ML20153C652
| ML20153C652 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/06/1986 |
| From: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20153C655 | List: |
| References | |
| 50-456-85-58, 50-457-85-54, NUDOCS 8602210367 | |
| Download: ML20153C652 (11) | |
See also: IR 05000456/1985058
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U.S. NUCLEAR REGULATORY CCMMISSION
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REGION III
Reports No. 50-456/85058(DRP); 50-457/85054(DRP)
Docket Nos. 50-456; 50-457
Licenses No. CPPR-132; CPPR-133
Licensee: Connonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Braidwood Station, Units 1 and 2
Inspection At: Braidwood Site, Braidwood, Illinois
Inspection Conducted:
December 2, 1985 through January 24, 1986
Inspector:
R. D. Schulz
W. J. Kropp
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N.' Ga dner, Acting Chief
cf/g/[d
Approved By:'Braidwooo Project Section
Daye /
Inspection Sunnary
Inspection on December 2, 1985 through January 24, 1986 (Report No.
50-456/8505S(DRP); E0-457/85054(DRP]"
Areas Inspected: Routine, unannounced safety inspection of activities with
Fegard to licensee action on previously identified items, licensee action on
10 CFR 50.55(e) reports, plant tours (cold hydro), piping, electrical
construction, and coatings allegation meeting. The inspection consisted of
168 inspector-hours onsite by two NRC inspectors including 24 inspector-hours
onsite during off-shifts.
Results:
No violations or deviations were identified.
8602210367 960210
ADOCK 05000456
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DETAILS
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1.
Persons Contacted
Commonwealth Edison Company (CECO)
M. J. Wallace, Project Manager
- P. L. Barnes, Regulatory Assurance Supervisor
- D. L. Shamblin, Project Construction Superintendent
G. E. Groth, Assistant Construction Superintendent
- E. E. Fitzpatrick, Station Superintendent
G. Marcus, Assistant Manager Quality Assurance
- T. E. Quaka, Site Quality Assurance Superintendent
S. Hunsader, Quality Assurance Supervisor
~*L. Kline, Regulatory Assurance Group Leader
C. Gray, Project Construction Supervisor
- D. Skoza, Engineering Supervisor
M. Gorski, Engineer
D. Boone, Project Construction Field Engineer
D. Farr, Project Mechanical Supervisor
Phillips Getschow Company (PGCo)
T. O'Connor, Site Manager
K. Kranz, Quality Assurance Site Manager
J. Stewart, Project Engineer
G. Galloway, Assistant Project Engineer
R. Hamilton, Welding Supervisor
The inspectors also contacted other licensee and contractor personnel,
including craftsmen, and technical and engineering staff members.
- Denotes those attending the exit meeting on January 24, 1986.
2.
Licensee Action on Previously Identified Items
a.
Violations
(Closet; e.56/84-07-04; 457/84-07-04:
Four L. K. Comstock (LKC) weld
inspectors were not proficient in the American Welding Society
Structural Welding Code, AWS D1.1-1975.
This was evidenced by their
inability to answer questions pertaining to the repair of weld
cracks and fit-up tolerances.
The licensee'v torrective action
consisted of conducting training for LKC QC ina ectors in the AWS
D1.1-1975 we ding code and revising LKC Preteaure 4.8.3, " Weld
Inspection," to further clarify weld inspection requirements.
The
inspector verified that this corrective action was implemented by
the licensee.
The training of the LKC QC inspectors in the AWS D1.1
welding code was conducted on May 15, 1984, by LKC's Corporate
Welding Engineer.
LKC procedure 4.8.3 was revised to clarify weld
inspection requirements and was effective May 15, 1984.
The
corrective action taken to avoid further noncompliance included
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revising LKC Procedure 4.1.3, " Qualification Classification and
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Training of Quality Control Personnel," to inclu.ie AWS Dl.1-1975 as
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required reading.
The inspector verified that LKC procedure 4.1.3
identifies AWS D1.1-1975 as required reading for weld inspectors.
In the response to this violation, dated August 20, 1984, the
licensee stated that the LKC weld inspectors are competent and have
been competent to ptform tt.nr assigned weld inspection tasks and
acknowledged that the weld inspectors had not received specific
training in the AWS Dl.1-1975 welding code.
The licensee believed
that this lack of specific training in AWS D1.1 occurred because the
weld inspector training concentrated on the procedure used to
perform the inspections which included the applicable AWS Dl.1
requirements (LKC Procedure 4.8.3, " Weld Inspection").
To
determine if the LF'; weld inspectors, prior to the vioh ion, were
competent to perform assigned weld inspection tasks, the inspector
reviewed documents w*th the following results:
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(1) LKC Procedure 4.8.3, Revision E, " Weld Inspection," in effect
at the time of the violation, adequately delineated the
requirements for weld acceptability.
This procedure was
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reviewed and found acceptable by a regional specialist.
This
procedure was required reading for LKC weld inspectors.
(2) LKC Welding Inspectors have previously identified discrepancies
with weld fit-ups.
The inspector reviewed three Inspection
Correction Reports (ICRs) issued in 1984 which identified in an
acceptable manner inadequate weld fit up or inaccessibility to
verify fit up.
(3) Nonconformance Reports (NCRs) were issued for identifying
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cracks in welds.
The inspector reviewed five NCRs which were
properly dispositioned.
The dispositions included, where
necessary, the required nondestructive examination and rework
of the cracked weld.
(4) Previous NRC inspections have not identified a programmatic
problem with LKC inspection of welds.
These previous inspections
included a Construction Appraisal Team inspection (456/84-44;
457/84-40) which involved an assessment of LKC welding activities.
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Based on the above, the inspector has determined that the LKC QC
inspectors were competent to perform assigned weld inspection tasks
and to identify any weld deficiencies.
This item is considered to
be closed.
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(Closed) 456/84-07-06; 457/84-07-06:
The licensee did not take
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appropriate corrective action with regard to an audit deficiency
issued during their site QA audit QA-20-80-22.
This audit
deficiency pertained to a site contractor (Napoleon) not having a
procedure for certifying QC inspectors.
This audit deficiency was
closed based on a procedure being developed and issued which
delineated the certification process of the QC inspectors.
The
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corrective action for the audit deficiency did not require assessing
the adequacy of the inspectors' qualifications for potential impact
on work performed prior to the audit finding.
The licensee's response
to this violation documented the following corrective action:
(1) A review of the educational background and training of each of
the Napoleon Quality Control Inspectors employed at Braidwood
prior to July 1980.
(2) A review of deficiencies identified during their 1980 QA audits
at Braidwood to assure properly documented close out.
The
focus of this review was to assure that the acceptability of
past work was documented.
(3) Revising commonwealth Edison's Quality Assurance Manual
Procedures Q.P. 18-1, " Quality Program Audits," and Q.P. 18-51,
" Audits for Operation - Quality Assurance Program Audits," to
require that audit deficiencies shall only be closed after
corrective action completion has been verified.
(4)
In an effort to reinforce the importance of addressing past
work when closing audit items, coverage of the proper
evaluation and documentations of past work in the close out of
audit items was added to the training outline of the licensee's
auditor training course.
The inspector evaluated each of the above corrective action items
with the following results:
(1) The Napoleon QC inspectors activities included final inspections
of placement of reinforcing steel and the installation of post
tensioning components.
It was determined that these inspections
were subjected to additional inspections by other site organi-
zations.
The installation of the reinforcing steel was also
inspected by Gust K. Newberg (GKN) QC inspectors in accordance
with GKN Quality Control Procedure, Section 8, " Placement of
Reinforcing Steel." The inspector reviewed eight documentation
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packages and verified that GKN QC inspectors had verified the
acceptability of the reinforcing steel placement.
The inspector
also verified that a QC inspector from Inryco, the supplier of
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the post tensioning materials, monitored the installation of
the post tensioning components.
These inspections were
documented on Inryco " Weekly QC Reports." The Inryco field
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inspector verified that the following activities were acceptable:
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Tendon placement
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Button heading of tendons
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Tendon stressing and
Greasing of tendons
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Based on these overinspections of Napoleon's final inspections
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performed by other site organizati ms, there was no impact on
work prior to the audit deficiency.
(2) The licensee's review of the closing of audit deficiencies
identified during their 1980 QA audits at draidwood was
expanded to audit deficiencies issued during their 1981 audits.
This expanded review was to provide additional assurance that
past work has been adequately addressed.
This review
determined that past work was addressed, did not require to be
addressed because of the nature of the audit deficiency, or was
in the process of being resolved.
The inspector reviewed
several of these audit deficiencies and concurred with the
licensee's assessment.
(3) The inspector verified that Q.P. 18-1 and Q.P. 18-52 were
revised to required audit deficiencies to be closed only after
corrective action has been determined to be implemented.
(4) The inspector verified that the training outline of the
licensee's auditor training course covered the proper
evaluation and documentation of past work in the close out of
audit items.
In addition, the format for deficiency write-ups
have been revised to address any impact on previous work. An
inspection by regional personnel in September 1985 (456/85046;
457/85045) verified that this corrective action was effective.
This item is considered to be closed.
(0 pen) Violation 456/84-44-04; 457/84-44-04:
Fasteners utilized in
Class 1E seismic cable tray hangers and battery racks did not always
meet the requirements of ASTM A307 in regards to the manufacturer's
identification marking.
Some of the corrective action had been
evaluated and verified for implementation during the inspection
period documented in Inspection Report 456/85032; 457/85031.
The
inspector, assisted by a regional specialist, reviewed the test
results for sixty (60) fasteners selected from various installations.
The sixty fasteners tested were in addition to the sixty fasteners
selected from storage which were previously tested.
The disposition
of the licensee's Nonconformance Report (NCR) 692, which identified
this deficiency in the ASTM A307 fasteners, was reviewed by Sargent &
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Lundy and appropriate licensee personnel.
The disposition was "use
as is" based on the results of the product audit (testing of 120
faster.ers).
The inspector has determined that the corrective action
and disposition documented on NCR 692 was adequate.
The inspector
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reviewed NCR 783, which was issued December 2, 1985, that identified
unmarked A307 bolting in vendor supplied equipment.
This NCR does
not yet have an approved disposition.
The inspector will review the
disposition once it is approved by the appropriate licensee personnel.
This violation will remain open pending the adequate closure of NCR
783.
(Closed) 456/85007-08; 457/85007-08:
The piping contractor did not
have a procedure or documented instruction stipulating a systematic
method for producing an accurate Inservice Inspection drawing.
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The corrective action consisted of revising Commonwealth Edison
Procedure PCD-25, " Distribution And Control Of Site Preservice
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Inspection Drawings." The change was included in Section 4.1 and
stated, "The PSI Isometric's drawings shall include all the
attributes detailed on the ISI checklist (Attachment B)."
A supplemental response from the licensee to the NRC was issued on
January 24, 1986, and stated that the ISI checklist would be used by
Phillips Getschow piping personnel and a letter from the Project
Construction Superintendent to Phillips Getschow on January 26,
1986, notified the contractor of this requirement.
In addition the supplemental response stated that the licensee has
and will continue to review the drawings for conformance with
preservice conditions, including the fact that examination crews
walkdown the drawings while performing the baseline volumetric and
surface examinations.
This item is considered to be closed.
(0 pen) 456/85015-06: The licensee's Quality Assurance Department
inappropriately closed Nonccqformance Report (NCR) 600 and as a
result did not assure that conditions adverse to quality were
corrected.
Part of the licensee's corrective action and corrective
action to preclude recurrence was evaluated and verified for
implementation during the inspection period documented in Inspection
Report Nos. 456/85032; 457/85031.
The inspector evaluated and
verified further licensee corrective action pertaining to this
violation.
This corrective action ccrsisted of the licensee's QA
department performing an independent review of ten NCRs closed
during the same time frame as NCR 600 (September 1984).
This review
included verification that the corrective actions were complete and
effective.
The review also addressed proper identification,
documentation, and disposition of the selected NCRs.
The NCRs
reviewed by the licensee were:
NCRs 511, 366, 623, 570, 468, 437,
569, 332, 424, and 483.
The inspector also reviewed the NCRs and
their supporting documentation and determined that they were
properly closed.
The licensee's QA department identified
clarifications which were required for some of these NCRs.
These
clarifications had no technical effect on the disposition of the NCR
(typographical errors, blocks left blank instead marked "N/A,"
etc.).
The inspector also selected five other closed NCRs to
verify the effectiveness of licensee's review.
These NCRs were:
Issued
Closed
521
6/84
9/84
591
1/84
8/84
648
8/84
12/84
726
2/85
8/85
743
5/85
10/85
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The inspector verified that these NCRs were also dispositioned and
closed in a proper manner.
Based on the ten NCRs reviewed by the
licensee and the five NCRs selected and reviewed by the inspector,
the improper closure of NCR 600 has been determined to be an isolated
case.
However, this violation will remain open pending the closure
of NCR 600 which was reopened to resolve any hardware deficiencies.
The closure of NCR 600 will then be evaluated by the inspector to
ensure that any hardware deficiencies pertaining to ASME Class I
supports have been adequately resolved.
b.
Unresolved Items
(Closed) 456/84-13-05; 457/84-13-05:
Two spent fuel storage racks
were damaged.
One of the rack's flare plates at the end of the
alignment box was bent.
The other rack had slightly deformed
support beams.
Sargent & Lundy analysis and the fabricator's
inspection of the deformed beams supported an acceptance of the
beams in their present condition. The slight deformations will have
no effect on the functional aspects of the rack and no safety
significance exists.
Cell number nineteen was free path tested and
met the acceptance criteria of the drag force required to insert and
remove the assembly from the cell.
The damaged flare plates have
been removed and replaced.
The three welds made for the repairs
were visually inspected by the licensee's Quality Assurance
department and found acceptable.
This item is considered to be
closed.
(Closed) 456/84-13-07; 457/84-13-07:
Documentation for the spent
fuel storage racks and failed fuel rack was missing.
This
documentation was subsequently found at the fabricator's shop.
The
documentation was reviewed and found to be in conformance with
specifications 5106-M-200 and F/L-2743.
Documentation reviewed
included:
Welding Records
Visual Inspection Procedure 763, Revision 1
Joirt Preparation Inspection Records
Surface Roughness Inspection Records
Penetrant Test Reports
Certified Material Test Reports (Components and Welding
Material)
Functional Free Path Test Inspection
Dimensional Acceptance Reports
Cleanliness Acceptance Reports
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Penetrant Test Report No. 3913 was traceable to the failed fuel
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rack assembly
This item is considered to be closed,
c.
Open Items
(Closed) Open Item 456/84-07-01; 457/84-07-01: Conflict between
licensee directive BRD 7921 and Regulatory Guide 1.58 which endorses
ANSI N45.2.6 (1978), " Qualifications of Inspection, Examination, and
Testing Personnel for Nuclear Power Plants." The licensee issued a
directive BRD 12,256 on July 11, 1984, which transmitted to site
contractors a site standard for qualifying and certifying personnel
to ANSI N45.2.6 (1978). This standard required the site contractors
to use the education and experience as stated in ANSI N45.2.6 except
for the requirement t5at personnel have a high school diploma or GED
equivalent (this is an NRC approved exception noted in Appendix A
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in the FSAR).
Licensee Procedure PM-12 " Qualification / Certification
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of Contractor Personnel Performing Inspection Services at the
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Braidwood Station," clearly establishes the qualification and
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certification requirements for site contractor QC personnel. This
item is considered to be closed.
(0 pen) 456/85023-05; 457/85024-05: Thirteen structural steel bolted
connections had torque values below the installation torque, and
turn-of-the-nut-installations were subject to fluctuations in
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foot-pound torque. The licensee analyzed these 13 connections and
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found the discrepant torques not to be design significant, based on
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the connections being " bearing" type connections in which the joint
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does not rely on the friction developed by the pre-tensioning torque
to transfer forces.
Furthermore, additirnal training was given to
the craftsmen to assure proper tightening of future installed
structural connections. These training records were reviewed by the
inspector and were found to be adequate.
However, based on the
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fluctuations in the turn-of-the-nut-installations, the licensee will
reinspect all " slip-critical connections," which were tightened by
the turn-ef-the-nut method.
For " slip-critical" connections the
friction force developed by pre-tensioning is required to prevent the
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connection from slipping.
Pending the completion of the reinspection
this issue will remain open.
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No violations or deviaticns were identified.
3.
Licensee Action on 10 CFR 50.55(e) Reports
(Closed) 456/84-06-EE; 457/84-06-EE: A leak in the bottom of the Recycle
Holdup Tanks, OAB01TA and 0AB01TB, was caused by lap joint welds with
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weld crevices and foundatior sand which provided an environment that
promoted bacteria growth leading to accelerated corrosion.
As
corrective action measures the licensee:
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replaced the sand bed with concrete fill
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replaced the tank floor utilizing butt welded joints rather than the
existing lap joint fillet welds-
The NRC examined the tank bottoms and reviewed the final documentation
package including:
Code Data Reports
Hydrostatic Test Report
Nondestructive Examination Personnel Qualifications
Vacuum Box Test Report
Welding Records
Nondestructive Test Reports
This item is considered to be closed.
No violations or deviations were identified.
4.
Plant Tours
The inspectors observed work activities in progress, completed work, and
plant status during general inspections of the plant.
Observation of
work included high strength bolting, safety-related pipe welding, reactor
coolant pipe welding, HVAC welding, anchor bolts, structural welds,
mechanical equipment installations, piping spool transfers,
instrumentation racks, instrumentation piping, and cable trays in the
containments and auxiliary building.
Particular note was taken of
material identification, nonconforming material identification, and
housekeeping.
Craft personnel were interviewed in the work areas.
On January 23, 1986, the licensee completed a cold hydro on the reactor
coolant system, pressurizer system, chemical and volume control system,
safety injection system, and residual heat removal system.
The hydro was
a partial retest for all replacement material and repair welds.
The
original cold hydro was completed on August 4, 1983.
The pressure was
held at 3107 psig for ten minutes and then the applicable welds were
examined for leakage at 2485 psig.
The cold hydro was reviewed for
compliance with:
Fill Vent and Heatt a Procedure BwPT-RC-24
Cold Hydro Procedure
ASME Boiler and Pressure Vessel Code,Section III, Subsection
NB-6000
PGCP-39, Pressure Testing of ASME and Safety Related Piping
Both the resident inspectors and regional based inspectors witnessed the
cold hydro.
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The cold hydro was deemed to be satisfactory with the exception that
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several valves were found in an incorrect position (closed vs. open), by
the piping contractor.
The incorrect position of these valves will be
evaluated to determine if some of the welds were not subject to either
the cold hydro test pressure or were not tested on the original cold
hydro date of August 1983.
This evaluation by the piping contractor, to
determine if an additional partial cold hydro test is required, will be
reviewed by the NRC.
Weld maps were used by the weld inspectors and the
welds were identified with yellow tape to assure that all welds were
visually inspected.
No violations or deviations were identified.
5.
Piping
A 3" piping line, 1CV01FB-3," was walked down between valve 1CV8401B and
letdown heat exchanger ICV 04AA.
Field examinations included
identification of welder symbols and weld numbers, weld quality, material
identification markings, configuration, clearances, and line location in
accordance with the as-built drawing, IA-CV-10.
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After field installations were inspected, the inspector reviewed the
following associated documentation and determined the installations met
regulatory requirements:
Piping, NPP-1 Code Data Reports
Valve, NPV-1 Code Data Reports
Welding Filler Metal Material Certifications
Piping Material Certifications
Weld Numbers and Welder Qualification Records
Welding Procedure Qualification Records
Nondestructive Examination Reports, Penetrant and Radiograph.
Quality Control Inspection Records Including End Preps, Fit-up, Root
Weld, Pre-Heat, Interpass Temperature, and Final Visual Weld
Examinations.
No violations or deviations were identified.
6.
Electrical
The inspector reviewed the licensee's activities pertaining to
construction of electrical raceways in the Unit 2 containment.
The
construction of electrical raceways in the Unit 2 containment has been
assigned by the licensee to Gust K. Newberg (GKN).
The inspector
reviewed the procurement change documents for this new scope of work.
The contract change documents require the work to be performed in
accordance with Sargent & Lundy Specification L-2790A, " Electrical
Installation Work - Braidwood Unit 2."
The inspector reviewed the
interim approval GKN Quality Control Procedures for compliance with
applicable regulatory requirements, codes and standards.
No problems
were noted.
The quality control procedures reviewed were:
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Section 2, "Trair.ing Program"
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Section 3, "QAM and QC Procedure Control"
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Section 5. " Deviation /Nonconfermance Reports"
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Section 6, " Control of Measuring and Test Equipment"
Section 8, " Receipt, Storage and Issuance of Safety Related
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Materials
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Section 11-1, " Weld Repair"
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Section 14, " Installation and Inspection of Conduit Junction Boxes,
Pull Boxes, Wireway, Terminal Boxes and Their Supports"
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Section 15, " Installation and Inspection of Cable Pan"
No violations or deviations were identified.
7.
Coatings Allegation Meeting
(0 pen) Allegation (RIII-86-A-0008): On January 23, 1986, a meeting was
held by the licensee to discuss the disposition of certain nonconformance
repcrts (NCRs) issued by the coatings site contractor (Midway). This
meeting was attended by key personnel of the licensee's staff, Sargent &
Lundy (S&L) personnel involved in the disposition of the NCRs and NRC
personnel.
The NCRs discussed at this meeting identified a deficiency in the coatings
for the Unit 1 and 2 containments in that the coatings were not applied in
accordance with the manufacturer's recommendations. The S&L disposition
of these NCRs were "use-as-is."
This disposition was based on pull test
results which are used to determine the adhesiveness of the coating system.
The licensee presented their position as to why pull tests, used as a
basis for dispositioning the NCRs, was acceptable in lieu of performing
Design Basis Accident (DBA) testing in accordance with ANSI N101.2,
" Protective Coatings (Paints) for Light Water Nuclear Reactor Containment
Facilities." As a result of this meeting, the licensee committed to submit
data which supports their position to NRR for review.
No violations or deviations were identified.
8.
Exit Interview
The inspector met with licensee and contractor representatives denoted in
Paragraph I during and at the conclusion of the inspection on January 24,
1986. The inspector summarized the scope and results of the inspection
and discussed the'likely content of this inspection report. The licensee
acknowledged the information and did not indicate that any of the
information disclosed during the inspection could be considered proprietary
in nature.
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