ML20136J077
| ML20136J077 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/11/1985 |
| From: | Danni Smith COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20136J064 | List: |
| References | |
| NUDOCS 8511250275 | |
| Download: ML20136J077 (7) | |
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Commonwealth Edison One First National Plaz' Chicago. Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 March 11, 1985 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Nuclear Power Station Units 1 & 2 Revision to Inspection Report 83-09 Response NRC Docket Nos. 50-456 and 50-457 Reference (a):
J. G. Keppler letter to Cordell Reed dated May 7, 1984.
(b):
L. O. DelGeorge letter to J. G. Keppler dated July 16, 1984.
(c):
E. D. Swartz letter to J. G. Keppler dated July 23, 1984 (d):
E. D. Swartz letter to J. G. Keppler dated August 31, 1984
Dear Mr. Keppler,
On February 20, 1985, M.
J. Wallace, et al., o f Commonwealth Edison Company met with Mr. John Streeter,)et al. of your staf f to discuss our response in References (b), (c, and (d) to your Inspection Report, Reference (a), regarding HVAC weld concerns.
During that meeting, we reiterated our position that there is adequate assurance of the quality of installed HVAC welds.
The NRC, however, stated the position that we be required to demonstrate positive confirmation of the adequacy of the welds through a limited sample test program.
Commonwealth Edison Company, therefore, has developed a proposed HVAC Weld Testing Program which is described in Attachment A.
This program will:
1.
Confirm that a final visual inspection for AWS welding is adequate to establish quality of the work; and thus "311250275 040031 MAR I f 1985 l'DH ADOCK 05WO456 u
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Provide the additional assurance desired by the NRC that the installed HVAC welds are adequate.
It is our understanding that successful completion of this test program will provide the NRC with sufficient additional confidence in the installed quality of welds and allow closure of the following issues:
83-09-078 Unknown Welders 83-09-10A HVAC Weld Quality, including multi-pass welds 83-09-10B Fitup Inspection 83-09-10C Base Metal Inspection The specifics of this proposed HVAC Weld Testing Program were reviewed with Mr. John Jacobson of your staff on February 26, 1985.
Attachments B & C contain revisions to our Reference (b) and (d) responses to identify the HVAC Weld Testing Program as corrective action for specific items.
Attachment D contains revisions to our Reference (b) l response outlining the sample program to provide additional l
assurance of correct material installation for class H instrument l
- piping installed prior to February, 1984.
l If you have any questions concerning this matter, please l
contact this office, i
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Ver truly
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David H. Smith Nuclear Licensing Administrator l
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NRC Resident Inspector - Braidwood i
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ATTACHMENT A HVAC WELO TESTING PROGRAM A.
Sample Selection Criteria 1.
Sample size will be a minimum of 75 safety related field inspected and accepted welds made prior to September 15, 1983.
2.
Each of the following types of welds will be included in the sample population:
a.
Welds that were considered acceptable without rework during the 100% reinspection effort.
b.
Welds made by welders having high reject rates, c.
Welds that have troublesome weld configurations or special weld configurations, d.
Welds for which fitup can not be determined after welding, including angle splices, e.
Multi-pass welds.
f.
Welds from among the highly stressed connections.
g.
Welds made from all processes other than the silicon-bronze process (the silicon-bronze process will be addressed separately),
h.
Sheet to sheet welds.
1.
Sheet to structure welds.
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Structure to structure welds.
3.
In some cases, multiple welds may be selected from a single component, provided the other selection criteria are met.
4.
In some cases, welds will be selected from locations for which welder identification can not be verified.
This data will be utilized to add confidence to the acceptability of welds of this type.
5.
In some cases, welds will be selected which had minor defects that had been accepted-as-is by the Architect / Engineer.
This data will be utilized to add confidence to the acceptability of welds of this type.
6.
If only a portion of a specific weld is tested, it will be confirmed that the sample is representative of the entire weld.
B.
Testing 1.
Testing will be performed which is appropriate for the nature of each weld sample, such as a tensile test, micro-etching, bend test, non-destructive examination,
-etc.
2.-
Testing for a portion of the sample population may be accomplished by static loading of an assembly to equivalent design loads.
C.
Acceptance Criteria 1.
Acceptance criteria for each weld tested will be based on design requirements.
D.
NRC Concurrence 1.
The NRC Inspector assigned to review sample selection and the testing program will sign off acceptance of samples selected and test results on an as-completed basis.
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ATTACHMENT B Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-078 and 457/83-09-078 Notice of Violation Item lc Commonwealth Edison's Reference (b) response identified actions to be taken to resolve the issue of unstamped HVAC welds.
This included direction from Commonwealth Edison to Pullman Sheet Metal to either establish welder identification by in place physical markings or by other production or quality type records, or to replace the welds, if no welder identification can be established.
The HVAC Weld Test Program delineated in Attachment A, will include welds from locations for which welder identification can not be verified.
Successful completion of this test program will provide sufficient additional confidence in the quality of installed welds where welder identification can not be established by in place physical markings or by other production or quality type records.
This test program will be completed in lieu of replacing welds described in our Reference (b) response.
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is it ATTACHMENT C e
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Supplemental Response to
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,1 Inspection Report 456/83-09 and 457/83-09 e ',
Item 456/83-09-10A and 457/83-09-10A'
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Notice of Violation Item 3a Q
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Commonwealth Edison's Reference (d) response outlined a reviewJ in' the area of multipass welding to be performed in addition q
to the final visual inspection of the complete $ welds.
This review was to identify welders with a high rejedtion rate and s
then identify the hangers that were welded by th'ese identified
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welders.-
These hangers would be reviewed to identi,fy the y);
existence of any multipass welds which would thehf bet magnetic particle inspected to provide additional assurance bbyond the final visual examination as to the acceptable qualm;pof the completed welds.
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The HVAC Weld Testing Program delineated in Attachment A calls i; 4 for the testing of multipass welds.
Successful completion of
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this program will provide sufficient additional confidence in the quality of installed welds.
This test program will be completed in lieu of the review identified in Reference (d).
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01 ATTACHMENT-D Supplemental Response to Inspection Report 456/83-09 and 457/83-09 Item 456/83-09-07A and 457/83-09-07A Notice of Violation Item la Phillips Getschow Company established improved procedural controls for the Q.C. inspection and verification of safety related (class H) instrument piping materials in February,
- 1984..These requirements are in procedure PGCP-30, Rev. 7.
The Region III Inspector identified a concern that PGCP-30 did not explicitly require the Q.C. inspector to compare the installed materials that were too small to be physically marked against the Stores Request.
In order to clarify this point, Supplement 1 was written to PGCP-30.
In. order to provide additional confidence in the Stores Request documentation of class H instrument piping materials for work performed prior to February 1984, Phillips Getschow will develop a procedure similar to the Material Traceability Verification Program.
This procedure will require field verification by Quality Control of installed class H instrument materials on a sampling basis.
The installed materials will be verified against the Stores Request documentation and the bill of materials listed on the isometric drawing.
This procedure will be submitted to Commonwealth Edison Company for approval by April 4, 1985.
The installed material verification will be performed on a random sample of class H instrument isometrics installed prior to. February, 1984.
The random sample will be selected in accordance with Military Standard MIL-STO-1050.
It is anticipated that the field verifications will be completed by July 1, 1985.
As part of the field verifications, materials which do not have unique markings traceable to the Stores Requisition and drawing will have digital thickness measurements or mechanical measurements taken to establish the schedule of the material.
The data from the field verification sample will be reviewed and a final report put together by August. 30, 1985.
The final report will compare the installed material against the design requirements, the l
tsometric bill of material and the Stores Request.
Installed material quantities will be compared against Stores Request quantities also.
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As part of final document review, Phillips Getschow Q.C. has been comparing the materials listed on the Stores Request against the materials listed on the isometric bill of material for class H instruments.
Any discrepancies noted during this review are brought to the attention of the Phillips Getschow Engineering Department for resolution.
This process however, has not been fully delineated in a procedure.
Phillips Getschow will Incorporate this process into a final document review checklist.
This checklist will be prepared by April 1, 1985, in accordance with Phillips Getschow procedure QPC-B30.
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