IR 05000249/1974010

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Letter Referring to 08/17/1974 Inspection of Dresden 3 - RO Inspection Report 05000249/1974010
ML17252B164
Person / Time
Site: Dresden Constellation icon.png
Issue date: 10/03/1974
From: James Keppler
US Atomic Energy Commission (AEC)
To: Brian Lee
Commonwealth Edison Co
References
IR 1974010
Download: ML17252B164 (12)


Text

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. DIRECTORATE

<;>F .REGUL:A.TORY OPE_RATIONS

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  • -U. S. ATOMIC ENERGY COMMISSION

---. DIRECTORATE-QF-REGULATORY OPERATIONS-----REGION III Report of Construction Inspection RO Inspection Report No. 05.0-249/74-10 Licensee:

... * ** * ** .r. {# Connnonwealth Edison:

_ ** * * * * * '"" * Chicago, Illinois 60690 .* Dresden Unit 3 Morris, . Illinois Type of Licensee:

BWR (GE).-809 Mwe* . : _. ----*...

. -. --' . . . . License No. DPR-25 Category:

C Type of Inspection:

Announced, In-service Follbwup _Date of Inspection:

September 17, 1974 Dates *of Previous Inspection:

.. June 27 and 28, July 3 and * August 2, 1974 Principal Inspector:

Inspectors:

None .Other Accompanying Personnel:

None Reviewed By: Senior Reactor Inspect'ion Construction Projects /0 ... /.: 75( (Date) /o -1-.?Y' * (Date)

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.**.:. .... -* . SUMMARY OF FINDINGS* . . -*---------



*---------,


*-A. * Violations

  • ' .No v:iolations were identified during this inspectfon. . -** .. B. Safety Matters No safety matters were identified
  • . Licensee Action. on. Pr.e:viously Identified*.

Enforcement

.. Matters* * A. Use *of* Unapproved In-service Inspection Procedures. (RO Inspection Report No. 050-249/74-04)

B. During the inspection of April 1, 2, an_d 23, 1974, it was esta-_blished that nondes.tructive examination (NDE) procedures, being utilized for the in-seririce.inspection and those for the valve wall not __

as. required by Secti_on 6.2.E. of the Technical.Specification During the inspection, the steps taken to correct this noncompliance, as stated in the Commonwealth Edison Company (CE) letter dated June 20, 1974, were by the inspector and determine to be acceptabl *This matter is considered resolve *use of Nondestructive Examination Procedures Which Did Not Conform to ASME Requirements (RO Inspection Report No. 050-249/74-04)

During the referenced inspection, it was established that some of the NDE procedures in use for the in-service inspe_ction program did not conform to the requirements of ASME Section XI, including -Summer Addenda -1971, ASME Sec.tion III, and Appendix IX, including Summer*Addenda-1971, as require During this inspection, the steps taken to correct this noncompliance, as stated in the CE letters dated June 20, 1974, and August 8, 1974, were reviewed by the. inspector and determined to be acceptabl This matter is considered resolved. (Paragraph C.l, C.2 and C.3 Status of Previously*

Unresolved Matters, and Paragraph l,_.Report Details) C. Records Not Available to Establish That Calibration Blocks Were of the Required Materials (RO Inspection Report No. 050-249/74-04)

During the referenced inspection, it could not be established that* *the calihration blocks used for the in-service inspection were of the required material *-*.*.

  • -* ,*

' .. ... *:.. --* .1 During thi tfle_ t .. a.keti,: ( nc;mconipliance

  • -,*as stated in the* CE:: Le.Her* da-ted* Jutie*>'iO, 19,j,4:,:

were Feviewed by . ___

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"'!" .* . considered resolved. . . . * * . . . . ..-. '* ' D. Required Calibration Check .Exceeded Specified Time Liniit (RO Inspection Report No .. 050249/74-04)

During the referenced inspection, a review of calibration sheet*55, dated March 29, 1974, indicated that the calibration check had not been performed within the. 'time limit of* four hours, as specified in . . , . * i"* * .-:_-.. :., ... : .. ;, '*.,:'. *.i ': l *l . Procedure NDT-C-2, Revision 2. * * During this the takex:i, tq c;:orrect thii? noricompliance, * . * ** ;..., *-.. * *"*"'"_T_,,.

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..... s ... *,i:.,. . as stated in the CE letter dated June 20, 1974; *were by * the inspector and determined to be.acceptable; This matter is considered resolve Design Changes: Not applicabl Unusual Occurrences: .No unusual occurrences were identifie A *.. * Current Findings 2. i. In-servic Inspection

  • The in-service inspection, completed during the outage'which extended from March 11, 1974, to June. 4, 1974, resulted in the finding by the licensee of no reportabl indicat.ion on any of the components examined .. This.finding was substantiated by an independent .evaluation of the in-'service inspection records by General.Electric Company (GE) as stated in their letter to the* licensee dated August 21, 1974. Relativ to the valve wall measurement program, also concluded during the March 11, 1974, to June 4, 1974 outage, the eight . . valves which were originally measured to be below the required specified wall* thickness have all been technically justified*

for acceptance as is. (Paragraph 2) Inspection of Structural or Seismic-Supports-Class 1 Components As a result of Regulatory Operation Bulletin (ROB) 74-03, CE ted to Region III their proposed program for inspection of reactor vessel support skirt bottom flange bolts and the upper vessel -3 -.-**----**. *--*. *.* r D-E-"'

. **-* ....... ' . . . . . '. . . *;i *stabilizer assemblie This program wc:ts completed during the


-* *--. .I. \ *l B. and stabilizer componeu-ts checked were. found to be acceptable. (Parag-raph 3) Unresolved Matters No unresolved matters were during this inspectio c. Staf{is o'f Previol.islY Unresolved

Matters'

1. Transfer Mechanisms (RO Inspection Report No. 050-249/74-04)

2. ,:** "": .* ; ... .. :, UT Procedures No. NDT-C-2,*N NDT""'.C-4, and-No. ND'T-C-5, as written and approved on April*23, 1974, did not contain provision for transfer mechanisms. . . During this inspect.ion, a review of the procedures enumerated above-established that provisions for transfer mechanisms had been incorporated in Revision 4 of NDT-C-2, dated April 23, . : 1914; Revision 2-of-NDT-C-4;.

dated AprH *23,* i.974: and*Re.;ision-

  • * 2 of NDT-C-5, dated April 23,-1974. -This matter is considered resolve * Procedure NDT-C-11, Revision 1. Ultrasonic Inspection of Flange to Vessel, Flange to Head Welds, and Flange Ligaments Between Bolt Holes, Dated April 17, 1974 (RO Inspection Report No. 050-249/74-04)

The subject procedure, as written, did not appear to conform to the.requirements of ASTM Section III, Appendix IX, to a calibration block with the specified size hole for the referenced calibratio During this inspection, Revision 2 of NDT-C-11, dated April 23, 1974, Ultrasonic Inspection Flange Ligaments Between Threaded Bolt Holes, was reviewed by the inspector and lished as The vessel-to-flange weld and flange weld were tested, using Procedure NDT-C-5, Revision 2, dated April 23, 1974. All procedures used to cover the items, formerly covered by the original NDT-C-11, Revision 0, utilize calibration from code reference reflector This matter is considered resolved. -4 -. t -;**--:--***

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. 3. Procedure NDT-C-12, Ultrasonic Inspection of Reactor Vessel . A Head Welds -Dresden .. and Quad-Cities Stations (RO Inspection

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-. >---.-This procedure was not uti*lized during this in-service*

inspectio This matter is considered resolve However, if the procedure is utilized during a subsequent in-service inspection, it will be * . reviewed by the inspecto . Documentation for Transducers (RO Inspection Report No .* 050-2'49/74-0'4)

Previously, no doc\lill.en_tation, relative to the of the transducers utilized for the tests,_was availab for During this inspection, performc:tnce documentation for each. of the transducers utilized wa:s reviewed_

by the inspector and' was considered acceptabl Performance documentation, datec1J1ay 3, 1974 ,-and May 20, 1974, .was supplied to.CE by Aerotech Laboratorie This matter is considered resolve .... Validity of Records ._(RO -Inspection Report "No. * 050-:-249

/'*7 4-04-)'.--

'" .-6. Test records, which were obtained by use of procedures that were considered in nonconformance with the ASME .Codes, were C:ons.idered unacceptable until they reviewed and justified by CE. During this inspection, it was established that tests were repeated, where required, to procedures revised to be in conformance with ASME requirement Where the tests were not repeated, they were shown. to be in conformance with code*ri::quirements by utilization of . procedures which were equivalent,.

or, superior, to those. requirements

.... * specified in ASME. As indicated earlier in this report, an indepen-* . dent review of the in-service inspection data by GE, substantiated

  • . CE's finding that no relevant indications were found. This matter is considered resolve Technical Justification For Thin Wall Valves (RO Inspection Report No. 050-249/74-04)

During the referenced inspection, a total of eight valves were measured and established to have wall areas below the specified wall thickness require DUring this inspection, the technical justification for of these valves, as is, was reviewed by the inspecto cations appear to be acceptable, and we have no further at this time. (Paragraph 2) -5 -acceptance The question?

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V. ;. .

-* --** ..... *. . . . Management Interview

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A. The following persons att.ended the management interview at the .conclusion of the inspectio Commonwealth*

Edison Company (CE) G. J. Diederich, Administrative Assistant to.Superintendent J. W. Wujciga,, Unit 1, Lead Engineer B. Matters discussed comments, on the part of management personnel, were as follows: The .inspector discussed the results of the inspection indicating that *the licensee had corrected all of the deficiencies-which had been identified during the inspection of April 1, 2 and 23, 1974, and that there were no further questions relative to these matters at this time. -6 -,,,, ... ,--...

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  • REPORT DETAILS ---------

The following persons, in addfrion'to individuals listed under the Managemen Interview Section of this report, were contacted during the * inspectio Commonwealth Edison Company .(CE) Station A. M. Roberts, Assistant

'superintendent Results of Inspection . 1. Use of NDE Procedures Which Did Not Conform to AMSE Requirements (RO Inspection Report No. 050-249/74-04)

a. NDT-C-1, Revision 0, Ultrasonic Inspection of Pressure Retaining Bolting,.Two Inches .in Diameter and Above, Dated January 4, 1974 _ ---------During.the previous inspection, it was es!;:aqlished that dure NDT-C-1, Revision 0, did not meet the requirements of AsME Section III, through Summer Addenda -1971, Article NB-2585. NB-2585. 3 requires that .calibration be. lished on a test bar of the satne nominal composition and diameter as the production part and one-half the length, utilizing the code specified drilled hole. Instead, the procedure utilized the back.reflection from the opposite end of the bolt. * During this inspection, it was established that Procedure C-14, dated April 13, 1974, for pressure retaining bolting over four inches in diameter, providing for"the code ments was utilized for bolts over four inches in diamete For bolts between in diameter inclusive, Procedure NDT-C-1 was revised (Revision 1) and utilize With. the use of these procedures for bolt sizes, as stated, the procedures appear to meet the code and this matter is considered resolved *. Revision 2, Ultrasonic Inspection of Pipe Welds, Dated December 3, 1973 Previously, it was established that the referenced procedure utilized:

(1) pieces of pipe (for piping up to ten inches * -7 -------

. **-. v *O A outside diameter), (2) a section of pipe (for piping*_t;el!___..oc

___ _ . 9

_____________ -inches-t;o-ct;wenty-tn:cne*s--oues1d*e-d-iameEeif an<l -T3)-a flat plant-calibratfon piece* (for pipe over twenty inches in diameter)

each with notches nominally*

.3% to. 10% wall thickness machined in the outside diameter and the inside diameter surf aces in lieu .of the. dr.illed holes, as required by ASME Appendix IX, ..Section III, with addenda througli**summer 1971. 1. ' I -c. d. The code allows, under .Article :IX-:3434, .other. calib.i"ation . . . . . reflectors, provided equivaient response is demonstated.*

However; *the .licensee was *unable. to. :conclusively demonstrate . this equivalenc Moreover,_

the procedure did not provide for transfer as_ requied. by Appendix IX of Section III. During this inspection, Revision 4 of .P-rocedure NDT-C-2, which was utilized for the in"'-service inspection, was* reviewed by the inspector and determined to be acceptabl Revision-4 of NDT-C-2; dated April 23, 1974, had been .revised to require calibration for code drilled holes and reference to mechanisms, as required by the AMSE Code. This matter is c-:

r,e§.ol:ved

  • . __.,._ . :'*. '" : ,.,-. 0 *c=*

Revision 0, Ultrasonic-Inspection of External Support Attachment Welds on Piping, Dated January 7, 1974 The comments for Procedure No. NDT-C-2, above, also_apply to No. NDT-C-4, with the exceptiorithe revised procedure utilized for the in-service inspection was NDT-C-4; Revision 2, dated April 23, 1974. NDT-C-5, Revision.a, Ultrasonic Inspection of Reactor Vessel Welds -Dresden and Quad-Cities Stations, Dated January 4, 1974 Previously the NDT-C-5 procedure for calibration, relative to longitudinal waves, .utilized the -back of the calibration block as the primary reference in lieu of the basic calibration hole as required by Article IX-3433 fo Section III, including Summer Addenda -1971. Moreover, the procedure did not provide for transfer mechanisms as required by Appendix IX of Section III. During this inspection, Revision 2 of NDT-C-5, dated April 23, 1974, as utilized for the in-service inspection, was reviewed by the inspecto This review established that the procedure had been revised to include the required calibration block and transfer mechanisms in conformance with the code requirement This matter is considered resolved. -8 --------

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, ' ..,, **** .;.I ... e. NDT-C"-10, Revision O, Ultrasonic:

Inspectio of.* Inne.r *.Radius . -. . . -'Of Nozzle-to-Vessel Junction, Dated March 1; *19*74* :* *

  • *. _ ._ __ ._ ____ ----------------The-*ref*erencea-revTs-ion-t:o t'neprocedure-

--*----**-

--. *-----of the standard wedge used during.calibration to a compound angle wedge appropriate to the nozzle being examine during the examination

  • . This. practice,*

while* apparently not excluded by the code, did raise questions as the validity of the test. During this inspection,.

Revision 2 to the procedure, dated April 24, 1974, incorporated CE Analysis ment reports M-268-71 and M-861-74, which appear to document the validity of the use of compoun angle wedges app'ropriate to the nozzle being examine This mat.ter. is considered resolved *.. 2. Technical Justification for Thin Wall Valves (RO Inspection Report No. 050-249'/74-04)

The referenced inspection report indicated that eight valves were measured and established as having wall thickness areas below that specified as. the minimum wall/ thickness require The. eight valves . WJ'?re:_, No. 202-AA,, .. N *02-5B-f.'

No*0; -1501-"25A-, No.C-150r-

No. 220-57A, No. iOOl-5B, and No. 1001-2C. Valves No. 202-4A, No. 202-4B, and Nci.-202-5B were technically justified as acceptable, as *is, based upon calculations supplied by Crane Company (Crane) letter dated May 1, 1974, which utilized the formula from Part II of MSS...:sP-66, and resulted in a minimum wall requirement of 1. 75. Based upon this calculation, the valve minimilm wall thickness measured exceeded that thickness required as calculated by* use of the formula; Valves No *. 1501-25A and No. 1501-25B were technially justified as acceptable as is; based upon the calculation, supplied by.Atwood

& Morrill Company, Incorporated (A&M) in a letter dated June 28, 1974, for a 680

_rated carbon steel valve. This calculation resulted in a requirement for a minimum wall thickness of 1.077. inches. The minimum wall thickness measured for these valves exceeded that required for the 680 psig valve. Originally, the valve thickness requirement was based upon a rating for these valves of 900 psig. Valves No. 1001-5B and No. 220-57B were technically justified as acceptable, as is, based upon a CE evaluation that the measure wall thicknesses, as stated, were within the accuracy of the measurin equipment. -9 -..,;.-:...,-----*

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--.* . i ** . .* Valve No. 1001.2C was technicaliy justified for as is, based . upon calculations supplied by Crane* in a letter dated Apri1___1£, ___ . ___ _ ----.c __ --.-*--1974-;;---Thecalctilations-*suppliecf;-basecf up.on -paragraph- of USAS 1316.5, require a minimum wall thickness of 1.123. All measure-ments on this valve exceeded the calculated minimum thicknes Based upon the foregoing technical justifications for acceptance of these valves, the RO Inspector stated he had no further questions in regard to this matter at this time. 3. Inspection of Structural or Seismic Supports -Reactor Pressure Vessel During this inspection, the inspector reviewed the resulting data from the inspection of 60 RV support skirt_ flange bolts, 14 of 16 *vessel *stabilizer pins, 16 stabilizer shafts, and 6 vessel stabilizer*

assemblie Review of this data established that no indications had been found, and the data app*eared to be acceptabl The bolts were examined visually, using NDT-V-1, Revision 0, and ultrasonically using Procedure NDT-C-1, Revision 1; both. had reviewed by the inspector dur.ing the previous in-service inspection

_andc found to_ be acceptable

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-The stabilizer pins and shafts also examined visually and ultrasonically, utilizing the same two procedure The vessel .stabilizer assemblies (6)were examined only visuall Two stabilizer

  • assemblies and two stabilizer pins were not examined,-

due to their inaccessibility, as they are located under nozzle N45B. The bolts were examined on April 17, 1974, and the stabilizers were examined on May 2, 1974 *. -10 --*--. . **---.. **-;*---*-------* .. ------------*