ML20085C271
| ML20085C271 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/30/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20085C274 | List: |
| References | |
| NYN-91134, NUDOCS 9109040216 | |
| Download: ML20085C271 (16) | |
Text
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.t : Now Hampshiro-Ted C. Feigenboom :
h Presdent and Chief Executive 04cer l
NYN 91134 !
August 30, 1991 h i
United States Nuclear Regulatory Commission
{
. Region ! l 475 Allendale Road . }
King of Prussia, PA 19406 Attention: Mr. Thomas T, Martin, Regional Administrator -)
References:
(a) Facility Operating Licens< No. NPF 86, Docket No. 50 443, ;
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_(b) NRC Letter dated March 19,1991, " Completeness of Radiographic :
Records" T T. Martin to T. C Feigenbaum - !
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(c) Transcribed Public Meeting Detween New Hampshire Yankee and-the l NRC conducted on April 10, 1991, j k
.(d) NHY. Letter- NYN 91076 dated May 13, 1991, " Transmittal of the Program' Description for the Reverification of Pullman Higgins Field $
Weld Records", T.C. Feigenbaum to T,T. Martin, (e) NHY Letter NYN 91088 dated May 30,1991, "May 1991 Status Report -
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for the Program for the Reverification of Pullman Higgins Field Weld-Records," T,C. Feigenbaum to T.T. Martin.
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_ (f)_ NHY Letter NYN 91101 dated June 28,1991. " June 1991 Status Report !
for the Program for the Reverification of Pullman Higgins Field Weld i Records," T.C. Feigenbaum to T T. Martin. --!
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(g) _ NHY Letter NYN 91122 dated July 31,1991, " July 1991 Status Report - l for the Program for the Reverification of Pullman Higgins Field Weld-j Records," T.C. Feigenbaum. to T.T, Martin, t
Subject:
August 1991 Final Status Report for the Program for .the Reverification of .$
Pullman Higgins Field Weld Records !
)
t
- Gentlemen: .
In the April 10,1991 Public . Meeting between' New Hampshire -Yankee (NHY) and'the LNRC [ Reference (e)], _ and ' as provided in - the NHY Program Description- for . the ;
7 Reverification . of Pullman Higgins.- Field 1. Weld. Records, . transmitted _- to ; the NRC on [
E May;13,1991- [ Reference (d)], NHY agreed to' provide the NRC with a - monthly written :
report of the progress of the Reverification of Pullman Higgins Field Weld Records Program._
' Accordingly, enclosed please find the status report for the month of August 1991. This final i
- status report provides the status of activities conducted during the month of August and;the ;
overall results of the- Reverification Program. ,
t e
New Hampshire Yonkee Division of Public Service Company of New Hampshire !
P.O. Box 300
- Seabrook, NH 03874
- Telephone (603) 474 9521 i f=^^PDR.@l WO40216 ADOCK 05000443910930 76b 3 h
R PDR
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i United States Regulatory Commission August 30, 1991 Attention: Mr. Thomas T. Martin Page two As provided in the enclosure, the results of the Reverification of Pullman Higgins Field Weld Records Program demonstrated that 2669 field welds required radiography by Code. New Hampshire Yankee has verified that in every instance the required radiograph examination method was conducted and subsequently reviewed, approved and found acceptable per the applicable Code requirements. The Reverification Program demonstrated compliance with Code administrative criteria applicable to the review of radiographs. The Program did not verify film quality or include a technical review of the radiographs. This demonstrates that 100 percent of the Code required radiography was performed per the NHY construction programs. In four (4) instances New Hampshire Yankee discovered that although the field welds were radiographed at the time of original installation and found acceptable per Code requirements, the Reverification Program could not subsequently locate the Radiograph inspection Reports (for 3 of the 4 instances) or radiographs (all four instances) for four (4) field welds. These four instances pertain solely to the retention of records. NHY has retadiographed these four field welds. The results have been reviewed by New Hampshire Yankee and found acceptable per Code requirements. Therefore, per th?
request outlined in the March 19, 1991 NRC letter to NHY [ Reference (b)], NHY currently l retains a complete radiograph record set for each field weld requiring radiography by Code.
In addition, all construction related radiographs and Radiograph inspection Reports have been independently reviewed by the Yankee Atomic Electric Company (YAEC) in accordance with the 1984 Yankee Quality Assurance Radiography Surveillance commitment.
Prior to the initiation of the Reverification Project, NHY found and took corrective action for three radiographic records packages that did not contain evidence of a prior YAEC independent review. With the exception of thr four sets of missing records, mentioned above, the Reverification Program found complete compliance with the various informal and formal YAEC Ouality Assurance Surveillance program requirements for a documented indepen6:nt review by YAEC since Pullman Higgins began welding in 1979.
NHY has conducted a Root Cause Analysis of the anomalies discovered during the Reverification Program. The results of this analysis indicate that there is no generic or systematic cause underlying the anomalies discovered as part of the Reverification Program.
All of the anomalies identified by the Reverification Program pertain to records management issues. This analysis therefore concluded that the already completed specific corrective actions bring the radiographic records into full compliance with Code and Quality Assurance requirements for records retention.
Should you have any questio.:s regarding this matter, please contact Air,. Neal A.
Pillsbury, Director of Quality Programs at (603) 474 9521, exte nsiosp3341. !
Very t[ ours,
& dAnSf Ted C. Fei rn.
Enclosure TCF:EWD/ss/act
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-United States Regulatory Commission - August 30, 1991 Attention Mr. Thomas T. Martin Page three cc: Mr. Gordon E. Edison, Sr. Project Manager Project Directorate 13 Division c,f Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ebe C. McCabe, Chief Reactor Projects Section U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406
- Mr. William Bateman Regional Operations Staff Chief Office of the Executive Director for Operations U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, NH 03874 Mr. Phil Joukoff United States Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Mr. Frank Forgione, Special Agent Office of the Inspector General
= United-States Nuclear Regulatory Commission MNBB 6715 Washington, DC 20555
'M hocument fCdatrdtl Desk %
United States Nuclear Regulatory Commission Washington, DC 20555 l-l l
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- g .
. New Hampshire Yankee August 30, 1991 I
ENCLOSURE 1 to NYN 91134 AUGUST 1991 FINAL STATUS REPORT FOR THE PROGR AM FOR THE REVERIFICATION OF PULLM AN HIGGINS FIELD WELD RECORDS i
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i AUGUST 1991 FINAL STATUS REPORT FOR THE PROGRAM FOR THE REVERIFICATION OF PULLM AN HIGGINS FIELD WELD RECORDS A. INTRODUCTION The following provides the final results of the New Hampshire Yankee Reverification of Pullman Higgins Field Weld Records Program. This report also summarizes programmatic activities conducted during the month of August 1991. This program was implemented in accordance with the program description submitted to the NRC on May 13, 1991.
B. PROGRESS B.1 Weld Tabulation (Task 1)
On April 22, 1991, Nuclear Energy Services (NES) personnel started the Task 1 weld tabulation effort, This effort was designed to provide a list of field welds requiring radiography in order to meet Code. As provided in the program description, the basis for this list is engineering design documentation (drawings and change documents) and the N-5 Code Data Reports.
The July 1991 Status Report [ Reference (g)] indicated that NES had completed the Task I weld tabulation effort. As part of the NHY verification, discussed in Sections C.3 and C.6 of this report, NHY determined that Pullman Higgins had also performed welding on containment electrical penetrations. Therefore, NES returned to the site to complete the drawing review for ASME Section 111, Subsection NE, Class MC field welds. The scope of the NES review included field welding performed under the ASME Section 111, Subsections N3, NC, ND, NE and NF, ASME Section Vill and ANSI B31.1 Codes. This work scope bounded the field welding performed by Pullman Higgins. The NES review was completed on August 19, 1991.
The final results of the weld tabulation effort demonstrate that Seabrook Station has 2,669 field welds which require radiography by the requirements of the ASME Sections !!!
and Vill and ANSI B31.1 Power Piping Codes. The 2,669 includes existing field welds for these Codes prior to the start of the current refueling outage. This total includes field welds performed by NHY, United Engineers and Constructois (UE&C) and Pullman Higgins.
The following table summarizes the distribution of the total field welds requiring radiography by installing organization and Code.
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e IOTAL FIELD WELDS REOUIRING R ADIOGR APHY QY CODE NILY. UEAC PH Totals ASME Ill Piping 52 8 2329 2389 ASME Ill Supports 0 0 8 8 ASME Ill MC 0 0 41 41 ASME Vill Unfired 0 0 1 1 Pressure Vessels B31,1 Power 0 9 221 230 Piping 52 17 2600 2669 As indicated in Section C,2 of this report, the NHY Nuclear Quality Group has
- - performed three Quality Assurance Surveillences of the NES efforts. One of the surveillances specifically focused on the NES drawing review which identified the field welds requiring radiography to meet Code. NHY has also reviewed the NES Interim Reports described in Section C.6, These separate reviews were used as a redundant check to ensure the accuracy of the wcid tabulation effort.
B.I.a Reouests for Engineerine Services During the_ portion of the weld tabulation effort conducted in the month of August there were no Requests for Engineering Services (RES) generated. As described in the program description, an RES is the mechanism for identifying and responding to potential anomalies generated as part of the we!d tabulation effort.
During the conduct of the entire Reverification Program there were a total of seven RES's generated. The questions raised by NES on the seven RES's pertained to clarifications on engineering documentation. As previously reported, NHY determined that none of these RES's had any impact on weld quality and were therefore not reportable to the NRC pursuant to the program description.
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B.2 Radioerach Package Inventory (Task 2)
On April 29, 1991, NES personnel began the Task 2 Radiograph Package Inventory.
This task was designed to provide a list of field welds for which radiographic films and Radiographic Inspection Reports (RIRs) are retained in the site records vault. This task also recorded the initials of the individuals that had reviewed the radiographic film.
The July 1991 Status Report [ Reference (g)] indicated that NES had completed the Task 2 Radiograph Package Inventory effort on July 2,1991. As of July 2,1991 NES had reviewed 4089 radiograph packages. The performance of the Task 3 Field Weld List and Radiograph Comparison, discussed in Section B.3 of this report, identified field welds requiring radiography that were performed by United Engineers ard Constructors and NHY.
Subsequently, NHY requested that NES return to the site to complete the Radiograph Package inventory for radiographs performed under the cognizance of UE&C and NHY The final results of the Radiograph Package loventory indicate that there are 4096 radiograph packages retained in the site records vault for ASME Section III Piping, Supports and Metal Containment. ASME Section Vill Unfired Pressure Vessel Base Metal Repairs; B31.1 Power Piping; and, Owner specified radiography applicable to B31.1 piping. 2,665 of the 4.096 radiograph packages retained in the site records vault are necessary to meet these Code requirements. The balance of the radiographs retained in the records vault were originally taken for two reasons. In the first instance radiographs were taken for field welds which were subsequently deleted, in the second instance radiographs were taken at the direction of NHY. Therefore, there are 1,431 of the 4096 radiograph packages retained in the records vault, that are in excess of those required to meet Code requirements. The Seabrook construction installation Specification for piping directed Pullman Higgins to radiograph field welds on the Main Steam, Feedwater and Condensate Systems. This Specification criteria was above and beyond the radiography requirements cited in the B31.1 Code. NHY applied this conservative requirement as a prudent means for ensuring the service performance of key non-nuclear, non safety related piping systems. The majority of the excess radiographs apply to this conservative measure. The comparison of the list of welds requiring radiography with the list of radiography retained in the records vault also delineated the radiographs for field welds which have been deleted by subsequent design modifications. The balance of the radiographic records retained were taken at the request of NHY for infor national purposes. NHY is retaining these radiographic records for historical purposes.
This retention is above and beyond Code and regulatory requirements.
l 'B.2.a Corrective Action Reouests Generated from the Radiograph Package Inventorv l
l- As described in the program description, the Corrective Action Request (CAR) is the
! mechanism for identifying and responding to potential weld record anomalies generated as part of the radiograph review effort. During the month of August one CAR was generated.
This CAR pertains'to the field weld list and radiograph package inventory comparison and is discussed in Sections B.3 and C.1 of this report.
l During the entire Reverification Program there were a total of 28 CAR's generated.
Eight of 28 pertain to the field weld list and radiograph inventory comparison and are discussed in Section B.3. The remaining 20 pertain to the radiograph inventory effort.
l None of the administrative discrepancies identified in these CAR's affected the physical l quality of the subject welds. As stated in previous monthly status reports these CAR's i
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addressed administrative issues including: legibility of radiographic film data; minor adrainistrative data mismatches between RIR*4 and radiographic film; and questions regarding required approvals of RlR's. Two (2) of the 20 CAR's identified a total of 4 individual pieces of film for two welds that did not retain the appropriate flashbox identification information. Flashbox information is imprinted on radiographic film for identification. The exposure date, system /line/ isometric nuruber, weld number and manufacturer's identification were not irnprinted on these 4 individual pieces of film.
Based on an average of 10 pieces of film per weld for 4096 radiographic packages there were approximately 41,000 individual pieces of film reviewed. Therefore, approximately 99.99% of the radiograph film, satisfied Code required administrative criteria. The corrective actions for the four individual pieces of film have been completed bringing the radiographic records into full compliance with Code administrative criteria.
B.2.b Corrective Action Associated with NRC Insocction 91-12 During a separate review of radiographic film associated with the NRC inspeution to review a sample of radiographs, NHY identified one field weld where the film did not fully satisfy the comparative density requirements specified in the ASME Code. NHY recently re radiographed this field weld to produce a film record set that fully meets the Code requirements.
B.2.c Summary of Radiograph Corrective Actions NHY has completed the corrective actions for these administrative deficiencies and ar> notated the radiographic film packages with references to the appropriate CAR's. These actions bring the radiographic records into full compliance with Code administrative requirements.
B.3 Field Weld List and Radiograoh Comoarison (Task 3)
A comparison was made between the list of field welds requiring radiography (Task 1 output) and the list of field welds for which radiographic records packages are retained in the vault (Task 2 output), This comparison confirmed that, with the exception of the four missing radiographic records packages, there are radiographs and RIR's in the vault for field welds which require radiography by Code. Section C.3 of this report describes the NHY Verification of the NES Task 3 Comparison Effort.
The Task 3 comparisons performed during the month of August generated one CAR.
, This CAR indicated that for one field weld,1 F1188-01 F0150, the requisite RIR and i
radiographic film was unavailable. NHY provided a report regarding this documentation deficiency to the NRC in a letter dated August 23,1991 (NYN 91130). Section C.1 of this
! report summarizes this CAR, For the entire Reverification Program there were 8 of 28 CAR's gen-rated from the field weld list and radiograph comparison. Four of the eight CAR's were completely resolved by NHY. The resolution of the remaining four CAR's indicated that were a total 4
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of four field welds for which certain parts af the applicable radiographic records (radiographs and RIR) were not available. NHY has previously reported all four records anomalies to the NRC in accordance with the reporting requirements delineated in the program description. The independent NHY comparison of field welds with retained radiograph packages discussed in Section C.3 of this report did not reveal any additional instances of records anornalies.
Regarding the identified welds for which certain parts of the radiographic records (radiographs and RIR) were not available, NHY has conclusively determined that these four welds had been radiographed and determined to be of acceptable quality. These four anomalies pertain solely to retention of records. Comparison of the four records anomalies to the total number of radiographic recoeds 'that are required to be retained by Code, 2669, reveals a successful records retention rate. of 99.85 percent. Additionally, the foregoing also demonstrates that 100 percent of the Code required radiography was performed per the NHY construction program.
NHY has reradiographed tt.e field welds for which the radiographic inspection reports and radiograpbs were missing. The radiographic film was reviewed in accordance with our present program requirements. The radiographs indicate that the field welds meet Code requirements. These four new radiographs and required radiograph review forms ? ave been retained in the NHY records msnagement system. With the completion of these corrective actions NHY retains all of the radiographic records for the 2669 field welds r. quiring radiography by Code. Therefore, rbe radiographic records are in full compliance with Code records retention requirements.
C. PERFORM ANCE MFajip_REMENT AND REPORTING C.1 Reports to the NRC During the month of August, NHY determined that one weld documentation anomaly was reportable pursuant to the Program Description for the Reverification of Pullman.
Higgins Field Weld Records. This anomaly regards the lack of radiographic film and the radiographic inspec! ion report for weld 1-FI 188-01-F0150.
In accordance with the reporting requirements delineated in the program description, telephone notifications regarding this anomaly were made to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the determination that it was reportable. Additionally, a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> written report regarding this anomaly was provided to the NRC on August 23,1991 (NYN-91130). This written report established that the identified weld record anomaly does not compromise the integrity of this weld or other Seabrook Station welds. It was also established that this record deficiency does not compromise the integrity of the system in which this weld is located, thus it does not produce any reduction in the protection provided for the health and safety of the public.
The following provides a summary description of this records anomaly, cause of the deficiency, and corrective actions implemented.
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Descritstion of Anomalv Pullman Hinnins F; eld Weld 1 F1188 01 F0lSO As stated in NHY letter NYN 91130, dated August 23, 1991 Pullman Higgins field weld 1 FI 158 ObF0150 is a circumferential groove weld on a twelve inch diameter spare electrical penetration (E 10) outside of the Containment Building, This electrit.al penetration is ASME 111, MC Class, and the weld is a Category B joint- This weld connects the penetration sleeve to a prefabricated end cap. This weld joint employs a machined in backing ring, which fits inside of the end cap assembly, la some cases, this type of joint configuration does not permit radiographic examination. In accordance with ASME Section ill, Subsection NE 5211.1, when the joint detail of a penetration assembly does not permit radiographic examination, ultrasonic examination plus liquid penetrant or magnetic particle examination of the completed weld may be performed. On May 4, 1982, NHY issued Engineering Change Authorization (ECA) 74/1663A, to adopt the above stated ASME Code exception for the electrical penetrations.
A currently available Quality Assurance (OA) document, the Pullman Higgins Field Weld Process Sheet, demonstrates that this field weld was radiographed on June 18,1982 in accordance with the Non Destructive Examination (NDE) requirements contained in the 1977 Edition of ASME Section III up throu6h and including the Winter 1977 Addenda (the Code applicable to Seabrook Station). The process sheet also references the above stated ECA, and it is clear that at one point, ultrasonic examination was considered for this weld. At a subsequent point the Weld Process ' Sheet Hold Point for ultrasonic examination was deleted. Furthermore, no other process sheets could be located for this weld which indicated that an- ultrasonic examination was performed. In addition, magnetic particle examination for this weld was performed on June 16, 1982. The examination results were acceptable with no rejectable indications noted.
The weld records package for weld 1 F1188 01 F0150 has not yet been located and may have been misfiled or inadvertently discarded, it is currently believed that the RIR and the radiographs for this weld were never transmitted by Pullman Higgins to Yankee Atomi:
-Electric Company (YAEC) OA/NDE personnel for review and that the records were never transmitted to the Seabrook Yankee Document Control Center (SBYDCC) for final vault storage. Based on the above, the lack of weld record documentation for this weld does not meet the record retention- requirements of ASME NCA 4134.17 and ANSI N45.2.9.
NHY Nuclear Quality Group (NQG) personnel have reviewed the available engineering documentation regarding this weld and 'have concluded that the lack of the RIR and radiographs for this weld does not call into question the quality of this weld. Review of the weld process sheets for 1-FI 188 01 F0150 indicates that this weld was completed on June 8,1982, and on June 9,1982 an external visual examination of this weld was performed. The attributes of this visual examination included weld reinforcement, undercut, arc strikes, removal of purge dams, presence of joint- and welder identification, and suitability of the NDE performed. Nuclear Quality Group review of the field weld process sheet and the related Pullman Higgins procedures has determined that the initials of the Level 11 and the ANI indicate that the procedures had been completed and the radiographic film showed the weld to be of . acceptable quality. Other currently available OA documentation also demonstrates that the radiographic records for this weld were reviewed as part of the Pullman-Higgins N-5 as built Seabrook Station records verification process.
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Cause of Deficienst
,4 NHY has reviewed the identified records deficiency and has determined its cause to be personnel error on the part of Pullman Higgins records management personnel. The j
Pullman Higgins records management personnel apparently misfiled or inadvertently discarded the radiograph and the RIR prior to the transfer of records to YAEC for review and failed to transmit these documents to the SBYDCC for ultimate archival in the Seabrook Station records management system.
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1 Corrective Actions NHY has completed the following corrective actions for this records deficiency: 1) performed a radiographic examination of field weld 1 F1188 01 F0150; and 2) reviewed the
- film in accordance with our present program requirements. The radiographs and the
- required radiographic review forms have been incorporated into the NHY records managemerit system. These actions ensure compliance with the Code.
C.2. NHY NOG Surveillance The NHY Nuclear Quality Group (NOG) performed three separate surveillance activities for the reverification effort. The surveillance results are provided below.
The first NHY surveillance addressed the adequacy of the procedures, scope and starting point for the weld tabulation, radiograph package inven ory, and field weld list and radiograph - comparison efforts described above. This surveillance confirmed that the
- procedures, scope and starting point for the NES cffort were adequate for the conduct of the Weld Records Reverification Program.
The second NHY surveillance sampled 20 percent of the field welds from each of the isometric and suppost drawings previously reviewed by NES as part of the Task 1 weld tabulation effort. This surveillance addressed the procedural requirements outlined in NES Procedure 83A5643, " Review of Drawings." The scope of this surveillance included ASME Section III Piping, " Supports and Metal Containmentt ASME Section VIII Unfired Pressure Vesselst and ANSI B31. Power Piping. The results of this surveillance indicated that the NES- performance of the Task 1 effort was adequate. This surveillance revealed that in a few isolated instances, minor corrections were needed on the NES data sheets. NES has incorporated these corrections into the appropriate data sheets and the data base.
The third NHY surveillance sampled 20 percent of the radiograph packages, by system, that NES had reviewed as part of the Task 2 effort. This surveillance addressed the procedural requirements outlined in NES Procedure 83A5642, " Review of Radiographs." This
- surveillance was completed for all systems on July 24, 1991. The results of this surveillance indicated that the NES performance of the Task 2 effort was adequate. This surveillance also revealed that in a few isolated instances, minor correction.; were ueeded on the NES data sheets. NES has incorporated these corrections in the appropriate data sheets.
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4 4 In summary, the above described NHY surveillances established that the Weld Records Reverification Program, as implemented by NES, was performed in an accurate and acceptable manner.
C.3 NHY Verification of the NES Task 3 Comriarison Effort As discussed in the April 10, 1991 Public Meeting between NHY and the NRC and the Program Description, NHY committed to perform an independent verification of the NES Task 3 comparison effort. To facilitate this verification, NHY developed an electronic data base upon wMch the NES Task 1 and 2 data was entered. This program performed the
, following three comparisons:
- 1) Field welds requiring radiography where radiography exists;
- 2) Field welds requiring radiography where radiography does not exist; and
- 3) Field welds for which NHY has radiography that is not required by Code.
4 The purpose of these comparisons was to act as a check and balance on the NES field weld list and radiographic package inventory. NHY used the data sheets NES developed from the weld tabulation and radiographic package inventory to develop a separate NHY data base. Upon entering the requisite data, NHY conducted a separate field weld list and radiograph comparison. This NHY comparison matched the NES comparison in identifying the same four field welds that were missing radiographic records. The comparison also identified several minor administrative anomalies that required correction. Data entry errors and data sheets that were missed in the data entry process typified these anomalies.
Sections B.1, B.2, B.3 and Attachment A provide the discussion and results of the three comparisons NHY performed.
, - C4 NES Management Oversicht NES also provided management oversight regarding the activities being performed by the NES personnel as part of the reverification of weld records project. The management oversight activities included: a redundant 5% overcheck of the weld tabulation and radiograph intentory by the NES Project Manager; NES Quality Assurance sutveillances of the field weld tabulation and radiograph inventory; procedure reviews; periodic trips to Seabrook; and direct involvement in the preparation and issae of the NES Final Report (Attachment B).
C.5 Performance Monitoring NHY monitored the performance of the Reverification Program by tracking key paran2et e rs. These parameters were addressed in the respective sections of Section B of this and the prior status reports. Upon completion of this Program, NHY, for the purpose of
- prudency, will also sunmarize the resources expended and associated costs involved with this Project.
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C.6 NES Interim Reports i
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An indicated in the July Status Report [ Reference (g)], NHY was in the process of reviewing the NES Interim Reports. The eleven NES Interim Reports addressed the preliminary results of the Task 1, 2 and 3 efforts for all systems exclusive of the ASME 1 4
Section Ill, Subsection Nil, MC Class penetrations. The format of each report specifically
! idertified the following categories of information:
unresolved or missing information t
a list of CARS and RESs applicable to the system (35) a list of field welds requiring radiography where no radiographic records
} packeges were found (4)
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a list of field welds requiring radiography where radiographic record packages
[ are retained in the site records vault (2,665) a list of field welds not requiring radiography but radiographic records packages are retained in the site records vault (92) 1 a list of field welds not identified during the drawing review where radiographic record packages are retained in the site records vault (1,339) a list of all radiographic packages reviewed (4,096) a list of all field welds tabulated (19,431) a list of all drawings reviewed (2,681, During the month of August, NHY completed the review end evaluation of the eleven NES Interim Rep .s. The NHY review resolved open items and corrected administrative anomalies. In addition to this review, NHY also used the results from the NHY NOG surveillances (Section C.2 of this report) and the NHY Task 3 Comparison (Section C.3 of this report) as separate mer. for verifying the information contained in the NES Interim Reports. NES has incorporated the results of the NHY review into their data base. NES has resubmitted the results for the Interim Reports for the categories cited above.
C,7 NHY Root Cause Analysis in the April 10, 1991 presentation and in thc Program Description, NHY committed to evaluate any reportable weld record anomalies for generic implications and possible additional corrective actions, The Reverification Program identified weld records anomalies which NHY reported to the NRC. These anomatics fall into the following three groups:
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missing radios aphs and radiograph inspectica reports (4) incomplete radiograph identification (2)
. fi'm cc:npatative density (1)
The anomaly regarding film comparative den,ity was included in the root cause analysis although it ws outside of the scope of the Reverification Program. Radiographic film quality was not an attribute included in the NES work scope. The root cause analysis it.cluded this anotonly for completeness in reporting and analysis. Film quality root cause analysis and generic implications will be further addressed in a separate NilY report to the NRC. This separate report sill address the NilY weld quality and film quality corrective actions and evaluation of generic issues talsed b', NRC Inspection Report 50 443/91 12. NilY will sebiait this report on September 16, 1991.
The NilY Reliability and Safety Engineering Group performed the root cause anal > sis of these weld record anomalies in accordance with the procedural requirements of NHY 12709, *Special Reportine Requirements for Verification of Pulln.an.Higgins Field Weld Radiographic Records . c ct' Kepner Tregoe analysis was selected as the most appropriate method for detert@ am of cause end pttential generic implications. The 100% Scrification effort provided a iou t tasis to judge potential generic implications. Althotigh the Pullman-Higgins records manag. lent program ended in 1986 and Pullman Higgins records management personnel are no longu available, the rigorous root cause analysis is still applicable.
't he root cause analysis determined that the total number of records anomalies was
. mall and the specific instances varied both in time and type of deficiency. The root cause analysis found that 99.74% of the records reviewed meet all requirements. This is apportion d as follows: 99.85% of the radiograph records packages were available, and 99.92% d the radiograph records packages had all required data. The lack of any trends and the small number of problems lead to the cor.:lusion that the observed records anom,ilies did not result from a deficient Pullman lliggins records management prograrn. Since over 2665 required records packages were reviewed, and the anomalies occurred at widely eparated times, :hese problems were considered isolated incidents.
The root cause analysis concluded that no additional corrective actions beyond those identified in the specific Corrective Action Reports were necessary.
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Attachment A FIELD WELDS REQUIRING R ADIOGR APHY 11Y COE A. ASME Pin!nr hutem Quantity
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- 1. Auxiliary Stearn 0
- 2. Contalument Air llandling 0
- 3. Containment Air Purge 4
- 4. Contalument 11unding Spray 396
- 5. Containment On Line Purge 6
- 6. Component Cooling 65
- 7. Combustible Gas Control 11
- 8. Condensate 0
- 9. Charging (Chemical Volume and Control) 620
- 10. Diesel Generator 0
- 11. Demineralized Water 0
- 12. Fire Protection 5
- 13. Feedwater 153
- 14. Instrument Air 9
- 15. Main Steam 128
- 16. Main 3 team Drains 0
- 17. Nitrogen Gas 0
- 18. Reactor Coolant 331
- 19. Residual Heat Removal -243
- 20. Reactor Make Up Water 6
- 21. Resin Slice 0
- 22. Service Air 0 11
e e Attachment A (continued)
ASME Pinine Enttm Quantity
- 23. Steam Blowdown 121
- 24. Speut Fuel 3
- 25. Safety injection 284
- 26. S atupling 0
- 27. Service Water 0
- 28. Vent Gas 0
- 29. Waste Gas 0
- 30. Waste Liquid 4 B. p31.1 Piolne
- 1. Diesel Generator 18
- 2. Feedwater 117
- 3. Main Steam 95 C. ASME Suncorts 8 D. ASME Metal Contai4 mm 41 E. ASME Unfired Pressure Vessels Base Metal Repairs 1 2669 12
4 New llampshire Yankee August 30, 1991 ATTACllMr!NT B TO ENCLOSURE,,,J, FINAL REPORT NES PROJECT 2007 FIE LD WE LD R A DIOG R A PH Y R E V,lBF, FOR NEW HAMPSHIRE YANKEE SEABROOK NUCLEAR STATION AUGUST 1991 l
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