ML20211E735
| ML20211E735 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/21/1986 |
| From: | Jeffrey Jacobson NRC |
| To: | |
| Shared Package | |
| ML20211E689 | List: |
| References | |
| OL, NUDOCS 8606160227 | |
| Download: ML20211E735 (150) | |
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 4, ~ '
)p, cIf BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 V
(Draidwood Station, Units 1 and 2)
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NRC STAFF TESTIMONY OF JOHN M. JACOBSON REGARDING BRIDCET LITTLE ROREhi, ET AL. SUBCONTENTION 10.B Q1. Please state your name, position and business address.
Al My name is John M. Jacobson.
I am employed by the Nuclear Regulatory Commission as a
Reactor Inspector (Metallurgical Engineer) in the Division of Reactor Safety.
My business address is United States Nuclear Regulatory Commission, Region
- III, 799 Recsevelt Road, Glen Ellyn, Illinois 60137.
Q2. Please describe your responsibilities as a Reactor Inspector.
A2. As a Reactor Inspector I am primarily responsible for performing inspections in the areas of plant materials and processes to ensure that such activities are conducted in accordance with regulatory requirements.
Q3. Have you prepared a statement of your professional qualifications?
A3. A copy of my professional qualifications is attached hereto as Exhibit 1.
8606160227 860421 PDR ADOCK 05000456 T
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Q4. What is de purpose of your testimony?
A4. The purpose of my testimony is to address Subcontention 10.B which states:
10.
Contrary to Criterion X, "Inspectio'n," of 10 C.F.R.
Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a progran for inspection of activities affecting quality was established and executed by or for the organization perfgrming the activity to -verify
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conformance with ' the documented instructions; procedures, and drawings for accomplishing 'the activity.
B.
A special NRC QA l'nspection reported May 7, 1984 that deficiencies concerning piping 3
material contrci resulted in the quality of some installed piping being indeterminate and resulted in some material being installed that did not meet decign requirements.
A docume'nte'd inspection progran had not been implemented to assure correct material installation for 2"-an d-un d er safety-related pipi,ng prior to July 1983, therefore, inspection records verifying correct material installation prior to that date do not exist.
A documented inspection program had not been imple=
mented to assure correct material installation for safety-related piping over 2"
prior to November 1982; therefore in spection records verifying correct material installation prior to that date do' not exist.
During the March 7, 1984, enforcement conference Edison described a verification program which will include a 100% inspection of all installed piping and associated records.
The results of that program and the completion of any necessary corrective actions that might risult are required to
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ensure that all installed piping material meets design requirements.
Since the NRC will need to evaluate the results of this ' verification effort in order to fully assess the 1 significance of the programmatic deficiencies, enforcement action was not being taken on this violation at that time.
Following the NRC's review of Edison's efforts, it -
will determine the appropriate enforcement action.
Until. that time, this matter is being classified as Unresolved Items.
This violation is extremely serious and has been classified as a potential severity level II depending upon the extent of deficient hardware identified in the on-going corrective action program.
(Exh. 6. )
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s Q5. Plen describe how the problem described in Subcontention 10.B was identified?
A5. During a s,pecial QA inspection conducted at the Braidwood site, the installation of piping by Phillips Getschow (PGCo), th e piping installation contractor, was reviewed to assess the effectiveness of the Quality Assurance Progam.
This inspection focused on the verification of correct heat number traceability for piping components.
The results of this inspection are documented in Inspection Report Nos. 50-456/83-09; 50-457/83-09.
The inspector determined that PGCo had not been performing documented inspec-tions for correct material usage of piping and piping components at the time of the installation.
At the time the NRC Inspection Report Nos. 50-456/83-09; 50-45"/83-09 was issued, the exact extent and the significance of the programmatic deficiencies were unknown, therefore this issue was made an unresolved item.
As detailed in the Commonwealth Edison Company (CECO) response to the inspection report, the Material Tracechility Verification (MTV) program was initiated.
Q6. What was Applicant's response to this identified problem?
A6. Applicant contended that neither the ASME Code nor 10 C.F.R.
Part 50, Appendix B required inspections identified as necessary during the NRC inspection and documented in Inspection Report Nos. 50-456/83-09; 50-457/83-09 for purposes of verifying material control and traceability.
Applicant contended that the PGCo Stores Request System met the necessary piping material control and
. traceability requirements of the Code and Criterion VIII of 10 C.F.R. Part 50, Appendix B.
Since some instances of incorrectly installed material were identified, the Applicant directed PGCo to modify its procedures to require a documented QC verification of material traceability at the point of material installation.
In ad dition, Applicant instituted the MTV program to reinspect all safety-related installed piping components to demonstrate the reliability of the Stores Request System as a means to satisfy ASME Code and regulatory requirements.
The MTV program was also structured to identify specific examples of failure to follow the applicable procedures in this area.
In February 1985, a National Board of Boiler and Pressure Vessel Inspectors audit team was requested by Applicant to review the implementation of the MTV Program.
Out of a total of 28,815 installed items, 145 were removed because Code traceability could not be conclusively established.
The Appli-cant conducted chemical and physical tests on the 145 items to deter-mine if they were the correct material.
Q7. What actions has the Staff taken to determine whether these y
corrective actions were adequate?
A7. Inspections were conducted by the Staff during the time period from July 1985 through January 1986 to review and evaluate the results of the MTV program and Applicant's corrective action.
In spection
, Report Nos. 50-456/84-09; 50-457/84-09, Inspection Report Nos.
50-4 % /84-21; 50-45"/84-20, Inspection Report Nos. 50-456/84-31; 50-457/84-29, Inspection Report Nos. 50-456/84-34; 50-457/84-32, Inspection Report Nos. 50-456/84-42; 50-457/84-38, Inspection Report Nos. 50-456/85-07; 50-457/85-07, In spection Report Nos. 50-456/
85-15; 50-457/85-16, and Inspection Report Nos.
50-456/85-43; 50-45"/85-42 described inspections that monitored the performance of the MTV program and related activities.
The Staff's review of the final CECO report O!aterial Traceability Verification at Braidwood ),
November 1985, is documented in Inspection Report Nos. 50-456/
85061; 50-457/85057.
The Staff reviewed th e' requirements of the ASME Code and 10 C.F.R.
Appendix B regarding material control and verification.
The ASME BPV Code gives no detailed information either on the specific nature of material control systems or on the type of Duality Control inspections required.
The portion of the ASME BPV Code Section III which directly addresses this issue states:
NA-4441 Establishment and Maintenance of Identifi-cation and Control Measures.
Measures shall be established for identification and control of material and items, including partially fabricated assemblies.
These measures shall assure that identification is maintained either on the item or records traceable to the item throughout manufacture or installation.
These measures shall be designed to prevent the use of incorrect or defective items, and items which have not received the required examinations, tests, or inspections.
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,. This paragraph allows a control system such as the one used by the Applicant which utilizes records traceable to the item.
The intent of the material control system is to prevent the installa-tion of incorrect or defective items.
The language of NA-4441 closely parallels Criterion VIII of Appendix B, 10 C.F.R.
Part 50 which says in part:
These measures shall assure that identification of th e item is maintained by heat number, part number, serial number or other appropriate means, either on the item or on records traceable to the item.
The PGCo material control system in existence at the time the NRC identified the traceability item addressed by Subcontention 10.B complies with both the ASME BPV Code,Section III, and Cri-terion III of Appendix B.
The Code does not require QC inspection verification at the point of installation.
1" hen implemented correctly, the material control system provided the required traceability record.
The discrepancies in the traceability of actual piping and piping components were the result of failure to implement the material control system properly.
The Staff reviewed the elements and methodology of - the MTV progran to determine its effectiveness in determining material trace-ability.
The activities performed under the MTV program were controlled by two documents.
These procedures were PGCo Procedure QCP-B-31, Revision 4, " Material Traceability Verification,"
and PGCo Work Instruction PGWI-17, Revision 3, "QCT Review of
. ?!TV Progran."
The procedures contain five major requirements as follows:
(1) 100% field walkdown for subject piping.
(2) All material identification marking recorded.
(3) Field gathered data compared to stores request for item.
(4) Field gathered data compared to certified material test reports (CMTR's for correct material specification, type, grade, class, size and schedule.
(5) Itens not found traceable per stores request or discrepant were identified as noncon-forming and nonconformance report generated for each item.
The Staff determined that the Procedure Q CP-B31 and PGWI-17 contain an acceptable method for determining the traceability of the installed piping and piping ecmponents.
In addition, the Staff reviewed PGCo Procedure QCP-B31.1, Revi-sion 1,
" Untraceable Material Sampling Program."
The purpose of this procedure is to control untraceable items and to control and store items removed from the plan t.
This procedure contains an acceptable method for controlling these activities.
In an effort to better understand the nature of those items found to be in noncompliance and their disposition, the Staff reviewed Appli-cant's efforts on nonconformance reports generated by the MTV pnogram.
The MTV program found 145 items to be in nonconform-ance with applicable requirements for Code traceability.
Another 562 items were found to be in nonconformance with procedural
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requirements;
- however, Phillips Getschow Compcny's precedural requirements exceeded those of the ASME Code. 85 others for which Code traceability was required were found to be in procedural nonconformance,
- however, other supplemental quality records established traceability.
The disposition of these NCR's was provided by consensus of a group including representatives of Commonwealth Edison, Sargent & Lundy, Phillips Getschow Company, the Authorized Inspection Agency (AIA), and generally a member of the National Board Audit Team.
The NRC Staff attended the disposition of a number of nonconforming items.
The disposition of the NCR's was acceptable.
In addition to attendance at the NCR disposition meeting, the t
inspcetor reviewed a number of the NCR packages.
The information contained in the NCR packages complied with the requirements of the procedures and the disposition of the individual items was acceptable.
Braidwood procedural traceability requirements exceed those of the ASME Code.
Of the 792 nonconforming items identified, it was determined that 647 items did not comply with Phillips Getschow Company and CFCo procedural requirements but did comply with the traceability requirements of the ASME Code.
The remaining 145 items were removed from the piping systems and replaced with trace-i able material. As a result of these reviews, the Staff has confidence in the handling of those items identified as nonconforming.
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The Staff conducted a review of the PGCo stores request system as a method of maintaining material traceability.
One of the original concerns r. elative to pipinE material control was the viability of the Phillips Getschow Company stores request system as an effective material control system.
To further develop assurance concerning this system, a detailed review was performed on the documentation associated with 30 items whose traceability was established per the original procedure by the stores request document.
The details of this inspection are contained in Inspection Report Nos. 50-456/85043; 50-457/85042.
In summary, "none of the documents reviewed contradicted [ Applicant's] conclusione and in a majority of cases, independent information, other than the stores request was on file in the documentation packages which supported Applicant's conclusion."
Inspection Report Nos. 50-456/85043; 50-457/85040 at p. 5.
In addition, the members of the National Board Audit Team reviewed documentation associated with 50 installed items whose traceability was established based on a stores request document only.
The results of their review is contained in the National Board letter of September 26, 1985 to Cordell Reed.
The National Board Audit Team agreed that the audit confirmed the integrity of the stores request system.
The Staff review of the stores request documentation demonstrated the effectiveness of this method of material traceability control.
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l To verify the effectiveness of Applicant's effort with respect to pipe wall thickness measurement, the Staff performed a sampling of measurements.
As discussed in Inspection Report Nos. 50-456/85050; 50-457/85048 independent thickness measurements were taken on six piping systems, which contained MTV items.
These measurements were taken using an ultrasonic digital thickness measuring device.
These measurements were taken to confirm that the schedule of the installed piping (wall thickness) complied with the design specification and agreed with the information used in the MTV program.
All of the measurements taken confirmed the schedule of the installed piping cnd also confirmed the acceptability of the information that was developed by Applicant.
Tu nitl iti evaluating the significance of those items cut out or removed from the plant, the Staff reviewed Applicant's selection of those items to be tested and the results of those tests.
Near the completion of the MTV program, Applicant decided to perform tests on the piping removed from the plant due to lack of traceability.
The purpose of these tests was to demonstrate whether the untraceable material was in fact, the correct material and therefore, the lack of traceability did not decrease the ability of the affected systems to function properly.
All of the removed items (except for 3 items mistakenly lost or scrapped) were analysed to determine the chemical composition of the material.
A selected sample of the removed items was subjected to physical tests which demonstrated that they met the strength requirements of the applicable
,. speciffention.
Two considerations determined which items were appropriate for physical tests.
The first consideration was size; approximately 90 of the removed items were too small for physical testing.
The second consideration was the presence of manu-facturer's markin g.
Approximately 30 items with clear manufac-turer's marks as to material type did not have the same degree of uncertainty associated with their physical properties and therefore, were not appropriate for physical testing.
Of the items appropriate for physical testing, sixteen were chosen.
The group of items tested included both carbon steel and stainless steel and both large bore and small bore items.
In addition, the only untraceable section of piping in an ASME Class I system was tosted O'CR 4756 Item 68).
A portien of the testing was witnessed by the Staff.
All of the items subjected to the chemical testing conformed to the applicable ASME/ ASTM specifications.
All of the items subjected to the physical testing for strength also conformed to the applicable ASME/ ASTM specifications.
The final report produced by Taussig Associates, Report No. 64188-1
" Chemical and Tension Testing of Samples Associated with the MTV Program," was reviewed.
O b A number of the chemical composition and physical (stre:yth) results were revicued for compliance with the ASME Code requirements. All results demonstrated compliance with applicable Code requirements.
Based on its evaluation,
the Staff concludes that those items originally deemed untraceable, had they not been removed, would have performed satisfactorily.
The Staff reviewed the Applicant's report " Material Traceability Verification at Braidwood", the National Board's letter of Septem-ber 26, 1985, and the Office of the Illinois State rire Marshall, Division of Boiler and Pressure Vessel Safety letter of June 21, 1985.
Based on the NRC inspections of the MTV program and the review of Applicant's final report, the Staff finds that the final report is an accurate representation of the activities conducted and their results.
In addition, our review of the National Board acti-vities and our review of its letter at page 5 supports the National Board's general conclusions:
The Phillips Getschow quality assurance program as written did provide the necessary controls to assure that the work performed by PGCo at the CECO Braidwood Nuclear Power Station met the requirements of the ASME Code and the certified design specification.
As noted previously in the report, there were implementation deviations for the PGCo quality assurance program's requirements.
These deviations led to the generation of the MTV program and the resulting revisions to the PGCo quality assurance program and material control i
procedures, e
t
. Also, Duane R. Gallup, Superintendent of Boiler and Pressure Vessel Safety for the State of Illinois, supported the MTV program in his June 21, 1985 letter.
Mr. Gallup was satisfied that the corrective action program of Commonwealth Edison Company (CECO) had undertal:en would result in assuring the piping systems at the Braidwood site would be in compliance with the requirements of the ASME Code.
As part of the overall MTV program, S&L Performed a " safety significance" evaluation for all the items which were nonconforming due to insufficient tracechflity.
These evaluations calculated the strength of the items to demonstrate compliance with ASME Code strength requirements.
The Staff reviewed a random sample of these evaluations in detail and found them to be acceptable.
In addition, the Sargent & Lundy Report BRF-PMD-01 (November 13, 1985),
" Design Significance Evaluation of Braidwood Material Traceability Verification (MTV)
Program Cut Out Items" was reviewed.
The Staff found the report and the disposition of these NCR's acceptable.
In Inspection Report Nos. 50-456/83-09; 50-457/83-09, two items were identified which did not have the required schedule of piping installed.
Because these itens were replaced prior to the installation of the formal MTV program, they were not included as items in the MTV program final report.
Safety significance evaluations were
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. performed.
The evaluation found that the installed item could have performed its safety function in compliance with the ASME Code.
The evaluation was reviewed and found acceptable by the Staff.
QP. What conclusions has the Staff reached concerning the adequacy of these corrective actions?
A8. The corrective actions consisting of the MTV program and associated procedural revisions are adequate to resolve this issue.
Q9. What are the bases for the Staff's conclusion?
A9. The bases for the Staff's conclusion are as follows:
(1) The original material control systen contained in the PGCo QA manual complied with the requirements of the ASME Code.
(2) All 792 items out of a total cf 25,815 items for which the proper procedures were not followed were identified as nonconforming based on PGCo proecedural requirements and were properly dispositioned.
(3) The specific instances of failure to follow PGCo procedures did not have a negative impact on the ability of the piping systems to perform their safety function.
(4) The PITV progrem was an effective method to determine the traceability of the items in question.
(5) The MTV program was conducted in accordance with appli-cable procedures.
(6) 145 ftems of questionable traceability according to the ASME Code have been removed from the plant and replaced with items which have the required traceability.
(7) Based on the results of the MTV program, the Material Control System originally employed by PGCo was effective in that none of the installed items would have compromised i
the ability of the piping systems to function properly.
l on e.
. Q10. Is there reasonable assurance that Applicant's present program for material traceability of piping is adequate to ensure that this activity is in accordance with applicable regulatory requirements?
A10. The Staff's review, findings and conclusion concerning Applicant's Quality Assurance program for piping installation (documented in Inspection Report Nos. 50-456/85061; 50-457/85057) provides reason-able assurance that the activity conforms with applicable regulatory requirements.
Materials lacking traceability were identified by the MTV program and have been removed from the plant.
Based on the Staff's evaluation of the Applicant's QA program, the MTV program and its findings, we have a high degree of confidence that the installed piping at the Braidwood Station complies with the ASME Code requirements.
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December 31, 1984 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. R. D. Schulz and R. Gardner of this office on November 12 through December 19, 1984, of activities at Braidwood Nuclear Power Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. D. Shamblin at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix.
i With respect to item 3, the inspection showed that subsequently: the documentation had been received, the cabinet was not damaged and had been installed properly, and the corrective action included verifying that any other items lacking the required documentation had not been released for installation. Consequently, no reply to this item of noncompliance is required and we have no further questions regarding this matter at this time.
Regarding the remaining two items, a written response is required.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s),
and your response to this letter will be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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8501240668 841231 PDR ADOCK 03000456 G
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Commonwealth Edison Company 2
We will gladly discuss any questions you have concerning this inspection.
Sincerely, "CrI;!..1 ::.
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~. 7. '.is nickP R. Warnick, Chief Projects Branch 1 1.
Appendix, Notice of Violation 2.
Inspection Reports No. 50-456/84-34(DRP);
No. 50-457/84-32(DRP) cc w/encls:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent J. F. Gudec, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
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Appendix NOTICE OF VIOLATION Docket No. 50-456 Commonwealth Edison Company Docket No. 50-457 As a result of the inspection conducted on November 12 through December 19, 1984, and in accordance with the General Policy and Procedures for NRC j
. Enforcement Acticas, (10 CFR Part 2, Appendix C), the following violations were identified:
10 CFR 50, Appendix B, Criterion IX, states in part that measures shall 1.
be established to assure that special processes, including welding, are controlled and accomplished in accordance with applicable codes and specifications.
Sargent and Lundy Specification F/L-2782, HVAC Work, June 6, 1983, commits to either AWS DI.1,1977 or AWS D1.3,1978 for the welding of stiffener angles, companion angles, or support angles to the duct.
Structural Welding Code, AWS DI.1, and Specification For Welding Sheet Steel In Structures, AWS D1.3 require that welds upon visua'l inspection l
contaiu no cracks.
Contrary to the above, the following safety-related companion angle to duct welds were completely cracked resulting in no bonding between the weld metal and companion angle:
duct 4032 -
I weld
~ duct 4024 -
5 welds duct 4684 -
4 welds duct 4686 -
3 welds This is a Severity Level V violation (Supplement II).
10 CFR 50, Appendix B, Criterion V, states in part that activities 2.
affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, c
i Sargent and Lundy Specification F/L-2739, July 5, 1977, Amendment 6, Piping System Installation, commits to AWS DI.1, Structural Welding Code,
'the ASME Boiler and Pressure Vessel Code,Section III, Subsection NF.
Co'ntrary to the above, for AISC safety-related steel welds, not under the jurisdiction of the ASME Boiler and Pressure Vessel Code,Section III, Subsection NF, the piping contractor did not have an AWS DI.1, Visual Weld Examination Procedure.
This is a Severity Level V violation (Supplement II).
8501240670 841231 1
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Appendix 2
3.
10 CFR 50, Appendix B, Criterion V, states in part that activities affecting quality shall be accomplished in accordance with instructions, procedures or drawings.
Commonwealth Edison Company Quality Assurance Manual, Section Q. P. No.
-l 7-1, Control of Procured Material And Equipment - Receiving and Inspection, June 6, 1984, requires in Section 5 that items lacking' 1
required documentation be placed on hold.
L. K. Comstock Procedure, 4.10.3, Requisitioning For Installation CECO Stored Equipment / Material, November 11, 1980, requires that a CECO furnished material requisition form be used for issuance of material and the authorized signatures of personnel approving the material requisitions be on file with the CECO Site Lead Electrical Engineer.
Contrary to the above, Hydrogen Recombiner Power and Control Cabinet, 00G04J, was received on July 7, 1981 without the documentation required by Purchase Order Number 216484, was not placed on hold, and was subse-quently released from the warehouse for installation.
In addition, no material requisition could be found authorizing the release of the cabinet.
This is a Severity Level V violation (Supplement II).
pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration ony be given to extending your response time for good cause shown. No response to Item 3 is required.
DEC 31 GS4 ReW0 A
Dated R. F. Warnick, Chief Projects Branch 1 e
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U. S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-45'6/84-34(DRP); 50-457/84-32(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Ediso1 Company Post Office Box 767 Chicago, IL 60690 Facility Name:
Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: November 12 through December 19, 1984 Inspector:
R. D. Schulz R. Gardner
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[
Approved By:
e Projects Section IA Date /
Inspection Summary Inspection on Nosember 12 through December 19, 1984 (Report No.
50-456/84-34(DRP); 50-457/84-32(DRP)
Areas Inspected: Routine, unannounced safety inspection of allegations, licensee action on previously identified items, work activities observed during plant tours, piping material traceability verification program, pipe supports, hydrogen recombiner power and control cabinet, licensee nonconformance reports, electrical cables, and reactor coolant piping. The inspection consisted of 139 inspe c to r-hou rt. onsite by two NRC inspectors including 12 inspector-hours onsite during off-shifts.
Results: Of the nine areas inspected, no items of noncompliance were identified in six areas, one item of noncompliance was identified in each of the remaining areas.
(Deficient HVAC welds Daragraph 4; lack of appropriate pipe support, welding inspection procedure - Paragraph 6; and failure to follow material control procedures - Paragraph 7).
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DETAILS 1.
Persons Contacted Commonwealth' Edison Company (CECO)
- M. Wallace, Project Manager
- G. Fitzpatrick, Assistant Manager Quality Assurance Corporate
- C.
Schroeder, Licensing and Compliance Superintendent
- D.
Shamblin, Construction Superintendent T. Quaka, Quality Control Supervisor G. Groth, Assistant Construction Superintendent S. Hunsader, Quality Assurance Supervisor R. Wrucke, Licensing Engineer E. Netzel, Quality Assurance Supervisor M. Gorski, Engineer R. Tate, Quality Assurance Engineer
- W. Vahle, Field Engineering Manager
- L.
Kline, Project Licensing Compliance Phillips Getschow Company (PGCo)
- T.
G. O'Connor, Site Manager
- J.
Carlson, Quality Control Supervisor L. J. Butler, Assistant Quality Control Supervisor W. Berg, General Foreman G. Galloway, Assistant Project Engineer R. Hamilton, Welding Supervisor M. Knaff, Engineering Group Instrument Supervisor G. K. Newberg Company C. Zavada, Level II Inspector L. K. Comstock and Company, Inc. (LKC)
- I. Dewald, Quality Control Manager L. Seese, Assistant Quality Control Site Manager M. Lechner, Lead Inspector J. Malmquist, Area Manager i
T. Simile, Welding Engineer Pullman Sheet Metal
- D.
Grant, Site Quality Assurance Manager
- G. Minor, Quality Control Supervisor Sa ssent and Lundy D. A. Gallagher, Field Project Manager K. Fus, Field Coordinator
- Denotes those personnel contacted concerning inspection findings.
2
a 2.
Allegations i
a.
(Closed) Allegation (RIII-84-A-0096). Part I > Phillips-Getschow rusted pipe was described on August 9, 1984, as having less than minimum wall thickness.
Commonwealth Edison identified a 10 CFR 50.55(e) reportable ites on June 21, 1984, regarding wall thickness inadequacies for one heat of 2" S/80 pipe. The inspector investigated the minimum wall issue and identified numerous heats of pipe with potential minimum wall'defi-ciencies in Inspection Report 84-17.
The investigation resulted in two violations designated by control numbers (456/84-17-01; 457/84-17-01) and (456/84-17-02; 457/84-17-02). The violations concerned failure to adequately control pipe in a rusted condition.
In addition, an open item designated by control number (456/84-17-03; 457/84-17-03) is docu-mented in Inspection Report 84-17 for 337,350 feet of pipe which requires analysis for wall thickness degradation. This allegation is considered to be closed.
Part II - Holes burned in steel above the reactor which were thoeght to be identified.
Flame out holes in steel have been identified in the containments i
and documented in nonconformance reports, with the corrective action approved by Sargent and Lundy. The Gust K. Newberg Construction Company identified the holes in the following nonconformance reports:
f Nonconformance No.
Description 213-557 Structural Steel, Containment II 213-558 Structural Steel, Containment I 213-577 Structural Steel, Containment I 213-599 Structural Steel, Containment II 213-602 Structural Steel, Containment II 213-609 Structural Steel, Containment II 213-619 Structural Steel, Containment II 213-620 Structural Steel, Containment II i
213-623 Structural Steel, Containment II 213-630 Structural Steel, Containment II l
213-637 Structural Steel, Containment II 213-656 Structural Steel, Containment II 213-658 Structural Steel, Containment II l
213-660 Structural Steel, Containment II 213-676 Structural Steel, Containment II 213-835 Structural Steel, Containment I This allegation is considered to be closed.
s i
i 3
i a
a b.
(Closed) Allegation (RIII-84-A-0119). On August 17, 1984, the alleger, an employee of the L. K. Comstock quality control department, stated that he was intimidated and harassed by L. K.
Comstock quality control supervisory personnel. On September 21, 1984, the inspector met with the alleger and four,other quality control inspectors. The five individuals did not provide any specific examples or records substantiating intimidation or harassment. During the course of the interview, it was revealed that the main issue is a morale problem which appears to be related to monetary matters and subjective opinions of poor management. The inspector met with Commonwealth Edison Project management and Construction Superintendent to discuss the issue of intimidation and harassment. Subsequently, Commonwealth Edison management met with the L. K. Comstock Site Quality Control management to ensure that all parties understood that any form of intimidation or harassment would not be tolerated by Commonwealth Edison or the NRC. This allegation is con-sidered closed.
3.
Licensee Action on Previously Identified Items a.
Bulletins The following Bulletins are considered closed because they concern boiling water reactors which are not used at Braidwood:
I. E. Bulletin 80 Core Spray Spargers I. E. Bulletin 80 Scram Discharge Volume I. E. Balletin 80 25 - Target Rcch SRV's I. E. Bulletin 80 Air Operated ADS Valves I. E. Bulletin 80 Jet Pumps I. E. Bulletin 80 BWR Control Rods b.
Unresolved Items (Closed) (456/83-10-05; 457/83-10-05): Calibrated instruments utilized to verify acceptable pipe bends, in numerous cases, are not traceable to inspection records. This item was additionally identified in inspection report number 83-09 and will be tracked by control number 83-09-02(c). The item is closed due to duplicate findings, however, 83-09-02(c) will remain open and be reviewed at a later date for adequate corrective action.
(Closed) (456/84-08-05; 457/84-08-05): Six high strength bolts were below the required structural steel torque values. The six bolts were re-tightened by the turn of the nut method and this problem was determined to be an isolated case, as these bolts had been removed and replaced without proper authorization. Training was conducted with regard to the proper procedures to follow in the removing and replacing of items. The six bolts were documented on nonconformance report number 213-795 on June 5, 1984.
4
o o
c.
Open Items (Closed) (456/84-17-05; 457/84-17-05): Blockwall columns with structural steel bolted and welded connections missing inspection reports. A sampling inspection plan was originally proposed by the licensee to assure quality work; however, the licensee has decided to inspect all connections or provide additional support to those not inspected. This action was based upon the numerous weld deficiencies identified. All connections are to be repaired or additionally supported as required. This corrective action was documented on November 2, 1984, in a 10 CFR 50.55(e) transmittal by the licensee to the NRC. The 50.55(e) is identified by designated number 82-10.
(Closed) (456/84-17-07; 457/84-17-07):
Instrument piping drawing contained a statement, " pitch pipe 1/2" per foot if possible". The note on the drawing has.been changed and now states single pipe pressure instruments are recommended to have their sensing lines installed with a continuous slope (1/2" per foot recommended),-
however, it is acceptable to have horizontal runs without slope and a high point without high point vent valves, provided no traps are fo rmed. Flow lines must have 1/2" per foot slope. No lines were identified by the NRC inspector with unacceptable pitch and an instrument line retro-fit program, per quality control procedure, has been instituted by the piping contractor to verify acceptable pitch.
4.
Plant Tours Tine inapectos observed work activitic: in progre::, completed work, and plant status during general inspections of the plant. Observation of work included high strength bolting, safety-related pipe welding, anchor bolts, structural welds, and cable trays in the containments and auxiliary building. Particular note was taken of material identification, nonconforming material identification, housekeeping, and equipment preservation. Craft personnel were interviewed in the work areas.
While touring the containment and fuel handling building, the inspector noticed numerous pieces of small bore piping laying on the floor with a hold tag attached to each bundle of pipe containing five or six pieces.
This pipe was on hold per Phillips Getschow Co. nonconformance report number 2001 as a result of potential minimum wall deficiencies. This issue was discussed with Phillips Getschow Co. quality control supervision, and since the pipe laying on the floor was not an optimum material control practice, a decision was made by quality control supervision to remove this pipe to designated hold areas. The pipe has been removed from the containments and fuel handling building and the inspector considers this issue closed.
4 The inspectors toured the plant on several occasions and identified HVAC duct welds that had cracked completely in a direction parallel to the weldment. These welds were designed to join a companion angle to the 5
duct but the cracking resulted in no bonding of the weld metal to the companion angle. The welds were made by a silicone bronze braze process.
The cracked safety-related welds and associated ducts identified by the inspector are detailed below:
Duct No. of Welds Systems 4024-Unit II 5
Aux. Bldg. Vent System 4032-Unit II 1
Aux. Bldg. Vent System 4684-Unit I 4
Aux. Bldg. Control Room Vent Sys.
4686-Unit I 3
Aux. Bldg. Control Room Vent Sys.
Sargent and Lundy Specification F/L-2782, HVAC Work, commits to either AWS D1.1, 1977 or AWS DI.3,1978 for the welding of stiffener angles, companion angles, or support angles to the duct. Engineering Change Notice 4591 was incorporated in Specification F/L-2782 on June 6, 1983 and allowed the welding of angles to duct to the criteria of either AWS D1.1 or AWS DI.3.
Neither welding codes, AWS D1.1 or AWS D1.3, allow cracks in welds. The cracked welds are in violation of 10 CFR 50, Appendix B, Criterion IX (456/84-34-01; 457/84-32-01). Additionally, the inspectors noticed other welds on ducts 4684 and 4685 that appeared to be cracked, however, these cracks were not complete cracks resulting in a lack of bonding and may only be surface cracks The welds were painted, making weld quality determination difficult. The inspectors requested Pullman Sheet Metal quality control supervision to investigate these cracks and subsequent inspections by Pullman resulted in the documentation of twenty-nine weld cracks in Correction Notices 5534 and 5535. Subsequent inspections by the licensee will determine the severity of the cracking in the HVAC duct system and Sargent and Lundy will analyze the cracking for design significance.
The inspector reviewed Pullman silicone bro'nze braze welding procedure, PSM-WP-307, which was approved by Sargent and Lundy on March 3,1981. The procedure only rejected weld cracks that were parallel to weldcent. This is not in accordance with AWS D1.1 or AWS DI.3 which do not allow cracks in any direction. Furthermore, rejection of.only parallel cracks results in difficult inspection criteria with regard to the definition of the allowable angle for parallel cracks.
Parallel cracks did not appear to be defined. The rejection of only silicone bronze cracks parallel to the weldment will remain an open item awaiting analysis and justification by the licensee (456/84-34-02; 457/84-32-02).
5.
Piping Material Traceability Verification Program The material traceability verification program was reviewed. The program was instituted as a result of an NRC finding identified in Inspection Report Number 83-09, which stated that a documented inspection program to verify correct material installation had not been implemented for 2" and under safety-related piping prior to July 1983, and for over 2" safety-related piping prior to November 1982. As a result of this finding the licensee decided to inspect all the piping installed prior to 6
the above applicable dates in order to determine the acceptability of piping material installations. Completion of the material traceability verification program is expected by February 28, 1985.
As of November 23, 1984, the following inspection results have been recorded by Phillips, Getschow Co. for large bore and small bore piping:
Large Bore Pipina(Over 2")
Total number of items inspected - 1679 Percentage of total items - 18%
Total number of probable items accepted - 1440 Total number probable rejections - 25 Total number of items requiring further analysis - 213 Small Bore Pipina (2" and under)
Total number of items inspected - 4668 Percentage of total items - 28%
Total number of probable items accepted - 3870 Total number of probable rejections - 12 Total number of items requiring further analysis - 786 The final acceptance and rejection of items will be made by the licensee.
No violations or deviations were identified.
6.
Pipe Supports The inspector reviewed Visual Examination Procedure, VE-01, Revision 2, and discovered that Phillips, Getschow Co. had a procedure for ASME Section III, Subsection NF, Welds and ANSI B31.1 Safety-Related Welds, but did not have an inspection procedure for safety-related AISC Steel Welds under the jurisdiction of AWS D1.1, Structural Welding Code, 1975.
Sargent and Lundy Specification F/L-2739, July 5, 1977, Amendment G, Piping System Installation, commits to AWS DI.1, Structural Welding Code, 1975, for AISC safety-related steel welds not under the jurisdiction of the ASME Boiler and Pressure Vessel Code,Section III, Subsection NF.
However, the architect engineer, Sargent and Lundy, did not specify on the drawings that the weld inspection was under the jurisdiction of AWS D1.1.
In addition, the final pipe support documentation did not indicate the Code acceptance criteria that the non-NF safety-related welds were inspected to for compliance; although the NF welds were documented as being in compliance with ASME Section III, Subsection NF acceptance criteria. Numerous safety-related pipe support welds fall under the jurisdiction of the AWS DI.1, Structural Welding Code. The acceptance criteria for both ASME and AWS D1.1 welds contain the attributes of porosity and crater pits, however, crater pits and porosity are not inspection criteria for ANSI B31.1 safety-related welds. Therefore, the acceptance criteria' for ASME and AWS DI.1 welds are more restrictive and evidence should be provided by the licensee to assure that the non-NF 7
safety-related welds were inspected to the applicable AWS D1.1 or ASME criteria and not to the ANSI B31.1 acceptance criteria. The inspector interviewed six quality control welding inspectors and all stated that they rejected welds for porosity and crater pits and they were inspecting all safety-related welds to the ASME procedure. The inspector also has examined numerous AWS D1.1 pipe support welds and these welds met the acceptance criteria of AWS DI.1, 1975. The six welding inspectors and NRC examined pipe support welds are only a sample of their respective total populations, and th'is sample does not provide statistical assurances that all non-NF safety related weld inspections were performed to the AWS D1.1 Code or ASME Code. Failure to have an AWS DI.1, Structural Welding Code, visual inspection procedure is in violation of 10 CFR 50, Appendix B, Criterion V (456/84-34-03; 457/84-32-03).
Constant and variable supports were examined for proper markings and the supports were identified in accordance with Specification F/L-2739 and Engineering Change Notice No. 7595. The markings included manufacturer's catalog number, serial number, size, load, and travel.
The inspector randomly selected eight pipe supports and examined the tube steel, wide flanges, and plate used in the supports for material traceability.
The supports are detailed below:
Support No.
System 1RH020815 Residual Heat Removal IRC12101S Reactor Coolant 1RYO9100S Reactor Coolant Pressurizer IRC04004V Reactor Coolant IRC13091S Reactor Csolant IRC13053S Reactor Coolant IRC13090S Reactor Coolant IRC13044S Reactor Coolant All material inspected was the correct type. The plate'and wide flanges met the requirements of ASTM A-36 and the tube steel met the requirements of ASTM A500 Grade B. Material receipt inspection reports and material test reports were reviewed and found to be satisfactory.
Additionally, eight pipe supports were randomly selected and examined for compliance to Sargent and Lundy Specification F/L-2739, drawings, and Phillips Getschow Co. Procedure, QCP-B23, Revision 8, Installation and Inspection Of Component Supports. The supports inspected and their system identification are as follows:
Pipe Support System ICV 06001V Chemical and Volume Control ISI20020X Safety Injection 1SIO9036X Safety Injection ICV 06009C Chemical and Volume Control 1RH02006R Residual Heat Removal 8
y
...,m-
,~
o Pipe Support System ICV 06015R Chemical and Volume Control IRYF47A036T Reactor Coolant Pressurizer ISIO9034V Safety Injection The supports were installed in compliance with the specification, drawings, and procedure.. Attributes examined included welding, location, dimensional tolerances including pin to pin distance, material identifica-tion, welder identification, weld rod traceability, clasp and U-bolt condition, locking devices, and configuration.
7.
Hydrogen Recombiner Power and Control Cabinet The inspectors examined the installation of the Unit 1, Hydrogen Recombiner Power and Control Cabinet 00G04J. The installation was in accordance with drawing 0-3391Y Revision G and Specification L-2790, Amendment 40, Electrical Installation Work, July 18, 1984. The inspection included verification of concrete expansion anchors,.
dimensional tolerances, and weld conformance with regard to quality, location, and length. The cabinet was properly marked with Serial No.
113C and Part No. N139000234-01. The Material Receiving Report, No.
7337, was reviewed and the inspector discovered that the cabinet was received on July 7, 1981, without the documentation required by Purchase Order Number 215484. However, the cabinet was not placed on hold as required by the Commonwealth Edison Company Quality Assurance Manual, Section Q.P. No. 7-1, Control of Procured Material and Equipment-Receiving and Inspection. Furthermore, the cabinet was released for installation to the electrical contractor without a material requisition as required by L. K. Comstock Procedure 4.10.3, Requisitioning for Installation Ceco Stored Equipment / Material. The date of the release is unknown without a l
material requisition. Failure to follow procedures concerning the material i
requisition and hold policy is in violation of 10 CFR 50, Appendix B, Criterion V (456/84-34-04). The documentation was subsequently received on March 22, 1983, and the inspector confirmed that the cabinet was purchased l
and supplied in accordance with Sargent and Lundy Specification F/L-2845, Amendment 5, dated June 23, 1983, Post LOCA Hydrogen Control System. Purchase i
Order Number 216484 included 10 CFR 21 reporting requirements. Since the inspector determined that the cabinet was installed correctly and was not damaged, and corrective action by the licensee (documented on nonconformance report number 699) included verifying that no other equipment had been released for installation without the required documentation, no reply to this item of noncompliance is required.
8.
Nonconformance Reports (NCR's)
Fifteen Commonwealth Edison nonconformance reports were randomly selected and reviewed for identification of nonconforming conditions, corrective action, an'd design basis disposition. The nonconformances are listed below:
l 9
NCR No.
Date Subject 561 8/18/83 Weld Cracks in HVAC Ducts.
639 7/25/84 Removal of Piping ASME Nameplates.
637 7/10/84 Diesel Oil Storage Tank Machining.
626 6/14/84 Defective Electrical Penetration Support Bushings.
625 6/5/84 Improper Wire Connections - 480V Motor Control Center Compartments.
613 3/8/84 Rusted bolts - Electrical Penetrations.
609 5/16/84 Radiographs of ASME Section III Pipe Welds Violate Density Requirements.
602 4/17/84 Incorrect Structural Steel Material Specification and Lack of Traceability for Plate.
594 2/2/84 Concrete Block Certifications.
595 2/29/84 Incorrect Cable Grips.
593 1/24/84 Wiring Error, 125V D.C. Buses.
600 3/13/84 Incorrect Classification of ASME, NF Supports.
537 6/13/84 Flanges Not in Conformance With Heat Treatment Requirements.
543 7/12/84 Use of Incorrect Filler Metal.
631 6/18/84 Bent Flare End Plates on Spent Fuel Storage Racks.
No violations or deviations were identified.
9.
Electrical Cables Five Unit 1 installed cables were inspected in the upper cable spreading room for compliance to IEEE-384, the cable pull cards, and L.K. Comstock procedure 4.3.8, Cable Installation Inspection. Detailed below are the cables which were inspected:
Cable No.
From To Type IMS659 Main Steam Junction Annunciator Input 7/C-14 Box V1JB2212A Cabinet IPA 31J ILV051 Auxiliary Power Con-Annunciator Input 12/C-14 trol System Cabinet Cabinet IPA 31J IPA 33J IDG204 Diesel Generator Annunciator Input 12/C-14 Control Panel Cabinet IPA 31J 12/C-14 IPLO7J 4
1CCO26 Main Control Board -
Annunciator Input 7/C-14 Engr. Safety Features Cabinet IPA 31J IPM06J 10 e
4 t
Cabic No.
From To TZE8 1CS010 Main Control Board -
Annunciator Input 7/C-14 Engr. Safety Features Cabinet IPA 31J IPM06J Cable number IMS659 in riser 1R255 did not have the support cable grips attached as a result of rework request No. 936. The inspector, notified the L. K. Comstock qualit'y control manager and the cable grips were immediately reattached. The inspector considers this ites closed.
NRC inspections of the cables included the following attributes:
. racewa'y free of debris raceway f ree of sharp edges
. raceway free of damage
. segregation codes correspond raceway corresponds to routing shown on pull card-cable routed per pull card cable correct size and type cable free of damage cable correctly identified
~
cables are properly supported No violations or deviations were identified.
J 10.
Reactor Coolant Piping l
Three reactor coolant piping spools were examined in the Unit I containment. The spools were classified as ASME Boiler and Pressure Vessel Code,Section III, Subsection NB, Class 1 and consisted of 8" S/160 SA-376 TP304 piping material installed in accordance with design specification 1540BB. The spools were identified on drawings IC-RC-1-4, IC-RC-1-4P, and IC-RC-1-5.
Field examinations included the identification of welder symbols and welci numbers, weld quality, material identification markings, configuration, clearances, and line location in accordance with the as-built drawing.
After the line was walked down the NRC inspector reviewed the.following associated documentation to determine, compliance with regulat,ory requirements and agreement with the actual hardware installations.
Piping, NPP-1 Code Data Reports
. Valve, NPV-1 Code Data Repprts
. Welding Filler Meta 1 Material Certifications including Ferrite
~
Testing Piping Material Certifications
. Weld Numbers and Welder Qualification Records
. Welding Procedure Qualification Records
,, Nondestructive Examintcion Reports, Penetrant and Radiograph
. Nondestructive Inspector Qualifications, SNT-TC-1A
. Quality Control Inspection Recordr. including End preps, Fit-up, Root Weld, Pre-Heat, Interpass Temperature, and Final Visual Weld Examinations 11
~
Material Requisitions Field Change Orders Penetrant Material Test Reports, ASME Section V Three procedures were reviewed:
VE-01, Revision 2. Section 8, Visual Examination Procedure For Butt Welded Pipe - ASME,Section III, Class 1, 2, and 3 QAP-1, Revision 5, Liquid Penetrant Examination QC-RT-1, Revision 16, Radiographic Examination Procedure VE-01 was in conformance with the ASME Boiler and Pressure Vessel Code,Section III,1974, including acceptance criteria for welds, maximum of fset of aligned sections, thickness of weld reinforcement for vessels - pumps - valves, thickness of weld reinforcement for piping.
Procedure QAP-1 was in conformance with the ASME Boiler and Pressure Vessel Code, Section 5, Article 6, 1974, including: penetrant materials qualification, temperature range, surface preparation, examination method, and acceptance standards, 1
Procedure QC-RT-1 was in conformance with the ASME Boiler and Pressure Vessel Code, Section 5, Article 2, 1974, including:
radiographic procedure qualification, location markers, and interpretation of radiographs.
No violations or deviations were identified.
11.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
An open item disclosed during the inspection is discussed in Paragraph 4.
12.
Exit Interview The inspector met with licensee and contractor representatives (denoted under Persons Contacted) during and at the conclusion of the inspection on December 18, 1984. The licensee acknowledged the information.
4 e
12
APR 181985 Docket No. 50-456 Docket No. 50-457
~
Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs.
D. L. Williams, A. Dunlop Jr., M. J. Farber and M. A. Ring of this office on February 14 through March 27, 1985, of activities at Braidwood Nuclear Power Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. H. A. Zimmerman at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative rscords, observations, and I
interviews with personnel.
During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC's Public Document Room.
The responses directed by this letter and the accompanying Notice (Order) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
g I
8505020110 850418 PDR ADOCK 05000456 G
PDR l
l'
1 Commonwealth Edison Company 2
We will gladly, discuss any questions you have concerning this inspection.
Sincerely, mMy@t-yr J. J. Harrison, Chief Engineering Branch
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Report No. 50-456/85008(DRS);
No. 50-457/85008(DRS) cc w/encls:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent i
J. F. Gudac, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division s
Appendix NOTICE OF VIOLATION Comonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on February 14 through March 27, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violation was identified:
10 CFR 50, Appendix B, Criterion XIII states, in part, that " Measures shall be established to control the handling, storage, shipping, cleaning and pre-servation of material and equipment...to prevent damage or deterioration."
The Comonwealth Edison Company Quality Assurance Program contains in Quality Requirement Q.R. 2.0 6 commitment to the regulatory positions of Regulatory Guide 1.37, Revision 0, Regulatory Guide 1.38, Revision 2, and Regulatory Guide 1.39, Revision 2.
Regulatory Guide 1.37, Revision 0 endorses the requirements of ANSI N45.2.1 1973, " Cleaning of Fluid Systems and Associated Components During Construction Phase of a Nuclear Fower Plant." Section 6, " Maintenance of Installation C1f.onliness", states, in part, "If access to a sealed system is required, precautions shall be taken to prevent introduction of contamin-ants. Prior to opening the seals, the innediate surroundings should be cleaned to remove solid contaminants which might be introduced in the system.
Personnel entering the system should wear clean outer clothing and shoe covers. When the necessary work is completed, the interior surface shall be locally cleaned to its original condition and the system should be re-sealed".
Regulatory Guide 1.38, Revision 2 endorses the requirements of ANSI N45.2.2-1972.
" Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants During the Construction Phase." Section 6.5 of ANSI N45.2.2 states, in part, that, " Items released from storage and placed in their final locations within the power plant, shall be... cared for in accordance with the require-ments of Section 6 of this Standard." Section 6 of ANSI N45.2.2 states in part that, "(6.1.1) Levels and methods of storage necessary are defined to minimize the possibility of damage or lowering quality due to corrosion, contamination, deterioration, or physical damage.
(6.2.2) Cleanliness and good housekeeping practices shall be enforced at all times in the storage a rea s.
(6.4.2) Items...shall have all covers, caps, plugs or other closures intact... covers removed for internal access at any time for any reason shall be imediately replaced and resealed after completion of the purpose for removal."
s 8505020121 850418 PDR ADOCK 05000456 G
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Appendix 2
Regulatory Guide 1.39, Revision 2 endorses the requirements of ANSI N45.2-3-1973," Housekeeping During the Construction Phase of Nuclear Power Plants". Section 3.2.1 states, in part, " Garbage, trash, scrap, litter and other excess material shall be collected, removed from the job site, or disposed of in accordance with s'pecified requirements or planned practices. Such excess material shall not be allowed to accumulate and create conditions that will adversely affect quality."
Contrary to the above:
a.
Shoe covers were not provided or worn by personnel entering the recircula-ion sump area during BWPT EF-11 and some debris was noted in the sump water during the preoper6tional test. (456/85008-10c) b.
On March 15 and 21, 1985, the pennanent spool pieces for Residual Heat Removal Suction lines and Containment Spray Pump Suction lines were found with inadequate or non-existent coverings for protection from damage or deterioration of these components. (456/85008-10b) c.
On March 15 and 21, 1985, during tours of the 1A positive displacement charging pump room the following was observed; empty cans in the room cooler, plastic sheeting strewn about the area, partially eaten food items, accumulation of flamable material and a layer of dust on all equipment in the room. (456/85008-10a)
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) correc-tive action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
APR 181985 Dhiss-g-
Dated J.
J. Harrison, Chief Engineering Branch I
l w
y-
U.S hUCLEAR REGULATORY COMMISSION REGION III Report No. 50-456/85008(DRS);50-457/85008(DRS)
Docket Nos. 50-456; 50-457 '
Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicaga, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: February 14 through March 27, 1985 M.b h
t Inspectors:
D. L
_ 4 =e 44 /is /sq Date h.
h A.
p 4 /lg /e(
Date M/fk M. A ng Date' M. J. Farber
- sdslW Date e Approved By-
.A
- eyes, 4 /f t/tf Test Programs Section Datt Inspection Summary Inspection on February 14 throuch March 27, 1985 (Report No. 50-456/85008(DRS);
50-457/85008(DRS))
Areas Inspected: Routine, announced inspection to review actions on previous inspection items, preoperational test program implementation, preoperational test procedure review, test performance witnessing, preoperational test results evaluation. This inspection involved 254 inspector-hours onsite and 56 inspector-hours in office by 4 NRC inspectors including 90 inspector-hours onsite during off-shifts.
Results: Of the five areas inspected, three had no items of deviation or noncompliance. Two areas, preoperational test program implementation and preopeyational test perfomance witnessing, had examples of one item of noncom-pliance (failure to maintain housekeeping - Paragraphs 3.b(1), 3.b(2), and 5.c(3)).
8505020158 850418 PDR ADOCK 05000456 G
DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
C. J. Tomashek, Proje'ct Startup Superintendent
+*H. A. Zimmerman, Project Startup Testing Supervisor
- D. Cecchett, Licensing and Compliance Engineer
- J. Jasnosz, Licensing / Training Group Leader
- C. Schroeder, Licensing and Cnmpliance Superintendent B. Wurglitz, System Test Engineer P. Hable, Shift Foreman G. Nagy, System Test Engineer
+ D. R. Redden, System Test Engineer
+ R. T. Jenkins, System Test Engineer R. E. Letko, Group Leader B. Ronchetti, System Test Engineer J. W. Thunstedt, Turnover Coordinator P. Barnes, Licensing and Compliance Engineer Additional station technical and administrative personnel were contacted by the inspectors during the course of the inspection.
- Denotes those personnel present at the exit meeting on March 21, 1985.
+ Denotes those personnel present at the exit meeting on March 27, 1985.
2.
Actions on Previous Inspection Findings (Closed) Open Item (456/84-15-01). This concerned the startup organiza-tion meeting the Final Safety Analysis Report (FSAR) commitments. The inspector reviewed Amendment 46 to the Braidwood FSAR and considers this item closed.
3.
Preoperation Test Program Implementation This review consisted of a determination if administrative controls had been developed and implemented to support Final Safety Analysis Report (FSAR) commitments, and regulatory requirements. The inspector had the following comments:
a.
The inspector reviewed Braidwood Quality Assurance Audit (OA.A) 20-85-05 of qualifications of Test Review Board (TRB) and Group Leaders for System Test Engineers (STEs) and compared the educational and experience levels with ANSI 18.1-1971 requirements.
The qualifications appear adequate and the inspector has no further comments.
{
s i
I 2
b.
The inspector also completed several housekeeping tours of safety-related areas to evaluate the impact of construction activities on maintenance and equipment preservation. The findings of these tours are as follows:
(1) On March 15, 1985, the inspectors toured the Unit 1A positive displacement charging pump room. An accumulation of plastic sheeting, empty cans, rags and wood scaffolding was in the room. The next tour on March 21, 1985, found the room in the same condition. This lack of housekeeping is considered to be an example of a violation of 10 CFR 50, Appendix B, Criterion XIII (456/85008-10a(DRS). This item was discussed with the licensee on March 21, 1985.
(2) During a tour of the residual heat removal pump and containment spray pump rooms on March 15, 1985, it was observed that the permanent spool pieces in the pumps' suction lines had been removed and replaced with temporary spool pieces containing strainers. The permanent spool pieces are required to have covers, caps, plugs or other closures intact. Contrary to this the spool pieces were only covered by tape that was not intact.
Further, tape is not considered an adequate cover. This is considered to be an example of a violation of 10 CFR 50, Appendix B, Criterion XIII (456/85008-10b(DRS)) and is discussed further in Paragraph 5.c.(3).
4 Preoperational Test Procedure Review q
The inspectors reviewed the following preoperational test procedures against the FSAR, Safety Evaluation Report (SER), proposed Technical Specifications,and Regulatory Guides 1.68, 1.108 (DG-10), 1.79 (EF-11),
and 1.82 (EF-11).
BWPT CS-10 Rev. O
" Containment Spray System" BWPT EF-11 Rev. 1 "ECCS Full Flow Test" BSPT RY-10 Rev. 0
" Reactor Coolant Pressurizer" BWPT SI-10 Rev. O
" Safety Injection" BWPT SI-12 Rev. O
" Safety Injection (Flow Balancing)"
BWPT CC-10 Rev. 1
" Component Cooling Water System" BWPT DG-10 Rev. 0
" Diesel Generator" a.
With respect to the review of DG-10, the inspectors noted the l
following concerns:
l (1) The test procedure nerforms various starts of the diesel generators to obtain the required test results. However, the licensee does not address the initial conditions of the diesel generator (temperature, etc.) in order to detennine whether a hot or cold start is being conducted. This is considered an unresolved item (456/85008-01(DRS)) pending
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s additional information from the licensee on the starting procedure of the diesel.
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(2) The test procedure did not include several of the regulatory positions on testing the diesel generators from Regulatory Guide 1.108. Upon further investigation the inspector located a February 11, 1985, letter from T. R. Tram to H. R. Denton
'concerning replies to Office of Nuclear Reactor Regulation (NRR) questions 423.44 through 423.48 for FSAR amendment approval which discusses the above regulatory positions in question 423.45.
In the proposed amendment, the licensee did not address (in Table 14.2-25 of the Braidwood FSAR) acceptance criteria for the regulatory positions in the following paragraphs or the preoperational test in which they are demonstrated:
(a) Regulatory Guide 1.108, Section C.2.a(2) which demonstrates proper operation for design-accident-loading-sequence to design-load requirements. This will be considered an open item (456/85008-02(DRS)) pending incorporation into a preoperational test procedure.
(b) Regulatory Guide 1.108,Section C.2.a(5) which demonstrates functional capability at full-load temperature conditions by rerunning the test phase outlined in Regulatory Positions C.2.a(1) and C.2.a(2) imediately following C.2.a(3). This will be considered an open item (456/85008-03(DRS)) pending incorporation into a preopera-tional test procedure.
(c) Regulatory Guide 1.108, Section C.2.a(7) which demonstrates that the engine will perfonn properly if switching from one fuel oil supply system to another to satisfy the 7-day storage requirement. This will be considered an open item (456/85008-04(DRS)) pending incorporation into a preopera-tional test procedure.
(d) Regulatory Guide 1.108, Section C.2.a(8) which demonstrates that the capability of the diesel generator unit to supply emergency power within the required time is not impaired
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during periodic testing. This will be considered an open item (456/85008-05(DRS)) pending incorporation into a preoperational test procedure.
b.
The inspectors commenced the test procedure reviews of preoperational tests BWPT AF-10. " Auxiliary Feedwater",and BWPT RH-10, " Residual Heat Removal". However, these reviews are not yet complete and will be documented in a subsequent inspection report.
5.
Preoperational Test Performance The inspectors witnessed the performance of portions of the below listed preoperat.ional test procedures in order to verify that testing was conducted in accordance with approved procedures, independently verify the acceptability of test results, and evaluate the performance of licensee personnel conducting the tests.
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BWPT SI-12
" Safety Injection (Flow Balancing)"
.BWPT CC-10
" Component Cooling Water" BWPT EF-10
" Unit One Engineered Safety Features" BWPT DG-10
" Diesel Generator" BWPT'EF-11 "ECCS Full Flow" The inspectors had the following coments concerning the conduct of testing:
a.
BWPT EF-10, " Unit One Engineered Safety Features" During the conduct of testing the inspector observed a lack of independent verification of installation and removal of jumpers.
The technician was placing momentary jumpers to verify response of relays. The System Test Engineer (STE) was sitting in front of the panel calling out the terminals to be jumpered and the relay number to the technician. The technician would place the jumper and announce the state (energized or de-energized) to the STE. The STE would then record the infonnation in the procedure without leaving his sitting position. The inspector expressed concern for the validity of data recorded due to the lack of independent verification.
The prine reason for independent verification is verification of proper placement and removal of jumpers. The momentary placement of jumpers will cause little concern for verification of removal but proper placement is somewhat suspect. The licensee assured the inspector that subsequent testing activities will reinforce the proper operation of the components. This will be considered an open item (456/85008-06(DRS)) pending completion of supporting preopera-tional testing and no further evidence of lack of independent verification of lifted leads, jumpers and relays, b.
BWPT DG-10, " Diesel Generator" The licensee was experiencing problems with the diesel generator being up to proper speed, voltage and frequency in the required 10 second time frame. The cause was thought to be a loss of prime in the fuel oil system that would manifest itself after the diesel generator had been sitting idle for varying times.
In an attempt to ensure a valid start of the diesel generator the licensee proposed to initiate a maintenance start prior to the preoperational test start that would in effect prime the diesel generator fuel oil system. The inspectors expressed concern that this method of testing was considered improper and could impact the preoperational test result. The licensee agreed with the concerns and then proposed waiting 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> between starts to provide more acceptable data. The inspectors expressed further concern that future testing will.have to address the " loss of prime" and subsecuent failure of both diesels to come up to proper speed, voltage and frequency s
within the expected time. Investigation by the licensee revealed that the check valves in the fuel oil system had minor damage (a 5
nick on mating surfaces) and were improperly installed when received from the vendor. These conditions have been repaired and successful starts of the diesel generator initiated since the repairs. The licensee indicated that some method of verification of correct starting with respect to time (allow time for fuel oil system to drain) will be addressed in the future. This is considered an unresolved item (456/85008-07(DRS)) pending successful demonstration of the effectiveness of repairs to the diesel fuel oil system and acceptable diesel generator starts.
c.
BWPT EF-11. "ECCS Full Flow" During the test briefing and the conduct of the test the inspectors observed that proper effort was being made to inform all personnel of the expected evolutions of the preoperational test procedure.
Guidance was given to personnel regarding actions to be taken in the event of abnormal conditions and when these conditions occurred the Test Director imediately attempted to determine the cause and impact on the test. Comunications were well established and verified prior to each planned evolution. Operations personnel conducted detailed walkthroughs of the procedure to familiarize themselves with their expected actions to support the test.
During conduct of the test the following items became evident:
(1) The licensee had agreed to wait 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> between starts of the diesel generator as discussed in the above paragraph.
Approximately I hour prior to the "A" train testing an inadvertent undervoltage condition was initiated that attempted to start the 1A Diesel Generator. The diesel rolled for approximately 6 seconds but was prohibited from starting by operator action. Since the purpose of waiting between successive starts of the diesel generators was to avoid impacting the test results by priming the fuel oil system, this action appears to negate the previous efforts by the licensee to provide more meaningful data. This concern has been discussed with the licensee and is considered an unresolved item (456/85008-08(DRS))
pending further evaluation by the licensee and review by the
.i inspector.
(2) When conducting the "B" train section of testing and to verify independency of the Division 11 and Division 12 electrical systems, all Division 11 power supplies were disconnected.
When the safety injection signal was initiated and components started it was noticed that flow indication and discharge pressure for the IB Safety Injection pump were not functioning.
Investigation revealed that the process transmitters had a backup power supply from the Division 11 Instrument Power
.. Supply. The inspector has asked for more information to 5
evaluate the potential impact of this design feature. This is considered an unresolved item (456/85008-09(DRS)) pending technical review and evaluation by the NRC inspectors.
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(3) While viewing the recirculation mode of the ECCS pumps and containment spray pump the inspector noted that cleanliness controls were being either ignored or not enforced. ANSI N45.2.1-1973, " Cleaning of Fluid Systems and Associated
' Components during Construction Phase of Nuclear Power Plants",
requires that in order to maintain cleanliness classification certain precautions shall be adhered to in order to prevent the introduction of foreign material into the Reactor Coolant System. These precautions require access control, material accountability, personnel accountability, and shoe coverings.
The inspector observed that there were no precautions posted outside of the sump area and personnel were unaware of requirements to maintain material accountability, personnel accountability or the wearing of shoe covers while in this cleanliness zone. The precautions had been undertaken in the refueling cavity but not posted in tie area. The posting of precautions would provide needed information for all personnel entering these areas.
During observation of the flow, while taking suction from the containment recirculation sumps the inspector noted some debris, primarily paper, in the sump and surrounding area that entered the suction flow path. This observation was discussed with the licensee and corrective actions were taken. This is an example of a violation of 10 CFR 50, Appendix B, Criterion XIII (456/85008-10c(DRS)) and is discussed further in Paragraphs 3.b(1) and 3.b(2).
(4) The methodology for monitoring and evaluating vortex fonnation in the sumps appeared to be inconclusive to the inspector. The inspector has discussed this concern with the licensee, but the licensee has been unable to provide any more information about the validity of the testing method. The Senior Resident Inspector has contacted N.R.R. for further guidance for this issue and will track it in inspection report 50-456/85011.
6.
Preoperational Test Results Evaluation The inspectors reviewed the results of the below listed preoperational test procedure to verify all test changes were identified and approved in accordance with administrative procedures; all test deficiencies were appropriately resolved, reviewed by management and retested as required; test results were evaluated by appropriate engineering personnel and specifically compared with acceptance criteria; data was properly recorded, signed, dated and documented as test deficiencies, as necessary; test packages were reviewed by QA for adequacy of contents; and test results were approved by appropriate personnel.
BWPT CS-1.0, Rev. O " Containment Spray System" kheinspectorhadthefollowingcomment:
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The "A" and "B" Containment Spray (CS) pumps have different acceptance criteria due to different sized impellers. The "B" CS pump should deliver a higher flow rate at the same Total Developed Head (TDH) as the "A" CS pump. Utilizing the data, the licensee attempted to verify that the correct impellers are installed in the correct pumps. The licensee indicated that the data supported the correct installation. The inspector has been unable to independently verify the proper installation of impellers and has recuested more supporting information. The licensee has supplied the additional information but the inspector has not completely evaluated the additional information at this time. This is considered an open item (456/85008-11(DRS)) pending evaluation of the supplied informa-tion.
7.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 4.a.(2)(a), 4.a.(2)(b),
4.a.(2)(c), 4.a.(2)(d), 5.a., and 6.
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, Items of Noncompliance, or Deviations. Unresolved items disclosed during the I
inspection are discussed in Paragraphs 4.a.(1), 5.b., 5.c.(1), and 5.c.(2).
9.
Exit Interview The inspector met with licensee and contractor representatives (denoted in Paragraph 1) on March 21 and 27, 1985. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents / processes as proprietary.
The licensee acknowledged the statements by the inspectors with respect to open and unresolved items.
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0 N7;2'".'255 Docket No. 50-456 Docket No. 50-457 Correr, wealth Edison Corrpary ATTN:
f'r. Cc rdell Recd Vice President Post Office Ec) 767 Chicago, IL 60690 Ger.t ler er::
This refers tc the special safety inspection conducted by Mr. J. F. Schapker cf this office on Farct 5 through Noverrber 7,1985, of activities at Braidwood Stati(r., l' nits 1 ard 2, authcrized by NRC Construction Perrits Nc. CPPR-132 and ho. CFFE-133 and to the discussion of our findings with Messrs. V. Wallace erd C. Schreeder and others of your staff at'the conclusion of the inspectiori.
The er. closed ccry of our inspectico report ider.tifies areas exan,ined during the inspection. Within these areas, the inspection consisted of a selective e>aninatic.n of procedures and representative records, observations, and i
ir.terviets vitt. persentiel.
During this inspection, certain c,f ycur activities appeared to be in violation of NFC recuitt u nts, as specified in the enclosed Appendix. A written response i
is rec,uired.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of ttis lettet ar'd the encicsures will be placed in the NRC's Public Document Rocr..
The respenses directed by this letter (and the accornpanying Notice) are not sutject tc the clearance procedures of the Office of Mar.agen,ent and Budget as required by the Paperwork Reduction Act of 1980, FL 96-511.
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8512050482 851121 l
PDR ADOCK 05000456 G
100V 211985 Commonwealth Edison Company 2
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
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,;.:n by U. U....
J. J. Harrison, Chief Engineering Branch
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Reports No. 50-456/85009(DRS);
No. 50-457/85009(DRS) cc w/ enclosures:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent J. F. Gudac, Plant Manager C. W. Schroeder, Licensing and Compliance Superintendent DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB L.
Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on March 5 through November 7, 1985, and in accordance with the Gereral Policy and Procedures for NRC Enforcement Actions (10 CFR Part 2, Appendix C), the following violation was identified:
'n CFR 50, Appendix B, Criterion V, states in part that activities affecting q., 'tv shall be prescribed by documented instructions, procedures, or drawing and shall be accomplished in accordance with these instructions, procedures, c-drawings.
L. K. Comstock Coepany Welder Qualification Procedure 4.7.1, Revision 07-18-80, states in part in Section 3.10 that the QC inspector shall have in his possession the Welder Qualification Test Record, Form 88, and the record is to be completed during the period the welder is performing the weld process, and that upon completion of the testing of the weld coupons by the independent testing company the Form 88 is to be signed and dated.
Contrary to the above:
a.
A welder qualification record was signed and dated prior to the testing of the welder's coupons by the independent testing company.
b.
The welder qualifications records exhibited numerous clerical errors and omissions.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violation and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
NOV 211985 Dated J. J. Harrison, Chief Engineering Branch 8512050484 851121 DR ADCCK 0500 6
U.S. NUCLEAR REGULATORY COMMISSION REGICN III Reports No. 50-456/85009(DRS); 50-457/85009(DRS)
Docket Nos. 50-456; 50-457 '
Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: March 5 through November 7, 1985 Inspectorh.Ydbt l' /TkT
- b W
F. Schapker
/
Date
[n Approved By:
D. H. Danielson, Chief
/ /Thf Materials and Processes Section Date Inscettien Summary Inspection on March 5 through November 7, 1985 (Reports No. 50-456/85009(DRS);
No. 50-457/85009(DRS))
Areas Inspected: Special, unannounced safety inspection to review allegations concerning welding deficiencies by the electrical contractor (L. K. Comstock).
This inspection involved a total of 192 inspector-hours onsite by one NRC inspector including 30 inspector-hours of in-office review.
Results: Of the areas inspected, one violation was identified (failure to document welder qualification records to procedure requirements paragraph 2.h and 2.j, allegation 4),
s 8512050486 851121 PDR ADOCK 05000456 G
i DETAILS 1.
Persons C'ntacted o
Cor.rr.cnwealth Edisor Corp,any,,(CE,Cp]
- M. Wallace, Project Manager
- C. Schroeder, Licensing and Cortpliance Superintendent
- L. Klire, Liter sing and Cortpliance Supervisor
- G. Groth, Assistant Constructior. Supervisor R. Gardner, PSI Coordinator, level III C. Mennecke, Lead Electrical Supervisor P. Berry, QA Inspector
- C, Torresbek, Stertur Surerinter der.t
- T. Cuaka, CA Super ir.ter.derit
- 0. Srrith, Nuclear Licerising
- W. Vahle, Project Fie'd Engir.eer
'J. Gieseker, Project Cerstructico Engineer T. Ronkoske, Project Field Er.gineer L. K. Cc,r s tpc},,Cc,ryppy,,(,LJ:C)
'T. Sirile, Welding Engineer
- R. Seltrar.r., CA Mene g r
- I. Develd, CC Parager
- F. Relar., Project Mar.ager
- J. Klena, Project Engineer Sarcent J, L, undy, EnSqinee,r,s,,(S,E,L)
- G. Jcnes, Project Manager
- D Gallagber, Field Engineer
- K.
Kcstal, Project Director USNRC i
- W. Kropp, Resident Inspectnr
- L. McGreger, Senior Resident Inspector The inspector aisc contacted and interviewed other licensee and cor. tractor personnel.
- Denctes those attending the final exit interview.
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2.
(Closed) RIII 84-A-0123 Allegations On August 28, 1984, a former employee of the L. K. Comstock Company (LKC) at the Braidwood Nuclear Station contacted the Senior Resident Inspector
- Operations (SRI) Braidwood, with information regarding the L. K. Comstock Company. On August 31, 1984, the former employee telephoned Region III and spoke with the Chief, Plant Systems Section, Division of Reactor Safety (ORS) and provided the following allegations. In reviewing these allegations the NRC, in addition to utilizing information supplied by the alleger, also used a hearing transcript provided by the Department of Labor (DOL) relating to the alleger's complaints with DOL that also identified some apparent technical issues.
a.
Allegation L. K. Comstock Company (LKC) welders have been welding A-446 material to A-36 material; hewever, a weld procedure was not available. These welds were contrary to AWS D1.1-1975 according to the alleger. A nonconformance report (NCR) was eventually written (NCR No. 3099).
The alleger questioned the qualification of the weld when joining A-446 material to A-36 material, as A-446 is not addressed in the AWS code.
The alleger also identified that the technique sheet "0" for LKC weld procedure 4.3.3 was a reject.
NRC Review The electrical contractor (LKC) issued a nonconformance report (NCR No. 3099), and subsequently issued a stop work order on August 17, 1984, thereby stopping welding activities regarding this problem. The NCR was later dispositioned "Use-As-Is."
This disposition was based on the interpretation by the contractor, licensee engineers, and the architect-engineers of the American Welding Society (AWS) Standard 01.1-1975, Section 5.5, that states A36 steel is also qualified for use with welding procedure specifi-cation, Attachment H, of LKC Weld Procedure 4.3.3.
The procedure was revised to include A-36 to A-446 as part of the qualified base materials. Subsequently, the NCR was closed and the stop work order was lifted. The technique "0" which was referenced in weld procedure 4.3.3 was requalified on July 2,1984 with acceptable test results.
Conclusion This allegation was substantiated with no adverse effect on the quality of the welds. The NRC inspector reviewed the referenced NCR and weld proceQ re and concurred with the disposition of the NCR; that is, the referenced base material (A-446) although not specifically listed in AWS 01.1-1975 code, is qualified by virtue of qualifications performed in Weld Procedure 4.3.3, Attachment H, wherein A-446 to A-500 was a qualified material combination and A-36 to-A-500 was also a qualified combination. The chemical and i
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r.echarical prcperties of A-446 and A-36 are closely corrpatible and do r et pose a welc'aliility problen.. Although A-446 is riot listed it; th AWS 01.1-1975 code, the code does not require that only n.attrials listed in the code be utilized, other rraterials are allowed at the discretion of the " Engineer" and can be qualified by weld proc'edure qualification (PQR). The PQRs for Weld Procedure 4.3.3 fulfill tM requirer.ents for qualification of A-36 to A-446 material ir. accordance with AWS DI.1, Section 5.5, which states in part:
"Cualification of a welding procedure established with a base netal included in 10.2 and not listed in 5.5.1.2, having a minimum specified yield peint less than 50,000 psi (345 MPa) shall qualify the procedure for welains any other best netal or con,bination of those base metals included in 10.2 that have a minirnurn specified yield point equal to or less that thet of the base inetal used in the test." The weld prccedure was in error in that the A-446 base material was net listed as required and that technique sheet "0" was referenced with rej(cted test results wittin the procedure. The inspector reviewed the raised procedure and the foCR and fourd theri to be acceptable.
This ittr. was satisfactorily resolved.
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, Allegation The alleger centended the L. K. Corrstock Weld Procedure No. 4.3.14 ves (,uilified to the SG weld position, but the procedure was usec' te weld all pcsitions. The alleger also stated that language ir consister.cies e>ist within the procedure (e.g., instruction to use r.egr.(tic pcrticle testing on stainless steel).
h,RC, Review The f;EC ir.srector reviewed the referenced Weld Procedure 4.3.14 are deternir.ed that the procedure was qualified to the SG position as the alleger stated. Sone welds were perfortsed in the horizor.tal welding pcsiticn (2G) for which the procedure was not qualified. This ncnconforr.arce was idertified by the electrical contractor in noncon-foir ar.ce report (f4CR) fio. 3145 dated August 24, 1984 The corrective actior ('ispositier. of this fiCF was to requalify the weld procedure ard welders to include the 2G (horizontal) position for welding, and tc rer.ose the previously installed hcrizontal welds and replace ther after requalification. The qualification perforrned to the SG position quclifies the procedure for positions 1G, 3G, 4G, and SG.
The language irccnsistencies cited by the alleser was the use of a paragraph from the Anerican Welding Society (AvS) D1.1-1975 code, Paragraph 3.7.2.4 concerning, " Cracks in Weld or Base Metal." The stct(rent in this paragraph which caused the concern was: " Ascertain the extent of the crack by use of acid etening, magnetic particle inspection (MT), or other equally positive means." Since weld procedure 4.3.14 is for austenitic stainless steel, magnetic particle exanination would not have been effective. The inspector reviewed a sartple cf c,uality docunentation, in conjunction with allegation 5
RIII-EE-A-0005 in Paragraph 3 cf this report, to verify the proper utilizaticr. of NDE procedures.
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,C,o,nc,1 u s ion The first part of this (cncern was substar.tiated. Welds were made utilizir.s weld procedure 4.3.14 which was not qualified for the tcri2ontel welding position. This nonconfomance was ider.tified by the alleger, and L. K. Conistock initiated NCR 3145. The correc-tive action taker., rec. oval of noncorplying welds and replacement after reqbalificat-ion of the weld procedure ard welders was adequate to assure conpliance to the AWS D1.1-1975 code.
The alleged language inconsistencies had no detrinental effect to the quality of the welds madt with this weld procedure. The quote frorr AWS 01.1 is c ger.eral workmanship requirement for exan.ination of all typts of welds, and not specific to stainless steel. Although the statenent is misleading, it is not in error. The paragraph states a " suitable nethod" to assure removal of the crack. MT is not suit-able for stainless steel as it is nonferron.agnetic; therefore, other suitable neans (i.e., liquid penetrant would be utilized). Fersonnel who perforr MT cr sefcty-related conpener.ts are required to be qualifiec tc perform this exaninaticn. Also included as part of the qualification requirerar.ts is that the inspecter rnust be knowledgeable cf the type cf caterials that can be exan;ined by the magratic particle process. The NFC did nct fird any case where the incorrect NDE methed was otilizec' in the retiew cf thE contractor 's quality docun entatior..
c.
A,1,lega tion A procedur( was uscd to rcke tiretellic welds, but the procedure is not a binetallic procedure. Binetallic welds have been made, but L. K. Constock does not have a procedure to qualify its welders for biretellic wcids. Therefore, wclders are nct quclified to take bir..etallic welds.
,N,RC Review The NRC inspector interviewed (Farch 12,1985) the alleger for specifics in rE5 erd to the birrctallic welds. The alleger informed the inspettor that the welds he was referring to were stainitss steel (SS) jur.ction boxes within the reactor building. The elleger cen-tended the junction boxes were being welded to carbon steel (CS) ccoduit. The NRC inspector located the junction boxes per the alleger's description and verified that they were stainless steel (out of core neutron detector juncticn boxes); however, the CS conduit attachner.t to the junction box is not welded but mechanically attached (Uniseal Hub Appleton). There is, however, an 8" Schedule 40 SS pipe welded within the jur.ction box for supporting cables ar.d therto-couples. All base netal within or attached to the junction boxes by welding is stainless steel, no bimetallic welds were made. (Reference the Architect Engineers [Sargent&Lundy] Drawing 20E-0-3550, Rev-ision R.) The NRC inspector physically examined the referenced junction boxes ard verified no carbon steel was welded to ther.. The 5
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NRC inspector's further inquiry of the Level III welding supervisor and Level II weld inspectors stated they knew of no stainless to carbon steel welds performed by the electrical contractor. The alleger also made reference to welder qualifications being made to SA-312 to SA-312 when SA-240 to SA-312 was being performed in the field. This concern was found to be true; however, this is not a violation of code requirements. The base metals SA-240 and SA-312 are both SS P-8 Group 1 (ASME Section IX) material. SA-240 is plate and SA-312 is pipe. AWS D1.1-1975, paragraph 5.23.2.4 states
" Qualification in the 6G (inclined fixed) position qualifies for all positions groove and all positions fillet welding of pipe, tubing, and plate."
Conclusion No stainless steel to carbon steel welds (bimetallic) were performed by the electrical contractor. The electrical contractor had quali-fied welding procedures and welders for stainless to stainless steel as required by AWS D1.1-1975.
d.
Allecation In general, the L. K. Comstock weld procedures are filled with errors and inconsistencies (e.g., decimal fraction conversion tables show 0.750 = 32/32).
NRC Review The NRC inspector reviewed the contractor's weld procedures which were generally accurate and adequate. Minor typographical errors as referenced by the alleger were encountered, but were not prevalent.
Further discussion with the alleger (March 12, 1985) disclosed that this allegation was not critical of the weld procedures adequacy but that clerical errors within the procedures needed to be corrected.
Conclusion The contractor has revised and corrected the clerical errors in subsequent revisions of the weld procedures. The type of errors encountered in the past revisions were minor and did not affect the overall adequacy of the weld procedures or the quality of the welding. Reference allegation b. above for other "inconsis-tencies," as well as NRC Inspection Reports No. 50-456/84-36(DRS);
50-457/84-34(DRS), Section 3.
e.
Weld Filler Material Allecations Allegation 1 L. K. Comstock Company does not have any weld filler material controls, as the procedure is only now being written.
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NRC Review The L. K. Comstock Procedure 4.3.10, Revision C, dated December 8, 1983, titled, " Storage, Issue and Control of Welding Material," was in effect at the time of the alleger's employment at Braidwood. The alleger may have been referring to weld filler material control problems which were identified in L. K. Comstock nonconformance report (NCR) 3275,.which was issued September 12, 1984 as a result of the alleger's concern addressed to L. K Comstock. The NRC inspector reviewed this NCR which identified violations of the referenced procedure. The corrective action taken by this NCR included revision of the procedure to enforce additional requirements in the weld material control area.
Conclusion The L. K. Comstock Company had adequate weld filler material controls in place. NCR 3275 identified some violations to this procedure which were adequately dispositioned and appropriate corrective action implemented. The revision of the procedure did require additional weld material control measures as corrective action to prevent recurrence as required by 10 CFR 50, Appendix B, Criterion XVI.
These controls and corrective actions were found to be acceptable to the NRC inspector.
Allecation 2 Filler material withdrawal forms have inconsistent heat nLep rs.
The alleger could not find any paperwork to backup heat numbers in the possession of either L. K. Comstock or Phillips-Getschow.
Phillips-Getschow, the Braidwood Mechanical Contractor, furnishes the filler materials to L. K. Comstock.
NRC Findinos The NRC inspector selected a random sample of weld filler material withdrawal forms (FMdF) from three different tirce periods, covering a three year time frame. Included in this samnle were withdrawal forms for E-7018, E-6013, and E-309-16 weld material of various sizes. The inspector reviewed 50 FM4Fs and traced the referenced heat numbers to the appropriate weld material certifications (CMTR).
The alleger identified three heat numbers for which he could not locate the applicable CMTRs (reference LKC NCR 3275, Sheet 4). The NRC inspector research for these heats disclosed the following:
40157441 CMTR was located and conformed to the specified material requirements for E-7018 welding electrode; 40159011 was not located but 40259011 for 7018 was on file. The 40159011 is undoubtedly a typing or clerical type error in recording of the heat number on the weld rod issue slip; 3520261 was located as 3S20261 for 6013 weld rod. The "S" was obviously misidentified as a 5.
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, Conclusion The f;RC inspector's review cf FMWFs over a thret year period did not disclose a deficiency in this area.
In sone cases, it was necessary fer the fiRC inspector to trace the heat nurt.bers to the licensee's qt,al'ity records v6 Lit as the contractor did not have the CMTR in their records vault. The three heats of weld rod which the alleger could not locate were found, two with obvious variations of the recording or inter'pretation of the numbers / letters of the identifying heat numbers.
f.
Allecetic,n The alleger has found that L. K. Cortstock Company (LKC) does not have any control of construction n.aterials in ternis of heat numbers or other tracectility.
,fiRC, _ Review The t;RC inspector selected a rarden. san;ple of LKC constructiot.
n.aterial tc urify traceability. The material irspected was narked with a naterial receipt nurrber (MRR). LKC perforns receiving ir spectico of all naterial received (reference LKC Procedure 4.10.2, "Feceitir s ar c' Storage") ard subrits the MRR to the licensee's Qt.clity Assurance Cepartment (CECc CA) who is resper sible to verify tre naterial neets the requirements of the applicable purchase order.
The (t,61ity Assurance group reviews the adequacy of the dccun,entation such as: certified naterial test reports, certificates of confor-ner.ce, cr ary other required docunentation. The licensee QA group also grforr.s a physical inspection of the n,aterial as required by procecure 501-06, "Matcrial Feceiving Repcrt (MRR) Processing." Upen cor pleticr. of acceptable review by the CECO CA group, the contractor is authcrized for release for irstellation ir safcty-related areas.
The PRR rtrber is tracealle to the applicable purchase order and stility records are iritiated arc' maintained by the licensee. Only safety-related conponents/nitterial were required to be marked with the FFF idertification nurber and is required to be sc ider.tified for use in safety-related constructior..
Conclusion o
The concern was partially correct as the alleger's contention that transfer of heat nunbers is not accortplished for rr.aterial traceability is accurate. However, transfer of heat numbers is not a requirement to nair.tain traceability of materials. The use of an approved procedure and the MRR rurber as a basis to assure adequate material traceability is censidered by the NRC to afford proper control.
1 Thus, the licensee's methcd of niaterial traceability for the electrical contractor was found to be adequate to assure the natirial traceability is controlled to the point of installaticn.
A siniilar ccncerr. was previcusly addressed in NRC Inspection Report tsc. 50-45E/84-23(DRS); 50-457/84-22(DRS), Section 2, Paragraph c.
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Allegation Welds were r.adt withcot the required preheat. A procedure was developed that did r.ct require weld preheat, but quality centrcl did rot participate by observing the making of the weld coupon qual'ifyir.g the procedure.
NRC Review This allegation was partially correct; however, the contractor took corrective acticn through nonconformance report (NCR) 3423, dated October 12, 1984 NCR 3423 identified the violation of questicrable preheat docunentation for welds which required preheat due to the thickness of the members being joined, that is in excess of 1-1/2".
The centractor developed weld procedure qualifications (p(R) for those welds fror.1" to 3" thickness welded without preheat.
Tbc welds to nenbers ir. the plant in excess of 3" in thickness were rcrcycd erc' replaced utilirirs the required preheat ar.c' that rewerk it.cludir.g the preheat was docun.ented acccrdingly. The alleger's cor tention that quality centrol did nct participate in the nakir.s cf tte v. eld coupens qualifying the procedure was not correct. The t'RC inspectoi interviewed the CC inspector who was responsible for sorseillar.ce of the PQRs. The QC inspector attested that he witnessed thE weldir.s Cf the test CoupO0s throughcot the process.
Conclusion i
The concern as steted that quality certrol did nct participate in the weldir.g of the weld procedure qualifications was not subster:tiated. The inplied concern that welds were made withcut rec,uired prettet was substantiated but this probler had beer ider.tified ar.d adequately dispcsitiotied by NCR 3423. The hPC found ttis issut had been adequately resolved.
h.
Allegati,cn Welder qualification records have inconsister.cies which n.ake welder qualificaticns indetern.inate.
NRC Reviey The NRC inspector selected a randon, sample of welder qualification records for this review. The san:ple consisted of 75 past and current welders for the electrical contractor. Some minor discrepancies were noted in the welder qualification records such as typographical and clerical errors which have been addressed ir. LKC NCR 3710 dated Decerber 8, 1984 Past welder qualification records were revised in error wher. the electrical contractor was replaced onsite, i.e., white out of "E. C. Ernst" replaced with "LK Comstock"; incorrect changes of material type (A36 for A106); signatures not dated; and type of 5
electrode not docurented. The NRC inspector also reviewed welder qualification records which the alleger specified incensister:cies which were net identified in LKC NCR 3710, 9
o Conclusion The welder qualification records did have some inconsistencies as stated by the alleger. However, none of the inconsistencies observed by the NRC inspector would have made the welders' qualifi-cations indeterminate. The minor clerical errors observed were readily obvious, some were originally correct and had been changed in error. Some of.these errors have been documented in LKC NCR 3710 dated December 8, 1984 and dispositioned adequately. There were addi-tional inconsistencies identified by the alleger which were in violation of the LKC welder qualification procedure 4.7.1.
This is considered an example of a violation of 10 CFR 50, Appendix B, Criterion V (456/85009-01(DRS); 457/85009-01(DRS)).
1.
Alleoatien Many of L. K. Comstock field welders are qualified to L. K. Comstock Procedure 4.7.1.
However, this procedure is not traceable to L. K. Comstock AWS DI.1 weld procedure qualification records. Some welders were originally tested on Schedule 80 pipe, but the current r
procedure refers to test on plate. Welder qualification cards stated the welder was qualified to LKC 4.7.1 but the welders were actually qualified to E. C. Ernst Procedure 9.2.
NRC Review I
L. K. Comstock Procedure 4.7.1, Revision 6, dated June 22, 1982, titled, " Manual Shielded Metal Arc Welding (SMAW) for Structural i
Steel and Stainless Steel Qualification Procedure," was reviewed by the NRC inspector. The purpose of this procedure is to qualify welders per AWS D1.1-1975 for groove and fillet welding using the SKAW process. The procedure need not be traceable to L. K. Comstock welding procedures as it is not utilized for construction. The procedure is written to the requirements dictated in Section 5, Part C of AWS D1.1-1975. Accordingly, this procedure was intended for welders' qualifications only. These qualification tests are not intended to be used as a guide for welding during actual construction, but are specially devised tests to determine the welder's ability to produce sound welds.
The NRC inspector reviewed the welder qualification records as described in allegation h. above. During thisireview it was observed
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l that the welder qualifications were performed on Schedule 80 pipe l
when E. C. Ernst (ECE) was the electrical contractor (ECE 9.2).
l L. K. Comstock subsequently revised the procedure to utilize plate in lieu of pipe for welder qualifications. The use of pipe or plate for welder qualifications meets AWS D1.1 for the welding applications by LKC.
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o Conclusion This concern was correct in that Weld Procedure 4.7.1 is not traceable to L. K. Comstock weld procedure qualification records.
This, however, is not a deficiency. AWS D1.1-1975, Section 5, Part C, describes the welder's ability to produce sound welds.
L. K. Comstock Weld Procedure 4.7.1 is the contractor's method of qualifying the welders which is taken from the requirements listed in AWS.
Welders who qualify on Schedule 80 pipe are also qualified to weld plate within the thickness and positions for which they qualify, reference AWS D1.1-1975, Paragraph 5.23.2, Table 5.23 and 5.26.1.
Therefore, those who qualified per ECE 9.2 also qualified for LKC 4.7.1 (also reference paragraph 2.j, allegation 2 of this report).
j.
Welder Qualification Records Allegations The alleger submitted a list of welder qualification record deficiencies which was utilized in addition to the referenced random samples.
Allecation 1 Welders were tested on 1/2" thick material, but records showed the welder with an unlimited thickness range.
NRC Review The NRC inspector reviewed a random sample of 75 welder qualification records for current and past welders. Within the sample reviewed the welder qualifications records defined the limits of the welder's qualification, which referenced fillet weld only for those qualified on 1/2" thick material.
Conclusion The NRC inspector did not identify any deficiencies as described by the alleger. The alleger could possibly have misinterpreted the qualification of fillet welders on 1/2" plate which complies with AWS DI.1-1975, Table 5.26.1.
This test for fillet welder qualification only is performed on 1/2" plate and qualifies the welder to weld fillet welds of unlimited thicknesses. In addition, some welders whose qualifications had expired performed requalification on 3/8" plate but had previously qualified on 1" plate. This requalification on 3/8" plate qualifies the welder to perform welds of unlimited thickness. reference AWS DI.1, Paragraph 5.30 and L. K. Comstock procedu-e 4.7.1, Revision C, dated November 26, 1984, " Welder Perforrance Qualification Test."
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1 Allecation 2 Welders were tested cn 6" Schedule 80 pipe, but welder records showed an unlimited thickness range. AWS D1.1 shows a' lower range-of 0.137" thick, but actual welding is down to 0.105".
NRC Review Tht: finding ha1 been previously identified in NRC Inspection Report No. 50-456/84-21(DRP); 50-457/84-20(DRP) as an unre. solved item (456/84-21-05; 457/84-20-05). The NRC inspectot interviewed (March 12, 1985) the alleger for additional details in regard to this concern.- The alleger stated the thickness of unistrut was approxi-mately CC105". ' Review of the AWS D1.1-1975 code identified that Table 5.'26.1 does' limit the minimum thickness to be qualified with 6" Schedule 80 pipe as.187".
However, the AWS D1.1-1976 code added the footnote which qualified the welder for unlimited thicknes's for fillet welds. This was an obvious oversigh't.in'the 1975 code which'was subsequently added in the 1976 code, as a welder who demonstrates the ability to weld pipe groove weids wcUld also be capable to weld fillet welds of any thickness. Furthermore, AWS D1.1-1975, Section 5.23.2,
" Groove Pipe Test Welds," and Table 5.23 designates welders qualif.ied to weld pipe groove welds are qualified to weld ~ fillet welds for the position qualified.
The welds utilized on uni;trut material in the instal.lation of cable pan are fillet welds.
Conclusion This concern was correct in that the AWS D1.1-1975 code did specify a minimum thickness qualification for wel.ders who qualify on 6" Sche:uie 80 pipe, However, this limitation was not intended to include fillet welds as the 1976 code revision clarified by addition of the footnote. The purpose of tha welder qualifications is to assure the welder is capable to produce sound welds within a welding process, position and thickness. A welder who qualifies on 6" Schedule 80 piping groove weld demonstrates this ability to perform fill.et welds as specified in AWS D1.1, Section 2, Table 5.23.
The exclusion of the footnote in Table 5.26.1 1975, in the inspector's opinion, was an obvious oversight which was corrected in the 1976 edition of the code.
Allegation 3 Welders with " rejected positions" only took one test on retesting.
The alleger contended that the code required two retests, not one.
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NRC Review The NRC inspector reviewed the AWS DI.1-1975 code. Paragraph 5.29.1.2 of the code states, "A retest may be made provided there is evidence that the welder has had further training or practice.
In this case a complete retest shall be made." It is not required by LKC Procedure or the AWS code that the further training or practice be documented, or how much training is required to qualify for this option. This determination is at the discretion of the contractors. The NRC inspector reviewed a random sample of welder qualification records, including those welders referenced by the alleger, for retest of welders who had previously failed the test. No violations of the AWS D1.1 or contractor procedure was apparent.
Conclusion The AWS code gives two options when a welder fails to meet the requirements of one or more test welds. The first option is stated in Paragraph 5.29.1.1, "An immediate retest may be made consisting of two test welds of each type on which the welder failed. All retest specimens shall meet all the specified requirements." The other option is as stated above in Paragraph 5.29.1.2.
Therefore, if this practice was utilized as stated by the alleger it would not necessarily violate the code. The NRC inspector did not find any violations involving the retesting of any welders who had failed a welding test during review of welder qualification records.
Allecation 4 Records showed that an identified welder had a rejected test on a 1" thick plate and that the welder performed two additional tests on the same day. M c alleger thought it was ir.possible and the record was wrong.
NRC Review The NRC inspector performed a random sample review of welder qualification records, and reviewed one welder's qualification record identified by the alleger with this deficiency. Welder No. 735 identified by the alleger as the welder who, according to the welder qualification records, had welded three 1" coupons in one day. The inspector's review of this person's welding qualifi-cation record revealed the following data: A weld test was performed by the welder on February 26, 1981 on 1" plate (LKC Form 88). The lab test for this test coupon was performed on March 5, 1981 per the Pittsburgh Testing Lab (PTL) test report. (PTL is the indepen-dent testing lab who performs the physical test [ bend test, machros, etc.] of the welder's test coupons for LKC's welders' qualifications.)
These test reports dated March 5, 1981, identified as Lab Report BST 5676 testing of coupon for 3G position (failed test), Lab Report BST.5677 for testing of coupon for 4G position was acceptable. PTL Lab Test Reports BST 5683 and 5684 dated March 10, 1981, both for the i
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3G position retest for the same welder, was acceptable. The LKC Form 88 (welder qualification test record) was signed February 26, 1981, the same date as the original test. This was an obvious error on the Form 88 as the retest by PTL was dated March 10, 1981. The inspector's review of 75 additional welders' qualification records did not reveal any additional record errors of this type.
Conclusion The contention that the welder's qualification record was in error was correct. However, the PTL test records which accompany the LKC Form 88 provided objective evidence that the test coupons were welded, and tested over a period of two weeks. The error was obvious that the LKC Form 88 was signed prior to the final testing of the weld coupons, which violates the LKC welder qualification Procedure 4.7.1, Revision July 18, 1980, Paragraph 3.10.4, which instructs the QC inspector to sign Form 88 after receipt of the Independent Testing Company report. This is considered an example of a violation of 10 CFR 50, Appendix B, Criterion V (456/85-009-01(DRS); 457/85009-01(DRS)); however, the welder's qualification record was adequate in that there was objective evidence to support the welder had satis-factorily completed the welder qualification in accordance with the requirements of AWS D1.1-1975, Section 5, Part C - Welder Qualifica-tion. The inspector's review of the random sample did not disclose any additional violations of this type.
k.
Welder Qualification Inconsistencies Allecation 1 The alleger believes there are many instances of record falsification; for example: An unidentified welder took three test coupons and got the results all in one day. The alleger stated that this was administratively impossible.
NRC Review This concern was addressed in paragraph 2.j, allegation 4 of this report. However, the NRC inspector reviewed additional welder qualification records, L. K. Comstock Procedure 4.7.1, Revision C, dated November 26,1984, " Welder Performance Qualification Tests,"
and Procedure 4.3.20, Revision 0, dated February 29, 1980, " Manual Shielded Metal Arc Welding for Structural Steel Qualification Procedure." These procedures establish the method of qualifying welders per AWS D1.1-1975 utilizing Shielded Metal Arc Welding process (SMAW). The procedure requires the QC inspector to initiate the Form 88, " Welder and Welding Operator Qualification Test Record."
This record is partially completed during the period that the welder is performing the weld test; however, no dates are required until the completion of the guided bend test or fillet weld test (whichever is' required) and the LKC QC manager or his designee sign and date the form. The guided bend test and fillet weld tests are performed by an independent laboratory (Pittsburgh Testing Lab).
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Conclusion The welder qualification records do not reflect the period of time it takes to weld and test welders' coupons. It is possible that a welder performed the three tests over a period of time and were all submitted for testing to PTL on the same day, tested, reviewed, signed, and dated by the QC manager on the same day. The alleger only cited one example which was addressed in paragraph 2.j, allegation 4 of this report. No other evidence of record falsification was identified by the NRC inspector.
Allegation 2 Face bend and root bends were done on 1" thick plate material which the alleger contended was physically impossible.
NRC Review The NRC inspector performed a random sample review of 100 welder qualification records in addition to the samples previously reviewed.
No face or root bends were observed to have been performed on 1" thick plate material. The alleger found one welder with this deficiency. The NRC inspector reviewed this finding and concluded from the records that the plate thickness was actually 3/8" plate and the 1" plate thickness annotated on the Form 88 was a clerical This was substantiated through the review of the PTL testing error.
data which identified the plate thickness to be 3/8".
Conclusion The NRC inspector's review did not disclose the deficiency as stated by the alleger. The incident identified by the alleger was an obvious clerical error; hewever, the sample of test results observed by the NRC inspector were recorded on the Form 88 for 1" thick test coupons and were tested by PTL as required by AWS D1.1-1975, Table 5.26.1.
The tests performed were the required side bend test and were found to be acceptable.
Allegation 3 Overheard that an inspector inspected 1,000 welds in one day.
NRC Review The NRC inspector reinterviewed the alleger (March 12, 1985) who stated he had no personal knowledge of this concern, but had heard that the inspector was the same person as in paragraph 2.p and that the welds were located on the turbine floor. This concern is addressed in conjunction with the allegation documented in paragraph 2.p of this report.
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1.
Allecation
" Master Hammer Log" - A welder was assigned welder stamp numbers 23 and 123, but two other welders were also assigned the same stamp numbers. Other inconsistencies in the Master Hammer Log were also found.
NRC Review The NRC inspector reviewed the welders' Master Hammer Log. The welder assigned welder stamp 23 was also identified with his " brass" or employee identification number 123 in the same record. The brass number is an employee identification number and is not used in iden-tifying the welder's work. The stamp number 23 was used previously by another welder who worked for E. C. Ernst, the previous electrical contractor. However, the dates of stamp issue were recorded and therefore is traceable to the work the welder performed through the inspection records. The issue of a welder's stamp to another individual after the previous welder turned in his stamp (layoff, resignation, change in jobs) is acceptable provided the dates of issue and surrender are maintained and there are records to validate the date when the welds were produced. The NRC inspector sampled the control of 50 additional welders stamps with no adverse findings.
Conclusion This concern was partially correct, but does not adversely affect f
the welder's identification records. Although the stamp number may be issued to more than one individual, the Master Hammer Log records the issue and surrender date with the identity of the welder. This, together with tre inspection records, makes it possible to trace the individual weld to the appropriate welder. In addition, LKC Procedure 4.8.3, 'N'ald Inspection," Paragraph 3.11, requires the weld inspector to verify, during his inspection, that welder identification is indicated by assigned stamp near the weld joint, m.
Allegation A Level 2 Quality Control inspector was responsible for the welder test booth. The Level 2 was also assigned to perform inspections in the fabrication shop and routine field inspections; consequently, no inspectors watched welder testing in the qualification booth. The alleger considered this to be inadequate control of the welder testing program and inadequate or no quality control involvement in the weld qualification test implementation.
NRC Review The NRC inspector interviewed the welder test booth inspectors named by the alleger who were responsible for inspections to be performed on selder qualification tests required by LKC Procedure 4.7.1, Revision C.
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The inspectors interviewed stated that, to their knowledge, in no case that they were aware of was there a welder qualification test performed without the presence of a QC inspector, as required by the referenced procedure. In addition, the NRC inspector reviewed more than 100 welder qualification records which documented that a QC inspector performed the required inspections and recorded the applicable welding data on the welder qualification record. One inspector did indicate that he voiced his displeasure of having to do inspections in the welder qualification area and in the field; however, he did not consider this a safety concern as the required inspections were completed by the QC inspector.
Conclusion This concern was partially substantiated with no detrimental effect to the welder qualifications. That is, the QC inspectors were also assigned to perform inspections in the fabrication shop and in the field (power plant). This is common practice as welder qualifications are not usually performed 7 days a week but only on an as needed basis. When a welder was performing welder qualification testing the QC inspector was required to be present to witness the welder's performance in accordance with LKC Procedure 4.7.1.
n.
Allecation The L. K. Ceestock Company's Corporate Quality Assurance Manager intimidated quality control inspectors during discussions on compensation by telling the inspectors that he had 20 people ready to take the places of the inspectors.
NRC Review Further discussion with the alleger (March 12, 1985) concerning this allegation revealed that the source of the allegation was hearsay and that the discussions with management concerned the hiring of new inspectors at higher salaries without compensating the other inspectors.
Conclusion This allegation was previously investigated and closed in NRC Inspection Report No. 456/84-34(DRP); 457/84-32(DRP), Allegation RIII-84-A-0119. The inspection concluded that there was no intimidation.
o.
Allegation Comstock inspection procedures do "not deal with a full penetration weld of any kind," and it's the alleger's understanding that there has been full penetration welds done on the project.
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NRC Review The NRC inspector reinterviewed the alleger (March 12, 1985) who provided further clarification; "he heard the full penetration welds only required visual inspection - no other NDE was performed." The NRC ' inspector's review of the full penetration welds produced by LKC revealed that the full penetration welds performed by the contractor were on riser collar support assemblies, column bars within the riser cable pans, main control board modifications, and equipment pads.
The riser collars provide support for the vertical riser cable pans through floor penetrations. During a CECO audit performed on April 30, 1984, the licensee's Quality Assurance auditors discovered that some of the riser collar assemblies were not installed and fabricated to the applicable design drawings.
LKC issued nonconformance report (NCR) 2648, dated June 19, 1984, to identify the discrepant riser collars and to implement corrective action. The corrective action stated on this NCR was to rework the riser collars to conform to the latest design drawing and Engineering Change Notice (ECN) 24181. The NRC inspector reviewed the referenced NCR and ECN and confirmed the corrective action was adequate to correct the deficiencies. The alleger's contention that the full penetration welds only required visual examination was correct.
However, the Architect-Engineer (S&L) specification previously required only visual examination (LKC Procedure 4.8.3, " Weld Inspection") which complies with AWS D1.1-1975. A recent amendment to the S&L specification L-2790, subsequent to NCR 2648, Paragraph 401.19.1, Amendment 42, dated November 9, 1984, requires additional nondestructive examination to be performed on full penetration welds. This change has been implemented on all new fabrication and installation utilizing full penetration welds.
The use of only visual inspection for acceptance of full penetration welds prior to November 9, 1984 met the nondestructive testing requirements of AWS D1.1.
Based on engineering judgement, as an added measure of assurance, additional NDE (radiographic testing) is currently (post November 9, 1984) being performed.
Conclusion Although the electrical centractor did not perform nondestructive examination (NDE) other than visual on the full penetration welds, the architect-engineer (AE) specification (L-2790) did not require NDE other than visual examination at the time the welds were made.
AWS 01.1-1975 does not require.other NDE unless specified by the engineer (AE) or owner, reference Section 6.6 of the code. Discrep-ancies identified by the licensee in regard to the rise collars have been adequately addressed and corrective action has been implemented.
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Allegation The'L. K. Comstock Braidwood QC Manager was previously an inspector and passed many welds which should have been rejected.
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NRC Review The NRC inspector reinterviewed the alleger (March 12, 1985) who stated his information "was hearsay and he had no personal knowledge of this concern." The alleger also stated that "he heard that the area'of concern was on the turbine floor." The turbine floor is located in the turbine building, a non-safety related area.
The NRC inspector " selected a random sample of the welds that had been inspected by this individual in safety-related areas to verify the adequacy of those inspections. The majority of these welds had been painted; therefore, it was not possible to inspect 100% of these welds. Some of the welds were not painted due to reinspection being performed by an independent laboratory (Pittsburgh Testing Lab).
Those that the NRC inspector observed met the visual acceptance criteria of AWS D1.1-1975.
Conclusion The alleger, by his own admission, had no first hand knowledge of i
this concern. Furthermore, the hearsay information involved a non-safety related area. The NRC inspector's sample in safety-related areas did not reveal any defective welds.
Additionally, the Pittsburgh Testing Laboratory (PTL), an independent laboratory, performed a 10% overinspection of the LKC inspections of welds. These overinspections were documented and included with the
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weld inspection records. A review of these records by the NRC inspector did not disclose a problem with the QC manager's previous inspections as a weld inspector.
q.
Allecation The Alleger had reviewed weld procedures for L. K. Comstock at Perry and had identified procedure inconsistencies.
NRC Review This concern was addressed in NRC Inspection Report No. 50-440/85043.
The inspector substantiated this allegation and identified the inadequacies of the procedure within the referenced report.
Reference violation 440/85043-01(a), (b), (c), and (d)(DRS).
Conclusion This concern was verified but does not apply to this licensee.
The procedural violations identified in NRC Inspection Report No. 50-440/85043 were resolved.
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Allecation "Within three days after I started working, I noticed that there was a joint design, a weld being made in the shop that was outtide the criteria of the AWS D1.1 code."
NRC Review The NRC inspector'reinterviewed the alleger for specifics (March 12, 1985). The alleger stated he had noticed a weld, 1/4" plate to unistrut, which violated AWS DI.1, Figure 8.8.5.
The NRC inspector performed field and shop welding observations and noted the joint the alleger referred to as a violation of AWS D1.1, Figure 8.8.5.
AWS D1.1, Paragraph 8.8.5 states, " Fillet welds deposited on the opposite sides of a :ommon plane of contact shall be interrupted at the corner common to both welds."
The observations the NRC inspector made, in the application of this weld, were in compliance with the Architect Engineer (S&L)
Drawing 20-E-0-33930, Revision AE.
In addition, the NRC inspector inspected a sample of 50 cable pan hangers with the referenced weld orientation which complied with the S&L drawing requirements.
Conclusion AWS DI.1, Section 8.8.5, requires the fillet weld deposited on oppositt planes be interrupted at the corner common to both welds. The welds observed by the NRC inspector complied with this requirement. Some of the subject welds butted up against each other, but none of those observed were continuous. The S&L Drawing (20-E-0-3393D) specified 1/8" fillet welds for the full length on both planes. The application of this configuration does not violate the AWS code.
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Al k gation l
Noncompliances had been performed by a E. C. Ernst, which was the j
contractor prior to Comstock, and these were still faulty problems that had not been addressed.
NRC Review Further discussions with the alleger (March 12,1985) disclosed that the "noncompliances" he referred to were with the welder qualification records. This concern is addressed in paragraph 2.h.
t.
Allecation
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L. K. Comstock Company had qualified a General Electric procedure by.only doing a tensile test on the coupons when it's customary 5
to do a bend test as well.
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NRC Review The NRC inspector reviewed the referenced procedure which was generated for use on non-safety related aluminum welding (bus bars).
The welding performed utilizing this procedure was not safety-related and therefore was not subject to the requirements for qualification specified in AWS D1.1-1975 code.
Conclusion This concern was not substantiated. The weld procedure is not utilized for safety-related welding and therefore is not required to meet the AWS DI.1-1975 code.
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Allecation The alleger stated that he was prevented from making a " formal finding" because he was not certified.
NRC Review This allegation was correct in that the alleger, because he had not certified as an inspector, could not issue / sign a nonconformance report (NCR). However, during the review of the allegations the NRC inspector noted that several NCRs were prepared by the alleger and signed by a certified inspector. The alleger also supplied documents / memorandums in which he expressed concerns, and for which the contractor took action to address these concerns, i.e., stop work orders, NCRs, memorandums addressed his concerns.
Conclusion per the requirements of the LKC Quality program, the issuance / signing of a nonconformance report must be signed / initiated by a certified inspector. This requirement did not prevent the alleger from expressing his concerns, and as evident from the supporting documen-tation supplied by the alleger to the enclosed allegations, was acted on by the electrical contractor. Other documentation reviewed by the NRC inspector throughout this inspection clearly demonstrated that the alleger's concerns were addressed and resolved when the alleger made them known to the contractor's management. In addition, there were NCRs prepared by the alleger which were issued through a certified inspector (reference LKC NCRs 3099, 3137, and 3145).
One violation with two examples was identified (paragraphs 2.h and 2.j, allegation 4).
3.
(Closed) Allegation RIII-85-A-0005 The document reviewer stated that the Comstock Rework Program is " full of loopholes" and that "the documentation flow through QC is not clear in the procedure." As an example, a final inspection will be done, but 21
B i
" seldomly is there a basemetal inspection." The reviewer continued "the basemetal inspection is required to be done after a defective part is removed, but before the replacement is installed."
NRC Review The NRC inspector interviewed each L. K. Comstock document reviewer and their supervisor independently. None of the personnel interviewed were knowledgeable of the alleger's concerns. The NRC inspector reviewed L. K. Comstock Procedure 4.13.1.1 titled, " Turnover Document Review."
This procedure " prescribes the guidelines for the review of quality control inspection documents to be followed by all Document Review personnel."
The procedure provides a checklist for all quality documents reviewed.
The Document Reviewers are required to review the quality document to the applicable checklist in the procedure. None of the checklists reviewed specified a review for base metal inspection but rather to ensure that all records were complete and properly approved in accordance with ANSI N45.2.9.
The NRC inspector reviewed a random sample of quality documents with no adverse findings.
Conclusion Tnis allegation was not substantiated. The Document Reviewers do not review the quality documentation for base metal inspection as it is not part of the procedural requirement. However, base metal inspection is required to be performed as stated by the alleger, when a (defective) i part is removed and before the replacement is installed. This is a requirement of LKC Procedure 4.3.12, Fevision C, dated February 6,1985, Paragraph 6.6, which states that QC will be notified to perform a base metal inspection if at any time a hanger / component is to be moved or cut down during or after installation. This is documented on LKC Form 244 and signed by a Level II inspector. Document reviewers are not Level II inspectors and would normally not be knowledgeable of when a base metal inspection is required. This concern was also acdressed in NRC Inspection Reports No. 50-456/85044(DRS); No. 50-457/85043(DRS) in conjunction with this review.
No violations or deviations were identified.
4.
Exit Interview The inspector met with site representatives (denoted in Persons Contacted Paragraph) at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection noted in this report. The inspec-tor also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensce did not identify any such documents /
processe.s as proprietary, s
22
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UNITED STATES f*
C.,
NUCLEAR REGULATORY COMMisslON
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REGION lli I
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ctc~ cuev~. itu~ois soor JUL 1 1 1955 Docket No. 50-456 Docket No. 50-457 Comonwealth Edison Company ATTh: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. R. D. Schulz, L. G. McGregor, W. J. Kropp, and R. N. Gardner of this office on May 9 through June 21, 1985, of activities at Braidwood Nuclear Power Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. M. Wallace at the conclusion of the inspection.
The enclosed copy of our inspecticn report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, cne of your activities appeared to be in noncompliance with NRC requirements, as specified in the enclosed Appendix. A written response is required.
In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the encicsure(s) will be placed in the NRC's Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
s l500010318850711 R
ADOCK 05000456 O
Comonwealth Edison Company 2
'JUL 1 1 E We will gladly discuss any questions you have concerning this inspection.
^
Sincerely, W. S. Little, Director Braidwood Project
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Reports No. 50-456/85023(DRP);
No. 50-457/85024(DRP) cc w/ enclosures:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent i
J. F. Gudac, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DME/ Document Control Desk (RIDS)
Resident Inspector,' RIII Braidwood Resident inspector, Rill Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. 5. Taylor, Quality Assurance Division E. Chan, ELD J. Stevens, NRR
o 1
(
Appendix NOTICE OF VIOLATION Comonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on May 9 through June 21, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions (10 CFR Part 2, Appendix C), the following violation was identified:
10 CFR 50, Appendix B, Criterion XIII, states in part, that measures shall be established to control the storage and preservation of material and equipment to prevent damage or deterioration. The Commonwealth Edison Company Quality Assurance Program contains in Quality Requirement (QR) 2.0 a connitment to Regulatory Guide 1.39, Revision 2.
Regulatory Guide 1.39, Revision 2, endorses the requirements of ANSI N45.2.3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plants". ANSI N45.2.3, Section 3.2.1, requires that scrap and excess materials shall be collected and disposed of in accordance with specified requirenents.
Such excess material shall not be allowed to accumulate and create conditions that will adversely affect quality.
Contrary to the above:
a.
Nails, washers, bolts, screws, wire, metal brackets and a grinding wheel were found in cable trays which had installed cable, b.
The upper cable spreading room was noted as having debris in cable trays and empty aerosol cans which had contained a highly flammable liquid.
I c.
High strength bolting material, (A490 and A325 galvanized bolts, which canrot be reused per the AISC Code) were found laying in various work areas of the plant, not controlled or stored in a material staging area.
This is a Severity Level IV Violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.' Consideration may be given to extending your response time for good cause shown.
~
ner ffM' Datep~
W. 5. t.ittlef Director "
B500010333 850711 Braidwood Project PDR ADOCK 0500pf56 0
O U. S. NUCLEAR REGULATORY COMMISSION g
REGION III Report ho. 50-456/85023(DRP);50-457/85024(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: May 9 through June 21, 1985 Inspectors:
R. D. Schulz L. G. McGregor i
W. J. Kropp R. N. Gardner spl-LD Approved By:
W.
e, Director 57 /'
$6-Braidwood Project
< Dater Inspection Summary Inspection on May 9 through June 21, 1985 (Report No. 50-456/85023(DRP);
50-457/85024(DRP))
Areas Inspected: Routine, unannounced safety inspection of activities with regard to licensee action on previous inspection findings, plant tours, pipe supports, high strength bolting, surveillances, bolted flange connections, piping (small bore) as-built drawings, HVAC installations, hydrostatic tests, corrective action programs, and electrical installations. The inspection consisted of 315 inspector-hours onsite by four NRC inspectors, including 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> onsite during off-shifts.
inspector Of the eleven areas inspected, no items of noncompliance or Results:
deviations were identified in ten areas, one item of noncompliance was identified in the remaining area: failure to control the storage and preservation of material and equipment (paragraph 3).
85<MD010Cb47 850711 PDR ADOCK 05000456 0
DETAILS
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1.
Persons Contacted Comonwealth' Edison Company (CECO)
- M. Wallace, Project Manager
- C. Schroeder, Licensing and Compliance Superintendent
- D. Shanblin, Construction Superintendent
- T. Quaka, Quality Control Supervisor
- W. Vahle, Engineering Manager S. Hunsader, Quality Assurance Supervisor G. Fitzpatrick, Assistant Manager Quality Assurance Corporate E. Netzel, Quality Assurance Supervisor
- L. Kline, Licensing and Compliance Supervisor P. Hoffman, Engineer C. Gray, Project Construction Supervisor D. Skoza, Engineering Supervisor
- J. W. Gieseker, Engineer M. Gorski, Engineer M. Curinka, Engineer K. Miller, Quality Assurance Engineer
- D. Boone, Project Construction Field Engineer
- G. F. Marcus, Project Management
- C. Tomashek, Startup Superintendent
- D. Cecchett, Li:ensing and Compliance
- C. Allen, Project Construction
- E. Wendorf, Project Engineering
- J. Williams, Quality Assurance Inspector
- J. Phelan, Project Engineering
- H. Zimerman, Startup Testing 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 G. James Quality Assurance Engineer R. Hamilton, Welding Supervisor S. Forbes, Quality Assurance Coordinator G. K. Newberg Company
- D. Craven, Project Manager D. Maxwell, Project Engineer
- R. Donica, Quality Assurance Manager P. Struckholz, Engineer L. K. Comstock and Company, Inc. (LKC)
- R. Seltmann, Quality Assurance Manager 2
- l. Dewald, Quality Control Manager L. Seese, Assistant Quality Control Site Manager
- T. Rolan, Project Manager
- J. J. Klena, Project Engineer Pittsburgh Testing Laboratory R. B. McCollough, Quality Control Inspector F. Forest, Site Manager L. White, Quality Control Inspector Sargent and Lundy (S&L)
- K.
Fus, Assistant Over-Field Coordinator
- L. Jacquet, Structural Project Engineer The inspectors also contacted other licensee and contractor personnel, including craftsmen, and technical and engineering staff members.
- Denotes those attending the exit meeting on June 21, 1985.
2.
Licensee Action on Previous Inspection Findings a.
Unresolved items (Closed) 456/84-42-02; 457/84-38-02: Programmatic deficiencies in Instrumentation Retrofit Verification Program. The Retrofit program was revised on March 12, 1985 by Procedure QCP-B32. The revision included the requirement that all unacceptable conditions be documented on a " Field Problem Report" in accordance with procedure PGCP 1.1.
In addition, the issuance of uncontrolled drawings for retrofit inspection was eliminated. The drawings used for inspection purposes are required to be " Retrospection" documents which include the latest design data and are checked by engineering personnel other than those preparing the documents. Processing of " Field Problem Reports" will be the subject of future NRC inspections.
b.
Open items (Closed) 456/84-31-01; 457/84-29-01:
Inadequate procedural controls for temporary pipe supports. On January 24, 1985, the licensee issued Construction Guidelines for Temporary Supports to all site managenent personnel.
Examples of the measures delineated in the January 24 correspondence are stated below:
"It is allowable to use installed and pennanently supported piping for the following purposes with the listed restrictions and precautions.
i a.
Temporary support for other piping up to 2 pipe diameter i
sizes larger for piping greater than 4" diameter. For 4" l
and smaller diameter piping temporary support only same size or smaller size piping.
3 L
O Restrictions / Precautions No concentrated loads are to be located in close proximity to in-line flanges, valves, equipment nozzles, etc. Do not attach temporary supports (i.e. cable, etc.) directly to permanent supports. Temporary supports must be installed every:
7-10 ft. maximum - 2" diameter piping 10-15 ft. maximum - 2 1/2" diameter - 4" diameter piping 15-25 ft, maximum - 6" diameter - 12" diameter piping 30 f t. maximum - 14" diameter piping Temporary supports should be installed so the location dimensions of the supporting pipe is not altered.
Tops of electrical panels and cabinets, instrument panels or racks and rotating equipment should not be used as scaffolding support points."
In the last few months there has been a definite improvement in the use of temporary supports. This area will be subject to future inspections to determine continued compliance with the January 24, correspondence.
(Closed) 456/84-17-04; 457/84-17-04: Flange bolt-up documentation deficiencies. The procedure for implementing a Mechanical Joint Retrofit Program, PGCP-46 was reviewed by the NRC and found to be ambiguous with regard to the visual inspections to be performed. The procedure was subsequently revised on April 22, 1985 and specifically designated the mechanical joints that required retrofit, visual inspections, and documentation reviews. The procedure is being adequately implemented and is identifying for rework those mechanical joints whose condition is in question. Attributes to be checked include cleanliness of joint faces, damage to bolting material, lubri-cation of bolting threads, and proper thread engagement including loose hardware.
3.
Plant Tours The inspector observed work activities in progress, completed work, and plant status during general inspections of the plant. Observation of work included blockwall column modifications, high strength bolting, instrument piping, safety related pipe welding, anchor bolts, structural welds, HVAC welding, and cable trays in the containment and auxiliary buildings.
Particular note was-taken of material identification, nonconforming material identification, and housekeeping. Craft personnel
~
were interviewed in the work areas.
4
Junction box, IJB1611A, was found removed from its mounting.
It was i
determined that this junction box was being controlled by rework No. 1794.
Also, several cables installed in conduit were noted as not being terminated at one end. The inspectors verified through the review of documentation that these cables had not yet been, terminated by the electrical contractor and therefore, did not represent an unauthorized rework. The ' inspectors noted no unauthorized removal of electrical equipment / items during plant tours.
The inspectors noticed a strap for conduit, CIA 1403, missing. This conduit is located in the auxiliary building at approximately location W-15 at the 390' elevation. The conduit was routed from junction box IJB542A to valve 1CV8105. A review of documentation revealed that this conduit was previously inspected and accepted by the electrical contractor on January 16, 1964. The electrical contractor issued Inspection Corrective Action (ICR) 10235 to document this deficiency. As a result of this missing conduit strap the inspector selected several recently inspected conduits to verify proper installation. The results are noted in the electrical section of this report. Since no other missing straps were noted during further tours of the plant and the conduits specifically selected for inspection during this reporting period were found to be satisfactorily installed, the inspector considers the missing strap on conduit CIA 1403 as an isolated case. However, this area will be closely monitored in future inspections.
During the tours of the plant, unsatisfactory housekeeping activities were noted in cable tray cleanliness and the control of high strength bolting material.
The following cable trays, with cable installed, were noted as having debris:
1618F - nails, washers, bolts
~
1318M - nails 11521M - wire 11803J - wire, sharp metal 21753J - screws, wire, broom 21653J - metal brackets 21609J - grinding wheel, screws The upper cable spreading room was noted as having debris in cable trays (e.g., nails) and empty aerosol cans which had contained a highly flamable liquid.
With regard to the control of high strength bolting material which cannot be reused, the following areas had high strength bolts which were not within a material staging area:
, Area V-12, elevation 467' - A490 bolts were noted on the floor l
without being identified as to their material status (i.e. scrap, l
acceptable for installation etc.),
t 1
5
.o Containment Building Unit 1, R-11 elevation 450' - A325 galvanized bolts not identified as to their material status.
Containment Building Unit 2, Polar Crane - A490 bolts not identified as to their material status.
The threads on the A325 and A490 bolts did not appear damaged or upset to prevent use.
The debris in cable trays, empty pressurized cans in the upper cable spreading room, and the lack of control of high strength bolting material in various areas of the plant are considered to be examples of a violation of 10 CFR 50, Appendix B Criterion XIII (456/85023-001; 457/85024-001). The licensee has initiated immediate action to correct these conditions.
The NRC inspector identified two loose bolts on structural tube steel to beam connection MS-47. This deficiency was brought to the attention of the structural contractor G. K. Newberg and subsequent evaluation by the structural contractor revealed that the tube steel was installed with the ends reversed. The end of the tube steel that was required to be bolted to the beam was welded and the end that was required to be welded was bolted to the beam. Newberg documented these deficiencies on nonconformance report number 213-1154 and issued a structural steel installation traveler, number 7619, to correct the installation. Further inspection by the NRC and Newberg identified an Engineering Change Notice, No. 2495, dated March 26, 1982, which required that this connection be reinspected as a result of axial lengthening criteria problems concerning sliding connections. MS-47 is a sliding (bolted) connection. The Engineering Change Notice was open due to forthcoming inspections and planned rework. Therefore, based on the Engineering Change Notice and measures established to correct the MS-47 installation this issue is considered closed.
The NRC inspectors also found a loose bolt on A196B1 beam to embed connection in Containment ho. 1.
The structural contractor was notified.
Subsequently a nonconformance report, No. 1522, was issued to document the loose bolt and a structural steel installation traveler, No. 7448, was issued to replace all the bolts in the connection, including tightening each bolt to the required torque value. Upon removal of the bolts the structural contractor discovered that the beam bolt holes had been torch cut. Torch cutting is not an acceptable practice unless allowed by the design engineer based on engineering analysis. The AISC Code states that holes may be punched, subpunched and reamed, or drilled. The A196B1 beam was installed by Napolean Steel Contractors. This issue will remain unresolved pending both Sargent and Lundy review of the acceptability of this connection, (taking into consideration the loose bolt and the torch cut holes), and licensee evaluation of torch cutting practices by Napoleon Steel and the generic application to other connections (456/85023-002; 457/85024-002).
6
While touring the upper cable spreading rooms, Unit I and Unit 2 the NRC inspectors noticed numerous small holes in HVAC ducts which were being filled with sealant. Subsequent inspection revealed that although the sealant was an approved product adequate procedures had not been established for repairing holes in the HVAC ducts caused by the removal of insulation. The inspector reviewed Pullman Construction Industries, Inc., Procedure, B5.1.F, Revision 3, HVAC Repair / Adjustment Procedure, which stated in Section IV A. Repair:
"A Small Hole - Shall be tack welded or a sheet metal screw surrounded by an approved sealant shall be installed in the hole and on immediate area of interest.
A large Hole - Shall have a bolt, nut and washer installed on both sides of metal with approved sealant between and on imediate area of interest."
Size was not defined for large holes or small holes, nor the maximum size of the nole to be filled with sealant. Therefore, it was difficult to determine the appropriate or adequate repair method.
Furthermore, the number of holes allowed in a duct or sectional area was not defined by Sargent and Lundy drawing M-1261, Revision K, or specified in procedures or instructions.
Or May 30, 1985, the HVAC contractor, Pullman issued a stop work order stating:
"The method of repairing of holes in sheet metal by use of sheet metal screws or bolt, nut, and washer and sealant only, is hereby directed to be stopped."
On May 31, 1985, Pullman issued a memorandum to production personnel stating that holes up to 1/8 inch in diameter may be repaired with sealant.
Pullman is in the process of revising their procedures delineating the acceptable repair processes, including defining hole sizes and corresponding approved repair techniques. This issue will remain unresolved pending procedure revisions and licensee analysis of any recuired reinspections, based on past repair practices in relation to hole size and safety significance (456/85023-003; 457/85-024-003).
The NRC inspectors discovered two loose nuts for an electrical, auxiliary steel, bolted connection. The auxiliary steel is for hanger CC-30 on drawing 20E-1-3547.
It is located in Unit 1 Containment, at column R-1, at elevation 412'.
The connection, per drawings 20E-1-3547A and 20E-0-3393H, is classified as Category I.
The FSAR, Amendment 39, defines this category as including those structures, systems, and components whose safety function is to retain their own integrity and/or not constitute a hazard to other safety Category I structures, systems, and components.
7
Further review by the NRC inspectors disclosed that Category 1, seismic non-safety related, electrical bolted connections are not being inspected by personnel independent of cost and schedule. These connections are being inspected by production personnel responsible for installation activities. Although quality control inspectors are not inspecting bolted connections, they are inspecting Category I, seismic non-safety related welded connections. This policy of not inspecting electrical bolted connections does not appear to be in conformance with the comitments stated in the FSAR, Section 3.2, Amendment 39 or Regulatory Guide 1.29, to which the licensee cocinitted in Amendment 37 of the FSAR. Both Section 3.2 of the FSAR and Regulatory Guide 1.29, Seismic Design Classification, invoke the quality assurance requirements of 10 CFR 50, Appendix B, Criterion X, which requires that an inspection program be established.
This issue is considered unresolved pending licensee evaluation and subsequent NRC review, including the apparent need for an inspection program to assure that any additional deficient bolting is identified.
The safety significance of the loose bolts found on the auxiliary steel and any loose bolts identified in a licensee implemented inspection program will be examined by the NRC in order to detennine whether this item will be ultimately classified as a violation or deviation (456/85023-004;457/85024-004).
The inspector examined Category 1, seismic non-safety related, instrument supports and determined that both welded and bolted connections are being inspected by quality control inspectors.
4 Pipe Supports Seventeen pipe supports were examined for compliance to Sargent and Lundy Specification F/L-2739, drawings, and Phillips Getschow Co. Procedure, QCF-B23, " Installation and Inspection of Component Supports." The supports inspected and their system identification are as follows:
Pipe Supcort System Location ISX03001X Essential Service Water Auxiliary Building - Unit 1 1CV54004X Chemical and Volume Control Auxiliary Building - Unit 1 ISX39032T Essential Service Water Auxiliary Building - Unit 1 1FP11021X Fire Protection Auxiliary Building - Unit 1 ISX36002X Essential Service Water Auxiliary Building - Unit 1 1AB15001R Boric Acid Proc.
Auxiliary Building - Unit 1 1FP11040 Fire Protection Auxiliary Building - Unit 1 1AB15003X Boric Acid Proc.
Auxiliary Building - Unit 1 1AB16001R Boric Acid Proc.
Auxiliary Building - Unit 1 1AB16025R Boric Acid Proc.
Auxiliary Building - Unit 1 1AB11019R Boric Acid Proc.
Auxiliary Building - Unit 1 1CV102007G Chemical and Volume Control Containment - Unit 1 1CV23012S Chemical and Volume Control Containment - Unit 1 1CV102002G Chemical and Volume Control Containment - Unit 1
~
1CC24017R Component Cooling Containment - Unit 1 1CC23018R Component Cooling Containment - Unit 1 ICC23032X Component Cooling Containment - Unit 1 8
The supports were installed in compliance with the specification, drawings, and procedure. Attributes examined included welding, location, dimensional tolerances, material identification, welder identification, and configuration.
In adoition, concrete expansion anchor installations were inspected for compliance with Sargent and Lundy Specification BY/BR-CEA.
Pipe support ISX03001X contained a 3/4" thick carbon steel plate that had numerous laminations. These laminations had been identified by a Phillips Getschow Co. quality control inspector and the nonconfoming condition was documented on nonconformance report No. 1438 dated April 2, 1984 This issue is considered closed based on the documented identification of the condition.
No violations or deviations were identified.
5.
High Strength Bolting Numerous 7/8" diameter, ASTM A-325 high strength, structural steel bolting connections were re-torque tested at the request of the inspector.
The torque testing was witnessed by a Commonwealth Edison representative.
G. K. Newberg Company installed numerous structural steel items by using the turn-of-the-nut method. Napoleon Steel Contractors, Inc. installed numerous structural steel items by using the calibrated torque wrench method. Both methods are acceptable per the AISC specification for structural joints using ASTM A-325 or A-490 Bolts. The installed bolting inspection records were reviewed, and the bolts that were originally tightened by the calibrated torque wrench method were documented as having installation torque values of 530 to 620 ft-lbs. The inspection records represented ten percent of the bolts in a connection, but never less than two. Before re-torque testing the installed bolts, Pittsburgh Testing Laboratory tested three bolts in a tension device and determined a torque-tension relationship for the 7/8" bolt diameter as stated in Sargent and Lundy Specification, F/L-2735, " Structural Steel." The torque-tension relationship was 530 ft-lbs. Therefore, based on the original values of 530 to 620 ft-lbs. documented in the inspec-tion records and the 530 ft-lbs. determined in the torque tension relationship, the NRC inspector expected to find high strength bolting installation torque values in the range of 475 to 620 ft-lbs.
This range is based on 5 to 10% relaxation allowances, as stated in the AISC Structural Code, "Comentary for Structural Joints Using ASTM A-325 or A-490 bolts."
The 7/8" bolts examined and their re-torque values are listed below:
No. of Bolts Tested /
Contractor / Method Connection Re-torque ft-lbs.
of Installation 4
Beam 164B1 to 3/530 Napolean/ Calibrated embed plate 530 Torque Wrench 530 (Total Bolts In Connection - 5) 9 n.
No. of Bolts Tested /
Contractor / Method Connection Re-torque ft-lbs.
of Installation Beam 164B1 to 5/530 Napolean/ Calibrated column 189R13 530 Torque Wrench 530 530 530 (Total Bolts In Connection - 9)
Beam 164B4 to 2/530 Napoleon / Calibrated embed plate 530 Torque Wrench Beam 16EE2 to
- 3/150 Newberg/ Turn-Of-cclumn A152R11 100 The-hut 75 (Total Bolts In Connection - 9)
Beam 132B1 to 7/530 Napoleon / Calibrated embed 530 Torque Wrench 530 530 530 i
530 530 (Total Bolts In Connection - 8)
Bean 133B3 to
- 4/530 Napoleon / Calibrated embed 550 Torque Wrench 350 450 Beam 1341B to 4/530 Napoleon / Calibrated embed 530 Torque Wrench 530 530 Beam 102B1 to 6/530 Napoleon / Calibrated column A101R18 530 Torque Wrench 530 530 530 530
~
Beam 102B2 to
- 4/530 Napoleon / Calibrated column A111C1 530 Torque Wrench 530 i
150 (Total Bolts In Connection - 6) 10
. o o
No. of Bolts Tested /
Contractor / Method Connection Re-torque ft-lbs.
of Installation Beam 128B1 to 3/530 Napoleon / Calibrated column A111C5 530 Torque Wrench 530 (Total Bolts In Connection - 4)
Beam 128E1 to
- 5/530 Napoleon / Calibrated column A113C1 530 Torque Wrench 530 490 430 (Total Bolts In Connection - 8)
Eea-13052 to 2/530 Napoleon / Calibrated embed 530 Torque Wrench (Total Bolts In Connection - 3)
Beam 130E1 to 3/530 Napoleon / Calibrated embed 530 Torque Wrench 530 Bear 102B1 to 3/530 Napoleon / Calibrated column A113C1 530 Torque Wrench 530 Beam 132E1 to
- 6/100 Napoleon / Calibrated embed 370 Torque Wrench 450 550 600 370 (Total Bolts In Connection - 8)
Beam 132B1 to 9/530 Napoleon / Calibrated column A101R18 530 Torque Wrench 530 530 530 530 530 1
530 530 (Total Bolts In Connection - 10) 11 l
l
No. of Bolts Tested /
Contractor / Method Connection / Report No.
Re-torque ft-lbs.
of Installation Blockwall Column /
2/530 Newberg/ Turn-of-2AB-7N 530 The-Nut Blockwall Column /
4/530 Newberg/ Turn-of-2AB-3N 530 The-Nut 530 530 3.6AS4N/SB-2375 page 6
- 3/480 Newberg/ Turn-of-100 The-Nut 160 3.6AE34N/SB-2375 page 4
- 3/230 Newberg/ Turn-of-320 The-Mut 200 4AE31N/55-2375 page 5
- 3/320 Newberg/ Turn-of-180 The-Nut 300 4AE31N/SB-2375 page 3 2/530 Newberg/ Turn-of-530 The-Nut 4.3AB43N/SS-2375 page 2
- 3/220 Newberg/ Turn-of-330 The-Nut 330 55!T7205/SS-2468 page 1
- 3/280 Newberg/ Turn-of-300 The-Nut 320 4AE31h/SB-2375 page 1
- 3/550 Newberg/ Turn-of-1 420 The-Nut 400 SSIT5628/SB-2401 page 1
- 14/100 Newberg/ Turn-of-530 The-Nut 530 530 530 530 530 530 530 530 530 530 530 530 12
ho. of Bolts Tested /
Contractor / Method Connection / Report No.
Re-torque ft-lbs.
of Installation DCT394/SB-2400 page 1
- 4/500 Newberg/ Turn-of-260 The-Nut 250 550 (Total Bolts In Connection - 8)
DCT412/SS-2467 page 1 3/400 Newberg/ Turn-Of-550 The-Nut 550 A 530 ft-lb. torque value recorded by the inspector represented a torque at which the bolts did not turn. Therefore, the bolts were torqued to a higher value than the 530 ft-lbs. The other bolts turned at the value reported. The number of bolts tested equals the number of bolts in each connection unless otherwise indicated. The connections with an asterisk indicate a need for an analysis by the licensee to determine acceptability. The mean value of the readings taken at 530 ft-lbs. or's below for the calibrated torque wrench installation method was 490 ft-lbs.
while the value for the turn-of-the-nut method was 421 ft-lbs.
Additionally, the turn-of-the-nut installation torque values were subject to greater fluctuations.
Licensee determination of the acceptability of the connections re-torque tested and evaluation of the implementation of the turn-of-the-nut installation method, is considered an open item subject to NRC review (456/85023-005; 457/85024-005),
ho violations or deviations were identified.
6.
Surveillances Surveillances performed by the piping contractor were reviewed with regard to identification of deficiencies, corrective action, and overall effect of improving quality performance. The following surveillances were reviewed:
Surveillance No.
Subject Date 263 Indoctrination and Training 09/13/84 327 Stores Request 10/12/84 183 Certification of Inspectors 08/09/84 272 Certification of N.D.E. Personnel 09/14/84 325 Large Bore Piping 10/10/84 460 Equipment 12/26/84 003 Bolted Connections 04/04/84 i
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i.
The NRC found the surveillances to be effective. Although surveillances by definition are limited in scope, they identified quality related deficiencies and initiated corrective action to prevent repetition, including identifying deficient procedures which were subsequently revised. The surveillance findings were also trended and graphed forming a basis for increasing surveillances or audits in a specific area.
No violations or deviations were identified.
7.
Bolted Flance Connections Six bolted flange connections, installed by the piping contractor, were examined. The inspector checked for correct component identification, flange location as detailed on the approved drawing, proper centering of the gasket, and that the joint was properly tightened. Documentation reviews included the piping quality control inspection records. Quality control hcid points had been established and witnessed for the following installation check points:
Component Identification Internal Cleanliness Joint Faces Clean Bolting Material Male / Female Inspected For Damage Correct Bolting / Gasket Material Used and Recorded Threads Lubricated and Lube Type Entered Flange Surface Parallel Measurement Recorded Prior to Bolt-Up Gasket Properly Centered Joint Prcperly Tightened The flanges were furnished in accordance with the design specification for size, type, and rating. Two of the flanges were bolted to valves and the NV-1 Code Data Reports were found to comply with the design specification. Certifications for the flange nuts and bolts met the requirements of the ASME Boiler and Pressure Vessel Code, Section 11 and Section III.
The flanges which the NRC inspector examined are detailed below:
Joint Identification System / Unit I Size AB-26-F-1-1 Boric Acid Proc.
3" 150 lb.
AF-13-F-1-1 Auxiliary Feedwater 4" 900 lb.
AB-25-F-1 Boric Acid Proc.
4" 150 lb.
AF-13F-3-1 Auxiliary Feedwater 4" 900 lb.
AF-13F-2-1 Auxiliary Feedwater 4" 900 lb.
SX-6F-15 Essential Service Water 30" 150 lb.
The inspector discovered that the 30" Essential Service Water flange was pot physically identified as SX-6F-15 on the flange.
Further inspection revealed that the Essential Service Water flanges had been marked in the early years of construction with different identification numbers than are currently documented on the drawings. Furthermore, original installation inspection records for the Essential Service Water 14
flange, SX-6F-15, could not be traced to SX-6F-15, due to the different identification numbers which did not appear on obsolete drawings. Subse-ouent NRC documentation reviews disclosed that this lack of traceability for flange SX-6F-15 had been identified by the piping contractor under the scope of the Mechanical Joint Retrofit program, PGCP-46 Revision 0.
The applicable installation inspection hold points would be reverified under the scope of PGCP-46.
Due to the adequacy of the Mechanical Joint Retrofit Program, which identified this deficiency for corrective action, this issue is considered closed.
No violations or deviations were identified.
8.
Pipina (Small Bore) As-Euilt Drawinas Small bore is defined as less than or equal to 2" diameter piping.
Six installed small bore piping runs were examined for conformance to the as-built drawing. The NRC inspectors' walkdown included the following check points:
dimensional conformance configuration location (elevation) material identification (heat traceability) welder identification (physical marking) l The piping runs are detailed on the following drawings:
Unit 2 - M-2544A, Sheet 131 - Essential Service Water Unit 1 - M-2552C, Sheet 20 - Steam Generator Blowdown Unit 1 - M-2552C, Sheet 12 - Steam Generator Blowdown Unit 1 - M-2552C, Sheet 21 - Steam Generator Blowdown Unit 1 - M-2536C, Sheet 8 - Main Steam Unit 1 - M-2536C, Sheet 6 - Main Steam Drawing M-2552C, Sheet 12, was inspected from penetration P-90 to the missile barrier wall at 1RB-207.
The associated documentation for the small bore piping lines was examined and found to be in compliance with the ASME Boiler and Pressure Vessel Code,Section II, III, IX, and regulatory requirements. Records checked included:
welding procedure qualifications welder qualifications certified material test reports (components and weld rod) fit-up and final visual inspection documentation s stores' requests (storage withdrawal forms)
No violations or deviations were identified other than those that had been previously identified by the piping contractor.
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9.
HVAC Installations Two Unit I safety related HVAC duct runs were examined for confomance to fabrication sketches and installation drawing M-1285, Revision AA. The ducts were checked for correct identification, location, damage, configuration., adequate joint sealant, joint tightness, dimensional confomanae, and general weld quality. The inspection included one run consisting of ducts 3727, 3728, 3729, and 3730 and another run consisting of ducts 3758, 3760, 3761, and 3762. Duct number 3762 was found to be damaged (two 1/16 inch diameter holes) and had some welding deficiencies; however, these deficiencies had been identified by BCAP inspectors. The BCAP findings were identified on Comonwealth Edison nonconformance report No. 6071. Based on the documentation of the defi-ciencies on nonconfomance report No. 6071, this issue is considered closed.
No violations or deviations were iden'tified.
- 10. Hydrostatic Tests The hydroctatic test program of the piping contractor was reviewed, including procedure PGCP-39, " Pressure Testing of ASME and Safety Related Piping." The inspector also reviewed three hydrostatic test report packages listed below:
System Applicatle Drawines Date of Test Safety Injection M-2061 Sheet 1 03/19/85 Chilled Water M-118 Sheet 1 03/28/85 M-82 Sheet 15 M-82 Sheet 14 Component Cooling M-66 Sheet 2 07/13/84 Water M-66 Sheet 4 The' hydrostatic test program and test report packages met the requirements of the ASME Boiler and Pressure Vessel Code,Section III, however, two concerns were identified.
a.
Drawings or weld maps identifying the location of all the welds were not being provided to the quality control inspectors. The ASME Code,Section III, requires that following the application of the hydrostatic test pressure for a minimum of ten minutes, all joints shall be examined for leakage. The inspector posed the following questions to the licensee:
"If weld maps or drawings identifying the welds are not being provided to the quality control inspectors, who are supposed to sinspect' all the welds for leakage, how are they sure they have inspected all the welds? Since documentation identifying the welds is not being provided, is it reasonable to assume that all the in-service inspection stainless welds, which can be difficult to detect due to surface finish, have been inspected by the quality control inspectors?"
16
The licensee stated that the hydrostatic testing perfomed included a detailed hand over hand check of each foot of pipe, and this hand over hand check assures that all the welds are inspected, including the in-service inspection stainless welds. The inspector met with five hydrostatic test quality control inspectors who stated that they preferred to have weld maps which identified the location of all the welds. However, they also stated that during the hydrostatic testing they were performing, detailed hand over hand checks and believed that all the welds had been inspected.
Furthermore, the documentation test packages did not specifically state that all the welds were inspected, although Procedure PGCP-39 required all the welds to be examined. The adequacy of the past hydrostatic tests, completed without weld maps, will be further evaluated by the NRC and is considered an unresolved issue (456/85023-006; 457/85024-006).
b.
The piping contractor had not established measures to assure that piping lines would be hydrostatically retested after removal of items within the line. Numerous items are being removed due to documenta-tion deficiencies, such as material which is nonconforming due to lack of traceability. At the end of the inspection period the licen-see and piping contractor were establishing measures to assure that lines, which have had or will have items removed, are subsequently retested. Pending adecuate implementation and NRC review, this issue will remain open (456/85023-007; 457/85024-007).
Ne violations or deviations were identified.
- 11. Corrective Action Programs The corrective action program for Avoid Verbal Orders (AV0), as defined in the disposition to L. K. Comstock (LKC) Nonconformance Report (NCR) number 1996, was evaluated for effective implementation. This NCR identified the use of AV0s to remove or reinstall electrical hangers by LKC craf t personnel without issuing a Hanger Installation Report.
Therefore, required inspections by LKC quality control personnel might not have been performed.
NCR 1996 was issued March 30, 1984 and concurrence by CECO of the disposition occurred January 4, 1985. During this review, the corrective action was in the early stages of implementation. The inspectors determined that the AV0s previously issued were sequentially numbered and logged by accounting personnel. The AV0s reviewed clearly identified the work to be perfomed by the LKC craf t.
One problem was noted by the inspectors concerning " voided" AV0s. During discussions with the LKC personnel implementing the AVO corrective action, it was revealed that if an AVO was noted as " voided" in the log, the AVO was not processed per the disposition of NCR 1996. The inspectors selected two " voided" AV0s, No. 9 and No. 10, to determine if the work described on these AV0s was completed by LKC craf t.
Inspections of the items identified on these AV0s revealed that the work described had been perfbmed. The inspectors discussed, with licensee personnel, the need for evaluating " voided" AV0s for possible impact on installed equipment rather than assuming the work was never performed. The licensee committed to evaluate " voided" AV0s under the corrective action program described i
in CECO NCR 1996. This corrective action will be further evaluated as implementation progresses.
17
The LKC Drawing Review Program (DRP) was reviewed to determine if there were any obvious programatic problems that would affect the program's implementation. The purpose of this program, as stated in the program document is "To demonstrate that drawing revisions, made prior to initiating the current Engineering Drawing Review (May 1, 1984) and Rework Procedure (April 1, 1954), and the cessation of writing AV0s, have been proper 1p implemented / corrected in the field and that QC inspections are current". Based on discussions with the licensee, the DRP was written due to a NRC open. item (456/84-42-10; 457/84-38-10). This open item identified that there did not appear to be an adequate system established to assure reinstallation. The licensee stated that the DRP will determine if in fact there was an adequate system for controlling rework which was generated by revisions to electrical drawings.
If the DRP indicates the rework system was ineffective, the licensee stated a corrective action document will be issued (i.e. NCR). No programatic problems were identified.
The inspectors reviewed the corrective action program pertaining to the inspection /walkdown by LKC of installed safety related cable pan hangers.
This corrective action program is documented as a supplement to CECO NCRs 708 and 709. This supplement, Sargent and Lundy's project instructions PI-0B-77, Revision 0, " Cable Tray Separation Walkdown Procedure", and PI-BB-85, Revision 0, " Instructions to Perform Survey of Safety Related Cable Tray Supports for Shop Weld Presence and for Hanger Configuration" were reviewed and no apparent programatic problems were identified. The inspectors verified implementetions of this corrective action program by inspecting the following cable pan hangers:
20E-1-3043-H002 20E-1-3221-H0013 20E-1-3221-H0014 20E-1-3221-H0015 20E-1-3251-H063 The drawings and inspection records associated with these hangers were reviewed and compared with the results of the inspections conducted by the NRC inspectors. As a result of this comparison, a dimension for hanger 20E-1-3043-H002 and a dimension for hanger 20E-1-3251-H063 were noted as being different than the dimensions recorded by LKC Quality control. This was brought to the attention of the licensee who took imediate action. The dimensional discrepancy did not have a safety significance.
No violations or deviations were identified.
- 12. Electrical Installations Three conduits recently inspected and accepted by L. K. Comstock quality control were inspected to verify conformance with established requirements. The conduits inspected and the applicable drawings were:
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Conduit Drawings j
C0A8654 20E-0-3386 CT1
'20E-0-3386 20E-0-3386 C03 20E-0-3386A CIA 1752 20E-1-3317 20E-1-3317A 20E-1-3317 D02 20E-1-3317 CT1 20E-1-3317 C04 20E-1-3317 C010 C1R54J0 20E-1-3591 Sht. 2 20E-1-3554A 20E-1-3554 CT2 20E-1-3554 C06 The conduits were inspected for correct size, number of supports, support location and the distance between supports. No problems were identified.
The inspector selected four electrical panels and one motor control center (MCC) to determine if the installations were in accordance with design requirerents. This was accomplished by reviewing installation records and inspecting the installed equipment. The equipment inspected and the documents reviewed were:
i S&L Eauipment Records Design Documents IP5044J (Containment Welding Installation 20E-0-3334 1F5043J Hydrogen Record; CEA In-Process Detail: 001 Monitor Inspection Checklist; ECN 24856 Panels)
Installation Report; Inspection Checklist; Weld Inspection Checklist; Component Fabrication Installation Record IPSO 47J (Containment Welding Installation 20E-0334 Hydrogen Record; CEA In-Process Detail: ECh Monitor)
Inspection Checklist; 24515 Weld Inspection Checklist; Fabrication Installation Record IVE01J (HVAC Control Equipment Installation PL-3 Panel)
Record; Concrete Expansion Detail:10-6 Anchor Inspection Record FCR L-8486 1AP21E (MCC)
Inspection Records for the Disposition Re-torquing of Mounting Bolts to CECO i
NCR #596 19
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The review of the above records revealed no deficiencies. The inspection of this equipment to verify conformance to the S&L drawings revealed that panel IVE01J was not installed in accordance with FCR L-8486. However, further investigation revealed that this panel was selected for a BCAP inspection and the discrepancies associated with the installation were already identified as a BCAP observation. No other problems were noted.
No violations or deviations were identified.
- 13. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 5 and 10, 14 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 3 and 10. Unresolved items identified in this report will be subject to detailed NRC review.
15.
Exit Interview The inspector met with licensee and contractor representatives denoted in Paragraph I during a.id at the conclusion of the inspection on June 21, 1985. 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.
20
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NOV 2 7 G85 Docket No. 50-45'6 Docket No. 50-457 Commonwealth Edison Company i
ATTN: Mr. Cordell Reed l
Vice President Post Office Box 767 Chic &go, IL 60690 Gentlemen:
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This refers to the routine safety inspection conducted by Messrs. R. D. Schulz and W. J. Kropp of this office on September 9 through October 18, 1985, of activities at the Braidwood Station, Units 1 and 2, authorized by NRC l
Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. M. Wallace at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during -
the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
1 During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Appendix. A written response is required.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure (s) will be placed in the NRC's Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as i
required by the Paperwork Reduction Act of 1980, PL 96-511.
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l We will gladly discuss any questions you have concerning this inspection.
l Sincerely, W. S. Little, Director i
Braidwood Project
Enclosures:
1.
2.
Inspection Reports No. 50-456/85038(DRP);
No. 50-457/85037(DRP) cc w/ enclosures:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager j
D. Shamblin, Construction Superintendent I
E. E. Fitzpatrick, Station Superintendent i
l C. W. Schroeder, Licensing and Compliance Superintendent DCS/RSB(RIDS) l Licensing Fee Management Branch Resident Inspector, RIII l
Braidwood t
Resident Inspector, RIII Byron i
Phyllis Dunton, Attorney General's Office, Environmental j.'
Control Division j
D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division il H. S. Taylor, Quality Assurance Division E. Chan, ELD I
J. Stevens NRR l
The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB l
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Commonwealth Edison Crapany Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on September 9 through October 18, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violation consisting of two examples was identified:
10 CFR 50, Appendix B, Criterion V, states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures or drawings.
Commonwealth Edison's Quality Assurance Program Manual, Quality Procedure (QP) 15-2, Revision 6 " Reporting Significant Deficiencies That Occur During Construction and Tests", Section 5.1 states in part that immediately upon observance or discovery of a potential significant deficiency the individual shall notify the Project Construction Superintendent or Cognizant Engineering Project Manager.
Section 5.15 further states in part that an evaluation shall be conducted of the factors involving each identified outside organization reported deficiency to determine if it constitutes a reportable deficiency. _
The evaluation must be documented by the cognizant Engineer.
Pullman Sheet Metal Works Procedure B16.2.F, Revision 0, January 18, 1985,
" Corrective Action," states in part in Section 6.3.B. " CAR Closure," that the Quality Engineer shal.1 assure the corrective action identified has in fact been implemented and is effective.
Contrary to the above:
a.
Pullman Corrective Action Requests (CARS) 002 and 005 were closed by Pullman Quality Assurance prior to verifying that all the corrective actions stated in CARS 002 and 005 were implemented and effective.
b.
Pullman Procedure B16.1.F, "Nonconformances," Revision 7, June 17, 1985, does not require deficiencies identified as potentially reportable to be identified to the licensee.
This is a Severity Level V violation (Supplement II).
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i Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
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W. 5.fLittle, Director Braidwood Project
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6 U.S. NUCLEAR REGULATORY C0tEISSION REGION III Reports No. 50-456/85038(DRP);50-457/85037(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: September 9 through October 18, 1985 Inspector:
R. D. Schulz W. J. Kropp
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Approved By:
W.
. Little, Director
- /J24 Braidwood Project Date '
Inspection Sumary Inspection on September 9 through October 18, 1985 (Reports No. 50-456/85038(DRP); 50-457/85037(ORP))
Areas Inspected:
Routine safety inspection of licensee actions on previously identified items, plant tours, instrumentation, essential service water piping, piping attachments, bolted flange connections, cable routing, cable pan / cable pan supports, piping supports, electrical components, and nonconformance reports / corrective action reports. The inspection involved a total of 267 inspector-hours onsite by two NRC inspectors including 32 inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, no violations were identified in ten areas, one violation with two examples was identified in the remaining area (failure to assure that HVAC corrective actions were effectively implemented and failure by the HVAC contractor to transmit n.onconformance reports to the licensee for 10 CFR 50.55(e) review (paragraph 12)).
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Details 1.
Persons Contacted Comonwealth Edison Company (Ceco) i
- G. Fitzpatrick, Assistant Manager Quality Assurance Corporate i
- M. Wallace, Project Manager l
- C. Schroeder Licensing and Compliance Superintendent
- D. Shamblin, Construction Superintendent
- T. Quaka, Quality Control Supervisor
- W. Vahle, Engineering Manager S. Hunsader, Quality Assurance Supervisor.
E. Netzel, Quality Assurance Supervisor
- L. Kline, Licensing and Compliance Supervisor
- D. Skoza, Engineering Supervisor M. Gorski, Engineer D. Boone, Project Construction Field Engineer
- E. Wendorf, Project Engineering
- J. Dierbeck, Project Construction Field Engineer l
Phillips Getschow Company (PGCo) l T. O'Connor, Site Manager K. Kranz, Quality Assurance Site Manager J. Stewart, Project Engineer M. Galloway, Assistant Project Engineer R. Hamilton, Welding Supervisor L. Butler, Quality Control Supervisor G. K. Newberg Company (GKN)
R. Donica, Quality Assurance Manager L. K. Comstock and Company, Inc. (LKC)
T. Zych, Lead Engineer D. Bradfute, Assistant Project Engineer J. Gremchuk, Field Engineer L. Welch, Field Engineer i
F. Rolan, Welding Inspector i
L. Seese, Assistant Quality Control Site Manager Pullman Sheet Metal Works, INc. (PSM)
P. Weiker, Engineering Manager D. Butzen, Office Engineer R. Waterfield, Quality Engineer l
C.' Holt, Quality Assurance Supervisor e
The inspectors also contacted other licensee and contractor personnel,
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including craftsmen.and engineering' staff, members.
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- Denotes those. attending the exit meeting'on Oc'tober.17, 1985.
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Licensee Action on Previously Identified Ite.ns 4
Although all of the corrective actions havs not been completed for the j
following previously issued violations, t'.ie inspector reviewed the issues and found that the actions completed and planned by the licensee appear to be adequate to resolve the findings.
The licensee's corrective actions are delineated below:
.Ij Violations (0 pen) 456/82-05-01; 457/82-05-01:
Inadequate corrective action with regard to bolting of the steam gene ator supports. The licensee will remove and either replace or reinstall all the cap screws holding the vertical supports to the steam generators.
The NRC will inspect the cap i;
screws and examine the documentaticn which shall include cap screw
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traceability, length, final torque values, and the number of Heli Coil inserts.
1 (0 pen) 456/83-07-02; 457/83-07-02:
Bolting deficiencies for mechanical equipment.
A new Millwright Supervisor was assigned to the Braidwood Site in July 1984.
The supervisor has extensive experience in the nuclear industry and implemented an Equipment Inspection Retro-fit Program which includes the reinspection of mechanical equipment bolting.
Both thread engagement and torque are being examined.
Rework is being completed as_
required.
For example, the 1RY01S pressurizer bolts were found to be not properly torqued and are presently being torqued to the correct values.
The Retro-fit Program is controlled by QCP-B22, Equipment Installation Procedure, Revision 8.
(0 pen) 456/83-09-07B; 457/83-09-07B:
Corrective action was not adequate concerning the acceptance of welds for which the welder was unknown and Correction Notices were not analyzed for significance.
There were originally 53 items identified as having no welder 1
identification.
Further document reviews identified welders for 29 of the 2
items and the remaining 24 items were dispositioned for removal.
Subsequent document reviews by Pullman Sheet Metal Works, Inc. identified 349 additional items for which no welder identification has yet been found, l1 either by a welder stamp next to the weld or by quality assurance documenta-l tion. These welds have been properly identified by Pullman and document
'i searches are still being performed in an effort to determine the welder.
These 349 items are being evaluated by the licensee.
A Region III specialist will examine and disposition all of the items having inadequate welder identification.
All of the Correction Notices were analyzed by Pullman for significance.
Welding was determined to have a 38% deficiency rate in November 1983.
In the period, February through July 1985, this rate had declined to 12%.
i This appears to be due to additional welder training, the increase in 1
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improved traveler control system which designates the welding procedure to be employed. Trending of Correction Notices is now done on a monthly and quarterly basis in order to determine the significance of deficient i
j conditions.
]3 (0 pen)456/85007-02;457/85007-02:
Installation of the support plates for the containment spray pumps was not in accordance with drawing requirements.
Nonconformance Report No. 3963 was issued to document the deficient condition. The installations are being reworked to conform with drawing requirements as specified in the nonconformance report.
I No violations or deviations were identified.
3.
Plant Tours k
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, structural welding, anchor bolts, HVAC welding, pipe erection, safety-related pipe welding including fire protection and reactor coolant system welds, cable supports, cable trays, junctior boxes, mechanical equipment, and instrument piping. Particular note was taken of material identification, nonconforming material identification, and housekeeping. Craft personnel were interviewed in.the work areas.
The inspector identified a bent or bowed pipe connected to the auxiliary feedwater pump. This was brought to the attention of the Phillips Getschow Company and discrepancy report number D0254 was imediately issued by Phillips Getschow.
It appeared that this pipe was damaged during construc-tion field activities. Based on the identification of this item in the discrepancy report, for disposition by engineering personnel, this issue is considered closed.
During one tour, the inspector noticed that the scaffolding adjacent to the steam generators in Unit I contained several flanges, nuts, bolts, and short pieces of pipe. The licensee was notified of the existing condition and took the necessary corrective actions. The material was determined to be nonsafety-related and was taken to the appropriate material storage 1'
areas.
While inspecting the safety injection pump rooms, the inspector identified that the room for pump ISIO1PA contained bags of sand, soda-pop cans, nuts and bolts, angle iron, tube steel, pieces of concrete, and fittings. The pump had been turned over to the licensee from the contractor for preoperational testing, and was undergoing a flushing process. The licensee was notified of this condition and imediately cleaned up the area. The 1
inspector noted no adverse hardware affect, as the sand did not enter the i
pump suction or discharge openings. The material was returned to designated l
material storage areas. The licensee was responsive to NRC concerns during the inspection period and took prompt corrective action.
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l The inspector witnessed the testing associated with pour 7A X 24. The i
pour utilized grout instead of concrete for a wall in the Auxiliary Building at Elevation 475', Columns S-17 through S-19.
The grout was pumped to the location of the pour and the samples for the testing were 1
obtained from the pump discharge. The grout was tested for slump, air i
content, and temperature in accordance with Pittsburgh Testing Laboratory
.i Procedure QC-FSTC-1, Revision 16, dated July 29, 1985.
Six cylinders (Set No. 4252) were also prepared for future strength testing.
The results of the testing were:
- I Slump 6 1/4" Air content 5.0%
Temperature 71*
'z No violations or deviations were identified.
2 4.
Instrumentation Instrumentation lines detailed on the following drawings were examined:
IFT-657 sheet 2, Component Cooling Flow Transmitter IFT-660 sheet 2, Component Cooling Flow Transmitter 1PT-AF057 sheet 1, Auxiliary Feedwater Pressure Transmitter 1PSL-AF055 sheet 1, Auxiliary Feedwater Pressure Switch Installation and inspection documentation were also reviewed.
Attributes checked included:
separation criteria line properly pitched installation clearance
]
separation color code identification drawing conformance e
welderandjointidentification J
?
In addition, field change requests associated with the installation were y
reviewed for accuracy and completeness.
,J The installations were in accordance with Procedure PGCP-30, Revision 12, cq
" Installation Of ASME Section III and Safety Related Instrument and l'
Instrument Lines."
The procurement of instrumentation identified in Sargent & Lundy Specification L-2906, " Instrumentation Installation Work", was reviewed to verify compliance with applicable codes and standards. The mechanical contractor, Phillips Getschow, was responsible for preparing purchase requisitions for all instruments which were designated in the Instrument Index and. detailed in Specification L-2906.
The licensee issued purchase i
orders for the instruments based on the purchase requisitions from Phillips Getschow. The inspector reviewed procurement documents such as Purchase Orders (PO), Material Receiving Reports (MRR), Certificates of Conformance,
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and other supporting documents.
This review was to determine if the appropriate instruments were purchased and received. The instruments selected and the documentation reviewed were:
Instrument Identification Type Number Vendor Model No. Documentation Flow Transmitter 1FT-C5013 Rosemount 1153DB6 P0 26250.
MRR 12306.
Instrument Data Sheet FF65.
Rosemount Quality Certification of Compliance.
l Flow Transmitter 1FT-CS004 "SAME AS 1FT-C5013" Flow Transmitter 1FT-AF016 Rosemount 1153088 P0 262050.
MRR 12306.
Instrument Data Sheet a FT-76.
Rosemount Quality Certification of Compliance.
Pressure Switch IPSL-AF051 United 552 P0 262089.
Lw Electric Requisition BR 52765.
Instrument Data Sheet PS-180.
Phillips Getschow Receiving Inspection Report, dated May 27, 1982.
I Pressure Switch IPSL-AF055 "SAME AS 1PSL-AF051" j
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Transmitter MRR 16885.
. Certificate l
of Conformance (Stallings &
Co.).
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Certificate of j
Conformance 1
(ITT Barton).
ij Pressure 1PT-0934 Barton MRR 11315.
Transmitter Westinghouse
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Quality ajj Release 1
N69246.
The Purchase Order for instruments IFT-CS013,1FT-C5004, and 1FT-AF016 referenced applicable technical requirements such as IEEE 323, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations" and IEEE 344, "IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations."
The purchase order was classified as safety-related and these instrumenfs were received with a Rosemount Quality Certification of Compliance.
This certificate referenced a Rosemount Qualification Report, No. 108025, as a basis for nuclear application. The purchase order for instrument IPT-PC004 was classified as " safety related - commercial grade." The pressure transmitter for instrument IPT-0934 was procured by the Nuclear Steam Supply System (NSSS) vendor, Westinghouse, and was received on site with a Quality Release, N69246.
The Purchase Order for pressure switches IPSL-AF051 and IPSL-AF055 was classified as nonsafety-related.
There were no technical or quality requirements identified in the Purchase Order.
The Sargent & Lundy Instrument Data Index and the Instrument Data Sheet, PS-180, identified these instruments as Class 1E and Seismic Category I.
The inspector did verify that documentation existed which qualified the United Electric pressure switch, Model 552, as qualified for nuclear applications. This documentation consisted of a Sargent & Lundy Equipment Qualification Volume, EQ-BB115, "EQ (mild) of United Electric Pressure Switches", Revision 00, 1
dated February 8, 1985.
Since these switches were procured as i
nonsafety-related, the inspector has a concern that these pressure switches
- I might not have been properly receipt inspected, stored, installed, calibrated, or otheryise controlled.
The licensee has committed to evaluate the procurement and the subsequent activities associated with pressure switches IPSL-AF051 and 1PSL-AF055 to determine their acceptability. The licensee also stated that the procurement of safety
'I.
related balance of plant instruments will be evaluated by a surveillance j
conducted by their QA organization. This matter is considered an e
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unresolved item pending a review of the licensee's evaluations of pressure switches 1PSL-AF051 and 1PSL-AF055 and the completion of the QA surveillance (456/85038-01; 457/85037-01).
I J
No violations or deviations were identified.
l 5.
Essential Service Water Piping 1
Documentation for 48" outside diameter Essential Service Water piping, which is buried underground, was reviewed for drawings ESW-2 and ESW-12.
t J
j Documents examined included:
'e welding inspection reports weld rod test reports welder qualification records magnetic particle test reports NPP-1 Code Data Reports t
'l traceability of pipe and welding consumables i
The records were found to be in compliance with the ASME Boiler and i
Pressure Vessel Code, Sections II, III, and IX.
The inspector reviewed Nonconformance Report No. 5337, which was written by the Phillips Getschow Company on August 12, 1985. The nonconformance identified Essential Service Water spools with base metal weld repairs whose repair cavity exceeded 10% of the wall thickness, that were not subsequently radiographed as required by ASME Section III.
This issue will remain open, pending licensee disposition and subsequent NRC review by Region III specialists.
(456/85038-02;457/85037-02)
No violations or deviations were identified.
6.
Piping Attachments Twelve lugs welded to three reactor coolant piping spools, and two stanchions welded to a piping feedwater spool were examined for weld quality, material identification, welder stamp identification, and dimensional conformance.
The lugs and stanchions are detailed below:
four lugs on 4" 0.D. Spool, RC-9-2 four lugs on 3" 0.D. Spool, RC-9-4 four lugs on 4" 0.D. Spool, RC-2-4 two stanchions on 6" 0.D. Spool, FW-38-5.
L Documentation reviews disclosed that the piping NPP-1 Code Data Reports i
met the requirements of the ASME Boiler and Pressure Vessel Code and I
design spe~cification 1540BB.
The weld rod certifications were found to i
be in compliance with ASME Section II, Part C and Section IH, NB-2000.
j The lugs and stanchions were manufactured from material which met the
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requirements of ASME Section II, Part A and Section III, NB-2000. The lugs were also in accordance with ASME Section III, NB-4435.
Nondestructive examination reports were reviewed and its was detemined l
that the requirements of ASME,Section III, NB-5000 were satisfied. The welding process was controlled through welding inspection checklists.
i While reviewing the Code Data Report for spool FW-38-5, the inspector i
also randomly selected the Code Data Report and welding material
}
certifications for spool FW-13-7. The spool is a 16" 0.D. spool and has i
an.844" wall.
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Specification F/L-2739 stipulates the special requirement that Charpy Impact Tests must be performed on ASME Section III, Class NC feedwater j
piping in accordance with ASME Section III, NB-2300. The inspector found that the Charpy Impact Tests had been performed for both the spool and welding consumables.
No violations or deviations were identified.
1 7.
Bolted Flange Connections I
Piping Procedure PGCP-15, Rev. 5, " Bolted Connections," was reviewed; I
the controlling document for bolting flanges together is a Mechanical i
JointChecklist(MJC). The MJC specifies the following attributes for_the craftsmen:
approved lubricant, Fel-Pro-N-5000 assembly sequence torque values material identification
~
drawing identification
[
joint identification The MJC also establishes quality control hold points for the following aspects:
component identification i
internal cleanliness J
joint faces clean 1
bolting material male / female inspected for damage
~
correct bolting / gasket material used and recorded threads lubricated and lube type entered flange surface parallel measurement recorded prior to bolt-up gasket properly centered l
j joint properly tightened The MJC's for two Safety Injection flange connections were examined for 1
compliance with procedure, PGCP-15, Rev. 5 and design table 140BB. The t
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i MJC's were in compliance with the procedure and design table.
The 6" 150 lb. raised face, weld neck flanges were to be connected to a Unit 2 safety injection pump and were designated SI-23-F1 and SI-23-F2. The work had not j
been performed but the quality control hold points had been properly established and the correct material had been drawn.
j Subsequently, the MJC's for two Chemical and Volume Control flange connections were examined.
The connections had been completed and the quality control hold points had been appropriately signed off.
The 4" i
l 150 lb. raised face, weld neck flanges were designated as connections CV-3-F3 and CV-3-F-4-1.
The connections were examined by the inspector and the flanges were installed in accordance with the checklist. The 1
checklist met the requirements of Procedure PGCP-15 and design table 140B8. The flanges, nuts, and bolts were traceable and met the i
requirements of design specification F/L-2739.
Certifications were j
reviewed for the flanges and bolting material.
- ].
The inspector did have a question with regard to Procedure PGCP-15, Paragraph 5.1.2.2.
The Paragraph states:
j "For mechanical joints (including valve bonnets) in hip pressure steam i
piping and high pressure feedwater piping using the 600 lb., 900 lb.,
1500 lb., or 2500 lb., pressure design standard in sizes 2 1/2 inch and larger, a predetermined and measured torque calculated to produce an l
initial stress of approximately 45,000 pounds per square inch in the l
fastener shall be specified on the M.J.C."
(
The inspector requested that the licensee evaluate their justification for not including the high pressure emergency core cooling systems in their requirements for predetermined torque that is to be specified on the MJC.
This is considered an open item pending licensee review (456/85038-03; 457/85037-03).
1 No violations or deviations were identified.
i 8.
Cable Routing j
The following L. K. Comstock procedures were reviewed:
4.3.8, Cable Installation, Revision E 4.8.8, Cable Installation Inspection, Revision C.
Five Unit 1 installed cables were inspected in the upper cable spreading room for compliance to IEEE-384, the cable pull cards, and Procedure 4.3.8, Cable Installation.
Subsequently, the L. K. Comstock quality control inspection reports were reviewed for compliance to Procedure 4.8.8 and the I
actual cable installations.
Detailed below are the cables which were inspected:
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I Cable No.
From Raceway To Riser / Raceway M
10C117 12025C 1R482 12-C-14 i
IVX004 12015C 1R480 12/C-14 j
IVV092 12028C
/11909C 2/C-14 j
10126 12025C 1R482 12/C-14 IVC 017 12025C 1R480 12/C-14 The inspectors determined that Cable No. IVV092 was not routed thru raceway 12026C as required by the cable pull card.
The quality control inspector accepted the pull as being correct on November 20, 1981.
The i
licensee was notified and the electrical quality assurance supervisor stated that a nonconformance report would be written and that additional cables which were inspected by the same quality control inspector would be reinspected for compliance with the pull cards. The licensee's review concluded that the incorrect routing was not design significant.
Pending the reinspection effort and NRC evaluation, this issue will remain unresolved (456/85038-04).
The licensee stated that they did not believe the incorrect routing was design significant because the cable passed through another "CIE" raceway, the same category as raceway 12026C, and then returned to the correct routing.
NRC inspections of the cables included the following attributes:
raceway free of debris raceway free of sharp edges 4
raceway free of damage segregation codes correspond e
raceway corresponds to routing shown on pull card cable routed per pull card cable correct size and type cable free of damage e
cable correctly identified 1
cables are properly supported No violations or deviations were identified.
9.
Cable Pan / Cable Pan Supports The inspector performed field inspections on 13 Unit I randomly selected cable trays and their structural supports in order to determine if they were installed in accordance with the design drawings. The cables, i
associated supports, and applicable Sargent & Lundy design drawings are detailed below:
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o Cable Trays Supports Drawings 11516M H118, H126 0-3671, 1-3061H i
11521M H099, H170 0-3671, 1-3061H 11584K H102, H103, H104, H141 0-3671, 1-3061H 11585K H105, H106 0-3671, 1-3061H 11587KJ H042 0-3672, 1-3061H 11591J H038. H039, H040, H041 0-3672, 0-3061H 11592J H048 0-3672, 0-3061H f
11593J H034, H035 0-3672, 0-3061H l
11597J H049 0-3672, 0-3061H 11600J H018 0-3672, 0-3061H 11601J N016. H017 0-3672, 0-3061H 11682J H033 0-3672, 0-3061H 11683J H032 0-3672, 0-3061H The cable trays and supports were installed per the drawings. Locations,
}
dimensions, and correct identification for both trays and supports were i
examined. Dimensional checks included distances between supports.
l The inspector subsequently reviewed the installation and quality control I
inspection records for the trays and supports. The electrical contractor was unable, at the close of the inspection period, to produce quality control welding inspection records for structural cable tray supports ;
H102, H141, H104, and H106. Pending the outcome of the electrical contractor's search for these records, or reinspections, if justified, this issue will remain unresolved (456/85038-05).
No violations or deviations were identified.
10.
Piping Supports The following pipe supports were examined for drawing compliance including configuration, weld details, dimensional tolerances, location, and correct components:
Identification System M
M-1CC12002R Component Cooling Mini Strut M-1CC12009X Component Cooling Sway Strut M-1CV18002X Chemical & Volume Control Sway Strut M-1CV18048R Chemical & Volume Control Sway Strut i
M-1CV18063R Chemical & Volume Control Sway Strut I
M-1CV18079G Chemical & Volume Control Structural Tube M-1CV18083R Chemical & Volume Control Structural Box M-1CC12017X Chemical & Volume Control Mini Sway Strut M-1SX47003X Essential Service Water Sway Strut M-1SX5003X Essential Service Water Sway Strut The supports were installed in accordance with the drawings.'
i No violations or deviations were identified.
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11.
Electrical Components Installed junction boxes IJB011A, IJB005A, and and IJB015A were inspected j
for compliance with the following established requirements:
junction box installed per the latest drawings as to size, location, I
and box type junction box is adequately supported junction box identification is correct j'
junction box is free of any internal or external damage junction box is clean, no debris, tools or foreign materials are stored in or on the junction box concrete expansion anchors are installed in accordance with Specification BY/BR/CEA The following drawings were used in the inspection:
20E-1-3610 20E-1-3301 20E-1-3607 20E-0-3393T 20E-0-3393H 20E-0-3393J 20E-0-3390 The junction boxes were installed correctly.
The inspector reviewed LKC NCR No. 4302 which stated that concrete expansion anchors have been installed in several locations without quality control inspections being performed because of construction crews failing to turn in installation reports which initiate the qualicy control inspections.
The final disposition of this nonconformance will remain an open issue pending licensee corrective action and subsequent NRC review (456/85038-06; 457/85037-04).
Equipment panel IPA 33J, located adjacent to the control room, was inspected and it was determined that the panel was installed and aligned per the latest drawings.
The applicable drawings were 20E-0-3371B and 20E-0-3391C.
.The inspector noticed that the panel did not appear to be properly covered to prevent the entry of foreign matter. The licensee was notified and immediately covered the panel with a protective tarpaulin.
No damage was observed.
No violations or deviations were identified.
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- 12. Nonconformance Reports / Corrective Action Requests Piping nonconformance reports, No. 5300 through No. 5349, written by the Phillips Getschow Company, were reviewed for correct identification of the condition, adequate corrective action, and disposition compliance with the ASME Boiler and Pressure Vessel Code.
The inspector reviewed the corrective action system at Pullman Sheet Metal Works (PSM) as described in PSM Procedure B16.2.F. " Corrective Action",
Revision 0.
This procedure became effective January 18, 1985. This review I
consisted of verifying that the corrective action system established by Pullman is in compliance with applicable codes and standards.
The i
I corrective action system described in PSM Procedure B16.2.F requires the issuance of a Corrective Action Request (CAR) when a significant condition adverse to quality is identified.
The following five CARS were reviewed by
)
the inspector:
j CAR Issued Date Status
'f 002 January 30, 1985 Closed on June 13, 1985 j
003 N/A Invalidated on May 3, 1965 004 N/A Invalidated on June 20, 1985 005 June 19, 1985 Closed on July 17, 1985 006 August 2, 1985 Corrective Action being implemented _
and is scheduled for completion on March 31, 1986.
The above CARS were reviewed for adequate description of the adverse condition, adequate follow-up verification of the corrective action, and adequate documentation for justifying the invalidation of CARS 003 and 004.
The justifications for invalidation of CARS 003 and 004 were signed by the 2
PSM Quality Assurance Supervisor and Quality Assurance Director.
The justifications appeared appropriate for the invalidation of CARS 003 and 004.
'l The review of CARS 002, 005 and 006 resulted in identifying the following:
a.
The " Description of Condition" block on CAR 006 stated that i
Nonconformance Reports (NCRs) 748 and 749 did not identify the possibility that some clips to existing building steel welds may also i
be questionable and need further evaluation to determine appropriate corrective action if necessary.
Documentation available and discussions with PSM's QA Supervisor revealed that some of the clip to existing building steel welds were noted as being undersized.
During a sample (60) inspection of S2.1 connections conducted between May 21-28, 1985, it was noted that some of the clip to building steel welds were undersize (1/4", 3/16", etc.).
Sargent & Lundy (S&L) drawing 1261, sheet 6, specified a 5/16" fillet weld. Therefore, the clip to 5
existing building steel welds were not questionable at the time of the j
issuance of CAR 006 on August 2, 1985, but were deficient in that the j
welds did not, meet the applicable S&L drawing.
PSM 16.2F, Revision 0, 1
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Paragraph 6.1.B.2, requires that the block on the CAR titled "Descrip-tion of Condition" provide sufficient details as to fully describe the deficient condition including source, if applicable. Since the other j
four CARS reviewed had the " Description of Condition" block completed in accordance with procedural requirements, this concern is cr.nsidered an isolated case. CAR 006 has been revised by PSM to provide I
sufficient details as to fully describe the deficient conditian. The proposed action to assure the quality of installed items identified on CAR 006 was also revised to accurately describe the actions t.eing currently implemented by PSM QA/QC, b.
NCRs 748 and 749 associated with CAR 006 were noted as potentially reportable (10 CFR 50.55(e)) by Pullman QA. These NCRs were not transmitted to the licensee and therefore were not evaluated by the licensee for reportability in accordance with Procedure PCD-23, Revision 1. " Site Contractor Nonconformance Reports / Procedure Processing." A review of Pullman Procedure B16.1.F. Revision 7 "Nonconfomance," revealed that it does not require NCRs identified as potentially reportable to be submitted to the licensee. Subsequent to identifying this lack of a 10 CFR 50.55(e) review, appropriate licensee personnel have conducted and documented the necessary 10 CFR 50.55(e) review in accordance with Procedure PCD-23. The failure to have documented instructions to assure that Pullman NCRs identified as potentially reportable are submitted to the licensee is considered a violation of 10 CFR 50, Appendix B, Criterion V (456/85038-07; 457/85037-05).
c.
CAR 002 and CAR 005 were closed without fully verifying that the corrective action was implemented and was effective as required by PSM Procedure B16.2.F Revision 0, Paragraph 6.3B.
In regards to CAR 002, which identified that PSM drawings were not reviewed for variance from the S&L design drawing, the following were noted:
(1) The action taken to assure quality of installed items, which is documented on CAR 002, required that PSM shop drawings be reviewed l
for variance from the S&L design drawings. This review was to identify all items that were not fabricated or installed in compliance with the design drawings. This action also stated that PSM QC has been inspecting to S&L design drawings since l
September 17, 1984. There was no objective evidence that PSM QA verified the implementation and effectiveness of the action taken to assure the quality of installed items prior to closing CAR 002.
(2) The action taken to prevent recurrence of the deficiency noted on CAR 002 included revising the PSM Procedure B3.2.F. " Drafting,"
to require the necessary reviews of all shop drawings before
' issuance and to perfom a QA surveillance of the feview process.
CAR 002 was closed on June 13, 1985, based on the. revision of
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Procedure B3.2.F and the fact that a QA surveillance was lt scheduled for June 1985.
A review of PSM QA surveillance activities revealeu that a surveillance (QA-S-85-054) was conducted on June 21, 1985, but it did not address the review 1
process for PSM drawings as described on Procedure B3.2.F.
The j
inspector also reviewed the PSM QA audit records and noted that an audit (85-04) of Procedure B3.2.F was conducted on July 16-18, 1985.
A review of the audit checklist determined that there was no objective evidence that the audit covered the drawing review
{
process.
A potential problem pertaining to a welders certification was identified on CAR 005.
The corrective action to prevent recurrence included revising the active welder log to provide a 3
column for documenting the surveillance of welder certifications by PSM QC.
This revision of the active welders log was to provide adequate tracking for maintenance of PSM QC surveillance activities.
PSM QA closed CAR 005 based on the active welders log being revised to include the QC surveillance column. There is no objective evidence that PSM QA verified the effectiveness of the revision of the active welders log for QC surveillance 3
activities.
The failure to perform proper follow-up verification to assure that the corrective action was implemented and effective as required by PSM Procedure B16.2.F for CAR 002 and CAR 005 is considered a violation of 10 CFR 50, Appendix B, Criterion V
(
(456/85038-08; 457/85037-06).
During the review of the corrective action system at PSM, the inspector noted that PSM Procedure B16.2.F, " Corrective Action," required CARS to be transmitted to the licensee for "information only." Since these PSM CARS are utilized to identify significant conditions adverse to quality, the inspector is concerned that the licensee reviews only an "information" copy.
The processing of site contractor documents which identify significant conditions adverse to quality by the licensee in a manner at least commensurate with the processing of NCRs is considered an open item (456/85038-09; 457/850037-07).
1
- 13. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 5, 7, and 11.
14.
Unresolved Items Unresolved-items are matters about which more information is-required in order to ascertain whether they are acceptable items, violations, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs 4, 8, and 9.
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Exit Interview i
j The inspector met with licensee and contractor representatives denoted in Paragraph 1 at various times during and at the conclusion of the inspection on October 17, 1985.
The inspector summarized the scope and results of the j
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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NUCLE AR REGULATORY COMMISSION
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's,.....J NOV 1 4 GG5 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. T. M. Tongue and M. J. Farber of this office on September 3 through November 1, 1985, of activities at the Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. M. Wallace and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection.
Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in violation of hRC reauirements, as specified in the enclosec Appenaix.
A written eesponse is required.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of *his letter and tne enclosure (s) will be placed in the NRC's Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Commonwealth Edison Company 2
NOV I 4 Gs5 We will gladly discuss any questions you have concerning this inspection.
Sincerely,
/b W.[Little, Director Braidwood Project
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Reports No. 50-456/85045(DRP);
No. 50-457/85044(DRP) cc w/ enclosures:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent J. F. Gudac, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DME/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwood i
Resident Inspector, RIII Byron
^
Phyllis Dunten, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public utilities Division H. 5. Taylor, Quality Assurance Division E. Chan, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honopable Richard F. Cole, ASLB t
Appendix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on September 3 through November 1, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violation was identified:
10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, as implemented by the Comonwealth Edison Quality Assurance Manual, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, corrective actions were inadequate or not implemented for the following NRC identified issues:
a.
Corrective actions (instruction to contractors), in response to NRC concerns over protecting systems and components from intrusion of foreign matter, such as dust and moisture, were insufficient and resulted in exposure of the internals of reactor protection electrical components in the auxiliary electrical room and control roon panels to deposition of significant dust from nearby ongoing masonry work.
Previous corrective actions addressed specific examples identified by the inspectors, but was apparently narrow in scope and not applied to other systems and areas, b.
On or about Septerber 19, 1955, the inspectors identified the following deficiencies to the licensee:
1)
Numerous damaged flexible electrical cable conduits were observed during a plant tour. The damaged conduits exposed the cable insulation to cuts and gashes from the sharp edges of the conduit and also forced the cable to support the conduit.
2)
An accunulation of oil was found inside the bearing thermocouple junction box for centrifugal charging pump 1CV01PA. This caused the thermocouple cable insulation to be imersed in oil and resulted in potential degradation of the insulation.
In addition this oil represented a fire hazard to the pump.
As of October 28, 1985, no corrective action had been taken to correct these conditions or identify and correct their cause.
This is a Severity Level IV violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.
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Appendix 2
Consideration may be given to extending your response time for good cause shown.
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Yhflk 4ated W. 5:' Little, Director
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Braidwo'od Project
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U. 5. NOCLEAR REGULATORY COMMISSION REGION 111 Reports No. 50-456/85045(DRF); 50-457/85044(DRP)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee:
Comenwealth 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:
September 3 through November 1, 1985
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Inspector:
T. M. Tongue Date
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//!/J!Pf M. J. Farber Date j
1 Approved By:
L' le, Director
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f-Era'dwood Project De te '
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Inspection Sumary Ir.spection o Sectember 3, throucF November 1, 198E (Report Nc. 50-456/85045(DRP);
50-457/E5044(DRF))
Areat inspected:
Routine, unannounced safety inspection of activities with regard tc licensee action on previous inspection findings, plant tours, fuel receipt preparatiers, technical specification reviews, operational preparedness, comunications, adtrinistrative controls for Startup Deficiency Reports, steam generator hydrostatic testing, piping and instrument diagrar verification, fire protection plug valves, and guard force picket activities.
The inspection consisted of 212 inspector-hours onsite by two NRC inspectors including 36 inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, no violations were identified in ten areas, one violation was identified in one area (inadequate corrective action
- Paragraph 3)..
Details 1.
Persons Contacted Commonwealth Edison Company (CECO)
Corporate Personnel A. Miosi, Nuclear Licensing Administrator Braidwood Personnel
- M. J. Wallace, Project Manager
- C. W. Schroeder, Project Licensing and Compliance Superintendent
- D. L. Shamblin, Project Construction Superintendent J. Gudac, Station Superintendent
- E. E. Fitzpatrick, Assistant Manager, Quality Assurance
'L. M. Kline, Project Licensing and Compliance Supervisor N. Tomis, POAD Supervising Engineer H. Zimmerman, Project Startup Testing Supervisor D. Paquette, Maintenance Assistant Superintendent
- D. O'Brien, Administrative and Support Services Assistant Superintendent R. Legner, Senior Operating Engineer G. Masters, Operating Engineer F. Willaford, Security Administrator M. Andrews, Station Chemist
- G. Nelson, Assistant Technical Staff Supervisor T. Keith, Lead Health Physicist
- i. W. Sinpkin, Technical Staff-Licensing
'T. E. Quaka, Site Quality Assurance Superintendent
- R. Kyrouac, Quality Assurance Supervisor
- C. Tomashek, Startup Superintendent NRC Personnel J. Stevens, Braidwood Licensing Project Manager G. Pluelee, Licensing Reviewer NRC Contractor D. McHuron, E.G.&G. Senior Engineer The inspectors also talked with and interviewed several other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shif t engineers and foremen, electrical, mechanical and instrument personnel, contract security personnel and construction personnel.
- Denotes those attending one or more exit interviews conducted on September 5, 12, 19, October 10, 17, 24, and 31, 1985 and informally at various times throughout the inspection period.
2
2.
Licensee Action on Previous Inspection Findings The inspectors reviewed licensee corrective actions on the following items and the results are as stated:
(Closed) Violation (456/85023-Ol(DRP); 457/85024-01(DRP)):
Failure to keep trash and debris out of safety related cable trays and control of high strength bolting material (construction material). The licensee provided instructions to contractors for control of trash, debris and safety related material and this specific issue was closed in inspection report No.
456/85032(DRP); 457/85031(DRP). However, plant tours by the inspectors revealed that this is still a problem and corrective action has not been effective.
(0 pen) Violation (456/85008-10(a),(b), and (c)(DRS); 457/85008-10(a),(b),
and(c)(DRS)):
Inadequate protection of installed safety related plant equipment.
Steps were taken to correct the specific items identified, however, the actions were inadequate in that a number of new and ongoing conditions remain uncorrected.
With regard to the adequacy of the corrective action on both of the foregoing items, refer to Paragraph 3 of this report.
3.
Plant lours During this inspection period, the inspectors conducted tours of the facility to make independent assessment of equipnent, plant conditions, security, fire hazards and fire protection, maintenance, comunications, work authorizations, and system controls during and after flushing, testing, and maintenance.
The inspectors reviewed applicable logs, procedures, work packages, a$d interviewed personnel involved in ongoing activities as part of the inspection.
Durinc plant tours the inspectors identified areas where equipment prctection was inadequate.
Electrical panels in the auxiliary electrical equipner.t room and the main control board in the control room were lef t uncovered and/or open while masonry work was being conducted in the imediate vicinity.
This resulted in fine masonry dust settling out on the control panels and internal components as well as leaving them vulnerable to further intrusion of other contaminants such as moisture, spray, or aerosols.
Although there may not be an imediate problem with the equipment, the intrusion of foreign matter can cause unpredictable equipnent failures in the future. The inspectors identified an open electrical junction box for temperature element leads on centrifugal charging pu.mp ICV 01PA which contained an accumulation of oil such that theicable insulation was submerged in the oil. Additionally, the oil accumulation constitutes a potential fire hazard. The inspectors also identified a number of ficxible electrical conduits which were damaged such that the cable supported the conduit and the cable insulation was exposed to cuts and gashes from the sharp edges of the conduits. The open junction box and the damaged flexible conduits were presented to 3
licensee management representatives during an exit meeting on September 19, 1985.
As of October 26, 1985, no evidence was available to show that action had been taken to correct the conditions and that any evaluation had been performed to determine the reason for the accumulation of oil in the temperature element junction box.
The inspectors noted that in the past year there have beer at least two previous violations for inadequate housekeeping and equipnent protection.
The lack of effective overall corrective action to protect safety related equipment in response to NRC violations and failure to respond in a timely manner to inspector findings is considered a violation of 10 CFR 50, Appendix B, Criterion XVI,
- Corrective Action (456/85045-01(DRP);
457/E5044-01(DRP)).
On October 29, 1985, subsequent to the inspector informing the licensee of the issuance of the violation for inadequate corrective action on housekeep-ing and equipment protection, the licensee issued an action plan. The plan delineates specific steps and responsible individuals for cleaning electrical panels and equipment in the Unit I and 2 control rooms auxiliary electrical roors, and computer rooms on elevation 451'.
The plan is specific to those areas and if effective, should prevent further intrusion of construction dust, dirt and debris into those control and electrical components. The action plan does not address other areas of the plant, e.g., safety related equipnent areas of the turbine, auxiliary, and containment buildings, and is specific to electrical equipment.
It does not address other systems such as mechanical ventilation, diesel generator, etc.
The limited scope was discussed with licensee management personnel at the e>it met:ing on October 31, 198E, and they stated that this was the beginning to an overali program in preparation fcr shif ting the plant to a test / operational status. This will continue tc be monitored as part of the routine inspection.
One viclation was identified.
4 New Fuel Receipt Preparations The inspectors reviewed the proposed Special Nuclear Materials License (No. SNC-1938) in preparation for receipt and storage of new fuel, post accider.: monitoring detectors, and a sealed plutonium calibration source.
l The inspectors also monitored the status of preparation of the spent fuel pool, new fuel storage area, and reviewed the status of required preoperational testing for fuel handling systems, personnel and training requirenents, security preparations, required fire protection systems,
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and health physics programs.
Subsequent to these reviews the license (SNM-1938.) was issued on October 8,1985.
The inspectors will continue to monitor licensee preparations during forthcoming inspection periods.
No violations or deviations were identified.
5.
Technical Specification Review During the inspection period, the inspectors conducted a review of the
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draft Technical Specifications, dated September 16, 1985. The review was 4
for techrical content, clarity, enforceability, typographical errors, and any questions where interpretation was in question.
On October 29 and 30,1985, the inspectors met with members of the NRR Headquarters staff, an NRC contractor, and with licensee representatives to discuss the results of their individual review findings.
The results of the meetin'g will be considered for resolutior, prior to the final proposed Technical Specification proof and review.
No violations or deviations were identified.
6.
Operational preparedness Through interviews with personnel and observation of activities, the inspector identified the following concerns during the inspection:
a.
An apparent shortage of operations personnel when considering the station is entering an intensive startup and testing program along with a large portion of personnel on training assignment for licensing.
b.
The need for station maintenance personnel to get involved in as much activity as possible for a better understanding of the plant equipment prior to turnover for operation.
c.
An exceptional number of nonessential design changes and modifications of systems during and after construction and testing.
This can create unnecessary delays as well as making the station vulnerable to unexpected equipnent failure events later in plant life, as evidenced by some of the recent occurrer.ces at the LaSalle and By ron stations.
These issues were discussed with prcject management personnel who were knowledgeable on each of the items and could justify the condition or sht+ that corrective actions were being implemerted.
These concerns will continue to be monitored routinely in future inspections.
No violations or deviations were identified.
7.
Comunications During the inspection period, the senior resident inspector (SRI) attended a number of morning meetings in the control roor to acquire a knowledge of the daily ongoing activities.
It became evident that the Ceco Operational Analysis Departnent (OAD) was not represented, even though there were about 20 OAD crews conducting testing on site.
In addition, the inspector noted that, occasionally, a start-up engineer from the start-up group would miss the ineeting.
The purpose of these meetings is for planning daily activities and the very important function of keeping all appropriate plant operations personnel apprised of activities in the plant that are related to control room indications, alarms or controls.
Since the station is in a transition process from construction to a testing / operational mode, the SRI suggested that 0AD and all start-up engineers be represented at the meeting.
The 5
9 licensee acknowledged this and has provided representation as suggested.
Further evidence of connunication breakdown was identified when two small fires of suspicious origin occurred within a two week period. The construction Fire Marshall was informed and assessed the incidents, however, the station Fire Marshall or his assistant was unaware of the events. The licensee has -taken steps to assure better comunication between these individuals.
The inspector expressed concern about adequate comunications between the start-up test group and the station personnel throughout the start-up program to assure' an adequate understanding of the equipment perfomance history to assure efficient operation.
Comanications will continue to be routinely monitored.
ho violations or deviations were identified.
8.
Administrative Controls on Startup Deficiency Reports (SDR)
In response to concerns raised by Region III Test Program Section inspectors and as a result of observations by the inspector during a review of Startup Deficiency Reports, the inspector comenced an evaluation of the administra-tive controls for Startup Deficiency Reports. This document identifies broken, incomplete or improper installations, do:unentation, or testing itens.
These deficiencies have the potential to be nonconfoming items and the Startup Deficiency Report may be the only record of a nonconformance until a Nonconfomance Report (NCR) is generated. As such, SDRs written on safety related items are quality records.
The following documents were reviewed:
0.R. Nc.15.0, Rev. E, "Nonconfoming Materials, Parts, or Components and Operations" Q.P. No.15-1, Rev. 7, " Reporting Quality Nonconfomances During Construction and Test
Braidwood Project Startup Manual, Res.13, Section 4.1.4,
" Deficiencies" Braidwood Project Startup Manual, Rev.13, Section 4.6.3.9, " Test Fe rforma nce
Following the review of these documents the inspector iden'.ified the following concerns:
a.
The Braidwood Project Startup Manual, Seccion 4.1.4 provides the procedural requirements for centrol of the Startup Deficiency Report within.the confines of the Startup organization.
It does not provide 5 instructions for the control of this document once it has been transferred to other departner.ts. The inspector was unable to identify procedures in other site departments, Quality Assurance excepted, which contained instructions for the control of SDRs.
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Evaluation of the requirement for organizations processing SDRs to have procedures which control them is an open item (456/85045-02(DRP);
457/85044-02(DRP)) pending further discussions with the licensee staff, b.
Review of the procedures controlling the deficiency reporting process revealed. that there is no requirenent to identify on the SDR documents such as work requests, NCRs, letters, and evaluations used in the resolution of the deficiency. Without the identification of these corrective action documents, the traceability of the corrective action is indeterminate.
The ability to audit SDRs and trace corrective action from issue to closure is an open item (456/85045-03(DRP);
457/85044-03(DRP)) pending an audit of Startup Deficiency Reports by the inspector.
c.
While attempting to identify procedures for control of SDRs the inspector was unable to determine whether or not provisions in existing Project Construction Departrent procedures would ensure that SDRs received a review to identify nonconforming items.
Without these provisions it is not clear that Startup Deficiency Reports have been properly reviewed for nonconformance and that Nonconforrance Reports have been written for all nonconforming items which were identified on SDRs.
Review of Startup Deficiency Reports for nonconfornance is an open item (456/85045-04(DRP); 457/85044-04(DRP)) pending a review of SDF.s by the inspector to determine if there has been a consistent f ailure to report nonconforming items which are identified on Startup Deficiency Reports, d.
While exanining the project procedure index to identify PM or PCD procedures related to SDRs the inspector noted that Procedure PM-05
- Noncon'orr.ance Reporting" was not issued.
Since this procedure would be expected to define the projects administration controls for the issuing, handling, and tracking, of a quality record, the inspector is concerned that NCRs are not adeauately controlled.
Evaluation of the circumstances involved in the failure to issue this procedure is an open iter (455/E5045-05(DRP); 457/85044-05(DRF)).
No violations or deviations were identified.
9.
Stear Generator Hydrostatic Testing The licensee is currently scheduled to conduct a Reactor Coolant System primary hydrostatic test.
To gain familiarity with the licensee's methods for conducting major hydrostatic tests, the inspector conducted a brief review of the construction procedure used to conduct the Unit I steam generator hydrostatic testing and witnessed portions of the test. The inspector had the following comments regarding the procedure and the evolution:
l 7
a.
The procedure was very loosely constructed and was more of a set of broad general guidelines fer conducting the evolution.
Valve lineups did not appear to be well-structured or formal.
b.
Secondary systems such as Condensate and Feed were used in support of the test.
Personnel conducting the test used no procedures in the operation of these systems relying instead on their knowledge of the system to lineup valve: and run the pumps.
Verylittleinstrumenk.ationwasavailabletotheoperatorsinthe c.
control room to enable them to monitor the status of the plant.
They were forced to rely on radio and face-to-face reports from test personnel to determine conditions in the plant.
During the filling of the steam generators the only instrumentation which the inspector could identify as functioning were Condensate Booster Pump Amps and a Condenser Hotwell Level computer p:, int.
Significant steam generator parameters such as level, pressure, and temperature were not available to operators nor was the valve position indication for the feedwater Regulating Bypass Valves which were used to control flow to the steam generator.
The inspector met with the Startup Superintendent to discuss these comments.
It was noted by both the inspector and the Startup Superintendent that this was a construction test on a secondary system and it was not subject to the same requirements as a preoperational test on a safety-related primary syster.
However, the inspector pointed out that the primary hydrostatic test is also a construction test but that a similar test procedure and test performarece would not be considered acceptable.
The inspector stated furtier that the test procedure would be closely reviewed and witnessed.
hc siciations or desiations were identified.
10.
Allecation Revie.
In response to an allegation concerning the accuracy of Piping and Instrucent Diagrams (P&lD) the inspector has commenced walkdowns of P& ids for selected safety systems and has interviewed members of the licensee's operational staff to eva;uate the effectiveness of the P&lD verification and correction process.
A walkdown of M-37, Auxiliary Feedwater has been completed and some minor deficiencies were noted.
These were turned over to the licensee staff for resolution.
A walkdown of the Diesel Fuel Oil j
l syster P&lD was started but will not be completed until the next reporting l
period.
Further discussions with the operations staff regarding the P&lD verification and correction process will be required to determine the adequacy of the licensee's program.
Upon completion of the inspector's redew of all issues involypd in the
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allegation a-report will be issued which will detail all the issues and address the resolution of each one.
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No violations or deviations were identified.
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11.
Fire Protection Isolation Valves An issue which emerged from both the fuel receipt preparation inspections and the allegation discussed in Paragraph 10 was the acceptability of the ITT Grinnell plug valves used as header and standpipe isolation valves in the fire protection system in the containment.
In discussions with regional fire protection personnel a concern was raised as to whether or not these valves were approved for use in fire protection systems by the Underwriters Laboratory (UL) as required by the National Fire Protection Association (NFPA) Code, Section 14.
The inspector met with the Project Construction Department (PCD) engineer responsible for fire protection and during the meeting was shown a letter dated May 17, 1985, from M&M Protection Con-sultants to Comonwealth Edison, which identified that the ITT Grinnell valves were not UL listed.
The letter stated that the valves were seismically qualified but that a UL listing is not available for seismic class valves. The recomended resolution was that since UL listing is not available for seismic class, the valves are acceptable.
Further discussions with regional fire protection specialists questioned this conclusion.
Acceptability of the ITT Grinnell plug valves for use in fire protection applications is an open item (456/85045-06(DRP); 457/85044-06(DRF)) pending review of the matter by Region III fire protection specialists.
NC violations or deviations were identified.
12.
Guard Force Pickets On Novenber 1,1985, the licensee inplemented the services of Burns Security, replacing Guards Mark.
On that date, the teminated guards established informational pickets at the north and south gates of the plant. Access to the plant was delayed by up to thirty minutes due to traffic ccrgestion, however. the pickets dispersed by mid-morning. A number of contractor trades personnel honored the picket, however, licensee personnel appeared to be ur.a f f ected.
There was some news media interest through an announcement over a local radio station.
The inspector monitored the activities ar.d relayed information to Region III as appropriate.
ho violations or deviations were identified.
- 13. Meetings, Training, and other Activities On October 21 and 22, 1985, Mr. Yoshitah Arakawa of the Japanese Ministry of Internal Trade and Industry was on site for an infomation gathering session as part of his three month tour of the United States. Mr. Arakawa's agency is the Japanese equivalent of the NRC and he expressed interests in a number of areas, such as the NRC Resident Inspector Program, Technical Specjfications, emergency diesel generators, certification of construction work in accordance with construction codes, etc.
Mr. Arakawa provided enlightening discussion when comparing the two nations and expressed gratitude for the time and information provided by the licensee personnel and the inspectors involved.
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14 Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 8 and 11.
15.
Exit Interview The inspectors met with licensee and contractor representatives denoted in Paragraph I during and at the conclusion of the inspection on October 31, 1985.
The inspectors 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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p taGy UNITED STATES g
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NUCLEAR REGULATORY COMMISSION
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j ctE~ cetvu. ittinois ois, APR 7 1986 Docket No. 50-456 Docket No. 50-457 Corronwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Mr. R. A. Westberg cf this office on March 19 through April 2,1986, of activities at Braidwood Nuclear Powcr Station, Units 1 and 2, authorized by NRC Construction Permit No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. G. E. Groth at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective e> amination of procedures and represer.tative records, observations, and interviews with personnel, ho violations of NRC requirements were ider,tified during the courst of this inspecticn.
In accordance with 10 CFR 2.790 of the Corrission's regulations, a copy of this letter and the enclosed inspection repert will be placed in the NRC Public Dccur.ent Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
~
&W J. J. Harrison, Chief Engineering Branch
Enclosure:
Inspection Reports No. 50-456/86014 DRS ;
No. 50-457/86012 DRS See Attached Distribution
Commonwealth Edison Company 2
APR 7 1986 cc w/ enclosure:
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D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager D. Shamblin, Construction Superintendent E. E. Fitzpatrick, Station Superintendent P. L. Barnes, Regulatory Assurance Supervisor DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division
'sJ E. Chan, ELD J. Moore, ELD G. Berry, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB 4
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/86014(DRS); 50-457/86012(DRS)
Dccket Ncs. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licsnsee: Commonwealth Edison 'ompany C
Post Office Sox 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, IL Inspection Conducted: March 19 through April 2, 1986
\\l d \\, C jl b A H /7 86 Inspector:
R. A. Westberg v
I Date J%e W-4b Approved By:
J. W. Muffett, Chief Plant Systems Section Date hsfection Sumary Ins pection on Ma rch 19Arough April,,2,,19,8,6,,(, Reports No._,5,0,,4,5,6/8,60E(p,R,5),
No. 50-457/86012(DR'Sll Treas Inspected: Routine, announced inspection by one regional inspector of licensee action on previously identified items and safety evaluation report review and followup.
It was ccr. ducted in accordance with NRC Inspection Procedures No. 92701, No. 92702, and No. 92719.
Results: No violations or deviations were identified. Of five previously identified items reviewed, four were closed.
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DETAILS 1.
Persens Contacted Comonwealth Edison Compm_(_C_E_C,o)
- P. L. Barnes, Regulatory Assurance Supervisor
- D. L. Cecchett, Regulatory Assurance Engineer
- J. F. Phelan, Project Field Engineering, Electrical Supervisor J. R. Wozniak, Project Construction Department (PCD), Field Engineer Electrical
- T. W. Ronkoske, PCD Field Engineer Electrical
- A. J. D' Antonio, Regulatory Assurance Engineer
- G. E. Groth, Assistant Construction Superintendent
- E. R. Netzel, Quality Assurance Supervisor D. L. Shamblin, Project Construction Superintendent J. A. Zych, Quality Assurance Engineer Sargent and Lundy Engineers (S&L)
- J. D. Regan, Electrical Project Engineer D. J. Raef, Project Leader Electrical J. Paprocka, Designer USNRC W. J. Kropp, Senior Resident Inspector Other personnel were contacted as a matter of routine during the inspection.
- Indicates those attending the exit meeting on March 26, 1986.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Violation (456/82006-02A):
Safety-Related cable trays were found to be in physical contact with non safety-related cable trays at nodes 1696H-CIE and 1713D-CIB; 113358-CIE and 11335F-PIB; and cable ISX001 and 1689A-PIE.
Insufficient horizontal spacing was found between 213985-PZE and 21384T-P21B. The inspector verified that the current design drawings call for covers on cable trays 1713D-CIB, 11355B-CIE, 11335F-PIB, 21398S-P2E, and 21384T-P28. With covers installed, the spacing can be one inch metal to metal and comply with IEEE 384-1974 Separation of a safety-related cable in free-air in contact with a cable tray was found acceptable by NRR in
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the SSER letter dated February 25, 1986. Additionally the inspector visually verified that the trays were not in physical contact (metal
.to meta'1). All items reviewed were found acceptable.
b.
(Closed) Violation (456/82006-02B):
Insufficient separation was found between safety-related cable trays and non safety-related cable trays at ncdes 21398T-C2E and 21384U-C2B; and 12028C-CIE and 120860-CIB.
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The design drawings did not specify the required covers. The inspector verified that Drawing No. 20E-0-3052B, Revision S now specifies a cover for tray 213844-C2B and Drawing No. 20E-0-3072C, Revision AD, specifies a cover for 12086D-C18. All items reviewed were found acceptable, c.
(Closed)~ Open Iten (456/82006-03): Ten examples of areas where minimum separation was not maintained were found. The inspector verified that the design drawings show enclosed raceways for eight of the ten examples which makes their separation acceptable. The other two examples were analyzed by S&L and found acceptable. The inspector reviewed the following documents:
(1) Drawing 20E-0-3667, Revision AU; (2) Drawing)20E-0-3659, Revision AD; (3) Drawing 20E-0-3663, Revision AK; (4 Drawing 20E-0-30518, Revision Y; (5) Drawing Drawing 20E-0-3031A, Revision R; (8)g 20E-0-302IA, Revision AE; (7) 20E-0-3021B, Revision AH; (6) Drawin Drawing 20E-0-3031B, Revision T; (9) Drawing 20E-1-3041C, Revision S; (10) CSCV No. 330. All items reviewed were found acceptable, d.
(Closed) Violation (456/84044-06):
Inspection program contains insufficient electrical separaticn acceptance criteria to verify that design requirements had been met (CAT Item Secticn IIB.1.B(1)).
The inspector reviewed L. K. Comstock (LKC) Procedure No. 4.3.5,
" Cable Pan Installation," Revision E, and No. 4.8.5, " Inspection of Class 1E Safety-Related Cable Plan Installations," Revision F.
The procedures reference the three inch horizontal and 12 inch vertical separation criteria from the Braidwood FSAR. The inspector also reviewed S&L Project Instructions (PI) No. BB-59, " Documentation cf Cable Separation Criteria Violations," Revision 1 and No. BB-77,
" Cable Tray Separation Walkdown Procedure" and found them in agreement with the separation criteria in the FSAR. The inspector reviewed the 61 apparent separation criteria viclations from the CAT inspection with the following results:
(1) Seven were determined to meet the criteria; (2) Four were identified and dispositioned by S&L en their walkdown; (3) Three were dispositioned by S&L on the basis of a calculation; (4) Two were duplicates of tray nodes already en the list; (5) Four were determined to be acceptable based on the recent SSER on cable separation; (6) Ten were trivial, non safety-related cable in conduit over safety-related trays; and (7) 31 will be enclosed by a raceway cover as indicated by the design drawings.
The review of these items determined that acceptable separation, and separation criteria now comply with design requirements.
e.
(0 pen) Violation (456/82006-04) Cables in free air were routed closer than the 12 inch limit allowed by procedure. The inspector reviewed this iterr but detennined visually that some violations of the cable separation critieria still remain.
Pending further review. this item remains open.
4 3.
Physical Identificat.i_o_n a_n_d_.I.n.d.ep_endence of Class 1E Cables and Non-Class 3
c a.
Introduction The Braidwood Final Safety Analysis Report (FSAR) Section 8.3.1.4
" Physical Independence of Redundant Systems" established the separation requirements for the physical arrangement of cable trays.
With respect to safety and non safety-related cable trays, the Braidwood FSAR specifies an exception to the Regulatory Guide (RG) 1.75 required separation distances of five feet vertical and three feet horizontal and substitutes 12 inches vertical ar.d three inches horizontal in. stead.
The Construction Appraisal Team (CAT) inspection used these reduced separation criteria as the basis for their inspection of cable trays and identified El instances that violated the criteria. These deficiencies were discussed with Sargent and Lundy (S&L) and licensee.personrel who disclosed that in areas where less than the required separaticn exists, approved fire barriers such as cable tray covers w]uld be installed. The CAT inspectors then selected seven out of the 61 identified deficiencies and reviewed the applicable design drawings with S&L personnel to determine whether fire barriers had been specified for these examples. The results of this review indicated that fire barriers were not specified in three of the seven examples.
(See Section 2.d of this report for the closc-cut of these items.)
Cable separation deficiencies have been previously noted by Region III inspections.
As a result of these inspections, the CAT inspection, and differences in interpretation of the separation criteria between licensee and NRC personnel, the NRC Office of Nuclear Reacter Regulation was requested to evaluate the reduced separation criteria of Class 1E cables from non-Class 1E Cables.
The reduced physical separation was justified by the licensee by testing and analyzing various test configurations. The NRC staff reviewed the results of these tests and determined that the test program and the results were acceptable in the NRR SSER letter dated February 25, 1986.
Therefore the reduced separation criteria are acceptable.
The purpose of this inspection is to accomplish the following:
(1) Closecut the CAT items relative to cable tray separation.
(2) Select a new semple of cable trays for inspection and verify that the 12" vertical and three inch horizontal separation criteria is being observed.
5(3) Closecut previous open items relative to cable tray separation.
b.
Documents Reviewed 4
5 (1) Sargent and Lundy Project Instruction (PI) No. PI-BB-59, "Docun,entation of Cable Separation Criteria Violaticns,"
Revision 1.
(2) NO. PI-BB-77, " Cable Tray Separation Walkdown Procedure,"
Revision 0.
(3)
L. K. Comstock (LKC) and Company Procedure No. 4.3.5, " Cable Pan Installation'," Revision E.
(4) LKC Procedure No. 4.8.5, " Inspection of Class IE Safety-Related Cable Pan Installation," Revision F.
c.
Inspection Results (1) The inspector reviewed the specific CAT items on separation criteria ar.d verified that the licensee's inspection program now contains sufficient acceptance criteria for cable separation.
The inspector also reviewed the violations of separation criteria identified by the CAT inspection and verified that either they had been corrected or that no safety concerns existed.
See Section 2d of this report for details.
(2) The inspector selected a sample of 17 apparent violations of the separation criteria for further review during a walkcown cf the 439 foot elevation of the Unit I cable spreading rooms.
The resiew of this sample with S&L personnel shcwed that in all but one case, the violations had been previously identified and dispositioned by analysis or by covering the trays. The fact that cr.e violation was not identified was still acceptable since S&L had not performed their final walkdown of the cable trays in this area. The other violations were identified by S&L during the engineering process.
d.
Conclusions The inspector's review of the licensee's program for cable separation indicated that it was consistent with the program described in the NRR SSER letter dated February 26, 1986 and the Braidwood FSAR.
4.
Exit Interview The inspector met with licensee representatives cn March 26, 1986, and sunnarized the purpose, scope and findings of the inspection.
The inspector also discussed the likely infonnational content of_ the inspection. The inspector also discussed the likely infonnational content of the inspection report with regard to documents or processes revihwed by the inspector during the inspection.
The inspector also net with licensee representatives on April 2,1986, to discuss the review of two additional previously identified items.
5
e UNITED STATES g* 2fGg\\
8 NUCLEAR REGULATORY COMMisslON
[hyiS REGION m f
799 ROOSEVELT ROAD E^
g[ng ot ~ cetvu. imuOis som FEB3 1986 Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This refers to the special inspection conducted by Messrs. J. W. Muffett and J. M. Jacobson of this office on July 8, 9, 11, 25, 26; August 1, 2, 5; September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985; and January 9,1986, of activities at the Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. M. J. Wallace at the conclusion of the inspection.
The purpose of this inspection was to assess the implementation of the Material Traceabil'.ty Verification (MTV) Program at the Braidwood Station. A prior inspection report (50-456/83-09; 50-457/83-09) identified deficiencies concerning verification of installation of correct piping materials. Our questions concerning these deficiencies were made into unresolved items (456/83-09-04A,457/83-09-04A;456/83-09-04B,457/83-09-048). The deficiencies in your material control program identified in this prior report resulted in a number of installed piping components which did not comply with applicable design specifications.
During the March 7, 1984 enforcement conference, you described the MTV Program which provided for 100% inspection of the piping installed during the period of interest. The procedures which control the MTV program and the implementation of the procedures have been reviewed and inspected by the NRC as discussed in the attached report. Our inspections and reviews have found both the procedures and the implementation of the procedures to be acceptable to address this issue.
The MTV Program, as discussed in your final report " Material Traceability Verification at Braidwood", has discovered a number of instances in which the materia 1' control procedures during the period of interest were not followed.
Although the MTV Program discovered examples of failure to follow material control procedures and examples of installed piping components which did not comply with the applicable design specifications, engineering evaluation of the results of the MTV Program has demonstrated that all installed components were capable of performing their safety functions.
~
Commonwealth Edison Company 2
FEB 3 1986 Therefore, due to the lack of safety significance, it has been determined that the violation for failing to follow the material control procedures is a Level IV violation.
The inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Our understanding of your corrective s
actions are described in Paragraph 2 of the enclosed inspection report.
Consequently, no reply to the violation is required and we have no further questions regarding this matter at this time.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
%fn A
amesG.Keppfehf Regional Administrator
Enclosures:
1.
Inspection Reports No. 50-456/65061(DRS);
No. 50-457/85057(DRS)
See Attached Distribution i
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FEB 3 1986 Commonwealth Edison Company 3
Distribution cc w/ enclosures:
D. L. Farrar, Director of Nuclear Licensing M. Wallace, Project Manager s
D. Shamblin, Construction Superintendent E. E. Fitzpatrick, Station Superintendent C. W. Schroeder, Licensing and Compliance Superintendent DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq.
J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Moore, ELD G. Berry, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB Mike Parker, Illinois Department of Nuclear Safety Duane R. Gallup, Office of the Illinois State Fire Marshall
NOTICE OF VIOLATION Conrnonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on July 8,9. 11, 25, 26; August 1, 2, 5; September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985; and January 9,1986, and in accordance with the " General Policy and Procedures for N
NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation wa.s identified:
10 CFR 50, Appendix B, Criterion V as implemented by Commonwealth Edison Company (CECO) Quality Assurance Manual, Quality Requirement No. 5.0, requires that activities affecting quality be prescribed by documented instructions, procedures or drawings and be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, prior to September 6,1983, for small bore piping and prior to January 1,1983, for large bore piping, certain activities affecting quality were not accomplished in accordance with documented instructions and procedures in that the material traceability portion of the quality assurance program was not adequately implemented in that 792 (approximately 3% of a total of 25,815) installed items were identified as nonconforming when compared to the CECO's procedural requirements for material traceability.
The CECO requirements for documentation of traceability exceeded those of the ASME B&PV Code,Section III, for 562 of those items, and 85 others were determined to be acceptable based un supplemental quality records. The remaining 145 (approximately 0.5% of the installed items) were found to lack the required ASME B&PV Code,Section III evidence of traceability and were removed; however, subsequent physical and chemical tests established that the material that was removed was in fact the correct material.
This is a Severity Level IV violation (Supplement II).
The inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, no reply to this violation is required and we have no further questions regarding this matter.
F L -, >9n 0
0, M ~ L gRegionalAdministrator ames G. Kepplee u Dated O
1 U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/85061(DRS); 50-457/85057(DRS)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee:
Commonwealth Edison Company s
Post Office Box 767 Chicago, IL 60690 Facility Name:
Braidwood Station, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, IL Inspection Conducted:
July 8, 9, 11, 25, 26; August 1, 2, 5; September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985, and January 9, 1986 J~ w Q Inspector:
J. W. Muffett i /i1 [84 Date
/7)dl P
. M. Jacobson 8
Date lc =
l j Approved By:
D. H. Uanielson, Chief
/// 7/84 Materials and Processes Section Date Inspection Summary Inspection on July 8, 9, 11, 25, 26; August 1, 2, 5; September 17, 25, 26; November 18, 19, 21, 26; December 10, 17, 1985; and January 9, 1986 (Report: No. 455/85051(ORS); 457/85057(DRS))
Areas Inspected:
Special unannounced safety inspection of a previously identified unresolved item concerning traceability of piping and piping components and the licensee's Material Traceability Verification (MTV) program. The inspection involved a total of 160 inspector-hours by two NRC inspectors.
Results:
In the area inspected, one violation was identified (failure to follow procedures as identified in Paragraph 2.1.(2)).
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Summa ry and _0v_ era,ll,,C_o,n_cl_u_sions Purpose The purpose of this report is to document Region III review of the piping material traceability issue at Braidwood.
In addition, this report documents the actions taken to assure that the Braidwood Material Traceability Verifica-tion Program (MTV) was properly carried out, and to document the review and evaluation of the " Report on Material Traceability Verification at Braidwood",
s dated November 1985, subnitted by Commonwealth Edison Company (CECO).
Backcround A special Region III team inspection, conducted in June, July, August and October of 1983 and during January and February of 1984, resulted in an unresolved item concerning verification of correct heat number traceability for piping and piping components. Specifically, it was determined that Phillips Getschow Company (PGCo) had not been performing documented inspections for correct material usage of piping and piping components at the time of installation and a few instances were identified where material traceability cculd not be readily verified. At the time NRC Inspection Report No. 50-456/
83-09; 50-457/83-09 was issued, the exact extent and significance of the progranr.atic deficiencies were unknown; therefore, this issue was made an unresolved item. As detailed in the CECO response to the inspection report, two actions were taken. The first action was to modify the piping material control and installation procedures to provide documentation of material traceability verification at the point of installation. This action tends to minimize the possibility of recurrence of traceability deficiencies. The second action was to initiate the MTV program. The MTV program contains the following basic elements:
1.
A material verification field walkdown on 100% of piping installed prior to the procedure change.
2.
A Quality Control verification of the field verified heat numbers against the heat numbers in the original stores request.
3.
A Quality Control verification to show that the installed items complied with the design specification.
4.
A Quality Control review of the " stores request" for items which do not have physical identification.
In addition to the concern related to material verification at point of installation, there was a related concern dealing with specific examples of failure to follow the applicable procedures in this area. The MTV Program was also structured to identify these items. Also, the MTV Program was independently reviewed and audited by the National Board of Boiler and Pressure Vessel Inspectors National Board. The Illinois State Division of Boiler and Pressure Vessel Safety also reviewed the program. Both crganizaticns found the program acceptable.
2
Conclusions Based upon the Region III inspections and the review of " Report on Material Traceability Verification at Braidwood," dated November 1985, it is concluded that:
1.
The MTV Program was sufficient to determine the traceability of the items in question.
2.
The MTV procedures and work instructions were implemented properly.
s 3.
All items without the ASME Code required traceability have been removed from the plant.
4.
A number of installed items did not comply with applicable CECO or PGCo procedures.
5.
The original material control system delineated in the PGCo QA manual met the requirements of the ASME Boiler and Pressure Vessel Code (ASME B&PV),Section III.
6.
The physical and chemical tests performed on the items removed (due to lack of traceability) from the plant demonstrate that in fact that the material installed was the correct material and could have performeo its safety function.
7.
Review of documentation indicates that all of the installed items could have performed their respective safety function.
8.
All installed items now have the ASME B&PV Code required traceability; therefore, concerns relative to future 10 CFR Part 21 notifications are resolved.
It is concluded that CECO has taken adequate corrective action to resolse specific instances of failure to follow material control procedures.
- Also, the results as delineated in the CECO " Report on Material Traceability Verification at Braidwood" demonstrate the extent and significance of implementation deficiencies found in this area.
3
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-O TABLE 1 Braidwood Material Traceability Verification Program Chronology of Activities April 1983 PGCo, Audit 83-8R3 identifies findings related to material traceability.
s June 1983 NRC inspection begins; NRC inspectors identify deficiencies in material traceability.
July 1983 CECO issues a 50.55(E) notification concerning material traceability.
March 1984 Enforcement Conference in Region III concerning findings of inspection.
March 1984 NRC Inspection Report No. 50-456/83-09; 50-457/83-09 issued.
February 1985 National Board Audit Team arrives at Braidwood site.
June 1985 D. Gallup, State of Illinois, Superintendent of Boiler and Pressure Vessel Safety, issues letter accepting MTV program.
June 1985 Public meeting held in Region III concerning CECO's plans for MTV program.
July 1985 NRC review and inspection of MTV program starts.
September 1985 National Board Audit Team issues final report on MTV program.
September 1985 NRC Inspection Report No. 50-456/85043; 50-457/85042 issued.
Inspection Report documents review of
" Stores Request."
I October 1985 Taussig Association issues report on test results of
" cut out" items.
November 1985 CECO issues final report on MTV program.
November 1985 NRC Inspection Report No. 50-456/85050; 50-457/85048 issued.
Inspection Report documents independent j
thickness measurements of a sample of installed MTV items.
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December 1985 Region III met with NRC IE and NRR personnel to brief them on the MTV program and Region III conclusions.
January 1986 Telephone conference with the Illinois State Department of Nuclear Safety discussing the Region III evaluation of the MTV program.
January 1986 Region III MTV inspection exit interview at the N
Braidwood site.
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e DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
- M. J. Wallace, Project Manager
- C. W. Schroeder, Licensing and Compliance Superintendent
- D. Shamblin, Project Construction Superintendent, Unit 1 s
- W. Vahle, Project Construction Superintendent, Unit 2
- D. Skoza, Mechanical Field Engineer
- Louis Kline, Supervisor, Licensing and Compliance Department
- P. L. Barnes, Licensing Engineer
- T. Quaka, Site QA Superintendent
- E. F. Fitzpatrick, Station Manager G. E. Groth, Assistant Construction Superintendent
- M. R. Dougherty, Project Construction Engineer
- E. R. Wendorf, Project Field Engineer
- J. F. Phelan, Project Field Engineer
- J. K. Jasnosz, Regulatory Assurance Staff
- T. W. Simpkin, Technical Staff
- D. L. Cecchett, Licensing Engineer
- A. D. Miosi, Nuclear Licensing Administrator
- C. J. Tomashek, Startup Superintendent
- G. F. Marcus, Assistant to Quality Assurance Manager
- L. O. Del George, Assistant Vice President, Engineering and Licensing Phillips Getschow Co. (PGCo)
J. R. Stewart, Project Engineer The inspectors also contacted and interviewed other licensee and contractor employees.
- Denotes those attending the final exit interview at the Braidwood Station on January 9, 1986.
2.
Licensee Action on Previous Unresolved Items (Closed) Unresolved Items (456/83-09-04(a); 457/83-09-04(a):
This item was classified as unresolved until the completion of the MTV program.
This report documents the NRC review of the pertinent issues and activities, a.
ASME Code and Appendix B Traceability Requirements The ASME B&PV Code gives no detailed information either on the specific nature of material control systems or on the type of
' Quality Control inspections required.
The portion of the ASME B&PV Code,Section III, which directly addresses this issue states:
6
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"NA-4441 Establishment and Maintenance of Identification and Control Measures:
Measures shall be established for identification and control of material and items, including partially fabricated assemblies.
These measures shall assure that identification is maintained either on the item or records traceable to the item throughout manufacture or installation.
These measures shall be designed to prevent the use of incorrect or defective items, and items which have not received the required examinations, tests, or s
inspections."
The language of NA-4441 closely parallels Criterion VIII of 10 CFR 50, Appendix B, which states, in part:
"These measures shall assure that identification of the item is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item."
The intent of the material control system is to prevent the installation of incorrect or defective items.
NA-4441 allows a control system which utilizes records traceable to the item.
The PGCo stores request system, as delineated in the QA manual, complied with both the ASME B&PV Code,Section III, and 10 CFR 50, Appendix B, Criterion VIII, prior to identification of the unresolved item.
When properly applied, this material control system provided a record traceable to the item as required.
The discrepancies in the traceability of actual piping and piping components were the result of failure to properly implement the stores request system. -
b.
Review of MTV Procedures Activities performed under the MTV program were controlled by two procedures:
PGCo Procedure QCP-831, Revision 4, " Material Traceability Verification," and PGCo Work Instruction PGWI-17, Revision 3, "QCT Review of MTV Program." The procedures contain five major requirements as follows:
(1) 100% field walkdown for subject piping.
(2) All material identification marking recorded.
(3) Field gathered data compared to stores request for item.
(4) Field gathered data compared to certified material test reports (CMTR) for correct material specification, type, grade, class, size, and schedule.
'(5)
Items found not traceable per stores request or otherwise discrepant identified as nonconforming, and a nonconformance j
report generated for each item.
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PGCo Procedure QCP-831 and Work Instruction PGWI-17 contain an acceptable method for determining the traceability of installed piping and piping components.
In addition, the NRC inspector reviewed PGCo Procedure QCP-B31.1, Revision 1, " Untraceable Material Sampling Program." The purpose of this' procedure is control of untraceable items and control and storage of items removed from the plant.
This procedure provides an acceptable method for controlling these activities.
s c.
Nonconformance Board The MTV program found 792 items to be in nonconformance with applicable procedural requirements.
The disposition of these NCR's were provided by consensus of a nonconformance board consisting of representatives of CECO, Sargent and Lundy Engineers (S&L),
PGCo, the Authorized Inspection Agency (AIA), and generally a member of the National Board Audit Team.
The NRC inspector attended the disposition of a number of nonconforming items.
The NCRs discussed while the NRC inspector was in attendance are as follows:
NCR 2301 NCR 2230 NCR 2183 (Item Removed)
NCR 2179 NCR 3595 NCR 3669 NCR 3729 The disposition of these NCRs was acceptable.
The NRC inspector independently reviewed the NCR packages listed below:
NCR 3720 NCR 3301 NCR 3326 NCR 3161 NCR 3068 i
NCR 3046 l
NCR 3026 NCR 2320 NCR 4873 NCR 4573 NCR 4601 l
NCR 3496 NCR 3423 NCR 2985 NCR 4769 (Item Removed)
NCR 2814 8
r The information contained in the NCR packages coinplied with procedure requirements and the dispositions of the individual items were acceptable.
Of the 792 nonconforming items, it was determined that 647 items, while in nonconformance with PGCo and Ceco procedural requirements, were in' compliance with the traceability requirements of the ASME Code (Braidwood procedural traceability requirements exceeded those of the ASME Code).
The remaining 145 items, listed below, were removed from the piping systems and replaced with traceable material:
s NO.
NCR NO.
MTV ITEM NO.
ASME DESCRIPTION CLASS 1.
1742 MTV #2 2
Rad Access plug CS7-1 2.
1742 MTV #3 2
Rad Access plug CS7-1 3.
1742 MTV #1 2
3"-S/40S Pipe; 18" long CS7-7 4.
1742 MTV #2 2
3"-S/405 Pipe; 5" long CS7-7 5.
1742 MTV #7 2
3"-5/40S Pipe; 19" long CS7-9 (Item Physically Tested) 6.
1831 2
Rad Access Plug CS7-2 7.
1871 MTV #1 2
Rad Access Plug CS23-7 8.
2071 MTC #2 3
4"-S/40 Pipe; 45" long 1ASX92-1 (Item Physically Tested) 9.
2073 MTV #3 2
3"-S/160 Pipe; l'0" long IC-CV-25-4 10.
2085 MTV #2 3
2"-3000# SW 90 EL 2556A-71 11.
2089 MTV #33 3
1-1/4"-3000# SW 90 EL 2556A-35 12.
2089 MTV #34 3
1-1/4"-S/80 Pipe; 2556A-35 4-1/2" long 13.
2131 MTV #4 2
12'-6"X3/4"-3000#
1AC-CC44 Sockolet 9
14, 2131 MTV #5 2
3/4"-3000# SW Plug 1AC-CC44 15.
2133 MTV #8 3
6"-S/40 Pipe; 2" long CC40-1 16.
2133 MTV #3 3
4"-5/40 Pipe; 6'-11" long CC40-12 (Item Physically Tested) s 17.
2176 2
3"-5/405 Pipe; 3" long 1A CS-8-9 18.
2177 2
Rad Access Plug CS-8-FW-5AP 19.
2177 2
Rad Access Plug CS-8-FW-4AP 20.
2183 MTV #A 2
3"-5/40 Pipe; 3'-1" long IC-CC-41 (Item Physically Tested) 21.
2183 MTV #B 2
3-5/40 Pipe; 4'-11" long IC-CC-41 22.
2353 MTV #1 2
3/4"-S/80 Pipe 2" long 2544A-159 23.
2353 MTV #2 2
3/4"-5/80 Pipe 2" long 2544A-159 24.
2376 MTV #11 2
3"-5/405 Pipe; 4'6" long 1A-CS-9-6 (Item Physically Tested) 25.
2434 2
Rad Access Plug CS9-17 26.
2434 2
Rad Access Plug CS9-19 27.
2505 MTV #9 3
2"X3/4" 6000# SW 2537C-32 Reducing Insert 28.
2511 MTV #2 2
3"-S/160 Pipe; 10" long IC-CV-39-10 29, 2516 MTV #18 3
2"X3/4" 6000# SW 2537C-39 Reducing Insert 33 0.
2785 MTV #2 1
Rad Access Plug RH-8-2 31.
2785 MTV #3 1
Rad Access Plug RH-8-3 10
O O
32.
2785 MTV #2 1
Rad Access Plug RH-8-5 33.
2813 MTV #2 1
3"-S/160 Pipe; 4" long CV-10-4B 34.
2813 MTV-#1 2
3"-S/160 Pipe; 4" long CV-10-4D 35.
2828 MTV #12 3
2"-3000# SW45 EL s
2556A-72 36.
2873 MTV #1 2
3/4"-S/160 Pipe; 2539C-84 5'3"long 37.
2873 MTV #3 2
3/4"-S/160 Pipe; 2539C-84 l'9"long 38.
2873 MTV #5 2
3/4"-5/160 Pipe; 2539C-84 10'7"long 39.
2873 MTV #7 2
3/4"-S/160 Pipe; 2539C-84 4'6"long (Item Physically Tested) 40, 2873 MTV #9 2
3/4"-S/160 Pipe; 2539C-84 l'1" long 41, 2875 MTV #7 3
2" 3000# SW 90 EL (FW 7&8) 42.
2875 MTV #14 3
2"-3000# SW 90 EL (FW 15&l6) 43, 2902 MTV #3 3
3/4"-5/80 Pipe; 18" long (FW 3&4) 44.
2917 MTV #23 3
2"-3000# SW 90 EL (FW 20A&21A) 45.
2919 MTV #8 2
3"-5/405 Pipe; 1A-CV-13-3 11-1/2" long 46.
2919 MTV #9 2
3"-S/405 Pipe; 1A-CV-13-3 14-1/2" long l
47.
2919 MTV #10 2
3"-5/405 Pipe; 1A-CV-13-3 2" long l
'48.
2919 MTV #13 2
3"S/40S Pipe; 11" long 1A-CV-13-3 11 1
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49.
2919 MTV #13 2
3"-S/405 Pipe; 39" long 1A-CV-13-3 50.
2919 MTV #14 2
3"-S/405 Pipe; 1A-CV-13-3 3-1/2" long 51.
2919 MTV #15 2
3"-S/405 Pipe; 1A-CV-13-3 2"&24" long N
52.
2930 MTV #1 3
3"-5/40S Pipe; 1A-BRS-5 8-13/16" long 53.
2953 MTV #1 3
3/4"-S/80 Pipe 5" long 2546A-79 54.
2973 MTV #13 3
2"-S/80 Pipe; 3" long (FW16&l7) 55.
2973 MTV #47 3
2"-S/80 Pipe; 1" long (FW35&36) 56.
2984 MTV #3 3
Ring & Bar lug 1A-SX-30-2 57.
2990 MTV #6 2
Rad Access Plug 1A-SI14-3 58.
2993 MTV-#5 3
3/4"-5/80 Pipe 4" long 2537A-65 59.
2993 MTV-#19 3
3/4"-S/80 Pipe 4" long 2537A-65 60.
3027 MTV #9 2
3/4"-S/160 Pipe; 2" long 2546C-61 61.
3027 MTV #15 2
3/4"-S/160 Pipe; 2" long 2546C-61 62.
3126 MTV #5 2
3"-5/40(S) Pipe; 1A-CV-10-3 10-3/4" long 63.
3165 MTV #12 3
s 4"-S/40 Pipe; 2'3" long CC-11-5 64.
3166 MTV #5 2
2 Plates, 2"X6" Welded 2A-CC-31 Attachment 865.
3215 MTV #5 2
Rad Access Plug 1C-FW-14-7 66.
3216 MTV #7 2
3/4"-6000# Coupling PG-2539C-75 12
67.
3221 MTV #4 3
Nailer Ring (SA240)
OA-FC-3AB Welded Attachment 68.
3226 MTV #1 2
6"-S/80 Pipe; 12" long FW38-1 (Item Physically Tested) 69.
3275 MTV #2 2
Rad Access Plug RH-2 70.
3291 MTV #1 2
24"-S/40S Pipe; SI43-2 l'-6" long (Item Physically Tested) 71.
3300 MTV #2 2
Rad Access Plug 1A-RH-4 72.
3318 MTV #3 3
5"-3"X3/4" 3000# SOL CV4-5 73.
3327 MTV #6 3
4"-5/40 Pipe; l'0" long (FP-33-11) 74.
3327 MTV #7 3
4"-S/40 Pipe; 6" long (FP-33-9) 75.
3334 MTV #1 3
1"S/80 Pipe; l'-0" long (FW-15) 76.
3334 MTV #19 3
1"-S/80 Pipe; 4" long (FW-12) 77.
3335 MTV #2 3
4"-S/40 Pipe; 6'6" long FP-20-4 78.
3343 MTV #1 2
4"-5/160 Pipe; 8" long 1A-SI-12-4R 79.
3350 MTV #13 3
2"-S/40 Pipe; 40" long 2537A-104 80.
3350 MTV #11 3
2"-S/40 Pipe; 2537A-104 10-1/2" long 81.
3365 MTV #25 3
1"-S/80 Pipe; l' long (FW34&35) 82.
3365 MTV #27 3
1"-5/80 Pipe; l' long (FW 36&37) 83.
3322 MTV #6 3
6"-S/120 Pipe; 5'4" long 1A-AF-8-3C (Item Physically Tested) 13
84.
3422 MTV #1 3
6"-S/120 Pipe; l'1" long 1A-AF-8-6 85.
3422 MTV #2 3
6"-S/120 Pipe; 10" long 1A-AF-8-6 86.
3432 MTV #2 1
Rad Access Plug RC-16-5 87.
3432 MTV #3 1
Rad Access Plug s,
RC-16-5 88.
3433 MTV #17 3
6"-S/40 Pipe; l'6" long FP-21-5 (Item Physically Tested) 89.
3458 MTV #2 3
Welded attachment lug for AF-16-2 2AF01028R (Item Physically Tested) 90.
3465 MTV #1 3
3"-S/405 Pipe; 6" long CV-7-6 91.
3470 MTV #9 3
4'-5/40 Pipe; 6" long FP-77-7 92.
3474 MTV #2 3
18"0D S/40 Stanchion ISX02061X 93.
3474 MTV #3 3
18"0D S/40 Stanchion ISX02061X 94.
3476 MTV #2 1
Rad Access Plug 2C-51-25 95.
3487 MTV #2 2
3"-S/160 Pipe; 5" long CV-2-12 96.
3488 MTV #1 3
4"-5/40 Pipe; 4'-6" long CC-29-5 97.
3492 MTV #1 2
3/4"-S/405 Pipe; 3" long 2535A-38 98.
3518 MTV #3 2
1/2" closure plate CV33-5 99.
3520 MTV #3 3
2"-3000# 90 EL 2556A-50A 100.
3553 MTV #18 3
2"-3000# 45 EL 2556A-71 101.
3594 MTV #8 3
1-1/2"-300# Flange 2537A-50A 14
1 o
102.
3594 MTV #10 3
1-1/2"-300# Flange 2537A-50A 103.
3594 MTV #11 3
1-1/2"-S/80 Pipe; 2537A-50A 7-1/2"long 104.
3992 MTV #25 2
1/2"-S/160 Pipe; 6" long 1FT-444-2 105.
4022 HIV #1 3
3"-S/40 Pipe; 5" long s
1A-SX-15-10 106.
4032 MTV #6 3
4"-S/40 Pipe; 3-3/8" long 2FH-FP-28-14 107.
4055 MTV #4 2
3"-S/160 pipe; 2A-CV-28-12 7'-10" long 108.
4079 MTV #1 3
4"-S/40 Pipe; 10" long 2A-CC-27-6 (Item Physically Tested) 109.
4100 MTV #1 2
10"-S/40 Pipe; 10" long IC-SX-74-1 110.
4294 MTV #19 3
2"-3000# - 90 EL 2537C-12 111.
4527 MTV #55 2
1"-5/160 Pipe; 2539A-29 l'-10" long (Item Physically Tested) 112.
4587 MTV #2 3
36"-12"X1"-3000#
2A-CC-20-3 Sockolet 113.
4589 MTV #1 3
2"-S/405 Pipe; 29549A-28 l'-10" long 114.
4605 MTV #1 2
14"-S/ST0 Pipe IC-SX-34-8 l'7" long (Item Physically Tested) 115.
4756 MTV #12 2
2"-S/40S Pipe; 2546A-5 Item 90 5'-2" long 116.
4756 MTV #4 2
3"-5/405 Pipe; 9" long 1A-CV-37 Item 8 117.
4756 MTV #1 2
1"-S/405 Pipe; 2539C-44 Item 128 6-1/2" long 118.
4756 MTV #3 2
1"-S/405 Pipe; 2539C-44 Item 73 6'-4" long 15
a 119.
4756 MTV #5 2
1"-S/405 Pipe; 12' long 2539C-44 Item 74 120.
4756 MTV #7 2
1"-S/405 Pipe; 2539C-44 Item 75 12'5" long 121.
4756 MTV #2 2
1"-S/405 Pipe; 4' long 2539C-89 Item 76 122.
4756 MTV #2 2
1"-S/40S Pipe; 4' long 2539C-39 Item 127 123.
4756 MTV #9 1
2"-5/160 Pipe; 3'9" long 2546C-25 Item 68 (Item Physically Tested) 124.
4756 MTV #1 2
2"-S/405 Pipe; 2546A-46 Item 109 5-5/8" long 125.
4756 MTV #3 2
2"-S/405 Pipe; 2546A-46 Item 110 10-5/8" long 126.
4756 MTV #5 2
2"-S/405 Pipe; 2546A-46 Item 111 11-1/2" long 127.
4756 MTV #7 2
2"-S/405 Pipe; 2546A-46 Item 112 10-3/4" long 128.
4756 MTV #8 2
2"-5/405 Pipe; 4" long 2546A-46 Item 93 129.
4756 MTV #12 2
3/4"-5405 Pipe; 3" long 2546A-88 Item 95 130.
4769 MTV #2 2
5"-3"X3/4" - 3000# SOL i
2PC-44A l
131.
4824 MTV #21 3
3/4"-S/405 Pipe; 2546A-2 15'10" long (Item Physically Tested) l 132.
4824 MTV #1 3
3/4"-S/405 Pipe; 4" long i
2546A-2 i
133.
4824 MTV #9 3
3/4"-S/40S Pipe; 5" long 2546A-2 134.
4824 MTV #11 3
3/4"-S/405 Pipe; 5" long 2546A-2 4
- 135, 4824 MTV #13 3
3/4"-5/405 Pipe; 2546A-2 9'11"long l
16
136.
4824 MTV #15 3
3/4-S/405 Pipe; 2546A-2 10-1/2" long 137.
4824 MTV #17 3
3/4"-S/40S Pipe; 2546A-2 4'10" long 138.
4824 MTV #19 3
3/4"S/40S Pipe; 2546A-2 9-3/4" long s
139.
4824 MTV #23 3
3/4"S/40S Pipe; 2546A-2 l'11-1/4" long 140.
4873 MTV #1 3
3/4"-S/405 Pipe; 1" long 2549A-16 141.
4973 MTV #6 1
Rad Access Plug RH14-2 142.
5226 MTV #3 2
2"-S/405 Pipe; 12" long 2546A-92 143.
5226 MTV #22 2
2"-5/405 Pipe; 2546A-92 14-3/4" long 144.
5364 MTV #5 3
4"-S/160 Pipe; CC12-1 13'2" long 145.
5490 MTV #1 2
10"-5/405 Pipe; 11" long CSS-7 d.
Stores Request Review One of the original concerns relative to piping material was the viability of the PGCo " stores request" system as an effective material control system.
To further develop assurance concerning the implementation of the system, the NRC inspector performed a detailed review on the documentation associated with 30 items whose traceability was established by the " stores request" document per the original procedure.
The details of this inspection are contained in NRC Inspection Report No. 50-456/85043; 50-457/85042.
Summarizing the results, "None of the documents reviewed contradicted the licensee's conclusions and in a majority of cases, independent information, other than the stores request was on file in the documentation packages which supported the licensee's conclusion."
Members of the National Board Audit Team reviewed documentation associated with 50 installed items whose traceability was established based on stores request documents only.
The results of their review sare contained in the National Board Supplementary Report dated September 26, 1985, and addressed to Cordell Reed, Vice President, Ceco (" Material Traceability Verification at Braidwood", November 1985, Appendix A), and states "The audit confirmed the integrity of the stores request system."
17
o e
e.
Thickness Measurement of Installed Items As discussed in NRC Inspection Report No. 50-456/85050; 50-457/85048, independent thickness measurements, using an ultrasonic digital thickness measuring device, were taken on six piping systems which contained MTV items. These measurements were taken to confirm that the schedule of the installed piping (wall thickness) complied with the design specification and agreed with the infomation used in the MTV program. Measurements were taken on portions of the following piping systems:
10004AB - Diesel Fuel Oil ICC09AB - Component Cooling Water ICC97AB - Component Cooling Water ISX17AB - Essential Cooling Water 1CCD8AB - Component Cooling Water 10063A - Diesel Fuel Oil All of the measurements taken confirmed the schedule of the installed piping and also confirmed the acceptability of the infomation that was developed by CECO.
In addition, the independent measurements closely agreed with the measurements taken by CECO.
f.
Selection of Samples At a point in time near the completion of the MTV, CECO decided to perform tests on the piping removed from the plant due to lack of traceability. The purpose of these tests was to demonstrate that the untraceable material was in fact, the correct material and therefore the lack of traceability did not impact the ability of the affected systems to function properly. All of the items which were removed (except for 3 items mistakenly lost or scrapped) were subjected to an analysis which determined the chemical composition of the material. Sixteen of the removed items were subjected to physical tests which demonstrated that they conformed to the strength requirements of the applicable specification. Two considerations determined which items were appropriate for physical tests. The first consideration was size; approximately 90 of the removed items were too small for physical testing. The second consideration was the presence of manufacturers' markings. Approxi-mately 30 items, with clear manufacturers' marks identifying material type, did not have the same degree of uncertainty associated with their physical properties, and therefore were not appropriate for physical testing.
The group of items tested contained both carbon steel and stainless steel and both large bore items and small bore items.
In addition, untraceable section of piping in an ASME Class I system was theonly(NCR4756 Item 68). A portion of the testing was witnessed by i tested a NRC inspector.
18
All of the items subjected to the chemical testing conformed to the applicable ASME/ ASTM specifications.
All of the items subjected to the physical testing for strength conformed to the applicable ASME/ ASTM specification.
The final report produced by Taussig Associates, Report No. 64188-1,
" Chemical and Tension Testing of Samples Associated with the MTV Progra9," was reviewed.
A number of the chemical composition results were reviewed by the NRC inspector for compliance with ASME B&PV Code requirements for chemical composition. A number of the s
physical (strength) results were also reviewed by the NRC inspector for compliance with ASME B&PV Code requirements for strength.
All results demonstrated compliance with applicable code strength and composition requirements, g.
Review of Reports As part of the inspections associated with the MTV program, Ceco's Report " Material Traceability verification at Braidwood," the National Board's letter of September 26, 1985, and the Office of the Illinois State Fire Marshall, Division of Boiler and Pressure Vessel Safety letter of June 21, 1985, were reviewed.
Based on the NRC inspections of the MTV program and the review of the CECO's final report, it has been determined that the Ceco final report is an accurate representation of the activities conducted and their results.
In addition, our review of the National Board activities and our review of their letter supports the National Board's general conclusions:
"The Phillips, Getschow quality assurance program, as written, did provide the necessary controls to assure that the work performed by PGCo at the CECO Braidwood Nuclear Power Station met the requirements of the ASME Code and the certified design specification."
"As noted previously in the report, there were implementation deviations from the PGCo quality assurance program's requirements."
"These deviations led to the generation of the MTV program and the resulting revisions to the PGCo quality assurance program and material control procedures."
Duane R. Gallup, Superintendent of Boiler and Pressure Vessel Safety for the State of Illinois, supported the MTV program in his June 21, 1985 letter.
Quoting the letter, "I am satisfied that the corrective action program which Commonwealth Edison Company (Ceco) has undertaken will result in assuring the piping systems at the Braidwood site will be s
in compliance with the requirements of the ASME Code."
19
h.
Safety Significance Evaluation As part of the overall MTV program, a " safety significance" evaluation, composed of calculations necessary to demonstrate compliance with ASME B&PV Code strength requirements, was performed for all the items which were nonconforming due to insufficient traceability.
A random sample of these noncomforming item evaluations (listed below) was reviewed in detail:
N NCR 2085 NCR 2183 NCR 2785 NCR 2873 NCR 2919 NCR 3027 l
NCR 3291 NCR 3350 NCR 3465 NCR 3553 NCR 4294 NCR 4756 NCR 4769 NCR 4873 NCR 5490 In addition, the Sargent and Lundy Report BRF-PMD-01 (November 13, 1985), " Design Significance Evaluation of Braidwood Material Traceability Verification (MTV) Program Cut Out Items" was reviewed.
This report and the disposition of these NCRs were acceptable.
In NRC Inspection Report No. 50-456/83-09; 50-457/83-09, two items were identified which did not have the required schedule of piping installed.
Because these items were replaced prior to the initiation of the formal MTV program they were not included as items in the MTV program final report.
Safety significance evaluations were performed which found that the installed items could have performed their safety function in compliance with the ASME B&PV Code.
The evaluations were reviewed and found acceptable.
i.
Inspection Conclusions Based on the NRC inspections and reviews of the MTV program, the following conclusions have been reached:
(1) The original material control system contained in the PGCo QA manual complied with the requirements of the ASME B&PV Code.
(2) There were a number of instances in which the proper procedure's 8
were not followed.
These are the 792 items identified in the CECO final report as nonconforming.
This is the basis for a violation of 10 CFR 50 Appendix B, Criterion V. (456/85061-01; 456/85057-01).
20
~
(3) The specific instances of failure to follow procedures did not appear to impact the ability of the systems to perform their safety function.
(4) The MTV program was an effective method to determine the traceability of the items in question.
(5) The MTV program was conducted in accordance with applicable procedures, s
(6) 145 Items lacking the required traceability have been removed from the plant and replaced with items which have the required traceability.
(7)
It now appears, based on the results of the MTV program, that the Material Control System originally employed by PGCo was effective to the extent that no items were installed which would have impacted the ability of the piping systems to function properly.
3.
Exit Interview The Region III inspectors met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on January 9, 1986.
The inspectors summarized the scope and findings of the inspection.
The licensee acknowledged this information.
The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection.
The licensee did not identify any such documents / processes as proprietary.
l 1
4 l
l 21 t