ML20153C652

Insp Repts 50-456/85-58 & 50-457/85-54 on 851202-860124.No Violations or Deviations Identified.Major Areas Inspected: Plant Tours (Cold Hydro),Piping,Electrical Const & Coatings Allegation Meeting

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: IR 05000456/1985058 ML20153C652
References
50-456-85-58, 50-457-85-54, NUDOCS 8602210367
Download: ML20153C652 (11)

See also: IR 05000456/1985058

Text

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U.S. NUCLEAR REGULATORY CCMMISSION

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

PDR ADOCK 05000456

G PDR

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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

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.

4 (3) Nonconformance Reports (NCRs) were issued for identifying

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.

I 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

! 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

packages and verified that GKN QC inspectors had verified the

acceptability of the reinforcing steel placement. The inspector

i also verified that a QC inspector from Inryco, the supplier of

the post tensioning materials, monitored the installation of

the post tensioning components. These inspections were

documented on Inryco " Weekly QC Reports." The Inryco field

i 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

performed by other site organizati ms, there was no impact on

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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 & ,

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 '

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

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Procedure PCD-25, " Distribution And Control Of Site Preservice

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:

NCR 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

i equivalent (this is an NRC approved exception noted in Appendix A

in the FSAR). Licensee Procedure PM-12 " Qualification / Certification .

of Contractor Personnel Performing Inspection Services at the '

, Braidwood Station," clearly establishes the qualification and

] 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

the connections being " bearing" type connections in which the joint

! 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

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

3 friction force developed by pre-tensioning is required to prevent the

connection from slipping. Pending the completion of the reinspection

this issue will remain open.

i No violations or deviaticns were identified.

3. Licensee Action on 10 CFR 50.55(e) Reports

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(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

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.

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"

_ Section 5. " Deviation /Nonconfermance Reports"

_ Section 6, " Control of Measuring and Test Equipment"

_ Section 8, " Receipt, Storage and Issuance of Safety Related

Materials

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Section 11-1, " Weld Repair"

_ Section 14, " Installation and Inspection of Conduit Junction Boxes,

Pull Boxes, Wireway, Terminal Boxes and Their Supports"

_ 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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