ML20151K956
| ML20151K956 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Braidwood |
| Issue date: | 06/19/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20151J031 | List: |
| References | |
| FOIA-87-866 NUDOCS 8506260575 | |
| Download: ML20151K956 (26) | |
Text
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I J UN 1 1 13 0 1
l HEHORANDUM FOR:
C. E. Norelius, Director Division of Reactor Projects, Region 111 FROM:
J. G. Partlow Otractor Olvision of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF !HPt.EHENTATION OF TSE NRC INSPECTION PROGRAM BY REGION !!! AT BRAIDWOOD STATION The Of fice of Inspection and Enforcement described to the Commission in SECY 82-150A the assessment of the implementation of the NRC inspection program in conjunction with Construction Appraisal Team CAT) lispections.
Accord-ingly, we have examined Region 111 s implementat on of the construction inspec-tion program based on the December 1984-Janur..y 1985 CAT inspection at Braidwood.
The results of the inspection wtre documented in Inspection Report 50 456/84-44, 50-457/84 40 dated February 2C,1985.
The enclosure to this memorandum documents the results of our asst ssment of the construction inspec-tion program implementation.
J. G. Partlow, Director Division of Inspection Programs l
Office of Inspection and Enforcement
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REGIONAL CONSTRUCTION INSPECTION PROGRAM ASSE55 MENT
- BRAIDWOOD (R-III) 1, OBJECTIVE The Construction Appraisal Team (CAT) of the Division of Inspection Programs conducted an announced construction inspection at the Braidwood Station of the Commonwealth Edison Company (CECO) during the period of December 10 20, 1984 and January 7 18, 1985. While the predominant effort of the inspection team was devoted to hardware inspection, the team also evaluated project management, the control of design changes and corrective action.
At the specific request of regional management an ef fort was also made to evaluate the ongoing Braidwood Construction AssessmentProgram(BCAP).
BCAP is a comprehensive assessment program instituted by Ceco to verify the quality of construction at the site.
The program elements of the a6sessment plan are to implement a construction sample reinspection, a reverification of procedures to specification requirements and a review of significant corrective action programs.
The objective of this assessment was to evaluate Region !!!'s implementa-tion of the Construction Inspection Program, and to make an overall assessment of the adequacy of Region Ill's oversight of construction activities at the Braidwood site.
- 11. Assessment Activities A review was made of Braidwood's inspection reports, SALP reports and construction deficiency reports to identify those deficiencies that were i
previously identified by Region !!! inspectors or the licensee.
The inspection reports of 1979 1984, the 1983 and 1984 sat.P reports, open items and violations were reviewed.
To determine inspection ef fort at the Braidwood site the inspection reports for 1979 1984 and the 766 inspection data were analyzed.
It was determined that Region !!! performed approximately 3600 manhours in 1983 and 5300 manhours in 1984 of direct inspection effort at the Braidwood site.
The inspection hours for 1983 and 1984 were compared to two unit sites in a similar state of construction and the manhours were found comparable thus indicating a satisfactory level of inspection effort at the site. The analysis of the inspection reports and 766 cemputer data indicated that the construction inspection program was approximately 90 percent complete at the start of the CAT inspection.
The Executive Summary and Potential Enforcement Actions of the Braidwood CAT inspection report (50 456/84-44 50 457/84-40) is provided as Appendix A and Appendix B, respectively, j
To determine the adequacy of the BCAP, a review was made of the written program, the organization, the implementing procedures and the periodic progress reports issued by BCAP and the Region. Only a limited BCAP sample of hardware was available for overinspection by the CAT and these samples were inspected and a limited assessment made.
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Ill. ASSESSMENT FINDINGS A.
Electrical and Instrumentation Construction 1.
CAT Findings The CAT inspectors found that electrical separation criteria established in quality control procedures were not sufficient to identify installations of raceway and cables violating design requirements for separation.
2.
Assessment g.
The cable raceway separation deficiencies were previously identified by Regional Inspectors in Braidwood Report No.
50-456/82-06.
During this inspection the inspectors identified two areas of separation deficiencies.
These were:
a.
Inadequate separation between Class IE and non-Class 1E cable trays.
b.
Inadequate separation distance in four areas where Class 1E cables travel in free air.
As a result of the separation deficiencies identified during this inspection a Level IV and Level V notice of violation were initiated against Commonwealth Edison Company, 3.
Recommendation Region 111 has satisfactorily implemented the Construction Inspection Procedures in the areas of Electrical Construction.
However, a number of electrical separation problems have been identified at plants in other regions and an Information Notice has been prepared and issued so that resident and regional inspectors will be aware of the problem.
In addition, a memorandum has been transmitted to NRR requesting clarification on different interpretations of IEEE-384.
B.
Mechanical Construction 1.
CAT Findings The CAT inspectors determined that the licensee's inspection programs have failed to identify areas where seismic category I pipe supports / restraints and other seismic pipe supports /
restraints have not been constructed in accordance with design requirements.
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Assessment The region has implemented a significant portion of the inspection module relative to pipe supports.
In Inspection Report No. 84-14 a number of supports / restraints were inspected and no major problems were identified.
In Inspection Report No. 84-09 inspectors identified missing hardware and inadequate documentation in their examination of pipe whip restraints.
In addition to the inspections, Regional Management has encouraged the licensee to conduct a reinspection of a sample of pipe supports / restraints to determine the adequacy of construction.
Subsequent to the licensee's inspection the results of the reinspection will be analyzed and and further corrective action, if required, will be recommended by the Region.
3.
Reconendation The Construction Inspection Procedures for this area are evaluated to be adequate to have identified the problem found by the CAT inspectors.
C.
Welding - NDE 1.
CAT Findings The CAT inspectors found that vendor procured tanks and heat exchangers were accepted and installed with deficient welds.
In addition, various vendors have supplied radiographs which did not have the required weld and film quality.
2.
Assessment Past CAT inspections have also identified welding deficiencies in vendor provided equipment.
This problem has been brought to the attention of the Vendor Program Branch and they are modifying their inspection approach in an ettempt to reduce the number of deficiencies that are being found in the field.
Problems similar to the vendor supplied radiographs which did not have the required weld and film quality were previously identified by the Mobile VAN (NDE) during their inspection at Braidwood on March 26-April 6 and April 9-20, 1984 (Inspection Report No. 84-05).
The inspection was conducted of safety-related piping, structural and support weldments fabricated to ASME Code,Section III, Classes 1, 2 and 3 and AWS D1.1.
As a result of this inspection four violations were identified concerning unacceptable radio-graphs, obsolete drawings, failure to identify non-conforming conditions and failure to identify weld defects.
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The findings of the Mobile NDE van were compared to CAT findings in the welding and design change control area and were found to be in general agreement.
3.
Recommendation l
The Construction Inspection Procedures for this area are deter-mined to be adequate.
An IE Information Notice has been issued relating to the tank and heat exchanger weld problems.
0.
Material Traceability and Control 1.
CAT Findings y
10,500 feet of General Electric "Vulkene" switchboard wire was received at Braidwood.
Some of this wire has been i
installed without appropriate qualification to IEEE i
383-1974.
Bolting material for Class 1E seismic cable tray hangers and fer Class IE storage battery racks were found that did 7
not meet the requirements of ASTM A307 that was specified.
2.
Assessment In Braidwood Inspection Report No. 8413, the Region III inspectors checked electrical discipline procurement documents for technical adequacy, Quality Assurance program requirements,10 CFR 21 provisions, identification of items, and if the supplier was on the approved bidders list.
The sample of procurement documents totaled 14 items which included ASTM A36 plate, structural steel, tube steel, and heat shrink tubing.
Problems were not identified with the procurement documents except for the failure of one vendor to specify the application of 10 CFR Part 21 to the procurement item.
Regional inspectors inspected 6 cable raceway supports for configuration, dimensions, elevation, welding detail, 1
bolting, and correct material type in October,1984 as documented in Inspection Report No. 84-31.
There was no i
documentation that there were problems identified with improper bolting material.
In October, 1984 Regional inspectors inspected the battery racks as documented in i
Inspection Report No. 84-29 but there was no identifica-i tion of improper bolting material.
3.
Recommendation The Construction Inspection procedure for the area of procure-ment appears to be adequate. The procedures for the inspec-tion of cable tray supports and battery racks to assure that material installed is as specified also appears to b2 adeouate.
However, even though the inspection procedures appear to be adequate, in the last seven of 10 CAT inspections, problems have 4
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i been identified with traceability for fasteners.
The Reactor Construction Programs Branch will conduct a review of the fastener traceability problem and if justified issue an Informa-tion Hotice identifying traceability as a potential problem area.
E.
Corrective Action Systems 1.
CAT Findings NCR 39 identified weld deficiencies in electrical struts and hangers.
The supporting document. tion attached to the NCR identified that 90 percent of the welds were unaccept-able.
The corrective action block on the NCR was marked "N/A" and contained a statement identifying the welds as acceptable.
There was no documentation supporting this corrective action statement on the NCR.
HCR 293 identified weld deficiencies on back-to-back B-line strut and spaced back-to-back strut.
The corrective action was to rework the deficient welds on the back-to-back strut and return the spaced back-to-back strut to the vendor.
Inspection of installed spaced back-to-back struts identi-fled numerous weld deficiencies.
Based on the weld def t-ciencies noted in the installed strut, the corrective action for this NCR was ineffective.
2.
Assessment Region III management has recognized the inadequacy of the licensee's corrective action program.
In a meeting between Region III management and Commonwealth Edison management on February 17, 1983, it was brought to the licensee's attention i
that the corrective action may be narrowly limited to the precise finding instead of broad applicability.
It was further emphasized that there was a need to review construction events to determine root causes and '.ake positive corrective actions.
Followup meetings were held in July, September and October of 1983 in order to improve licensee construction performance. As a result of these concerns Commonwealth Edison Company initiated the BCAP. One element of BCAP is to determine that corrective actions have been adequately implemented and documented for past construction problems that have been identified and resulted in significant corrective action.
Those significant corrective action programs that are included under BCAP are:
Reinspection of safety-related mechanical equipment Quality control reinspection Piping heat number traceability Quality control structural steel review Electrical installation document review Safety-related pipe supports HVAC welding HVAC configuration 5-m
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HVAC duct stiffener and fitting detail Instrumentation installation verification HSSS component support verification 3.
Recommendation The Construction Inspection Procedures for these areas are evaluated to be adequate for their intended scope.
Regional efforts to improve licensee performance for adequate corrective actions are being accomplished through the management meetings and the BCAP.
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F.
Braidwood Construction Assessment Program 1.
CAT Findings The CAT inspectors found that three of six supports /
restraints that had been inspected by BCAP inspectors had deficiencies that were not identified by the BCAP inspectors.
The CAT inspectors found that of four piping runs inspected, that 2 runs had different inspection results between the BCAP and CAT inspectors. One run had a significant dimensional error that was not identified by BCAP and on one run BCAP had identified a dimensional error when in fact the dimension was correct.
2.
Assessment The program elements of BCAP consist of a construction sample reinspection, a reverification of procedures to specification requirements and a review of significant corrective action programs.
The status of the BCAP was such that it was not possible to do any of the three elements except a limited hardware overinspection.
It was possible to overinspect a very small sample of hardware in i
the areas of supports / restraints, piping runs, HVAC supports and ducts for welding, HVAC ducts for configuration and conduit runs.
In four of the six areas that were overinspected, there was general agreement between BCAP and CAT findings; in two areas, supports / restraints and piping runs deficiencies were identified by the CAT that were not identified by the BCAP.
3.
Recommendation On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports / restraints and piping runs.
The status of the other program elements of BCAP did not permit the CAT to make a meaningful assessment.
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IV.
REVIEW OF BRAIDWOOD CONSTRUCTION INSPECTION REPORTS 1.
Scope The inspection procedures itemized in IE MC 2512 were reviewed as to which were applicable to the Braidwood construction site.
A 766 computer printout was obtained for the entire construction period that identified report numbers, inspection procedures, inspection dates, staff hours, percent complete and status.
This information was tabulated as indicated in Attachment I for Unit No.1.
A review was then conducted for which procedures were implemented against procedure requirements.
The inspection reports prepared by the regional inspectors were evaluated to determine if they included the required information, if they were suf ficiently comprehensive, if the report was issued in a timely fashion and if the report was prepared in accordance with IE Manual Chapter 0610, 2.
Assessment The review of the MC 2512 inspection procedures required to be implemented as compared to those actually implemented indicated basically full implementation except for a few where plant construction was still in progress.
However, it was determined that one required procedure was not fully implemented.
Inspection Procedure 350208, "Audit of Applicant's Surveillance of Contractors QA/QC Activities" is required to be performed five months before docketing and subsequently as necessary.
There is no record in the 766 data bank to indicate that this procedure was performed initially or in a subsequent time frame.
At Braidwood performing the duties of construction manager, Commonwealth Edison is and is overseeing as many as ten contractors at a time performing saftty-related work.
For this kind of construction organization it is essential that the licensee conduct periodic surveillances and audits of the contrac-tor's QA/QC activities, inconsiderationofthemajorproblems identified in the electrical, mechanical, and HVAC areas, this procedure should have been implemented more than once over the past few years.
A random sample'of nine inspection reports indicated that they were essentially being prepared in conformance with IE MC 0610.
The reports included pertinent information such as report number, Docket No., Inspectors, inspection summary, results, details of inspection, persons interviewed, and individuals present at entrance and exit meetings.
Two areas for improvement were identified in the inspection reports.
One involved identifying the Inspection Procedures implemented during the inspection and including them in the paragraph of inspection summary. This format is shown in Exhibit 111 in IE HC 0610.
Another area for improvement involves the issuance of inspection reports.
The procedure suggests that inspection reports be issued 20 days af ter the last day of inspection or 20 days af ter the 7
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inspection period ends as in the case of monthly resident's reports.
The following lists the reports reviewed and the total time elapsed from the end of inspection to report issuance:
Elapsed last Day of Inspection Time Report No.
or Period Date of Report
. Date 84-07 May 31 July 20 50 84-13 July 6 Aug. 6 30 84-17 Aug. 31 Oct. 1 30 84-19 July 12 g Aug. 14 32 84-20/19 July 25 Oct. 18 83 84-22/21 Aug. 16 Aug. 28 12 84-28/27 Nov. 23 Nov. 28 5
84-31/29 Nov. 9 Nov. 26 17 The time required to issue reports is much lor.ger than recommended in MC 0610 and a concerted effort should be made to reduce the report time.
3.
Recommendation Overall the region has performed satisfactorily in the implementation of the construction procedures.
Procedure 350203 should be implemented as indicated in the assessment and regional management should make a concerted effort to have inspection reports issued in a timely interval.
V.
1983 AND 1984 SALP REPORTS An analysis was made of the two most recent SALP reports for those areas that were common to both SALP and the CAT inspection.
For the 1984 SALP report the two areas that were rated Category 3 were Piping Systems and Supports and Safety-Related Components.
In the area of Piping Systems and Supports where there was similar inspec-i tion effort, the CAT findings were similar to the regional findings, In one area there was a variance between CAT findings and Regional find-
- ings, in Inspection Report No. 84-13 a number of supports / restraints were inspected for weld defects, configuration and other attributes and no problems were identified.
The specific supports / restraints inspected were different from the CAT sample but the CAT insp ution identified an inordinate number of deficiencies.
It will be necessary for the Region to evaluate the results of the BCAP inspection in this area to determine if additional licensee effort is necessary.
In the area of Safety-Related i
Components the CAT was not able to reach a qualitative appraisal because of the ongoing reinspection and corrective action programs being imple-mented. The CAT did find that there still was not adequste protection of safety-related equipment even though this problem had been previously identified in the two most recent SALP reports.
The CAT specificall found the improper support of scaffolding on small diameter piping, ydamage to inst'cument tubing from scaffolding, unauthorized removal of supports, and poor housekeeping in safety related trays in containment.
The other
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areas rated by SALP; Containment and other Safety-Related Structures, Support Systems, Electrical Power Supply and Distribution, and Instrument j
and Control Systems were generally similar to the CAT findings.
VI.
REGIONAL HAtQLING OF ALLEGATIONS AT CONSTRUCTION SITES 1.
Scope To evaluate. regional effort in the handling of allegations.
To accomplish the foregoing a random sample of two items was selected 1
from inspection reports and reviewed for proper closure.
2.
Assessment A11ecations On March 30, 1984, an individual contacted the NRC Region III office and provided information with respect to deficiencies with the installation of the Heating, Ventilation, and Air Conditioning (HVAC) systems at the Braidwood Station.
The individual made nine specific allegations that encompassed poor worknanship because of pro @2ctivity pressures, inadequate QC inspectors, failure to follow requirements, by passing of the NCR system to correct deficiencies, improper certification of welders, failure to remove galvanized coating prior to welding and distortion of hangers because of excessive heat.
An experienced Regional Inspector conducted an unannounced safety inspection on June 12 15, 20 and 21, 1984 to address those allegations.
The inspector spent a total of 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> at the site and the result of the inspection is documented in Inspec-tion Report 84-14.
To evaluate the allegations, the inspector reviewed the contractor's past and present QA Programs, construction procedures, installation documentation, drawings, inspector training and certification pro-gram, and the current inspection and repair program.
In addition, the inspector conducted interviews with personnel and observed the training and testing of welders.
As a result of the inspector's review seven of the nine allegations were either substantiated or partially substantiated.
However, the inspector concluded that a work stoppage and a 100 percent reinspection program by the contractor, a reorganiza-tien of site management, a new QA and craft training program and revision of installation procedures would correct the alleged deficiencies.
The Region's timely and comprehensive response to this specific allegation is evaluated to be adequate.
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L.
The electrical contractor at Braidwood has a policy to interview all employees terminating their employment.
On March 9, 1984 a QC inspector who was terminating his employment provided a list of ten concerns relative to electrical construction work at Braidwood.
This list of concerns was provided to the fiRC's Senior Resident Inspector.
As a result of these concerns a Regional inspector conducted an unannounced inspection at the site on August 20-31, 1984.
The concerns identified by the QC inspector involved improper handling of inspection reports, corrosion of electrical equipment, mislabeled hangers and improperly installed conduits, trash in cable pans and trays, poor weld rod controikpoor control of in-process welding, poor control of stud welding, poor control of voided drawings and field change reports, cracks in concrete floors and walls and numerous cases of welders and electricians on drugs and/or alcohol.
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1 The inspector by reviews of licensee actions, training records, inspection check lists, procedures, construc-tion drawings, inspection reports and by interviews and,nlant inspection determined that seven of the ten concerns were substantiated.
The seven substantiated concerns were found to be previously identified by the i
contractor or licensee or there was a program in place to repair.
(Inspection Report No. 84-23)
The Region's response to the concerns are evaluated to be timely and comprehensive and were adequate.
3.
Recommendation The Region's handling of allegations relative to construction progress was evaluated to be satisfactory.
Vll. OVERALL ASSESSMENT CONCLUSIONS A review of Braidwood reports for 1979-1984 indicated that construction inspection modules appeared to be adequately implemented and that the reports were written to the appropriate scope and depth.
The Braidwood inspectors and Regional inspectors did identify a significant number of licensee deficiencies that resulted in notices of violation.
The Regional followup and corrective action review of the violations appeared to be satisfactory.
Regional management involvement with the Braidwood construction activities was evident from the Section Chief through the Regional Administrator.
Management was knowledgeable about site construction problems and had been instrumental in causing the licensee to improve and enlarge the Quality Assurance organizations at the site.
In addition, the management com-petence of a number of the site contractors was improved by changes and additions of personnel.
Regional management had a number of meetings with licensee management in 1983 and 1984 to encourage the licensee to improve its performance at the Braidwood site and to take more comprehen-sive action in the implementation of corrective action for identified
..u problems.
Regional management was also instrumental in causing the licensee to institute a comprehensive constructico assessment program (BCAP) to assure the quality of construction at the site.
Regional management attention will continue to be needed on Braidwood activities as a result of the BCAP findings and the large number of major ongoing corrective action programs thGt still have not been satisfactorily concluded.
In addition, the CAT inspection identified two areas of concern in that the licensee is placing excessive reliance on final walkdown inspections late in the construction program to identify and resolve problems and whether the site project management can manage the large r. umber of ongoing corrective action programs and still ensure that current construction work is correctly performed.
Overall, the Regional effort to oversee the construction activities at the Braidwood site appears to be satisfactory.
The implementation of the Construction Program Inspection Procedures was adequate.
Regional management attention to site construction activities is strong and will need to be maintained at the current level until some of the existing site problems are corrected.
As indicated in Section IV, Inspection Procedure 35020B needs to be implemented and regional management should make a concerted effort to have inspection reports issued in a more timely 6
fashion.
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APPENDIX A EXECUTIVE SUV?.ARY 1
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at Co=enwealth Edison Cempany's (Ceco) Braidwood Station during the period j
December 10-20, 1984 and January 7-18, 1985.
Overall Conclusions Hardware, Project Management and documentation (pr construction activities were generally in accordance with requirements and licensee comaltments.
- However, the NRC CAT did identify a number of construction program weaknesses that require increased management attention.
These are:
1.
The effectiveness of first level quality control (QC) inspection activi-ties needs to be improved, particularly in the pipe support / restraint and welding areas.
2.
A large number of final inspection activities are being included in a final walkdown, when greater difficulty will be encountered in identifying deficiencies because of interferences, accessibility and the pressure of schedule.
3.
The identification and resolution of cable tray and conduit electri-cal separation deficiencies is inadequate.
4.
An excessive number of incidents of damage to installed equipment has been caused by current construction activities.
The foregoing identified weaknesses require additional management' attention to 1
assure that completed installations meet design requirements.
An effort was made by the NRC CAT to evaluate the ongoing Braidwood Construc-tion Assessment Program (BCAp).
The schedule for the BCAP inspection program was su:h that only limited hardware samples were available for NRC CAT over-inspection.
It was possible to overinspect a very small sa ple of hardware in the areas of supports / restraints, piping runs, HVAC supports and ducts for welding, HVAC ducts for configuration and conduit runs.
In four of the six areas that were overinspected, there was general agreement between BCAP and NRC CAT findings; in two areas, supports / restraints and piping runs, deficien-cies were identified by the NRC CAT that were not identified by the BCAP inspectors.
On the basis of the limited sample overinspected, it appears that BCAP inspection effort needs to be improved in the areas of supports / restraints and piping runs.
AREAS INSPECTED AND RESULTS Electrical and Instru entation Construction The electrical and instrumentation samples inspected generally met the cpplicable design and construction requirements.
However, construction and inspection deficiencies were identified in several areas including several items which will require additional NRC review and analysis.
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Site implementation of electrical separation criteria is not consistent with the FSAR commitment which, with several exceptions, endorses IEEE Standaro 384-1914.
Several items regarding the interpretation of separation criteria will require additional NRR review.
The electrical contractor's quality control program was found deficient in that the inspection criteria was not i
sufficient to identify separation deficiencies.
As a result, a number of installations of non-Class 1E to Class IE raceway and cable were found that did not eeet, the IEEE requirements and the FSAR commitments for minimum separation.
The majority of b'olts used with raceway's identification required by the supports are of indeterminate material as they do not contain the manufacturer i
standard.
Although the instrumentation sample was not sufficiently large because of an ongoing reinspection program to draw an overall conclusion, a number of instances were identified of items damaged during the erection of scaffolding.
I Hechanical Construction Contractor QC inspections and site QA programs have not been effective in assuring that installed pipe supports /restaints meet design requirements.
The inspection and acceptance criteria provided for activities such as QC inspec-tion and document review and control need to be strengthened and clarified.
Numerous examples of generally poor construction practices were observed.
The need to protec' and maintain installed and accepted hardware needs to be reemphasized.
Piping, HVAC, concrete expansion anchors and mechanical equipment were generally found to be installed in accordance with requirements or with deficiencies that had previously been identified. However, because of ongoing re evaluations and reinspections, it was not possible to establish a coeplete and conclusive assessment of these areas.
1 The NRC CAT inspectors do not consider that the previously identified H8C i
concern regarding pipe to pipe and interdisciplinary clearances has been I
responded to in a timely or effective manner.
System and area walkdown inspec-i tions performed late in the construction program must be recognized as only an additional level of assurance of proper installation and not a substitute for i
detailed, item specific first line QC inspections.
Velding and Nondestructive Examination I
Welding and nondestructive examination activities were generally founo to be conducted in accordance with the governing codes and specifications.
- However, a number of examples were identified where completed structural welds in pipe supports / restraints did not have the weld sizes specified by the design draw-ings.
These undersized welds should have been identified during the weld inspection by QC, The licensee has perforced an engineering evaluation con-1 cerning this problem and concluded that most of these welds are adequate for i
j the intended application. In the area of vendor supplied A$ME tanks and heat exchangers a number of tanks were found to have undersized weld reinforcement I
h nezzle to shell and manway to shell welded joints.
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The HRC CAT inspectors also found radiographs which did not meet the specified acceptance criteria.
The licensee's quality assurance procedures do not require that an independent interpretation of radiographs be performed prior to final storage in the vault.
The NRC CAT believes that this lack of indepen-dent radiographic interpretation say have contributed to the Project's inability to detect, deficient radiographs.
Civil snd Structural Construction Concrete quality was acceptable.
Requirements for robar around three of four inspected construction openings and cadweld testing frequency were not met.
L Structuralsteelmembersizes!ghstrengthsteelboltswerefoundtobeconfigur concerns identified.
A few h installed at below specified torque values.
In the area of masonry wall construction, a concern was identified regarding the need to assure proper rebar anchorage prior to replacement of masonry tr the removed sections of masonry walls.
Haterial Traclability and Control The measures presently established for material traceability and control for ongoing work appear to be adequate except for one area.
During this inspec-tion, it was deterstned that 10.500 feet of switchboard wire not qualified to IEEE 383 1974 was installed at Braidwood Station.
Corrective Action The corrective action prograss generally are being implemented in accordance with requirements.
However, based on the results of this inspection, the controls for nonconformance reports issued by site contractors pr'evious to 1983 need additional review.
These include:
1.
Some nonconformance reports were volded without documented justification.
2.
Honconformances dispositioned "Use Al Is" or "Repair" were not routinely reviewed by the appropriate engineering personnel.
3.
The specified corrective actions did not in some cases adequately resolve the nonconforsances.
Design Chance Centrol, Design change control'was deterstned to be generally in conformance with applicable requirements.
In the area of the most significant finding was the f ailure to annotate unincorporated design changes on controlled design docu-ments.
The most significant finding in the area of design change control was design change documents written against superseded revisions of the approved design drawings.
In at least one instance, this dificiency resulted in a pipe support being installed and inspected to other than the latest approved design.
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i Project Management Theoverallprojectsanagementeffortisevaluatedto.besatisfactoryto construct the pro;fect in conformance with quality standards. Additional management attent'on is required to improve contractor performance in the areas of contractor deficiency trending, and craft and quality control inspector training.
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APPENDIX B POTENTIAL ENFORCEMENT ACTIONS As a result of the NRC CAT inspection of December 10 20, 1984 and January 718, 1985 at the Bratkood site, the following items are being referred to Region 111 as Potential Enforcement Actions (section references are to the detailed portion of the inspection report).
j 1.
Contrary to 10 CFR 50, Appendix B, Criterion VII and Ceco Quality AssuranceManual,QualityRequirementNo./.0,themeasurestoassurethat equipment and services conform to the proct /rersnt documents were found to be ineffective in that vendor procured tanks and heat exchangers were accepted and installed with deficient welds, in addition, various vendors have supplied radiographs which did not have the required weld and film quality.
(SectionIV.B.1,10) 2.
Contrary to 10 CFR 50 Appendix B, Criterion V!!! and CECO Quality Assurance Manual,-Quality Requirement No. 8.0, the licensee f ailed to implement measures to prevent the following incidents:
a.
10,500 feet of General Electric "VULKENE" switchboard wire was received at Brathood.
Some of this wir6 has been installed without appropriatt qualification to IEEE 383 1974.
(Section VI.B.1) b.
Sargent & Lundy standard EB115.0 required the use of ASTM A307 bolting material for Class 1E seismic cable tray hangers.
Hangers in the lower cable spreading room did not utilize ASTM 307 f asteners in some cases.
Also, the generic qualification document for the Class IE st.orage batteries specified ASTM A307 bolts for the battery racks.
The battery racts were inspected and found to have bolting material that did not meet the requirements of ASTM A307. (Section VI.B.1) 3.
Contrary to 10 CFR 50, Appendix B, Criterion X and Ceco Quality Assurance Hanual,iled to identify areas where seismic category I pipe supports have fa restaints and other seismic pipe supports / restraints have not been constructed in accordance with design requirements.
(Section !!!.B.2) 4.
Contrary to 10 CFR 50, Appendix B, Criterion X, and Ceco Quality AssJrance Manual, Quality Requirement No.10.0, the licenses failed to provide an adequate inspection program in that electrical separation criteria established in q'uality control procedures were not sufficient to identify installations of raceway and cables violating design requirements for separation.
(Section!!.B.1)
B1
5.
Contrary to 10 CFR 50, Apptndix B, Criterion X and the Ceco Quality 1
Assurance Manual, Quality R(quirement No. 10.0, the program for inspection of activities affecting quality was not effectively implemented in that the inspection programs have not identified that the specified wtId sizes in structural pipe support / restraints have the required weld configura-tion. (Section,IV.8.1) 6.
Contrary to 10 CFR 50, Appendix B Criterion XVI and CECO Quality Assurance Manual, Quality Requirem,ent 16.0, the licensee's electricai i
contractor's corrective actions for the following NCRs were found to be inadequate:
a.
NCR 39, issued in April 1979, identified weld deficiencies in elec-trical struts and hangers.
The supporting documentation attached to the NCR identified that 90 percent of the welds were unacceptable.
1 The corrective action block on the NCR was marked "N/A" and contained a statement identifying the welds as acceptable.
There was no documentation supporting this corrective action statement on the NCR.
(SectionVIII.B.1)
NCR 293, issued in May 1981,d spaced back to back strut.
b.
identified weld deficiencias on back to back B-line strut an The corrective action was to rework the deficient welds on the back to back strut and return the spaced back to back strut to the vendor.
Inspection of installed spaced back to back strut identified numerous weld deficiencies.
Bas.ed on the weld deficiencies noted in the installed strut the corrective action for this NCR was ineffective.
(Sectlen VIII.B.1)
'l 1
s l
B2
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ATTACHMENT !
INSPECTION PROGRAM HISTORY FOR BRAIDWOOD l
A.
Civil and Structural Procedures 1.
Program Requirements a.
IP 450618, 45063B, 45065B - Lakes, Dams & Canals - Procedures i
to be done before start of work and observation of work and i
review of quality records bafore tork is 50% complete, b.
IP 46051B, 460558 - Foundations - Procedures to be done before work is 10% complete and review of quality records before work is 60%, complete.
c.
IP 461538 - Site Preparattor, and Foundations - To be done before work is 60% complete,
- d. ' IP 47051B,l Concre,te)
Procedure review before start of work, 47053B 47054B, 47055B, 47056B - Containment (Structura observation of work af ter 10% and 50% and review of records af ter IG and 50%.
IP 47061B, 47063B, 47055B - Containment (Prestressing) -
e.
Procedures review before start of work, observation of work after 10% and records review af ter 20%.
f.
IP 48051B, 4B053B, 4B0558 Containment (Steel Structures and Supports) - Procedure review before start of work, observation of work and record review before work is 50% complete, g.
IP 48061B, 480638, 480648, 48065B, 48066B - Safety Related Structures (Structural Steel and Supports) - Procedure review before start of work, observation of work at 10% and 50%, and record review at 20% and 50%.
2.
Inspections Conducted at Braidwood Hod.
Report From To Staff Percent No.
Numbers Date Date Hours Complete Status a.
IP-45061B, 45063B, 45065B - Lakes, Dams & Canals 45061B 78-03 031578 031778 4
100 C
45063B 78-03 031578 031778 100 C
45065B 78-07 070678 0B1078 5
100 C
b.
IP 46051B, 460558 - Foundation 46051B 77 08 112177 112377 100 C
46053B 77 08 112177 112377 100 C
1 46055B 77 08 112177 112177 100 C
c.
IP 461538 - Site Preparation and foundations Module not in effect of time of activity.
Eariter site preparation and foundations modules completed, d.
IP 470518, 47053B, 470548, 47055B, 470568 - Containment StructuralConcrete) 4 470518 77 04 080377 080577 17 100 C
47053B 77 07 080377 080577 31 100 C
l 470548 78 10 112878 121978 1B 100 C
470558 77 05 090777 090977 11 100 C
470568 77 08 090777 090977 3
100 C
e.
IP 470618, 47063B, 470658 - Containment (Prestressing) 47061B 81 12 090981 092281 16 100 C
47063B 81 14 111881 112081 37 100 C
47065B 81 14 111881 112081 33 100 C
f.
IP 48051B, 48053B, 480558 - Containment (SteelStructuresand Supports) 48051B 79 09 080779 080979 8
100 C
48053B 79 02 020779 020979 6
100 C
48055B 79 02 020779 020979 3
100 C
g.
IP 48061B, 48063B, 480648, 480658, 480668 - Safety Related Strur,tures (Structural Steel and Supports) 48061B 81 07 060381 0605B1 1
100 C
i 480639 83 11 071183 072783 5
100 C
48064B 81 10 090181 090381 1
100 C
480658 83 11 071183 072783 4
100 C
48066B 84 17 070784 OB3184 67 100 C
B.
Mechanical Construction Procedures 1.
Program Requirements a.
IP 490518, 49053B, 490548 490558, 490568 - Reactor Coolant Pressure Boundary Piping, Procedure review before start of work, observation of work at 20% and 60% and record review after 20% and 60%,
b.
IP 490618, 490638, 490658 - Safety Related Pipirg Procedure review before start of work, observation of work at 40% and record review at 50%.
~
- ~.
J...
......................._.....,........m.,....
r
/
c, IP 500518, 500538, 500558 - Reactor Yessel Installation -
Procedure review before start of work,letion, observation of work at installation and record reytow of comp d.
IP 500618, 500638, 50065 - Reactor Vessel Internals Procedure i
review before start of work observation of work during instai-lation and record review af ter installation, e.
IP 500713, 500738, 500748 500758, 500768 - Safety Related Components Procedure rev,iew before start of work, observation of work at 10% and 50% and record review after 20% and 50% work completion, s.
f.
IP 500908 - Safety Related Pipe Support and Restraint Systems.
To be laplemented before work is 20% complete, g,
IP 500958 - Spent Fuel Storage Racks.
Observation of work before work is 50% complete 2,
Inspections Condugted as Braldwood Hod?
Report Froe To Staff Percent No.
Numbers M
Hours Complete Status a,
IP 490518, 49053B, 490548 490558, 49056B Reactor Coolant Pressure Boundary Piping,
490518 79 01 010979 011179 3
100 C
490538 41 04 040381 040881 3
100 C
490548 81 04 040381 040881 2
80 490558 81 07 060381 060581 3
100 C
490568 84 01 020884 021084 3
100 C
b.
IP 490618, 490638, 490658 - Safety Related Piping 490618 84 06 020184 033184 38 50 C
490638 81 04 040381 040881 19 100 C
490658 81 10 090181 090381 36 100 C
j c,
IP 500518, 50053B, 500558 - Reactor vessel Installation 500518 79 05 041979 042779 21 100 C
500538 79 09 080779 080979 10 100 C
500558 79 09 080779 080179 2
100 C
d.
IP 500615, 500638, 50065 - Reactor vessel Internals 500618 80 11 090980 091080 5
100 C
500638 81 04 040181 040881 13 100 C
500658 81 04 040381 040881 2
100 C
i i
I X
. ~.
e.
I e.
IP 500716, 500738, 500748, 500758, 500768 - Safety-Related Components i
500718 83 11 071183 070283 15 100 C
500738 82 08 091082 123182 84 100 C
500748 83 11 071183 072783 67 100 C
500b;B 84 13 060584 070684 66 100 C
500768 83 11 071183 072783 63 100 P
f.
IP 500908 Pipe Support and Restraint Systems 500908 84 13 060584 070684 34 50 g.
IP 500958 - Spent Fuel Storage Racks 500958 84 13 060584 070684 8
80 C,
Electrical and Instrumentation Construction Procedures 1.
Prooran Requirements a.
IP 510518, 510538, 51054B 510558, 510568 - Electrical Components and Systems frocedure review before start of work, observation of work at 30% and 60% complete and record reytev before 70%,
b.
IP 510618, 51063B 510648, 510658 510668 - tiectrical Cables and Terminations, Procedure revie,w before start of work, work observation at 10% and 50% completion and record review at 20%
and 50%.
I c.
IP 520518, 52053B 520548 520558, 520568 - Instrumentation -
Components and Sys,tems Erocedure review before start of work.
work observation at 10% and 50% and record review at 20% and 50%.
d.
IP 520618, 520638, 520648 520658, 520668 - Instrumentation -
Cables and Terminations
, Procedure review before start of work, work observation of 10% and 50% and record review at 20%
and 50%.
2.
Inspction Conducted at Braidwood Hod.
Report Free To Staff Percent No, Humbers Q,Gg Q,!,t2 Hour Complete 5 tam a.
IP 510518, 510538, 510548, 510558, 510568 - Electrical Component.: and Systems 510518 83 18 103183 011384 31 100 C
i 510538 83 18 081583 081883 60 60 510548 84 04 030584 030984 8
30 510558 84 13 060584 070684 30 60 510565 84 06 020184 033184 10 35 i
1
-i -
/
b.
IP 510618, 510635 510648, 510658, 510668 - Electrical Cables and Terminations,
51061B 83 18 103183 011384 24 100 C
I 51063B 84 23 082084 083184 40 100 C
{
510648 84 23 082084 083184 50 40 51065B 84 23 082084 083184 10 100 C
51066B 84 23 082084 083184 22 40 c.
IP 520518, 520538, 520548, 52055, 520568 - Instrumentation -
Components and Systeen 52051B 83 18 103183 111384 L
6 100 C
52053B 84 17 070784 083184 29 70 52054B 83 13 081583 081883 8
10 52055B 84 17 070784 083184 14 70 1
52056B 83 13 081583 081883 3
10 d.
IP 520618, 52063B, 520648, 520658, 520668 - Instrumentation -
Cables and Terminations
$20b,8 84-23 082084 083184 1
100 C
i 52063B 84 04 030584 030984 12 40 52064B 84 23 082084 083184 34 50 52065B Work in Progress 520668 Work in Progress e.
IP 530518, 530558, 530558 - Containment Penetrations i
530518 81 07 060381 060581 1
100 C
53053B 81 07 060381 060581 1
100 C
]
530558 81 10 090181 090381 6
100 C
0.
Velding and NDE Procedures 1.
Program Requirements I
a.
IP 550518 550538, 550558 - Containment Structural Steel Welding, Procedure review before start of work, work observa-tion af ter 20% and record review af ter 30%,
b.
Structures Veld \\ng 648, 550658, 550668 - Safety Related IP 55061B, 550638 550 Procedure review before start of work, work observation at 10% and 50% and record review at 20% and
)
50%.
c.
IP 550718 550738, 550748, 550758 550768 - Reactor Coolant FessuredoundaryPipingWelding, Procedures revlev, before start of work, work observation at 10% and 40% and record review at 20% and 50%.
4 4
d.
IP 550818, 55083B, 550858 - Safety Related Piping Welding -
Procedure review before start of work, work observation at 20%
j and record review at 30%.
i
- ~
e.
IP 550938 - Reactor Vessel Internals Welding Observation of work during installation, f.
IP 55151B, 551528, 551538 551548, 551568, 551578 $5158B -
Steel Structures and Suppo,rts Welding during var,ious stages of construction.
9 IP 55171B, 551728, 551738, 55175B, 55176B 551778 55176B -
Reactor Coolant Loop Piping Velding Activities:, To be performed at various stages of construction, IP 551818, 55182B, 55183B, 551858, 551868, 551878, 5518BB -
h.
Other Safety Related Piping Welding Activities:
1o be performed at various stages of construction.
2.
Inspections Conducted at Brathood Hod.
Report From To Staff Percent No.
Numbers Date Date Hours Complete Status a.
IP 55051B, 550538, 550558 - Containment Structural Steel Welding 550518 77 07 102677 102777 4
100 C
55053B 79 02 020779 020979 6
100 C
55055B 79 02 020779 020979 3
100 C
b.
IP 55061B, 550638, 550648, 550658, 55066B Safety Related Structures Welding 550618 81 10 090181 090381 2
100 C
55063B 78 04 041778 042078 4
100 C
550648 83 11 071183 072783 33 100 C
55065B 78 04 041778 042078 3
100 C
i 55066B 83 11 071183 072783 12 100 P
IP 550718, 550738 55074B 550758 c.
Pressure Boundary, Piping, Welding, 55076B Resctor Coolant These modules were consolidated into IP 55050 by Change Hotice 83 06.
55050 84 05 032684 042084 40 70 IP 55081B, 550838, 55085B Safety Related Piping Welding d.
550818 77 04 041977 042277 2
100 C
55083B 81 10 090181 090381 7
100 C
55085B 8001 020884 021084 3
100 C
l e.
IP 550938 - Reactor Vessel Internals Welding 1
55093B 84 01 020884 021084 3
100 C
i
~
.........,...... - -.. ~
t
/,
l f.
IP 551518, 551528, 55153B, 551548, 55156B, 551578, 55158B -
l Steel Structures and Supports - Welding Activities l-These modules were incorporated into new inspection procedure 55100 by Change Notice 83 06.
55100 84 05 032684 042084 17 80 j
g.
IP 55171B, 55172B, 55173B, 551758, 55176B, 551778, 55178B, -
Reactor Coolant Loop Piping - Welding activities 55171B 83 11 071183 072783 4
100 C
55172B 82 03 052482 060482 N 13 100 C
551738 83 11 071183 072783 11 100 C
55175B 81 09 071581 072081 1
100 C
551768 80 80 072480 081480 2
100 C
551778 81-09 071581 072081 3
100 C
55178B 83-11 071183 072783 2
100 C
h.
IP 551818, 551828, 55183B, 551858, 55186B 551878, 55188B -
,,OtherSafetyRelatedPiping-WeldingActlvities 551818 81 09 071581 072081 1
100 C
551828 80 08 072480 081480 7
100 C
551838 84 01 020884 021084 6
100 C
55185B 83 11 071183 072783 2
100 C
551868 84 01 020884 021084 2
100 C
551878 80 08 072484 081480 8
100 C
55188B 84 01 020884 021084 2
100 C
E.
Miscellaneous Inspection Procedures 1.
Program Requirements IP 30051B, 30702B, 30703B, 35020B, 350608, 35061B, 350658, a.
36100B, 37051B, 37055B, 64051B, 640538, 73051B, 730528, 73053B, 730558, 802208, 92800B, 92701B, 92702B, 92703B, 927158, 92716B -
Various inspections during construction phase, 2.
Inspection Conducted at Braidwood Hod.
Report From To Staff Percent Ho.
Numbers Date Date Hours Complete Status 300518 80 14 112580 112!60 4
100
.C 30702B Ten performed frc:t 19'.7 to 1983 30703B Perforced as proce@ces require 350208 35060B 82 03 052482 0504b?
18 90 C
350618 82 03 052482 060482 15 100 C
35065B 82 07 121582 121782 9
10 37051B 83 17 100383 121683 22 90 37055B 84 09 050184 060484 6
100 C
64051B 82 05 041982 111982 14 100 C
- +. - -
......... ~,..............
~.c
~.....
-~
i o
9 64053B 82 05 041982 111982 C
70051B 84 01 020884 021084 1
100 C
730528 84-01 020884 021084 1
100 C
Hod.
Report From To Staff Percent No.
Numbers Date Date Hours Complete Status 73053B 84 01 020884 021084 2
100 C
73055B 84 01 020884 021084 2
100 C
l 802208 80-09 011780 092300 10 100 C
927008 Performed as procedures require 92701B Performed as procedures require 92702B Performed as procedures require 92703B Performed as procedures require
.