ML20070N041
| ML20070N041 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/17/1983 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| REF-PT21-83-756-000 10CFR-50.55E, 1605-L, 1605-L3, PT21-83-756, PT21-83-756-000, U-10023, NUDOCS 8301250405 | |
| Download: ML20070N041 (4) | |
Text
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1605-L ILLIN018 POWER COMPANY U-10023 i
CLINTON POWER STATION, P.O. BOX 678. CLINTON. ILLINOIS 61727 I
January 17, 1983 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Potential Deficiency 82-11 10 CFR50. 55 (e)
Incorrect Identification of Base Material and Weld Procedures on Piping Hanger Travelers
Dear Mr. Keppler,
't On October 20, 1982, Illinois Power Company notified Mr. F.
Jablonski, NRC Region III, (Ref:
IP memorandum Y-13999, 1605-L, dated October 20, 1982) of a potential reportable deficiency per 10CFR50.55(e) concerning the incorrect identification of base materi-al and improper weld procedures on piping hanger travelers.
This notification was followed by one (1) interim report (IP letter D.P.
Hall to J.G. Keppler U-10010, 1605-L, dated November 19, 1982).
Our 3
investigation into this matter is not complete, and this letter represents an interim report per 10CFR50.55 (e)(3).
i STATEMENT OF POTENTIAL REPORTABLE DEFICIENCY During final review of piping hanger installation travelers, it' was discovered that incorrect identification of base materials and improper weld procedures were identified on piping hanger travelers.
This condition could potentially allow for incorrect welding and-i I
improper documentation of piping hanger installation.
Although investigation completed thus far has not revealed defective weldments due to this potential deficiency, further investigation is necessary to detennine the scope and significance of this concern.
INVESTIGATION RESULTS/ BACKGROUND During a Baldwin Associates (IP Contractor) Technical Services Department final review of piping hanger installation. travelers, it was realized that the wrong embed plate base material and welding procedure for welds between embed plates and piping hangers were identified on the documents.
This error was initially identified on approximately sixty-seven (67) piping hanger installation travelers 8301250405 830117 PDR ADOCK 05000461 JAN 201983 S
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Mr.1 J.G. Keppler NRC and resulted in the issuance of a Nonconformance Report (NCR-7725).
Upon further investigation by Baldwin Associates,.it was determined that approximately 1300-1400 travelers have the same problem, but have undergone final review and were transmitted to the records vault.
As a result of NCR-7725, the Baldwin Associates (BA) Quality Assurance Department issued a Corrective Action Request (CAR-105) which addressed improper traveler initiation by BA Engineering and improper traveler initial review by BA Technical Services on an undetermined number of piping travelers.
.Upon investigation by Illinois Power into the problems iden-tified by NCR-7725 and CAR-105, the following information was ob-i tained:
1.
Sargent & Lundy (CPS Architect-Engineer)-design drawing S21-1001 allows the use of both ASTM A-36 and ASTM A-572 l
Grade 50 as embed plate material.
2.
During pipe hanger traveler initiation, the BA Piping Department did not realize that an alternate type of material was allowed for embed plates.
It was erroneously assumed that all embed plate material was ASTM A-36, j
subsequently, pipe hanger travelers were prepared identify-ing the embed base material as ASTM A-36.
In reality, both i
ASTM A-36 and ASTM A-572 Grade 50 material were used for embed plates.
3.
The initial pipe hanger traveler review by BA Technical Services assigns a weld procedure to the traveler, based on the base materials identified on the document by the BA Piping Department.
There fore, if erroneous base material information is identified on travelers, the possibility of identifying an incorrect welding procedure exists.
4 4.
The weld procedure for welding ASME SA-36 (pipe hanger material) to ASTM A-36 embed material is designated as l
N-1-1-A-lM.
The weld procedure for welding ASME SA-36 l
(pipe hanger material) to ASTM A-572 Grade 50 embed L
material is designated as N-ASTM-A-SP.
As ASTM A-36 embed l
base material was identified on the travelers, weld proce-dure N-1-1-A-1M was subsequently identified on the travel-ers by BA Technical Services.
However, depending on actual embed material used, either procedure could be correct.
It should be noted that these two welding procedures both utilize the same filler material and the same essential l
variables, therefore, the welds are acceptable even though l
an incorrect weld procedure was specified.
l l
5.
The welders used to perform the welds in question were qualified to both procedures.
6.
A review of traveler programs in the electrical, instrumen-l ta tion, mechanical equipment, and HVAC disciplines for i
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Mr.' J.G. Keppler ~
NRC weldments to embeds disclosed no welding procedure errors such as those identified above.
7.
Investigation revealed that an ASME Code Case, N-71-10, approved for Clinton Power Station through FSAR commitments to Regulatory Guide 1.85, states that an ASME weld proce-dure qualification (such as N-1-1-A-1M) with a base metal in one P-number and Group number (for A-36, P=1) qualifies for all other base metals in the same S-number and Group number (for A-572 Grade 50, S=1).
Illinois Power's investigation of this concern continues and involves reviewing additional pipe hanger travelers to determine if similar problems exist in weldments to base materials other than embeds, such as structural steel.
This review has thus far iden-tified two (2) additional cases where incorrect base materials were identified on pipe hanger travelers.
These cases involve weldments to structural steel (ASTM-A588 Grade 50) as documented on Deviation Report 3896 and to tube steel (ASTM-A500 Grade B) as documented on Deviation Report 3895.
In both these cases, ASTM A-36 material was identified as the base metal, which resulted in the incorrect weld procedure, N-1-1-A-1M, being identified on the traveler.
The correct weld procedure for these cases is designated as N-ASTM-A-SP.
It should be noted that these two welding procedures utilize the same filler material and the same essential variables, therefore the welds are acceptable even though an incorrect weld procedure was specified.
CORRECTIVE ACTION (INTERIM)
Although investigation of this potential deficiency is still in progress, several actions are planned to correct the problem and to prevent recurrence:
1.
BA Piping Department has conducted department training relevant to traveler initiation and the importance of supplying correct material identification information on work related documents.
This training was completed on December 12, 1982, 2.
BA Piping Department will indicate, on piping travelers in which welds to embeds have not been started, that embed l
base materials are either A-36 or A-572 Grade 50, and that the applicable weld procedure is either M-1-1-A-1M or N-ASTM-A-SP, to show that alternate materials and weld
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procedures exist.
For those travelers where welding to embeds has been started or is completed, a copy of NCR-7725 will be included to correct the documents.
Concurrent with l
this effort, a review of the travelers will be made to verify correct identity of other base materials, such as ASTM-A500 and ASTM-A588, and travelers will be corrected and documented as necessary.
This effort involves approximately 1350 travelers where welding has not yet started, and approximately 4950 travelers where welding has
Mr'. J.G. Keppler
- NRC been started or is complete.
Due to the large number of travelers involved, this review will be complete approximately three (3) months from this reporting date.
3.
On December 12, 1982, Sargent & Lundy (CPS Architect Engineer) accepted the recommendation on NCR-7725 to accept the welds as-is.
The Piping Specification, K-2882, is presently being amended to allow the use of Code Case N-71-10, and should be completed by February 19, 1983.
SAFETY IMPLICATIONS / SIGNIFICANCE At this time, although documentation errors have been identified, it has been determined that associated weldments are acceptable.
There fore, this potential deficiency has not yet resulted in an adverse impact on the safety of operations of CPS.
However, further traveler review is necessary to assure that a significant deficiency has not occurred.
It is anticipated that approximately ninety (90) days will be necessary to complete the investigation and to file a final report on the subject.
Ue trust that this interin report provides you sufficient background information to perform a general assessment of this potential reportable deficiency and overall approach to resolution of the problem.
Verv truly yours, Hall Vice President l
l cc:
Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety NRC Resident Inspector l
Manager-Quality Assurance 1
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