IR 05000456/1986047

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Insp Repts 50-456/86-47 & 50-457/86-35 on 860827-1016.No Violation or Deviation Noted.Major Areas Inspected: Resolution of Previous Insp Findings,Followup on Allegation, Deficiency Repts & QC Weld Insp Practice
ML20215L381
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 10/24/1986
From: Danielson D, James Gavula, Jeffrey Jacobson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215L364 List:
References
50-456-86-47, 50-457-86-35, NUDOCS 8610280595
Download: ML20215L381 (10)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/86047(DRS); 50-457/86035(DRS)

Docket Nos. 50-456; 50-457 Construction Permits No. CPPR-132; CPPR-133 Licensee:

Commonwealth 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:

August 27 and 28, September 3-5, 17-19,

,7 and October 2, 3, 15 and 16, 1986, f > _~.

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Inspectors L./H.\\Qacobson

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A A. Gavula

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Date v/d7 Approved By:

D. H. Danielson, Chief

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Materials and Processes Section Dat'e Inspection Summary Inspection on August 27 and 28, September 3-5, 17-19, and October 2, 3, 15 and 16, 1986 (Reports No. 50-456/86047(DRS); 50-457/86035(DRS))

Areas Inspected:

Unannounced, special safety inspection of the resolution

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of previous inspection findings (92701 and 92702), follow-up on an allegation i

(99014), 50.55(e) deficiency reports (99020), and Q.C. weld inspection practice for main control boards (55100).

Results:

No violations or deviations were identified.

l 8610280595 861024 DR ADOCK 0000

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DETAILS 1.

Persons Contacted Commonwealth Edison Company (CECO)

  • T. E. Quaka, Site QA Superintendent
  • M. J. Wallace, Project Manager G. F. Marcus, Assistant to Manager Quality Assurance A. J. D' Antonio, Regulatory Assurance
  • D. L. Cecchett, Regulatory Assurance
  • P. L. Barnes, Regulatory Assurance Supervisor J. K. Jasnosz, Regulatory Assurance
  • G. E. Groth, Assistant Construction Superintendent D. L. Shamblin, Project Construction Superintendent
  • E. E. Fitzpatrick, Station Manager C. W. Schroeder, Services Superintendent
  • E. R. Wendorf, PFE Mechanical Supervisor
  • L. M. Kline, Regulatory Assurance
  • P. A. Boyle, Regulatory Assurance W. Bruns, Field Engineer Sargent & Lundy R. L. Hooks, SED, Assistant Division Head P. K. Agrawal, Senior Structural Project Engineer The inspector also contacted and interviewed other licensee and i

contractor employees.

  • Denotes those attending the exit meeting at the Braidwood Station on October 16, 1986.

2.

Licensee Action on Previous Inspection Findings a.

(Closed) Violation (456/84044-07; 457/84040-07):

Failure to follow design requirements with respect to weld size and configuration of skewed tee joints.

Phillips Getschow (PGCo) welded and inspected piping support and restraint connections as shown on the individual support drawings without utilizing the additional requirements of

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S&L drawing M-999.

The individual support drawings specify fillet leg sizes, which were interpreted by PGCo as equivalent leg sizes fortheskewedteejoints.

This practice may result in insufficient effective weld throat.

The NRC inspector reviewed Engineering Change Notices 25598, 25599, and 25600, which were issued to provide more detailed guidance with regard to skewed tee joints and found them acceptable.

The licensee issued NCR L-705 to resolve the issue regarding the installed skewed teejoints.

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In an effort to identify any detrimental effect on the installed supports as a result of the deficiency, S&L reviewed 60 pipe supports involving skewed connections.

As a result of this review, S&L concluded that all sampled supports except for two cantilever supports were adequate from a design significance consideration.

The two cantilevers were considered indeterminate due to the conservative review criteria.

For the purpose of this review, S&L conservativelyignoredweldswithskewangleslessthan30 and greater than 135 due to uncertainties involved in the determination of effective throat.

In order to determine the effective throat to be used in the evaluation of these two supports, S&L requested that PGCoperformasugplementalweldqualificationforconnectionswith skew angles of 20 and 160.

Using the effective throats obtained from this qualification, S&L determined that the connections were acceptable.

As a result of the engineering evaluations and the supplemental weld qualification, the licensee has demonstrated the acceptability of the installed supports, b.

(Closed) Open Item (456/85019-01; 457/85020-01):

Threaded portion of bolts loaded in shear.

During an NRC review of BCAP discrepancy evaluations CSR I-M-003-068-01 and CSR I-M-003-XXX-58 it was noted i

that Grinnel pipe clamp, figure 195, utilized a load bolt with threads loaded in shear.

ASME Code,Section III, Subsection NF, specifically prohibits the threaded portion of bolts to be loaded

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in pure shear unless permitted by the design specification.

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The NRC inspector reviewed S&L Calc. No. CLMP-SDS-001-BCAP.

This calculation demonstrated that the resultant bending and shear stresses are within Code allowables and that the design margin is available.

In addition, the inspector examined approximately 20 supports of the configuration in question and verified the installed condition as acceptable.

I c.

(Closed) Open Item (456/85019-02; 457/85020-02):

Review of final walkdown procedure for component supports.

Prior to plant operation, all safety related su) ports will be inspected. This walkdown inspection includes suc1 things as verification of support location, a check for adequate clearance from obstructions where required, verification of hardware configuration and material condition, and a check for proper engagement of fasteners.

The NRC inspector reviewed Phillips Getschow (PGCo) Procedure PGCP-48,

" Final Linewalk of Component Supports / Restraints," and found the pro-cedure to adequately control the walkdown inspection.

In addition, PGCo Procedure QCP-823, " Installation and Inspection of Component Supports," and Procedure QCP-23A, " Supplemental Procedure for Installation of Component Support Specialty Items," were reviewed and found acceptable.

d.

(Closed) Unresolved Item (456/83007-03; 457/83007-03):

Installation of safety related heat exchangers.

The moderating heat exchanger 1BR01A did not appear to have proper anchor bolt engagement in the slotted holes to allow for thermal expansion.

In addition, the

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Control Room Chillers, 0W001CA and 0W001CB did not appear to be properly installed and were not included in the mechanical equipment retrofit inspection program.

The NRC inspector reviewed S&L Engineering Change Notice (ECN)

Nos. 22896 and 26961 and inspected several heat exchanger installations.

These ECNs were written to clarify the installation requirements for heat exchangers and were found to be acceptable.

The following heat exchanger installations were inspected and found acceptable:

Control Room Chillers 0W001CA and 0W001CB Letdown Heat Exchanger 1BR03A Letdown Reheat Heat Exchanger ICV 05A Moderating Heat Exchanger 1BR01A As-documented in NRC Inspection Report 456/86009; 457/86008, the licensee's Safety-Related Mechanical Equipment Retrofit Program was evaluated and found to adequately address the mechanical equipment installation deficiencies.

Coincident with the inspection of the above listed heat exchangers, the NRC inspector also reviewed the installation and retrofit documentation packages.

The packages were found to adequately document the heat exchanger installations.

Phillips Getschow NCR No. 1127 was written to address the improper installation sequence of the Control Room Chillers.

Exclusion of these heat exchangers from the Mechanical Equipment Retrofit Program appears to be an 1solated incident and the corrective actions to correct the installation appear adequate.

e.

(Closed) Unresolved Item (456/85023-02; 457/85024-02):

Improper fabrication and bolt-up of a structural joint.

A loose bolt was found on a beam to embed connection in the Unit 1 Containment.

Upon removal of the bolts to correct the condition, the structural contractor noted that the bolt holes in the beam had been torch cut.

The AISC specification stated that holes may be drilled, punched, or punched and reamed.

The licensee was to evaluate the acceptability of this connection and the generic application of torch-cut bolt holes.

The June 6, 1985, revision to the AISC Specification for Structural Joints removed all reference as to the method of fabricating bolt holes.

Torch cutting of bolt holes is not prohibited and the design of slip-critical and bearing type bolted connections is independent of the hole cutting process.

The NRC inspector also reviewed a research publication reprinted from the AISC Engineering Journal

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entitled, "Effect of Hole Making on the Strength of Double Lap Joints." The research effort concluded that the torch cutting of bolt holes does not adversely affect the connection performance.

The S&L evaluation of this issue also concluded that the as-found condition of the beam to embed connection was not design significant and that torch cut bolt holes were acceptable.

3.

Licensee Action on 10 CFR 50.55(e) Items a.

(Closed) 10 CFR 50.55(e) Item (456/83-08-EE; 457/83-08-EE):

Fabrication and installation of Pullman Sheet Metal (PSM) duct fittings without approved design documents.

PSM had fabricated duct fittings based on their interpretation of the design specification and standard industry practices.

PSM was directed to submit design drawings as a part of their Duct Brochure for S&L review and approval.

These drawings were intended to reflect the designs used by PSM to fabricate the duct fittings in question.

S&L performed an engineering review of the designs and approved their use.

PSM was then directed to perform a review of all shop fabricated fittings to determine the total population involved and to verify those fittings which were in compliance with the S&L approved design drawings.

A total population of 2814 fittings were reviewed, of which PSM determined that 1849 fittings complied with the approved designs.

Of the remaining 965 fittings, 635 fittings required

"as-builts" to be submitted to S&L for review, with 67 requiring some modification.

The licensee directed PSM to forgo producing

"as-builts" on the remaining 330 and simply rework to achieve design conformance.

The engineering evaluations, inspections and rework performed are considered acceptable to resolve this issue.

b.

(Closed) 10 CFR 50.55(e) Item (456/84012-EE; 457/84012-EE):

ASME nameplates were removed from piping subassemblies without proper controls and documentation prior to July 1984.

In addition, Code required NDE of the removal areas was not performed.

CECO NCR 639 and Phillips Getschow NCR 1783 were issued to resolve this deficiency.

The NRC inspector reviewed Phillips Getschow Procedure PGCP-51, which was developed to verify traceability of those piping sub-assemblies with removed nameplates (prior to July 1984), locate the nameplate removal area, and perform the required NDE.

The scope of the program included 532 piping subassemblies and 25 penetration assemblies, determined by utilization of the licensee's MTV Program (see NRC Inspection Report No. 50-456/85061; 50-457/85057)

and production records.

Procedure PGCP-51 identified three conditions which were used to categorize the affected piping upon inspection:

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Condition No. 1 -

Area of Nameplate removal located, NDE and digital thickness measurements (DTM)

acceptable.

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Area of removal located, NDE or DTM not acceptable.

Condition No. 3 -

Area of removal not located.

NCRs were issued to disposition those piping subassemblies and penetration assemblies categorized as Condition Nos. 2 and 3.

The NRC inspector reviewed a random selection of the NCRs and found the'

dispositions to be acceptable.

Based on the licensee's corrective actions to bring the affected piping into Code compliance, this issue is considered closed.

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c.

(Closed) 10 CFR 50.55(e) Item (456/84014-EE; 457/84014-EE):

Laminar indications in steam generator snubber materials caused the

rejectionofcertainsnubberendcapsandrodends.

Utilizing

ultrasonic examination with ASME Section III acceptance criteria, j

ten end caps and one rod end were found to have unacceptable indications.

As a result of these findings, six end caps and the rod end were replaced.

Two of the remaining end caps were weld repaired to within code requirements.

The remaining two end caps were found acceptable based on a stress analysis of the modified parts once the defects were removed.

The NRC inspector reviewed the following documentation for the two end caps.

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Serial No. 18 " Stress Report Supplement No. 1"

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Rejected Material Report No. 29292

End Cap Flange Stresses Byron /Braidwood Steam Generator Snubbers l

SPS-847105 Supplement No. 1, November 12, 1985 Serial No. 30 " Stress Report Supplement No. 2"

Rejected Material Report No. 29203

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End Cap Bearing Hole Stresses Byron /Braidwood Steam Generator Snubbers

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SPS-847105 Supplement No. 2, November 12, 1985 Conservative assumptions were made relative to the reduction in

areas due to the removal of the defects.

In both cases stresses were well within code allowables.

No adverse comments were made during the review of the analyses.

d, (Closed) 10 CFR 50.55(e) Item (456/86005-EE; 457/86005-EE):

Flow induced vibration had caused fatigue cracks in portions of the cold

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legsafetyinjectionpipingduringpreoperationaltestingatCEco's l

Byron Station Unit 2.

This item was applicable to Braidwood because j.

of the similarity in piping configuration between the stations, i

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During the February 16, 1986, ECCS Full Flow test at Byron Unit 2 a socket welded elbow on the A Loop Safety Injection Line downstream from a flow limiting orifice was found leaking.

A metallurgical examination of the removed elbow indicated that the failure was due to high cycle fatigue.

In order to reduce the vibration / stresses, the configuration was changed by relocating valve 2SI8810A into a lower stressed portion of pipe and by replacing the socket welded elbow with a 5-times-diameter bend.

A subsequent evaluation of data obtained from hand held instruments and strain gauges confirmed that these changes resulted in vibrational stresses near the location of the previous crack well within~the stress limits defined in the FSAR.

However, during the course of confirming the acceptability of the Loop A modification, hand held vibration readings indicated a potential problem on the Loop D piping.

Based on an evaluation of this data it was decided to make several changes to the Loop D piping configuration.

The changes included replacement of an elbow with a 5-0 bend, addition of a support and utilization of butt welded pipe as opposed to socket welded fittings in a portion of the line.

The elbow that was replaced in the system was then metallurgically evaluated and found to have a high cycle fatigue crack in one of the welds.

Since a similar configuration existed in other units, it was decided to modify the Loop D piping on Braidwood Units 1 and 2 and Byron Unit 1, similar to the Byron Unit 2 modification.

Also, the Braidwood Unit 2 Loop A piping was modified to match the Byron Unit 2 Loop A modification.

No other problems were indicated in any of the other corresponding loop A, B, or C piping.

An NRC inspector reviewed the Sargent & Lundy report, " Vibration Testing of the SI Cold Leg Injection Lines," File No. EMD-060654, Revision 00, dated May 22, 1986.

The vibrational stresses resulting from the tests performed on the Byron Unit 2 and Braidwood Unit 1 Safety Injection Lines were shown to be within the allowable stress limit established in the FSAR.

4.

Licensee Action on SER Items (Closed) SER Item (456/86000-23; 457/86000-23):

The Braidwood Station Units 1 and 2 control valves are constructed to Section III, Class 1, of the ASME Boiler and Pressure Vessel Code, 1971 Edition, through the Summer 1972 Addenda.

In order to be in compliance with subsection (f)(3) of 10 CFR Part 50 Section 50.55a, these components should be constructedtoASMESectionIII, Class 1,1971 Edition,throughthe Winter 1972 Addenda to the code.

The staff has reviewed the difference: in these Code Addenda as applicable to the control valves, and has identified no major differences.

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The staff concludes that updating the control valves to meet the require-ments of subsection (f)(3) of 10 CFR Part 50, Section 50.55a, would not result in a commensurate increase in the level of safety.

Therefore, the staff finds that the ASME Code and Addenda used.in the construction of the control valves is acceptable and provides adequate assurance of component quality, Upon review of the FSAR, the NRC inspector noted that Table 5.2-1 erroneously lists the Braidwood Control Valves as having been purchased to the 1971 Edition, with the Winter 1972 Addenda.

The licensee committed to correct Table 5.2-1 to reflect the 1971 Edition,'with the Summer 1972 Addenda.

5.

Allegation Follow-up (RIII-86-A-0002)

a.

Allegation (Closed) An anonymous letter was received by mail in Region III on January 6, 1986 alleging that Sargent & Lundy's Engineering Mechanics Division (EMD) had utilized incorrect analytical methods for as-built reconciliation of pipe stresses and anchor loads.

A specific example referenced support relocations reviewed by a named individual where the induced movements from nearby supports were ignored.

(This item was previously reviewed and was closed for Byron in NRC Inspection Reports No. 50-454/86009; 50-455/86008 and No. 50-456/86011; 50-457/86009).

b.

NRC Review The NRC inspector selected the following five Braidwood calculations (these were in addition to the ten originally reviewed calculations, as discussed in the above referenced inspection reports):

(1) EMD-049890, "Braidwood Unit 1 Addendum to Stress Report for 1WO-26 Addendum A," dated June 28, 1985, Revision 03F1.

(2) EMD-050538, "Braidwood Unit 1 Addendum to Stress Report for 1AF-08," dated January 29, 1985, Revision 07F2.

(3) EMD-049482, "Braidwood Unit 1 Addendum to Stress Report for 1MS-05," dated October 11, 1984.

(4) EMD-049489, "Braidwood Unit 1 Addendum to Stress Report for 105-04," dated December 27, 1984, Revision 00F0.

(5) EMD-40272, "Braidwood Unit 1 Addendum to Stress Report for 1RH08," dated June 3, 1985, Revision 03F1.

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c.

Conclusion In all of the above cases, appropriate analytical techniques were used to reconcile the as-built configuration.

No adverse comments were made regarding any of the above analyses.

The allegation could not be substantiated.

Based on this inspection as well as that documented in NRC Inspection Report No. 50-454/86009; 50-455/85008, this item is considered closed.

6.

Inspection of Fabrication and Installation Welds for Main Control Boards CECO NCR 235 was issued to document apparent weld deficiencies noted upon receipt of main control panels from Systers Control (SC).

In an effort to resolve this issue, it was decided to map the size and length of the panel welds to allow for engineering evaluation.

L. K. Comstock (LKC)

QC issued a memo to the field on June 13, 1983, to permit inspection, presumably of the panel welds, in the painted condition.

This practice was consistent with a CECO QA memo of November 24, 1981, allowing over inspection of welds in the painted condition provided it is so noted on the inspection report.

This practice was not intended for first line inspections, only everinspections; furthermore, it was a requirement to note on the inspectiva report when the inspection was performed in the painted condition.

An LKC memo to CECO QA, dated March 9, 1984, stated that inadvertently, some first line weld inspections had been performed in the painted condition as noted upon a review of weld inspection reports.

A CECO QA memo, dated March 9, 1984, replied that no first line inspections were to be permitted in the painted condition as this was in violation of the AWS D1.1 Code requirements.

A review of inspection reports by LKC indicates that first line inspection of welds was limited to some of the control panel installation welds.

The NRC inspector reviewed the above information and examined several Inspection Correction Reports (ICR) from the time frame October 1982 through March 1984.

A review of these ICRs demonstrate that if welds had been painted before inspection, the first line inspections were not performed until the paint was removed.

This serves to substantiate the LKC position that it was at no time an acceptable policy to perform first line inspection of welds in the painted condition.

All available information indicates that first line inspection of the control board installation welds in the painted condition was an isolated incident due to misinterpretation of the LKC memo of June 13, 1983.

These installation welds have subsequently been evaluated and accepted by Westinghouse.

No violations or deviations were identified.

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4.

Exit Interview The Region III inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on October 16, 1986.

The inspector summarized the purpose and findings of the inspection.

The. licensee representatives acknowledged this information.

The inspector also discussed the likely informational content of the inspection report with regards to documents or processes reviewed during the inspection.

The licensee representatives did not identify any such documents / processes as proprietary, i

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