ML20070P776

Responds to 910305 Request for Addl Info Re Weld Radiograph Package Discovered Missing from Facility

ML20070P776
Person / Time
Site:	Seabrook
Issue date:	03/11/1991
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20070P788	List: ML20070P776 ML20070T336 ML20070T340 ML20070T345 ML20070T361 ML20070T372 ML20072R725
References
NYN-91040, NUDOCS 9103280095
Download: ML20070P776 (6)

Text

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NYN.t!.H0 Marsh 11,1991 Mr. Charts: W. Hehl Director. Diviolon of Reactor Projects Volted States Nucleer Restistory Commission Region 1 473 Allendale Road Kits of Prussia, PA 19406 R efererises (a) Fac!!Ity Operaties License No. HPP46, Duket No. 50 443 (b) USHRC Letter dated Marsh 3, 1991, 'Roriu s41 for Additlenal Informellus on Walds' C.W. Hohl to T.C. Folgenbeta (c) NHY Letter NYN.91029, dated Februry 14,1991,' Response is R6quut for Inforastlun', T.C. Folgeabsta to T.T. M6ttia

, (d) USNRC Letter dated Febratry 12, HP1, 'Rettent for Jaforattlen en Redlugraph Records', C.W. Hekt to 7.C. Folgesbana (s) NHY !. otter NYN.fl08, dated February'8,1991, ' Add ltlesal NHY l Response to 010 kequent c.c Infermatles , 7.C, Psigenbaum to 1 J.

j hortna

Subject:

Resposte to Regnait for Informaties

Dear Mr. H6ki,

Esclosed plaise find New Hispahlre Yaake6 ' resposas to ths lafernetlon stagnoited l In U NRC letter dated March $,19P1 (Refersats (b)).

. $hould you have any quentless reguding this matter pleut scattet Mr. Terry L Harpster, D!rsclor of Listn Ing sorrices at (6H) 4744521, satsusiva 2 N 5.

Very truly your6, l

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! Ted C,Tedgeabama

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es Mr. Themes T. Martin Regional Administrator Ustted Mates Nuslaar Reguistory Consisslos Reglos 1 en Allcedits Road King of I'rsula PA 1H06 f Mr. Oorden E. Edison, St. Project Meanger Project Dbscterate (4 Divisico of Rtsetor Projects .

U.S. Nutitar Regulatory Commissles Washington, DC 20$$$

Decement Centrol Desk U.S. Nuclest Regulatory Commisalos '

Washingica, DC 20$$$

Mr. Noel Dudley HRC gealer Resident laspector P.O. Box 1149

$sabrook, NH 018N I

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inounsio e The basis for NHY confidence that rsgn!rsd radlegnphs were made for (Pu11sts.

Higgins) flsid welds, with satisfactory results 'and tidlograph retention as requitsd.

J),j t ? ONS E NHY is enafident th,t the required radiographs were made for Fullman Higgins field wolds with satisfactory results and radlegraph retention as require '. Thl confidence is baisd on the followingt

1. The Deilgn, construction and Quality Aisnience pregrams and practicas la effect l- during the construction of Scabrook Station proylded a defenscels dspth approach to ensure the quality and latestity of the physical components and supporting record documenistion. The dtfenic.ls. depth concept catalled a hlorarchy ai laternal independent checke and balances by the organttationi lavolved la the design and construction of Scabrook station. In addition to thte Internal measures, satarnal reviews and audits by independent third partica verified the adequacy of both Individual program elements and the total overall program to eatura full complisace with the wcldlig Installatloc, lespection and records processes.

During de:Ign and cocitruction, the QA Programs of the- Architect Enginest (A.E)

United Engiaccis and Comitructors (UE&C), Instal!st Fullman.Higgins (P.H), and Yankte Atomic Electric Company (YABC), as agent for NHY, provided controle to parform radl: graphy including sufficient uversight to ensure that radiography for P.H field veelds wat entisfactorily performed. Key cuatrols associated with radiography for AgME !!! systems loc!vdsd:

a. Welds requiring radlography were Identiflad on P.H field drawings,

b. Perforrnance of radiography was controlled via F.H Field Wold Proces Shoots reviewed by p.H Engltettlag and QA. Aflat complsllon of rad!ography, P.H QA personnel reviewed completed records to enstro redlegraphy required by the Process Ehests was sadefauturtly periormed. '

c. At the eenclusion of nonstreetten, P.M Baglastring and CA perscanal performed separate field walkdowns to ensure the piping configuration was cenalstent with piplag drawings, A8MB N.5 eede data reports were prepared by both F.H (as the Installer) and UB&C (as the Dcilgnst) in order to demonstrate that ASMB 111 piping systems met the A5ME 111 code. Ons step in the process was to verify that vede required radlegraphy was satisfactorily performed. Another stop was a system PAID review performed by IJEAC Nrlanring to assure that all ASME portless of plplag systems wort aantlfled on as N 3 sede data report.

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d. YABC performed a third level audit functlbs of P.H redlegraphs activities. YAEC slao perforrned an add ltional, o.; trail review of radiographic packages for P H field welds prior to iscludic5 them la the rec 0rdt vnnlt.

2. The results of four separate recent review efforts substanilate the effectiveness l

and ediquacy of the programi and practices that were la effect durlag th l

de:Ign and construction of Seabroch 8tattua. These four reviews lnoluded the NRC's Special Independent inspectlun Review Team (NUREO 1423), corrastive l actions NHY performed as described in NHY CAR 91001, Congressional Inquirica (vla the NRC) requesting Wcld Process 8heets and Radicgraphic Inspection Reports and flcally a separate HHY review of P.H weld packages performed for the years 1981 through 1984

3. As a result of these comblacd reviews only one field wold record, a radiograph for weld number CS 318 02.P0104, was not found. Although the radlograph was not in the weld record package, other documentation clearly demonstrates that the radiograph was taken, appropriately reviewad si required by the procedures and programs and accep:ed as satisfsutury. As part of the correctlve actione for Hl!Y CAR 91001, NHY has committed to re radlugraph tkla wsld in tlac upcoming plant outage to somplete the wald record docuacatation package.

In svamary, N!!Y's confidence is based on the Design, Constructlan and Quality Assuranse programs and practices in effect durlag the construction of 8sabrook $tatloa. This

( confidents is further confirmed by the recent additiont! detailed revicWs natt laguirles j regardins wcldlag practices and records, l

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eva2/91 00:33 tRO RI DCCCT ROOH FC.267 ,y , , ,

. P.EOVEIT 17 8 e Clarification of tb number of (Pullman Higgins) ridlographs sedited/saamined incident to respor.sts to posticcaltraction inquirles conceralag weld adequacy.

RESPONSE

NHY bas conducted a separate physical count of the radbgraphy packassa rammved from the vault as part of post. construction follow up questlots. The post.cocitructlet follow.up questions cotilsted of four separats efforta. These efforts lat,ludedt a) NUftEO 142J.

e b) Cortcetivo actiota performed as deteribed in NMY CAR 91401, e) congresalonal laguires and d) Additional NHY taviews.

Thl physical count was also sepa.4:ely verlfled to ensure the prettelon and accuracy vf ths results. The physivil count proccis entalled the followlag notloast

1. A alngle listing of wilds was developed from the font separate fo!!aw.up afforts.

2. Thti list was compared with the tetual lades sards need to remove the weld packages from the vault for review.

3. This resulted in a tabulatloa of the actual anaber of times a weld s radiograph package was removed from ths vault for uch of the four '

asparate efforts.

Thl physical count escrately _ determined the exact number of esparats nad distinct radiograph packages retrieved and the number of unique wolds lavelved. !a the February 26, 1991 sulamittal NHY Indicated thati

'There have best 1174 occanlocs where P.H wsld indlographic film packagst have been retrieved from the NHY storagt vault incident to post.constructics follow.sp on wcld adequacy questless. 8(ace certain packages wars retrieved on multiple occasions, it has basa determined that at tenit 920 separate and dlatlast redlestaphis packages have been retrievad and subsequently verifled as a result of this effort.'

o Based on the phyalcal count there were 1225 separate oceaslona whers radiograph packasse ws:s retrieved from the NHY vault for rivlew. In some lastances a slagte package was reviewed as many sa fivs (5) times. Ella!natlag thla duplication ladicates that there were 960 utlque weld packages revlowed.

NHY has completed a review of each of these petioes and verlflod that the reguired redlegraphs wora present in the vault for each of thsae no walds, s 1 l

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ATTACHMENT 10 l

l 99 7!*Vq ,

gi I*g UNITED STATES i f NUCl. EAR REOVt.ATORY COMMISSION 4 RtoloN 1 g / 475 ALLENDALE ROAD ese** KING OF PMVltlA. PENNSYLVANIA 19464 Docket No. 50 443 MAR 191991 Public Service Company of New Hampshire A1TN: Mr. Ted C. l'eigenbaum President and Chief Executive Officer New Hampshire Yankee (NHY) Division Post OfCce Box 300 Seabrook, iJew Hampshire 03874 Genticmen:

Subject:

CompNeness of Radiogrnphic Records We have reviewed your March 11, 1991 letter describing the bases for your confidence that all required radiographs for Pullman Higgins field welds were made, that those welds are satisfactory, and that the radiographs'and associated radiograph inspection records (RIRs) were received by New llampshire Yankcc for permanent storage. .

NRC inspections and assessments during Seabrook construction, the NRC special indepmdent l Review Team (IRT) inspection documented in NUREG 1425, hydrostatic tests, in servi:e inspections, and Seabrook's Quality Assurance program and processes provide reason 6te l

assurance that the safety related welds which required radiographic verification are adequate for the service. This includes field weld CS 328 02 F0204, for which the radiograph, original RIR and evidence of the committed confirmatory Yankee Atomic F.ncrgy Company.

(YAliC) review are missing.

Notwithstanding the above, the Quality Assurance and overview programs which you described as being in effect during construction should have ensured that the noted missing records were reviewed and retained as required. While you appear to have identified a likely cause for the missing radiograph, the staff is not satisfied that you have identified the actual root cause. As a result, it is not clear that all radiographs and RIRs have been independently reviewed by YAEC for acceptability in accordance with your commitmentcand have been permanently retained by New Hampshire Yankee. Therefore, to conclusively show whether the code required radiographs and RIRs were fully processed, and retained,- for Pullman- t Higgins Scld welds, New Hampshire Yankee is requested to accomplish the following.

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1. Re review the Seabrook rs built isometric drawings and identify all Pullman Higgins field welds for which radiography was a requirement established by code (e.g.,

ASME, B31.1).

I MM /

Public Service Company of 2 WAR 191991 New Hampshire

2. Determine whether New Hampshire Yankee has the required radiographs and RIRs for all welds identified by the above review, and whether those records attest to independent YAEC determination of acceptability, if they do not, please explain why not.

3. During the above review and determination, if any additional incomplete records are noted, assen the individual and generic causes and safety implications, and take appropriate compensatory and/or correet;ve actions.

4 Report the results of this effort to the NRC within about one week of its completion, retaining auditable records of the effort on site for reference.

By March 25,1991, please advise this office of your schedule for completing that effort.

Sincerely,

/-

haf * -

Thomas T. Martin Regional Adminis'rator s

-(

cc:

1., E. Maglathlin, Jr., President and Chief Executive Of6cer, PSNH J. M. Peschel, Regulatory Complianec Manager, NHY D. E. Moody, Station Manager, NHY T. Harpster, Director of Licensing Services, NHY R. M. Kacich, Manager of Generation Facilities Licensing..NUSCO J. F. Opeka, Executive Vice President, NU G. Garfield, Esquire R. Hallisey, Director, Dept. of Public Health, Commonwealth of Mauachusetts S. Woodhouse, legislative Assistant Public Document Room (PDR)

Local Public Document Room (1.PDR)

Nuclear Safety Information Center (NSIC)

NRC Resident inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Seabrook Hearing Service List

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SEAllROOK HEARING SERVICE LIST Robert A. Backus, Esq. Jack Dolan Backus, Meyer and Solomon Federal Emergency Management Agency 116 Lowell Street 442 J. W. McCormack (POCH)

Manchester, New Hampshire 03106 Boston, Massachusetts 02109 Gerald Garfield, Esq.

Regional Administrator, Region 1 1

U.S. Nuclear Regulatory Commission Day, Berry and Howard City Place 475 Allendale Road Hartford, Connecticut 06103 3499 King of Prussia, Pennsylvania 19406 Resident inspector Ms. Suzanne Breiseth U.S. Nuclear Regulatory Commission Board of Selectmen Town of Hampton Falls Seabrook Nuclear Power Plant Drinkwater Road Post Office Box 1149 Hampton Falls, New Hampshire 03844 Seabrook, New Hampshire 03874 i

Mr. R. Sweeney Administrative Judge New Hampshire Yankee Division Howard A. Wilber .,

Public Service Company of New Hampshire Atomic Safety & Licensing Board Panel Suite 610, Three Metro Center U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 Bethesda, Maryland 20814 Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore, Esq.

l Atomic Safety & Licensing Appeal Board i Atomic Safety and 1.icensing Appeal Board U.S. Nuclear Regulatcry Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Board Panel Durham Board of Selectmen U.S. Nuclear Regulatory Commission Town of Durham

- Washington, D.C. 20555 Durham, New Hampshire 03824 l

Paul McEachern, Esq. Dr. Mauray Tye, President

- 25 Maplewood Avenue Sun Valley Association P. O. Box 60 209 Summer Street Portsmouth, New Hampshire 03801 Haverhill, Massachusetts R. Scott Hill Whilton, Esq.

' Diane Curran, Esq.

1.agoulis, Clark, Hill-whilton Harmon, Curran, & Tousicy

& Rotondi 2001 S Street, N.W.

79 State Street Suite 430 i Newburyport, Ma.s sachusetts 01950 Washington, D.C, 20009 i

Seabrook Hearing Service 1.ist 2 i Mr. Alfred V. Sargent Ashod N. Amlrian, Esq.

Chairman' 145 Main Street Board of Selectmen P. O. Box 38 Salisbury, Manachusetts 01960 Bradford, Massachusetts 03801 Town of Exeter Seacoast Anti Pollution League 10 Front Street 5 Market Street Exeter, New Hampshire 03823 Portsmouth, New Hampshire 03801 Jane Spector Administrative Judge Federal Energy Regulatory Commission Ivan W. Smith, Chairman (2) 825 North Capitol Street, N.li. Atomic Safety and Licensing Board Room 8105 U.S. Nuclear Regulatory Commission Washington, D.C. 20426 Washington, D.C. 20555 Mr. George L. Iverson, Director Mr. John 1., Lovering, Acting Director New Hampshire Office of limergency Massachusetts Civil Defense Agency Management 400 Worchester Road State Ornec Park South P. O. Bnx 1496 '

107 Pleasant Street Framingham, Manachusetts 02108 Concord, New Hampshire 03301, A'1TN: James Muckerheide Mr. T. L. Harpster Administrative Judge

?ublic Service Company of New Hampshire Kenneth A. McCollom P. O. Box 300 1107 West Knapp Street Seabrook, New Hampshire 03874 Stillwater, Oklahoma 74057 4 Administrative Judge Adjudicatory File (2)

O. Paul Dollwerk,111, Chairman Atomic Safety and Licensing Board )

Atomic Safety & Licensing Appeal Board -Pcnel Docket U.S. Nuclear Regulatory Comminion U.S. Nuclear Regulatory Commission Washington, D.C. 20555 washington, D.C. 20555 Administrative Judge Barbara J. Saint Andre, Esq.

Richard F. Cole Kopleman and Paige, P.C.

Atomic Safety and 1.icensing lkaard Counsel for Amesbury, Newburyport, _

U.S. Nuclear Regulatory Commission Salisbury Washington, D.C. 20555 77 Franklin Street Boston, Massachusetts 02110 Mr. Leon Maglathlin Congressman Nicholas Mavroutes -

Public Service Company of New Hampshire U.S. House of Representatives 100 Elm Street 70 Washington Street Manchester, New Hampshire 03105 Salem, Massachusetts 01970

Seabrook Hearing Service List 3 Mr. R. M. Kaelch Mr. J. F. Opeka Northeast Utilities Service Company Northeast Utilitics Service Company P. O. Box 270 P. O. Box 270 Hartford, Connecticut 06141 0270 Hartford, Connecticut 06141 0270 John P. Arnold, Attorney General Atomic Safety and 1.icensing Appeal George Dana Bisbee, Associate Board Attorney General U.S. Nuclear Regulatory Commission ^

Attomey General's Office Washington, D.C. 20555 25 Capitol Street Concord, New Hampshirc 03301 Mr. J. M. Peschel Mr. Peter Brann Public Service Company of New Hampshire Assistant Attonley General P. O. Box 300 State House, Station #6 Seabrook, New Hampshire 03874 Augusta, Maine 04333 Office of the Attomey General Board of Selectmen -

One Ashbunon Place Town of Amesbury 20th Floor T o w n H all Boston, Muuachusetts 02108 Amesbury, Massachusetts Thomas Dignan, Esq. Chairman, Board of Selectmen John A. Ritscher, Esq. RFD 2 Ropes and Gray Scuth Hampton, New Hampshire 01950 One International Place Boston, Massachusetts 02110 2524

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ATTACHMENT 11; i

! Attachment 3 Request 2 (questions 1, 2 & 3 of June 19, 1990):

1. (paraphrased) In my May 29 memorandum I requested that I be provided the procedures that, prior to implementation of Procedure #5 in May 1984, l governed the YAEC 100% radiograph review. The May 29 request encompassed procedures that mandated the review.

Whether or not a specific procedure governed the YAEC 100% review prior to May 1984, I assume the ongoing NRC inspection will provide information:

(Several questions follow)

Response .

It is our understanding that information pertaining to questions la-1f & 2 will be addressed in the report of the NRC Independent Regulatory Review Team estab- r itshed to review welding at Seabrook Station. Responses to questions lg & 3 follow: ,

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Questions lg & 3 19 A statement as to the approximate date on wnich the NRC learned of the YAEC 100% review and a discussion as to whether and during what time period the NRC assessed the adequacy of this review.

3.

As of this date,1 am unable to locate an NRC document, issued prior to IR 90-30 on February 7,1990, which refers to a YAEC 100% review.

If the NRC staf f knows of any such reference, please provide it to me prior to COB, Friday, June 22.

Response

NRC Region I was aware in December 1983 of the licensee's intent to review 100% of the radiographs transmitted to the document control vault as qual-ity records. This date is based upon documentation in a January 4,1984 Region I memorandum (previously provided) documenting NRC awareness of the YAEC 100% radiographic review and upon reference in the resident inspector SAlp office files to Deficiency Report (OR) 527 issued on December'7,1983 with the supporting "YAEC RT INTERPRETATION" listing. It is possible that the NRC knew before December 1983 that YAEC was reviewing all film as it was received. However, we have not found any record of NRC cognizance of the 100% review prior to December 1983.

An NRC assessment of the adequacy of the YAEC review program was performed during the Systematic Assessment of Lic'ensee Performance (SALP) conducted for piping systems and supports on February 14, 1984. This is documented in the final SALP report issued on May 17, 1984 as a YAEC " customer re-r view" of ASME final code accepted radiographic film, Furthermore, the NRC Construction Appraisal Team (CAT) inspection conducted over the period

Attachment 4 April 23 - May 25, 1984 reviewed several radiographic film packages. The CAT inspection report, 50-443/84-07, issued on July 18, 1984 documents the following:

l "No significant problems were identified involving film that was re-

! viewed by the applicant's NOE organization. However, several irregu-larities were identified involving film that had not [yet] been re-viewed by the applicant."

If the film in which the irregularities were identified by the CAT inspec-tors had been accepted final radiographs, enforcement actions would have been pursued. Instead, the CAT recognized that the licensee's program required the noted YAEC review of all safety-related vendor anci site gene-rated radiographs. In documenting the dif ference between the radiographic r film which had been reviewed by the applicant and that which had not, the

)

CAT inspectors specifically highlighted the fact that the radiographic review process would have represented a regulatory concern had it not been for the applicant's review process. Hence, this area of inspection was not listed as one where .either potential enforcement actions or signif f-cant weaknesses were identified. Such inspection logic and the resulting findings and conclusions represent an additional NRC assessment of the adequacy of the YAEC 100% radiographic review program.

Additional documentation of an NRC assessment of the YAEC radiographic review process can be Nnd in other NRC inspection reports (irs). As an example, IR 50-443/8? v or inspection conducted from November 28 -

December 1, 1983 incl a review of the reactor pressure vessel (RPV) safe end radiographs. e NRC inspector reviewed radiographs that had been rejected by YAEC ite a differing position tendered by Westinghouse as the RPV supplier, ent ,he NRC concurred with the YAEC findirgs. Other

' copponent radiographs were also reviewed, resulting in additional assess-ment of the quality of the YAEC review, An example is IR 50-443/85-31 for an inspection conducted from October - December 1935. Documented in this

( IR is the statement that:

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"To date, the licensee has performed an overview of virtually all vendor supplied radiographic film. Where problems were found, such as geometric unsharpness failing to meet the ASME code, radio was re performed on site and repairs were made, if necessary." graphy The inspector reviewed 'a sample of film during this inspection, which also provided a measure of the NRC assessment of the YAEC radiographic review program.

Other NRC inspections (e.g., IR 50-443/85-19 conducted in July 1985) used the NRC NDE Van to independently radiograph welds. Such inspections veri-fled the adequacy of the 'censee's radiographic program and compared site file film to NRC radiograpns in an assessment of the licensee's overall NDE quality control program.

Attachment 5

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Another assessment o'f licensee performance inthis irea was ' conducted during the $ Alp appraisal on February 19, 1985. In the SALP report, issued on May 28, 1985, the following evaluation was documented:

"It is noted, however, that with regard to completed and finally in-spected hardware, very few problems were identified. In fact, in the welding and NDE areas, independent examinations by NRC inspectors revealed generally high quality work and ef fective licensee overtvew of the final radiographic film packages."

In assessing the overall performance in the area of piping during this January 1 - December 31, 1984 SALP period, it was noted that significant improvement had been achieved and that the licensee had demonstrated "ade-quate control over their self-identified construction problems," One of the areas evidencing such licensee control was the Y?:C 100% radiographic i review process.

Further, in the previously mentioned Region I internal memorandum of January 4,1984, it was noted that:

9 "A key operation in providing assurance of QC field activities is the YAEC surveillance program. Specifically, YAEC NOE personnel had been and still do conduct 100% review of contractor accepted radiographs."

This memorandum not only provides the requested reference to an NRC docu-ment acknowledging the YAEC 100% radiographic review ef fort but also l assesses this program in the context of NRC followup of the previously reported NDE falsi fication problem, (i .e. , the "Padovano" case). It should be noted that the above quote discusses the 100% review in reference to the "YAEC surveillance program." As has been discussed in previous re-sponses to Dr. Myers' requests, prior to the implementation of the YAEC i NDE Review Group procedure No. 5 in May 1984, the YAEC radi: iphic review l process was controlled as a surveillance activity. Thus, even though sur-l veillances were not normally 100% inspection efforts, the above NRC quota .

tion illustrates the YAEC intent to conduct 'such film reviews on a 100%

basis some time before the existence of the procedural requirement to do so.

l The inspection reports identified in the response to this request have l been provided previous 1y.

1 O

e

_m V .

Congreggof theEn(teh6tated maenen m.c. mu February 6, 1991 Honorable Kenneth Carr Chairman United States Nuclear Regulatory Commission -

Washington, D.C. 20555

Dear Mr. Chairman:

We are again writing to seek information concerning the quality of welds at the Seabrook station. The Commission's repeated failures to address the central issues of the Congressional investigation necessitate this request.

Please provide the following:

A. The specific procedure (s), if any, that governed the Yankee Atomic Electric Company's (YAEC's) purported 100%-

review of radiograph packages, prior to April 1984.

B. The Commission's position as to whether the procedure (s) referred to it Item A above complied with the requirement -

of 10 CFR 50, Appendix B, Criterion V.

C. The Commission's position with - regard to whether the -

Seabrook licensee, in the conduct of the purported 100%

review of radiographs, complied with the record keeping-requirements of 10 CFR 50, Appendix B, Criteria XVI-and XVII.

D. The Commissicn's position as to , whether ' the Seabrook-licensee, with - regard to the- purported 100% review of radiographs, complied with tb2 audit requirements of 10 CFR 50, Appendix-B, Criterit (VIII.

E. The Commission's explanation, in light of the contention that the purported 100% review was conducted throughout ,

the duration of pipe welding. activities, of Lwhy-approximately 95% of welds reviewed by the NRC in its NUREG-1425 inspection showed YAEC approvals af ter Wampler arrived at the site.

F. A Commission statement- providing the following information:

1. The-date when the NRC-Region I staff _first became aware of the purported 100% radiograph review by.

YAEC.

2. An explanation of any delay in the NRC becoming l

• ~

l Hon. Kenneth Carr February 6, 1991 aware of the purported 100% review and_its role in assuring weld quality at seabrook.

3. The date of the first NRC inspection and/or SALp report which described the role of the " purported 100% review in assuring weld quality.

4. An explanation of the delay in the licensee's awareness of a large backlog of radiographs that had not been transmitted from the welding contractor to the licensee and how this lack of knowledge can be explained in light of the NRC's repeated claims that the licensee maintained a 100% review of all radiographs beginning with the initiation of the pipe welding program.

G. The Commission's explanation of why the NRC staff, in the conduct of the inspection leading to NUREG-1425 failed to obtain information specified in Items 4e, 4f, and 4g of the PLAN FOR TEAM INSPECTION AT'SEABROOK, reproduced in NUREG-1425, Appendix 2.

The NRC staff's initial decision to cease providing Seabrook weld i

documents that had to be obtained from the licensee causes us considerable concern. The decision to cease cooperation with

certain of our documents requests was apparently made without consulting the Commission. It was made without a notificat!on by the Commission of the members who, on April 2,1990, requested that "you instruct the NRC staff to cooperate in this endeavor so that it is not necessary for us to become directly. involved in requests for documents."

We again wish to emphasize that we require such documents in order to fulfill our oversight responsibilities and we expect continued cooperation from the Commission and its staff in. obtaining all necessary materials.

1 Please provide the information requested herein prior to February 22, 1991.

l Sincerely, i

/ jf w --

r (

A id M A.

A et . . Kost ayer M. Kanr n  %

• i -

l Edward J. arke Nicholas Mavroules John F. Kerry

_ . ._ - . . - _