ML20063K978

Interim Deficiency Rept Re Zack Co Discrepant Shop Welding Records on safety-related HVAC Duct Work & Hangers.Initially Reported on 820801.CF Braun Co Conducting Review Per Amend 4 to License NPF-11.Also Reported Per Part 21

ML20063K978
Person / Time
Site:	LaSalle
Issue date:	08/31/1982
From:	Schroeder C COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
REF-PT21-82 10CFR-050.55E, 10CFR-50.55E, 4916N, 82-07, 82-7, NUDOCS 8209080572
Download: ML20063K978 (3)

Text

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'i. ~ Conunonwealth Edison . .

C > I one First Nitionsi Plaza, Chicago. Ilhnois a

.g' g O' Address Riply to: Post Office Box 767  ;

Chicago, lilinois 60690  :

Augus t 31, 1982

Mr. James: G. ,Keppler, Regional Administrator Directorate of Inspection and-  !

i- Enforcement - Region III U.S. Nuclear ' Regulatory Commission 799 Roosevelt Road i Glen Ellyn,_ IL 60137- l' i

Subject:

' LaSalle County Station Units 1 and 2  !

Zack Company Weld Records l

- 10 CFR 50.55(e) Interim Report 82-07

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NRC Docke t No's'.' 50-373 ' an d 50-374 l

{ References (a): C. W. Schroeder letter to A. 'Schwencer  !

dated August 11, 1982, "Do cumenta tion  !

I of HVAC Information Presented During  !

Meetings o f August 2-4, 1982."  :

(b): License NPF-ll, Amendment 4 dated August 13, 1982, Condition 2.C. (33) . (b) .

4

Dear Mr. Keppler:

1 The purpose of this letter is to provide an interim report

[ on Zack' Company Weld Records in accordance with the provisions of 10 CFR 50.55(e).

A Description of Deficiency a

The Nuclear Regulatory Commission was notified by Commonwealth Edison Company on August 1,.1982, o f a possible -discrepancy -between i

the shop ' welder of record and the shop welder who .may have actually i

I performed the welding;on certain' safety-related HVAC ductwork and hangers. This ' notification was made af ter the Zack Company advised '

Commonwealth Edison Compan'y (CECO) on July 29, 1982 of their intent

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to report a Part 21 on .this subject.- During the July 30, 1982 to Augtst 2, -1982 period, CECO Quality. Assurance ~ Department with assis-

! tance from Sargent -& Lundy Engineers, confirmed discrepancies exist in the documentation records of the shop . welder of -record on certain

-Unit #1 - and #2 sa fety-related HVAC ductwork.and hangers. The review results indicated certain shop-. welding may have.been done by unqualified welders. The results of this review are documented as ipart of Reference -(a) .

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~ Corrective ~ Action Th'e approach toL resolving the problem is to:- ;l) Substantiate the discrepant, shop welding records by additional auxiliary' records

.(1.e. -payroll,1 shipping notices, e tc. ); 2) To inspect in the field, o

the shop. welds done by apparent unqualified welders, or;' 3) To confirm the existing shop weld _ quality and strength by destr tive testing. Additionally, .an independent review is being cond ted by

,C. F. Braun Company in^.accordance with the ' requirements'of e ference

'(b) . _ The results' of this review will be utilized in the resohtlon tof this issue.

gg P O -[ SII Q[g

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r J. G. Keppler Augus t 31, 1982 The status of the proposed resolution to date is as follows:

l. Discrepant shop welding records have been segregated into those applicable to Unit #1 and those not applicable to Unit #1. Shop welding records which may indicate unquali-L fled welders have been identified for those applicable to

Unit #1. This task remains to be completed for those records not applicable to Unit #1.

2. A sample review has been completed of other similar shop welding records which were thought by the Zack Company not

, to contain discrepancies. The sample review revealed no l ,

instances of documentation discrepancies.

l

.3. A certain number of the shop welding records applicable to Unit #1 involve HVAC hangers. As a result of previous stop work actions at the LaSalle County Site, the possibility

, existed that the questionable hanger and shop welds may

have been reinspected and repaired in the field. Records

. indicated that all questionable HVAC shop hanger welds had i been reinspected by Zack Q.C. in the field and a certain portion had been independently inspected by ConAm Inspec-tion. Additional surveillances recently conducted by CECO L Quality Assurance and ConAm reverified the above weld inspections as acceptable. Thus, even if the above HVAC

shop hanger welds were made by unqualified welders, they had been inspected una deemed acceptable.

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4. The balance of the shop welding records applicable to Unit

1. 1 involve HVAC duct pieces. A visual inspection o f 69 duct pieces (2270 welds) showed approximately 7.4% of the shop welds did not meet procedure visual acceptance criteria. Af ter evaluation by Sargent' & Lundy Engineers, a number of the visually rejected shop welds were repaired.

Also, the installed condition of remaining accessible duct-work from the suspect welding records have .been forwarded to Sargent & Lundy for evaluation.

5. Samples of visually rejected duct shop welds have been destructively-tested. Preliminary results indicate. that in no cases'did the visually rejected shop welds fail. In all cases the sheet metal ~ or angle stif fening f ailed. A report is_being prepared which will finalize testing results. Onc e the final testing results are evaluated and conclusions

' drawn, a decision will be made whether to conduct = further

[> visual inspections on HVAC duct shop welding.

_ The primary effort- to date has been to technically show i that the discrepant welding records do not affect the Unit #1. Thus very little ~ resolution work _ has been completed on Unit #2. This is 3 the main reason the final report will be delayed. A ' secondary f reason is part of the finalL resolution involves. the completion of C.

I, F. Braun's independent investigation o f HVAC ' work.

I L

e J. G. Keppler Augus t 31, 1982 All Unit #1 corrective action will be completed commensu-rate with any necessary corrective actions resulting from the C. F.

Braun's independent review in accordance with Reference (b) . Unit

1. 2 corrective actions will be completed by fuel load. A final report should be submitted by December 31, 1982.

If there are any questions in this matter, please contact this office.

Very truly yours,

^

-#  % 6/3//gt C. W. Schroeder Nuclear Licensing Administrator 1m cc: Director of Inspection and Enforcement Washington, D.C.

Mr. Tom Novak, NRR NRR Resident Inspector - LSCS 4916N l

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