilY implemented the WRRP and reported the results to the NRC. It was the WRRP that identified three (3) of-the four (4) mitsing weld radiographie packages cited in Violation ll.A. The fourth missing weld radiograph package was discovered by NilY and reported to the NRC on December 27, 1990, with additional information forwarded in NilY letter NYN.91023, dated Pebruary 8, 1991.
In all four (4) instances, NilY discovered that although the - field welds were radiographed at the time of originalinstallation and found acceptable per Code requirements, l
the radiographic records packages were not retained in the site records vault, i
- The second set of corrective actions pertalacd to the above mentioned : four (4) individual weldro NilY-teradiographed these welds ^and' interpreted the radiographs in accordance with current p,qtam requirements. These new radiographs substantiate and confirm that the original welds were in compliance with the Code. Additionally, the new 6
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tudiographs also c(.uply with the film quality requirements contained in the Code. These new radiographs and their isdiographic inspection reports have been included in the NilY Records Managemet.t System.
Also ar. described in NilY letter NYN 91134, dated August 30, 1991, the WRRP revealed that all construction related radiographs and radiographic inspection reports %ve been independently reviewed by YAEC in accordance with the 1984 Yankee Quality Assurance Radiography Review commitment, pslot to the initiation of the WRRP, NilY found and took corrective action for the two (2) radiographic records packages that did not contain evidence of a prior YAEC independent review. With the exception of the four (4) sets of misslug records mentioned above, the WRRp found complete compliance with the various informal and fortial YAEC Ouality Assurance Surveillance program requirements for a documented independent review by YAIJC since Pullman liiggins began welding in 1979.
As described in NilY letter NYN.91051, dated March 28,1991, with regard to the two (2) welds that did not originally receive YAEC review, in order to confirm that the final weld ra 'iography was adequate, the radiographs associated with these two (2) weld record packages were indeper dently read and interpreted as being in compliance with Code requirements by a YAEC Level 111 RT reviewer.
10.
Corrective Actions That W411 lie Taken to Avold l'urther Violations As described above, NilY has designed and implemented comprehensive programs to expeditiously respond to a variety of issues as a result of weld radiography performed during the construction era at Seabrook Station.
These programs have included comprehensive corrective actions to address these concerns as appropriate. NilY has previously concluded that there are no remaining unresolved film quality or records concerns for field welds requiring radiography by Code. NilY has further concluded that the Pullman liiggins field weld concerns raised at Seabrook Station have been fully examined and resolved.
Additionally, the Seabrook Station Construction Program and the related Construction Quality Assurance Program is no longer in place.
Any radiography performed on future modifications will be conducted under the control of the Operational Quality Assurance Program. Based on this, NilY concludes that no further corrective actions are necessaiy to respond to the aforementioned violations, Notwithstanding this, NiiY is in the process of evaluating the current radiographic processer, and will incorporate program enhanecments as i
a result of lessons learned and experience gained during the first refueling outage, l'.
Date When l'ull Compilance Will lie Achieved l
NilY is currently in full compliance with all regulatory and procedurn! requiremenis cited in this Notice of Violation. This compliance was achieved upon completion of the.
Weld Radiograph Reverification Program (WRRIP),
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