ML19330B929

Responds to NRC 800610 Ltr Re Violations Noted in IE Insp Repts 50-456/80-04 & 50-457/80-04.Corrective Actions:All Repair Spot Welds on Unistrut Hangers Will Be Identified & Coated Prior to Fuel Loading,Unless Adequacy Demonstrated

ML19330B929
Person / Time
Site:	Braidwood
Issue date:	07/11/1980
From:	Peoples D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19330B925	List: ML19330B929
References
NUDOCS 8008070230
Download: ML19330B929 (5)

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Commonwealth Edison g

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[7 O \, one First Nati nal Plaza. Chicago, Illinois Addr:,ss R; ply tr Post Offica Box 767 t

\ Cf Chicago, lltinois 60690

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ig 15 980 July 11, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Response to IE Inspection Report 50-456/80-04 and 50-457/80-04 NRC Occket Nos. 50-456 and 50-457 Reference (a): G. Fiorelli letter to C. Reed dated June 10, 1980

Dear Mr. Keppler:

Reference (a) contained the results of an inspection conducted by Messrs. E. R. Schweinbinz, E. J. Gallagher, and K. R.

Naider of your office on May 14-15, 1980, of activities at the Braidwood Nuclear Power Station, Units 1 and 2. During this inspection certain activities appeared co be in noncompliance with NRC requirements. Commonwealth Ediso:i Company responds to this item of noncompliance in the Attachment to this letter.

Please address any additional questions that you might have concerning this matter to this office.

Very truly yours, GU D. L. Peop es i Director of Nuclear Licensing Attachment i

5154A- l 8008,070, 236 ,

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Attachment O

Response to Notice of Violation i

The items of apparent noncompliance identified in Appendix A of the NRC letter dated June 10, 1980, is responded to in the following paragraphs.

10 CFR 50, Appendix-B, Criterion III, states, in part, that

" Measures shall be established to assure that applicable . . .

design basis . . . for those structures, systems, and components

. . . are correctly translated into specifications, drawings, procedures, and instructions."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Paragraph 3.1 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures. The design documents include, but are not limited to, design and construction specifications, equipment specifications, and process drawings. Review of and evaluation by the Architect Engineer will ensure that designs and materials will conform to the ASME Code and other applicable codes, standards, regulatory requirements, SAR commitments, and appropriate quality Standards as applicable.

. Contrary to the above, it was determined that CECO did not ensure that Sargent and Lundy adequately translated the requirements in paragraphs 6.2.1.6 and 3.2.8.6.1 of.the Braidwood PSAR and the .

requirements in Table 302.4 of S&L Specification 2831 into S&L Specification No. 2815'for electrical cable tray hanger supports in that corrosion protection was not specified for the exposed carbon

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steel-material and exposed spot welds used in the installation of

seismic Category 1 electrical cable tray hangar supportp.

Corrective Action Taken And Results Achieved The NRC inspector referenced the requirements in paragraph 6.2.1.6-and 3.8.2.6.1 of the Braidwood PSAR and stated that they were inadequately translated into Specification F/L-2815 and that this was an item of noncompliance. Section 6.2.1.6 of the PSAR describes the coating systems that will be used in the containment and Section 3.8.2.6.1 refers to the AISC Manual of Steel Construction as one of-the codes of practice used to establish standards of construction procedure. In this context, the noncompliance deals with.the surface preparation and painting that is required on steel surfaces covered by' fabrication Specification F/L-2815.

Specification F/L-2815 deals with electrical equipment hangers,

. fabrication and erection. Standard EB-115.0 B/B is part of this specification. The.following' requirements are noted in this standard.

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A. In Section 2.8.1 of this standard, it is stated that all components of hangers made from UNISTRUT members shal1 have a mil-galvanized finish. Therefore, coating requirements were not required for components addressed in this section.

B. In Section 2.d.2 of the EB Standard, the use of nongalvanized structural steel members or plates when the thickness is greater than 1/8" was allowed. In this context, the manufacturer of the hangers used carbon steel material for connecting UNISTRUT members. These are basically channel sections made of carbon steel. Although the " Field Finish Coating Work" Specification F/L-2831 would address these components, it is acknowledged that certain installed carbon steel connectors were not coated.

Sargent & Lundy has reviewed the corrosion rate anticipated l using the 9th Edition of American Society for Metals (ASM)  ;

Handbook, Volume 1, " Properties and Selection: Iron and Steels," 1 l

and determined that the corrosion in mils for a 40-year life in a rural environment would be 8.5 mils and for an industrial area would be 12 mils. (Attached is a copy of page 723 of the referenced document.) Since the containment environment is less corrosive than a rural environment, and since we have allowed in the design for the possible loss of thickness in the end nlate .

connection members, we do not require that these end (plant,)[25bi 2 '

connections be painted. Sargent & Lundy will issue an Engineering Change Notice (ECN) to Specification F/L-2815 to eliminate the need for coating these connectors.

I In some other instances, a substitution was requested for the use of tube sections instead of UNISTRUT members. The tube sections are carbon steel material. The request for this substitution came from the manufacturer and in some instances from Commonwealth Edison Company. Also, auxiliary steel members have been installed without a shop primer coat. Specification F/L-2831 requires that these carbon steel sections be painted. Table 302.4, Schedule 1, for the containment structure on page 3-4, under all other miscellaneous steel, requires that bare metal (metal without a shop primer coat) have a sarface preparation SL-SP1 and a coating system SL-CS2. As long as this work is done prior to fuel loading, this item, in our opinion, will not be in noncompliance. For the Auxiliary Building, on pages 3-6 of Specification F/L-2831, under Structural Equipment Supports, Pipe Supports, etc., it is required for steel without a shop primer coat that a surface preparation of l SL-SP2 be performed and a coating meeting SL-CS4 be applied. If this work is done prior to fuel loading, this item, in our opinion, will not be in noncompliance.

In addition, the carbon steel tube sections substituted for galvanized UNISTRUT have been assessed. It is our intention to coat these struts in accordance with the requirements of Specification F/L-2831 prior to fuel loading, or on a component specific basis, perform a technical evaluation to confirm that sufficient corrosion allowance exists to preclude the need for field coating. Therefore,

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all such struts will either be coated, or documentation will be

, provided justifying not coating specific struts or classe's of struts. )

C. In Section 2.8.6 of the'EB Standard, it is required that "after l fabrication . . . surfaces shall be repaired with a zinc-rich paint. . ." Section 4.1 of the EB Standard requires that field welds _over galvanized surfaces be touched up with a suitable

_ galvanizing repair product. Sinca repair spot welds of this type have been made by the supplier, it will be necessary to either coat the subject repair welds or demonstrate that the installed product is acceptable. UNISTRUT has been requested to provide an engineering assessment of the adequacy of the repair welds by October 15, 1980.

Corrective Action Taken To Avoid Further Noncompliance 1

As was indicated above, Specification F/L-2831, " Field Finish Coating Work", would, in fact, address the coating requirements' applicable to the discreoant components discussed.

However, in order to assure proper adherence to these coating requirements for the components addressed in Specification F/L-2815, Sargent & Lundy has issued a clarification letter to the Commonwealth Edison Company Station Nuclear Engineering Department and to the Braidwood Site Construction Superintendent which clearly identifies the operative sections of Specification F/L-2815 and the applicable coating requirements in Specification F/L-2831. In addition, as described above, an ECN will be issued to climinate the need for coating non-galvanized UNISTRUT connectors.

4 Date of Full Compliance Inasmuch as the " Field Finish Coating Work" Specification F/L-2831 requires coating be completed prior to completion of field

, work, the discrepant components addressed in this noncompliance and other similar areas will be identified and coating completed prior to fuel loading on the unit involved. This includes all carbon steel tube' struts for which technical justification is not provided

, to eliminate field coating. In addition, all repair spot welds on UNISTRUT hangers will be identified and coated prior to fuel loading, unless the technical adequacy of the installed product is demonstrated. A technical assessment has been requested of the supplier which will be available by October 15, 1980.

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2. S. R. Addanki et al, Role of Different

'.. Tchio 7 Comparison of corresten for 9ropical and .

Variables Affecting Atmospheric gast Coast snarino sites Corrosion of Steel, Proceedings ofthe conoston lose ThirdInternationalCongress on Me-fallie Corrosion,, Vol 4, Moscow, c ,,,,, $8hg",8,',h, 1969, p 554 Time, carbon meal beartns eted ta) one nm atte 3. B.Sanyal,G. K.Singhania and J. N.

yr am aus nm Nanda, Corrosion of Metals in the roe.co.

5.6 115- 4.5 63 2.5 Tropics, Proceedings ofthe Third In-Kure Beach, NC(b) 7.5 142 530 21 450 17.6 245 - 9.7 ternational Congress on Metallie Panama Canal Zone 8 Corrosion, Voi.4, Moscow,1969, p (o Compositione, alttough not slike. resemble one another. (b) 245 m (800 fu fro" eeean.

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4. A. Gallicio, Galvanic Test Methods, Handbook on Corrosion Testing and 7;bie S Corrosion of structural steels la variees ~ .

Evaluation, W. Ailor (Ed.), John Wi-environments (ttef 9) ley, New York,1971, p 143 Aver se nduction in thicknees, one (w 5. D. P. Doyle and H. Godard, A Rapid ser.etural structural M. e.thod for Determining the Corro.

UNS UNS UNS UNS Timme, carbon copper sm,ty of the Atmosphere at Any Lo-Type of atmosphere yr steel eteel K1151o(b) K11430(c) K1163o(d) K11576(e) cation, Nature, Vol 200 (No. 4912),

1.3 1.8 1.4 2.2 21 Dec 1963, p 1167 3.5 3.3 2.6 Industrial 3.2 1.5 2.1 1.7 '* 6. K. G. Compton, A. Mendir2a and (Newark, NJ) 7.5 4.1

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" W. W. Bradley, Atmospheric Ga!-

. 15.5 5J 4.0 1.8 vanic Couple Corrosion, Corrosion, 1.4 1.2 1.6 Semi.indcstrial 1.5 2.2 1.7 1.1 Vol 11,1955, p 383t 2.1 1.4 2.4 (Monroeville, PA) 3.5 3.7 2.5 1.2 7. S.G. Clark and E.E.Longhurst,The 3.2 1.4 2.4 1.7 7.5 5.1 1.8

' 1.8 '... . Corrosion Behavior of Metals and 15.5 7.3 4.7 Protective Coatings in Tropical At-1.8 1.4 1.0 1.3 1.0 1.5 mospheric Exposure Tests, Metallic Semi. industrial 1.5 2.2 1.3 1.9 1.5 2.4 Corrosion-First International Con-(South Bend, PA) 3.5 2.9 7.5 4.6 3.2 1.8 2.7 1.9 pss on Corrosion, Butterworth's, 7.0 4.8 2.2 ' 2.5 IAndon,1962, p 254 15.5

8. S. K. Coburn et al, Corrosiveness of 2.5 '- 1.3 0.8 1.2 Various Atmospheric Test Sites as Rural 1.4 1.2 1.8 (Potter County, PA) 3.5 2.0 1.7 1.1 Measured by Specimens ofSteel and 2.5 1.3 1.5 1.5 7.5 3.0 Iron, Metal Corrosion in the Atmo-4.7 3.8 1.4 2.0 15.5 sphere, STP 435, American Society 0.9 0.8 0.6 0.8 0.7 1.0 . for Testing and Materials, Philadel-Moderate marine 0.5 1.5 2.3 1.9 1.1 1.7 1.2 1.7 phia.1968, p 360 (Kure Beach, NC, 2.2 9. C.P.Larrabee and S.K.Coburn,The 4.9 3.3 1.8 2.5 1.9 800 ft from ocean) 3.5 5.6 4.5 2.5 3.7 2.9 *'

Atmospheric Corrosion of Steels as 7.5 Influenced by Changes in Chemical 2.2 3.8 1.1 0.7 Severe marine 0.5 7.2 4.3 Corr. position, Metallic Corrosion-19.0 3.3 12.2

' 2.1 First Internationa! Congress on Cor-(Kure Beach, NC, 2.0 36.0 28.7 3.9 3.9 80 ft from ocean) 3.5 67.0 38.0 ... rosion,Butterworth's,14ndon,1962, 19.4 38.8 5.0 5.0 (0 (D P 276 284 (a)Teobtain (grede Al (d i

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