ML20027E133

Ack Receipt of IE Bulletin 82-01, Alteration of Radiographs of Welds in Piping Subassemblies. Status of Util Response to Bulletin Requested

ML20027E133
Person / Time
Site:	LaSalle
Issue date:	04/21/1982
From:	Goodie J ILLINOIS, STATE OF
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20027A786	List: IR 05000373/1982021 ML20027A785 ML20027A790 ML20027A792 ML20027A796 ML20027A799 ML20027A808 ML20027A816 ML20027A817 ML20027E079 ML20027E090 ML20027E096 ML20027E102 ML20027E107 ML20027E109 ML20027E110 ML20027E111 ML20027E115 ML20027E127 ML20027E131 ML20027E133 ML20027E141 ML20027E144 ML20027E146 ML20027E150 ML20027E153 ML20027E159
References
FOIA-82-328 IEB-82-01, IEB-82-1, NUDOCS 8211120117
Download: ML20027E133 (1)

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qm TYRONE C. FAHNER ATTORNEY GENERAL STATE OF ILLINOIS TELEPHht 160 NORTH LA 5,ALLE STREET M-3504 CHICAGO 60601 5

Apri1 21, 1982 Mr. C. E.

Norelius, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re:

IE Bulletin 82-01

Dear Mr. Norelius:

Thank you for forwarding IE Bulletin 82-01, entitled h

" Alteration of Radiographs of Welds in Piping Subassemblies,"

issued March 31, 1982.

According to Attachment 1, Table 1, Group 1, LaSalle Units 1 and 2 are sites for which the actions specified on pages 2 and 3 of IE Bulletin 82-01 are required.

Furthermore, those actions are required to be completed " prior to the issuance of an OL or within 90 days of receipt of this bulletin, whichever occurs first."

An operating license was issued to Commonwealth Edison Company for LaSalle Unit 1 on April 17, 1982.

Would you olease rovide this office with a copy.of the documents which_ indicate t_e" stat W of'Edis'od's~re~sponse to IEB 82-01, both curre'ntly and as of April 177 Thank you for you assistance.

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Very truly yours, i

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JU ITH S.

GOODIE i

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' Assistant Attorney General Environmental Control Division 188 W.

Randolph St.,

Suite 2315

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) Oy Nation *1 Pl.ua. Chicago. tilinois jy Ada. s Rzpty tr Post Olhce B:x 767 Chicago, Illinois 60690 April 22, 1982 l

Mr. A. Schwencer, Chief Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

LaSalle County Station Units 1 & 2 Comments and Clarifications on Meeting Transcript, March 31, 1982 NRC Docket Nos. 50-373 and 50-374 Reference (a):

Transcript, United States of America Nuclear Regulatory Commission, Docket Nos. 50-373 and 50-374, Room P-422, 7920 Norfolk Avenue, Bethesda, MD, Wednesday, Ma rc h 31, 198 2.

Dear Mr. Schwencer:

Commonwealth Edison Company has reviewed Reference (a).

This review provided three types of comments:

TYPO:

Misspelling.

CORRECTION:

Wording change to correct the transcript to what was actually said.

CLARIFICATION:

Wording change proposed by CECO to add clarity to what was said.

These comments are contained in Attachment A to this letter.

Commonwealth Edison Company believes that the transcript accurately represents our position on the allegations contained in the petition from the Attorney General of the State of Illinois.

Where clarifications are listed in our comments, they are presented to remove any doubt as to our intent.

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Commonwealth Edison does not intend to update this I

transcript in the future.

It is our intention to provida you with a

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final report in the near future which will summarize the results of our review of damaged rebar due to drilling or cor;ing holes.

By copy of this letter, our comments are being transmitted to the Attorney General of the State of Illinois and to Alderson Reporting.

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d A. Schwencer April 22,1982 If there are any further questions in this rctter, please contact this office.

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Very truly yours, #

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C. W. Schroeder Nuclear Licensing Administrator 1"

i Attachment cc:

Attorney General, State of IL Alderson Reporting l

NRC Resident Inspector - LSC l

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,e ATTACHMENT A

,P_a ge Line Commen t 2

7-L. DelGeorge (Typo)

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13 V. Reklaitis ( Typo) 4 1

6 4

. Lou DelGeorge.

( Typo) 6 21 MR. REKLAITIS:

V. Reklaitis.

( Typ o) 9 3

DelGeorge.

( Typo) 10 9

floor should be roof (Clarification) 10 25 Commonwealth should be County (Correction) 15 18 deficiency should be concern.

The review established that there was no deficiency

( Clari fica tion) 16 13 measured should be mentioned (Correction) 18 25 MR. REKLAITIS:

( Typ o) 19 5

MR. REKLAITIS:

( Typo) 20 11

. Mr. De1 George iTypo) 21 1

line should read " negative moment, bottom reinfor-cino carrying positive moment".

The insertion of reinforcino provides technical accuracy

( Cla ri f Aca tion) 23 17 controlled (Typo) 23 23 line should read " evaluation of all reported" The words " structural -- or" should be removed.

Intent was to say reinforcement (see line 24)

( Clarifica tion) 24 2

repaired should be impaired (Correction) 26 2

both should be those (Correction)

J26 14 ther should be there (Typo) 28 19 fromn should be from (Typo) 30 16 core should be cored (Typo) 30 17 drill should be drilled (Typo) 30 18 core should be cored (Typo)

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Page Line Commen t 30 19 core should be cored (Typo) 30 25 core should be cored (Typo)

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31 2

core should be cored (Typo) 32 8

audited should be routed (Correction) 32 9

auditing should be routing (Correction) 32 14 core hold should be cored hole

( Typ o) 32 24 audit should be routed (correction) 33 24 is should be has (Typo) 34 6

of should be on (Typo) 35 7

. core should be cored (Typo) 36 9

distress should be stress (Correction) reiforcing should be reinforcing ( Typ o) 36 19 reduction should be increase.

In this context, we are increasing the stress levels and/or reducing our acceptable levels.

(Clarification) 37 4

cord should be cored (Typo) 37 22-25 Change to read "could not tolerate any more bars being cut.

That did not occur until the latter stages of drilling operations, pYimarily 1979 through 1981."

( Clarifica tion) 38 1, 2 Omit.

See p. 37 lines 22 through 25 (Clarification) 38 18 tewo should be two (Typo) 38 20 core should be quarter (Correction) 40 14 Add:

MR. LONGLAIS:

Speakers changed at this point (Correction) 41 7,8,9 Change to read " drawings on which we have marked the location of damaged rebar reports s~ubmitted due to the drilling operations and the assumed rebar damage locations due to the coring of mechanical equipment foundation anchor bolts." ( Clari fica tion) 41 16 Change to read " contacted in safety related areas o f Unit 1" (Clarification)

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Page Line Commen t 41 20 Change to read "MR. LONGLAIS:

Yes, that is for Unit 1 safety-related area s"

( ClarificationT 42 11-12 Replace with "recently plotted the core holes associated with the mechanical equipment foundation anchor bolts which are shown on Mechanical Drawings"

( Clarifica tion) 43 3

drill should be drilled (Typo) 44 4

Change to read " span, Yin the top o f two-way slabs, and in the middle span ~(Clarification) 47 5

Change to read "and are in force prior to going into the drilling operations.

During" (Clarification) 48 2

nipped should be nicked (Typo) 48 4

Change 4-A to 3-A (Correction) 48 14 Change to read "towards the latter part of 1977 or the early part" (Clarification) 48 17 Change studying of to starting (Correction) 48 19 poured should be cored (Typo) 53 17,18,19 Change to read "Mr.

Longlais:

To the extent of all reports received."

(Clarification) 53 24 in the house should be in our house ( Typ o) l 53 25 Change to read " submitted to us are nothing more than a copy of previous documents received at Sargent & Lundy; - - we are going" ( Clari fication) 54 4

Change to read "That is the review that is presently taking place.

The" (Clarification) 54 13 Change entire sets of to RHS (Clarification) 54I 16 Add:

Note:

A revised slide will be provided in the i

_ final report from Commonwealth Edison.

1 This is being revised based on the final

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review by Sa rgen t and Lundy.

( Clarification)

SS 20-22 Change to read "Mr.

Longlais:

These are the locations of reinforcing steel damaged due to drilling; these are the locations due to camage due to coring" (Clarification)

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J' Page Line Commen t 56 10 Change 1.33 to 3.33 (Clarification) 57 15 nick should be nicked (Typo) f i

l 60 20-22 Change to read "MR. REKLAITIS:

We had some expansion anchor holes in the containment wall.

There were no core holes through these walls.

They were for"

( Clarifica tion) 61 1

MR. REKLAITIS:

( Typo) 5 MR. REKLAITIS:

( Typo) 6 Change to read "did not compromise the boundary integrity of the containment."

( Clarificatio n) 62 21 phalanges should be flanges (typo) 63 14 that should be there (Typo) 64 3

. ware should be aware (Typo) 64 4

This statement was true at the date of this meeting.

Since then, as a result of this review, it was determined that there were some discrepancies.

Tr.e re f o re, this review and evalustion, though sub-stantially complete, is continuing.

We still are not aware that these reports represent any problems in this matter.

This matter was discussed with NRC personnel during their field review.

(Clarification) 64 14 LSC should be LSC EA (Typo) 68 5

replacemgnt should be displacem'ent (Typo) 68 12 Change tne number to some (Clarification) 69 7

required required should be required (Typo) i 71 20 Change to read "each of the concrete elements.

We have done a selected" (Clarification) 74 l'7-19 Change to read "MR REKLAITIS:

There are two cuts I

that were noted in the off gas building and they were observed, and there are seve; al nicks which are not detrimental.

There were no reported cuts in the roof reinforcing steel ( Clari fica t,io n) t 3822N

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Atttchment C

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GLEN APR 2 7 14:.'

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I Docke(No.50-373 Commonwealth Edison Company ATfN:

Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety inspection conduct d b of this office on March 24 and Apsil 6 y Mr. F. C. Hawkins e

Station, Unit 1, authorized by NRL: Construct on Permit No. CPPR-99 and to th discussion of our findings with Mr of the inspection.

also refers to the continuation of that This report spsetion conducted by Messrs. F. (:.

Chicago, Illinois on April 8, 198?at the LaSalle site on April 7, l'282, an undy Engineers in the inspection.' Within these areasThe enclosed copy of our inspe i/.entifies areas examined during tarviews with personnel.excmination of procedures and rep 2 esentative records, t

, observations, and in-No items of noncompliance with NRL' requirem course of this inspection.

e-ts were identified during the In accordance with 10 CFR 2.790 or this letter and the enclosed insPo the Commi>sion's regulations, a copy of Public Document Room.

ction repo:t will be placed in the NRC's If this rel' ort contairs any information that you (or your contractors) believe to be e.Nempt from iisclosur it is necessary that you (a) notify e under 10 CFR 9.5(a)(4),

days from the date of this letter this off2ce by telephone within ten (10) withholding; and (b) submit within twenty-fise (25) dletter a of your intention to file a request for

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your receipt of this letter has be I

such information.

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available for your review, pleen delayed such that less than seven (7) days

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new due date may be established.

ase notify this office promptly so that a such sppliEation must be accompanied by an a;fidavit exConsistent with Section 2.790 ecuted by the owner of L

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Commonwealth Edison Company 2

APR 2 7 682 theinformationwhichidentificsthedocumentorpartsoughttobe) withheld, and which contains a full statement of the reasons which are the bases for the

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claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the con-siderations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.

If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, C. E. Norelius, Director Division of Engineering and Technical Programs

Enclosure:

Inspection Report g

No. 50-373/82-21(DETP) cc w/ enc 1:

Louis O. De1 George, Director of Nuclear Licensing R. Cosaro, Site Construction Superintendent T. E. Quaka, Quality Assurance Supervisor R. H. Holyoak, Station Superintendent B. B. Stephenson, Project Manaper DMB/ Document Control Desk (RIDS)

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Resident Inspector, RIII Hary Jo Hurray, Office of Assistant Attorney General I

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U.S. NUCLEAR REGUIETORY COMMISSION REGION III J

Repo;rtNo. 50-373/82-21(DETP)

Dockst No. 50-373 License No. CPPR-99 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Station, Unit 1 Inspection At: LsSalle County Station, Unit 1, and Sargent & Lundy Engineers in Chicago, IL Inspection Conducted: March 24 and April 6-8, 1982 a

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wL Inspector:

F. C. Hawkins

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March 24 and April 6-8, 1982 I

3 Accompanying Personnel:

S. P. Chan April 7-8, 1982 I

R. E. Lipinski

~I April 7-8, 1982 W50' Approved By:

C. C. Williams, Chief Y //f h d Plant Systems Section

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Inspection Summary Inspection en March 24 and April 6-8, 1982 (Report No. 50-373/82-21 (DETP))

Areas Inspected: Special joint inspection conducted by IE Region III and NRR in response to alleged indiscriminate concrete drilling /ccring which resulted in damage to embedded reinforcing steel.

This inspection involved a total of 49 inspector-hours by one Region III inspector and two NRR repre-esntatives.

Rasultp: No items of noncompliance or deviations were identified.

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DETAILS Persons Contacted 1

i Commonwealth Edison Company (CECO)

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R. Cosaro, Project Construction Superintendent L. De1 George, Director of Nuclear Licensing 1

W. Carrigan, Supervising Staff Auditor J. Gieseker, Project Construction Engineer J. Harchut, Project Construction Engineer

• M. Morris, Structural Engineer I. Netzel, Quality Engineer T. Quaka, Site Construction QA Manager

• C Schroeder, Nuclear Licensing Administrator D. Shamblin, Staff Assistant Sargent & Lundy Engineers (S&L)

• L. Dolder, QA Coordinator

• S. Kazmi, Supervising Design Engineer

• K. Kostal, Assistant Manager - Structural Department

• T. Longlais, Structural Engineering Department Head

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• V. Reklaitis, Structural Project Engineer Valsh Construction Company M. Dougherty, QA Manager Other personnel were contacted as a matter of routine during this inspection.

• Denotes those attending the exit interview on April 8, 1982.

Functional Areas Inspected This inspection was conducted in response to alleged indiscriminate concrete drilling / coring which resulted in damage to embedded reinforcing steel.

In-formation of the specific concerns were transmitted to the NRC by the Attorney General of Illinois in the form of a 10 CFR 2.206 request.

This report addresses only the contention regarding damage to reinforcing steel during drilling / coring activities.

The scope of the inspection was twofold:

Phase I, which was conducted at the LaSalle site by Region III, investigated the programmatic approach to assure control of dri]Iing/ coring activities.

Specifically, Phase I consisted of review of procedures, interviews with cognizant personnel, and review of quality records.

Phase II, of the inspection was conducted at S&L by Region III and NRR repre-sentatives.

The expressed purpose of the S&L assessment was to verify proper and complete engineering disposition of field supplied data pertaining to damaged reinforcing steel.

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Phase I The scope of work for three site contractors *was evaluated:

H. P. Foley Co., Commercial Concrete Drilling and Sawing Co.'(a Foley subcontractor),

and Commonwealth Electric Co.

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jThe contractual relationship between Foley and Commercial Concrete was

} reviewed. Commercial Concrete acted as the drilling / coring subcontractor

'to Foley for the period December 1977 through December.1979. During this period Commercial Concrete used the Foley procedures and the, applicable S&L Specification to accomplish all drilling / coring work. For that reason, the programmatic appraisal of both companies was based on the review of the H. P. Foley drilling / coring program.

Additionally, the examination indicated that Commonwealth Electric was responsible for installation of temporary lighting and had commenced drilling activities on March 7, 1980. The review indicated that Commonwealth Electric had exclusively used carbide-tipped drill bits for the work.

Past experience has shown that carbide-tipped drill bits are i

not capable of inflicting damage to reinforcing steel.

Consequently, work performed by Commonwealth. Electric is not considered relevant and was not included as pdrt of this inspection.

1.

Drilled Holes Typically, drilled holes are provided for the installation of.

concrete expansion anchors which vary from 1/4" to 1" in diameter.

The corresponding' depth for holes of this size varies from 1-1/4" to 8",

respectively. Drilled holes penetrate only partially into the concrete section.

To facilitate evaluation of the Foley drilling program, S&L

" Standard Specification for Concrete Expansion Anchor Work" (Form LS-CEA) and H. P. Foley " Concrete Expansion Anchor Instal-lation" procedure (No. WI-601) were reviewed. Each revision to j

both documents contained provisions to control drilling activities j

and identify reinforcing steel whi:h may have been damaged during work operations.

It is our assessment that the extent of control for drilling / coring work was commensurate with the level of activity in progress at all times during construction. The following revisions to each document were reviewed:

W1-601 Form LS-CEA I

Revision 0, December 7, 1976 Revision 0, September 30, 1976 I

Revision 1, November 21, 1977 Revision 1, December 7, 1976

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Revision 2, January 31, 1978 Revision 2, November 29, 1978 Revision 3, May 8, 1979 Revision 3, July 20, 1979 Revision 4, October 23, 1979 Revision 4, September 7~,

1979 Revision 5, August 6, 1981 Revision 5, December 10', 1979 l

Revision 6, February 13, 1980 I

Revision 7, October 27, 1980 Revision 8, May 13, 1981 3

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F'oley Procedure No. WI-601 includes a daily report work form (No. HPFCo-016) on which any reinforcing steel which is damaged du.-ing drilling is reported. Following' completion of form HPFCo-016, WI-601 requires thct the form be forwarded to S&L for engineering review. This is the mechanism through which the necessary engineering assessment is accomplished for each* piece i

f of reinforcing steel which is damaged during concrete anchor in-stallation. The specifics of any drilling damage to reinforcing steel is tabulated and plotted by S&L on Reinforcing Hit Schedule (RHS) drawings.

Approximately 200 of the Foley daily reports (No. HPFCo-016) were reviewed.

Each wac properly completed and in cases where reinfore-ing steel damage had occurred, pre-er notation of the damaged area was made on the form by the driller. Transmittal records of the forms to S&L for engineering evaluation were also verified.

2.

Cored Holes Cored holes typically range in size from 3" to 12" in diameter.

In this application, cored holes pass completely through the concrete section.to allow the passage of an electrical component (e.g., conduit). The routing of cored holes for electrical com-ponents is determined during the initial design phase (office routed) or in the field by the electrical contractor (field routed).

Office routed cores are designated on the structural design drawings and an engineering assessment is made of the effects of reinforcing steel likely to be damaged during the coring opera-This is accomplished prior to the release of the drawings tion.

for construction purposes. Field routed cores are requested by the contractor via a Field Change Request (FCR). The FCR is i

submitted to S&L prior to the coring operation. Approval of both the field routed core and the office routed core is based on an engineering evaluation by S&L. The core locations are indicated on the structural design drawings.

It is important to note that both office and field routed cores are approved by the designer prior to the commencement of any coring operations.

3.

Audit / Surveillance Activities Three CECO audits of H. P. Foley concrete expansion anchor activi-

- I ties were reviewed. The audit numbers were 1-79-72, 1-80-22, and 1-80-45.

The results of CECO surveillance inspection Nos.79-237, 79-462,79-571, 81-597, and 82-167 were also reviewed. Each audit and surveillance inspection was well planned, the findings well I

supported, and the resulting corrective actions appropr, late.

In addition, a summary of Foley internal audit report N'os.

1 through 5 were reviewed. The summary indicated that the audits were conducted systematically and the findings were of substance.

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Training

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Records of twelve Foley training sessions on concrete anchor in-stallation procedure No. P.PFCo-WI-601 were reviewed. Each package consisted of a lessen plan and list of attendees. The training sessions were conducted in a timely fashion by qualified,

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individuals.

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Personnel Interviews Interviews with H. P. Foley and CECO personnel were conducted to assess their knowledge of the Foley drilling / coring program and discuss any specific problems which they may have encountered during its implementation. The selected personnel were chosen because of their knowledge of past as well as present drilling /

coring practices and policies.

Interviews were held with the following personnel:

Foley Labor Superintendent Foley Labor General Foreman Three Foley Concrete Drillers Foley Quality Assurance Manager CECO Quality Assurance Manager CECO Quality Engineer r

Each individual categorically stated that, in his opinion con-crete drilling / coring by H. P. Foley and Commercial Concrete Companies had and is presently progressing in an orderly and well controlled manner.

Each individual,was knowledgeable within the scope of his assigned responsibilities.-

B.

Phase II The documentation of the NRR assessment of S&L on April 8, 1982, is forthcoming and that report will be issued through their office upon its completion.

C.

Conclusion r

Based on the results of our review, we have concluded that (1) adequate procedures to control concrete drilling / coring are and have been in place at LaSalle; (2) these procedures are being successfully implemented; (3) l the engineering disposition of damaged reinforcing steel by S&L was proper and complete; and (4) the completed drilling / coring represents no

compromise to the structural-integrity of the LaSalle plant structures.

i This issue is considered closed.

E Extt Interview t

The Region III inspector and NRR representatives met with licensee repre-i septatives during the conclusion of the inspection on April 8,1982. The scape and conclusions of the inspection were summarized during the exit ingerview.

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