ML20091B859
| ML20091B859 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/31/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NYN-91122, NUDOCS 9108020193 | |
| Download: ML20091B859 (10) | |
Text
. . . _ _ - . . _ _ - _ _ _ _ _ _
' New Hampshire Ted C. Feigenbaum Yhhk(( Presdent and Chief Executivs Of fker NY N-91122 July 31,1991 United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Attention: Mr. Thomas T. Martin, Regional Adiainistrator
References:
(a) Facility Operating License No. NPF-86, Docket No. 50-443.
(b) Transcribed Public Meeting Between Ne'v Hampshirc Yankee and the NRC condrcted on April 10, 1991.
(c) NilY Letter N Y N-91076 dated May 13, 1991, " Transmittal of the Program Description for the Reverification of Pullman.lliggins Field Weld Records", T.C. Feigenbaum to T.T. Martin.
(d) UilY Letter NYN 91088 dated May 30,1991, "May 1991 Status Report for the Pragram for the Reverification of Pullman-Higgins Field Weld Records," T.C. Feigenbaum to T.T. Martin.
(e) NilY Letter NYN-91101 dated June h,1991, " June 1991 Status Report for the Program for the Reverification of Pullman Higgins Field Weld Records," T.C. Feigenbaum to T.T. Martin.
Subject:
July 1991 Status Report for the Program for the Reverification of Pullman-liiggins Field Weld Records Gentlemen:
In the April 10, 1991 Public Meeting between New llampshire Yankee (NHY) and the NRC [ Reference (b)], and as provided in the NilY Program Description for the A
' Reverification of Pullman-Higgins Field Weld Records, transmitted to the NRC on d 't 9 May 13,1991 [ Reference (c)), NHY agreed to proside the NRC with a monthly written
{20* report of the progress of the Reverification of Pullman-Higgim Field Weld Records Program.
M ot o Accordingly, enclosed please find the status report for the month of July 1991.
y pg As provided in the Enclosure, (% preliminary results of the Reverification of Pullmaa-
-o Higgins Field Weld Records Prograrr ;ndicate that there are .only three welds for which O@ certain parts of the applicable radiot ophic records could not l$e locand. Notwithstanding 8 tLis, NHY has conclusively det.:.iuir,-d that these three welds bad been radiographed and og determined to be of acce;- tabic qua' ty. Thus, these three anomalies pertain solely to os o. cc mtention of records. Oer preliminary cr.rmination of the total number of records required te be retained by Con; is 2610. Comparison of the three records anomalies to this prelitr> ,ry total indi:ates a hi@ successful program for documenting and retaining weld reco, Additionally, the foregoing also demonstrates that 100 percent of the Code required radiography was performed per the NHY construction program.
I l
.g,yyfg New Hampshire Yankee Division of Public Service Company of New Hampshire P.O. Box 300 = Seobrook, NH 03874 = Telephone (603) 474 9521 h} } i I i i
.o . . .
' United Stites Nuclear Regulatory Commission July 31,1991
. Attention: Mr. Ti.omas T. Martin Page_ two The preliminary results presented in the Enclosu vill be finalized in the NHY August 30, 1991 Final Report. Should you have any quest:m.s regarding this matter, please contcet Mr. Neal A. Pillsbury, Director of Quality Programs at f 603) 474 9521, extension 3341. ,
Very truly yours, l Enclosure
- cc: Mr. Gordon E. Edison, Sr. Project Manager Project Directortte 13 Division of Reactor Projects U.S.- N ucleat 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 j
Office -of the Exebutive 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
' Unitt 1 States Nuclear Regulatory Commission l --1450 Maria Lane, Suite 210 l -Walnut Creek, C A 94596.
Mr. Frank Forgione, Specia' Agent Office of the Inspector General United States Nuclear Regulatory Commission MNBB 6715 Washington, DC 20555 l
k$$cumeAtNojUoliD,6sk( j United States Nuclear Regulatory Commission l
Washington, DC ' 20555 i
New llampshire Yankee July 31,1991 FNCI.OSURE 1 to NYN-91122 JULY 1901 S fATUS REPORT FOR THE REVERIFICATION OF Pijl.l.M AN-HIGGINS FIEl,D WEI.D RECORDS d
W
. . .. - . _ - - - - .~ - _ . ~ = . . . ---
JUL.Y 1991 ST/.TUS RFPORT i
l FOR Tlin NEW II AMPSillRE_ YANKEE PROGR AM FOR THE
{
l REVERIFICATION OF .rVLLM/ N 1110 GINS FIELD WFLD RECORDS A. IN TRODUCTION The following provides the status of the New Ilampshire Yankee Reverification of Pullman-Higgins Fich! Weld Records Program as of July 26, 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 anomatics identified as a result of this program, ar.d corrective actions implemented to address these anomalies.
H. PROGitESS B.1 . W-ld Tabulatior),
! On April 22, 1991,- Nuclear Energy Services (NES) personnel started the Task 1 weld tebulation effort. This effort was. designed to provide a list of field welds requiring radiography in order to meet code. As provided in the program description, the basis for this list is engineering design documentation (drawings and chsnge documents) and the N.
5 Code Dota Reports.
On July 18, 1991, NES completed the Task I weld tabulation enfort. The preliminary results of this effort indicate that there are approximately 2610 field welds which require radiography by Code. This includes all welds for ASME Section !!! Piping, ASME Section
'lli Supports, ANSI-B31.1 Piping, and ASME Section Vill Unfired Pressure Vessels. As
-indicated in Section C.6 of-this . report, NHY is currently reviewing and verifying the NES Interim-Reports which transmitted the results of this eft .t A detailed discussion of the .
results of _this effort, including a breakdown by system ans Code, of the field welds which require radiography by Code, will be presented in the NHY August 30, 1991 Final Report.
~B.1.a Requests for Eng.ineerine Services j During the portion of the weld tabulation effort conducted in the month vi July, one Reoru 'o r Engineering Services (RES) was generated. As described in the program dest r+Wn, an RES is the mechanism for identifying and responding to potential anomalics
-gene .cd as part of the weld tabulation effort. The RES generated during the month of July, requested clarification between an isometric drawing and an N 5 data package. NHY has responded to this RES and has determined that it pertains- to an administrative issue with no impact on weld quality. Therefore, this issue is not reportable to the NRC pursuant
- to the program description.
1
- . _ _ _ _ . ._ _ _ _.____ _____._ __m _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _
f f
- 11. 2 - Radiouranh Packane Inventory On April 29, 1991, NES personnel began the Tark 2 Radiograph Package inventory.
This task was designed to provide a list of field welds for which radiographic films and Radiographic inspection Reports (RIRs) are retained in the site records vault. This task also records the signature of the individuals and organizations reviewing the r.idiographic film.
On July 2,1991, NES completed the Task 2 Radiograph Package inventory effort. .,
lThe preliminary =results of this effort indicate that there are approximately 4089 radiograph package 4 retained in the site records vault, As indicated in Section C.6 of this report, NilY is cuuently reviewing and verifying the NES Interim Reports which transmitted the results of . this effort. A detailed discussion of the tesults of this effort, including a listing by system and Code, of the radiograph packages retained in the site records vault, will be presented in the NilY August 30, 1991 Final Report.
l IL2.a Corrective Action Requests Generated from the Radionraoh Pacirace inventorv !
. As describcd in the program descri pti on, the Corrective Action Request (CAP) is the mechanism for identifying and responding to potential weld record anomatics generated as !
part of the radiograph review effort, During tLe month of July, a total of four CARS were generated. Three of these four Cars pertain to the field weld list and radiograph package inventory comparison, and are di; cussed in Sections 11.3 and C.1 of this report. NilY has completed -the-initial investigatise action for the one CAR pertaining to tb radiograph-package inventory effort, and has concluded that it does not contain anomatics which are reportable to the NRC pursuant to the program description, Specifically, this CAR identified minor administrative issues including: legibility of radiographic film data; minor administrative data mismatches between RIRs and radiographic film (e.g., numbers t wsposed); and questions . regarding required approvals on RIRs. None of these administrative discrepancies ' affect the physical quality of the subject welds. NilY is correcting minor administrative. discrepancies identified by this CAR and annota'ing the radiographic film package with a reference to this CAR.
As described -in -the June 1991 Status Report for the Reverification of Pullman.
liiggins Field Weld Records Program, NIIY previously initiated seven CARS during the June.
reporting period. As of July 26, 1991, corrective actions have been formulated for these seven CARS.
11 . 3 Field Weld-Iist and Radiocraph Comnarison The-comparison.of the list of field welds requiring radiography (Task 1 output) with the= list of field welds for which radiographic records exist (Task 2 output) will provide a single list which indicates that reliographic records are retained for field welds which require ruliography by Code.
2
_ _ _ ~ _ - - _
The Task 3 comparisons performed during the month of July generated three CARS.
In addition, the evaluation was completed for the one outstanding CAR previously generated at the end of June. The first three CARS did not contain any anomalies which were reportable to the NRC. The fourth CAR, however, indicated that for one field weld,1-CBS 1201-07-F0701, the requisite radiographic inspection report and radiographic film was unavailable. NilY provided a report regarding this documentation deficiency to the NRC in a letter dated July 3,1991 (NYN 91105). Section C.1 of this report summarizes this CAR.
On July 18, 1991, NES completed the Task 3 comparison effort. The preliminary results of this effort indicate that there are only three welds for which certain parts of the applicable radiographic recards are not available. NilY has previously reported the three records anomatics to the NRC in accordance with the reporting requirements delineated in the program description. As indicated in Section C.6 of this report, NilY is currently reviewing and verifying the NES Interim Reports which transmitted the results of this effort.
A detailed discussion of the results of this effort will be presented in the NilY August 30, 1991 Final Report.
Regarding the three identified welds for which certain parts of the radiographic records are not available, NilY has conclusiv:ly determined that these three welds had been radiographed and determined to be of acceptable quality; thus these three anomalies pertain soiely to retention of records. Comparison of the three records anomaties to the preliminary total number of radiographic records that are required to be retained by Code (approximately 2610), reveals a successful records retention rate of 99.88 percent. Additionally, the foregoing also demoastrates that 100 percent of the Code required radiography was performed per the NilY construction program.
C, PERFORMANCE MEASt1REMENT AND REPORTING C.1' Reports to the NRC During the month of July, NilY determined that one weld documentation anomaly l was reportable pursuant to the Program Description for the Reverification of Pullman- !
L iliggins Field Weld Records. This anomaly regards the lack of radiographic film and the
- radiographic inspection report for weld 1-CBS-170107 F0701, 1
In accordance with the reporting requirements delineated in the program description, telephone notifications regarding this anomaly 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 it was reportable. Additionally, a 72-hour written report regarding this anomaly was provided to the NRC on July -3, 1991 (NYNM105). This written report established that l' e identified weld record anomaly does not compromise the integrity of th's' i weld or other Seabrook Station welds. It was also establithed that this record deficiency.
does not compromise the integrity of the system in which this weld is locatedf thus it does not produce any reduction in the protection provided for the health and safety of the public.
The following provides a summary description of this records anoraaly, cause of the j deficiency, and corrective actions implemented. l t
i l
3
m .
_ Description of Anomaly Pullman-Hinnins Field Weld 1-CBS 1201-07 F0701 As stated in NilY-letter NYN-91105, dated July 3,1991, Pullman-Hi SFi ns field weld 1 CBS 1201-07 F0701 is a circumferential groove weld on a fourteen inch diameter section of piping in the Containment Building Spray (CBS) System. This sect, ion of the CBS System is ASME 111, Class 2, and Safety Class 2. This weld connects a 45 long radius elbow to a section of piping. This weld is located in the line between the Refue'ing Water Storage Tank (TK 8) and the suction side of the "B" train Containment Building Spray Pump (CBS.
P-90).- This line_ also provides a source of water for the "B" train Safety injection Pump (SI P 6B) and the. "B" train Residual Heat Removal Pump (RH P 84). The weld is physically located inside the tank farm between the Refueling Water Storage Tank (RWST) and the bermed wall. -A currently available Quality Assurance (OA) document, the Pullman liiggins Field Weld Process Sheet, demonstrates that this field weld was radiographed in 1983 in accordance with the Non Destructive Examination (NDE) requiren":nts contained in the 1977 ~
Edition of ASME Section 111 up through and including the Winter 1977 Addenda (the Code applicable to Seabrook Station).
1 The_ weld. records package for weld 1-CBS 120107-F0701 has not yet been located and may be misfiled or inadvertently discarded. It is currently believed that the RIR and the radiographs for this weld weie 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 s ault storage. Based on the above, the lack of weld record documentation for this weld dacs 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 we.ld process sheets for 1-CBS-120107-F0701 indicates that this weld was completed on February 11, 1983, and on February 16, 1983 an external visual examination of this weld was performed. ,The attribute.; 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'Ouality 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 avellable OA documentation also -
demonstrates that the radiographic records for this weld were reviewed as part of-the-x Pullman Higgins N-5 as built Seabrook Station records verificaiion process.
Additionally, this weld was ultrasonically tested in 1983 and deemed to be acceptable. The results are documented on the Pullman Higgins' Field Weld Process Sheet.
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-A l
l'
,_ - _ . __ . __ _ _ _ _ ~ _ , _ _ _ . _ . - _ _ _ _ _ . _ .
i 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 NilY has determined that the appropriate corrective actions for this records deficiency are to: 1) complete a radiographic examination of field weld 1-CBS 120107 F0701t 2) review the film in 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 refueling outage which began on July 26, 1991.
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 implication.s and possible additional corrective actions.
C.2. NHY NOG Surveillance The NHY Nuclear Quality Group (NOG) is performing three separate surveillance activities for the reverification effoit. These surveillances and their progress as of July 26, 1991 are provided below.
The first NHY surveillance addresses the adequacy of the procedures, scope and starting point for the weld tabulation, radiograph package inventory, and field weld list and radiograph comparison efforts described above. This surveillance will be completed in early August following completion of the second and third surveillances discussed below.
The second NHY surveillance samples 20 percent of the field welds from each of the isometric and support drawings previously reviewed by NES as part of the Task I weld tabulation effort. This surveillance addresses the procedural requirements outlined in NES Procedure 83A5643, " Review of Drawings." With'the exception af a few drawings which are still currently being reviewed, this surveillance is complete for the Class 1, 2, and 3 piping systems. This surveillance has also been completed for all of ASME VIII, and the majority of ANSI . B31.1, and the Class 1 Supports. The preliminary results of this surveillance indicate that thc NES performance of the Task 1 effort was adequate. This surveillance also revealed that in a few isolated instances, minor corrections were needed on the NES data sheets. NES will incorporate these corrections into the appropriate data sheets and the detta base. The balance of this surveillance will be completed in early August 1991.
The third NHY surveillance samples 20 percent of the radiograph packages, by system, that NES has reviewed as part of the Task 2 effort. This surveillance a,ddresses the procedural requirements outlined in NES Procedure 83A5462, " Review of Radiograpl.s." This surveillance was completed for all systems on July 24, 1991. The results of this surveillance indicate that the NES performance of the Task 2- effort was adequate. This surveillance 5
l:
- 2. __ _- _
. s.
,; ~
. also revealed that in a few isolated instances, minor corrections were needed on the NES datn sheets. NES will incorporate these corrections in the appropriate data sheets.
In summary, the above described NilY surveillances perform ,d to date, establish that the Weld Records Reverification Program, as implemented by NES, was performed in an j accurate and acceptable manner. l C.3 NilY Verification of the NES Tgk 3 Comparison Effort -i As discussed in the April 10, 1991 Public Meeting between NilY and the NRC, NilY committed to perfor.n an independent verification of the NES Task 3 cornparison effort. To facilitate this verification, NilY has developed an electronic data base upon which all the
' NES Task I and 2 data are in the proc:ss of being entered. Tnis program will perform the following three comparisons:
- 1) Field welds requiring radiography where radiography exists;
- 2) Field welds requiring radiography where radiography does not exist; and
- 3) Field welds not requiring radiography where radiography exists.
NilY will execute this program upon completion of data entry. The results of this independent Task 3 comparison effort will be ,. resented in the NIIY August 30,1991 Final Report.
CA: NES Myacement Oversicht NES also provides management oversight regarding the activities being performed by
'f ,
sonnel as part of the reverification of weld records project. On July 11, 1991, an officer of NES visited Seabrook Station to monitor the status and progress of the project.
C5 Performance Monitorine NilY also monitors the performance of the reverification 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.
4 C.6 NES Interim Reports NilY has received- a total of eleven NES Interim Reports,- which transmit the
. preliminary results of the Task 1, 2, and 3 efforts for all systems. NHY is currently in the
. process of reviewing, evaluating, responding to open items, and verifying the information contained in these Interim Reports. The finalized information from these Interim Reports-will serve as one of the' inputs-to the basis for the final results of this project, which will be presented in the NHY August 30, 1991 Final Reoort, i
6
-_. -- .~-_-.~~~- -,.- - - - -.-~.- ._-- - _ _.~.~.._...
C.7 NFS Final Reoort it is anticipated that NilY will receive NES's Final Report for this project in early August 1991. This report will be attached to the NilY August 30, 1991 Final Report.
C.8 Channe Document Trackine Verification Provram '!
i NRC luspection Report 50 443/91-09 noted an unresolved it e m (UNR 91-09 01) !
, pertaining to the data listed in the Change Document Tracking (CDT) System. Specifically, this report stated that:
"The licensee needs to ensure that the initial data base for the ISOs and related drawing t hunges is accurate for defining the NES field weld take off. Also, this aspect needs ongoing attentior to ensure that future Request fer rngineering Services ,
(RESs) or other problem resolutions are unique of themselves a.nd do not generically linpact. the initial data base,' ,
As stated in-the inspection Report, NilY has implemented a number of corrective acilons to address this unresolved item. The first of these corrective actions was to ensure ,
that field weld data are not omitted in the review of isometric drawings. NilY and NES coordinated a rework effort on May 2,1991, to ensure that field weld data had not been omittetl from any. work performed prior to the identification of this issue. This corrective action included a. tForough review of not only the latest revision of the isometric drawings and CDT information, but also the N 5 data packages. This corrective action -has been applied to previous, and subsequent NES work.
The' second corrective action was to conduct the Chaage Document Tracking Verification' Program. This program was to verify that the CDT data and design change
- documents agree. At the time the subject NRC inspection was conducted,. NilY had comoleted the portion of the CDT Verification Program pertaining to Engineering Change -
Anthorizations (I . 's), - On June 28, 1991, NilY completed the CDT Verification Program for all'Puttman fliggins Non Conformance Reports (NCRs). NIIY subsequently provided the results of thq CDT Verification Program to NES, and these results have been factored into
'the NES weld tabulation effort-NilY' has - also reviewed all RESs generated as a result of the Weld Record Reverification Program, and has determined that they do not contain issues which generically
[
impact the accuracy-_of the-CDT data base.
Based on the foregoing, NilY is confident that the CDT data is consistent with the-cont. rolled design change documents, and therefore, CD T 1., accurate for defining one of the initial data Sases for the weld tabulation effort as cited in the Mai 13, 1991 Program Description submitted to the NRC.
t t
7 l
1 r;
< , , . , ,. . . . . . . . ~ , _ . . . , , , . - , . _ . , _ - , _ ~ - _
L__ .._ .... _ . . . - - , . . _ . . . . ,..-~.-...._,-,_u,__,,,._,