ML20136G627
| ML20136G627 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/28/1984 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Lash T ILLINOIS, STATE OF |
| Shared Package | |
| ML20136G602 | List: |
| References | |
| FOIA-85-452 NUDOCS 8508190571 | |
| Download: ML20136G627 (28) | |
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/W December 28, 1984 State of Illinois Department of Nuclear Safety ATTH: Terry R. Lash Director 1035 Outer Park Drive Springfield, IL 62704
Dear Mr. Lash:
This is in response to your letter dated December 20, 1984, in which you request that we meet to discuss the present status of the Braidwood project.
Mr. A. Bert Davis, Deputy Regional Administrator, and others of our staff will plan to r.:eet with you at 10:00 a.m. on January 10, 1985 in your offices in Springfield. We will present a history of the Braidwood project, the present status of the BCAP program, and will include a discussion of the lack of documentation for piping material installed at the Braidwood Station, as you requested.
We suggest that you invite representatives of other State agencies or offices who may have an. interest in the Braidwood project.
We appreciate your offer to also discuss your emergency planning and response capabilities and environmental monitoring program for the nuclear power plants in Illinois. We look forward to discussions on these subjects as part of the meeting.
Sincerely, Cr!Mn:1 :-: md by Jca:a C. r
' ' - r James G. Keppler Regional Administrator j
cc:
R. F. Warnick, RIII W. L.'Forney, RIII 8508190571 850719 PDR FOIA CARDE85-452 PDR RII RIII RI;J j
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HVAC CORRECTIVE ACTION PROGRAMS A.
HVAC WELDING PROBLEM:
PRIOR TO MARCH 1980 PSM QUALITY CONTROL ONLY INSPECTED 10% OF FINAL WELD INSTALLATIONS.
.,C.A.P.:
IN MARCH 1980, PSM WAS DIRECTED TO PERFORM 100%
/[,
0.C. INSPECTION OF NEW FIELD WELDS, AND TO he'*
INSPECT ALL PREVIOUSLY INSTALLED FIELD WELDS U
WHICH WERE NOT QC INSPECTED.
ADDITIONALLY, IN FEBRUARY 1982, PSM WAS DIRECTED TO CONDUCT REINSPECTIONS TO IDENTIFY AND REPAIR CASES OF WELDING DETAIL HISINTERPRETATION.
SUMMARY
PREVIOUSLY COMPLETED HVAC FIELD WELDS HAVE/WILL BE INSPECTED FOR CONFORMANCE WITH DESIGN REQUIREMENTS.
B.
HVAC CONFIGURATION PROBLEM:
PRIOR TO OCTOBER 1982, PSM DID NOT PERFORM QC CONFIGURATION INSPECTIONS FOR HVAC HANGERS.
C.A.P.:
IN OCTOBER 1982, PSM WAS DIRECTED TO PERFORM 100%
0.C CONFIGURATION INSPECTIONS FOR ALL NEW HANGER INSTALLATIONS AND TO INSPECT ALL PREVIOUSLY INSTALLED HANGERS.
SUMMARY
PREVIOUSLY COMPLETED HANGERS INSTALLED BY PSM HAVE/WILL BE INSPECTED FOR PROPER MATERIAL AND CONFORMANCE TO DESIGN DRAWINGS AND SPECIFICATIONS.
(1426A)
\\ ~'
HVAC CORRECTIVE ACTION PROGRAMS C.
HVAC DUCT STIFFNER AND FITTING DETAIL PROBLEM:
IN FEBRUARY 1982, IT WAS DETERMINED THAT SHOP WELDING OF PSM HVAC DUCT STIFFNERS WAS NOT PER DETAILS.
IN JUNE 1983, IT WAS DETERMINED THAT CERTAIN SHOP-FABRICATED DUCT FITTINGS WERE NOT FABRICATED IN ACCORDANCE WITH APPROVED DESIGN j
DOCUMENTS.
C.A.P.:
PSM WAS DIRECTED TO CONDUCT REINSPECTIONS AND/0R REPAIRS ON ALREADY INSTALLED DUCTWORK.
SUMMARY
DUCTWORK STIFFNER WELDING AND DUCT FITTINGS WILL
]
BE BROUGHT INTO CONFORMANCE WITH APPROVED DESIGN DRAWINGS.
a (1426A)
1.E. INSPECTION REPORT 83-09
SUMMARY
- JULY 6. 1984 RESPONSE 1.
COMMONWEALTH EDISON COMPANY CONTINUES TO BELIEVE THAT HVAC PROGRAMS AND PROCEDURES, AT THE TIME OF THEIR APPROVAL, WERE ADEQUATE TO ASSURE THE QUALITY OF COMPLETED CONSTRUCTION WORK.
2.
PULLMAN SHEET METAL HAD IN PLACE THE NECESSARY UPFRONT PROGRAMMATIC CONTROLS TO CONTROL HVAC WELDING ACTIVITIES CONSISTENT WITH HVAC SYSTEM REQUIREMENTS AND INDUSTRY STANDARDS.
3.
PROGRAMS AND PROCEDURES WERE SUBSEQUENTLY REVISED TO PROVIDE BETTER DETAILED DOCUMENTATION OF HVAC CONSTRUCTION i
AC11VITIES.
l (1426A)
~
I.E. INSPECTION REPORT 83-09 HVAC OA PROGRAM CONTROLS 1.
HVAC QA PROGRAM DID NOT HAVE ADEQUATE POLICIES, PROCEDURES OR INSTRUCTIONS FOR CONTROLLING FIT-UP AND WELDING.
JULY 6, 1984 RESPONSE STATED COMMONWEALTH EDISON'S POSITION THAT PROGRAMMATIC CONTROLS PROVIDED WERE ADEQUATE TO CONTROL WELDING ACTIVITIES.
THESE CONTROLS INCLUDE:
A.
USE OF QUALIFIED AND TRAINED WELDERS.
B.
USE OF QUALIFIED AND APPROVED WELDING PROCESSES AND PROCEDURES.
C.
USE OF CERTIFIED MATERIALS IN ALL CASES.
D.
INDEPENDENT VERIFICATION OF WELDER TRAINING AND QUALIFICATION.
E.
USE OF MINIMAL NUMBER OF WELDING PROCEDURES.
F.
NO PROBLEMS OBSERVED DURING THE LIMITED NUMBER OF IN-PROCESS WELDING INSPECTIONS WHICH WERE PERFORMED.
G.
FINAL VISUAL WELD INSPECTION BY PSM QUALITY CONTROL.
H.
OVERVIEW INSPECTIONS BY INDEPENDENT TESTING l
LABORATORY.
CONCLUSION:
REASONABLE ASSURANCE EXISTS TO SHOW THAT PAST WORK WAS PR0 GRAMMATICALLY CONTROLLED AND RESULTED IN QUALITY WORK.
(1426A)
I.E. INSPECTION REPORT 83-09 HVAC OA PROGRAM CONTROLS - WELDER TRAINING ASPECTS OF PSM WELDER TRAINING:
1.
MATERIAL SPECIFICATIONS 2.
WELDING PROCESSES 3.
POSITION OF WELDING 4.
FILLER METAL CLASSIFICATION 5.
SINGLE OR MULTIPLE PASS REQUIREMENTS 6.
WELDING CURRENT 7.
POLARITY 8.
WELDING PROGRESSION 9.
PRE-HEAT AND INTERPASS TEMPERATURE 10.
ELECTRODE SIZE 11.
AMPERES RANGE 12.
VOLTAGE RANGE 13.
TYPE OF JOINT DETAIL TRAINING DOCUMENTATION HAS BEEN INDEPENDENTLY VERIFIED.
1 (1426A)
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.PULLARD SHEET i
P mETRL WDRMS,IllC.
l400 E ASI 97tH PLAct.CHICMO,lLLIh01$ 60628.312 / 374 6700 i
QUALITY ASSURANCE PROGRAM I
WELDERS TRAINING On EBRUARV b. N8I IERRw Hotono
( Pr*30.h received training in the use of the PSM-LdP7to-301 REV. 4 approved welding procedure. At a minimum, the welder was trained to identify the following f
areas of the approved procedures I
Material Specification Welding Process l
Position of Welding Filler Metal Classification Single or Multiple Pass Welding Current Polarity Welding Progression Preheat and Interpass Temperature slectrode Size Amperes Range Voltage Range Type of Joint Detail kld/sJ 4-M -RI e
WamsR mrs MJ A-M-BI F
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I.E. INSPECTION REPORT 83-09 WELD FILLER METAL CONTROL 1.
E-7018, E-308 & E-309 CERTIFIED WELD MATERIALS HAD CONTROLLED ISSUANCE c-u>n 2.
ER-705-2, E7-T-GS WIRE.ARCUSI-A, ER-308 & ER-309 CERTIFIED WELD MATERIALS DID NOT HAVE CONTROLLED ISSUANCE l
3.
DOCUMENTED EVIDENCE IS LACKING SHOWING TYPE OF FILLER l
METAL USED ON EACH COMPONENT.
l AUGUST 31, 1984 SUPPLEMENTAL RESPONSE STATED BASIS FOR CONFIDENCE IN EXISTING WELDS
^
A.
ALL PSM CARBON STEEL ELECTRODES HAVE' 70 KSI OR GREATER TENSILE STRENGTH.
B.
QUANTITIES PURCHASED ARE TOTALLY CONSISTENT WITH WORK SCOPE NEEDS.
C.
NO CASES HAVE EEEN IDENTIFIED DURING 100% VISUAL WELD INSPECTIONS OF SILICON BRONZE MISAPPLICATION.
D.
NO EVIDENCE OF STAINLESS STEEL FILLER METAL MISAPPLICATION HAVE BEEN IDENTIFIED AFTER CONDUCTING A STATISTICALLY BASED SAMPLE INSPECTION PROGRAM.
CONCLUSION:
REASONABLE ASSURANCE EXISTS.T0 SHOW CORRECT FILLER METAL IS IN PLACE FOR EXISTING WELDS.
(1426A)
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PULLERD SHEET f
mETEL LUDBM5, IDE.
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OUALITY ASSURANCE PROGRAM hir! cuoa < 2 DATE:
O " / Q. "7 Q PROJECT:
- INDICATES PORTABLE ROD OVEN USED OVEN I.D.# MM-I TEt#ERATURE N [d I. TYPE ROD HEAT NO.
OVEN TEiB NO.
THIS OVEN ISSo ESLDER STN.:i' NO.
ROD SIZE NO.
RODS KO.
ISSUED RODS RTND.
NO.
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INSPECTION REPORT 83-09 UNVERIFIABLE FIT-UP CHECKS 1.
FIT-UP CHECKS PRIOR TO WELDING WERE NOT COMPLETED FOR WELDS UNVERIFIABLE AFTER WELDING.
JULY 6 & 23, 1984 RESPONSES STATED COMMONWEALTH EDISON POSITION AND PROPOSED CORRECTIVE ACTION FOR PREVIOUSLY COMPLETED WORK.
A.
PROGRAMMATIC CONTROLS PROVIDED WERE ADEQUATE TO i
CONTROL WELDING ACTIVITIES INCLUDING ENSURING l
PROPER FIT-UPS BY CRAFT PRIOR TO WELDING.
, p-B.
ONLY ONE (1) DUCT HANGER.HAS BEEN COMPLETED WHOSE CONFIGURATION MAKES FIT-UP UNVERIFIABLE AFTER THE FACT.
AN NCR HAS BEEN WRITTEN REQUESTING ENGINEERING DISPOSITION.
C.
TWO (2) FAN BASE WITH 4 LEGS / BASE HAVE ALL AROUND FILLET WELDS.
WELDS WERE MADE IN FABRICATION SHOP.
FABRICATION CONTROLS ARE DEEMED ADEQUATE TO ENSURE PROPER FIT-UP.
D.
ANGLE SPLICE ALTERNATE DETAILS ARE FULL PENETRATION WELDS.
WELDS WERE INSPECTED DURING 100% WELD REINSPECTION PROGRAM.
NO EVIDENCE OF IMPROPER FIT-UP WAS FOUND.
CONCLUSION:
REASONABLE ASSURANCE EXISTS THAT INSTANCES OF COMPLETED WELDS WITH UNVERIFIABLE FIT-UPS MEET ACCEPTABLE QUALITY STANDARDS.
.(1426A)
LE. INSPECTION REPORT 83-09 DOCUMENTED INSTRUCTIONS FOR QA INSPECTORS - 3/16" FIT-UP GAP 1.
DOCUMENTED INSTRUCTIONS SAID INSPECT FOR FIT-UP GAP AND 3/16" GAP WAS ACCEPTABLE.
2.
DOCUMENTED INSTRUCTIONS TO QC INSPECTORS DID NOT STATE FILLET WELD LEG SIZE MUST BE INCREASED FOR GAPS GREATER THAN 1/16" UP TO 3/16" GAP PER AWS Dl.1-1977.
JULY 6 & 23, 1984 RESPONSES STATED COMMONWEALTH EDISON POSITION RELATIVE TO FIT-UP INSPECTIONS OF PREVIOUSLY COMPLETED WORK.
A.
PROGRAMMATIC CONTROLS PROVIDED WERE ADEQUATE TO CONTROL WELDING ACTIVITIES INCLUDING ENSURING 4
PROPER FIT-UPS BY CRAFT-PRIOR T0 WELDING.
B.
ALL PSM QUALITY CONTROL INSPECTORS HAD BEEN INSTRUCTED IN THE AWS CODE REQUIREMENTS TO INCREASE FILLET WELD LEG SIZE FOR GAPS GREATER THAN 1/16" UP TO 3/16" GAP AND WERE AWARE-OF THESE REQUIREMENTS DURING B 10.2.F INSPECTIONS.
C.
PSM HAS REINSPECTED 100% OF FIELD WELDS PREVIOUSLY MADE, INCLUDING INSPECTIONS FOR PROPER FIT-UP, GAPS AND INCREASED WELD SIZES.
DEFICIENCIES WERE IDENTIFIED ON CORRECTION NOTICES.
CONCLUSION:
REASONABLE ASSURANCE EXISTS THAT PREVIOUSLY COMPLETED WELDS HAVE BEEN INSPECTED FOR PROPER FIT-UP, GAPS AND INCREASED WELD SIZES.
(1426A)
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4c0 l AS1971H PLA01. CHICAGO. lLLih0i5 60628. 312 / 274 (10; A t / C S I <N
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Electrode Type G Size 4 7( 5' -
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COMPLETE ( v)
ACC DEF N/A COMMENTS 1.
Surface preparation.
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Joint fit-up.
3.
Backing strip.
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V 5.
Weld profile.
V 6.
Free of defects.
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7.
Surface appearance.
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8.
Welder I.D.
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9.
Tools used by inspector:
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INSPECTION REPORT 83-09 l
MELDING PROCEDURE SPECIFICATION 1.
SPECIFICATION OF WELDING PROCEDURE.BY CRAFTSMAN.
2.
NO QC VERIFICATION DURING THE INSTALLATION PROCESS THAT ACCEPTABLE-WELDING PROCEDURES WERE EMPLOYED FOR EACH HVAC INSTALLATION.
i DECEMBER 20, 1983 ENFORCEMENT CONFERENCE PRESENTATION AND IN JULY 6, 1984 RESPONSE STATED COMMONWEALTH EDISON POSITION THAT REGULATORY REQUIREMENTS AND INTENT OF AWS CODE WERE COMPLIED WITH DURING PSM WELDING ACTIVITIES.
A.
ALL PSM WELDERS WERE TRAINED IN THE PSM WELDING PROCEDURES.
B.
THE ASSIGNMENT OF APPLICABLE WELDING-PROCEDURES WAS A SIMPLE DETERMINATION.
C.
MARCH 1978 TO SEPTEMBER 1979 (SHUTDOWN) - PSM USED ONLY TWO (2) WELDING PROCEDURES (1-7018 STICK, 1-SILICON BRONZE).
D.
APRIL 1980 TO AUGUST 1983 - PSM USED 9 WELDING PROCEDURES.
A.
1 WELDING PROCEDURE FOR HANGER WORK -
SINGLE PROCEDURE FOR HANGER WORK THROUGHOUT JOB DURATION.
B.
4 PROCEDURES (SILICON BRONZE, 6013 STICK, l
MIG) FOR DUCT TO HANGER OR SEAL WELDING.
C.
2 STAINLESS STEEL PROCEDURES - 5% OF WORK.
D.
2 MIG PROCEDURES FOR SPECIAL APPLICATIONS.
i E.
NO EVIDENCE OF IMPROPER PROCEDURE USAGE HAS BEEN FOUND BY PREVIOUS INSPECTIONS.
CONCLUSION:
FOR WORK PERFORMED PRIOR TO AUGUST 1983, WELDERS WERE ABLE TO CORRECTLY CHOOSE 1
REQUIRED WELDING PROCEDURE.
-(1426A)
]
- O 1, E. INSPECTION REPORT 83-09 0.C. VERIFICATIONS l'
1.
NO DOCUMENTED Q.C. VERIFICATIONS DURING THE INSTALLATION PROCESS-0F WELDING POSITION OR POLARITY FOR ELECTRODE CLASSIFICATION.
2.
NO DOCUMENTED Q.C. VERIFICATION DURING THE INSTALLATION PROCESS _JHAT ACCEPTABLE WELDING PROCEDURES WERE EMPLOYED FOR EACH HVAC INSTALLATION.
3.
INADEQUATE INSPECTION FREQUENCY TO ASSURE ACCEPTABLE CONFIDENCE LEVCL THAT THE WELDERS WERE COMPLYING WITH THE WELDING PROCEDUPE ESSENTIAL VARIABLES.
JULY 6, 1984 RESPONSE STATED COMMONWEALTH EDISON POSITION THAT Q.C. VERIFICATIONS (INPROCESS AND FINAL WELD) MET REGULATORY REQUIREMENTS AND AWS CODE AS WELL AS CECO QUALITY REQUIREMENTS.
1.
IN PROCESS INSPECTIONS PERFORMED BETWEEN FEBRUARY 1983 UNTIL JULY 1983 IDENTIFIED HQ CASES OF IMPROPER WELD PROCEDURE IMPLEMENTATION.
SURVEILLANCES DEMONSTRATED TRAINING GIVEN TO WELDERS WAS EFFECTIVE.
2.
UP-FRONT PROGRAMMATIC CONTROLS IMPLEMENTED BY PSM COUPLED WITH 100% POST-WELD Q.C. VISUAL INSPECTIONS VERIFIED ACCEPTABLE WELDS WERE MADE BY PSM WELDERS.
3.
LIMITED NUMBER OF WELDING PROCEDURES WERE USED BY SMALL NUMBER OF TRAINED WELDERS.
4.
PRIOR TO OCTOBER 1982 Q.C. PERFORMED A POST WELD VERIFICATION OF WELD PROCEDURE USED IN WELDING PROCESS.
5.
QUALITY CONTROL DID PERFORM RANDOM IN-PROCESS QUALITY CONTROL INSPECTIONS THROUGHOUT ENTIRE WORK PERIOD.
CONCLUSION:
FINAL AND IN-PROCESS QUALITY CONTROL i
VERIFICATION MADE OF WELD PROCEDURE IMPLEMENTATION FOR PAST WORK SHOW WORK IS OF ACCEPTABLE QUALITY.
(1426A) mv
1, E. INSPECTION REPORT 83-09 0.C. EXAMINATION OF BASE METAL f
1.
NO Q.C. EXAMINATION OF BASE METAL PRIOR TO WELDING.
JULY 6, 1984 RESPONSE BY COMMONWEALTH EDISON STATED ADEQUATE CONTROLS WERE IN PLACE FOR PREVIOUS WORK TO PRECLUDE USE OF SUBSTANDARD MATERIALS.
A.
PROGRAMMATIC CONTROLS PROVIDED BY PSM WERE ADEQUATE TO CONTROL WELDING ACTIVITIES.
B.
MILD STEEL EDGE DISCONTINUITIES ARE GENERALLY PRESENT IN THICK STEEL MEMBERS.
RESULT FROM STEELMAKING PROCESS.
PSM WELDS IH1R MEMBERS.
C.
RECEIPT INSPECTION IS PERFORMED ON PSM SUPPLIED SHEET AND STRUCTURAL ITEMS.
D.
INSPECTIONS ARE PERFORMED ON PSM SUPPLIED SHEET AND STRUCTURAL ITEMS PRIOR TO SHIPMENT FROM SHOP.
E.
JOBSITE FABRICATED ITEMS ARE SAWCUT, NOT OXYGEN CUT - MINIMIZES LIKELIHOOD OF IRREGULAR EDGES.
CONCLUSION:
REASONABLE ASSURANCE EXISTS THAT SUBSTANDARD MATERIALS WERE NOT USED IN PREVIOUS INSTALLATIONS.
(1426A)
1, E. INSPECTION REPORT 83-09 WELDER I.D. UNKNOWN 1.
WELDER I.D. IS UNKNOWN FOR SPECIFIC WELDS.
JULY 6,+1984 RESPONSE BY COMMONWEALTH EDISON STATED VISUAL WELD ACCEPTANCE PLUS OTHER PROGRAMMATIC CONTROLS (I.E. ALL WELDERS QUALIFIED) WAS SUFFICIENT BASIS TO DEMONSTRATE AWS CODE COMPLIANCE WHEN WELDER I.D. UNKNOWN.
COMMONWEALTH EDIS0N COMPANY SUBSEQUENTLY AGREED TO ESTABLISH LOST WELDER I.D. FOR AWS D1.1 SAFETY RELATED STRUCTURAL WELDS BY IN PLACE PHYSICAL MARKING OR BY OTHER PRODUCTION OR QUALITY TYPE RECORDS OR REPLACE WELD.
To DATE (2/11/85), PSM REVIEWS INDICATE 35 REMAINING AWS D1.1 WELDED ITEMS REQUIRE FURTHER INVESTIGATION OR REWORK TO ESTABLISH WELDER I.D.
THIS EFFORT WILL BE COMPLETED PRIOR j
TO MARCH 29, 1985.
COMMONWEALTH EDISON COMPANY /PSM REVIEW OF LOST WELDER I.D.
FOR AWS D1.3 SHEET METAL WELDS IS STILL IN PROGRESS.
SINCE THE HTD AND COMPANION ANGLE WELDS ARE SINGLE PASS FILLET WELDS, FINAL VISUAL INSPECTION OF THE COMPLETED WELD PROVIDES ADEQUATE ASSURANCE THAT THE WELDER WAS QUALIFIED TO PERFORM THIS PROCESS.
CONCLUSION:
PSM WILL ESTABLISH WELDER INDIVIDUAL I.D. FOR AW5 D1.1 CODE COMPLIANCE.-
WELDER IDENTIFICATION FOR AWS D1.3 MAY BE ESIABLISHED BASED ON ALL WELDERS PERFORMING WORK WERE QUALIFIED.
(1426A)
I.E. INSPECTION REPORT 83-09 MULTI-PASS WELDING 1.
REGION INSPECTOR REQUESTED ADDITIONAL ASSURANCE IN THE AREA 0F MULTIPASS WELDING.
AUGUST 31, 1984 SUPPLEMENTAL RESPONSE STATED ADDITIONAL ASSURANCE MEASURES WHICH WE UNDERSTOOD WOULD SATISFY NRC CONCERNS THAT COMMONWEALTH EDISON COMPANY WILL TAKE FOR PAST WORK INVOLVING AWS MULTIPASS WELDING.
A.
PULLMAN SHEET METAL WILL PERFORM A REVIEW 0F THE CORRECTION NOTICES GENERATED PRIOR TO THE IMPLEMENTATION OF IN-PROCESS WELDING INSPECTIONS IN ORDER TO IDENTIFY WELDERS WITH A HIGH REJECTION RATE.
B.
PULLMAN SHEET METAL WILL IDENTIFY THE HANGERS THAT WERE WELDED BY THE IDENTIFIED WELDERS WITH HIGH REJECTION RATES.
C.
THESE HANGERS WILL BE REVIEWED TO IDENTIFY THE EXISTENCE OF ANY MULTIPASS WELDS.
D.
THE IDENTIFIED MULTIPASS WELDS WILL THEN BE MAGNETIC PARTICLE INSPECTED TO PROVIDE ADDITIONAL ASSURANCE BEYOND THE FINAL VISUAL EXAMINATION AS TO THE ACCEPTABLE QUALITY Of THE COMPLETED WELDS.
CONCLUSION:
REASONABLE ASSURANCE WILL EXIST THAT PREVIOUSLY MADE AWS MULTIPASS WELDS ARE 0UALITY WELDS.
(1426A)
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Common obith Edison one First National Plaza, Chicago, minois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 PRIORITY ROUTING h$#gj{N April 8, 1985 j_
M uxS r.L ta D@.1 Mr. JPmes 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 Corrective Action Programs NRC Docket Nos. 50-456/457
Dear Mr. Keppler:
In early March, 1985, Mr. L. O. De1 George of Commonwealth Edison, in a discussion with Mr. Bert Davis of your s,taff, agreed to provide an update of the current " top twenty" corrective action programs at Braidwood.
The purpose of this letter is to provide a summary of each of these programs including a description of actions taken or planned, the current status of such actions, and expected completion dates where available.
The programs summarized on the attachments have been selected for special attention at Braidwood.
The selected programs are subject to change as issues are resolved or new issues arise.
Please address any questions that you or your staff may have concerning this matter to this office.
hyytruly
- urs, dd David H. Smith Nuclear Licensing Administrator
/klj cc: NRC Resident Inspector - Braidwood
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Braidwood Corrective Action Program ASE Material Procurement ER-655 50.55(e)'84-16 A sample review of records of past site-procured ASiE material revealed that the records do not always indicate that the material was supplied in accordance with the ASE Material Manufacturers and Material Suppliers Quality System Program requirements. Program statements or ASME Quality System Certificates are not always referenced on the documents received with the material.
The problem with the records was partially identified in 1981 but adequate measures were not established to control the materials and provide complete corrective action to the identified records. An initial review has indicated the following inadequacies which have contributed to the problem:
1.
Quality requirements not included on site procurement records.
2.
Inadequate documentation reviews during receipt inspections.
3.
Inadequate corrective action for ASE material suppliers removed from CECO Approved Bidder List.
4.
Procurement of ASE material from vendors with only Safety-related Approved Programs.
Based on initial revien of the records, site-procured ASE materials received prior to October 27, 1981, which were still in stock were put on hold. Project Procedure PFE-100-1 was approved for the review of the site-procured ASE material documentation.
Essentially all documentation for materials received prior to October 27, 1981, has been reviewed. At this time, the documentation review for materials received since October 27, 1981, is still in progress. It is estimated that the entire review effort is over 905 complete.
For the records which have been reviewed, approximately 1600 heat / lot nurters out of an estimated 4000 heat / lot numbers require some type of revised or additional documentation from the original manufacturers and/or material suppliers. Materials with questionable documentation received since October 27, 1981 are being placed on hold until the documentation problems are resolved. Of the estimated 4000 heat / lot nutters, approximately 2% require other corrective actions to bring the documentation into conformance with ASE Section III requirements.
Connonwealth Edison Company is working expeditiously with vendors to obtain revised or additional documentation which meets ASE Section III requirements or resolves technical questions. Issue resolution is anticipated by December, 1985.
'(1.1)
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Braidwood Corrective Action Program ASE Nameplates NCR-639 l
50.55(e) 84-12 ASE NPT synt)ol nameplates were removed from piping subassemblies during installation without proper controls and documentation. Nondestructive examinations of the nameplate removal areas, required by ASE Section III, were not subsequently performed.
In addition, the removal of ASE PPT nameplates leaves installed spool pieces without ASE Code-required positive identification. This issue affects 2-1/2 inch and larger piping spools fabricated by Southwest Fabritating and Welding under Sargent & Lundy Specification L-2741.
Phillips Getschow Conpany has developed procedure PGCP-51,
" Verification of Code Nameplate Data and Resolution of Discrepancies." This procedure defines the following corrective actions:
1.
Spools without nameplates will be positively traced using vendor fabrication documentation.
2.
An examination of the spools without nameplates will be performed to locate nameplate removal areas.
3.
Where nameplate removal areas have been located, ASE Section III required nondestructive examination will be performed and pipe wall thickness measurements will be made.
4.
Any required repair to the nameplate removal area will be performed per established procedures.
5.
With the concurrence of Commonwealth Edison Co. and the Authorized Nuclear Inspector, replacement identification plates will be attached to the installed spool pieces.
6.
Spools for which the nameplate removal area can not be located will be dispositioned on a PGC0 Nonconformance Report which will be submitted to Commonwealth Edison Company for disposition on a case-by-case basis.
Spool identification was conducted as part of the Material l
Verification Program. A list is being developed by Phillips, Getschow Company of isometric drawings not within the scope of MTV. Piping not within the j
scope of MTV that was not subject to installation procedures to properly control removal of NPT nameplates will have a separate visual exam to verify j
nameplate attachment.
As of March 1, 1985, 480 spools with missing nameplates have been identified. It is projected that the total population of deficient spools will be about 600. Field verification actions relative to the identified spools are in progress. A completion date of October 1,1985, is currently projected for this program.
(2.1)
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Corrective Action Program Corroded Pipe PCR-633R1 50.55(e).84-10 Initial inspections of two-inch schedule 80 carbon steel pipe, Heat Nunber KD6751 purchased as ASME Class II, determined that approximately 25% of the pipe in storage had wall thicknesses less than that required by the ASTM material specification. The reduced wall thickness, which is primarily present as pits and grooves, apparently is the result of excessive corrosion.
This pipe was stored outdoors for an extended period of time after receipt in 1977. In 1981, corroded conditions were observed in the field and the pipe was subsequently chemically cleaned and stored indoors. The chemical cleaning process was purchased as a non-safety related standard commercial service.
l Specific chemical cleaning procedures were documented, however, and incorporated into the purchase order.
l Other lots of small bore safety-related carbon steel pipe were received in bulk quantities during the same time period (1977) and also subjected to prolonged outdoor exposure. A large quantity of this pipe suffered excessive corrosion and was chemically cleaned along with Heat Number KD7651. Continuing investigations by Commonwealth Edison Company have indicated that the wall thickness problem is not confined to Heat Number KD6751. Consequently, all small bore safety-related carbon steel pipe, which was stored outdoors for extended periods, has been categorized as suspect pending further evaluations. Nine heats of material (ten size / schedule combinations) are affected. Quantities of the suspect pipe have been installed in various plant systems including Class B, C and H safety-related systems.
Commonwealth Edison Company NCR 633 (Rev. 1) was written to track issue resolution. All suspect pipe in storage has been placed on hold pending the dispositioning of installed pipe.
A corrective action program has been developed by Commonwealth Edison Company and Sargent & Lundy to disposition the subject pipe that has been installed. The corrective action program includes the following elements.
1.
Laboratory testing to verify the design significant properties of the suspect pipe.
4 2.
Analysis to evaluate the effect of prolonged outdoor storage and subsequent chemical cleaning.
3.
Measurement of the actual wall thickness of samples of suspect pipe taken from both installed pipe and pipe on hold in storage.
(3.1) u
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4.
Analytical analysis of laboratory testing results and pipe-wall thickness measurements to determine the acceptability of installed l-piping relative to ASE Section III design requirements.
i As of March 1,1985, the laboratory testing program has been completed. A final report is being prepared for evaluation by PED /S&L. The procedure for selecting pipe sanples and thickness measurements has been developed and has received interim approval. Pipe inventories are being taken to support sample selection and subsequent thickness measurements. Program completion is expected by July 1,1985, at which time the extent of rework, if any, will be identified.
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(3.2) i
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O Braidwood Corrective Action Program Material Traceability verification PCR-541' 50.55(e) 83-07 At the time of issue identification, Phillips, Getschow Company Procedure QCP-821, Installation and/or Field Routing of Two Inch and Under Process Piping Systems - ASE Classes 1, 2 and 3, established the procedural controls for inspection and verification of correct small bore process piping material.
Phillips, Getschow Company Audit No. 83-8R3 (April 26, 1983) identified a Finding that the verification of different heat numbers on the Production drawings w,as not completed in cases where more than one heat nuder per drawing was being used. In response to NRC concerns related to material traceability deficiency re, port in July,1983. Commonwealth Edison Company filed a potentia control verification of heat or mark nu@ers of installed piping systems not adequately documented.
of Code small bore material heat numbers on drawings. Procedure Specifically, the Quality Control inspector would verify all entries of traceability nu@ers made by Production and this verifIcatlon would be documented by initial and date.
In order to establish a level of confidence that material traceability exists for previous Code small bore piping installations, Phillips, Getschow Company began traceability verifications in August,1983.
This verification was based on random samples of previously installed Code small bore piping.
Standard MIL-STD-1050.The samples were selected in accordance with Military The preliminary results of the sample inspection program were reviewed by NRC personnel as documented in the MC Inspection Report Nos.
50-456/83-09 and 50-457/83-09.
The sample inspection program identified a small nu4er of cases in which installed piping material was not in compliance with design requirements. Additionally, a Commonwealth Edison Site QA Audit 20-83-33 dated July 15, 1983, identified a case in which installed piping material was of a code class different from that required by the design.
result of the sample inspection program and subsequent discussions with NRC As a Yerification (MTV) Program. personnel, CECO developed the Piping Heat Num (4.1) w -
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The scope of the MTV Program includes ASME small bore piping installed prior to August 31, 1983, and ASE large bore piping installed prior to Nove@er 30, 1982. (Documentation of the verification of material traceability by CC personnel has been generated for piping installed subsequent to these dates.) This Program will ensure that the installed material is traceable and that the material is in accordance with design requirements.
Program Details are contained in Phillips-Getschow Procedure QCP B31.. The procedure requires completion of the following steps:
1.
A material verification field walkdown on 100% of previously installed piping will be completed. The material heat nueer will be recorded and/or verified by a Quality Control inspector. A check will be made to ensure that the field verified heat nueer is approved for use at Braidwood Station.
2.
A Quality Control verification will be made of field verified material heat numbers against the heat nu 2 ers recorded on the Stores Request for'each installation package. This verification will establish that material withdrawn from Stores was installed in the correct location.
3.
A Quality Control verification will be made of field verified material heat numbers to ensure that'the correct meterial is installed for the specific application.
4.
For those cases where meterial heat merkings are no longer available in the field, a Quality Control review will be made of the Stores Request to verify that the material was approved for use at Braidwood Station and was the correct meterial for specific anplication.
As of March 1,1985, all field inspections and verifications are complete. Phillips, Getschow is in the process of compiling, sorting and reviewing all data prior to turnover to CECO. Nonconformance reports have been written to disposition unvarified material. In conjunction with nonconformance resolutions, a procedure for heat nueer verification via chemical sampling is being developed.
(4.2)
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Braidwood Corrective Action Program CEA Inspections PCR-658 50.55(e)-84-17 A review of the Braidwood Station Contractor Programs for concrete expansion anchor (CEA) installations has revealed that:
1.
The number and types of attributes considered significant to the quality of a CEA installation and verified by Quality Control personnel are not consistent with those observed in CEA Installation Programs at our LaSalle County and Byron Stations.
2.
A small nunt)er of those attributes considered significant to the quality of a CEA installation have not been verified by Production and/or Quality Control personnel.
3.
An apparent trend exists of CEA installation rejections by the Quality Assurance Department's Independent Inspection Agency for -
attributes they have inspected.
The procedures affecting the installation of Concrete Expansion,
Anchors for the four contractors performing Safety Related installations >
(Phillips Getschow Co., L. K. Comstock, G. K. Newberg and Pullman Sheet Metal) have been revised to include increased Production verification and Quality Control verification of all attributes considered significant to the quality of a CEA installation.
In an effort to provide assurance that future CEA installations will be installed, inspected and documented in a consistent manner, the Commonwealth Edison Company, in conjunction with Sargent & Lundy, has developed a generic procedure for the installation and inspection of CEA's. (,
This generic procedure includes recomendations of The. Institute of Nuclear Power Operations (IPO) contained in IWO Good Practice (Draft) -
" Installation of Concrete Expansion Anchors". This procedure, PCO-08 "On Site Contractor Installation and Inspection of Concrete Expansion Anchors", was transmitted to the contractors performing CEA installation activities for implementation on March 4, 1985.
In an effort to ascertain the quality of past CEA work, a sampling reinspection program is under development which will determine if the lack of Quality Control involvement in CEA activities has resulted in nonconfortring installations. A new procedure, PCD-30, " Evaluation of Concrete Expansion Anchor Installations", has been distributed to applicable site contractors.
Sample populations are currently being selected based on lists of prior
\\,
installations supplied by the Contractors.
It is anticipated that reinspections will be initiated in April.
(5.1)
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Braidwood Corrective Action Program o'.
CEA's In Repaired Areas
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,a ICR-634 50.55(e) 84-07.
4 Contrary to Sargent and Lundy Specification BY-BR-CEA, Section 3.1.9, the ent>edment length of Concrete Expansion Anchors (CEAs) installed through surface repaired concrete extending beyond the reinforcing steel cover was not increased by the "X" dimension shown in figure 38-5 (X= thickness of concrete cover plus nominal diameters of outside reinforcing steel). As a result, CEA installations have anchor embedment lengths which are potentially less than the required minimum.
For new installations in surface repaired concrete areas, all contractors installing CEAs were sent a set of drawings showing major patches (repairs to areas which had exposed rebar). As any new major patches are made, revised drawings are being transmitted to all CEA installation contractors. Additionally, major patched areas have been physically demarcated.
For previous installations in surface repaired concrete areas, Sargent & Lundy completed a walk down in order to map the size and location and to determine the acceptability of previous CEA installations. Walkdown results are currently being evaluated. When evaluation of the walkdown results is finished, a completion date will be determined.
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Braidwood Corrective Action Program CEA's In Finished Slabs PCR-617 50.55(e).84-07 Contrary to Sargent and Lundy Specification BY-BR-CEA, Section 3.1.5.
the embedment length of Concrete Expansion Anchors (CEAs) installed in finished slabs was measured from the elevation of the finished floor rather than from that of the rough concrete. As a result, CEA installations have anchor embedment lengths which are potentially less than the required minimum.
For new installations in finished floors, all contractors installing CEAs have been instructed to notify Sargent & Lundy and obtain the correct embedment length prior to installation.
For previous installations in finished floor areas, Sargent & Lundy completed a walkdown of the finished floor areas in order to map the size and location, and to determine the acceptability of previous CEA installations.
Forty-five installations were identified during the review of the data obtained during the walkdown. Even though none were of deslyn significance, they are currently being reworked in accordance with Sargent and Lundy requirements. Completion is expected in June, 1985.
l l
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Braidwood Corrective Action Program Welded and Bolted Connections - Block Wall Columns NCR-434 -
50.55(e) 82-10 During a Site Quality Assurance review of ccntractors' work procedures, it was determined that inadequate provisions exist to ensure bolt torque and weld inspection for structural steel installation. The provisions for performing the structural steel installation were found to be generally adequate. The deficiency is limited to G. K. Newberg's installation of blockwall columns and miscellaneous structural steel in the Auxiliary Building.
All accessible welded and bolted connections which had missing QC inspection records have been either QC inspected and accepted, or have been repaired and QC accepted.
A review of installation inspection records identified a total of 2436 inaccessible welded e d bolted connections with missing inspection records. The block walls nave been removed from around a sample of 180 inaccessible bolted and welded connections and the connections have been inspected and evaluated by Sargent & Lundy. The types of discrepancies found during the sample inspection program include:
(1) AWS weld quality deficiencies such as overlap, undercut, included slag, fit-up gaps, undersize welds; (2) incomplete welds; (3) bolting deficiencies such as bolt locations in the slots and width of slots; (4) member and connection angle size changes; and (5) expansion anchor embedment lengths. None of the inspected connections were determined to have discrepancies with design significance (i.e., design margin remains within specified limits and code allowable stresses).
Commonwealth Edison Company has decided to repair or upgrade and inspect all inaccessible connections with inadequate records. One of the reasons for this decision is that Byron loads were used in the evaluation for design significance. The actual Braidwood loads, when they become available near completion of construction, may in some cases be greater than the Byron loadings. From a construction standpoint, it is more prudent to make modifications now, and upgrade the walls to increase design margins, rather than making modifications shortly before fuel load when the actual Braidwood loadings become available.
There are 83 miscellaneous structural beam connections embedded in concrete and/or masonry. Of these, nine connections do not require inspection or rework since the beam reaction can be transferred directly to the concrete wall in which they are embedded. Thus, these connections were required only during construction. The remainder of the beam connections will be included in the inspection and rework program.
(8.1)
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O While performing the sample inspections, it was also noted that some shop welds on the blockwall columns had some discrepancies similar to those found for field welds. Sargent & Lundy developed a sample inspection program to address the adequacy of blockwall column shop welds. Blockwall columns were supplied by American Bridge, Mid City, or Ramco. The inspections were performed as part of the inspection and rework program for field welds. Those shop weld discrepancies were evaluated by Sargent & Lundy for engineering
-significance and none was found.
Inspections, rework, and/or modifications of the field installations without inspection records and examination of the shop welds are being performed in accordance with Gust K. Newberg Procedure 57. There are approximately 1050 inaccessible menbers to be resolved. As of March 1, 1985, 473 menbers have been exposed and_ inspections are ongoing. It is anticipated that Unit I related work will be complete by Septenber,1985.
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l Braidwood Corrective Action Program HVAC Installation Tolerances NCR-460R1 50.55(e)*83-01 A number of HVAC safety-related hangers, auxiliary steel, and_ bracing were not installed in accordance with dimensional tolerances and typical details as shown on the Sargent and Lundy design drawings.
The following actions were taken to resolve this issue:
1.
The Pullman Sheet Me'tal procedure addressing configuration inspection of all hangers, auxiliary steel, and bracing was revised.
2.
Design tolerances were clarified ard additional tolerances were provided in order to achieve proper installation and inspection of the HVAC system.
3.
Safety-related HVAC field installation work is being inspected in accordance with the revised inspection procedure to insure compliance with design details and tolerances.
4.
A backfit program has been established for the inspection of hangers, braces and auxiliary steel installed prior to the implementation of Pullman's revised configuration inspection procedure.
The total scope of the backfit program involved 1676 hangers, 918 auxiliary steel components, and 228 braces (2822 total). Reinspections identified 813 items which required rework. As of March 1, 1985, 611 items remain unresolved.
(9.1)
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Braidwood Corrective Action Program NSSS Supports NCR-489 50.55(e).83-03 As a result of reviewing the as-built locations of Unit 1 and 2 Steam Generators and Reactor Coolant Pump Support Columns (NSSS), it was determined that the locations exceeded the tolerances shown on S&L drawing S-1105.
3&L revised drawing S-1105 to incorporate tolerances based on the functional requirements of the NSSS components. Based on the review of. field verification data, it has been determined that all subject component installations are adequate. FCR's developed in association with acceptance of the reactor ccolant pumps were approved in June, 1984. One FCR (17027) was required for Steam Generator acceptance. This FCR is currentlj at PCD for approval.
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1 Braidwood Corrective Action Program Southwest Fab Radiographs PCR-606 During the NRC Mobile Van Inspection at Braidwood, Radiographs for ASE Section III Code piping supplied by Southwest Fabrication were found to have degraded film quality due to improper processing. The yellowed film was not acceptable for ASE extended archive storage requirements. This issue was an Item of Noncompliance in Inspection Report 84-05 (Item No. 84-05-08).
In order to prevent recurrence, Pittsburgh Testing Lab is performing testing of film for archive quality on a daily sample basis. Additionally the radiograph turncver Procedure SQI-24 was revised to require sample checking for film yellowing caused by inadequate fixer removal prior to turnover to the Station.
The initial S & L disposition of NCR-606 consisted of:
1)
Review of sample of film for visjble yellowing and 2)
Determination of potential for future deterioration by chemical testing.
3)
Corrective actions to be based on results of Items #1 and #2 The preliminary review for visible yellowing was completed with 553 welds consisting of 2500 views. Five views associated with five (5) different welds were found to exhibit sign of visible yellowing represents two-tenths of one percent (0.2%). (It should be noted that the recent CAT inspection included a review of approx.160 Southwest Fab welds with no visible film yellowing noted.)
' The chemical testing referred to in Item 2 of the recommended disposition was found to be unsuitable for determination of the potential for future deterioration. An alternate test is available; however, it requires destruction of a sample cut from the film. This is felt-to be an unacceptable alternative.
As a result of the limitations encountered with the options for determining and dispositioning the yellow film issue, CECO intends to rewash Southwest Fabrication radiographs and return to file. Any film found to exhibit conditions which render the film uninterpretable will be reshot as required to comply with Code requirements. The current completion date is projected for July, 1985.
(11.1)
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o-o Braidwood i~
Corrective Action Program
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PTL Radiograph Density NCR-609-R1 50.55(e).84-04 This issue is associated with radiographs which were originally reviewed / interpreted;by the Site Independent Testing Agency, Pittsburgh 3
Testing Laboratory (PTL). The issue developed when, upon re-review of radiographic film representing pipe weldments, it was noted that certain views I
.of the film contained out of tolerance densities. The initial discrepancy was i
found in a limited number of field-shot, site evaluated radiographs.
Preliminary investigation seemed to indicate that one individual was responsible for the questionable density interpretations for radiographs taken prior to Septenber,1979 (July,1976 to construction shutdown). Reviews of radiographs shot prior to Septenber,1979 also indicated the presence of some marginal interpretations of film indications.
The re-review of film was then expanded to include all film interpreted.by the questionable reviewer through 1980, and a sample of. film reviewed by all others through 1980. The results of the expanded review i
indicated that the problem radiographs dated only from the July 1976 to i
September, 1979 period. The following tabulation identifies, by contractor, the total population of radiographs requiring investigation.
l 1)
Production Radiographs (Phillips, Getschow) 974 2)
Phillips, Getschow Welder Qualifications 279 3)
G. K. Newberg Welder Qualifications 19 4)
Power Systems Inc. Welder Qualifications 84 i.
5)
Universal Power Piping Welder Qualifications 2
Total
'"I3M The re-review conducted by qualified Level II and/or III Interpreters, as necessary, has yielded the following results:
4 i
1)
Of the 965 production radiographs reviewed for both density concerns
~
1 and quality related indications, 104 were not accepted. The current status of these 104 radiographic packages indicates that 59 have been f
repaired and/or re-radiographed to comply with Code requirements.
2 Approximately 30 remain that are accessible for radiography and PGCo Q.C. is~ preparing these welds for radiography. Approximately 20 are on the Unit 2 Containment spray header which is currently e
l inaccessible.
The 9 additional production radiographic packages needed to account-for all 974 radiographic packages have yet to be located.'
Consequently, Commonwealth Edison Company has directed PTL to re-radiograph these 9 welds and provide results to Commonwealth Edison _ Company. These actions are also underway.
(12.1) m
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2)
In regard to the 279 Phillips, Getschow welder qualification packages, all have been re-reviewed with 62 identified as not acceptable. Commonwealth Edison is currently developing a program to satisfactorily address the rejected Phillips, Getschow welder qualifications.
3)
For G. K. Newberg, 19 welder qualifications required review, with all
.19 found acceptable. As a result of these_ welder qualifications meeting Code requirements, m further action is required.
4)
For the period of interest 84 welder qualifications were radiographed for Powers Systems Inc. Because Power Systems Inc. has completed their scope of work relative to the Braidwood Project, they are no longer on site. Consequently, Powers System Inc. was contacted and requested to provide these radiographs to Commonwealth Edison Company for additional review. The written response from Powers Systems Inc.
indicates that all' welder qualification radiographs have been discarded and were no longer available for review.
As a result, Commonwealth Edison Company will establish if the work performed by Power Systems was safety related or non-safety related.
If the work is determined to be non-safety related, no additional actions need to be taken.- If the work performed is determined to be safety related, the program under development for Phillips, Getschow discussed above will also be used to resolve Powers Systems Inc.
welder qualification packages.
5)
The final contractor qualifying welders by radiography during the subject time frame was Universal Power Piping Inc. Only 2 welder qualifications were performed during this period for work conducted at the Commonwealth Edison Company's Dresden facility. Universal Power Piping Inc., has indicated that these radiographs have been discarded and are no longer available for review. After further investigation with Commonwealth Edison Company personnel at Dresden, it was determined that during the time frame referenced, Universal Power Piping Inc. was only performing work on Dresden. Unit 1.
Because Dresden Unit 1 is currently being decommissioned, no further action needs to be taken.
Issue resolution is contingent on development of a disposition for PGCo and Power Systems Welder Qualification. No completion date is forecast at this time.
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(12.2)
Braidwood J
Corrective Action Program NSSS Support Steel PCR-446 -
4 i
NSSS Support Steel was installed by G. K. Newberg without Q.C.
Inspection. This issue is being resolved by NISCO as a part of the NSSS' backfit program. NISCO procedure ES-3009-CECO-1, which addresses the backfit i
program, requires inspections to verify:
1.
The traceability of all materials installed by G. K. Newberg.
l 2.
Proper location and orientation of NSSS components.
Untraceable or nonconforming materials are written up and tracked by NISCO NCR's. In general, accessible materials without traceability are being replaced. This includes all A-490 bolting. Inaccessible materials are being s
- dispositioned by S&L.
This issue, as of March 1,1985, -is nearing completion ~ with only the 4
replacement of approximately 500 nuts and bolts remaining. Completion-is expected by May, 1985.
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Braidwood Corrective Action Program Electrical Butt Splices NCR-598 -
50.55(e) 84-13 L. K. Comstock procedures did not include the manufacturer's ( AM)
Industries) installation instructions or inspection criteria for conducter extension butt splices. A small sample.(29 total) of the installed butt splices indicated a rejection rate of 38% (11 total). Consequently, the quality of the butt splice installations in this application are suspect.
A program was developed to ensure that all potentially deficient safety related butt splices are identified and inspected. Deficient splices will be repaired and reinspected in accordance with revised installation and inspection procedures. This program also provides for adequate documentation of corrective action activities. Currently, a listing of all cables / equipment potentially utilizing butt splices is being developed using documentation associated with completed and accepted terminations. Training sessions will be conducted for personnel involved in the implementation of the corrective action program. List completion, training, and initiation of inspection activities is anticipated by April 1, 1985. Overall program completion is projected for September,1985.
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Braidwood Corrective Action Program SSIT Document Review 50.55(e) 84-05 An overview of certain G. K. Newberg Structural Steel Installation Traveler-(SSIT) packages has revealed some inconsistencies in the documentation which include: heat numbers that have been changed on the fabrication tickets, recorded length oT welds on weld inspection requests that have been changed, and use of alternate details that were not noted. These changes have been lined out, initialed, dated, and there is no explanation as to why these changes were made.
Document reconciliation will be accomplished thru a review of all SSIT packages generated by Gust K. Newberg. This review will begin upon approval of G. K. Newberg's document review procedure (Procedure 29-1). The procedure is expected to be finalized by April 1,1985. It is anticipated that the SSIT review will take.approximately 3 months.
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(15.1)
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Braidwood Corrective Action Program G. K. Newberg Welding Program PCR-646 50.55(e).84-15 I
A review of. Gust K. Newberg welding has revealed some inconsistencies in the Gust K. Newberg welding program. These inconsistencies can be categorized as 1) Gust K. Newberg engineers specified AWS weld process specifications (WPS) that had not been incorporated into the Gust K. Newberg welding procedure for flux core welding, specified improper WPS's or did not specify WPS's for all joints, 2) Gust K. Newberg ironworkers welded to AWS pre-qualified details that were not approved by Sargent & Lundy for the flux core procedure or were not specified by the Gust K. Newberg Engineer, and 3)
Gust K. Newberg ironworkers listed procedures on traveler packages as being used that they did not use or did not list all WPS's used.
Investigations indicate that the problem is confined to cover plate installations in Unit 1 and Unit 2 Containments, and box beam end connection modifications in the Unit 1 Containment. Based on applicable Structural Steel Traveler Packages (SSIT) reviewed to date, documentation problems occur, in varying combinations, in approximately 82% of the Flux Core Arc Welding (FCAW)
SSIT's and 18% of the Shielded Metal Arc Welding (SMAW) SSIT's.
Commonwealth Edison believes that the problems relate to documentation only and that no associated physical defects exist. This belief is based on the following:
1.
The welders involved were qualified according to Aaerican Welding Society (AWS) to use all welding processes involved.
2.
The weld joints detailed by engineering and installed in the field conform to AWS pre-qualified details.
3.
The welding processes used were pre-qualified by AWS and the size and type of electrodes used were limited, thereby limiting the variables available to the welder.
4.
Electrode wire size, voltage, and amperage parameters are the same for all FCAW and SMAW welds regardless of joint detail or orientation.
5.
All welds were visually inspected and in some cases, Nondestructive-
{
Examinations (NDE) were conducted. No physical defects were identified.
l SSIT review to identify and correct document deficiencies will be part of the Gust K. Newberg final document review program. This program will be conducted in accordance with Gust K. Newberg Procedure 29. This procedure, which is under development, is expected to be finalized by April 1,1985. It is anticipated that the documentation review effort will take approximately 3 j
months.
(16.1)
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Braidwood i
Corrective Action Program HVAC Housings and Air Risers PCR-632 50.55(e) 84-08 The quarter-inch liner plates for the Auxiliary Building Ventilation (VA System) Exhaust Filter Housings and the Unit 1 and 2 Reactor Containment 4
(VP System) Fan Cooler Housings, and eighty-four inch Return Air Risers were not installed by Pullman Sheet Metal (PSM) in accordance with the appropriate drawings and specifications. Welding configurations do not match drawings in i
some cases, and weld quality, inspections were incomplete in some cases.
PSM is in the process of reviewing and organizing existing documentation to identify missing weld quality inspections records. This effort is approximately 15% complete.
In addition to the PSM documentation review, S&L is field verifying and evaluating the as-built conditions of the housings and risers. Following evaluation, S&L is developing sketches and drawings to be used by PSM to conduct the necessary inspections to develop a complete inspection record.
Sargent & Lundy field verification began January 3, 1985.
Tis field verification is being conducted in accordance with normal Sargent & Lundy design /as-built procedures. The field verification is approximately 33%
4 complete for the VA exhaust filter housings and 30% complete for the VP system (RCFC) housings & risers.
As-built drawings for the VA system at elev'ation 451'-0" were issued March 4, 1985. PSM has not initiated configuration / welding quality inspections at this time. The inspection effort will begin shortly after all necessary procedures and. personnel are in place. It is anticipated that the PSM inspections will be complete by October 31, 1985.
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O Braidwood Corrective Action Program i
Duct Fittings 1
ICR-540 50.55(e)-83-08 HVAC duct fittings such as Y-branches, nested elbows, and square-to-rounds were fabricated by Pullman Sheet Metal (PSM).without Sargent i
& Lundy approved design documents or vendor documents. Corrective actions.
include the development of the required documents-and inspections to confirm j
. compliance.
1 PSM revise'd their duct brochure to include generic fabrication details of duct fittings. The revised duct brochure was submitted to S&L for review and was subsequently approved in October, 1983. PSM then initiated i
i evaluations to determine which fittings did not comply with the approved design. Fittings not. in conformance were to be reworked or have their
]
as-built details shown on FCR's and be submitted.to S&L for review.
4 i
As a result of the as-builts developed and subsequent S&L review, l
additional duct. fitting details were incorporated into plant design through ECN generation and follow-up duct brochure revisions. In addition, PSM~
conducted a review of shop fabrication tickets to identify which fittings i
could be confirmed by shop QC inspections to be in compliance with the now-approved design. As of March 1, 1985, PSM Field Engineering personnel have reviewed all fittings for compliance with the revised duct brochure j
and/or S&L approved design drawings..The total number of fittings evaluated was 2,823.
I The evaluations identified 950 fittings which were not in conformance with design. As-builts were prepared for 619 of these fittings and submitted to S&L for review. To date, S&L-has reviewed 552 as-builts and identified 67 i
fittings which require rework. ~S&L's review of the remaining 67 as-builts.
j should be complete by June 1, 1985. The additional 331 fittings identified as l
nonconforming were not,as-built. These fittings will be reworked to achieve design conformance. All reworked fittings will be QC inspected by PSM.
Completion is expected in Decetter,1985.
The fittings'. review by PSM field engineering identified 1873
?'
conforming fittings. A random sample review program to verify-the adequacy of the field engineering review is currently being established. ~ Sample populations will be selected by S&L and inspections conducted by PSM QC.
Completion of the sampling program is scheduled in June,1985.
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Braidwood
]
Corrective Action Program Comstock Document Review i
- 50.55(e)-84-01 1
As early as March,1982, Commonwealth Edison Company Quality.
Assurance audits and the Technical Support Evaluation of September,~ 1982, d
identified deficiencies indicating the need to improve the L. K. Comstock
<*vv=ntation/ filing system.
As a result of identified deficiencies, Commonwealth Edison Company i
i felt that improvements could be made in the areas of:
l.
Timeliness of records retrievability.
2.
Better accountability'of the production records which support the i
Estatus of installation.
l q
3.
Reconciliation of outdated forms.
4 In_ October, 1982, it was determined that progress was poor in.the document review. In November of 1982 the L. K. Comstock Quality Control Manager was_ replaced because he' lacked administrative abilities. However, poor progress in the document review continued.
In March, 1983, Project Construction Department held a meeting with L. K. Comstock's Regional Vice 4
i President and in April,~1983 with L. K. Comstock's Executive Vice President,
~
Corporate Quality Assurance Manager and Regional Vice President to discuss the poor progress being made on the document review.- As a result, L. K. Comstock committed to provide four' inspectors to complete the document review and j
provide a plan for completion.
The plan to complete the review was submitted to Commonwealth Edison
_ Company for concurrence on March 9, 1983.. The plan's scope and depth was to 4
reconcile audit deficiencies of document retrievability,-as well as assuring
. record conpleteness and correctness.
In June, 1983, CECO' Project Construction Department and Quality j
Assurance met with L. K. Comstock to discuss the status of the document
.j i
review. :It'was' determined that L. K. Comstock was not proceeding as scheduled to meet their September, 1983, completion date. As a result.of the June meeting, Commonwealth Edison Company again replaced the L. K. Comstock Quality i
Control Manager. The intent of this change was to more adequately organize and complete the document review as projected for February.1, 1984.
. _The corrective measures which provide improvements to the L. K.
'Comstock document ^ system were presented to the NRC. In order.to prevent l
incomplete or unacceptable documents from being filed, L. K. Comstock has provided for multi-level review prior to filing. In addition, the'use of a l
computerized document tracking system was authorized. This system is used to 1
document the status of installation and inspections.
(19.1) -
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In March,' 1984, L. K. Comstock was' considered 100% complete with their review of all documents on file and the reconciliation of identified deficiencies was in progress. By January, 1985, the reconciliation effort was nearing completion..No deficiencies had been identified which required extensive rework and only limited field work had been required.
' In early 1985, however, the L. K. Comstock Document Review Program-was placed on administrative hold. Recent observations documented by BCAP (Braidwood Construction Assessment Program) and concerns by Project.
Construction Department ' identified inconsistencies in the thoroughness of.the
}
review. Not all of the inspection records were sufficiently reconciled as.
intended.
k In order to lift the ackninistrative hold, L. K. Comstock has been directed to revise their existing document. review program. Following l
necessary revisions, a complete document review will again be performed to l
assure that each record in the Quality Control file is identifiable, complete, comprehensive and properly reconciled. No completion date is projected at j
this time.
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O O-Braidwood Corrective Action Program Systems Control - Control Board Welding ER-235 During a 1980 !@C Inspection (80-06), the adequacy of welds on Main
. Control Board Panels supplied by Systems Control was questioned. Inspections were conducted and it was found that welding on the structural members of the panels did not meet applicable criteria. Weld defects included overlap,.
undercut, insufficient length, lack of fusion, and improper configuration.
ICR-235 was initiated in July,1980 to document the unacceptable welds and track issue resolution.
Corrective actions required panel inspection and preparation of weld
. eld. repairs were made by maps which were evaluated and dispositioned by S&L.
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L. K..Comstock in accordance with the S&L dispositions and subsequently QC inspected and accepted.
7 In order to confirm the adequate completion of corrective action, j
_ CECO QA conducted Surveillance 3563 in June,1984. It was found that final j
%=mtation packages were incomplete. This issue is now addressed by l
Finding 2 of QA Audit 20-84-545. As of March 1, 1985, LKC is in the process of assembling complete files for the 14 panels included in the scope of this issue.. Two panels require additional LKC QC inspections-and three panels i
require PTL overview inspections.
l The adequacy of corrective actions relative to NCR-235 was also recently addressed by General Office Audit G-85-02.of S&L. Open-Item 3 was i
developed to compile and review NCR-235 documentation. The required j-documentation is currently being assembled. A completion date of June 28, 1985, is currently projected, for this program.
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(20.1) 9949N
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C.:mmonwe.i Edison
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4 8 One First N te nal PMa. Chic'go. Ithnois 3
' Address Reply to Post Office Box 767 1
.. / Chicago, liknois 60690 April 25, 1985 James G. Keppler Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 & 2 Actions Taken For SALP Category 3 Issues NRC Docket Nos. 50-456 and 50-457 Reference (a):
J. G. Keppler letter to Cordell Reed dated November 6, 1984
Dear Mr. Keppler:
On March 15, 1984, a group from Commonwealth Edison including Messrs.
T. J. Maiman, M.
J. Wallace, and W. J. Shewski, met with Messrs. E. Greenman, R. F. Warnick, and W.
S. Little, and others of your staff.
They discussed actions which Commonwealth Edison Company has taken and/or initiated in the three areas which were rated category 3 in reference (a), piping, safety related equipment, and quality assurance.
The purpose of this letter is to provide documentation of the information which Commonwealth Edison provided to members of your staff relative to actions taken to improve performance in these areas.
The discussion topics were testing, the mechanical contractor and Quality Assurance.
The attachment begins with summaries of each of these topics.
These are followed by copies of the viewgraphs presented.
If you or your staff have any questions regarding this matter, please direct them to this office.
Very truly yours, 1
^-
f David H. Smith Nuclear Licensing Administrator
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SUMMARY
OF PRESENTATION TO NRC MARCH 15, 1985 f.
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TESTING The Braidwood Test and Startup Program was developed initially from the same Startup Manual that Byron used.
The production of that manual strongly considered LaSalle experience as well as the Byron experience to that point.
The Braidwood Startup organization was developed to address difficulties experienced at LaSalle County and Byron, particularly the requirement that the" Technical Staff personnel complete the end of the testing program and all of the preparatory activities for Station operation at fuel load in the same time frame.
During the course of time, the Braidwood and Byron programs diverged due principally to Lessons Learned, inputs from Quality Assurance, and commitments made to the NRC.
At this point, it is our intention to realign the Braidwood program with the present Byron program.
This should provide familiar activity for Quality Assurance, Project Engineering Department, and the NRC and should produce a " duplicate program" for each succeeding unit.
To accomplish this realignment, the Braidwood Startup Manual will be, compared with Byron's and the Braidwood manual will be made to parallel the Byron manual unless there is reason to change both manuals to a new method of operation.
To assure similarity bet' ween the tests for subsequent units and the original Byron tests, an example procedure will be written.
This procedure will be applicable to one of the remaining units.
A joint test review board from Byron and Braidwood will approve the technical content of the procedure.
For each subsequent unit the procedure will be reviewed to assure that physical differences between the units have been accounted for.
If a~ technical problem is found with the example procedure, this information will De fed back to the joint test review board and the example procedure corrected.
Tests which have been previously approved will be reviewed against a checklist to assure that the test at least includes all items covered by the original Byron 1 testing program.
To track this testing realignment, a tracking manager has been assigned.
The Braidwood Lessons Learned program which includes findings from Quality Assurance and the NRC at both, Byron and Braidwood has been put into place and, where necessary, administrative procedures are being changed to assure alignment between the two units.
The Byron Unit 2 tester, and the Braidwood Startup Superintendent worked closely on the Byron 1 startup.
They agree on the basic method that is being used to pursue this particular program.
Commitments to the NRC will be reviewed for both units and, subsequently, commitments to the NRC will be made for both units.
In the area of specific concerns, independent verification of jumpers and lifted. leads has been implemented.
A form for documenting minor test change requests is in use.
Checklists are being prepared for the test review board to use in conducting their
. reviews.
The checklists will be applied to all reviews completed prior to checklist implementation.
A separate verification of compliance with ANSI 18.7 will be' completed when the Braidwood Startup Manual has been modified.
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MECHANICAL CONTRACTOR In response to IE. Report.83-09, dated July 1984, Commonwealth Edison Company outlined a. number of management actions taken by Commonwealth Edi'so6 shd their Mechani'cdl'Co6 tractor, Phillips, Getschow Company. 'These management actions addressed the need to improve the Mechanical Contractor. quality and regulatory performance.
"O im ~ "
Since the initial management actions, both Commonwealth Edison and Phillips, Getschow Company,have taken additional management actions to improve quality and regulatory performance.
These actions are outlined on-the attached' presentation slides.
1.
Mechanical Contractor
- Late 1983/Early 1984 Actions 2.
Mechanical Contractor
~Beyond'1984. Actions 3.
Mechanical Contractor
'Recent kctions-1985 4.
MechanicalContgetor'"OutideAssessments j
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- Mechanical' Contractor ' hQ.C; Management Evaluation e:
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Mechanical Contractor _- Commonwealth > Edison Project Management Actions 7.
M'echanical Contractor - Management Feedback' Sessions 1
A summary of the actions presented on the above slides i
indicates that nuclear construction experienced people have been added to the Phillips, Getschow Company Project Management, Engineering, and Quality Control Departments.
When Phillips, Getschow Company did not have the-expertise in-house, Commonwealth Edison Company obtained nuclear construction experienced people from other nuclear construction experienced organizations, such as Daniel Construction Company.
Installation and inspection' procedures were revised and enhanced.
Work Instructions supplemented installation and inspection procedures.
Quality Control increased monitoring of all process activities, warehousing, and housekeeping.- Trend analysis systems were improved and provided feedback to all Phillips, Getschow Company departments.
Data management tools were i
provided and put in-place, thus allowing more effective management of retrofit and on-going activities.
Other feedback type activities have'recently been undertaker to further improve quality and regulatory performance.
Lastly, outside assessments have provided further recommendations for quality and regulatory performance improvements.
Commonwealth Edison and Phillips, Getschow Company have been pro-active towards quality and regulatory performance improvements.
Management actions have been or are being taken to 3
achieve an improved SALP rating.
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4 QUALITY ASSURANCE Braidwood Site Quality Assurances has focused considerable effort-toward improving effectiveness in several areas over the past year.
The overall goal h'as'been to continue the improving trend
~~
noted at the.end of the previ'ous SALP, period,and achieve a. rating of
'1" for this period.. Posi~tivel changes have' occurred in the area of
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organization, staf f size'. and-experience, and' audit' program depth and techniques.
Also there has been increasing interface with the Operating Quality Assurance Group as preoperational testing and system turnover activities become increasingly important.
The nine slides.which follow summarize the high points of each of the major areas of change.
We believe these changes place us in a position to achieve a SALP "1"
rating with our current level of effort in the Site QA organization.
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' INTRODUCTION MIKE WALLACE II.
TESTING CHUCK T0MASHEK III.
MECHANICAL CONTRACTOR DAN SHAMB'LIN
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PIPING SAFETY-RELATED EQUIPMENT-IV.
QUALITY ASSURANCE TOM QUAKA 1
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i AGENDA MARCH 15, 1985 I.
INTRODUCTION MIKE WALLACE e
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e PROJECT MANAGER Mika Wallaca SECRETARY Deb Krug QLELITY FIRST DIRECTOR l
Ray Preston BRAIObOOO CONSTRUCTION 03.0 ASSESSENT PROGRAM DIRECTOR ADMINISTRATIVE SERVICES DIRECTOR Ninu Kaushal O.
Terry Hallaren i
See 02.0 See 01.0 1
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PRtuECT FIELD PROJECT LICENSING PR(MECT (X)NSTRUCTION PROJECT STARTUP PROJECT STATION ENGIKERING MANAGER AND CDFLIANCE SUPERINTENDENT SUPERINTENDEA'!
SUPERINTENDENT SUPERINTENDENT q
Marren Wahle Chuck Schroeder Dan Shamblin Chuck Tanashek John Gudac See 10.0 See 20.0 See 30.0 See 40.0 See 50.0 i
D:
OMRT No.
00.0 ZTfff 1
h DEPARTENT KAD DATE
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TESTIES CONCERNS BYRON /BRAIDWOGG INTERFACE i
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BRAIDWOOD TEST AND STARTUP DEVELQFMENT STARTUP MANUAL & SCHEDULE INITIALLY THE SAME STRONGLY CONSIDERED LA SAtt.E ARD BYRON ORG lilZATION DEVEEQPEE IG KUUREss PROBLEMS
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L!A TAttE KYmon BIVElHEENG QUALITY AssuRARCE NRC LESSON LEARNED t
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TESTING RE-ALIGNMENT STARTUP RANUAL REVIEW COMPARE BYRON & BRAIDWOOD BRING BRAIDWOOD TO BYRON APPROVE.-AND IMPLEMENT.
l SUBSEQUENT UNIT TEST PROCEDURE REVIEW EXAMPLE PROCEDURE JOINT REVIEW INDEPENDENT UNIT REVIEW i
F5EDRACK TO EXAMPLE PROCEDURE PREVIOUSLY APPROVED TESTS INTERFACE TRACKING TRACKING PERSONNEL BRAIDWOOD LESSONS LEARNED PROCEDURE RODIFICATION AGREEMENT BETWEEN TESTING MANAGEMENT COMMITMENTS TO NRC
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SPECIFIC CONCERNS INDEPENDENT VERIFICATION OF JUMPERS AND LIFTED LEADS FORM FOR MINOR TEST CHANGE REQUESTS TEST REVIEW BOARD CHECKLIST REVIEW OF COMPLETED TEST REVIEW BOARDS VERIFY COMPLIANCE WITH ANSI 18.7
.. 8085 s
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III.
MECHANICAL CONTRACTOR DAN SHAMBLIN PIPING SAFETY-RELATED EQUIPMENT 9
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4 MANAGEMENT ATTENTION TO PIPING CONTRACTOR PFRFORMANCE
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PROJECT REVIEW MEETING PIPING QUALITY CONTROL EFFECTIVENESS WALLACE, FITZPATRICK, SHAMBLIN, QUAKA, VAHLE, SCHROEDER FEBRUARY' 14, 1985 3 HOURS 4
II.
PIPING QUALITY CONTROL FEEDBACK SESSION I SHAMBLIN, QUAKA, VAHLE, PHILLIPS, GETSCHOW III.
PIPING QUALITY CONTROL FEEDBACK SESSION II WALLACE, FITZPATRICK AND SESSION I PEOPLE i.
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- IV.
PROJECT REVIEW MEETING PIPING AND OTHER QUALITY AREAS
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_; i FEBRUARY 28, 1985 6' HOURS 69 ITEMS
- TOP.11 PRIORITY. ITEMS
..s..
V.
BRAIDWOOD PRIORITY ISSUES (BPI) LIST REVIEW WEEKLY GUIDELINES FOR ITEMS ON LIST
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BRAIDWOOD STATION - UNITS t'& 2 MECHANICAL CONTRACTOR IE REPORT 83-09 ACTIONS LATE 1982 To MID 1983 i
IN EARLY 1983, COMMONWEALTH EDISON PROJECT MANAGEMENT DETERMINED THE NEED TO SUBSTANTIALLY INCREASE THE LEVEL OF MANAGEMENT TALENT IN THE MECHANICAL CONTRACTORS ORGANIZATION.
THE BRAIDWOOD STATION MECHANICAL CONTRACTOR HIRED A NUMBER OF TOP. MANAGEMENT PERSONNEL PREVIOUSLY EMPLOYED BY THE LASALLE COUNTY STATION MECHANICAL CONTRACTOR.
AUGUST 1983 SITE MANAGER ASSIS' TANT TO SITE MANAGER SITE SUPERINTENDENT
-STAFF ASSISTANT TO QUALITY CONTROL / ENGINEERING PROJECT ENGINEER I
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SEPTEMBER /0CTOBER 1983 AREA SUPERINTENDENTS ASSISTANT AREA SUPERINTENDENTS AREA GENERAL FOREMAN NIGHT SHIFT SUPERINTENDENT THE MECHANICAL CONTRACTOR ENGINEERING DEPARTMENT WAS STRENGTHENED BY ADDITION OF PROJECT ENGINEER, ASSISTANT PROJECT ENGINEER AND 4 - GROUP SUPERVISORS WITH A COMBINED TOTAL-NUCLEAR EXPERIENCE OF 45 YEARS.
MOST OF THESE PEOPLE HAS LSCS EXPERIENCE.
LATER 7 OTHER EXPERIENCED PERSONNEL WERE ADDED TO THE ENGINEERING DEPARTMENT.
(1585A)
{
l BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR IE REPORT 83-09 ACTIONS LATE 1987 TO MID 1983 IMPROVE QUALITY DOCUMENTATION AREA BY " DOCUMENT STATION -
CONCEPT".
THIS CONCEPT PLACED STANDARDIZED AND STRINGENT CONTROLS OVER ALL PROCESS DOCUMENTS.
THIS SYSTEM EMPLOYED MANY EX-LSCS MECHANICAL CONTRACTOR PERSONNEL.
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J MECHANICAL CONTRACTOR QUALITY CONTROL ORGANIZATION WAS SPLIT INTO A FIELD SECTION AND AN OFFICE SECTION.
QUALIT,Y CONTROL WORKFORCE INCREASED FROM 57 PEOPLE TO 125 PEOPLE.
A NEW QUALITY CONTROL SUPERVISOR WAS ASSIGNED TO THE i
BRAIDWOODDSITE'MECHANI' CAL ~ CONTRACTOR.
GENERAL FOREMAN OF FIELD INSPECTIONS WERE APPOINTED TO PROVIDE MORE DIRECT FIELD SUPERVISION.
LEAD QUALITY CONTROL TECHNICIAN.
~
POSITION WAS ESTABLISHED AND FILLED IN PART WITH LSCS EXPERIENCED PEOPLE.
i 1
NUMBER OF MECHANICAL CONTRACTOR Q.C. TECHNICIANS INCREASED FROM 18 TO 56.
THESE TECHNICIANS INCREASED THEIR INVOLVEMENT IN THE INITIAL AND FINAL REVIEWS OF QUALITY DOCUMENTATION.
NUMBER OF MECHANICAL CONTRACTOR FIELD INSPECTORS INCREASED FROM 25 TO 50.
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FULL TIME ON-SITE MECHANICAL. CONTRACTOR Q.A. MANAGER AND 3 Q.A. ENGINEERS WERE ADDED'IN LATE 1982/EARLY MID-1983.
-(1585A)
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BRAIDWOOD STATION - UNITS 1 1 7 MECHANICAL CONTRACTOR LATE 1983/EARLY MID-1984 ACTIONS EXPERIENCED MECHANICAL CONTRACTOR PERSONNEL ADD $TIONS ENGINEERING QUALITY CONTROL (0FFICE AND FIELD)
PRODUCTION REVISED / ENHANCED ALL MAJOR INSTALLATION AND INSPECTION PROCEDURES (LB/SB PIPING, HANGERS, INSTRUMENTATION, WHIP RESTRAINTS, HYDROSTATIC TESTING, MATERIAL CONTROL, EQUIPMENT, ETC.)
WROTE / IMPLEMENTED NEW INSTALLATION, RETROFIT AND INSPECTION PROCEDURES (CALIBRATION, DOCUMENT DEFICIENCY REPORT, MTV, IRV, IDENTIFICATION OF IN-PROCESS DEFICIENCIES, ETC.)
STARTED IMPLEMENTATION OF VARIOUS DATA MANAGEMENT PROGRAMS.
IMPROVED Q.C. INSPECTION RECORD OF DEFICIENCIES (I.E. 9006 FORM)
INCREASED Q.C. MONITORING ACTIVITIES TO INCLUDE ALL PROCESS ACTIVITIES, WAREHOUSING AND HOUSEKEEPING.
j CONTINUED PREVIOUS IMPROVEMENT IMPLEMENTATIONS IN ALL AREAS.
j (1585A)
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BRAIDWOOD STATION - UNITS 1 &
2.-
MECHANICAL CONTRACTOR
~
BE OND'MID'1984 ACTIONS'l','
MECHANICAL CONTRACTOR INSTALLATION /INSP'ECTION PROCEDURES NUMBER 107 (MID 1983 AT 71 PROCEDURES)
WORK INSTRUCTION NOW SUPPLEMENT PROCEDURES MECHANICAL CONTRACTOR Q.C. PERSONNEL-NUMBER 239 (MID 1983 AT 87 0.C. PERSONNEL)
(MID 1983 NUMBER)
Q.C. MANAGER - 1.(0)
.Q.C.
SUPERVISOR
,1 (1)'
' + ' ' ' -
ASST. Q.C."SUPERV'ISOR - l'-(l)
~
Q.C. 0FFICE SUPERVISORS - 10 (0)
Q.C.' LEAD TECHNICIANS - 13 (2)
Q.C. TECHNICIANS -~83 (21/7" TRAINEES)
Q.C. CLERKS - 10 (3)
Q.C. AREA G.F. - 1 (1)
Q.C. G. F. - 5 (1)
Q.C. FOREMAN - 18 (5)
Q.C. INSPECTORS - 99 (29/16 TRAINEES)
PERSONNEL ADDITIONS HAVE BEEN EXPERIENCED IN NUCLEAR CONSTRUCTION WORK 4
OCTOBER 1984 HIRED 6 EXPERIENCED Q.C. SUPERVISORS TO MANAGE SPECIFIC DISCIPLINES.
MODIFIED Q.C. OFFICE SPACE TO IMPROVE WORKING ENVIRONMENT TO MAINTAIN HIGH MORALE.
(1585A)
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BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR BEYOND MID 1984 ACTIONS SIGNIFICANTLY STRENGTHENED THE SPIRIT OF COOPERATION BETWEEN QUALITY CONTROL, ENGINEERING, PRODUCTION AND SITE MANAGEMENT SO ANY TYPE OF PROBLEMS CAN BE IDENTIFIED, QUICKLY ADDRESSED AND CORRECTIVE MEASURES IMPLEMENTED.
IMPLEMENTED IMPROVED TREND ANALYSIS SYSTEM WITH FEEDBACK TO ALL MECHANICAL CONTRACTOR DEPARTMENTS.
STARTED " QUALITY CIRCLES" BETWEEN Q.C. DOCUMENT REVIEW GROUPS, FIELD' INSPECTORS AND LEAD PERSONNEL.
HIRED A PROFESSIONAL TRAINER TO ASSIST CRAFT TRAINING EFFORTS WITH EMPHASIS ON PIPING SUPPORT ERECTION ACTIVITIES.
EXTENSIVE DATA MANAGEMENT CAPABILITIES HAVE BEEN IMPLEMENTED FOR PRODUCTION AND QUALITY RELATED RECORDS.
i PROJECT MANAGER CONDUCTED SELF-IMPROVEMENT STUDIES THROUGH INTERVIEWS OF PERSONNEL IN ALL DEPARTMENTS.
FEEDBACK OBTAINED IS BEING PUT INTO SPECIFIC IMPROVEMENT ACTION PLANS.
(1585A)
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BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR RECENT ACTIONS - 1985 Q.C.. DEPARTMENT MANAGER PERFORMED A COMPREHENSIVE "NEEDS" ANALYSIS TO IDENTIFY AREAS NEEDING ADDITIONAL PERSONNEL <
REQUEST MADE TO COMMONWEALTH EDISON COMPANY FOR 18 ADDITIONAL Q.C. PERSONNEL.
THESE EXPERIENCED PERSONNEL,
ARE BEING PROVIDED THROUGH DAi!IEL CONSTRUCTION COMPANY, SCIENCE APPLICATIONS, INC. AND NUCLEAR POWER SERVICES, INC.
MECHANICAL CONTRACTOR IS BEING FURTHER PROVIDED WITH DATA MANAGEMENT TOOLS THROUGH COMMONWEALTH EDISON COMPUTER SYSTEMS GROUP.
TWO FULL TIME TRAINERS HAVE BEEN ASSIGNED FOR CERTIFICATION TRAINING AND ACT AS TECHNICAL ADVISORS FOR PROBLEMS.
THIS RELIEVES SOME BURDENS OF Q.C. INSPECTOR GENERAL FOREMAN AND ALLOWS MORE. TIME FOR SUPERVISION OF INSPECTORS.
SITE MANAGEMENT /Q.C. MANAGEMENT CONDUCTED A SERIES OF FEEDBACK SESSIONS WITH ALL DEPARTMENTS.
IDENTIFIED A-LISTING OF SELF-IMPROVEMENT ACTION ITEMS.
CONTINUE TO STRESS TO ALL PERSONNEL THE PERFORMANCE OF THEIR JOB IN A QUALITY MANNER.
IN SOME CASES PERSONNEL EMPLOYMENT HAS BEEN TERMINATED FOR LACK OF QUALITY WORK.
(1585A)
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BRAIDWOOD STATION - UNITS T'& 2
~
MECHANICAL CONTRACTOR j
~
OUTSIDE ASSESSMENTS A.
INSTITUTE OF NUCLEAR POWER OPERATIONS CONSTRUCTION PROJECT EVALUATION - JUNE / JULY 1984.
1.
RECOMMENDATION -
" MANAGERS AND SUPERVISORS SHOULD TAKE INITIATIVES TO BECOME MORE KNOWLEDGEABLE OF AND INVOLVED IN DAY-TO-DAY WORK ACTIVITIES INCLUDING INSTALLATION AND INSPECTION WORK."
RESPONSE - ADDITIONAL EXPERI'ENCED PERSONNEL ADDED TO
-MECHANICAL CONTRACTORS ORGANIZATION.
SOME DEPARTMENTS, SUCH AS QUALITY CONTROL, WERE RESTRUCTURED T0 ALLOW FOR SPECIFIC PERSONNEL TO HANDLE DAY-TO-DAY ACTIVITIES (Q.C. SUPERVISOR) AND
~
OTHERS T0!L00K AT PROGRAMMATIC ASPECTS (0.C. MANAGER).
2.
RECOMMENDATION - " IMPROVEMENTS REQUIRED IN IMPLEMENTATION OF MECHANICAL CONTRACTOR'S MATERIAL j
TRACEABILITY VERIFICATION PROGRAM."
RESPONSE - ADDITIONAL-EXPERIENCED PERSONNEL ADDED TO SUPERVISE MTV PROGRAM.
FOCUSED TRAINING GIVEN TO PERSONNEL PERFORMING MTV PROGRAM.
I 3.
RECOMMENDATION
" IMPROVE PIPING SUPPORT ACTIVITIES."
RESPONSE - ONGOING TASK FORCE OF UTILITY, MECHANICAL CONTRACTOR AND ARCHITECT ENGINEER PERSONNEL RECEIVE FEEDBACK ON ALL PIPING SUPPORT ERECTION ASPECTS AND EFFECT IMPROVEMENTS.
SPECIAL AND FOCUSED TRAINING GIVEN TO CRAFT AND Q.C. PERSONNEL.
TREND PROGRAM ACTIVITIES IDENTIFY SPECIFIC PROBLEMS FOR CORRECTIVE ACTION.
4.
RECOMMENDATIQR
" IMPROVE Q.C. INSPECTOR PERFORMANCE."
RESPONSE
ADDITIONAL SUPERVISORY PERSONNEL ADDED TO MONITOR Q.C. INSPECTOR EFFECTIVENESS AND FORWARD r
TRAINING GIVEN.
FEEDBACK SESSIONS BETWEEN CRAFT AND l
Q.C. INSPECTORS HELD TO IMPROVE JOB PERFORMANCE.
ONGOING TASK FORCE CONTINUALLY ADDRESSES Q.C.
INSPECTOR EFFECTIVENESS.
l (1585A)
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BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR OUTSIDE ASSESSMENTS A.
INSTITUTE OF NUCLEAR POWER OPERATIONS CONSTRUCTION PROJECT EVALUATION - JUNE / JULY 1984 (CONT.)
5.
RECOMMENDATION -
" IMPROVE CHANGES TO AND REVIEWS OF QUALITY RECORDS."
~
RESPONSE-ESTABLISHEbBETkERRECORDSREVIEWPLANS AND PROCEDURES.
ADDED EXPERIENCED PERSONNEL.
CONDUCT ONGOING TRAINING SPECIFICALLY FOCUSED TOWARDS RECORDS REVIEWS.
6.
TANGIBLE STRENGTHS "THE MECHANICAL CbNTRACTOR'S
^
WELDER QUALIFICATION-PROGRAM, ENFORCES:HIGH. STANDARDS +
FOR PERFORMANCE CAPABILITY.
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B.
MECHANICAL CONTRACTOR ~Q.C.: MANAGEMENT EVALUATION REPORT
~
,c AUGUST 1984 - CORPORATE MANAGEMENT DECIDED TO CONDUCT MANAGEMENT EVALUATION OF BRAIDWOOD SITE Q.C.
ORGANIZATION.
OCTOBER 1984 - MANAGEMENT EVALUATION DELAYED UNTIL 1
RECENT Q.C. ORGANIZATION / ADDITION CHANGES COULD BE COMPLETED.
NOVEMBER 1984 - N.C. KIST & ASSOCIATES, INC.
CONTRACTED TO PERFORM MANAGEMENT EVALUATION.
NOVEMBER / DECEMBER 1984 - MANAGEMENT EVALUATION PERFORMED.
DECEMBER 1984 - MANAGEMENT EVALUATION REPORT ISSUED.
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(1585A)
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BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR
~
OUTSIDE ASSESSMENTS B.
MECHANICAL CONTRACTOR Q.C. MANAGEMENT EVALUATION REPORT (CONT.)
JANUARY / FEBRUARY 1985 - MECHANICAL CONTRACTOR REVIE0 AND DISCUSSION OF REPORT RESULTS IN-HOUSE AND WITH CONSULTANT.
FEBRUARY 1985 - MANAGEMENT EVALUATION REPORT AND ACTION PLAN FORWARDED TO COMMONWEALTH EDISON COMPANY FOR INFORMATION.
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BRAIDWOOD STATION - UNITS 1 & 2 MECHANICAL CONTRACTOR
~
0.C ' MANAGEMENT EVALUATION f.
PURPOSE
' CONDUCT'iA'. MANAGEMENT EVALUATION OF THE BRAIDWOOD SITE Q.C. ORGANIZATIONAL STRUCTURE AND INTERVIEW SUPERVISORY PERSONNEL FOLLOWING*
ADDITION OF EXPERIENCED PERSONNEL ADDED TO HANDLE INCREASED SCOPE OF ACTIVITIES DUE TO i
REVERIFICATION PROGRAMS.
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- i EVALUATION METHODS -
INTERVIEWING PERSONNEL.
ATTENDING STAFF MEETINGS.,
DETERMIN,1NG SIGNIFICANT RESPONSIBILITIES FROM Q.C. MANUAL.
CHECKING WITH PERSONNEL FOR ASSIGNMENT OF RESPONSIBILITIES.
REVIEWING CURRENT ORGANIZATION CHART.
REVIEWING SAMPLES OF WORK.
REVIEWING RESUME'S.
PERSONNEL INTERVIEWED -
SITE Q.A. COORDINATOR Q.C. MANAGER SUPERVISOR - Q.C.
ADMINISTRATIVE ASSISTANT - Q.C.
ASST. SUPERVISOR - 0.C. FIELD ASST. SUPERVISOR - 0.C. OFFICE RECORDS REVIEW SUPERVISOR N5 DATA REPORT ~ SUPERVISOR RETROSPECTION SUPERVISOR MATERIAL CONTROL & CALIBRATION SUPERVISOR DOCUMENT CONTROL SUPERVISOR COMPLIANCE SUPERVISOR SITE MANAGER PROJECT ENGINEER (1585A)
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BRAIDWOOD STATION - UNITS 1 & 2
. MECHANICAL CONTRACTOR 0.C. MANAGEMENT EVALUATION CONCLUSIONS AND RECOMMENDATIONS
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PREPARE A WRITTEN FUNCTIONAL CHART LISTING ALL THE SPECIFIC RESPONSIBILITIES FOR EACH SUB-TIER SUPERVISOR.
DESIGNATE BY JOB TITLE ONE INDIVIDUAL WHO IS RESPONSIBLE FOR PROVIDING ANSWERS TO CODE & STANDARDS QUESTIONS.
THE BRAIDWOOD SITE Q.C. ORGANIZATIONAL STRUCTURE IS SUITABLE FOR THE INCREASED SCOPE OF ACTIVITIES.
THE EXPERIENCE OF SITE Q.C. SUPERVISORY PERSONNEL IN NUCLEAR QA/QC IS EXTENSIVE AND ADEQUATE FOR THE SCOPE OF ACTIVITIES.
THE SITE Q.C. SUPERVISION IS TAKING POSITIVE ACTIONS TO IMPROVE THE MANAGEMENT, CONTROL AND INTERFACES OF THE Q.C. FUNCTIONS.
THE CURRENT OFFICE' ARRANGEMENTS AND OFFICE SPACES ARE NOT CONDUCIVE TO WORKING EFFICIENTLY.
THE Q.A. MANUAL NEEDS TO REFLECT IN BETTER DETAIL THE CURRENT PROVISIONS FOR VERIFYING THAT CORRECT MATERIAL'FOR THE APPLICATION WAS RELEASED AND INSTALLED.
MECHANICAL CONTRACTOR ACTIONS WRITTEN FUNCTIONAL CHART LISTING EACH SUB-TIER SUPERVISOR AND THEIR SPECIFIC RESPONSIBILITIES WILL BE ISSUED IN MARCH, 1985.
OFFICE SPACE IMPROVEMENTS AND GROUPING OF FUNCTIONAL GROUPS HAS BEEN COMPLETED.
THE Q.A. MANUAL IS UNDER REVISION TO REFLECT CURRENT VERIFICATION OF MATERIAL APPLICATION PRACTICES.
(1585A)
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BRAlbWUbD STATION bNITS 1 & 2 MECHANICAL CONTRACTOR
[0MMONWEALTH'EDIsb's"PRbiECT'Mi'IGFNE'NT ACTIONS A
SEARCHEb FOR AND PkbVIDEb TO THE MECHANICAL CONTRACTOR NULCEAR EXPERIENCED PERSONNEL.
PROVIDED EXTENSIVE DATA MANAGEMENT HARDWARE AND SOFTWARE.
CONDUCTED ONGOING MINI-EVALUATIONS.WITH IN-HOUSE EXPERTISE
~
IN RESPONSE TO INP0~C0sSTRUCTION' PROJECT EVALUATIONS.
THESE MINI-EVALUATIONS WILL CONTINUE,. UTILIZING INPO in I'
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CRITERIA.
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ORGANIZE AND CHAIP ONGOING TASK FORCES WHICH LOOK AT SPECIFIC' WORK AND INSPECTION ACTIVITIES.
THESE TASK FORCES ARE MADE UP OF COMMONWEALTH EDISON COMPANY, MECHANICAL CONTRACTOR, AND ARCHITECT ENGINEER PRODUCTION, ENGINEERING AND QUALITY CONTROL PERSONNEL.
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(1585A) t-
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BRAIDWOOD STATION - UNITS T & 2 MECHANICAL CONTRACTOR MANAGEMENT FEEDBACK SESSIONS IN RESPONSE TO RECENT NRC CONCERNS, COMMONWEALTH EDIS0N COMPANY STARTED SPECIAL FEEDBACK SESSIONS WITH COMMONWEALTH EDIS0N COMPANY PROJECT FIELD ENGINEERING MANAGER, SITE QUALITY ASSURANCE SUPERINTENDENT AND PROJECT CONSTRUCTION SUPERINTENDENT AND MECHANICAL CONTRACTOR PRODUCTION, ENGINEERING QUALITY CONTROL AND QUALITY ASSURANCE MANAGEMENTS AND SUPERVISION.
PURPOSE PROVIDE COMMONWEALTH EDISON MANAGEMENT A DIRECT AWARENESS OF SUPERVISION AND WORKING LEVEL PERSPECTIVE.
PROVIDE CONTRACTOR PERSONNEL AN OPPORTUNITY FOR SIMULTANE0US FEEDBACK TO COMMONWEALTH EDISON ENGINEERING, CONSTRUCTION AND QUALITY ASSURANCE.
PROVIDE A FORUM FOR SOLICITING CONTRACTOR SUGGESTIONS.
PROVIDE A FORUM FOR' COMMUNICATING COMMONWEALTH EDISON SITE MANAGEMENTS PERSPECTIVE ON CRITICAL ISSUES.
I PROVIDE AN OPPORTUNITY FOR TEAM BUILDING.
STRUCTURE OF SESSIONS IDENTIFY TOPIC 0F DISCUSSION.
FOCUS ON POSITIVES AND NEGATIVES OF TOPIC.
IDENTIFY OPPORTUNITIES WHICH WOULD CONTRIBUTE TO OVERALL SUCCESS OF TOPIC.
PRIORITIZE OPPORTUNITIES.
DEVELOP VIABLE ALTERNATIVES FOR IMPLEMENTING OPPORTUNITIES.
ASSIGN ACTIONS.
(1585A)
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BRAID 1ddO'D STATION fNETS i & 2 MECHANICAL CONTRACTOR M4NAGEMIN'T kSEDBh d 5EskIONS PARTICIPANTS-D. L. SHAMBLIN' (CONSTRUCTION SUPT.')', T. E. QUAKA
~
(Q.A. SUPT.), W. E. VAHLE (FIELD ENG. MGR.)
SUPERVISION STAFF COMMONWEALTH EDISON' DEPARTMENTS T. O' CONN 0R (PROJ. MGR.), J. CARLSON (Q.C. MGR.),
S. FORBES (Q.A. MGR.), J. STEWERT (PROJ. ENG.),
W. NICHOLSON (GENERAL SUPT.)
SUPERVISION AND WORKING PERSONNEL MECHANICAL CONTRACTOR DEPARTMENTS ru u-TOPIC OF MECHANICAL CONTRACTOR SESSION
" PIPING QUALITY ' CONTROL' DOCONENTATION' AND INSPECTION ACTIVITIES" "WHAT THINGS IN THE MECHANICAL'CONTRhCTOR AREA CAN SE DONE TO HELP Q.C. INSPECTORS DO THEIR JOBS BETTER?"
SUGGESTED OPPORTUNITIES FINALIZE AND IMPLEMENT N-5 REVIEW PROGRAM.
IDENTIFY IMPORTANT PROCEDURE CHANGES AND EXFtulTE THEIR APPROVAL.
MINIMIZE PROCEDURE REVISIONS.
REVIEW FLOW OF WORK FOR ALL' ACTIVITIES.
IN SOME CASES, PROVIDE BETTER ENGINEERING DIRECTION.
IMPLEMENT MORE CRAFT TRAINING.
CONTINUE THESE TYPES OF FEEDBACK SESSIONS.
(1585A)
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BRAIDWOOD STATION - UNITS 1 1 2 MECHANICAL CONTRACTOR
SUMMARY
' MECHANICAL CONTRACTOR HAS BEEN PRO-ACTIVE COMMONWEALTH EDIS0N HAS BEEN PRO-ACTIVE MECHANICAL CONTRACTOR ORGANIZATIONAL STRUCTURE AND PERSONNEL ARE EXPERIENCED AND TOTALLY CAPABLE OF PERFORMING QUALITY WORK WHEN PROBLEMS IDENTIFIED, " MANAGEMENT" ATTENTION IS DIRECTED TO PROBLEM AND IMPLEMENTATION OF CORRECTIVE ACTION FEEDBACK SESSIONS / QUALITY CIRCLE SESSIONS HAVE STARTED T0 IDENTIFY _FURTHER OPPORTUNITIES FOR SELF IMPROVEMENT ACTIONS HAVE BEEN/ARE BEING TAKEN TO ACHIEVE A BETTER SALP RATING (GOAL = 1)
(1585A)
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QUALITY ASSIIRANCE TOM QUAKA
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MAJOR ARFAS OF CHANGF 9 ORGANIZATION 9
STAFF SIZE 9 STAFF EXPERIENCE 8 SITE AUDIT PROGRAM 9
INTERFACE WITH OPERATING 0.A.
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BRAIDWOOD QUALITY ASSURANCE 7/'N##
REPORTING RELATIONSHIPS l
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- Quality Assurance i
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. t BRAITWDDB ODAl ITY AKKURANCF MANN.TNG COMPARISDM f
i-JAMilARY 1984 ll ARCH 1985 l
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0 1
SITE QUALITY ASSURANCE 1
1 SUPERINTENDENT SITE QUALITY ASSURANCE GENERAL 0
1 SUPERVISOR i
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AUDIT COORDINATOR 0
1 Q11ALITY ASSURANCE SUPERVISORS 2
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011ALITY ASSURANCE ENGINEERS /
19 42 INSPECTORS 1
GUALITY ASSURANCE SUPPORT 10 40 (CLERICAL & CONTRACTOR)
TOTAL 32 90*
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" INCLUDES 18 BCAP DEDICATED PEOPLE 1
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EXPFRIFNCF COMPARISON fAVFRAGF YASPER PFRKON) f PERCENT j
JANilARY 19BI4 MARCH 19R5 INCRFASF TOTAL EXPERIENCE s.3 13.4 61 NUCLEAR EXPERIENCE 4.2 7.4 76 QUALITYASSURANCE/dIhALITY 2.7 5.1 89 CONTROL EXPERIENCE 1
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I SLIDE III (2705A) s
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l AllDIT PROGRAM IMPROVEMFMTS 8
ASSIGNED PERMANENT AUDIT COORDINATOR 9 PRE-AUDIT PREPARATIOR-MORE INVOLVEMENT OF AUDIT C00RDINAi2R/ LEAD AUDITORS IN AUDIT 0
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e BETTER AUDIT iEAM DEBRIEFINGS 9 PROMPT RESOLUTION OF UNACCEPTABLE AUDIT RESPONSES AND CORRECTIVE ACTIONS S SPECIFIC CORRECTIVE ACTION PROGRAMS INCLUDED IN 1985 AUDIT SCHEDULE
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IMPROVFDINTERFAdFWITHOPERATING0.3, IN THE F011OWING ARFAS l
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PRE-OP TEST PACKAGE REVIEW ISSUES 1
9 0.A. COVERAGE OF CONSTRUCTION WORK ON SYSTEMS TURNED OVER F0i! TEST
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S CCyERAGE OF START-UP GROUP i.
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EDISON MANAGEMENT IS ORGANIZED
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STAFFED FUNCTIONING TO FULLY AND ADE00ATELY 3
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COMPLETE PRODUCTION' EVALUATE ONG0ING WORK i
ADDRESS ANY NEW CONCERNS AE i
MEET MARCH, 1986 FUEL LOAD DATE U
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r, Commonwoehh Edieon ow flat im rwl t*ber
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Mr. Jame: D. Keppler, Regional Administrator
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U.S. Nuclear Reguintory Commission Regl'on III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 & 2 Raylalon to Inspection Report 83-09 Response NRC Docket Hos. 504456 and 504A57 Reference (n):
- 3. G. Kappler letter to Cordell Re6d dated May 7, 1984.
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(b):
L. O. Dolceorge letter to 3. C. Keppler dated July 6, 1984.
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(c):
D. H. Smith letter to J. G. Keppler
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dated March 11, 1985.
(d):
D. H. Smith letter to J. G. Keppler dated March 27, 1985.
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Dear Hr. Keppler:
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References (c) and (d) aubmitted to NRC for review commennesith Edison's proposed HVAC Wald TestinD ProDrem which F
M? NRC with suf fleient additional confidence in the installed quality pot walds and allow closure of certain HVAC weld issues. 4-The M-attachment lett Ides current status an N ',.
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L-J..,..d45-457/84-09-D76)identifiedinReference(a).
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"y'~. 'y'n*ta ct this of fic e.='-If you have any questions concerning this matter, pleas
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mith
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ATTACHNENT Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/B3-09-07B ano 457/83-09-078 Notice of Violation Item ic Commonwealth Edison's Reference (b) rssponse identified actions to be taken to resolve the issu6 of unstamped HVAC welds.
This included direction from Commonwsalth Edison to Pullman Sheet Metal to either establish welder identifleetion by in place physical marking or by other production or qualit ype records, or to replace the welds, if no welder identif1 a len can be established.
The HVAC Weld Test Program delineated in References (c) and (d),
Wall include welds from locations for which welder identificaticn can not be verified.
Successful ccmpletion of this test program will provide cdditional confidence in the quality of instelled welds where weld 9r identification can not be established by in piece
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The 53 welds identified in Reference (a) where I/elter identirloation can not be established will be replaced if welder identification can not be estabilehed by in place physical markings, production records or quality records, rollowing is the cuzrent status of Identification of these 53 weldst 29 - Welder ID found or determined by Production or Quality Records.
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