IR 05000456/1986030
| ML20206P361 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/26/1986 |
| From: | Danielson D, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206P349 | List: |
| References | |
| 50-456-86-30, 50-457-86-23, IEB-83-05, NUDOCS 8607020110 | |
| Download: ML20206P361 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-456/86030(DRS);50-457/86023(DRS)
Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: June 10 - 13, 1986 6 14//6 Inspector:
K. D. Ward Date
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Approved By:
D. H. Danielson, Chief 4/24/N Materials and Processes Section Fa'te ~
Inspe_ct_i_on Summary Inspection on June 10 - 13,1986 (Report Nos. _5_0-456]_86_0300(DRSJ1 50-457/86023(DRS))
TrTai~ Inspected: Routine, unannounced safety inspection of previous inspection findings,10 CTR 50.55(e) items, an IE Bulletin, and the spent fuel storage racks.
Results: No violations or deviations were identified.
8607020110 860626
{DR ADOCK 05000456 PDR
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DETAILS 1.
_ Persons Contacted CommonwealthEdisonCompanyjCECo,)
- G. Groth, Assistant Construction Superintendent
- P. Barnes, Regulatory Assurance Supervisor
- E. Netzel, QA Supervisor
- D. Skoza, Project Field Engineer
- A. D' Antonio, Regulatory Assurance
- D. Cecchett, Regulatory Assurance M. Gorski, Engineer U.S. Nuclear Regulatory Commis,sion_(NR_Cl
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- W. Kropp, Senior Reactor Inspector l
T. Tongue, Senior Reactor Inspector The inspector also contacted and interviewed other licensee and contractor personnel.
- Denotes those present at exit interview.
2.
Licens_ee Action on_ Previous Inspec_ tion Findings e
a.
(cio. 1) Violation (456/84-05-05; 457/84-05-05): Several welds were reported by the Pittsburgh Testing Laboratory (PTL), the NDE contractor to Phillips Getschow Company (PGCo), as containing rejectable base metal radiographic indications and the material was believed to be nonconforming. The Phillips Getschow Braidwood QA manual, Section 15, requires a nonconformance report to be written to control nonconforming materials. No nonconformance report was written for the reported conditions.
CECO wrote NCR 605 addressing the fact that Phillips Getschow Company did not generate a NCR to document evaluation of radiographic indications by the CECO Level III (as required by procedures in effect at the time). The corrective action requirements for this NCR consisted of identifying all radiograph reports that have indications that were accepted by the CECO Level III inspector.
j This was accomplished by having PTL and PGCo (the N-Stamp holder)
review all the radiograph reports in their possession dated from start-up to when the problem was first identified (approximately November 23,1984). The identified radiographs are listed in PGCo letter, Revision 3, dated June 4,1986, and a PTL letter originally dated November 24, 1984, and revir,ad June 6, 1986.
In addition, Southwest Fabricating welds CV-23-6 FW3 and FW6 were added to the list per CECO response to this item dated August 10, 1984. All identified radiographs were re-reviewed by the applicable A-E and docum m ted on Westinghouse letters dated December 12, 1084, and May 21, 1986, and a Sargent & Lundy (S&L) letter dated January 10, 1986, and two S&L letters dated February 20, 1986. Ultrasonic
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thickness examinations requested by the S&L reviewer were performed in February 1986 per CECO BRD letter No.15,542 dated April 9,1985, and accepted per S&L letter dated February 10, 1986. The required corrective action-to prevent recurrence consisted of revising the appropriate procedures to more clearly define the method of obtaining Level III dispositions of NDE indications. As required by the NCR, PTL ASME RT Procedure QC-RT-1, Revision 20, dated July 30, 1985, with CECO letter BR/PCD 86-256 dated April 25, 1986, and PGCo/PTL letter of agreement, 8th revision, dated December 26, 1984, were effectively revised to prevent recurrence. The NRC inspector reviewed the final
response dated April 18, 1985, the NCR, NDE reports and other related
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documentation. The actions taken by the licensee were acceptable, b.
(Closed) Violation (456/84-05-08; 457/84-05-08): Some radiographs have degenerated film quality from inadequate fixer renoval and do not meet archival quality standards. The licensee issued NCR 605 to identify this discrepancy and NCR 606 was issued to document the film yellowing of Southwest Fabricating radiographs. The licensee subse-quently issued NCR 606, Revision 1, to document the extent of the yellowing film and the use of a computer enhancement process.
Radiographic film which was supplied by Southwest Fabricating and was stored in the CECO Quality Assurance Vault was inventoried.
This consisted of approximately 9500 welds. Radiographs of 64 welds were found to be yellowed. The yellowed radiographic film was separated from the non-yellowed radiographic film. All the non-yellow radiographic film were placed in new interleaving paper and in new storage envelopes. A sample of the non-yellowed radiographic film was sent to Kodak and tested for residual chemical analysis.
It was found that when stored properly, the film should retain their infor-mation for at least 100 years. The yellowed radiographic film was also placed in new interleaving paper and new storage envelopes and accepted as is based on the following:
The original radiographs were reviewed by qualified personnel from Southwest Fabricating, Southwest Fabricating's Authorized Nuclear Inspection Agency, and Sargent & Lundy and found to be in accordance with the ASME Section III Code. Acceptable radiographic reader sheets and technique sketches were included with each set (double film) for each radiographic location.
Ultrasonic inspections rather than radiographic inspections
were used to establish the volumetric Pre-Service Inspection (PSI) baseline program at Braidwood.
l The amount of yellowed radiographic film, based on initial sampling, was approximately 1%.
If the yellowed radiographic filra needs to be viewed in the future, EPRI has developed a computerized technique which has been used to adequately enhance the image, thereby allowing interpretation.
In reviewing the radiographs, penetrameters were observed in the area
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of interest. During an NRC inspection at the Byron Station (Report Nos. 50-454/84-42; 50-455/84-29), a similar issue was reviewed and resulted in a violation (No. 50-454/82-01-01).
In the final Byron response to the. violation dated May 3,1984, CECO included their Code inquiry to Subcommittee V of the ASME for interpretation, the ASME response, and a copy of Code Case 1914 for alternate penetrameter -
placement. Code Case 1914 indicates that the placement of penetrameters on the weld is acceptable providing the lead penetrameter identifying'
numbers are not placed on the weld metal. The NRC inspector agreed with the Ceco corrective actions and closed the Byron violation. The NRC has also accepted Code Case 1914 for Byron and Braidwood. The NRC inspector reviewed the Ceco final response dated June 12, 1986, the NCRs, the yellowed radiographic film and other documentation.
The actions taken by the licensee were acceptable.
c.
(Closed) Violation (456/84-44-02; 457/84-40-02): The NRC Construction
' Appraisal Team-(CAT) inspectors reviewed radiographs' related to work perfonned by various vendors who supplied various equipment and hardware to the site. The NRC CAT inspectors identified irregularities related to radiographs supplied by several of the vendors. -As a result of these f_indings, the licensee issued NCRs and the welds were evaluated and repaired as needed. The NRC_ inspector reviewed 14 packages.of radiographs of welds that were repaired. The companies involved were Harnischfeger Corp., Aerojet General, CB&I, and PDM.
The welds radiographic quality and the reports were found to be acceptable. The NRC inspector also reviewed NCRs, NDE reports and other related documentation. The actions taken by the licensee were acceptable.
d.
(Closed) Unresolved Item (456/84-05-02; 457/84-05-02):
Radiographic reports used at Braidwood are preprinted forms with a series of blocks that identify comon indications that radiographic film interpreters generally encounter. The licensee's radiographic film interpreters were checking off the blocks and were not recording the locations of all the discontinuities that had beea identified. The NRC reviewers (Region I NDE van personnel) were unable to determine what indications had been identified and dispositioned on the radio-graphic reports. The licensee comitted to start documenting indication locations on radiographic reports in the future (reference letter dated April 13, 1984, BRD No. 10.911). The licensee also comitted to review the radiographs regarding the out of tolerance radiographic film densities (reference Paragraph 3.b in this report) to the guidelines of the aforementioned letter. The NRC inspector reviewed a Surveillance Report No. 4088 which was conducted to verify imple-mentation of letter BRD No.10.911. Many radiographic reports and film were reviewed for conformance with letter BRD No.10.911. In addition, the radiographs were reviewed for compliance with density requirements and found to be acceptable. CECO NCR 609 was written in regard to out of tolerance radiographic film densities and is now closed. The actions taken by the licensee were acceptable.
(Closed) Unresolved Item (456/86006-01; 457/86006-01):
In reviewing e.
radiographs of an installed pipe spool in the Essential Service Water system (ESW), the site mechanical contractor noted that field
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weld 8A was identified on the pipe as shop weld W3. A field review the licensee determined that of the spool and radiographs by(PTL) had radiographed field weld 8A Pittsburgh Testing Laboratory as shop weld W3 and shop weld W3 as shop weld W4. This resulted in Southwest Fabricating's shop weld W4 remaining unradiographed.
Therefore, the NRC Construction Appraisal Team (CAT) inspectors concern pertaining to the two identical radiographs for shop welds SX-36-1-SW3 and SX-36-1-SW4 was identified as an unresolved item.
At that time the involved spool was full of water due to testing and could not be re-radiographed correctly. Subsequently, the water was drained and the weld was radiographed with the correct identifi-cation. The NRC inspector reviewed the radiographs and reports for the welds and found them to be acceptable. The actions taken by the
licensee were acceptable, f.
(Closed) Open Item (456/85059-01): CECO NCR 558 was written as a result of Pullman's NCR BR-08 which identified component welds with missing welder ID stamps. A total of 52 components were specifically identified on this NCR. The approved disposition to this NCR was to perform a visual inspection of the identified welds and to rework those found unacceptable and accept-as-is those found acceptable.
During a subsequent review of NCR BR-08 by the NRC, the disposition was determined to be inappropriate (reference NRC Inspection Reports No. 50-456/85059; 50-457/85055). CECO generated NCR 558 to obtain an engineering evaluation of the disposition and requested that Pullman reverify welder identification or rework the identified welds.
Subsequent research by Pullman identified a much larger population than NCR BR-08. Review of visual weld inspection reports revealed 1095 cases where inspections were performed and the Pullman inspector recorded that there was no welder ID. Further review into the component documentation packages resolved all but 314 items.
In Pullman's letter to CECO dated May 28, 1985, this was sumarized and in each of the 314 cases an individual basis was given for closing the item.
Either the welder ID was established or the item was reworked. A further indepth field verification of the 314 items was performed and those for which ID could not be determined were addressed on Pullman NCRs 616, 929, 586 and 693.
Per these NCRs, the listed welds were reworked in accordance with applicable procedures. The NRC inspector reviewed the NCRs, inspection reports, and other related documentation. The actions taken by the licensee were acceptable.
3.
LicenseeActionon10CFR_50_.5,5(eJ__ Defic _i_ency_ Reports a.
(Closed)50.55(e)(456/77-01-EE;457/77-01-EE): System Control Corporation (SCC) was audited by CECO QA on May 19 - 20, 1977. The audit disclosed that SCC welding procedures and welders were not qualified in accordance with AWS D1.1 as required by Braidwood Specification F/L-2815. A stop work order was issued. Subsequent Ceco investigations revealed that 3CC submitted welding procedures in November 1976 which were rejected because AWS D1.1 was not given as the applicable code. SCC did not resubmit these procedures as required, but continued to fabricate cable pans using their own I
procedures. CECO and S&L failed to followup the resubmittal of
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these welding procedures. SCC resubmitted the necessary welding procedures to comply with AWS D1.1.
These procedures were reviewed and approved. All SCC welders were tested and qualified to AWS D1.1.
The same welding settings and parameters were used during qualification testing as during previous production runs. A system has been instituted within CECO and S&L to followup unaccepted procedures to preclude the recurrence of such deficiencies. SCC was reaudited by CECO many times. SCC submitted a field inspection procedure that was approved to examine welds on cable pans and hangers fabricated and delivered to the site, and in some cases installed. On July 25, 1977, Industrial Contract Services Limited (ICS) conducted a visual weld examination of all the Category I cable pan hangers which were delivered to the site as of that date.
They also visually examined the weldments of approximately 10% of all the cable pans delivered to the site as of July 25, 1977. This inspection was authorized by Systems Control Corporation in response
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to deficiencies in their welding program cited by a Commonwealth Edison Company audit. On July 30, 1977, Commonwealth Edison Company's Quality Assurance Division and Peabody Testing Laboratory also conducted an independent inspection of the safety Category I hangers.
Industrial Contract Services Limited's report dated August 11, 1977, identified the deficiencies. The results showed that a total of 804 hangers were examined and 226 hangers were defective.
In 189 cases there were missing welds. The NRC inspector reviewed documentation related to 1977 audits, NCRs, inspection reports and other related documentation. The actions taken by the licensee were acceptable.
b.
(Closed) 50.55(e) (456/84-04-EE; 457/84-04-EE): During a re-review of pipe weldment radiographs performed by Phillips Getschow's (PGCo)
ANI, it was noted that certain views of the film contained out of tolerance densities.
Initial investigations by CECO and PTL indicated that one PTL individual was responsible for interpretations of radiographs (RT) taken prior to September 1979.
PTL wrote NCR 185 which identified 104 Phillips Getschow Company (PGCo) production welds out of 965 welds as being unacceptable. These were welds that were RT'd from July 27, 1976, through S ptember 16, 1979, and had been reviewed by the PTL individual. Attachment VII to PTL NCR 185, Revision 4, documents the disposition of these 104 radiographs.
Attachment VIII to PTL NCR 185, Revision 4, documents that 62 PGCo welder qualification packages out of the 279 reviewed were unacceptable. The dispositions are documented in PTL NCR 185, Letter BRD No.16.647 and PGCo NCR 5302. NCR 185 documents the review of 19 G.K. Newberg welder qualifications packages and all were found to be acceptable.
In addition, 84 Power Systems, Inc.,
welder qualifications and two Universal Power Piping, Inc., welder qualifications were unavailable for review. The qualifications of the welders were evaluated in accordance with the disposition provided in CECO NCR 609, Revision 2.
This included examining welds made by the welders, reviewing NDE reports, etc. The results of this evaluation confirm the ability of the subject welders to perform sound welds. The applicable codes do not require retention of welder qualification radiographs.
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Attachment I to PTL NCR 185, Revision 4, delineates further review conducted based on the results of the original review, July 27, 1976 through September 16, 1977, which identified a definite problem with density and a situation of questionable interpretation. This review encompassed a 100% review of the film interpreted by the suspect reviewer and a 20% review of the other reviewers for the period March 1980 through December 1980.
Documentation of the PTL reviews was verified to be on file in the PTL vault. This documentation consists of handwritten log sheets documenting report number, weld number, correct penetrameter, density, interpretation, ANI review, documentation and the certified reviewer. This log consists of 92 pages and documents the PTL review until approximately May 1, 1984. At that time, due to an unrelated NRC concern, PTL began to complete a separate reader sheet for each weld reviewed documenting indications, density review and certified reviewer. This practice continued until the review was completed. This reader sheet was attached to the original report in the film package.
PTL also maintained a chronological log which was verified to document the review of the population of radiographs from July 27, 1976 through September 16, 1979 (Reports 1 through 1168) and the additional population from March 1980 through December 1980. To prevent recurrence, PTL administered training in the requirements of procedure QC-RT-1 to the film interpreters onsite. This training is documented on training record dated April 7,1986, and contained in PTL NCR 185, Revision 4.
Nineteen of the 104 unacceptable PGCo Production welds are not repaired and are associated with the Unit 2 containment spray system. NCR 788 was issued for the Unit 2 containment spray welds and will be completed following access and inspection. The NRC inspector reviewed NCRs, surveillance reports, NDE reports, and other related documentation. The actions taken by the licensee were acceptable.
4.
Licensee Action _on IE Bulletins (IEB)
(Closed) IEB 83-05(456/83-05-88): There are two ASME Code Hayward Tyler Pumps at Braidwood Station. These units are to be utilized as essential service water booster pumps for each diesel-driven auxiliary feedwater pump. They are identified as ISX04P and 2SX04P. The subject pumps are ASME Class 3 equipment. The ISI requirements for Class 3 components are outlines as follows for Table IWD-2500-1 of Section XI - Division 1:
A visual examination (VT-2) shall be performed under the
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operating condition as a System Inservice Test (IWD-5221)
during each inspection period.
A visual examination (VT-2) shall be performed under the
conditions of a System Hydrostatic Test (IWD-5223) at or near the end of each inspection interval, or during the same period of each inspection interval of Inspection Program B.
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The subject pumps were tested and included the following items for each pump.
A pre-start test was conducted which included a pump-to-diesel engine alignment and a hand rotation of the shaft.
A head (flow) check was made to measure differential pressure
across the pump and to calculate the pump head.
A temperature check was conducted to verify temperature
stabilization.
A visual inspection checked the pump for leaks at the joints and mechanical seals.
A pump rundown check was made to note the rundown duration and smoothness.
A rpm speed check was made to verify proper operation.
The pump ran for 48 consecutive hours during the above test. The above test for ISX04P and 2SX04P was integrated into the Unit 1 preoperational tests of the Auxiliary Feedwater System. The Essential Service Water (SX) System was hydrostatically tested at 125% of rated design pressure prior to system acceptance for testing.
There are no spare parts for the subject pumps onsite or ordered from Hayward Tyler Pump Company (HTPC). The HTPC reconnendations on replacement parts given in Attachment 3 of the subject Bulletin is incorporated into the applicable maintenance procedure. The NRC inspector reviewed the test procedure checklist and other documenta-tion, also the response dated August 12, 1983. The actions taken by the licensee were acceptable.
S.
Spent Fuel Storaje Racks, Units 1 & 2 The spent fuel storage racks were fabricated by Speedway Machine & Tool Company (SMATCo), supplied by NUS Corporation and installed by NISCo in accordance with Specification F 2834. The NRC inspector reviewed the design and purchase specifications, drawings, procedures for handling, shipping, storage and nondestructive examinations (NDE). The NRC inspector also reviewed work procedures that provided instructions for qualified and controlled field welding and personnel qualifications. Additionally, the NRC inspector reviewed the following quality assurance records indicating that applicable requirements and conmitments have been met:
receiving inspection reports, shop fabrication records, material certifications, installationreports,nonconformancereports(NCRs)andQAaudits. The NRC inspector also visually examined selected welds of the spent fuel racks that were installed in the spent fuel racks pit and found tham to be acceptable.
No violations or deviations were identified.
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6.
Exit Interview The inspector met with site representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection. The inspector sumarized the scope and findings of the inspection noted in this report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such document / processes as proprietary,
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