ML20107K631

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Responds to NRC Re Noncompliance Noted in Insp Repts 50-456/84-34 & 50-457/84-32.Corrective Actions:Broken Welds Will Be Reviewed to Determine Mechanism of Failure & Determination for Reinsp of Past Work
ML20107K631
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/13/1985
From: Farrar D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8502280351
Download: ML20107K631 (6)


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Commonwealth Edison one First National Pla2a. ChiCOgo, Illinois

/h Address Reply to: Post Office Box 767 Chicago, Illinois 60690 February 13, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.

50-456/84-34 and 50-457/84-32 NRC Docket Nos. 50-456 and 50-457 Reference (a): R. F. Warnick letter to Cordell Reed dated December 31, 1984

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. R. Gardner and R. D. Schulz on November 12 through December 19, 1984, of construction activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. Our response to these items is provided in the enclosure to this letter. As noted in Reference (a), no response to the Notice of Violation Item 3 was required. The delay in providing this response was discussed with W. L. Forney of your office on January 24, 1985.

Should you or your staff have any questions regarding this matter please contact this office.

Very ruly yours A=__& w j D nnis L. Farrar Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector FEB 15 N 8502280351 850213 PDR G ADOCK 05000456 PDR

/y b.

d ENCLOSURE COMMONWEALTH EDISON COMPANY RESPONSE-TO INSPECTION REPORT 50-456/84-34 AND 50-457/84-32 ITEM 456/84-34-01 AND 457/84-32-01 ITEM OF NONCOMPLIANCE 1.- 10 CFR 50, Appendix B, Criterion IX, states in part that measures shall be established to assure that special processes, including welding, are controlled and accomplished in accordance with applicable codes and specifications.

Sargent and Lundy Specification F/L-2782, HVAC Work, June 6, 1983, commits to either AWS Dl.1, 1977 or AWS D1.3, 1978 for the welding of stiffener angles, companion angles, or support angles to the duct.

-Structural Welding Code, AWS Dl.1 and Specification For Welding Sheet Steel In Structures, AWS Dl.3 require that welds upon visual inspection contain no cracks.

Contrary to the above, the following safety-related companion angle to duct welds were completely cracked resulting in no bonding between the weld metal and companion angle:

duct 4032 - l' weld duct 4024 - 15 welds duct 4684 - 4 welds duct'4686 - 3 welds

RESPONSE

Commonwealth Ed.i. son agrees that certain silicon bronze shop welds have broken between the companion angle and the sheet metal on

. fabricated ducts. Our investigation indicates that this occurred after shop quality control inspections were performed. It is suspected that silicon bronze welds separated from the companion angle as.a result of excessive loads being imposed during

. erection and other construction activities in the vicinity of the ductwork.

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-ITEM 456/84-34-01 AND 457/84-32-01 CORRECTIVE ACTION-TAKEN AND RESULTS ACHIEVED Commonwealth Edison has initiated NCR.701~.to address the concerns identified in the-breaking of silicon bronze shop welds between companion angles and sheetmetal. This NCR'is currently in

_ Commonwealth Edison Project Engineering for review and disposition.- As'part of the NCR disposition, the Architect 4

_ . Engineer will-reviewLthe identified broken welds to determine the l mechanism of failure, the possible design significance, and a L determination for re-inspection of past work completed by Pullman

, Sheet Metal.- Pullman Sheet Metal will repair known broken welds through established procedures.-

CORRECTIVE ACTION TAKEN'TO AVOID-FURTHER NON-COMPLIANCE o Commonwealth Edison has directed each Contractor to review their administrative and erection: procedures to assure the necessary

. guidance regarding rigging practices and protection of plant

-equipment are included in their procedures. Additionally, each

Contractor.was directed to review at safety meetings and/or training ' classes lthe need for " attention to. detail" and -
appropriately train ~ their employees -regarding the correct protection of equipment.

f Currently, Pullman's Q.C. inspection of various attributes for

. , duct installation includes gasketing and companion angle bolting -

i Linspection. - During this inspection, the existence of broken welds would be. noticed, reported and subsequently repaired' prior-to acceptance of the. item.- However, to ensure the-inspector.will-i verify the-integrity of the-companion angle to duct weld, Pullman j

Procedure B10.3F " Installation Inspection-Procedure" will be

- , revised to inspect for broken silicon bronze shop welds between companion angles and sheetmetal. Additional corrective action may be taken,-pending Commonwealth Edison-Engineering and the '

Architect-Engineer's evaluation and recommendations.

DATE-OF FULL COMPLIANCEI

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At.this time, date of full compliance cannot be determined-r pending final evaluations of NCR 701.and determination of'the extent of corrective action.

Pullman Procedure B10.3F " Installation Inspection Procedure" is 4

cexpected'to be: complete by March-1, 1985.

l Repair.af known broken welds is expected by' March 29, 1985.

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COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 5'0-456/84-34 AND 50-457/84-32 Item 50-456/84-34-03 and 50-457/84-32-03

2. 10 CFR 50, Appendix B, Criterion V, stated in part that activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Sargent~and Lundy Specification F/L-2739, July 5, 1977, Amendment 6, Piping System Installation, commits to AWS Dl.1, Structural

. Welding Code, 1975, for AISC safety-related steel welds not under the jurisdiction of the ASME Boiler and Pressure Vessel Code,Section III, Subsection NF.

Contrary to the above for AISC safety-related steel welds, not under the jurisdiction of the ASME Boiler and Pressure Vessel Code,.Section III, Subsection NF, the piping contractor did not have an AWS Dl.1, Visual Weld Examination Procedure.

RESPONSE

Sargent & Lundy (S&L) Specification F/L-2739, July 5, 1977, Amendment 6, Piping System Installation, established the governing codes for pipe support installation. Specifically Form 275-C, articles 2.1 and 2.2 delineate the applicable installation code.

Article 2.1 specifies that supports for piping systems except for those specified in Article 2.2 shall be installed in accordance with ASME NF or ANSI B31.1. Article 2.2 specifies supports 'not under the jurisdiction of ASME or ANSI Codes (non safety related class "N" or "W") shall be in accordance with the requirements of the AISC Manual of Steel Construction and AWS D1.1 - Structural Steel Welding Code. Class N or W piping / supports are not used at Braidwood.

Even though the S&L drawings do not explicitly identify the applicable code installation and inspection requirements beyond the NF boundary, they do identify the applicable pipe class.

Therefore, in accordance with Form 275-C, component support installation not specifically designated as ASME NF are under the jurisdiction of ANSI B.31.1.

Item 50-456/84-34-03 and 50-457/84-32-03 A comparison between ANSI B31.1 safety-related and ASME-NF

, inspection acceptance criteria in Phillips Getschow Procedure VE-01 shows that porosity is the only design significant attribute missing from Procedure VE-01 ANSI B31.1 safety-related inspection criteria. Although crater pits are not specifically identified in Procedure VE-01 as an inspection attribute for ANSI B31.1 safety-related supports, pits of any significant size would affect weld size, which is an inspected attribute. Therefore, craters of design significance would be identified utilizing the existing criteria.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Itfis Commonwealth Edison's position that this violation is limited to a lack of procedural consistency relative to the inspection attribute of porosity and does not impact the adequacy of-the component supports involved. The specific issue of porosity will be resolved in the following manner:

Phillips Getschow Company will identify all welding inspectors who visually inspected welds within the scope identifed. Each inspector will be interviewed to verify the visual criteria utilized by the inspector did include porosity.

Welds inspected by inspectors no longer employed by Phillips Getschow Company will be addressed by reviewing previously accepted welds subsequently rejected b Construction Assessment Program (BCAP)y the Braidwood This review will determine if an unacceptable number of welds exist which were rejected for exceeding the porosity limit of the criteria specified in ASME Section III, 1974 edition, Subsection NF paragraph NF 5342 subparagraphs b2, 3 and 4. The BCAP program provides a selected sample representive of the installation time frame and population of component supports.

Phillips Getschow Company welding inspectors certified to

~ inspect safety-related component support welds are being re-trained to insure that each inspector is evaluating the subject ~ welds to an acceptable criteria.

CORRECTIVE ACTION TAKEN TO AVOID'FURTHER NONCOMPLIANCE A note.will be added to the Sargent & Lundy M-999 Drawings to more explicitly define the' installation and inspection requirements for pipe supports beyond the NF Boundary.

3 Phillips Getschow Company Procedure VE-01, Visual Examination Procedure, is being revised to incorporate a single inspection criteila. This criteria will be based on ASME Section III

, Subsection NF. ^

DATE-OF' FULL-COMPLIANCE Weld inspector interviews expected to be complete by March 1, 1985.

Rejected weld reviews and review of BCAP results expected to be complete by May 1, 1985.

Weld inspector training expected to be complete by March 1, 1985.

S&L drawing notes expected to be added by March 1, 1985.

Phillips 15, 1985.

Getschow Procedure VE-01 expected to be revised by March

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