ML20126C734

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Responds to NRC Re Violations Noted in Insp Repts 50-456/84-21 & 50-457/84-20.Corrective Actions:Independent Testing Lab Directed to Perform First Line Weld Insp Only in Unpainted Condition
ML20126C734
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 01/31/1985
From: Farrar D
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9685N, NUDOCS 8506140507
Download: ML20126C734 (12)


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Commonwealth Edison One First Nationa! Plaza. Chicago, Ifinois Address Reply to: Post Office Box 767 Chicago. Illinois 60690 January 31, 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.

50-456/84-21 and 50-457/84-20 NRC Docket Nos. 50-456 and 50-457 Referennce (a): R. F. Warnick letter to Cordell Reed dated November 20, 1984

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. L. G. McGregor and R. D. Schulz on September 4 through October 5, 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. However, we are submitting a response in order to clarify our position'on this issue. The delay in providing this response was discussed with Messrs. R. F. Warnick and P. R. Pelke of your office on December 17, 1984, and January 16, 1985, respectively.

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

Very truly yours

=& W" Dennis L. Farrar Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector FEB 51985 8506140507 850131 l PDR ADOCK 05000456 s g G PDR 558/

c ENCLOSURE COMMONWEALTH EDISON COMPANY 50-456/84-21 AND 50-457/84-20 ITEM 456/84-21-01 AND 457/84-20-01

__ ITEM 456/84-21-02 AND 457/84-20-02 ITEM OF NONCOMPLIANCE

1. 10 CFR 50, Appendix B, Criterion IX, states in part: " Measures shall be established to assure that special processes, including welding . . . are controlled and accomplished . . . in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Commonwealth Edison Company FSAR, Volume 7, and Sargent and Lundy Structural Steel Specifications, F/0-2735, Structural Steel and F/L-2722, General Structures Work, commit to AWS Dl.1, 1975, Structural Welding Code.

AWS D1.1, Structural Welding Code, states in.part, in Section 3.10: " Welded joints shall not be painted until after the work has been completed and accepted". Section 6.5.1 of AWS Dl.1 states: "The Inspector shall make certain that the size, length, and location of all welds conform to the requirements of this code and to the detail drawings, that no specified welds are omitted,

. and that no unspecified welds have been added without approval."

Section 6.5.5 states in part that the Inspector shall examine the work to make certain that it meets the requirements of Section 3, Workmanship and Section 8.15, Quality of Welds. Section 8.15.1, Visual Inspection, states in part: "All welds shall be visually l inspected."

Contrary to the above:

a. One hundred and twenty safety-related structural steel fillet welds were painted prior to acceptance of the l

work and the welds were subsequently visually inspected for acceptance, with 79 accepted in the painted condition. The welds are identified in visual j inspection reports 709VW, 711VW, 713VW, 716VW, and 717VW.

b. Visual weld inspections which identify acceptable workmanship, size, length, location of welds, and that no unspecified welds were added, were not performed on i safety-related full penetration welds completed under
the jurisdiction of Structural Specifications F/L-2735 and F/L-2722 prior to May 1, 1984. The welds were
accepted based on other methods of nondestructive i examination, but were not accepted in accordance with l

the requirements of Section 8.15, Quality of Welds, Visual Inspection.

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. ITEM 456/84-21-01 AND 457/84-20-01 ITEM 456/84-21-02 AND 457/84-20-02 RESPONSE PART la'

. Commonwealth Edison agrees that certain structural steel fillet

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iwelds were painted prior to acceptance of work.

CORRECTIVE ACTION-TAKEN'AND-RESULTS ACHIEVED' PART la At1the time of the-original inspection by the NRC and the identification of this area as an unresolved item (456/84-08-03; 457/84-08-03) the Independent Testing Lab. initiated NCR No. 191 to disposition the. inspections performed through paint. A 100%

review of the affected records was performed. Only Visual Weld Reports 709, 711,.713, 716, and 717 encompassing the 122 welds

were identified as being performed through paint. ..The paint was removed and.a reinspection was performed. This inspection determined that 23 of the 122. welds reinspected required repair.

.Two. welds were found to be inaccessible for reinspection. One was documented and dispositioned on Commonwealth Edison Company NCR.No. 628 and the.other was documented on Commonwealth Edison Company NCR.No. 700.

CORRECTIVE' ACTION TAKEN T0 AVOID FURTHER NONCOMPLIANCE - PART la

'The review of the affected reports determined that inspection of structural welds."through paint" occurred during a one week period in,1980 and was limited to the five reports identified.

To' prevent: recurrence, the Independent Testing Lab has been directed to perform first line weld inspections only in the unpainted condition.

DATE OF FULL-COMPLIANCE -PART la Completion of repairs and reinspection of the subject welds is expected-by May 1, 1985.

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ITEM 456/84-21-01 AND 457/84-20-01 ITEM 456/84-21-02 AND 457/84-20-02 RESPONSF - PART lb CECO agrees that in accordance with the requirements of AWS, a visual inspection of full penetration welds is required even if other NDE is specified.

However, in resolving this item, AWS Dl.1 does not preclude the Architect Engineer from performing an engineering evaluation of weld inspections. In addition, in the footnotes to Table 3.8-2 of the Byron /Braidwood FSAR, it is stated that clarification to, and deviations from portions of AWS Dl.1, " Structural Welding Code", are made based on engineering evaluations.

CORRECTIVE ACTION AND RESULTS ACHIEVED - PART lb

' Commonwealth Edison NCR 616 Revision 1 requested an evaluation of alternate NDE in lieu of visual examination as defined in AWS Dl.l. The Architect / Engineer has accepted the MT/PT examination results for the quality aspects of the separate AWS visual examination. The size, length, and location aspects will be evaluated as noted in Revision 2 of NCR 616.

CORR CTIVE ACTION TAKEN TO AVOID-FURTHER NONCOMPLIANCE - PART lb Specification F/L-2722 has been revised to more clearly identify the requirements for visual inspection of full and partial penetration groove welds. The structural steel installation contractor-procedure #55 has been revised to incorporate the i revised specification requirements for visual weld inspection.

DATE OF FULL COMPLIANCE - PART lb At this time, the date of full compliance cannot be determined pending final evaluation of NCR 616 Revision 1 and 2 and determination of the extent of the corrective action.

Evaluation of the acceptability of past practices is expected prior to January 1986. As of May 1, 1984, full penetration welds under Specification F/L 2722 are being visually inspected. No further field work is being performed under Specification F/L 2735. Current activities are in compliance.

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ENCLOSURE COMMONWEALTH EDISON COMPANY RESPONSE T0' INSPECTION REPORT 50-456/84-21 AND 50-457/84-20 ITEN 456/84-21-03 AND 457/84-20-03 ITEM OF NONCOMPLIANCE

2. 10'CFR 50, Appendix B, Criterion V, states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings.

Piping Contractor Procedure, QAP-110, Reporting of Defects and Noncompliance, Revision 1, requires that a noncompliance of basic component or activity supplied to the owner of a licensed facility shall be reported to the owner by the Manager - Quality Acsurance under the requirements of 10 CFR 21.

Contrary to the above: On June 13, 1984, during receipt inspection an 8" S/120 SA-106 GR.B piece of pipe, heat No.

93739 -10 feet long, was found by the piping contractor's qualify control department to violate minimum wall

. requirements. This defect was not reported to the owner in accordance with 10 CFR 21.21 and Procedure QAP-110. The pipe furnished to the Braidwood facility, under the requirements of 10 CFR 21, was classified as ASME Boiler and Pressure Vessel Code, Section 3, Subsection NC, Class 2, Pressure Boundary Piping.

< RESPONSE Phillips Getschow Company performed a receiving inspection for one ten foot length of 8" S/120, .718" wall SA-106 Gr. B pipe.

Measurements for the end 2 feet of the pipe showed the wall dimension varied from .001 to .009 inches below the minimum wall requirement of .629 inches.

Phillips Getschow procedure QAP-110 requires Phillips Getschow Company to notify Commonwealth Edison of a suspected deviation or noncompliance, utilizing the Report of Noncompliance Form.

Commonwealth Edison agrees that Phillips Getschow did not report the deviation to Commonwealth Edison as required. Evaluation of the deviation is the responsibility of Commonwealth Edison.

When the nonconforming condition was identified, and contrary to their procedure, an evaluation was performed (although not ITEM 456/84-21-03 AND 457/84-20-03 documented)1byLPhillips Getschow Company.

Their evaluation determined this condition to be not reportable under the provisions of 10 CFR'Part 21 and they-did not notify Commonwealth Edison. Although Phillips Getschow Company did not properly notify Commonwealth Edison of this deviation, we would have been adequately informed by receipt of the Phillips Getschow. Company NCR had it been properly processed.

Phillips Getschow: Company NCR 1615 which documented the minimum wall violation, was initiated on 6/13/84, dispositioned to remove and_ scrap the nonconforming section 6/28/84, and closed on:7/25/84. Phillips Getschow Company did, however, fail to route'this NCR-through Commonwealth Edison Company for disposition concurrence. This failure to route the NCR to Commonwealth Edison Company for disposition concurrence was documented on Phillips Getschow Company NCR 2027 dated 9/4/84.

NCR's11615 and 2027 were reviewed-by Commonwealth Edison Company

' Project Construction Department on 9/13/84.- This included a review for reportability.

CORRECTIVE ACTION TAKEN AND-RESULTS ACHIEVED As a result of the concerns raised.by the NRC Inspector, Phillips Getschow Company issued a Report of Noncompliance to Commonwealth Edison Company in accordance with QAP-110.

Braidwood Project Field-Engineering performed a review for reportability under the provisions of 10 CFR Part 50.55(e).

.This review included a-check for reportability under 10 CFR Part

21. Based.on such a small sample, Commonwealth Edison Project Engineering Department was requested to perform an-evaluation pursuant.to 10 CFR Part 21 and the piping supplier was notified of the nonconforming condition. The Project Engineering Department evaluation determined the condition not to be reportable.

1 CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE Commonwealth Edison has discussed this item with-appropriate Phillips Getschow Company personnel to enhance awareness of the reporting requirements of procedure QAP-110 " Reporting of Defects and Noncompliance".

DATE OF FULL COMPLIANCE Full compliance has been achieved.

ENCLOSURE COMMONWEALTH EDISON COMPANY 50-456/84-21 AND 50-457/84-20 ITEM 456/84-21-07 AND 457/84-20-07 ITEM OF NONCOMPLIANCE

3. 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected".

The Braidwood FSAR, Amendment 43 and the Commonwealth Edison

' Company' Quality Assurance Manual commit to Regulatory Guide 1.116 , June 1976 which endorses ANSI N45 2.8, 1975, Supplementary Quality Assurance Requirements for Installation, Inspection and testing of Mechanical Equipment And Systems For The Construction Phase of Nuclear Power Plants.

ANSI N45 2.8, states in part in Section 3, Pre-Installation Verification, that inspections or checks shall be performed and include verifications such as removal of packaging, conditioning, and cleaning. Section 4, Control During Installation Process, states in part that inspections of the work' areas and the work in progress shall be performed for mechanical items and shall include cleanliness inspections and inspections to assure that items will not be contaminated as a result of adjacent construction activities.

ANSI N45 2.8. states in part in Section 2.4, Cleaning, that cleaning shall be performed in accordance with ANSI N45 2.1, 1973.

ANSI N45 2.1 states in part in Section 2, General Requirements, that the work and quality assurance requirements for the cleaning of items and systems to be incorporated in the Nuclear Power Plant and control of cleanliness thereof shall be established in order to (1) ensure the removal of any deleterious contaminants, (2) minimize recontamination of cleaning surfaces, and (3) minimize the cleaning required after installation. Section 4, Pre-Installation Cleanness, states in part that inspections, examinations, and tests as appropriate shall be performed immediately prior to installation to determine the cleanliness of the item.

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ITEM 456/84-21-07 AND 457/84-20-07

ITEM OF NONCOMPLIANCE (cont'd)

Contrary to the'above, after:an NRC inspection (82-05)

. identified that the licensee failed to. implement a quality assurance program for.the erection of mechanical safety-related equipment,.the piping / mechanical equipment contractor identified numerous . pieces of mechanical. equipment

.that had been installed without quality control verification of internal cleanliness. Although these nonconforming

. conditions were reported to the-licensee, the licensee failed

'to adequately evaluate or take corrective. action. The common evaluation of these nonconforming conditions was to waive the cleanliness inspection and " flush it clean". Quality control inspections ofEinternal cleanliness had not been formulated during the installation process to assure the absence of corrosion, pitting and contaminants including foreign objects that may affect the safe and reliable operation of safety-related equipment.

COMMONWEALTH-EDISON COMPANY POSITION CLARIFICATION Although no r uponse to this Item of Noncompliance was required, Commonwealth Edison wishe's to clarify our position with respect to

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!As stated in the Item of Noncompliance, during the mechanical equipment ~ retro-inspection resulting from NRC inspection 82-05, some pieces of equipment had no documentation showing-that

. l cleanliness inspections were performed during initial installation activities. -This lack of documentation does not imply cleanliness

-inspections were not performed at the time of initial installation

, l activities. Commonwealth Edison Company had sufficient confidence

~ in system cleanliness during initial ~ installation activities to

. warrant their disposition of waiving equipment disassembly and Lusing the piping system flushing program to demonstrate system

' cleanliness. Much of the equipment-has been flushed, and the

. flush'results indicate that the systems were clean. To date eleven (11) pieces of mechanical equipment on systems that had been' flushed have been opened.- The mechanical equipment was clean. The program established under Commonwealth Edison NCR-614 is a reverification to. add further confidence in internal equipment cleanliness.

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  • ENCLOSURE COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 50-456/84-21-AND 50-457/84-20 ITEM 456/84-21-08 AND 457/84-20-08
ITEMLOF-NbNCOMPLINCE 4.. 10 CFR 50, Appendix B, Criterion IX, requires measures to be established to assure that special. processes, including welding, heat treating and nondestructive testing, are controlled and accomplished by qualified personnel.using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other.special requirements.

ANSI N45.2 states in part: Qualification of personnel, procedures, and equipment shall comply with the requirements of applicable codes and standards. Documentation shall be maintained for currently

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_ qualified personnel, processes, or equipment in accordance with the

-requirements of pertinent codes and standards. For special processes not1 covered by existing codes and standards, or where item quality requirements exceed the requirements of established codes or

' equipment standards,shall the necessary be defined.

qualifications of personnel, procedures, or

' Construction Specification.No.. L2797 NSSS Support Steel for Braidwood Station Unit 1 and 2. requires: material tests and

. reports, such as required in NF-2000 of ASME Code Section III, certified copies of Charpy Impact Tests and Lamination Tests, material 1 identified as specified in NF 2150 of' ASME Section III, records of welding which conform to ASME Section III Subsection NF i

' Article 4000, Fabrication, test.and inspections applicable to ASME Code Section-III.

g Braidwood Quality Assurance Manual, Section 9, Procedure 9-1, states in part: "The contractor is responsible for preparing and submitting ~his procedures for the control of special- processes for review and acceptance in accordance with Quality Procedure 5-1. He is also responsible to maintain records that identify qualified

. personnel'where qualification is required for special processes involved. . The site Quality Assurance Superintendent is responsible for assuring that records of qualified personnel are maintained by

, the on-site contractor for work performed for Commonwealth Edison

' Company. He is also responsible for assuring that inspections and records verifying special processes at designated inspection notifications points specified in procedures are performed. For welding, records of filler metal (not only weld rod) shall be kept ITEM 456/84-21-08 AND 457/84-20-08 ITEM OF NONCOMPLIANCE (cont'd) for material traceability to the welder perlorming the work or as otherwise provided by the ASME Code for such Code work. Also, the specifying of the weld procedure and weld material shall be performed by competent personnel not directly involved in the welding, i.e., the welder or his foreman shall not select the procedure or weld material. In addition, a quality control surveillance of in-process welding shall include inspection of fitup and of a portion of the welding".

Contrary to the above requirements, a newly designed reactor coolant pump lateral support anchorage was installed in Units 1 and 2 without records to establish the material heat number, Charpy impact tests, lamination tests, welder identification, weld procedure, weld filler material, in-process inspections and other quality related records.

RESPONSE

Commonwealth Edison agrees that the subject lateral support was installed without Charpy impact tests and that the welder identification could not be established by records. The other inspections / records identified by the inspector are not required because this installation is not within the established jurisdictional boundary of the ASME Code. The design change and subsequent field modification to the subject Reactor Coolant Pump Lateral Support was handled in accordance with the Commonwealth Edison Company Quality Assurance Manual and the applicable approved contractor procedures in effect at the time of the modification.

The interference problem between the box beam and the embedments was design in nature. The relationship between the box beam and the embedment at Braidwood is similar to that at Byron. As stated by the Inspector, a cope of the box beam was utilized at Byron to resolve the interference. When the interference was identified at Braidwood, a cope design similar to that used at Byron was established and could have been installed at Braidwood. An alternate design established on FCR L506 was elected to resolve the interference of the box beam and the lateral supp3rt at Braidwood Station for economic reasons.

Commonwealth Edison Company takes exception to the statement that the necessary records to support the design change are inadequate or nonexistent. When the interference was identified, a Field Change Request (L-506-Unit 1 and L-775-Unit 2) was initiated by Commonwealth Edison Company, in accordance with the Commonwealth Edison Company Quality Assurance Manual, to obtain the necessary design change prior to continuing installation activities. Upon approval of the FCR, the modification was assigned to the structural steel contractor for implementation.

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50-456/84-21 AND 50-457/84-20 Commonwealth Edison Company contends the design meets the FSAR requirements and the design change was made in accordance with the approved Quality Assurance Program as summarized below:

1. The box beam which the brace connects to is sufficiently rigid relative to the brace to assume fixed support of the brace.

The calculations which support FCR L-506 show the stiffness of the box beam is 40 times that of the brace and thus total brace stiffness of the installed design is reduced by a negligible amount.

2. .The temperature differential between the brace and box beam will be smaller than that between the brace and the secondary shield wall because the concrete shield wall will heat up at a slower rate than the steel box beam. In either case the brace member need not be designed for faulted condition temperature effects per the ASME Code Section III Appendix F Article F1310.

3.- The records to support the design review and approval are contained in Sargent and Lundy Calculations for FCR L-506.

4. The subject change to the reactor coolant pump supports has no impact on FSAR Section 3.9.3.4.1.4 which describes the reactor coolant pump supports.

5.- For those portions of the brace detail within the ASME jurisdictional boundaries, the design is in accordance with the ASME Code.

The installation af the gusset plates was performed by Napolean Steel Contractor, Inc. under their approved Quality Program in accordance with Sargent and Lundy Specification L-2722. The reference to Specification L-2797 for installation is not applicable. Specification L-2797 is the specification for fabrication of the NSSS Supports performed by Teledyne Brown. The installation of the gussets was performed using safety related material by qualified welders'using approved welding procedures.

- The weld inspe~ctions were performed by Commonwealth Edison Company's Independent Inspection Agency.

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50-456/84-21 AND 50-457/84-20 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED During the investigation of this item, Commonwealth Edison Company identified that A588 material procured and installed as the gusset plate did not have the testing required by FCR's L-506 and L-775. Subsequently, Commonwealth Edison Company NCR 661 was initiated to identify and resolve the apparent nonconforming condition. As a result of the NCR, Sargent and Lundy issued ECN 23836 deleting the additional testing requirements. The deletion of testing requirement is consistent with the Sargent & Lundy design specification for structural steel. NCR 661 is currently in routing for closure.

The welder has been identified and his qualifications verified.

Material certifications have been assembled. These records and the Independent Inspection Agency weld inspection records are available for NRC review.

CORRECTIVE ACTION TAKEN TO AVOID-FURTHER-NONCOMPLIANCE The contractor organization which installed this lateral support is no longer onsite. Current site contractor's welding procedures conform to applicable AWS Dl.1-1975, ANSI N45.2 and Commonwealth Edison Company Quality Assurance Manual Requirements.

DATE OF FULL COMPLIANCE Commonwealth Edison NCR 661 review and closure is expected to be complete by March 1, 1985.

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