ML19338G484
| ML19338G484 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/01/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19338G483 | List: |
| References | |
| NUDOCS 8010290414 | |
| Download: ML19338G484 (4) | |
Text
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9 Commonwealth Edison C \\
One First National PL*2a Chictgo. tilinois Q'j~ Address Reply to. Post Office Box 767 C
Chicago, tilinois 60690 g
October 1, 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 a
Subject:
Braidwood Station Unit 1 Response to IE Inspection Report No. 50-456/80-08 NRC Docket No. 50-456 Reference (a):
August 28, 1980, letter from G.
Fiorelli to Cordell Reed transmitting IE Inspection Report No. 50-456/80-08
Dear Mr. Keppler:
Reference (a) contained the results.of an inspection conducted by Mr. E.
W. Lee of your office on July 24 and August 14, 1980, of activities at Braidwood Station.
During that inspection, certain activities appeared to be in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison Company's response to the item of noncompliance.
i Please address any questions that you might have concerning this matter to this office.
d Very truly yours, J. S. Abel Director of Nuclear Licensing l
Attachment bM
!0CT 7083A
NRC Docket No. 50-456 ATTACHMENT A
.1 Response to Notice of Violation The item of apparent noncompliance identified in Appendix A of the NRC letter dated August 28, 1980, is responded to in the following paragraphs.
j Item - Infraction 10 CFR 50, Appendix B, Criterion XIII, states, in part, that Measures shall be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection instructions to prevent damage 1
or deterioration."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 30, Section 13, states, in part, that
. Written instructions for handling, preservation, storage, and shipping will be used to specify special protectivs conditions necessary to prevent damage or deterioration of materials and equipment Phillips, Getschow Company (PG) Procedure No. QAP-3, Revision 0, Paragraph 4.1.2 req. ires that E7018, E308, E309, E310 and E316 electrodes manufactured by McKay be stored in the holding oven at 0
275 F.
PG Procedure No. QCP-88, Revision 4, Paragraph 4.7.1 states that Consumable inserts may be withdrawn provided that the requirements of 4.7 are met and that each consumable insert is tagged with the weld number that it is being withdrawn for."
PG Procedure NJ. QCP-B8, Revision 4, Paragraph 4.13, states, that "When the welder has completed the welds that the material was drawn for, or when he has used up the material on his welding electrode slip (Form PG-110-9) or at the end of the shift, he will return to the warehouseman his stubs, any excess weld material and the duplicate copy of the welding electrode slip."
Contrary to the above, during the inspection, the inspector established that control of welding material is inadequate.
Examples of this inadequacy are cited below; a.
A consumable insert for weld No. CV10-FW26C was issuhd to a welder on July 21, 1980.
Another consumable insert for weld No.
CV10-FW17A was issued to the same welder on July 24, 1980.
A consumable insert was tack welded to weld No. CV10-FW17A on July 24, 1980.
A consumable ring without tag was also in the possession of this welder on July 24, 1980, and no consumable l
=
.,.-p 4
. p insert was tack welded to weld No. CV10-FW26C.
Furthermore, evidence to indicate that the consumable insert for weld No.
CV10-FW26C was returned to the warehouseman since its issuance on July 21, 1980, was unavailable.
b.
E308 electrodes with heats No. 2297613 and No. 2877920, E309 electrodes with heat No. 217620 and E316 electrodes with heat No. 2166920 manufactured by McKay were stored at weld rod oven No. 12 in the welding material issuance station located at the Turbine Building.
The calibrated records dated March 19, 1980, and June 3, 1980, indicated weld rod oven No. 12 was set at 1750F.
c.
Approximately ten E308 electrodes were in the stub-can.
Upon questioning the welder, the inspector was informed that tne electrodes in the stub-can are good electrodes and not scraps.
Corrective Action Taken and Results Achieved Commonwealth Edison has reexamined, revised, and inttituted procedures regarding the control of weld material at its Braidwood Station.
The following information is provided regarding the specific examples cited above.
a.
The consumable inserts in question were removed and returned to the warehouseman and traceable inserts were issued.
l b.
Since, according to the manufactorer's recommendations, 1750F is acceptable for McKay E308, E309 and E316 coated welding rods, the storage procedure will be revised to reflect this requirement.
c.
With regard to the electrodes in the stub-can, Commonwealth Edison finds no conflicts with Phillips, Getschow procedures, no lack of traceability, nor any deviation from the time-out-of-oven requirements.
Commonwealth Edison does not concur that keeping stubs in the same container with whole rods causas a lapse in weld control.
On the contrary, in many cases such a practice enhances both the control of stubs and welder sE!ety.
More specifically, the welder is usually issued a portable oven with traceable E308, E309, or E7018 rods.
The rods are kept in the pertable oven, and the oven is plugged in near the work area.
Tc avoid #11 king over to the portable oven each time j
a rod is needed, the welder will put about thirty minutes worth of rods in a bucket (rod is permitted to be out of the oven for four hours).
The bucket usually resembles a water pall, thus making the rod easily accessible.
A bucket is also easier to get stubs into rather than the narrow cans, thus keeping stubs off the floor.
Stubs will not damage the whole rod and the I
welder is no more likely to pick a stub out of a bucket with whole rods than he would in using two separate cans.
~
o 4 l' In addition, putting whole rods in a stub bucket eliminates dragging a portable oven, with its high center of gravity, up into high scaffolding, thus eliminating one more cord and container in cramped spaces.
One large bucket is less likely to be kicked over than two small containers.
This enhances both safety and stub control.
Finally, responsibility for putting traceable rod into a joint, for following time-out-of-oven requirements, and for controlling stubs is still with the welder.
Whether the welder uses one bucket, two cans, or a stub can and pulls his rod rignt out of a portable oven, control is still left up to him.
Commonwealth Edison does not feel that using one bucket for stubs and whole rods conflicts with any procedural requirements 4
or detracts from traceability, final weld quality, or rod moisture level maintenance. In many cases, Commonwealth Edison feels that such a practice augments rod stub control and welder i
safety.
Corrective Action to be Taken to Avoid Further Noncompliance To avoid further noncompliance Commonwealth Edison took the following action regarding the examples cited.
a.
A training session was conducted on Pnillips. Getschow Company Procedure, QCP-B8, Rev. 4 (Issuance and Control of Welding Material).
Phillips, Getschow Company has also instituted a procedure whereby all inserts are tagged with a weld number and heat number.
D.
According to the manufactorer's recommendation, 1750F is acceptable for McKay E
, E309 and E316 coated welding rods.
Therefore, Phillips, Getschow Company has revised storage procedure QAP-3, Rev. 1. to reflect the requirements of the temperature at which the weld rod will be maintained.
c.
Per the previous discussion, further action is not neces ary.
Date When Full Compliance Will Be Achieved i
l With regard to the examples cited, full compliance has been achieved at this time.
More specifically, a.
Training sessions were inaugurated on August 15, 1980, and to date-all necessary personnel have been trained; b.
Procedure QAP-3 was revised on August 15, 1980, and c.
Per the previous discussion, full compliance already exists.
7083A
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