ML20137Q194

Responds to NRC Re Noncompliance Noted in Insp Repts 50-454/85-11 & 50-455/85-08.Corrective Actions: Reliable Sheet Metal Procedures for Welding to Structural Steel Revised to Incorporate Preheat Requirements

ML20137Q194
Person / Time
Site:	Byron
Issue date:	09/05/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0606K, 606K, NUDOCS 8509200071
Download: ML20137Q194 (4)

Text

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/^N Commonwealth Edison

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J One First Nationti Plua. Chicago, litinois Address Reply to: Post Office Box 767

\ Chicago, lilinois 60690 September 5, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 I.E. Inspection Report Nos.

50-454/85-011 and 50-455/85-008 Reference (a): August 6, 1985 letter from C. J.

Paperiello to Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of inspections by Messrs.

Jacobson, Jones, Ward and Muffett at Byron Station Units 1 and 2 for the periods of March 18-21, 25-27, April 3-4, 9-11, 16-19, 22-23, May 15-16, 28, and July 1-3, 16-17, 1985. During these inspections certain activities were found to be not in compliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation appended to reference (a).

Please direct any questions regarding this matter to this office.

Very truly yours, ce91 kl D. L. Farrar Director of Nuclear Licensing 1m Attachment A cc: Byron Resident Inspector S!'*%oon5%,R*

0606K SEP 01985 tl u____________ ._ R E o [ _ _ _ _

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ATTACHMENT A VIOLATION

1. 10 CFR 50 Appendix B, Criterion IX, as implemented by the CECO Quality Assurance Program, requires that special processes be controlled and be accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specification, criteria, and other special requirements.

-Contrary to the above, the following examples of failure to control special processes were identified:

a. Reliable Sheet Metal welding procedures did not properly address the required preheat in accordance with AWS Dl.1, and attachments to structural members were welded without the required preheat (454/85011-02(a)(DRS)) .

b. A Reliable Sheet Metal welder having insufficient records to justify qualification in accordance with AWS Dl.1 performed welds on heavy plate (454/850ll-02(b)(DRS)).

CORRECTIVE ACTION TAKEN AND RESULTS-ACHIEVED

a. By test Reliable Sheet Metal qualified welds made to structural steel without the required preheat in accordance with AWS Dl. This qualification showed that an acceptable joint was made using past procedures without preheat. (Reference R94 NR 093).

b.- The Reliable Sheet Metal welder, having insufficient activity level

.since initial qualification on heavy plate in accordance with AWS Dl.1, was readministered the appropriate GMAW test in the Reliable Sheet Metal welding test booth.- The test results showed he could still perform acceptable gas metal arc welding welds. Additionally, all welds made during the lapse in qualification were visually inspected by qualified. visual weld inspectors.

CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCOW LIANCE

a. Reliable Sheet Metal procedures used for welding to structural steel have been revised to incorporate the requirements of preheat per AWS Dl.l. All production supervisory and welding personnel have been trained to these current preheat requirements.

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b. A review of all other welders qualified to the AWS Dl.1 process showed proper qualification of other welders. Currently, Reliable Sheet Metal procedures require that a review of all active welders is done every six (6) months to ensure proper activity levels in each process per AWS 01.1.

DATE WlEN FULL COM'LIANCE WILL BE ACHIEVED

a. September 5, 1985

b. May 13, 1985 0606K

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VIOLATION

2. 10 CFR 50 Appendix B, Criterion XVI, as implemented by the CECO Quality Assurance Program, requires that conditions adverse to quality be promptly identified and corrected.

Contrary to the above, weld quality and inspection problems identified concerning the Reactor Containment Fan Cooler installations were not addressed in a timely manner in that four years elapsed between identification and resolution of the problems (454/85011-03(DRS)).

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Hunter, after improperly closing the original Nonconformance Report (NR 185), initiated a new nonconformance on March 6, 1985 (NR 1042). As part of the research into nonconformance NR 1042, it has been determined that the channel members and drain pans are not used to support the RCFC coils and are not required to function during a LOCA. As a result they have been classified as nonsafety-related. The remaining structural safety-related welds were mapped by inspectors in March,1985, and found by Sargent and Lundy engineers to be adequate to perform their intended function. Final disposition on the RCFC installation was "use as is" as a result of safety classification change for the channel members and drain pans and the safety-related weld mapping calculations.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NOFCOWLIANCE A review of all Hunter nonconformances was made to determine if other similar premature closure of deficiencies had occurred. This review identified no further deficiencies. Additionally, the Hunter QA audit and surveillance program have been enhanced to assure that all deficiencies identified by either an audit or surveillance would be corrected prior to close-out of the respective report.

DATE WHEN FULL COWLIANCE WILL BE ACHIEVED March 28, 1985 0606K

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