ML20070T345
| ML20070T345 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/06/1983 |
| From: | Bean F YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20070P788 | List: |
| References | |
| QCP7-1, NUDOCS 9104040117 | |
| Download: ML20070T345 (18) | |
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YANKEE ATOMIC ELECTRIO COMPANY
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l SEABROOK STATION Attachment 7.1 .
CONSTRUCTION Revised: 9/6/83 FIELD QUALITY ASSURANCE GROUP t' ASTER CHECx L.1ST I
Title:
RECEIVING INSPECTION OF UE&C Number: QCP7-1 PURCHASED ITEMS 7
Parent Specificaticn: I k i t b.
UESC QCP 7-1 O J t
I -. U :_. _. O ~
I i REVISIONS No. Date Prepared By l$pprovedBy Revision: 0 j
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Prepared y: Fra7dsin W. Bean 3 - *
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4 ppt ved B .T on 5
6 Approval Date: /-h 7- 77 -
- 4 REFERENCED DOCUMENTS -
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Reference l Rev. 6/or. Da tel Specific Sec tion, par. , etc. k A.UE&C OcP 7-1 lR-1 9/l/'76lN/A 1 B.UE&C FGCP-3 R-1 9/13/76l Para.3.0,6.0,and7.0 C. ANSI N45.2.2 12/20/72 Sections 1, 2, and 5
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9104040117 910322 PDR COMMS NRCC CORRESPONDENCE PDR -,
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REVISED: 9/6/63 Attachment 7.4 Check List No.: ANSI N45.2 Revision 1 ~~
Dates,_ 8/13/80 YAEC CFQA MASTER CRECK LIST LIST OF CRANCES Section/Page Change I/5 Added Ouestions 2.17, 2.18, 2.19.
II /A'.1 Added References 3 & C III/All Added Reference D iV/All Added Reference E & F V/All Added Reference G 1'
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,' REVfSED: 9/6/83 At tac,hnent 7.5
, YAEC CFQA Page 1 of 1 MASTER CHECK !IST INDEX B ,
File TITLE IDENT. Location R0 R1 R2 R3 Bedding & Backfilling BBC-1 M 13.4.4 -
7/16/79 Blasting Monitoring Program BM21 M 15.1.1 7/16/76 9/8/76 '8/31/77 Blast Monitoring Program Equipment Maintenance BM-2 M 15.1.2 9/8/76 7/11/79 Blast Monitoring Training- BM-3 M 15.1.3 9/8/76 ?
Program t
Requisition and Control of Blouin M 5.6.8- 10/3/80 Weld Rod Material FGCP-8
- Field Weld Procedure Spec. Blouin WPS-4 FGCP-12-2 M 5.6.11 10/2/80 I
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1 REVISED: 9/6/83 Attachment 7.6 FBM Check List: OCP-403 Revision: O Page 2 of 2 Yes No N/A Section II (Referenew ->
- 1. (3.15) For joint cleaning, are surfaces of the veld area thoroughly cleaned of all oxides, mill scale, cutting slag, grease, moisture and dirt injurious to welding? (Paga. 5.13)
- 2. (3.19) Is galvanizing removed for a minimum of \" in length of weld surface area? (Para. 5.13)
- 3. (3.20) Is paint removed for 2" either side of the veld?
(Para. 5.13)
- 4. (3.22) When grinding contaiminants from weld surface area is caution taken not to reduce base metal thickness?
(Parn. 5.13)
- 5. (3.28) Is joint fit qn of components during fabrication completed (0940) with the gap between veld joint areas kept to the minimuu (0530) necessary to complete the fit-up? (Para. 5.16) (FBM la 05-152
- 6. (3.29) Does the minimum gap between weld joint areas not exceed 3/16"? (Para. 5.16)
- 7. (3.30) Are fillet welds completed using the Electrode type designated in the applicable Welding Procedure Spec.?
(Para. 5.17.A)
- 8. (8.50.2) Are completed welds examined and final visual inspected in accordance with AWS-D1.1, Section 6 and OCP-403? (Para. 5.23.B)
- 9. (3.51) Are veld joints not painted until the veld has been completed, inspected and accepted? (Para. 5.24.A)
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w REVISED: '9/6/83 Attachment'7'.7 i Page 1 of 1 YAIC CFQA Referenced Documents for Master Check Lists
- Index M 2.0 API - - - - - - - - - - - - - Appendix B to 10CTR50 Document Eevision and/or Date ,
Master Check List Nos.
M 2.2. ACI STANDARDS I
H 2.2 ANSI STANDARDS i 2.2.1 N 45.2 4/7/77 QA-6, QA-14, QA-15, QA-1 l
QA-12,-QA-2-1, QCP-8 QCP-7-1, QCP-7-2
'j QCP-13-1, QCP-13-2 ,
ANSI 45.2 2.2.2 N 45.2.1 1973 ANSI 45.2.1 2.2.3 N 45.2.2 12/20/72 QCP-7-1, QCP'7-2, QCP-13-1, QCP-13-2 2.2c4 N 45.2.3 3/15/73 QCP-13-1, QCP-13-3
- 2.2.5 N 45.2.4 2.2.6 N 45.2.5 2.2.7 N 45.2.6 1/25/73 TL-1, QA-2-2, QAS-1 2.2.8 N 45.2.9 6/6/74
- QCP-17-1 2.2.9 N 45.2.11'
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2.2.10 N 45.2.13 2/27/76
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REVISED: 9/6/83 A t t a c hmen t 7'. 7 Page 1 of 1
, YAIC CPQA Referenced Documents for Master Check Lists Ind ex M 2.0 AP I - - - - - - - - - - - - - Ap p e n d ix B t o 10C FR5 0 Document Revision and/or Date !! aster Check List Nos.
M 2.1 ACI STANDARDS i .
M 2.2 ANSI STANDARDS 2.2.1 N 45.2 4/7/77 QA-6, QA-14, QA-15, QA-1 QA-12, QA-2-1, QCP-8
. QCP-7-1, QCP-7-2 "
QCP-13-1, QCP-13-2 %
ANSI 45.2 2.2.2 N 45.2.1 1973 ANSI 45.2.1 2.2.3 N 45.2.2 12/20/72 QCP-7-1, QCPa?-2, QCP-13-1, QCP-13-2 2.2.4 N 45.2.3 3/15/73 ,
QCP-13-1, QCP-13-3 2.2.5 N 45.2.4 2.2.6 N 45.2.5 2.2.7 N 45.2.6 1/25/73 TL-1, QA-2-2,-QAS-1 2.2.8 N 45.2.9 6/6/74- QCP-l? ,
2.2.9 N 45.2.11 2.2.1 "N 45.2.13 2/27/76 .
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ATTACHMENT 3 Attachment 2 Request 2:
(excerpt from Item II of request of May 14, 1990) please provide me a listing of records, pertaining to weld repsirs performed on nfety-related piping, that the Seabrook licensee is required to maintain pursuant to 10 CFR 50, Appendix B and other applicable NRC requirements.
Response 2:
The Code of Federal Regulations, in particular 10 CFR 50, Appendix B, does not delineate specific records which must be maintained relative to safety related pipe welding or repair welding. Specific commitments in this regard are docu-mented in the Seabrook Statien Final Safety Analysis Report (FSAR) which indi-cates general compliance with USNkC Regulatory Guide 1,88, Revision 2_. Regula-tory Guide 1.88, titled " Col'oction, Storage, and Maintenance of Nuclear power plant Quality Assurance Records," endorses an American Natienti Standard In-stitute ( ANSI) standard ( ANSI N45.2.9-1974) for quality assurance records asso-ciated with nuclear power plants. Additionally, the safety-related piping at Seabrook Station was generally installed in accordance with tre American Society of Mechanical Engineers ( ASME) Boiler and Pressure Vessel Code,1977 edition through the Winter 1977 addenda. The ASME Code,Section III, Subsection NA, i
specifies general requirements for quality assurance records.
Specifically, with regard to welding and weld repair activities on the safety-related piping installed at Seabrook Station, the quality records must include the final results of the Code required nondestructive examinations (including final radiographs, where required); heat treatment records, where applicable; and the welding or weld repair process sheets, which provide traceability to other required QA records such as certified material test reports (CMTRs for the pipe material), welding filler metal material reports, the welding and weld repair procedures and their qualification records, and the welder qualification reccrds. Additional quality records related to the above welding activities
- include nonconformance and deficiency reports, receipt inspection reports for i
vendor items, manuf acturing records supplied by piping and pipe component ven-dors, and the ASME Code Data Reports for the overall ASME. piping system and its components.
! Some of the above record types are " nonpermanent" QA records, while others are i " lifetime" records. These terms are defined and their criteria explained in ANSI N45.2,9-1974, with the recommended minimum retention periods forleach type
- of document spscified_in Appendix A.to the_ ANSI standard. It is also noted
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that, while the quality _ records' pertaining to welding and weld repairs r_equire-l retention, maintenance and retrievability for the periods specified, this does t
not imply that all of the records are available in tt.e weld package for a specific weld. For example, a field weld process sheet documents the heat num-ber of the weld filler material consumed and provides traceability to-the-pipe components being joined. The quality records for both of these items are main-tained separate from the specific field weld package,Lbut are still retriev-able. These vendor records themselves may evidence traceability to yet other vendor records, with documentation of the fact that the design and procurement -
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Attachment 3 i
l requirements for the purchased material have been met. Traceability of com-ponent and material quality is thus maintained in the construction process, f rom manufacture through item installation.
]n addition to the record types listed above as quality records related to pipe welding and weld repair activities, the ASME Code delineates certain record-requirements for specific activities impacting code criteria. For example, for ASME Section Ill, Class 1 component weld repairs, the dimensions of the weld repair must be recorded where postweld heat treatment (PWHT) is waived in mate-rial that otherwise requires PWHT. In such a case, either the actual repair dimensions, or some other evidence that maximum allowable repair criteria.are not exceeded, must be documented in a quality record to provide confirmation that any PWHT waiver was properly allowed in compliance with the ASME Code, Similarly, for Class 1 base metal repairs, the ASME Code specifies that a chart showing the location and size of the repair cavity be-provided if the depth of the material repair exceeds certain limits. Such a chart would be a quality record. The above examples illustrate the point that the evidence of quality provided by the records can be different depending upon the Code requirements and the criteria supporting them.
In general,10 CFR 50, Appendix B, Criterion XVII specifies that " sufficient records shall be maintained to furnish evidence of activities affecting qual-ity." While certain documents, as discussed above, are considered qtality records for retention in accordance with committed codes and standards, other documents, such as Weld Repair Orders, were not so prescribed. For such docu-ments, the requirement to retain them was dependent upon judgement as to whether they provided supporting evidence of quality, as necessary for the-prescribed QA records, e.g., nonconformance reports. Thus, while weld. packages contain documents delineated to be quality records, they also may cantain additional documents, not so prescribed, which relate-to weld quality.- As pre-viously discussed, the weld packages also provide traceability-to other quality records which are not part of the weld package.
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Attachr.ent 14 Request 9:
(Provide) the staff's position concerning specific failings of the licensee.
YAEC, and/or P-H to comply with Appendix B, particularly regard to compliance with Criteria II, V, VI, IX, XV, XVI, XVII, and XV111.
Response
As has been discussed in the NRC response, dated September 21,.1990, to_the July 30, 1990 letter from Congressmen Dingell and Kostmayer regarding welding issues at Seaorock Station, 28 notices of violations related to piping, welding and NDE activities at Seabrook Station were issued by the NRC during the con-struction period from 1978 to 1986. Twenty-three of these violations were cited during the period 1930 to 1933, resulting in significant corrective action _on the part of the licensee and resulting in improved performance, as reflected by both the declining number of enforcement actions and improved-Systematic Assessment of Licensee Performance (SAlp) ratings in this area.
With regard to the NRC Independent Review Team inspection of-the adequacy of the welding and NDE programs at Seabrook Station, the following major findings and conclusions are summarized in the Executive Summary of NUREG-1425:
P-H failed to identify and correct film and weld deficiencies until long after they occurred, violating NRC requirements and permitting-the same mistakes to keep occurring. However, through the YAEC film overview program, the licensee did eventually resolve these problems by ensuring that' the final welds and associated film met applicable code requirements.-
In some instances, records aeJ procedural adherence-type problems of. lesser 4 safety significance may have violated'NRC requirements during the construction period. These problems were investigated to the. depth necessary to reach a conclusion regarding their safety sigr.ificance.
One of the noted procedural adherence-type problems was reviewed by NRC-Region I inspectors with the finding that certain construction procedures had not been followed. This issue was documented in Inspection Report 50-443/90-12=and classified as a severity. level V, non-cited violation in accordance with the NRC Enforcement policy (10 CFR Part 2, Appendix C, Section V.A). However,_in evaluating the overall scope and conclusions of the NRC Independent Review Team effort at Seabrook-Station, to_ include cc. sideration of the typos, significance, and age of the problems identified and the corrective actions implemented by the licensee, no notices of violation were cited or other enforcement actions taken as a result of the NUREG-1425- findings.
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Furthermore, with regard to the unspecified-failures to comply with eight of the eighteen criteria of Appendix B, referenced in the _above request, a further
( explanation of the intent of 10 CFR 50, Appendix B, is warranted. The Introduction to Appendix B includes the following cogent. points relative to its applicability:
6 4
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=a . - . .. - . . , . - .w.... se.... ,__-.an Attachment 15 (Request 9 Continued) <
, "Every applicant for a construction permit is required by the provisions of section 50.34 to include in its preliminary safety analysis report a 4 description of the quality assurance program to be applied to the design, !
fabrication, construction, and testing of the structures syt,tems, and com-ponents of the facility."
r and- .
"As used in this appendix, quality assurance comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service."
As discussed in the NRC response, dated September 21,-1990, to an August 9, 1990 letter from five members of Congress regarding welding and NDE issues at Seabrook Station, the Final Safety Analysis Report (FSAR) provides a discussion, as required by 10 CFR 50.34, of how the applicable requirements of 10 CFR 50, Appendix B are satisfied. The YAEC program for quality assurance iv.olved three !
control levels. As the QA program related to Pullman-Higgins pipe welding and NDE, Pullman-Higgins quality control personnel provided Level 1 QA functions, while YAEC provided the Level 2 (surveillance) and Level 3 (audit) overviews.
As noted in the Introduction to Appendix B, these multiple level of controls
' and quality overviews comprise the total Quality Assurance program. YAEC QA personnel in their surveillance and audits identified problems in the Pullman-Higgins radiographic review program and required corrective measures (e.g.,
adding an additional review by a RT Level III film reviewer) to be initiated.
They further continued a licensee film review effort at a Scope in excess of
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what would have been normally expected of a Level 2 surveillance activity, j
Such corrective action and licensee management attention is viewed as a QA program
- that is working as intended. Of course, if Pullman-Higgins QA Level I controls j had been more effective, the YAEC QA Level 2 and 3 controls would not have needed l
to beccme so involved in the radiographic review effort. However,-the fact-that YAEC QA personnel did programmatically become involved is not evidence of.
general noncompliance with Appendix B, but rather the very intent of establishing quality assurance criteria, i.e., "to provide adequate. confidence that a structure, j system or component will perform satisfactorily in service."
Furthermore, NRC efforts like the Construction Appraisal Team (CAT) and NDE Van inspections, along with SAlp evaluations, assessed the effectiveness of-the YAEC QA program activities and the corrective action progress in the-welding and NDE areas. As was noted earlier, significant improvements in project per-formance were noted in these areas from 1984 forward.
In summary, it is the NRC staff's position that specific failures to comply with 10 CFR 50, Appendix B, with regard to pipe welding /NDE were identified- ,
during construction and were cited, as documented in several inspection reports.
The NRC Independent Review Team inspection resulted in the identification of some additional procedural adherence-type problems of lesser safety significance t
Attachment 16 (Request 9 Continued) which were not cited. One of the factors considered by the NRC in the decision not to issue any new notices of violation was the effectiveness of the corrective action taken by the licensee, In general, such overall OA program ef fectiveness is the very intent of the quality assurance criteria embodied in 10 CFR 50, Appendix B.
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ATTACHMENT 4 8l *(
- Verro starts 7 ! NUCLEAR RIOUI.ATORY COMMISSION
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( oo *** 4M ALitNDAL.s noAo XINO OP PMVSt!A. PENNSYl,VANIA 1H00 Docket No. 50 443 flh 8 219M Pubile Service Company of New Hampshire l ATTN: Mr. Ted C. Felgenbaum
! President and Chlef Executive Of!Icer New Hampshire Yankee (NHY) DiviJon Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:
Subject:
Inspection Report 50 443/90 24 It has come to my attention that there are some minor errors in the subject inspection report sen to you on January 17, 1991.
The corrections ac provided in the revised Section 8.2, attached. Corrected portions are marked by a .ertical line in the right niargin and do not change any conclusions in the report, Thank you for your cooperation.
Sincerely, f, . r." : -- .
on R. Johnson, Chief
' Projects Branch No. 3 Division of Reactor Projects
. .. .: As Stated
ENCLOSURE 8.2 Missing Radiographic Record i
On December 27,1990, the NRC senior resident inspector wu informed by the Ueensee that
( radiographic films for one specific weld could not be found during a search of Chemical Volume
, and Control System (CS) welding records. The missing radiographs were related to Field Weld l CS 328 F0204, located in a three inch pipe line in the Pdmary Auxillary Building. This piping l
is the common line for the seal injection retum flow from the reactor coolant pumps and is categorized as ASME 111, Class 2 piping, for which radiography is the specified final code acceptable method of nondestructive examination (NDE).
The licensee's search of the CS system welding records was conducted in response to a l
Congressional staff request for information and documents for approximately 70 CS field welds.
Of the record sets being compiled, the only record problem identified to the NRC inspector was the missing radiographs for Field Weld CS 328 F0204.
The inspector was informed by licensee Q A, engineering and welding personnel that the licensee believes that the subject radiographs were never tumed over by the piping contractor, Pullman-Higgins, to Yankee Atomic Electric Company (YAEC) QA/NDE personnel for review and final vault storage. This position is supported by the microfilmed Radiographic Inspection Report (RIR) for this field weld. That RIR indicates that the radiograph was shot and accepted by Pullman Higgins Level III review on August 17, 1982 and reviewed and approved by the Authoriaed Nuclear Inspector (ANI) on August 23,1982. This RIR record prov! des no evidence l
of accomplishment, for this weld, of the YAEC practice of conducting an additional QA examination of all safety related radiographs. The final, hud-copy RIR, which would have provided evidence of a YAEC review and would have been filed with the radiograph in the records vault, was likewise missing. Additionally, the index ce,rd filing system initiated by
'YAEC to identify the radiographs reviewed and stored with thtit RIRs in the vault provided no evidence that the film for Field Weld CS 328 F0204 had been received from Pullman Higgins.
l The QA records available for this weld indleme that a final radiograph WAS shot and interpreted, '
with the results documenting weld compliance with ASME III Code, Class 2 criteria. The microfilm RIR provides evidence of weld qualhy and is supported both by the field weld process sheet records, which were initialed and dated by the Pullman Higgins Level III reviewer and the l
ANI, and by Revision 2 of Nonconformance Report NCE 2128, which docuinents a Pullman.
Higgins QA engineer's verification on Octcber 7,1982 that the weld was acceptably repaired and re radiographed. Additionally, other qudity records indleate that Field Weld css 328 F0204 was
! subjected to a volumetric ultrasonic testing (UT) inspection on knuary 31,1986 and a liquid
- penetrant testing (LPT) examination on February 12,1986. Both of these tests were conducted l in accordance with ASME XI baseline inservice inspection provisions In excess of the ASME I
Ill construction code requirements, and provided evidence rf acceptable weld quality.
l Therefore, while sufficient QA records are available to show weld quality in compilance with ASME code criteria, the radiographs for Field Weld CS-18 F0204, which the ASME code requires to be retained, are missing. Potential contributhy factors include: (1) a piping
isometric drawing OSO CS 328 02) error which mislabeled CS Field Weld 0204 u 0209 on August 3,1982; and (2) an entier revision to NCR 2128 which proposed a disposition to cut out and replace Fie]d Weld 0204 instead of repairing it. Wh11e the drawing error noted in Revision 7 was corrected in Revision 13 on December 7,1984 and the NCR disposiden to replace the weld was subsequently char ged to conduct a repair, uncertainty surrounding Field Weld CS 328 F0204 during the latter part of 1982 also may have contributed to failure of Pullman Higgins to submit the final radiographs to YAEC.
The QA documents that were turned over for review and microfilming provided evidence that a final radiograph had been shot and approved,in accordance with ASME m code requirements.
The fact that the radiographs were noi retained as required needs further review by the licensee to determine if it is an isolated case. Additionally, since the YAEC NDE Review Group Procedure No. 5 specified (circa 1984) YAEC review of all safety related radiographs, the missing radiographs may represent a licensee-identified violadon of a construction QA procedure.
The inspector questioned licensee engineering personnel regarding the status of any determination as to the reponability of this idemified problem to the NRC and was informed that an evaluation was in process. The licensee is also considering the documentation of this issue in a corrective action report (CAR) to provide a documented determination of the cause of the problem and assessment of corrective action from a generic standpoint. Additionally, record sampling, based upon some commonality with the subject weld (e.g., a search of other similar founh repair cycle welds) may be pursued by the licensee. Also, the need to re radiograph Fiald Weld CS 328 F0204 must be addressed Since the existing weld quality is currently not in question bued upon the available QA records, re radiography can be delayed until the next refueling outage when the piping can be drained without impacting plant operation.
The inspector had no further questions regarding the licensce's analysis of this issue to date and no concerns regarding the existing weld quality or CS system operability. However, since the licensee evaluation is still ongoing, the results of their review will require further assessment.
Such issues as reportability, generic applicability,- corrective action implementation and radiographic record replacement need to be addressed. Additionally, the fact that a construction QA procedure may have been vlotated must be assessed for s!gnificance.
Pending licensee comp?ction of their evaluation, implementation of all planned corrective-measures, and further NFC review of safety and enforcement aspects, along with the schedule for re radiography of Fielt weld CS 328 F0204, this item remains unresolved (90 24 02).
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