ML20059F410

Forwards Responses to H Myers 900713 Request Re Pipe Weld Repair

ML20059F410
Person / Time
Site:	Seabrook
Issue date:	08/08/1990
From:	Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:	Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
References
CCS, NUDOCS 9009110203
Download: ML20059F410 (9)

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~ NUCLEAR REGULATORY COMMISSION i n 4 y) . WASHINGTON, D. C. 20555 j l' t'g f

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August 8,1990 ]

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u h The Honcrable Morris K. Udall, Chairman 1

'i Committee on Interior and Insular Affairc q United States House of Representatives .

. Washington, DC 20515- i

Dear Mr.. Chairman:

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L Enclosed, at the request of Dr. Henry Myers of your staff, are responses -l to his requests ofiuly 13, 1990, concerning Seabrook welds, i Sincerely, /'

/ a kN1 f/ys7 te Dennis K. Rathbun, Director Congressional-Affairs.

Office of Governmental and Public Affairs

Enclosures:

As Stated- ,

cc: The Honorable Don-Young I 1

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' ATTACHMENT RESPONSE TO DR.:H. MYERS' REQUESTS OF JULY 13.-1990 Request I:'

Please provide prior to COB, Wednesday, July 18 Seabrook Inspection Reports 80-06; 83-19 and 84-12.

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Response

L The three NRC Region'I, inspection reports listed above were forwarded separatel3 l i l

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's Attachment 2 Request II:

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A. Does the NRC consider the Weld Repair Order to be a quality record with regard to a weld repair that involves preparation of a cavity?

B. If not, what do:ument contains a report-that includes a chart which shows

-the location and size of the prepared cavity?

h Response:

1 As-has been documented in the responses to several previous requests from Dr.

Myers, Weld Repair Orders (WR0s) of themselves are not considered quality records, but were retained where required to support other QA documents (e.g., i l

nonconformancereports)orspecificcoderequirements. An example of the '

latter situation was previous)y discussed in the response to item II of Dr.

Myers' requests of. May 14, 1990. In responding to a general request regarding

. pipe weld repair records, it was stated that:

"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."

J L Typically, weld repair cavities were sketched and the cavity dimensions recorded l on a WRO. However, such charts would be considered quality records only where l-required by the ASME Code, i.e., as stated above "for Class 1 base metal re-  ;

pairs." The ASME Boiler and Pressure Vessel Code (1977' edition with Winter 77 J ll l

Addenda),Section III, Subsection NB-4132 for Class 1 components specifies-the L governing requirement. It states that for repair welds in base material, a i report which shall include a- chart which shcits the location and size of the l prepared cavity shall be prepared for repair welds exceeding in depth the L lesser of 3/8" or 10% of the section thickness. Therefore this requirement i for a cavity chart applies only to pipe repair welds for which all of the below I conditions are met:

(1) class 1 piping (i.e., typically the reactor coolant pressure boundary).

(2) base metal repairs (versus weld repair operations).

(3) the cavity depth exceeds the minimum of 3/8" or 10% of the pipe wall thickness.

For such base metal repair welds, the required cavity chart would be considered, as documented previously,'a quality record. - Such cavity charts, where required, may have been recorded on WR0's or could have been-included in the record

t k ' Attachment 3 packages as separate sketches. In any case, for situations where all three of the conditions noted above are applicable, the cavity report discussed in Re-quest II.B above, does represent a quality record.

However, this does not imply that all Weld Repair Orders involving the prepara-tion of cavities, as questioned in Request II. A above, constitute quality records. Pullman-Higgins procedures required that during repair operations,.

the cavity be examined and sketched and its dimensions recorded on a Repeir

. Order. WRO's were typically utilized to satisfy-this requirement. While the use of WR0's during the conduct of weld repairs was procedurally prescribed, the retention of each WR0 in the QA Records File was not so spec:fied.. 10 CFR 50, Appendix B requires that sufficient records shall be maintained to furnish evidence of activities affecting quality. In the case of weld repair activi-ties, such evidence is provided by the process sheets, the NDE results, mate-rial traceability reports and heat treatment records, where required.

In summary Weld Repair Orders were not generically classified as quality records. Except for the aforementioned ASME Code provisions involving Class 1 base metal repairs exceeding specified depths, a chart which shows the location and size of the prepared cavity was not a weld repair requirement. In those cases where the ASME Code specifies that such a cavity chart be prepared, either Westinghouse documents or Pullman-Higgins WR0's or sketches would be

' required to ba retrievable-to satisfy the ASME Code provisions.

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Attachment 4

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. ~ Request III.A:

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(paraphrased)-

Is'it the NRC position that applicable procedures and requirements did not mandate.that the listing pertaining to DR 527, which was provided by-the NRC as

-supplemental information, be retained by the-licensee as a QA record?

Response

Yes.

'The listing, entitled "YAEC RT INTERPRETATION", pertaining to DR 527 which was located in NRC office files and.provided as supplemental information to a pre-vious request from Dr. Myers is not considered a QA record. This handwritten list had=not been retained by the _ licensee, nor.was it required to be classified-or filed as a quality document.

Yankee Atomic Electric Company (YAEC) procedures specify that deficiencies dis-covered during YAEC surveillance activities shall be reported and that the re-sulting ' deficiency-reports.(DR) be controlled as QA records. DR 527 was' handled-in such a-manner. The basis for the requirement of controlling and' documenting such deficiencies lies in 10 CFR 50, Append x B. Criterion XV specifies the control of " materials,. parts, or components which do not conform to require-ments'in-order to prevent their inadvertent use or installation."-

As was previously discussed in the responses to Dr. Myers' requests of May_29,.

1990,.the final acceptability of any radiograph and of the_ weld it represents was verified by YAEC reviewer signature or initials on the associated Radio-

graphic Inspection Report (RIR). Thus,-in this particular situation of radio-graph reviews and film deficiencies identified by YAEC, the " inadvertent use" of the ucacceptable radiographs was precluded:by the fact that YAEC reviewers

.would not: sign the affected RIR's, dictating an additional review for accept-

' ability. YAEC QA personnel made an overt decision not to provide the details of'each film deficiency to Pullman-Higgins in order to elicit generic correc-tive action on the part-of-the contractor. '

Therefore, the "YAEC RT INTERPRETATION" listing was not made part of the DR 527 and was consequently not retained as a quality; record. This was an acceptable practice because it conformed to both the YAEC~ procedural practice and the 10 CFR 50, Alpendix B requirements. Criterion XVII specifies that " sufficient records-sia11 be maintained to furnish evidence of activities affecting quality"'

and further indicates that inspection records must include "the action taken in connection with any deficiencies noted". DR 527, in conjunction with objective evidence provided by-the:RIR's of YAEC review and acceptance of all of the weld radiographs, . meets the intent and the equirements of Criteria XV and XVII with regard to the control of nonconforming components and QA record provisions.

The retention of the "YAEC RT INTERPRETATION" listing was not mandated by either the' applicable procedures or any cegulatory requirements.

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_ Attachment- 5 Request III.B:

(excerpted)  :

The SALP report issued on May'17, 1984 does not state what if any review and/or analysis was undertaken by the NRC in support of. the change from "at least 25" noted in the earlier draft to "one" noted in the final draft.

Please provide prior to COB, Friday, July 20 NRC documents containing informa- i tion and/or results of any NRC review or analysis that supports the above noted-change from "at least 25" to "one".

Response

In the complete version of Request III.8, it is stated that an earlier version of the questioned SALP report (also dated February 14,1984) was transmitted to the licensee for comment on March 1,_1984. In order to clarify and correct any -

misunderstanding of the NRC SALP transmittal, the following chronology lists the NRC and licensee actions with respect to this special SALP in the piping area.

February 14, 1984 SALP board meeting, of NRC personnel alone, convened to ,

evaluate the performance at Seabrook in the area of piping systems and supports.

February 23, 1984 Notice of Significant Licensee Meeting published announcing-scheduled meeting of the NRC with-the Public Service Company ;

of New Hampshire (PSNH) on March _9, 1984. This Notice was  !

sent to the NRC public document rooms.-

March 1, 1984 SALP Report transmitted to the licensee for review and pre-paration for discussion at the-scheduled NRC/ licensee man-agement meeting.

March 9, 1964 NRC conducted a ieenagement meeting with the licensee to discuss the SALP results. (Note: it was during this meeting that the licensee indicated the fact that only one code l

L rejectable indication requiring field weld re l

-identified by YAEC radiograph review to date) pair had been April 25, 1984 PSNH letter commenting on SALP report issued, noting that other than the one field weld repair, the remaining YAEC .

l. identified radiographic film deficiencies did not impact i D hardware.

May 17, 1984 Final SALP Report issued attaching the licensee comments and noting in the cover letter the revisions made to the

! earlier version of the SALP report.

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s u J i Attachment 6 .-

o As has-been discussed in the NRC response to previous requests from Dr. Myers, the NRC had considered DR 527 issued on December 7, 1983 and the handwritten "YAEC RT INTERPRETATION" list in evaluating the performance in the piping area- t during the subject SALP period (i.e., July 1 through December 31,1983). In fact,-DR 527 documents, in part, the following categorization of deficiencies ,

identified by the YAEC radiograph review process: >

" Code rejectable (25)"

Misinterpretation of this phrase led to the incorrect statement in the earlier '

SALP report version that several code rejectable indications (at least 25) will-l require field weld repair. What the licensee pointed out to the NRC was_the .

j ~ fact that the term " code, rejectable" did.not differentiate.between weld quality and film quality deficiencies. Also, as stated on DR 527, as of December 29, L 1983 (i.e., at the end of the SALP assessment period and thus shortly before s L the earlier version of the NRC SALD Report was first drafted), Pullman-Higgins i, personnel were still evaluating the 184 film packages that had been returned to -

them to determine whether they agreed with the validity of all of the YAEC findings.-LIn the intervening time between then and March 9, 1984 when the SALP management meeting was conducted, the-licensee and Pullman-Higgins were able to determine whether any of the listed. deficiencies actually required weld repair. . <

Where_ disagreement may have occurred, it would not have been unusual to re-radiograph the weld to determine whether weld repairs were needed.

In direct response to the request for documents that support the change from 4 "at least 25" to "one", the aforementioned "YAEC RT INTERPRETATION" listing, which was located in the NRC SALP file, had been forwarded previously. Although the ".YAEC RT-INTERPRETATION" listing was filed with the NRC SALP report and-

analysis of listing comments and referenced weld records clearly supports the position tendered by the licensee, no written analysis other thn the conclusion documented in the final SALP report has been located. In fact, none of tne welds' associated with DR 527 requirad field weld repair as a result of the identification of the discrepancies noted on that deficiency report. The "one" code rejectable indication requiring field weld repair was actually documented on-DR 544 which was issued on Decenter and resulted in the issuance of Pullman-Higgins Nonconformance Report No.(NCR28,)1983 5773. ,

NRC inspector review of NCR 5773 is documented in Inspection Report (IR) 50-443/83-22 as one of "the last two NCRs initiated by the departed Level III" (i.e., Mr. Wampler). Copies of DR 544, NCR 5773, and IR 50-443/83-22 have been previously provided.

Finally, as documented in the SALP cover letter dated May 17, 1984, the NRC considered the licensee' comments provided in its letter of April 25, 1984 and determined that "our SALP conclusions have not been affected". A major Con-struction Assessment Team (CAT) inspection had commenced at Seabrook Station on April 23, 1984 and it was recognized that the radiographic review program would receive major inspection attention. Thus, the revision from "at least 25" to

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Attachment:

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"one" code rejectable indication requiring field weld repair wasiviewed:im-material;to the.' point being made by the SALP discussion; i~ e... the YAEC RT customer. film review represents a program "where apparent deficienciesJin the. .t '

contractor quality programs have been detected and are being corrected by licensee management overview". , ,

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CONGRESSIONAL CORRESPONDENCE SYSTEM

. DOCUMENT PREPARATION CHECKLIST 1 This checklist is to be submitted with each document (or. group of-1 gs/As) sont-for entering into the CCS. .

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1. BRIEF DESCRIPTION OF DOCUMENT (S) b ' -e cs U//c //

3. TYPE OF-DOCUMENT Correspondence Bearings (Qs/As)

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3. DOCUMENT CONTROL Sensitive (NRC Only) Non-Sensitive.

4. CONGRESSIONAL COMMITTEE and SUBCOMMITTEES (if applicable)'

Congressional committee Subcommittee l= s l

l- s. SUnaECT CooES

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(a)- l 4

(b)

(c)

L 8. SOURCE OF DOCUMENTS l (a) 5520 (document name __

(b) can.. (c) Attachmente -

.1 (d) Rakey (e) Other.

7. 8YSTEM LOG DATES (a), 7 d Date OCA sent document to CCS (b) .

Date CCS receives document 1

-(e) Date returned to OCA for additional information (4)- Date resubmitted by OCA to CCS

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(9) Data entered.into CCS by >

cc

-(f) Date OCA notified that document is in CCS

8. ~ COMMENTS l

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