ML20081B182
| ML20081B182 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/24/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20081B172 | List: |
| References | |
| CSC-6764, NUDOCS 8310270352 | |
| Download: ML20081B182 (15) | |
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General offices: 212 West eA6chigan A enue, Jackson. MI 40201 e (617) 788-0660 June 24, 1983 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER DOCKET NO 50-329 AND 50-330 - MIDLAND PROJECT RESPONSE TO NRC, REGION III LETTER DATED May 23, 1983 File:
0.4.2 UFI:
70*01 Serial: CSC-6764 0485.16 42*05*22*04
REFERENCES:
'(1) J G Keppler letter to J W Cook, dated hay 23, 1983 (2) J G Keppler letter to J D Selby dated February 8, 1983; Notice of Violation EA 83-3 This letter, including Attachment 1, provides our response to Reference 1, which requested additional information on our earlier response to Reference 2.
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i JWC/ BHP /1rb cc: RFWarnick, NRC Region III JJHarrison, NRC Region III RNGardner, hTC Region III
- MCook, NRC Senior Resident Inspector, Midland Site a
RBLandsman, NRC Region III RLBurgess, NRC Resident Inspector, Midicud Site g%hk oc0683-4071a-66-165 8310270352 831021 PDR ADOCK 05000329 0
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OL/0M SERVICE LIST Mr-Charles Bechhoefer, Esq Mr Frank J Kelley, Esq Administrative Judge Attorney General of the Atomic Safety & Licensing Board Panel State of Michigan U S Nuclear Regulatory Commission Mr Stewart H Freeman, Esq
~ Washington, DC 20555 Assistant Attorney General Environmental Protection Div 720 Law Building Lansing, MI 48913 Dr Frederick P Cowan Mr Myron M Cherry, Esq Administrative Judge Cherry & Flynn
~
6152 N Verde Trail 3 First National Plaza Apt B-125 Suite 3700 Boca Raton, FL 33433 Chicago, IL 60602
'Mr Michael Miller, Esq Mr Wendc11 H Marshall Isham, Lincoln & Beale RFD 10 3 First National Plaza Midland, MI 48640 Suite 5200 Chicago, IL 60602 Mr'D F Judd, Sr Project Manager Mr John Demeester The Babcock & Wilcox Company Dow Chemical Building
.P O Box 1260 Michigan Division Lynchburg, VA 24505 Midland, MI 48640 Atomic Safety & Licensing Board Panel Ms Mary Sinclair U S Nuclear Regulatory Commission 5711 Summerset Street Washington, DC 20555 Midland, MI 48640 Atomic Safety & Licensing Appeal Board Mr Steve Gadler U S Nuclear Regulatory Commission 2120 Carter Avenue Washington, DC 20555 St Paul, MN 55108 Mr William D Paton, Esq Mr Lee L Bishop Counsel for NRC Staff Harmon & Weiss i
U S Nuclear Regulatory Commission 1725 I Street, NW #506 Washington, DC 20555 Washington, DC 20006 Ms Barbara Stamiris Mr C R Stephens 5795 North River Road Docketing and Service Station Route 3 Office of the Secretary Freeland, MI 48623 U S Nuclear Regulatory Washington, DC 20555
'Dr Jerry Harbour U S Nuclear Regulatory Commission Atomic Safety & Licensing Board Panel Washington, DC 20555 i
oc0683-4071a-66-165
Attachraent l' Response to J G Keppler letter to J W Cook dated May 23, 1983 The response to J G Keppler letter to J W Cook dated May 23, 1983 is submitted in the following format:
NOV Item B Identification Number
-A.
- Statement of Original Violation (from J G Keppler letter to J D Selby dated February 8,.1983: Notice of Violation EA 83-3.)
B.
-Request For Additional Information (from J G Keppler letter to J W Cock
. dated May 23, 1983.)
C.
Statement of Additional Information l
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l NOV Item B - 1.a (82-22-02A)
A.
Statement of Original Violation
" Installation of diesel generator engine control panels 1C111, 1C112, 2C111, and 2C112 was not in accordance with the requirements delineated on foundation Drawing 7220-M18-250 in that the foundation bolt washers required by the subject drawing were not installed."
B.
-Request For Ad_ditional Information "Regarding Item 3.1.a, your response to this item and subsequent items does not address the measures you have taken or plan to take to provide training'to craft personnel and engineering personnel to ensure that quality requirements will be recognized and complied with during future installation / construction activities. A revised respqnse addressing this training is necessary."
C.
Statement of Additional Information The construction training procedure (FPG-2.000, Rev 3 approved May 11, 1983 and subsequently Rev 4 approved June 20, 1983) has been revised to establish a program which assures that Construction personnel working on the Midland Project receive appropriate training necessary for the execution of the Construction Completion (COP) Activities such as status assessment and installation work activities.
The procedure sets down specific requirements for type of training and' subject matter for each organization element. The training requirements by type and subj?ct are defined in a matrix for each organization, management and staff level including craftpersons. The training matrix l
has been approved by Consumers Power Company.
[
fne team training matrix includes the major elements described below:
(
1.
General training will be provided in A.
Quality requirements for nuclear work i
B.
Requirements of the CCP C.
Safety orientation D.
Inspection and work procedures Formal training in Items (A) through (C) and selected parts of (D) will be i
conducted, and will be given to all personnel including the craftpersons.
miO68J-4071a-66-163
NOV Item B - 1.a (82-22-02A) Continued In. addition, a " tool box" training session will be conducted at least monthly for the craftpersons by the foreman. The subject matter will be developed by the training coordinator, and will include information regarding quality issues across the job.
2.
Training in the procedures used to govern the performance of work will be ccaducted for designated field engineering, support personnel and craft personnel as defined in the training matrices.
Formal training will be cenducted for identified procedures that define the control of designated work processes, procedures for control of special processes and requirements for inspection and acceptance of completed work.
Formal training includes classroom or field demonstration / discussion sessions.
Required training in all applicable procedures will bo completed prior to start of "Q" work for each specific work activity.
miO683-4071a-66-163
-NOV Item B - 2.a (82-22-08)
A.
Statement of Original Violation
" Measures were not established for the selection and review for suitability of application of "Q" materials associated with the diesel generator exhaust muffler in thau design drawings and specifications did not indicate the material identity of the installed muffler saddle supports and plates."
B.
Request For Additional Information "Regarding Item B.2.a, we reiterate our position that the lack of design documentation which specified the material requirements for the diesel
. generator exhauct mufflers constituted an item of noncompliance.
Please provide any additional information supplied by the vendor regarding the traceability of the exhaust muffler materials, and as appropriate, your corrective actions and the results achieved, corrective actions taken to avoid futher noncompliance, and the date when full compliance will be achieved."
C.
Statement of Additional Information New information has just been received from the vendor and is being evaluated. We expect that an trended response will be submitted by July 8, 1983.
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)
NOV Item B - 2.c (82-22-15C)
A.
Statement of Original Violation
" Design Drawings C-1004 and C-147 did not specify the sizes of the diesel generator building HVAC fan gusset plates. A " combo" shop work order request was used to design the gusset plates without appropriate review and approval.
B.
Request for Additional Information "Regarding Item B.2.c, your response does not address any revision to the onsite practice of utilizing unapproved, unreviewed field sketches or shop work orders to perform design activit;es. Please provide an additional response addressing this concern."
C.
Statement of Additional Information FIG-1.600 Rev 3, l Preparation of Shop Work Request Form, allowed the use of
" free hand" sketches for the craft in the combination shop for clarification purposes only" as long as the sketch portrays only "information already given in the design documents." FCR C-5174 was issued and approved to clarify the design drawing criteria to be utilized for detailing bracing connections.
Subscquently, FIG-1.600 Rev 4 was processed as part of the overall CCP procedure review process, and approved on April 19, 1983. Revision 4 eliminates the use of the above mentioned free hand sketches and now requires the use of reviewed and approved field sketches.
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NOV Item B - 4.a (82-22-25)
A.
Statement of Original Violation "An inspection program was not established to ensure segregation of cables instelled in horizontal trays which used metal dividers to segregate control and instrumentation cables in accordance with design requirements."
B.
Request for Additional Information "Your response is incomplete in that the corrective action delineated in your response does not include the establishments of an inspection program to ensure required segregation during future cable installations. Please provide an additional response addressing this concern."
C.
Statement of Add _itional Information Quality Control Inspection Plan PQCI 7220-E-4.0, Rev 13 and Change Notice AA 5042 currently crtablishes the control necessary to ensure required segregation during future cable installation. These controls are noted in activity 2.10 for correct installation and activity 3.2 for tie downs in horizontal tray sections.
Activity 2.10 states, as follows:
" Verify that the cable is correctly installed in the identified vias as specified on the cable pull card by highlighting those vias which are complete."
This activity is identified as a Witness Point and an Inspect and Measure item. This requires that an inspector be present during the execution of the work and that he perform a visual examination and measurement to verify the conformance of the work operation to predetermined qua'ity requirements.
The following exclusions on raceway and pull cards are authorized by Project Engineering Specifications and Drawings as follows:
a.
Conduits shown terminating to a tray section can be installed a maximum of 18 inches into the adjoining tray section without requiring revision to the cabic routing as it appears in the circuit schedule (Drawing E-37) or raceway schedule (Drawing E-36).
b.
A cable can be installed a maximum of 18 inches into the adjoining tray section, without requiring revision to the cable routing as it appears in the circuit schedule (Drawing E-37).
Construction is to furnish a FCN if a section change affects cable routing.
miO633-4071a-66-163
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1 NOV Item B'- 4.a (82-22-25) Continued Activity 3.2 states, asufollows:
" Verify that cables are tied down in horizontal tray, sections at each horizontal change of direction, within two rungs in each dire.ction and in accordance with FPE-4.000(Q) Rev 7 dated 3/18/83."
1This activity is an Inspect and Measure Item. This requires the inspector
~
to perform a visual examination and measurement to verify-the conformance of tho work operation to predetermined quality requirements.
This PQCI will be used for the installation of Class "1E" cables,'and will be further assured by means of the Construction Work Plans which will include the required inspection points (MPQAD Procedere T-3).
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NOV Item B - 6.
(82-22-13)
A.
Statement of Original Violation
. During welding of the diesel generator building exhaust piping hanger support steel, the licensee did not verify preheat of existing safety-related structural steel at a temperature of 70 F as required by site specifications and the AWS 1974 Code."
B.
Request for Additional Information "Regarding Item B.6, it is our position that a 100% preheat verification be accomplished for preheats of all welds made between 32 and 70 until such time as you establish confidence in the welders' compliance with preheat requirements.
In addition, we request that you supply this office with the written evaluation of all welds for which preheat verifications were not previously identified.
Please provide an additional response addressing this concern."
C.
Statement of Additional Information (1) PQCI's that address welding inspection are being revised to include hold points to witness welders performing preheat checks for preheats between 32* and 70 F (using calibrated thermometers) 100% of the time until MPQAD is confident that welders are complying with preheat verification requirements. Thereafter, MPQAD will witness the preheat checks (done by welders) on a sampling basis.
The PQCI's involved will be revised prior to performance of related work and are forecast for completion by July 15, 1983.
(2) Preheat is covered by Bechtel specifications and welding procedures which are in accordance with the applicable code requirements and satisfy the project engineering technical requirements. One hundred percent in process inspection for preheat verification between 32 and 70 F was not performed previously based on the following:
1.
ANSI N45.2.5-1974, Section 5.5 r-fers to AWS D1.1 1972/74, Section 6, for inspection of structural steel welding.
2.
AWS D1.1, Section 6.5.4 states:
"The inspector shall at suitable intervals, observe the technique and performance of each welder, welding operator, and tacker to make certain that the applicable requirements of Section 4 are met."
Section 4 of AWS D1.1 contains the requirements to perform welding including the requirements for preheat.
The key words are " suitable intervals" and " observe".
This wording is what Engineering has based their requirements on.
miO683-4071a-66-163
r CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330 Letter Serial CSC-676h Dated June 2h, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 195h, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Campany submits the response to J G Keppler letter to J W Cook dated May 23, 1983 CONSUMERS POWER COMPANY By
/((-L J
Cook, Vice President Proj cts, Engineering and Construction Sworn and subscribed before me this A / day of Ote /d/J.
/
as sb e / er n a v v A er ~ m 1 1n Notary Public ttr Commission Expires _,
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/
-NOV Item B - 6. (82-22-13) Continued Consumers Power Company is confident, based on the following, that welds made which required preheats between 32" and 70 F were done in accordance with engineering and code preheat requirements. This confidence is based on a review of the records generated by PQCI W-1.60 from April 1, 1981 to the present.
During this time period the W-1.60 was used to monitor, on a sampling basis, weld preheats under 70 F.
In the three and one half years of implementation, no discrepancies concerning preheats were identified. However, considering that the monitoring was performed on a sampling basis, a possibility exists that some welds may have been made with less than the required preheat. Accordingly, the following rationale is offered:
The omission of the requirement for preheat between 32*F and 70'F for low carbon and mild steels as used at Midland would not have significant technical ramifications.
If preheat requirements were not observed, defects that could be produced would be detected during weld final acceptance. Any weld that meets the acceptance criteria of the applicable project specifications is technically acceptable whether or not the required preheat requirements between 32" and 70 F were met.
The requirement for a 70 F preheat for carbon steels is certainly not a universal requirement of construction codes.
In fact, even the AWS Structural Welding Code DI.1 reduced the required preheat to 50 F beginning with the 1975 edition.1 Project specifications have subsequently been revised to adopt this change in the AWS requirement.
For carbon steels (P1, Group 1) such as those used for the structural work at Midland,Section III of the ASME Boiler and Pressure Vessel Code suggests, but does not require 50*F preheat.2 The Power Piping Code B31.1 required only a 50*F preheat.' The API Standard 650, Weld Steel Tanks for Oil Storage' does not require preheat for carbon steels less than 1 l
1/4 inch in thickness unless the base metal temperature is less 32 F, and then the preheat is only that required to make the metal warm to the hand. The API Standard 1104, Welding Pipelines and Related Facilities impose no minimum preheat requirements.'
Both AWS and ASME codes recognize preheat as an essential variable in procedure qualification, but allow considerable latitude.
In the preheat specified on the welding procedure specification in relation to the procedure qualification specified preheat for AWS may be 25 F lower than the test temperature; for ASME Qualification, 100 F lower.
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NOV Item B - 6. (82-22-13) Continued Preheat could influence a number of conditions related to welding:
Reducing Distortion Reducing Residual Stress Reducing Porosity Insuring Arc Stability Affecting Toughness Reducing Cold Cracking Reducing Hardness Promoting Hydrogen Diffusion The reduction of distortion and residual stress is achieved with preheat of hundreds of degrees; the difference on the order of tens of degress is not significent. Whether or not preheat requirements are observed, the porosity acceptance criteria of the code and project specification must be met.
Erratic arc behavior due to moisture aggravates welders, especially on starts, but causes no inherent welding problems as long as the final product meets the inspection criteria.
Experimental data from test welds' on low carbon and mild steel indicate preheat and low hydrogen practices do not directly affect notch toughness.
The main consideration is cold cracking due to hydrogen embrittlement (toe cracks or underbead cracking' in the heat effected zone). This results when monatomic hydrogen is supersaturated in the weld metal and diffused into the base metal that is hardened by the existence of martensite. The purpose of preheat is primarily to reduce the temperature gradient between the weld and base metal, thereby reducing the cooling rate of the weld and heat affected zone.
The slower cooling rate reduces the formation of martensite. The cooling rate of importance here is in the vicinity of 1000F.
Calculations' indicate the cooling rate would be increased on the order of 10 percent (8%
greater for thick material,12% for thin material) if welding started at 32*F as opposed to 70 F.
In low carbon and mild steels such as those used in the structures at Midland the difference in cooling rates as result of preheat is not important. No appreciable quantity of martensite is formed even at very high cooling in the low-carbon steels. The martensite question does not enter into the fusion welding of homogenous low carbon steels.2' The S-curve on the isothermal transformation diagram (TTT curve) shifts increasingly to the left (shorter times) with lower carbon content.11 Below 0.30% carbon, the influence of martensite in low hydrogen welds and heat affected zone is not a problem. The benefit of token preheat to 70*F or even 150 F, with respect to underbead cracking in this case is negligible.32 In a hardenable steel, this difference could be significant in certain situations.
Whether the welds were made between 32 and 70*F or below 32*F, the arguments presented remain the same. The temperature gradient increase of tens of degrees is not significant.
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m NOV Item B = 6. (82-22-13) Continued For conventional construction, structural steel is often erected in this temperature range and it is rarely preheated. The same goes for pipelines.
Welding on a pipe filled with water or flowing compressed gas is not uncommon and for the most part, is more severe than welding on cold structural steel.
Years of experience in the construction cud piping industry show that there is no real problem in these cases even when low hydrogen electrodes are not used.
Recently at the Midland jobsite several A36 plates 13" thick were cooled below 0*F with dry ice and welded as a test.
They were sectioned and etched as required by the structural code, and not only visually examined but examined with liquid penetrant on the face and cross sections. No cracking was uncovered.
The discussions above apply to the thin material as well as the thick, but the thinner materials are most forgiving.
For the case where welds require a 32' to 70 F preheat, the materials are less than 3/4" thick, and are less of a heat sink. The cooling rate is slower and therefore less likely to produce cracking. The residual stress is, on the average,. lower with thinner metal because it is more flexible (less restraint) and the weld sizes are usually smaller.
Based on the above rationale, coupled with the fact that we believe that most welds made have met the requirements, it is our belief that the existing welds made requiring preheats between 32' and 70 F are of acceptable quality.
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-l References 1.
AWS D1.1-75, Structural Welding Code, p32 2.
ASME Boiler and Pressure Vessel Code 1980 Edition,Section III, Nuclear Power Plant Components, Division 1-Appendices, Article D-100, Nonmandatory Preheat Procedures, p525 3.
AWSI/ASME B32.1-1980 Edition, Power Piping Code, Paragraph 131.4.2, P-No 1, p73 4.
API Standard 650, Seventh Edition, November 1980, Welded Steel Tanks for Oil Storage, Paragraph 5.2.1.2, p5-1 5.
API Standard 1104, Fifteenth Edition, September 1980, Standard for Welding Pipelines and Related Facilities, Paragraph 4.11, p19 6.
McGeady, L J, " Effects of Preheating, Thermal Stress Relief and Electrode Type on Notch Toughness," Welding Research Supplement, December 1958, pp543 553-5 7.
Baillie, J G, "Underhead and Toe Cracks," British Welding Journal, 14 (2)
February 1967, pp51-61 8.
Welding Handbook, Volume Four, Seventh Edition, " Metals and Their Weldability," American Welding Society, Miami, Florida, 1976, pp2-7 9.
Welding Handbook, Volume One, Seventh Edition, " Fundamentals for Welding," American Society, Miami, Florida, 1976, pp84-85 10.
Udin II, Funk E R Wulf f J, " Welding for Engineers," John Wiley & Sons, Inc, New York, 1954, p237 11.
Stout, R D, Doty, M D, Weldability of Steels, Second Edition, Welding Research Council, New York, 1971, pp71-73 12.
Linnert, G E. Welding Metallurgy, Vol 2, Third Edition, American Welding Society, New York, 1967, p392 l
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