ML20091Q985

Discusses Insp of longitudinal-seam Pipe Welds Recently Identified During Final Stages of Preservice Exam Process & Documentation Reviews.Insps Performed by Qualified Exam Personnel

ML20091Q985
Person / Time
Site:	Callaway
Issue date:	06/03/1984
From:	Schnell D UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
ULNRC-839, NUDOCS 8406140224
Download: ML20091Q985 (4)

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~ UNION ELECTRIC COM PANY 1941 GRATIOT STREET ST. LOU IS, MISSOURI maiuMG ADDRE..:

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June 3, 1984

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Mr.-Harold-R. Denton,. Director

~OfficeJof Nuclear React'or Regulation-U.S. Nuclear Regulatory _ Commission Washington,. D.C.

20555

Dear Mr.zDenton:

ULNRC-839 DOCKET NUMBER 50-483 CALLAWAY. PLANT, UNIT 1 CALLAWAY PRESERVICE EXAMINATIONS

Reference:

SLNRC-84-0061 dated April 9, 1984 The reference letter advised.NRC_that.the preservice examination effort at Callaway Plant was essentially complete, and based on knowledge available at thatLtime, no additional volumetric' examination relief: requests would be required.

Subsequent: to the reference ' letter,.we have identified a number of longitudinal-seam pipe welds requiring preservice examination (volumetric and/or surface).

These welds were?not included'in the PSI program and have only recently been identified during the finalistages of the preservice examination process and documentation reviews.

The,need to extend the PSI effort to include additional

_ longitudinal-seam pipe-welds was~first indicated in March of this year when-inconsistencies were noted between the."as-built" Ldocumentation furnished by the piping supplier,. Dravo, and the

physical condition of several installed Class 2 pipe spools.

Specifically, longitudinal-seam welds were noted by the PSI exwminer in contrast to'the' Dravo documentation which indicated the: pipe being examined at that time to be seamless.

These inconsistencies.were documented on a Field Change Authorization and. action was subsequently taken to incorporate these welds into the PSI Program and to perform the required examinations.

It should be noted that the Bechtel purchase specification for Class'2 piping' permits use of either seamless or longitudinal seam-welded pipe and fittings.

Hence, the as-delivered and as-installed _ piping is in conformance with applicable purchase specifications.

However, because of PSI /ISI considerations, the

' specifications obligate the supplier to document gn the pip'ing spool. data sheets the as-built condition) i.e.,

seamless or

' seam-welded,fof the materials furnished.

(Note:

Only seamless piping materials are specified for use in Class 1 systems).

10 8406140224 840603 1

'PDR ADOCK 05000483 ff0 O

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E Mr. Hqrold R. Denton June 3,1984 Page 2 On the basis of the data indicated in the aforementioned

Field Change Authorization, it was apparent.that inconsistencies existed in some of the supplier's-documentation for the pipe spools referenced'therein.

Review of these documentation packages with Dravo confirmed the inconsistencies to be limited

'to recordingLthe physica1' condition; i.e.,

seamless or welded, of

.a number.of pipe spools.

Prompted.by these documentation errors, a comprehensive-investigation.was initiated by Bechtel and Union'. Electric to systematically examine all pipe spool data sheets furnished by

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Dravo _for Class 2 piping subject to PSI /ISI examination and to compare the recorded physical _ condition of the pipe and fittings on these data sheets against the data specified on the Certified Material Test Reports (CMTRs).-

Inconsistencies have been identified and subsequently verified by~ Dravo.

This effort has been completed and the results indicate the need for extending the preservice. examination effort (surface and/or volumetric) to 80 additional. pipe longitudinal-seam welds located'in the, following systems:

System EJ, Residual Heat Removal.

63 longitudinal-seam. welds

.-System EM, High Pressure Coolant Injection 16'

~ longitudinal-seam welds-

.. System EP, Accumulator Safety Injection.

..1 longitudinal-seam welds The required field examinations have been satisfactorily completed and no weld problems were identified.

Consequently, no relief requests are necessary.

The Callaway PSI Program Plan is being revised to incorporate.the additional pipe spools and will be forwarded to the NRC during the week.of June.4, 1984..Upon

-revision and'resubmittal of..the updated plan, this matter can be considered resolved.

We would like to emphasize the fact that.the inconsistencies L

in thelpiping supplier's as-built. data sheets were identified and recorded in.the course of scheduled' inspections performed by the PSI examination agency.

The inconsistencies were promptly reported: to the -NRC ' resident, inspector.

Once the nature and potential impact.of these inconsistencies were recognized, management actions were initiated in'the form of a system-by-

-system investigation of all Class 2' piping materials supplied by

.Drayo which are subject to preservice"and/or inservice examination..The results of this investigation were reviewed with the-responsible supplier and all identified inconsistencies confirmed through physical inspection of the particular piping materials in question.. Upon completion of the investigation and

. verification of the results, follow-up action was promptly taken to extend:the PSI effort to cover the additional seam weld

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= Mr. Harold R. Danton

- June ~3, 1984

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- examinations.:.These inspections have been' performed by qualified

-f examination-personnel and the results have been reviewed by Union Electric.

As previously indicated, all' inspections were satisfactorily completed without difficulty or complication and

no. weld defects were found.

We believe these actions demonstrate

. the effectiveness of'the quality program in place at Callaway and-provide further indication of Union Electric's continuing commitment to.take prompt and aggressive action to assure the integrity of the Callaway Plant.

-As'an added precaution, the. investigations described in-this letter have been extended-in'part to the other Callaway piping

- supplier,' Pullman-Kellogg.' Stainless steel piping spools 1

- supplied by1 Pullman-Kellogg requiring PSI /ISI examination are limited-to System BG, Chemical and Volume Control.

Discussions Ewith examination, agency personnel indicate no inconsistencies similar to that. reported with the Dravo piping materials'.

Representative Pullman-Kellogg documentation'has been ' audited and the results of this audit confirm no-inconsistencies between the Pullman-Kellogg data packages and the as-constructed condition of

- the piping. spools-We believe this review provides further confirmation of the fact'that the concerns described in this letter are limited to..the. discrepancies identified.

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We trust the information provided;in this~ letter will resolve any remaining questionsLyou have concerning the Callaway PSI effort.

Very truly yours, m

i Donald F. Schnell SJS/DS/lw

cc:_. William Forney, Region III Richard DeYoung, Director,'I&E Bruce-Little, USNRC/ Cal J. H..Neisler, USNRC/ Call p

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- STATE OF MISSOURI )

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CITY OF ST.. LOUIS )

Donald F.

Schnell, of lawful age, being first duly sworn upon oath says that he is-Vice President-Nuclear and an of ficer of Union ~ Electric Company; that he has read the foregoing document and knows the content thereof; that he -has executed the same for and on behalf of :said company with full powar and authority to do so; and that the' facts therein stated are true and correct to the best of his knowledge,- information and belief.

By Dt5nald F. ' Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 3N day of

, 198I v~

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BARBARA J. PFAF[

NOTARY PUBUC, STATE OF MISSOURt A(Y COMMfSSION EXPIRES april 22,1985-

.ST. LOUIS COUNTY I

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