ML20140D424
| ML20140D424 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/19/1984 |
| From: | Danni Smith COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20140D403 | List: |
| References | |
| NUDOCS 8412180480 | |
| Download: ML20140D424 (3) | |
Text
[^N Commonwealth Edison s
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November 19, 1984 Mr. James G. Keppler Regional Administrator
-Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2
- Supplemental Response to Inspection Report Nos. 50-456/84-05 and 50-457/84-05 tRC Docket Nos. 50-456 and 50-457 References (a):
R.' F. Warnick Letter to Cordell Reed dated July 2, 1984 (b):
D. L. Farrar Letter to J. G. Keppler dated August 10, 1984
Dear Mr. Keppler:
This letter provides additional response to the inspection conducted by Messrs. H. W. Kerch, R. H. Harris and R. M. Campbell of the Region I Office on March 26 through April 6, and April 9 through 20, 1984, of activities at our Braidwood Station. Reference (a) indicated that certain activities appeared to be in non-compliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation as appended to Reference (a) was provided by reference (b).
The enclosure to this letter provides current status on Items of :Dncompliance A.2 and B as identified in References (a) and (b). Corrective Actions for Items A.2 and B were expected to be complete with full compliance met by November 15, 1984. The scope of work for Level III review has exceeded previous estimates. These actions are now expected to be complete January 7, 1985.
Should you or your staff have any questions concerning these items please contact this office.
Resectfully,f David H. Smith Nuclear Licensing Administrator Enclosure cc: NRC Resident Inspector-Braidwood NOV 201964 8412180400 841213 PDR ADOCK 05000456 G
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ENCLOSURE SUPPLEENTAL RESPONSE TO INSPECTION REPORT 456/84-05 APO 50-457/84-05 ITEM 456/84-05-08 APO 457/84-05-08 ITEM A CORRECTIVE ACTION TAKEN Af0 RESULTS ACHIEVED
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Disposition of this item was pending NRC's position on Code Case 1914. During the f4tC inspection of Byron Station (Report Nos. 50-454/84-42 and 50-455/84-29) the inspector reviewed the similar Byron issue (50-454/82-01-01).
The inspector reviewed the final Byron response dated May 3, 1984, CECO code inquiry to Subcommittee V of the ASE for interpretation, the ASE response, and the Code Case 1914 for alternate penetrameter placement. Code Case 1914 indicates that the placement of penetrameters on the weld is acceptable providing the lead penetrameter identifying numbers are not placed on the weld metal. The inspector agreed with the Code Case and closed the Byron noncompliance. The May 3,.1984 Byron response letter and the ASE response are included for your information as Attachments A and B.
Based on NRR's acceptance of Code Case 1914 for Byron and Braidwood, this item is considered closed.
2.
Spool #Q6056-CV-23-6 Weld #6 has been added to Commonwealth Edison NCR 605. Construction activities have limited the amount of radiography possible. Disposition of this weld is expected to be complete January 7,1985.
3.
No further corrective action is necessary.
4.
Phase one of the program of corrective action to determine the extent of film yellowing has been completed. This consisted of a review of a sample of film for visual film yellowing.
The results have been tabulated as follows:
Number cf spool packages sampled - 166 Number of welds reviewed - 553 Number of welds with visual film yellow on at least one film - 5 Total percent of welds with yellow film - less than 1%
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Phase.two of the program involving chemical' testing of the same sample is pending determination of appropriate test 4
' method to determine residual chemicals on aged film. The
. manufacturer has been contacted for recommendations.
Because the population of radiographs-is~1arge and the -
corrective action delineated in NCR.606 is so-involved, l
corrective actions are not expected to be complete until July 1, 1985.
ITEM A DATE OF FULL COWLIANCE-
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Full compliance-has been achieved.-
2.
The additional Level III review is now expected to be 4.
-complete January 7,.1985..
3.
Full compliance has been achieved.
4.
Resolution of NCR 606 is now expected by July 1,1985.
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N Commonwealth ECson
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) one First Natenal Plaza. Chicago. Ilhnois
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C 7 Addrzss R; ply 12 Post Offect Box 767
'q,/ Chicago. Illinois 60690 ATTACHMENT A May 3, 1984 Mr. Harold R. Denton, Director Of fice of Nuclear Reactor Regulation U.S. Nuclear. Regulatory Commission.
Washington, DC - 20555
Subject:
Byron Generating Station Units 1 and 2 Braidwood~ Generating Station Units 1 and 2 Penetrameter Placement During Radiography NRC Docket Nos. 50-454, 50-455, 50-456, and 50-457 References (a):
January 27, 1982 letter from C. E. Norelius to Cordell Reed.
(b):
February 26, 1982 letter from L. O. DelGeorge to J. G. Keppler.
(c):
March 16, 1983 letter from D. L. Farrar to J. G. Keppler.
(d):
April 4, 1983 letter from R. L. Spessard to Cordell Reed.
Dear Mr. Denton:
This letter provides additional information regarding the placement of penetrameters during radiography of pipe welds at Byron and Braidwood stations.
This issue relates to the apparent noncompliance identified by I&E in reference (a) (Inspection Report Nos. 50-454/82-01 and 50-455/82-01) which was referred to NRR for resolution.
As indicated in reference (a), the I&E Region III inspector found that on several radiographs made by Southwest Fabricating penetrameters had been placed on the welds.
In reference (b),
Commonwealth Edison indicated that this practice had been discontinued for Byron and Braidwood work on January 22, 1979.
We maintained, however, that the practice was generally acceptable and that the radiography was adequate.
To resolve the matter, a code inquiry was submitted to ASME on February 2, 1982.
Later, ASME approved Code Case 1914 which addressed this issue and became ef fective on February 7, 1983.
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H. R. Denton May 3, 1984
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Code Case 1914 indicates that the placement of penetrameters on the weld is acceptable providing the lead penetrameter identifying numbers are not placed on the weld metal.
Our review of the radiographs involved confirms that they all conform to the code in this respect.
The tabulation below summarizes the results of our review on a unit-by-unit basis.
Unit Number of Welds Penetration Over Weld Byron 1 3015 518 Byron 2 1233 38 Braidwood 1 2204 273 Braidwood 2 1064 32 7516 816 I
Commonwealth Edison has reached the conclusion that even with the penetrameters placed on the welds, acceptable radiographs were produced considering the latitude and density permitted by the ASME Code.
Meaningful flaw indications would not have been obscured by penetrameters placed on weld material.
All of the subject radiographs are techically acceptable.
Please address further questions regarding this matter to this office.
One signed original and fifteen copies of this letter are provided for NRC review.
Very truly yours, g j.A&"
T. R.
Tramm Nuclear Licensing Administrator 1m 8174N l
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Tho Amcrican decinty of Mcchanical Er.d nscro 3
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- I retuun Tectmologr cud'4 4asI 5ern. taro Depsstrnent %: Sinp 8tl e 34S E.41th se.. Nece voan. 7#.s.100lf 212 706 7087. TYd?..f 10 %515767 e OW!!' 217 70S 7673 Mr solLE A /Jeo ATTACHMENT B Mtsvat vessel oAwarTEE IT.""/S:::mc. a.m.
March 1,,1983 T8tWip.u.
egeg Mr. E. Potter save pain Commonwealth Edison Co.
Haywood Technical Center 1319 South First Avenue Maywood, IL 60153
Subject:
Section V; Code Case 1914 for Alternate Pentrarneter Placement Item:
EC82-113
Reference:
Your letter of February 2,1982
Dear Hr. Fatter:
The Cormnittee at its meeting of September 17, 1982 approved a proposed Code Case which will be of interest to you.
The case is attached for yoiir informatieri.
The Code Case, as approved by Council, will become effective as of February ),1983, Very truly yours, CluA Paul D. Stumpf Assistent 8ecretary/5011er and Pressure Vessel Cormittee (212) 705-7096 PDS/ky i
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Ntn e Arneric** Astetutico or laqineettng Sociele i Accanditation Desed for EMttwesteg and Technolow ~
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cede case M14 for Aternative Penetrameter Pta_coment. Section__V Inttuir7:
la it permissible to place penetrameters on the weld in lieu of, or in addition to, che penetraeeters placed adjacent to the weld, an
- requiredby T-263,1(a) of Section V1 Meply:
It'is the opinion of the Comaittee that for Seccion V applications, che penetrameter glacement described in the Inquiry is permicced, provided the penetramatar identifying numbers and skim (s) (if used) are not placed on the weld metal.
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-ENCLOSURE StPPLEENTAL RESPONSE TO INSPECTION REPORT 50-456/84-05 Af0 50-457/84-05 ITEM 456/84-05/05 Ato 457/84-05/05 ITEM B CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED Review of testing lab and mechanical contractor records has been completed and the population of radiographs generated. This population contains the four (4) welds identified during NRC review as having base material indications, six (6) additional welds having base material indications and twenty-one (21) welds with Commonwealth Edison Level III involvement. The ten (10) welds with basemetal indications involve material supplied by the NSSS vendor. The re-evaluation of these welds will be performed by a Level III from this vendor. The remaining twenty-one (21) welds will be re-evaluated by the AE Level III.
The project procedure for control of Level III review outside the Pittsburgh Testing Lab or Phillips Getschow orginizations is in the review approval process.
With the review process exceeding previous extimates, this work is not expected to be complete until January 7, 1985.
ITEM B DATE OF FULL CO!FLIANCE Completion expected January 7,1985.
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