ML20037A991
| ML20037A991 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/21/1972 |
| From: | Brian Lee COMMONWEALTH EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20037A990 | List: |
| References | |
| NUDOCS 8008270811 | |
| Download: ML20037A991 (4) | |
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ILLINOIS Adhean Gene, k P O S T O P P I C E, S O E 167
- C H I C A G O. IL&lNOIS 60690 November 21, 1972 4
1 r. Doyce H. Grier, Regional Director Directorate of Regulatory Operations -
Region III-U.S. Atomic Energy commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Daar Mr. Crior:
This letter is in response to your letter of Octob:r 19, 1972 reporting the inspection of activities at Dresdc 1 1 by rescrs. Maura, Fisher and Fishbaugher.
These activities are authoriced by A2C Operating License No. DPR-2.
The activities which appeared to be in nonconformance with cartain codes and standards were reviewed with responsible personnel and we have the following comments:
1.
We assume that your letter had reference to the installation phase of construction with the statement that "neasures were not established to prevent cables from nonconforming installation".
It has been determincd that design and instruc-tiens for installation of electrical and control cables had been correctly established to meet IEEE Standard 279 criteria.
Installation was incorrectly carried out and inspection and audit had not detected this nonconformance prior to the Region III Inspection.
This con-dition has been corrected.
It is expected that this item would have been detected in Einal inspection prior to preoperational testing and placing the system in service.
The Commonwealth Edison Substation Construction Department, who was responsibic for this work, has been made aware' of your findings and agree that an error 5 72 s0008370
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tommonwealth Edison Company Mr. Boyce H. Grier November 21, 1972 was involved.
Additional instruction of personnel in the use of the manual and applicable procedures, which are considered adequate, has been carried out to preclude recurrence.
2.
Pipe hangers for the core. spray system were covered by approved Architect-Engineer drawings.
Field revisions to these approved drawings were made and reviewed with the Architect-Engineer.
Telephone approval was obtained but not docu-mented.
Subsequent to the Region III inspection, a final review of the installation was made and a letter from the Architect-Engineer is in Site files' covering the analysis and indicating the acceptunce of ths installation.
This letter was on file during your September inspection.
The' as-built drawings cre being finalized.
3.
Documentation of valve wall thickness measure-nents is not a Codo requirement nor is it r2 quired by specification covering core spray installation.
Houover, the site received documentation from the vendor for cast valves for this installation prior to the last inspection.
It is on file at the site.
The information can be checked during your next inspection.
4.
There was no evidence rit the Site to indicate approval of the liquid penetrant inspection procedure in use by the inspection agency.
Following the February, 1972 inspection, documentation of proccCure approval was sub-mitted and is on file at the site.
Additionally, the personnel qualifientions were reviewed and found to be in order.
5.
The lack of qualification of welders in accordance with the Site Piping Contractor's approval procedure has been corrected.
Special tests l
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Mr. Boyce H. Grier November 21, 1972 including radiography of completed welds were conducted to comply with paragraph 1-736.5.1 of USAS B31.7.
These records are on Site and can-be reviewed during the next inspection.
t 6.
The site Piping Contractor did have documented evidence that fit-up had been inspected and
- approved.
The inspection sheet did not include specific fit-up elements that were checked.
However, this should not detract from the fact that a visual inspection was carried out and documented.
We do not believe that USAS B31.7, Paragraph 1-736.5.1 requires every element checked to be documented.
7.
Paragraph 1-731.22 of USAS B31.1 is addressed to preheat and not interpass temperature.
Preheat of the stainless steel welds was not allowed by the approved welding procedure.
Although interpass temperature control was monitored, it was not documented because the applicable Standard and Contractor procedure did not require this to be done.
8.
Because of the small nanber of welders (four) enployed for this job, the Contractor considered the control by the foreman to be adequate.
The foreman had sole control of issuing welding electrodes.
Although there was no evidence of iaproper electrode usage, a procedure was developed and written to document the method of control.
This procedure was implemented shortly after the February inspection and a copy is on file at the Site.
9.
No vald repairs were made on stainless steel welds.
Consequently, no weld repair procedure was available for stainless steel welds during the February inspection..Nevertheless, a repair procedure was developed and written for stain-less stcol welds following the Fchruary inspection.
J This document is on file at the Site.
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Mr. Boyce H. Grier November 21, IN72 t
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.x A meeting was held with Site Contractor, Edison
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3 Engineering, and Edison Quality Acsurance personnel to review
,G1 areas of deficiency and the need to upgrade the Site N
quality assurance effort.
He believe that this, action
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resulted in a better understanding of what is expected and
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needed for the core spray installation a.t Dresden.
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,;i Very truly vours, s'
von Gw 1
Assistanttothe) President 3yron Lee, Jr.
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