ML20070T515

Forwards Correspondence Re Recently Confirmed Situation Concerning Production of Documentation of Util Review of Two Pullman-Higgins Safety Related Pipe Welds During Late 1979 to Mid 1980

ML20070T515
Person / Time
Site:	Seabrook
Issue date:	03/28/1991
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Norton L NRC
Shared Package
ML20070T517	List: ML20070T515 ML20070T542
References
NYN-91052, NUDOCS 9104040244
Download: ML20070T515 (4)

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New Hampshire Y

(h Ted C. Feigenbovm Freddent and Chief Executive Officer March 28,1991 NYN 91052 Mr. Leo J. Norton Assistant Inspector General for Investigations Office of Inspector General United States Nuclear Regulatory Commission Washington, D.C.

20555

References:

(a)

Facility Operating License No. NPF 86, Docket No. 50-443 (b)

NHY Letter NYN 91002, dated January 11,1991, ' Response to Request for Information', T.C. Feigenbaum to L.J. Norton (c)

NHY Letter NYN 91023, dated February 8,1991, " Additional NHY Response to OlG Request for luformation", T.C. Feigenbaum to L.J.

Norton S ubject:

Additional NHY Response to OlG Request for Information

Dear Mr. Norton:

In order to ensure that your office is aware of the correspondence and issues that have transpired since my last letter to you [ Reference (c)], I feel obliged to forward the enclosed correspondence to you and to call your attention to two specific issues that ycur team of investigators should be aware of.

First, the enclosed correspondence [ Enclosure (7)} addresses a recently confirmed situation where NHY has not been aple to produce documentation of a YAEC review of two Pullman Higgins safety-related pipe welds during the late 1979 to mid 1980 time frame. Our immediate corrective actions have confirmed that the weld records for these two welds satisfy ccde requirements and there are no unresolved NH'Y concerns over the quality of these welds.

Second, in the enclosed correspondence [ Enclosure (6)l, NHY commits to a re-review of the code related P-H field welds and associated documentation as well as the production of a report no later than one week after August 31, 1991.

When this effort has been completed, we will provide a copy of the report to your office simultaneous with our issuance of the report to the NRC.

If you have any questions on the enclosed docuruu.s or this matter in general, please do not hesitate to call Mr. Neal A. Pillsbury, Director of Quality Programs at (603) 474-9521, extension 3341.

Very truly yours' qffWVOofVy N& ff r

pg Awc4 esy y3 QGp Ted C. Fei,enbaum TCF: NAP /act Enclosures

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New Hampshire Yonkee Division of Public Service Company of New Hampshire 1

P.O. Box 300 = Scobrook, NH 03874

• Telephone (603) 474-9521 1'

9 United States Nuclear Regulatory Commission, OIG March 28,1991 Attention:

Mr, Leo J. Norton Page two cc:

Mr. Thomas T Martin Regional Administrator United States Nuclear Regulatory Commission Region 4 475 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 Mr. Noel Dudley NRC Senior Resident Inspector P,0, Box 1149 Seabrook, NH 03874 Mr. Frank Forgione Special Agent Office of the Inspector General United States Nuclear Regulatory Commission MNBB 6715 Washington, DC 20555 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555

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New Hampshire Yankee March 28,1991 page three LIST OF ENCLOSURES TO NYN 91052 (1)

USNRC Region 1 Letter dated February 22,1991, ' Request for Information on Radiograph Records, C.W. Hehl to T.C. Feigenbaum (2)

NHY Letter NYN 91029, dated February 26, 1991, ' Response for Request for Information", T.C. Feigenbaum to T.T. Martin (3)

USNRC Region I Letter dated March 5,1991, " Request for ~ iditional Information on Welds", C.W. Hehl to T.C. Feigenbaum (4)

NHY Letter NYN.91040, dated March 11, 1991, ' Response to Reqv a for Information', *,C. Feigenbaum to C.W. Hehl (5)

USNRC Region I Letter _ dated March 19,1991, ' Completeness of Radiographic Records", T.T. Martin to T.C. Feigenbaum

_(6)

NHY Letter NYN-91050, dated March-25,1991, " Response to Radiograph Review Request' T.C. Feigenbaum to T.T. Martin (7)

NHY Letter NYN 91051, dated March 28,1991, " Correction to Pilor Correspondence',

T.C. Feigenbaum to T.T. Martin

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New Hampshire Yankee March 28,1991 ENCLOSURE 1 TO NYN 91052 1

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,o 475 ALLENoALE ROAD M 2 51991 KING OF PRUSLIA, PENNSYLVANIA 19406 LICENSING Docket No. 50-443 Public Service Company of New Hampshire ATTN: Mr. Ted C. Feigenbaum President and Chief Executive Officer New Hampshire Yankee (NHY) Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject:

Request for Information on Radiograph Records The purpose of this letter is to confirm our request that New Hampshire Yankee provide the following information to the NRC in writing.

The number of Pullman-Higgins weld radiographs retrieved from the files incident to post-construction follow-up on weld adequacy questions, and the number of Pullman-Higgins weld radiographs which were not retrievable during this effort.

The number of Pullman-Higgins weld radiographs which should be on file.

The technical basis for your conclusion that the missing radiograph for Field Weld CS-328-F0204 is an isolated occurrence with no discernable generic implications (reference your letter NYN-91023 to NRC (OIG) dated February 8,1991).

Thank you for your prompt attention to this matter.

Sincerely, bw/A narles W. Heh!, Director Division of Reactor Projects l

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Public Service' Company of 2

FEB 2 21991 New Hampshire CC:

L. E. Maglathlin, Jr., President and Chief Executive Officer, PSNH J. M. Peschel, Regulatory Compliance Manager, NHY D. E, Moody, Station Manager, NHY T. Harpster, Director of Licensing Services, Sl!Y 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 Massachusetts S. Woodhouse, Legislative Assistant K. Abraham, PAO, RI (2 copies)

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

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

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_SEABROOK MEARING SERVICE LIST Jack Dolan Robert A. Eackus, Esq.

Federal Emergency Management Agency Eackus, Meyer anc Solomon 442 J. W. McCormack (P0CH) 03106 Boston, Massachusetts 02109 116 Lowell Street Manchester, New Hampshire Gerald GarfieM, Esq.

Phillip Ahren, Esq.

Day, Berry anc $.oward Assistant Attorney General City Place Office of the Attorney General Hartford, ".onnecticut 06103-3499 State House Station #6 Augusta, Maine 04333 Senator Gordon J. Humphrey Ms. Suzanne Breiseth ATTN: Tom Burack Board of Selectmen U.S. Senate Town of Hampton Falls 531 Hart Senate Office Building Drinkwater Road 03H4 Washincton, D.C, 20510 Hampton Falls, New Hampshire Administrative Judge Mr. R. Sweeney Howard A. Wilber New Hampshire Yankee Division Atomic Saf ety and Licensing Appeal Socrd Public Service Company of New Hampshire U.S. Nuclear Regulatory Commission Suite 610, ihree Metro Center Vashington, D.C.

20555 Esthesda, Maryland 2C514 Administrative Judge Administrative Judge Thomas S. Moore, Esq.

Alan S. Rosenthal, Chairman Atomic Safety and Licensing Appeal Ecard Atomic Safety anc Licensing Apoeal Board U.S. Nuclear Re;tlatory Commission U.S. Nuclear Regela ory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Administrative Judge Jerry Harbour Emmeth A. Luebke Atomic Safety and licensing Board Atomic Sa fety and Licensing Board U.S. huclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 H. Joseph Flynn, Esq.

Paul McEachern, Esq.

Assistant General Counsel i

Shaines and McEachern Federal Emergency Management Agency

,i 25 Maplewood Avenue Portsmouth, New Hampshire 03801 Washington, D.C.

20472 l

Diane Curran, Esq.

R. Scott Hill-Whilton, Esq.

Andrea Fenster, Esq.

Suzanne P. Egan, Esq.

Harmon, Curran, & Tousley Lagoulis, Hill-Whilton 2001 S Street, N.W.

& Rotondi Suite 430 01950 Washington, D.C.

20009 70 State Street 5

Newburyport, Massachusetts

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SEABROOK HEARING SERVICE LIST Edwin J. Reis. Esq.

Ashod N. Amirian, Esq.

Office of the General Counsel 145 Main Street U.S. Nuclear Regulatory Commission P. O. Box 3B Washinston,D.C.

20555 Bradford, Massachusetts 03130 Chairman, Boarc of Selectmen Seacoast Anti-Pollution League P. 0. Box 710 5 Market Stree; North Hampton, New Hampshire 03862 Portsmouth, New Hampshire 03E01 Jane Spector Adn.inistrative Judge Federal Enercy Regulatory Ccemission Ivan W. Smith, Chairman (2) 825 North Capitel Street, N.E.

Atomic Safety and Licensing Board Room S105 U.S Nuclear Regulatory Commission Washington, D.C.

20426 Washington, D.C.

20555

=Mri George L. !verson, Director Jchn Traficonte, Esq.

He,< Hampshire Office cf Emergency Chief, Nuclear Safety Unit Management Office of the Attorney General State cifice Park South One Ashburton Pla:e 107 Pleasant Street 19th Floor Concord, New Hampshire 03301 Boston, Massachusetts 0210S Mr. Ga y W. Helmes, Esq.

Administrative Judge Holmes and Eilis Kenneth A. McCollom 47 Winnacunnet Road 1107 West Knapp Street Hampton, New Hampshire 03842 Stillwater, Oklahoma 74057 Administrative Judge Adjudicatory File (2)

G;. Paul Bollwert, 111, Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Appeal Board Panel Docket U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission

-Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Mitzi A. Young Richard F. Cole Attorney Atomic Safety and Licensing Board Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Pegulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Robert-R~. Pierce, Esq.

Congressman Nicholas Mavroules Atomic Safety and Licensing Board U.S. House of Representatives U.S. Nuclear Regulatory Commission 70 Vashington Street Washington, D. C.

20555-Salem, Mtssachusetts 01970 Earbara'J. Saint Andre, Eso.

Judith H. Hizner, Esq.

Kopleman and Paige, P.C.

Counsel for West Newbury 101-Arch Street 79 State Street

' Boston, Massachusetts 02110 Newburyport, Massachusetts 01950 7

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SEABROOK HEARING SERVICE LIST

.Mr. R. M. Kacich Mr. J. F, Opeka Northeast Utilities Service Company Northeast Utilities 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 Licensing Appeal George Dar.a Bisbee, Associate Board Attorney General U.S. Nuclear Regulatory Com:nission Attorney General's Office Washington, D.C.

20555 25 Capitol Street Concord, New Hampshire 03301 3-e I

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New llampshire Yankee March 28,1991 L

b LNC1OSURE 2 TO NYN 91052 4

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New Hampshire Yankee

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Chief Executive Officer NYN-91029 February 26, 1991 Mr. Thomas T. Martin Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19405

References:

(a)

Facility Operating License No. NPF 86, Docket No. 50 443 (b)

USNRC Region 1 Letter dated February 22, 1991, ' Request for Information on Radiograph Records' C. W, Hehl to T. C. Feigenoaum (c)

NHY Letter NYN.91023, dated February 8,1991, ' Additional NHY Response to OlG Request for Information', T. C. Feigenbaum to L. J.

Norton

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S ubject:

Response to Request for Information Gentlemen:

Enclosed please find New Hampshire Yankees' response to the information requestec in USNRC letter dated February 22,1991 [ Reference (b)].

Should you have any questions regarding this matter please contact Mr. Neal A.

Pillsbury, Director of Quality Programs at (603) 474 9521, extension 314 Very tr y yours, M

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44b v Ted Feigenc. -

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9 New Hampshire Yankee Division of Pu'elic Ser< ice Ccmpcny cf New Hampshire P.O. Box 300 Sec'crcck, NH 03874

• Telephone (603) 474 9521

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United States Nuclear Regulatory Commission February 26, 1991

- Attention:

Mr. Thomas T. Martin p g, g,,

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' Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division of-Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Charles W. Hehl, Director Division of Reactor Projects U, S. Nuclear Regulatory Commission, Region I

- 475 Allendale Road-King.of Prussia, PA 19406 Mr. Noel Dudley NRC Senior Resident Inspector

- P.O.- Box 1149 Seabrook, NH 03874 m-

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New Hampshire Yaekee February 26, 1992 i

ENCLOSURE 1 TO NYN.91029 I

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Reouest No.1 The number of Pullman Higgins weld radiographs retrieved from the files incident tes post, construction follow up on weld adstpacy questions, and the number of Pullm #Higgius weld radiographs which were not retrisvable during this effort.

Resoonse_

A.

There have been 1174 occatiens w'aere P H weld radiographic film packages have been retrieved from the NHY storage vault incident to post construction follow up on weld ndequacy questions. Since certain packaps were retrieved on multiple occasious, it has been determined that at least 920 separate and dit, tint raditigraphic packages have been retrieved and subsequently verified as a result of ti.is effort.

These numbers were determined as follows:

NUREG 1425 (includes Wampler log).

276 Corrective actions performed as described is NHY CAR 91-00L 157 Congressional inquiries (estimated to be 300)

I requesting Weld Process Sheets and Radiographic Inspection Reportt through the NRC.

7'o (See Note 1)

Additionally, NHY has arbitrarily selected, from P H " Records Receiving Chect Lists',

a number of weld records for the years 1981 through 1934. These were the years d taost interest to the congressional inquiries as these yeats were prior to YAEC formally specifying their 100%

film review in a written precedure. As of 2/22/91, s

the weld radiographs for these pipe welds were verified to be in the NHY records vault with proper evidence of YAEC review.

.E5 Total 117s (See Hote 2)

Note:

1.

The number 300 was not used in this calculation because not all documented congressional L:quiries are available to NHY, cad a number of these requests were redundant. NHY believes that 76 conservatively understates the actual numbe r.

Notet 2. The number of radiograph package retrievals (1174), include many duplicate reviews of the same packages. NHY has further cross checked the weld numbers included in this set of 1174 and has ' termined that there are at least 920 sepan.te and distinct radiographic packages within this populati m of 1174 radiographic film set verifications.

B.

One (1) is the number of Pullman Higgitt field weld radiopaph sets not found to be retrievable during these efforts. P H tadiographs for P H weld number CS 323-4 02-F0204 were not located during the document research phase of an on going canztessional inquiry.

NHY wrote CAR 91001 to document and resolve this occurrence. CAR 91001 was encicted in Reference (c).

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Alsc> not included in these numbca are extensive NRC independent verification inspections such hs:

Construction AppraisalTwu Repo4t (CA7) 8. 06 w'r reviewed 9, )

welds, C. J D, /

which reviewed 180 P H weh!s, am YAU 8519 'Lich reviewed 79 ?-H weHs.

The above und car c(Mr NRC inspections were not ' post construction' retrievals and therefore were not included in our tabulation.

l Recuest No. _2 The number M Pullman Higgins weld radiogiap'.s which should be na file.

Resoonse The total number of radiograph sets which should be on file is the number of NHY records in the vault (4177), plus.ha one missing radiograph set for CS 32S 02 F0204, clus any

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additional radiograph sets which should be in the file but are not. NdY believes th 'he tumber t f radiograph sets in this latter categrf is zero based on the generi; impk.% -

4 review discune t in the resconse to Request No. 3 below.

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it is believed that the annber of radiograph sets should bt 4178 it o r d r to :- c. e t the applicabk AbiE Code and P-H contractual corritments fer &co Statiot This number can also be derived from the information which was previousF; provided to the NRC and then subsequently Gummarized in the table on paE 14-2 in the NRC's NURLG 1425

(' Welding a 2i Nondestructive Exacitation 1: sues at Seabrook Nuclear Stttion').

An e upirical verification of this :: umber mld require a review cf all as built isometric drawiugs of record.

NHV Lelieves that this type of verificction would be both time consutning ard utnetusary based on the resu!a of the extee.tive independent verifications conducted ;o date.

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ne technical basis for your conclusion that the tissing rrdiograph for Field Weld CS 328-02 F0204 is an isolated murre*.ee with no discernable generic implications (reference your leuer NYN-M023 to NRC (010) dued F;bruary 8,15 91).

D 3 onsq NHY is,onfident that yhe singk known insti:r;e of a missing radiograph set, for CS-328-q 02 F0204, is an isolated ocevnence with no d'.scernable ;-neric implications based on the o

geactic i=plicatio:u review descritnd in CAR 91. GJ1 [ enclosed in Reference (c)] and the unique circuastacces icvo!ved with this ae radiograph set.

As part cf the CAR 51001 generic inpiitations review, NHY checked radiographs for an additiatal IT piping welds. The2e v elds were selected for review because they exhibited cond'tiots cotentially similar to CSG 8 02?/0204, i e., NCRs were wr:tten and/or recair was needed. Thr seiection of these wel.s was based on a search of ccmputer data base NCR 9

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t information and a review of the P H Weld Repair Order (WRO) log (a non.QA planning and s.neduling control document). In part:cular, these welds were selected if hey had NCRs s in 3 or more repairs noted in the computer data base or the P H VRO log identified these welds as having 3 or more entri:s or 3 or rnore :epair cycles.

Far each of these 157 instances, NHY verified tb t a radiograph set was available in the NHY vault and that the set had been rniewed by YAEC, NHY believes that the circumstances invohed in the processing of the radiograph for CS-32S 02 F0204 have no discernsble generic implications based on the following:

1.

The Weld F0204 was incorrectly marked as F0209 on the pipieg isometric drawing after F0204 was radiographed.

2.

F0204 was incorrectly deleted fr ots the piping istruc t ric subsequent to the radiopapSic exarnination being performed and accepted (as F0204). As a result, a P.H examiner might have deter:sined that the radiegraph was no lenger needed and that there was no need to send the radiograph to YAEC for review and subsequent retention in the records vault.

3.

F0204 was re established on the piping isometric approximately 2 years after the radiographic examination ic F0204 was performed. In particular, the piping isometric g

drawing was revised to delete F0209 and re establish F0204 probably in response to N 5 deta report preparation. At that :ime, a review cf the S cld histo:y package would have indicated that the weld joint was cotapleted and accept $d because a P.

H Radiographic inspection Report (RIR) was available in the package.

Thus, documentation to prove that the radiographic examinatics was performed was available then as it is now.

I I' e in[or: ration provided above describts a uniqVe set of circurnslatees. As a re; ult of this e

information, NHY considers this occurrence to be an isolated cne with no discernable generic implications.

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1 New Ilame shlte Y..%ee March 28,1%'t i

i ENCL,OSURE 3 TO NYN 910'1 4

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NUCLEAR REGULATORY COMMISSION 4 (

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476 ALLENoALE ROAD KING OF FRUSSIA, FENNSYLVANIA 19406 Docket: 50-443 PAR 0 51991 Public Service Company of New Hampshire ATfN: hit. Ted C. Feigenbaum Picsident and Chief Executive Officer New Hampshire Yankee (NHY) Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:

Subject:

Request for AdditionalInformation on Welds Based on NRC review of your February 26,1991 response (NYN-91029) to our February 22,1991 request for information, we request that New Hampshire Yankee (NHY) provide, by March 11, 1991, the following additional written information on wcld radiographs.

The basis for NHY confidence that required radiographs were mtde for (Pullman-Higgins) field welds, with satisfactory results and radiograph retention as required.

Clarification of the number of (Pullman-Higgins) radiographs audited / examined incident to responses to post-construction inquiries concerning weld adequacy.

The basis for this request is the NYN-91029 assertion that a time consuming review of all as-built isometric drawings of record would be required to verify the Pullman Higgins radiographs which should be on file. That Inises a question of whether NHY (and their agent: Pullman Higgins, the authorized nuclear inspector, and Yankee Atomic Electric Company) ever determined that all required radiographs were made, found acceptable during construction, and were present in the vault. Clarification of the numbers of radiographs retrieved in response to post-construction questions is being requested because it is still not cie. M us which sample scts retrieved involved re-examination of the same radiography.

4 Nk you for your attention to this matter.

2 Sincerely, em @,

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I g harles W. Hehl, Director Division of Reactor I cojtets 1 m /- I y n y _N/P U Ag l

MAR 0 51991 Public Service Company of 2

New Hampshire CC:

L. E. Maglathlin, Jr., President and Chief Executive Officer, PSNH J. M. Peschel, Regulatory Compliance Manager, NHY D. E. Mcody, Station Manager, NHY T. Harpster, Director of Licensing Services, NHY R. M. Kacich, Manager of Generation Facilities Licensing, NUSCO J. F. Opeka, Executive Vice Presient, NU G. Garfield, Esquire R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts S. Woodhouse, Legislative Assistant K. Abraham, PAO, RI (2 copies)

Public Document Room (PDR)

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Local Public Document Room (LPDR) i Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee Seabrook Hea:ing Service List 4

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SH6 BROOK HEARING SERVICE LIST L

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- 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 I

Regional Administrator, Region I Gerald Garfield, Esq.

i U.S. Nuclear Regulatory Commission Day, Berry and Howard 475 Allendale Road City Place j

King of Prussia, Pennsylvania 19406 Hartford, Connecticut 06103 3499 o

I Ms. Suzanne Breiseth Resident Inspector j

Board of Selectmen U.S. Nuclear Regulatory Commi sion i

Town of Hampton Falls Seabrook Nuc ear Power Plant n

Drinkwater Road Post Office Box 1149 Hampton Falls, New Hampshire 03844 Seabrook, New Hampshire 03874 g

l Mr. R. Sweeney Administrative Judge t

New Hampshire Yankee Division Howard A. Wilber 4

Public Service Company of New Hampshire Atomic Safety & Licensing Board Panel

[i Suite 610, 'three Metro Center U.S. Nuclear Regulatory Commission Bethesda, Maryland 20814 Washington, D.C.

20555 Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore, Esq.

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Atomic Safety and Licensing Appeal Board Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission j(

Washington, D.C.

20555-Washington, D.C.

20555 s

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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 y

Paul McEachern, Esq. -

Dr. Mauray Tye, President 25 Maplewood Avenue Sun Valley Association P. O. Box 60 209 Summer Street 1

Portsmouth, New Hampshire 03801 Haverhill, Massachusetts

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R. Scott Hill-Whilton, Esq.

Diane Curran, Esq.

g Lagoulis, Clark, Hill-Whilton Harmon, Curran, & Tousley

& Rotondi-2001 S Street, N.W.

L,i 70 State Street Suite 430 Newburyport, Massachusetts 01950 Washington, D.C.

20009

s Seabrook Hearing Service List 2

hu. Alfred V. Sargent Ashod N. Amirian, Esq.

Chairman 145 hiain Street Board of Selectmen P. O. Box 38 Salisbury, hiassachusetts 01960 Bradford, biassachusetts 03801 Town of Exetcr Scacoast Anti-Pollution League 10 Front Street 5 hinket Street Exeter, New Hampshire 03S23 Portsmouth, New Hampshire 03S01 Jane Spector Administrative Judge Federal Energy Regulatory Commission Ivan W. Smith, Chairman (2) 825 North Capitol Street N.E.

Atomic Safety and Licensing Bond Poom 8105 U.S. Nuclear Regulatory Ccmmission

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'Vashington, D.C.

20426 Washington, D.C.

20555 hir. George L. Iverson, Director hir. John L. b]vering, Acting Director New Hampshire Office of Emergency hiassachusetts Civil Defense Agency bianagement 400 Worchester Road State Office Park South P. O. Box 1496 107 Pleasant Street Framingham, biassachusetts 0210S Concord, New Hampshire 03301 A*lTN: James hiuckerheide Mr. T. L. Harpster Administrative Judge Public Service Company of New Hampshire Kenneth A. bicCollom P. O. Box 300 1107 West Knapp Street Seabrook, New Hampshire 03874 Stillwater, Oklahoma 74057 Administrative Judge Adjudicatory File (2)

G. l'aul Bollwerk, HI, Chairman Atomic Safety and Licensing Board Atomic Safety & Licensing Appeal Bond Panel Docket U.S. N' dear Regulatory Commission U.S. Nuclear Regt'latory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Barbora J. Saint Andre, Esq.

Rich 1rd F. Cole Kopleman and Paige, P.C.

Atomic Safety and Licensing Board Counsel for Amesbury, Newburyport, U.S. Nuclear Regulatory Commission Salisbury Washington, D.C.

20555 77 Franklin Street Boston, hiassachusetts 02110 hir. Leon hiaglathlin Congressman Nicholas Mavroules Public Service Company of New Hampshire U.S. House of Representatives 100 Elm Street 70 Washington Street hianchester, New Hampshire 03105 Salem, hiassachusetts 01970

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- Seabrook Hearing Service List 3

Mr. R. M. Kacich Mr. J. F. Opeka Northeast Utilities Service Company.

Northeast Utilities Service Company P. O. Box 270 P. O. Box 270 Hartford, Cor.necticut 06141 0270 Hartford, Connecticut 06141 0270 John P. Arnold, Attorney General Atomic Safety and Licensing Appeal i

George Dana Bisbee, Associate Board Attorney General U.S. Nuclear Regulttory Commission Attorney General's Office Washington, D.C.

20555 25 Capitol Street Concord, New Hampshire 03301 Mr. J. M. Peschel Mr. Peter Brann e

Public Service Company of New Hampshire Assistant Attorney General P. O. Box 300 State House, Station #6 Seabrook, New Hampshire 03874 Augusta, Maine 04333 Office of the Attorney General Board of Selectmen One Ashburton Place -

Town of Amesbury 20th Floor -

Town Hall-Boston, Massachusetts 02108 Amesbury, Massachusetts L

Thomas Dignan, Esq.

Chairman, Board of Selectmen

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John A. Ritscher, Esq.

RFD 2 Ropes and Gray South Hampton, New Hampshire 01950 One International Place j

Boston, Massachusetts 02110-2624--

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New Hampshire Yankec March 28,1991 ENCLOSURE 4 TO NYN 91052 i

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' New Hampshire 1[allkee 1ed C. higenbevm Chiel becuse Olficer NYN 91040 March 11,1991 Mr. Charles W. Hebl Direuor, Division of Reactor Projec:s United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406

References:

(a)

Facility Operating License No. NPF 86, Docket No. 50 443 (b)

USNRC Letter dated March 5,

1991, ' Request for Additiocal Information on Welds' C.W. Hebl to T.C. Feige:baum (c)

NHY Letter NYN.91029, dated February 26,1991,' Response to Request for Infoi mation', T.C. Feigenbaum to T.T. Martis (d)

USNRC Letter dated February 22,1991, ' Request far Information on Radiograph Records', C.W. Hehl to T.C. Feige:bau=

(e)

NHY Letter NYN.91073, dated February 8,1991, ' Additional NHY Response to 01G Request or 1 formation', T.C. Fei e:baum to L.J.

t Norton

Subject:

Response to Request for I: formation

Dear Mr. Hehl,

E: closed please find New Ha:pshire Yankees' response to the i:for=ation requested in USNRC letter dated March 5,1991 [ Reference (b)).

Should you have any questions regarding this matter please contact Mr. Terry L Harpster, Director of Licensing Services at (603) 474 9521, extension 2765.

Very truly yours,

,aayA~

Ted C. Feige:baum TCF:JMPlact

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b New Hernpshire Yenice Divisien ci ?vilic Se.< ice Compcny cf New Hempshire i

P.O. Box 300

• Sechreck, NH 03374

• Telephone (603) 474 9521 l

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United States Nuclear Regulatory Commission March 11,1991 Atte ntion: -

Document Control Desk-pegg two ec:

Mr Thomas T. Martin Regional Administrator United States Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Mr. Gordon E. Edison, St. Project Manager Project Directorate 13__

Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Document Control Desk U.S. Nuclear Regulatory Commission f

Washington, DC 20555 1

Mr. Noel Dudley.

NRC Senior Resident inspe_ctor P.O. Box 1149 Seabrook, NH 03874

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New llampshire Yankee March 11,1991 ENCLOSURE 1 TO NY:'.91040 i

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s REOUEST di e

The basis for NHY confidence that required radiographs stre made for (Pullman.

Higgins) field welds, with satisfactory results and radiograph retection as required.

MSPONSE NHY is confident that the required radiographs were ::ade for Full =at.Higgins fic!d welds with satisfactory results and radicgraph retectic: as required. This cetfidecce is based on the followieg:

1.

The Desig:, Constructico a:d Outlity Atsura::ce prtgrats a:d ;rt:tices it. effe:t during the cot truction of Seabrook Statio: ;rovided a defe:se.ir..dttth appretch to the quality and i:tegrity of the physical compett:ts and suppcrting re:Ord ensur:

documenta: ion.

The deft:se in depth concept c:taile d a hittarchy of internal indepe:: dent checks and balecc:s by the crptiraticts inv:!ved it the desigt and construc. ion of Seabroek Statics, le additica to these itter:al =catur:s, extertal reviews and audits by i:depe:de:t third parties verified the adequacy of both individual program elece:ts and the total overall pogram to ensure full cocpliate:

with the welding lastallation, inspection etd records pro::sses.

During d: sign and constructien, the OA Fregrams of the Architect Engite:r (A.E)

Ucited Engineers and Co:structors (UE&C),1:staller Fullma:.Higgins (p.H), and Yankee Atomic Electric Co=pany (YAEC), as age:t for NHY, provided centrols to perform radiography includier sufficie:t oversight to c:sure that radicgraphy for P.H field welds was satisfactorily perfore:d. Key centrols associtte with radior:piy for ASME 111 systems included:

a.

Welds r:qu:ri:g radiography were identi!!:d c: P H field drawi:gs, t.

Perforca:c: of radiography was controlled v!: P H Field Weld Process She:ts revi:wed by F-H Engineeri g a:.d QA. After completice of -

radiography, P.H QA personnel reviewed completed records to c sure radiography r:quir:d by the Proc:ss Sh::ts wa r, satisfactorily perforced.

L At the cc:clusion of construction, P-H E:gi::tri:g and QA perso :el c.

>erforce:i sepente fi:!d walkdowns to ensure the pipi:g confi; uratic:

was consiste:t with pipic; drawings. ASME N.5 code data regerts were prepar:d by both P il (as the Instal!:r) and UE&C (as the Desi :er) in order to de=ctstr:te that ASME 111 pipicg syst: s cet F

ti : ASME Ill code. One st:p in the rccess was to verify that code t

requir:d radiography was satisfactorily perforced. Anoth:r step was e

a syste= P&lD review p:tforced by UE&C E:gineering to assure that all ASME porticas of piping syste::s were identified on an N 5 code dtta report.

1

d.

YAEC performed a third level audit function of P.H radiographs activities.

YAEC also performed an additional, overall review of radiographic packages for P H field welds prior to including them in the records vault.

2.

The results of four separate recent review efforts substettiate the effectiveness and adequacy of the programs and practices that were lo effect duricg the design and constructioc of Seabrook Station. These four reviews i:cluded the NRC's Special Independent lespection Review Team (NUREG 1425), corrective actiocs NHY performed as described in NHY CAR 91001, Congressional inquiries (via the NRC) requesting Weld Process Sheets and Radiographic lespectien Reports and fically a separate NHY review of T.H wad packages performed for the years 1951 through 1934 3.

As a result of these conbited reviews only one field weld record, a radiograph for weld cu:nber CS 325 02.F0 04, was not found. Although the radiograph was not in the weld record package, other documettation clearly de=cestrates that the radiograph was take:, appropriately reviewed as required by the procedures and pregra:us and accepted as satisfatory. As patt of the corrective actions for NHY CAR 91001, NH'Y has coccitted to re. radiograph this weld in the upcotaing plant cutage to complete ihe weld record documettation package.

In summary, NHY's confider.ce is based on the Design, Co struction and Quality Assurance programs and practices in effect duricg the construction of Seabrook Station.

This l'

confidence is further confirmed by the recent additional detailed reviews and icquiries regarding weldicg practices and records.

2 1

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• 6 l

e REOUEST #2 e

Clarification of the number of (Pullman Higgics) radiographs audited / examined incident to responses to post construction inquiries concerning weld adequacy.

E.ESPotiSE NHY has conducted a separate physical count of the radiogr:phy packages removed froc:

the vault as part of post construction follow up questions. The post. construction follow up questions coesisted of four separate efforts. These efforts included:

a)

NUREG 1425, b)

Corrective actiocs performed as described in NHY C/ R 91001, c)

Cocgressio:al 1:cuires and d)

Additional NHY reviews.

This physical count was also separately verified to c:sure the precisior. and accuracy of the results. The physical count process entailed the followicg ectiots:

1.

A single listing of welds was developed from the four separate follow up efforts.

2.

This list was ce=pered with the actual index cards used to re=ove the weld packages fro = the vault for review.

3.

This resulted in : tabulatica of the actual nu=her of ti=es a weld radiograph package was re=oved from the vault for : ch of the four separate efforts.

~

This physical count accurately deterni: d the exact cumber cf separate and disti:ct radiograph packages retrieved cd the number of unique welds invelved. In the February 26, 1991 submitta! NHY indicated that:

'There have been 1174 ccc25icts where F H weld radiographic film packages have been retrieved fro:: the SHY storage vault incident to post t 0:struction follow ur on weld adequacy questio 5.

Since certain packaces wert *etrieved on cultiple l

cc:asions, it has be"

^'"-1:ed that aL,.lf 1 separate a::d distinct l

radiegraphic packages have been retrieved and su

,,1y verified as a result of this effort.'

l Based on the physical count there were 1225 separate occasions where radiograph packages were retrieved from the NHY vault for review. In some instances a single package was l

reviewed as cacy as five (5) ti:nes. Elici:ating this duplication i:dicates that there were 960 unique weld packages reviewed.

NHY has completed a review of each of these packages and verified that the required radiographs were present in the vault for each of these 960 welds.

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New Itampshire Yankee March 28,1991 l.

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ENCLOSURE 5 TO NYN 91052 4

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.,og UNITED STATES k 'f ),

S NUCLEAR REGULATORY COMMISSION I

REGION I 475 ALLENDALE ROAD

'****j KING OF PRUS$1A, PENNSYLVANIA 19406 Docket No. 50-443 MAR 191991 Public Service Company of New Hampshire ATTN: Mr. Ted C. Feigenbaum President and Chief Executive Officer New Hampshire Yankee (NHY) Division RECElVED Post Office Box 300 Seabrook, New Hampshire 03874 M 2 0 90 Gentlemen:

LICENelNG

Subject:

Completeness of Radiographic Records We have reviewed your March 11, 1991 letter describing the bases for your confidence that ad required radiographs for Pullman Higgins field welds were made, that those welds are satisfactory, and that the sadiographs and associated radiograph inspection records (RIRs) were received by New Hampshire Yankee for permanent storage.

NRC inspections and assessments during Seabrook construction, the NRC special Independent Review Team (IRT) inspection documented in NUREG 1425, hydrostatic tests, in-service inspections, and Seabrook's Quality Assurance program and processes provide reasonable 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, oricinal RIR, and evidence of the committed confirmatory Yankee Atomic Energy Company (YAEC) 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 acted 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 commitment, and 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-Higgins field welds, New Hampshire Yansee is requested to accomplish the following.

1.

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

ASME, B31.1).

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Public Service Company of 2

!MR101991 New Hampshire 1

2.

Determine whether New Hampshire Yankee has the required radiographs and RlRs 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, assess the individual and generic causes and safety implications, and take appropriate compensatory and/or corrective 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 con ';'cting that effort.

Sincerely, p

Thomas T. Martin Regional Administrator cc:

L. E hiaglathlin, Jr., President and Chief Executive Of6cer, PSNH J. M. Peschel, Regulatory Compliance 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 Massachusetts S. Woodhouse, Legislative Assistant Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

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

M 1o

'i SEABROOK HEARING SERVICE LIST

[

- Robert A. Backus, Esq.

Jack Dolan Backus, Meyer and Solomon Federal Emergency Management Agency E

116 Lowell Street 442 J. W. McCormack (POCH) i Manchester, New Hampshire 03106 Boston, Massachusetts 02109 j

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Regional Administrator, Region I Gerald Garfield, Esq.

U.S. Nuclear Regulatory Commission Day, Berry and Howard 475 Allendale Road City Place i

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. King of Prussia, Pennsylvania 19406 Hartford, Connecticut 06103 3499.

3 b

Mr. Suzanne Breiseth Resident inspector g:

Paard of Selectmen U.S. Nuclear Regulatory Commission Town of Hampton Falls Seabrook Nuclear Power Plant 2

Drinkwater Road Post Office Box 1149 h

Hampton Falls, New Hampshire 03844 Seabrook, New Hampshire 03874 1

j Mr. R. Sweeney Administrative Judge j

New Hampshire Yankee Division Howard A. Wilber Puldic Service Company of New Hampshire Atomic Safety & Licensing Board Panel a

y Suite 610, Three Metro Center U.S. Nuclear Regulatory Commission 1

Bethesda, Maryland 20814 Washington, D.C.

20555

[

Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore, Esq.

7 Atomic Safety and Licensing Appeal Board

- Atomic Safety & Licensing Appeal Board

. U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 4

Washington, D.C.

20555 Washington, D.C.

20555-

[

3

- 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 7

Paul McEachern, Esq.

Dr. hjauray Tye, President 1-25-Maplewood Avenue

' Sun Valley Association f

PFO. Box 60 209 Summer Street 2

Portsmouth, New Hampshire 03801 Haverhill, Massachusetts.

q U

-R. Scott Hill Whilton, Esq.

Diane Curran, Esq.

a

.Lagoulis, Clark, Hill Whilton Harmon, Curran, & Tousley

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'& Rotondi 2001 S Street, N.W.

79 State Street-Suite 430 j

Newburyport, Massar'..asetts 01950 Washington, D.C.

20009 N

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Mr. Alfred V. Sargent Ashod N. Amirian, Esq.

Chairman 145 Main Street Board of Selectmen P. O. Box 38 Salisbury, Massachusetts 01960 Bradford, Massachusetts 03801 i

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.E.

Atomic Safety and Licensing Board Room 8105 U.S. Nuclear Regulatory Commission Washington, D.C.

20426 Washington, D.C.

20555 Mr. George L. Ivetson, Director Mr. John L. Lovering, Acting Director-New Hampshire Office of Emergency Massachusetts Civil Defense Agency Management -

400 Worchester Road i

State Office Park South P. O. Box 1496 107 Pleasant Street Framingham, Massachusuts 02108 Concord, New Hampshire 03301 ATTN: James Muckerheide Mr. T. L. Harpster Administrative Judge Public Service Company of New Hampshire Kenneth A. McCollom F

P. 0; Box 300 1107 West Knapp Street Seabrook,' New Hampshire 03874 Stillwater, Oklahoma ' 74057 Administrative Judge Adjudicatory File (2) _

G. Paul Bollwerk, III, Chairman -

Atomic Safety and Licensing Board Atomic Safety & Licensing Appeal Board Panel Docket

.U.S. Nuclear Regulatory Coinmission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Barbara J. Saint Andre, Esq.

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

Atomic Safety and Licensing Board Counsel for Amesbury, Newburyport, U.S.-Muclear Regulatory Commission -

_ Salisbury

Washington, D.C. - 20555-77 Franklin Street Boston, Massachusetts 02110 Mr. Lean Maglathlin

.Cengressman Nicholas Mavroules

[

Public Service Company of New Hampshire U.S. House of Representatives L

-100 Elm Street -

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70. Washington Street l

Manchester, New Hampshire 03105

- Salem, Massachusetts 01970 L

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i Seabrook Hearing Service List 3

Mr. R. M. Kacich hir. J. F. Opeka

- Northeast Utilities Service Company Northeast Utilitics Service Company l

P. O. Box 270 P. O. Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141 0270 John P. Arnold, Attorney General Atomic Safety and Licensing Appeal

_ George Dana Bisbee, Associate Board Attorney General U.S. Nuclear Regulatory Commission Attorney General's Office Washington, D.C.

20555 25 Capitol S'reet Concord, Nei Hampsnire 03301 Mr. J. M. Pesche!

Mr. Peter Brann Public Service Company of New Hampshire Assistant Attorney General P. O. Box 300 State House, Station #6 Seabrook, New Hampshire 03874 Augusta, Maine 04333 Office of the Attorney General Board of Selectmen One Ashburton Place Town of Amesbury 20th Floor Town Hall Boston, Massachusetts 02108 Amesbury, Massachusetts i '

Thomas Dignan, Esq Chairman, Board of Selectmen John A. Ritscher, Esq, RFD 2 Ropes and Graf South Hampton, New Hampshire 01950 One International Place

. Boston, Manachusetts- 02110-2624 j3 Vh

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New llampshire Yankee March 28,1991

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New Hampshire Yalll{ee Ted C. Feigenbovm ChieI Executive Of f;cer NYN 91050 March 25,1991 Mr. Thomas T. Martin Regional Administrator United States Nuclear Regulatory Commission Region !

475 Allendale Road King of Prussia, PA 19406

References:

(a) f acility Operating License No. NPF 86, DocF tio. 50 443 (b)

USNRC Letter dat-d March 19,1991, ' Completeness of Radiographic Records', T.T. Martin to T.C. Feigenbaum (c)

NIIY Letter NYN 91040, dated March 11,1991, ' Response to Request for Additional Information on Welds', T.C. Feigenbaum to C.W. Hebl (d)

USNRC Letter dated March 5,

1991, ' Request for

.ditional Information on Welds *, C.W. Hehl to T.C. Feigenbaum (e)

NilY Letter NYN 91029, dated February 26,1991, ' Response to Request for Infortnation', T.C, Feigenbaum to T.T. Martin

~

(f)

USNRC Letter dated February 22,1991, ' Request for Information on Radiograph }c aerds", C.W. Hehl to T.C. Feigenbaum

Subject:

Response to Radiograph Review Request

Dear Mr,

Martin, Enclosed please find New Harnpshire Yankees' response to the information requested in USNRC letter dated March 19,1991 [ Reference (b)).

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g, Hampshire Yankee Division of Public Semice Company of New cmpshire

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O United States Nuclear Regulatory Commission Patch 25,1991 Attention:

Mr. Thomas T. Martin Page two Should you have any questions regarding this matter please contact Mr. Neal A.

Pillsbury, Director of Quality Prograrns at (603) 474 9521, extension 3341.

Very truly yours, r

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,<kw~

Ted C. Fe genbaum TCF:EWD/act Enclosure cc:

Mr. Gordon E. Ed:. cu, Sr. Project Mange.

Project Directorate 13 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Docurnent Control Desk U.S. Nuclear Regulatory Cornmission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, NH 03874 e

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l New llampshire Yankee March 25,1991 l

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ENCL,OSURE TO NYN-91050 RESPONSE TO RADIOGRAPIl REVIEW REQUEST l

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New Hampshire Yankee March 25,1991 l

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ENCLOSURE TO NYN 91050 i

RESPONSE TO RADIOGRAPH REVIEW REQUEST 1

- Pursuant to the request in your March. 19, 1991 letter, New Harnpr, hire Yankee (NHY) will re review the Seabrook Station as built isometric drawings. This review willidentify Pullman-Higgins (PH) field welds that required radiography.by code, e.g. ASME, B31.1. This effort will_also verify that the quality documentation, e.g. radiographs and RIRs, for these welds is retained in the records vault. The documentation will also be reviewed to re verify the Yankee Atomic Electric Company Quality Assurance radiograph reviews, l>

NHY will generate records documenting the review process and the results of the review,-

The preparation of.auditable records for subsequent detailed reference requires that this entire effort be conducted in a rigorous and tightly controlled manner. NHY will complete this effort on or before August 31, 1991. As part of this process NHY will reconcile any discrepancies and take the appropriate corrective or compensatory actions. The results will be reported to the NRC within one week of completing the review.

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March 23,1991 s

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