ML20214C451
| ML20214C451 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/13/1986 |
| From: | Schultz R, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214C321 | List: |
| References | |
| OL, NUDOCS 8602210143 | |
| Download: ML20214C451 (14) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of COMMONWEALTH EDISON COMPANY
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Docket Nos.
50-456 (Braidwood Station, Units 1 and 2 1
50-457 AFFIDAVIT OF ROBERT D. SCHULZ IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR SUMARY DISPOSITION OF ROREM QA SU8 CONTENTION 6.!
I, Robert D. Schulz, being duly sworn, depose and state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Connission, Region III, as Senior Construction Resident Inspector at the Braidwood Station, Unit 1 and 2.
A copy of my professional qualifications is attached hereto as Exhibit 6.I-1.
2.
As Senior Construction Resident Inspector I am responsible for planning, coordinating, and personally conducting or leading inspections for the construction of Braidwood Station to assure compliance with design specifications, the conditions of the construction permit, provisions of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, and the rules and regulations of the Connission 3.
The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Summary Disposition of Rorem QA Subcontention 6.I.
This subcontention states as follows:
6.
Contrary to Criterion V, " Instructions, Procedures and Drawings," of 10 C.F.R. Part 50, Appendix B, Connonwealth Edison Company fogang g g g g,,
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has failed to ensure that activities affecting quality are prescribed by documented instructions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.
I.
Material installed for the pipe whip restraint plate was not of proper specifications.
- (InspectionReport84-09, Exhibit 22.)
4.
In preparing this Affidavit I reviewed the following documents:
a.
" Statement of Material Facts As To Which There Is No Genuine Issue;"
b.
" Testimony of James R. Stewart (on Rorem Q.A.
,Subcontentions 6.I);"
c.
" Testimony of David A. Boone (on Rorem Q.A. Subcontentions 6.I)."
5.
I identified the item which fonns the basis for this subcontention during a documentation review of the pipe whip restraints documented in NRC Inspection Report Nos. 456/84-09 and 457/84-09, for the period May 1 through June 4, 1984, Ex. 6.I-2.
The noncompliance involved incorrect material installed for reactor coolant whip restraint plate IWR-RC1-6.
6.
At the time of the NRC finding, the piping contractor, Phillips Getschow, was in the process of completing a review of all whip restraint documentation data packs.
The Phillips Getschow review was initiated as
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a result of Applicant audit No. 83-BR22, dated January 24, 1984, which l
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had identified another whip restraint material deficiency. At the time i
of the NRC inspection in May 1984, the piping contractor had not yet documented the results of its review in a nonconformance report or l
corrected the deficiency relating to pipe whip restrain plate IWR-RCI-6.
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---, Consequently, the NRC issced a notice of violation for reactor coolant whip restraint plate IWR-RCI-6. See Ex. 6.I-2.
7.
Applicant initiated the following corrective actions in response to the notice of violation. Applicant documented the installed material for all safety-related whip restraints through contractor inspection. Nonconforming conditions were then properly documented in nonconformance reports. The design engineer determined whether nonconforming whip restraint material should be removed and replaced with the proper material or accepted as installed.
8.
Corrective actions implemented by the licensee to preclude further noncompliances included:
a.
Documented approval by the contractor's engineering organization prior to allowing material substitutions.
b.
Quality control verification of correct material installation, 9.
I closed this item in Inspection Report Nos. 456/85-15 and 457/85-16 (pertinent portion attached as Exhibit 6.!-3) based on verification that reactor coolant whip restraint plate 1WR-RCI-6 was replaced per Field Change Order No. IRC-7592 with the correct material, and that an audit was performed by the piping contractor which identified and properly dispositioned six other material deficiencies.
Since all whip restraint material was audited by the piping contractor and nonconforming conditions were identified and properly dispositioned I
determined that whip restraint material usage does not pose any safety problem.
This item of nonconformance does not represent a significant
i breakdown of the QA/QC Programs of Comonwealth Edison or Phillips Getschow.
p2-Ap TM Robert D. Schulz /
Sworn ang subscribed before me this /J day of February, 1986
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Notary Public n
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Professional Qualifications ROBERT D. SCHULZ Organization:
U.S. Nuclear Regulatory Comission, Region III
Title:
Senior. Resident Inspector of Construction Birth Date:
June 9, 1948 Education:
B.S., Northern Illinois University,1970 Completed BWR Technology Courses and Two-Week FWR Technology Course, Chattanooga, TN Experience:
1984 to Senior Resident Inspector (Construction) -
Braidwood Site.
Plans, supervises and conducts Present inspections at the site.
Represents the NRC to the licensee state and local officials, and the news media.
NRC) 1983 to Reactor Inspector - Inspects reacters under 1984 construction and in operation.
(NRC) 1982 to Senior Resident Inspector - Nine Mile Point Plant, 1983 Region I, Construction Site.
Plans, supervises and conducts inspections at the site. Represents the NRC to the licensee, state and local officials, and the news media.
(NRC) 1981 to Resident Inspector - Nine Mile Point Plant, Region I, 1982 construction Site.
Performed 2513 and 2514 inspection programs at,the Nine Mile Point Plant.
(NRC) 1980 to Reactor Inspector - Inspected reactors under construction and in operation in Region !!!.
1981 (NRC) 1975 to 0.A. Engineer - Morrison Construction and Engineering, LaSalle Station. Braidwood 1980 Township, IL. Mechanical Contractor.
1973 to Senior Buyer - Sundstrand Nuclear, Belvidere, IL.
1975 Purchased material for the Fast Flux Test Facility located in Hanford, Washington.
1971 to Quality Control Inspector - Morrison Construction
$t. 6. [- l.
1973 and Engineering, Zion Station, Zion, IL.
Mechanical Contractor.
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U.S. NUCLEAR REGULATORY COMMISSION
'd REGION III Report No. 50-456/84-09(DPRP); 50-457/84-09(DPRP)
Docket Nos.50-45C;.50-457
]LicensesNo.CPPR-132;CPPR-133 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, 11 60690 Facility Name:
Braidwood Nuclear Power Station, Units 1 and 2 Inspection Conducted:
May 1 through June 4, 1984 Inspectors:
L. G. McGregor R. Schulz
'.h,
N Approved By:
W. 'ftfrney, Ch og 6/J 9 /M Projects Section 1A Date
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Inspection Summary Inspection on May 1 through June 4. 1984 (Report No. 50-456/84-09(OPRP):
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50-457/84 dMSDRP))
Areas Inspected:
Routine, unannounced safety inspection of lic usee action e previous inspection findings, work activities observed during plant tours, safety related piping, whip, restraints, piping post weld heat treatment, piping material verification program Fleid Change Requests, electrical installations, structual steel drawing control, craft training, safety related equipment, and preoperational test performance.
The inspection consisted of 292 inspecter-hours onsite by two NRC inspectors including 30 inspector-hours onsite during off shifts.
Results:
Of the twelve areas inspected, no items of noncompliance or deviations were identified in ten areas; one item of noncompliance was identified in each of the remaining areas (falturt to stipulate physical clearance criteria -
Paragraph 3; fallere to install the correct whip restraint plate - paragraph 5.
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Attributes checked included: quality of the welds, identification of the 4
weld and welder, and identification of the spool piece.
Subsequently.
documentation was examined for the following welds and associated spool pieces:
- System Weld No.
Spools Size.
ASME Class Main Steam FW-4 MS-18-3/MS-18-4 32.75" 2
Main Steam FW-5 MS-18-5/ Penetration 86 32.75" 2
Main Steam FW-3 MS-17-2/MS-17-3 32.75" 2
i Main Steam FW-4 MS-17-3/MS-17-4 32.75" 2
Feedwater FW-6 FW-15-3/ Penetration 84 16" 2
Feedwater FW-6 FW-16-3/ Penetration 87 16" 2
4 Documentation reviewed included verification of material requisitions, 1
welding material test reports, fit-up inspections, root weld inspections, final weld inspections, code data reports, magnetic particle test reports, and radiographic inspection reports.
The inspector discovered that FW-5, repair 2, radiographic inspection report for film view 43-53, stated, " Foreign material inside pipe in area of interest.
Does not interfere with interpretation." When foreign material is identified inside of pressure boundary piping it should be documented as to what the object or foreign material consists of and then i
appropriately dispositioned, such as removal of foreign material or accept as is. The inspector requested the licensee to investigate this parti-cular radiographic inspection report and others that may not have properly l
documented the nature of foreign material.
Pending licensee and further NRC review this issue will remain unresolved (456/84-09-02; 457/84-09-02).
i No items of noncompliance or deviations were identified.
1 5.
Whip Restraints i
The inspector examined whip restraints,1WRMS P7 and 1WRMS P15, in the Unit 1 containment at elevation 395', and noticed that washers had not i
i been installed for the ASTM A490 high strength bolts, as required by 1705, Standard Specification For Erection of Structural Steel.
These bolting i
connections had not been examined and accepted by Phillips, Getschow Co.
However, a review of the Phillips, Getschow quality control inspection program revealed that inspections to determine that washers were installed for high strength bolt connections were not required to be done.
The i
inspector brought this to the attention of the licensee and the licensee responded that all whip restraint high strength bolting connections would be inspected or re-inspected to assure correct washer installation.
i Pending these inspection efforts, which will determine if any connections had been -inspected and accepted without washers installed, this issue will remain unresolved (456/84-09-03; 457/84-09-03).
In addition, the inspector reviewed Comonwealth Edison Audit, QA-20-84-508, which identi-fled that Phillips, Getschow whip restraint installation is inadequate l
in that documentation of high strength bolt tightening was not required.
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Corrective action to be undertaken includes verification of tightening for all previously installed connections.
Tnis is an open item (456/84-09-04; 457/84-09-04).
Documentation for safety-related whip restraints 1WR-RCl-6 and 1MS-P11
_ was reviewed, including stores requests, material test reports for installed steel, filler metal test reports, weldit.g procedures, and installation inspection reports.
The inspector determined that drawing 1WR-RCl-6 (Revision A), Field Change Order #5497, data sheets for field weld 12 and field weld 14, and Specification for Pipe Whip Restraints F/L-2909 required ASTM A572 GR.50 plate material.
The inspector verified through documentation and by a physical inspection of the reactor coolant whip restraint, 1WR-RCl-6, that ASME SA-516 GR.60 material was installed.
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This is in violation of 10 CFR 50, Appendix B, Criterion V (456/84-09-05; 457/84-09-05).
Phillips, Getschow Audit #83-BR22 had identified that material substitutions were made by craft personnel during whip restraint installation without the knowledge of field engineers.
The NRC inspector identified that quality control inspectors had not been involved in verifying and documenting acceptable substitute material installations.
Pending Phillips, Gelschow quality control inspections of all substitute material installed, and documentation of correct or incorrect material installations, this issue will remain unresolved (456/84-09-06; 457/84-09-06).
6.
Piping Post Weld Heat Treatment The following documents were reviewed:
PGCP-41, Revision 3, Control of Preheat and Interpass Temperature and Post Weld Heat Treatment Welding Procedure Specification 1A-MA-13, Revision 3.
The documents were in accordance with the ASME Boiler and Pressure v'assel Code,Section III and Section IX,' 1974.
However, the inspector noted that although certified thermocouples and calibrated strip chart recorders were being used during post weld heat treating operations, Procedure PGCP-41 did not require the use of certified thermocouples or calibrated strip chart recorders.
The inspector brought this to the attention of the licensee, who immediately revised the procedure to require certified thermocouples and calibrated strip chart recorders.
The inspector con-siders this issue closed.
Actual heat treat recording charts were reviewed for the following post weld heat treated components:
Feedwater nozzle to Steam Generator IRC01BD l
Feedwater nozzle to Steam Generator IRC01BC l
Steam Generator Outlet Nozzle 2A, MS-60-1.
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U. S. NUCLEAR REGULATORY C0tttISSION REGION III 4
Reports No. 50-456/85015(DRP);50-457/85016(DRP)
Docket Nos. 50-456; 50-457 Licenses Nos. CPPR-132; CPPR-133 Licensee: Connonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Namei Braidwood Nuclear Power Station, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted: March 25 through May 3, 1985 Inspectors:
R. D. Schulz W. J. Kropp R. N. Gardner a
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Approved By:
W. S.
itti, Director
[f5.b-Braidwood Project D(te /
Inspection Sunnary Inspection on March 25 through May 3, 1985 (Report No. 50-456/85015(DRP);
50-457/85016(DRP))
l Areas Inspected:
Routine, unannounced safety inspection of activities with regard to licensee action on previous inspection findings and 10 CFR 50.55(e) reports, followup on allegations, plant tours, nonconformance reports / corrective action, safety-related piping, containment coatings, instrumentation, electrical equipment installations, and the Quality Control Inspector Reinspection Program.
The inspection consisted of 352 inspector-hours onsite by three NRC inspectors including 30 inspector-hours onsite during off-shifts.
Results: Of the nine areas inspected, no items of noncompliance or deviations were identified in five areas, one item of noncompliance was identified in each l
of the remaining four areas:
failure to adequately control structural beam modifications (paragraph 4); failure to take adequate corrective action for i
pipe support nonconfonning conditions (paragraph 5); inadequate review of con-I box installation (paragraph 9) graph 7); and inadequate inspection of junction tainment coating process (para v'
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A The inspectors also contacted other licensee and contractor personnel, t,
including craftsmen, and technical and engineering staff members.
- Denotes those attending the exit meeting on May 3, 1985.
2.
Licensee Action on Previcus Inspection Findings and 10 CFR 50.55(e)
Reports a.
Noncompliance (Closed) 456/84009-05; 457/84009-05:
Incorrect material installed for reactor coolant whip restraint plate IWR-RCl-6. The plate was replaced per Field Change Order ho. IRC-7592 with the correct material.
In addition, an audit was performed by the piping con-tractor and six other material deficiencies were noted and properly dispositioned.
b.
Unresolved Items (Closed) 456/83009-05; 457/83009-05:
In 1983 the inspector identified a concern with the qualification and certification of the licensee's i
auditors.
Based on audits reviewed by both the resident inspectors and Construction Appraisal Team personnel in 1964, it was determined i
that the training and knowledge level of the auditors has signifi-cantly increased.
Present audits are adequate in both scope and depth. The ' manager of Quality Assurance approves all auditors for 7
4, specific qualification areas and early in 1984 an experienced individual was added to the staff with sole responsibility for audit l
coordination. A qualification auditor matrix is maintained with documented evidence of qualifications.
(Closed) 456/83009-11; 457/83009-11: Welding discrepancies were identified on HVAC hanger No. 2210, hanger No. 2221, duct to flange e
connection (sheet 4033), and an actuator motor hanger bracket. All of the identified discrepancies were satisfactorily resolved through HVAC correction notices. The applicable correction notices were identified as Nos. 4463, 2826, 2844, 4461, and 4435.
l (Closed) 456/84009-03; 457/84009-03: Whip restraint inspections to detennine that washers were installed for high strength bolting were.
not required to be done. A retro-fit prcgram has been implemented to assure that the washers are installed per specification requirements.
In addition, a licensee hold point was placed on all ASTM A-490 bolted connections to allow site quality assurance to witness bolt I
tightening.
(0 pen) 456/84009-09; 457/84009-09: Lack of a documented training program for craft personnel. The licensee presented this item to the NRC for closure based on documented records of craft training.
Although craft training records were available, the licensee had not established a formal program identifying the specific training q
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SUBCONTENTION 9.A Subcontention 9.A, as admitted in the proceeding, states:
9.
Contrary to Criterion IX, " Control of Special Processes," of 10 C.F. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures are established to assure that special processes, including welding are controlled and accomplishad in accordance with applicable codes, standards, specifications, criteria and other special requirements.
A.
127 safety-related structural steel fillet welds were painted prior to acceptance of the work and the welds were subsequently visually inspected for acceptance, with 79 accepted in the painted condition.
In addition, visual weld inspections were not performed on safety-related full penetration welds completed under the jurisdiction of Structural Specifications R/L-2735 and F/L-2722 prior to May 1, 1984.
The welds were accepted based on other methods of nondestructive examination, but were not accepted in accordance with the requirements of Section 8.15, Quality of Welds, Visual Inspection.
In its Motion for Sumary Disposition, Applicant acknowledges that the events set forth in the first part of the subcontention constitute a violation of Criterion IX of 10 C.F.R. Part 50, Appendix 8.
See Applicant's Motion 9.A at 1.
Applicant contends, however, that this violation is an isolated occurrence having no safety significance.
Id.
l The Staff agrees.
The violation at issue -- the visual inspection and acceptance of painted fillet welds -- was identified by Region III NRC Inspector R.D.
Schulz. See Affidavit of John M. Jacobson In Support of NRC Staff's Response to Applicant's Motion for Summary Disposition of Rorem QA Subcontention 9.A at 16 (hereinafter "Jacobson Affidavit"). As NRC Inspector Jacobson indicates, during a review of Pittsburgh Testing Laboratories' (PTL) documents, NRC Inspector Schulz identified 120 fillet welds that had been visually inspected by PTL quality control inspectors even though the welds had been painted prior to inspection. M. Visual inspection of a painted weld is inconsistent with the requirements of Section D1.1 of the AWS Structural Welding Code (1975) to which Applicant is committed in its FSAR.
See Notice of Violation, 17, attached as Ex.9.A-2 to Jacobson Affid.nvit.
Applicant undertook a number of corrective measures to remedy this violation.
First, a complete (i.e., 100%) review of the visual weld inspection reports was performed to determine the extent of this activity. See Jacobson Affidavit at 17. This review indicated that only six visual inspections of painted welds were performed.
Five of these inspections had been performed by a single inspector during a nine-day period in January 1980. Jacobson Affidavit at 17. The sixth visual inspection of painted fillet welds was performed by a different inspector. Jacobson Affidavit at 18. This latter group, however, was not l
accepted solely on the basis of the inspector's visual inspection. The l
inspection report indicates that ecch of the accepted welds was subjected l
to, and passed, a magnetic particle examination. Jacobson Affidavit at i
- 18. Consequently, for this group of welds there was an independent basis upon which to conclude that the welds were acceptable. Nevertheless, the l
Applicant issued Nonconformance Report No. 774 upon discovering this group of fillet welds had been visually inspected after being painted.
l Jacobson Affidavit at 18.
Nonconformance Report No. 774 required that
i 1 the paint on the subject welds be removed and the welds be reinspected by visual and magnetic particle examination. Jacobson Affidavit at 18.
Similarly, the welds involved in the five inspections performed in January 1980 by the PTL inspector were all reinspected after the paint had been removed. Jacobson Affidavit at 19. All welds that did not conform to design requirements either were reworked or evaluated to determine whether they were acceptable "as-is."
Jacobson Affidavit at 19.
Finally, to prevent future visual inspections of painted welds, Applicant, in May 1984, issued a directive to PTL expressly forbidding this practice. Jacobson Affidavit at 19. There has been no identified a
recurrence of this practice since that time. See Jacobson Afficavit at 110.
The facts recounced above demonstrate that the violation which forms the basis of Rorem Subcontention 9.A is an isolated occurrence which has been corrected.
It is on that basis that the NRC Staff closed this violation in Inspection Report Nos. S0-456/85050 and 454/853039 (attached as Ex. 9.A-4 to Jacobson Affidavit).
Applicant has in place adequate measures to assure that special processes, including welding, are controlled and acco~mplished in accordance with applicable requirements as required by 10 C.F.R. Part 50, Appendix B, Criterion IX. Therefore, there are no genuine issues of fact to be heard regarding this subcontention and Applicant is entitled to a favorable decision on this subcontention as a matter of law.
Consequently, Applicant's Motion for Summary Disposir:on of Rorem Subcontention 9.A should be granted.
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