ML20214C468

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Affidavit of Jm Jacobson Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 9.A.Related Info Encl
ML20214C468
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 02/13/1986
From: Jeffrey Jacobson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214C321 List:
References
OL, NUDOCS 8602210148
Download: ML20214C468 (16)
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Text

UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

COMMONWEALTH EDISON COMPANY ^) Docket Nos. 50-456

) 50-457 (Braidwood Station, Units 1 and 2 )

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 I, John M. Jacobson, being duly sworn, depose and state as follows:

1. I am employed as a Reactor Inspector (Metallurgical Engineer) in the Division of Reactor Safety by the U.S. Nuclear Regulatory Comission (NRC), Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137.

I have been employed by the NRC in this capacity since June 10, 1984. A copy of my professional qualifications is attached hereto as Exhibit 9.A-1,

2. As 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.

3. The purpose of this Affidavit is to support the NRC Staff's Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 9.A. This subcontention states:
9. Contrary to Criterion IX, " Control of Special Processes," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures be established to assure that special processes, including welding, are controlled and accomplished in accordance with G

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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 F/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.

4. Rorem Subcontention 9.A actually consists of two parts: (1) the alleged visual inspection of painted fillet welds and (ii) the alleged failure to perform visual inspections on certain full penetration welds. Sunnary disposition is sought by Applicant only with respect to the first part of Rorem Subcontention 9.A. It is to that part of the subcontention that this Affidavit is addressed.
5. In preparing this Affidavit I reviewed the following documents:
a. Applicant's Statement of " Material Facts As To Which There is No Genuine Issue to be Heard;"
b. Inspection Report Nos. 50-456/84021 and 50-457/84020;
c. Aprlicant's Response to Inspection Report Nos.

50-456/84021 and 50-457/84020;

, d. Pittsburgh Testing Laboratories (PTL) Nonconformance Report No. 191 (Rev. 1);

e. CECO Nonconformance Report No. 774.
f. Inspection Report Nos. 50-456/85040 and 50-457/85040.

.. . = . - - . _ - . _ .

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6. The violation which forms the basis of Rorem Subcontention 9.A '

was identified during a review of PTL documents by Region III NRC Inspector R. D. Schulz. During this review, the NRC inspector identified 120 fillet welds that had been visually accepted even though the welds had been painted prior to inspection. This was deemed a violation of 10 C.F.R. Part 50, Appendix B, Criterion IX. This violation is described more fully in Inspection Report Nos. 50-456/84021 and 50-457/84020, the i

pertinent portion of which is attached as Exhibit 9.A-2 to this affidavit.

7. In its January 31, 1985 Response, Applicant acknowledged that certain structural steel fillet welds wer'e painted prior to visual inspection. See Exhibit 9.A-3. To remedy this violation, Applicant took several corrective actions. First a complete (100%) review of the structural contractor's visual weld inspection reports was conducted by PTL to determine the extent of this activity. Only six visual inspection reports indicating that the inspector had visually accepted a painted weld were found. This review indicated that five of these inspections had been performed by one PTL inspector during a nine day period in January 1980.

l 8. The other visual inspection report indicated that another inspector had visually inspected painted welds; these welds, however, were not accepted until after they underwent a magnetic particle inspection. Nevertheless, after learning that painted welds had been visually accepted, Applicant issued Nonconformance Report No. 774. This

NCR directed that the paint on the subject welds be removed and the welds be reinspected by visual and magnetic particle examination.

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9. Visual inspection reports 709, 711, 713, 716, and 717 also '

covered welds that had been visually accepted after painting. As noted in Paragraph 7, all of these inspections were performed by one PTL inspector during a nine day period in January 1980. To remedy this violation, PTL issued Nonconformance Report No. 191 (Rev. 1) which directed that the paint on the subject welds be removed and the welds

. visually reinspected. During this inspection, a small number of welds required design review due to inaccessibility and insufficient length.

Nonconfonnance reports were issued to provide the required design input for disposition of these welds. All remaining welds were accepted "as-is" or reworked as required. To prevent this violation from recurring, in May 1984, Applicant issued a letter to PTL directing all future visual inspections to be performed before the subject weld is painted.

10. I have reviewed and evaluated the corrective actions taken by PTL and the Applicant in response to the violation identified in the first part of Rorem Subcontention 9.A. Based on my review of PTL Nonconformance Report 191 (Rev. 1) and related documentation, and CECO Nonconformance Report 774, I am satisfied that this matter has been resolved. To my knowledge no other instance in which a painted weld was visually inspected has been identified.
11. I closed this violation in Inspection Report Nos. 50-456/85040 and 50-457/85039 (the pertinent portion of which is attached hereto as Exhibit 9. A-4). The basi.; upon which I closed this violation was the effective implementation of Applicant's corrective actions. In view of the circumstances relating to this matter which I have described in this

. Affidavit, I am satisfied that the violation which foms the basis of '

Rorem Subcontention 9.A is an isolated case and does not represent a significant breakdown in the Applicant's quality assurance program.

12. Accordingly, I agree with Applicant that there is no genuine issue to be litigated with respect to the first part of Rorem Subcontention 9.A.

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/ John M..Jacobson

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Sworn and subscribed before me this/3"' day of February,1986 1.u N, k s - . u d' -

Notary Public My Commission expires: ~

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i ShW TH 1 Professional Qualifications #

JOHN M. JACOBSON Organization: Region III

Title:

ReactorInspector(Metallurgist)

Birth Date: May 25, 1949 Education: B.S. Metallurgical Engineering, University of 1975 Experience:

1984 - Present Reactor Inspector, Division of Engineering - Respon-sible for routine and reactive inspections and investigations of reactor plants under construction and operating. (NRC) 1982 - 1984 Senior Consultant - Responsible for providing senior consulting services in the areas of welding metallurgy, materials, engineering, welding program development and field operations. (Nutech Engineers).

1980 - 1982 Senior Welding Engineer - Responsible for welding procedure development, resolution of metallurgical / welding issues for both shop and field fabrication of nuclear containments. Duties included responsibility for the Metallurgical Laboratory and numerous research and development programs. (Graver Energy Systems) 1977 - 1980 Maintenance Staff Engineer - Responsibilities included coordination and development of station welding programs, preparation of maintenance and repair procedures, design of plant modifications and technical direction of large scale maintenance projects. (Commonwealth Edison, Dresden Nuclear Power Station) 1975 - 1977 Quality Assurance Engineer - Responsible for review of contractor's procedures, daily monitoring of welding and erection activities of the LaSalle County Nuclear Power Station, review and acceptance of NDE results and auditing of supplier's facilities.

(Comonwealth Edison, LaSalle County Nuclear Power Station)

Ibihf.k"E U. S. NUCLEAR REGULATORY COMMISSION P

REGION III Report No. 50-456/84-21(DRP); 50-457/84-20(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: September 4 through October 5, 1984 Inspectors: L. G. McGregor R. Dqphulz s Approved By: L. k Projects Section lA hief Date ll Ik (9 Inspection Summary Inspection on September 4 through October 5, 1984 (Report No. 50-456/84-21(DRP);

50-457/84-20(DRP))

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Areas Inspected: Routine, unannounced safety inspection of licensee actions on previous inspection findings; licensee actions on 50.55(e) reports; plant tours; material traceability verification program; welder qualification; heating, ventilation and air conditioning systems; reactor coolant piping; preoperational test procedure reviews; preoperational test performance; radio-graphic incident; cleanliness inspections of piping and safety-related components; and design changes to reactor coolant pump lateral supports. The inspection consisted of 233 inspector-hours onsite by two NRC inspectors including 128 inspector-hours onsite during offshifts.

Results: Of the twelve areas inspected no items of noncompliance or deviations were identified in eight areas; one item of noncompliance was identified in each of the remaining areas (paragraph 2, failure to properly perform wald inspections and failure to perform visual weld examinations; paragraph 5, failure to report minimum wall defects; paragraph 12, failure to perform cleanliness inspections; and paragraph 13, failure to adequately complete a plant re-design).

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K. Vilt, Office Manager T. Voght, Corporate Welding Engineer -

T. Simile, Welding Engineer Pullman Sheet Metal D. Grant, Site Quality Assurance Manager G. Minor, Quality Control Supervisor T. Brooks, Quality Assurance Director

M. Farner, Quality Tssurance Supervisor
  • Denotes those persennel attending the exit interview.
2. Licensee Action on Peeviously Identified Items Two issues (unresolved item 456/84-09-10; 457/84-09-10, and open item 456/84-09-08; 457/84-05-08) were presented to the inspector for closure, ,

i but subsequent investigation by the inspector revealed that these items I

were not ready for closure.due to the lack of documentation. The licensee is re evaluating these two issues.

a. Unresolved Items Resulting in Violations (Closed) 456/84-08-03; 457/84-08-03: The inspector identified in i Inspection Report 84-08, that some visual weld inspections had been performed after the weld joints were painted. The NRC inspector requested the licensee to investigate this issue and determine the

, number of welds inspected after being painted. Subsequent review j determined that 120 fillet welds had been inspected for acceptability i

after they were painted and were identified in visual inspection reports 709VW, 711VW, 713VW, 716VW, and 717VW. This is a violation of 10 CFR 50, Appendix B, Criterion IX and the AWS D1.1, Structural Welding Code (456/84-21-01; 457/84-20-01). The inspector also stated in Inspection Report 84-08 that when a full penetration, weld was nondestructively examined, it appeared that the final visual weld inspection was waived. Subsequent review during this inspection period verified that final visual weld inspections had not been performed for full penetration welds completed prior to May 1, 1984, as required by Structural Steel Specifications F/L-2735 and F/L-2722 and AWS D1.1, 1975; however, the welds were accepted based on other nondestructive examinations such as magnetic particle or liquid penetrant tests. Visual examinations are intended to identify factors such as correct location, size, and length of welds or if any unspecified welds have been added which may not be identified by other methods of nondestructive examination. Furthermore, nondes-tructive examinations, such as ultrasonic, magnetic particle, or liquid penetrant, do not contain acceptance criteria that meet the requirements of AWS DI.1, Structural Welding Code, Section 3, Section 6, and Section 8.15, with regard to visual inspections. Failure to perform visual inspections is a violation of 10 CFR 50, Appendix B, Criterion IX and the AWS DI.1, Structural Welding Code (456/84-21-02; 457/84-20-02).

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  • Commonwealth Edison j one First National Ptara Chago minois l Address Reply to. Post Ottice Box 767 Chicago. Encis 60690 ,

January 31, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Braidwood Station Units 1 and 2 Responsa to Inspection Reports Nos.

C10-456/84-21 and 50-457/84-20 NRC Docket Nos. 50-456 and 50-457 Referennce (a): R. F. Warnick letter to Cordell Reed dated November 20, 1984

Dear Mr. Keppler:

This letter is in response to the inspection conducted by Messrs. L. G. McGregor and R. D. Schulz on September 4 through October-5, 1984, of construction activities at Braidwood Station.

Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. Our response to these items is provided in the enclosure to this letter. As noted in Reference (a),

no response to the Notice of Violation Item 3 was required. However, we are submitting a response in order to clarify our position on this is. sue. The delay in providing this response was discussed with Messrs. R. F. Warnick and P. R. Pelke of your office on December 17, 1984, and January 16, 1985, respectively.

Should you or yoUr staff have any questions regarding this matter please contact this office.

l Very truly yours q l

L y_

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Dennis L. Farrar Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector FEB 51MXi

hNU ENCLOSURE COMMONWEALTH EDISON COMPANY

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50-456/84-21 AND 50-457/84-20 ITEM 456/84-21-01 AND 457/84-20-01 ITEM 456/84-21-02 AND 457/84-20-02 ITEM OF NONCOMPLIANCE

1. 10 CFR 50, Appendix B, Criterion IX, states in part: " Measures shall be established to assure that special processes, including welding . . . are controlled and accomplished . . . in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Commonwealth Edison Company FSAR, Volume 7, and Sargent and Lundy Structural Steel Specifications, F/O-2735, Structural Steel and F/L-2722, General Structures Work, commit to AWS Dl.1, 1975, Structural Welding Code.

AWS Dl.1, Structural Welding Code, states in part, in Section 3.10: " Welded joints shall not be painted until after the work has been completed and accepted". Section 6.5.1 of AWS Dl.1 states: "The Inspector shall make certain that the size, length, and location of all welds conform to the requirements of this code and to the detail drawings, that no specified welds are omitted, and that no unspecified welds have been added without approval."

Section 6.5.5-states in part that the Inspector shall examine the work to make certain that it meets the requirements of Section 3, i

Workmanship and Section 8.15, Quality of Welds. Section 8.15.1, Visual Inspection, states in part: "All welds shall be visually inspected."

Contrary to the above:

a. One hundred and twenty 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. The welds are identified in visual inspection reports 709VW, 711VW, 713VW, 716VW, and 717VW.
b. Visual weld inspections which identify acceptable workmanship, size, length, location of welds, and that no unspecified welds were added, were not performed on safety-related full penetration welds completed under the jurisdiction of Structural Specifications F/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, N

1.f.d*3 ITEM 456/84-21-01 AND 457/84-20-01 ITEM 456/d4-21-02 AND 457/84-20-0?

RESPONSE - PART la Commonwealth Edison agrees that certain structural steel fillet welds were painted prior to acceptance of work.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED - PART la At the time of the original inspection by the NRC and the identification of this area as an unresolved item (456/84-08-03; 457/84-08-03) the Independent Testing Lab initiated NCR No. 191 to disposition the inspections performed through paint. A 100%

review of the affected records was performed. Only Visual Weld Reports 709, 711, 713, 716, and 717 enecmpassing the 122 welds were identified as being performed through paint. The paint was removed and a reinspection was performed. This inspection determined that 23 of the 122 welds reinspected required repair, i

Two welds were found to be inaccessible for reinspection. One was documented and dispositioned on Commonwealth Edison Company NCR No. 628 and the other was documented on Commonwealth Edison Company NCR No. 700.

CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE - PART la The review of the affected reports determined that inspection of structural welds "through paint" occurred during a one week period in 1980 and was limited to the five reports identified.

l To prevent recurrence, the Independent Testing Lab has.been directed to perform first line weld inspections only in the unpainted condition.

DATE OF FULL COMPLIANCE - PART la Completion of repairs and reinspection of the subject welds is expected by May 1, 1985.

(R/ u- 4'  :

U.S. NUCLEAR REGULATORY COMISSION REGION III Reports No. 50-456/85040(DRS);50-457/85039(ORS) ,

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 l Licensee: 'Cosmonwealth Edison Company i Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: August 19, 22, September 17-19, and October 3-4, 16-18, 24, 1985 W

Inspectors- . Jacobson is2a//4-Date YWE J. Muffett 'l[?h6,5 Date l: - -

Approved By: D. N. Danielson, Chief ##/12//T Materials and Processes Section Date j Inspection Summa _ry l Inspection on August 19, 22 September 17-19, and October 3-4, 16-18, 24, 1985 (Reports No. 50-456/85040(DRS): 50-457/85039(DRS) 1 -

Areas Inspected: Announced safety inspection of licensee actions concerning previous inspection findings and one 50.55(e) item. The inspection involved a total of 122 inspector-hours by two NRC inspectors.

Results: No violations or deviations were found.

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h.?A~Y Welder No.11 again left the jobsite and returned on May 23, 1983. He was retested on this date and failed to requalify.

Based on th'e above review, Welder No.11 was properly qualified j during the periods in which he performed safety related welding for 1

L. K. Comstock

c. (Closed) Violation (456/84021.-01; 457/84020-01): Safety-related structural steel fillet welds were visually examined for acceptance '

i in the painted condition. A 100% review of the Napolean (structural centractor) Visual Weld Reports w&s conducted by Pittsburg Testing

! Laboratory (PTL). Visual Weld Report Nos. 709, 711, 713, 716, and l 717 encompassing 122 welds were identified as being performed through

paint. These inspections were perfomed by a single inspector during

! a nine day period in 1980. These inspections were performed through paint at the direction of Ceco Site Quality Assurance and are deemed

, to be an isolated occurrence. All paint was removed and the welds were reinspected to correct this deficiency. To prevent recurrence, 1 PTL was directed to perform first line weld inspection only in the ,

unpainted condition. The NRC inspector reviewed PTL Nonconformance Report No.191, Revision 1 documenting the resolution of this item

! and found it acceptable.

! d. (Closed) Violation (456/83009-10(c); 457/83009-10(c)): Pullman l Sheet Metal (PSM) Procedure B10.2.F " Visual Weld Inspection", did

! not require a documented inspection of base metal surfaces and edges +

l prior to welding. Section 3 of the AWS D1.1-77 Code, entitled ,

t " Workmanship," states in part that surfaces and edges to be welded t shall be smooth, uniform, and free from discontinuities which would adversely affect weld quality.

PSM procedures require inspection of shop fabricated items at the time of shipping and inspection of materials for field fabricated

, items at the time of receipt at the Braidwood site. Jobsite 3

fabricated items are saw cut, which virtually eliminates the likelihood of irregular edges. In addition, the PSM welding procedures require inspection of the welding surface by the welder before welding is commenced.

To further demonstrate weld quality, the licensee performed a weld sample test program. The sample program consisted of tensile tests on 82 welded joint samples removed from the HVAC as-welded construction at the Braidwood Station. The results of this test program demonstrated that test failure loads were larger than the design allowable loads by at least 50%.

Based on a review of the above information and an inspection of in excess of 300 HVAC welds performed by the NRC inspector, it was .

concluded that the lack of a documented inspection of base metal surfaces and edges prior to welding had no design significant effect on weld quality.

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SUBCONTENTION 9.C -

. Subcontention 9.C, as adnitted in the proceeding, states:

9. , Contrary to Criterion IX, Control of Special Process, 10 C.F.R Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures were established to assure that special processes, including welding, are controlled and accomplished in accordance with applicable codes, standards, specifications, criteria and other special requirements.
  • C. Nine L.K. Comstock filler metal withdrawal authorization forms documented the release of E7018 weld rod for cable pan welds between May 25, 1982, and July 28, 1985 (Inspection Report 84-13 Exhibit 24).

In its Motion for Summary Disposition, Applicant acknowledges that the item which forms the basis of Rorem Subcontention 9.C constitutes a technical violation of applicable procedure. See Applicant Motion 9.C at

4. Applicant argues, however, that this violation is without design or safety significance. Id. The Staff agrees.

The violation in question was identified during a routine inspection of Applicant's construction activities conducted by Region III NRC Inspectors R.D. Schulz and L.G. McGregor. See Affidavit of Kavin D. Ward In Support of JRC Staff's Response To Applicant's Motion for Summary Disposition of Rorem QA Subcontention 9.C at 16 (hereinafter " Ward i

Affidavit"). During that inspection, the NRC inspectors reviewed more than 300 filler metal withdrawal forms and discovered that nine of these forms indicated that No. 7018 weld rod and E70 Series electrode were issued to welders for use in welding cable pans. Id.; see Inspection Report Nos. 50-456/84013 and 50-457/84013 (attached as Ex. 9.C-2 to Ward Affidavit). The applicable procedure, however, required that only E60

Series electrode be used to weld cable pans. See Ex.9.C-2 at 16. In addition, the NRC inspectors also determined that five of the weld filler metal withdrawal forms incorrectly identified the type of weld rod issued; E6013 weld rod was listed on the forms instead of the E7018 weld rod that actually was issued. See Ex.9.C-2 at 16. It was on the basis of these findings that the NRC Staff cited Applicant for the violation identified in Subcontention 9.C.

Applicant took a number of steps to remedy the effects of this violation and to ensure that it does not recur. First, Applicant strengthened its weld filler metal control procedures. Ward Affidavit at

17. As NRC Inspector Ward notes, the applicable procedure now " requires a filler metal issue tab to be issued for each type and size of electrode and for each day's welding activities." Id. Second, all personnel affected by this change in procedure were given instruction and training regarding these new requirements. Id. These measures diminish the likelihood that incorrect weld filler metal will be issued in the future; indeed, no weld rod control irregularities.have been detected since the date of the initial violation. .

In addition, to determine whether the violation identified in Subcontention 9.C was an isolated occurrence, Applicant committed itself to a review of all weld filler metal withdrawal forms issued since the start of the project. Applicant did not complete this review, however, ,

because it determined that none of the E60 Series electrodes used to weld cable pans have a tensile strength of less than 70,000 pounds per square inch, which is the minimum tensile strength for E70 Series electrodes.

What this means is "that is of no design significance that E60 weld rod

might have been used where E70 weld rod was called for; conversely, E70 -

weld rod might have been used where E60 weld rod was prescribed." Ward Affidavit at 18. As NRC Inspector Ward states: " Design requirements would have been met in either case." Id. The welders making the cable pan welds were qualified to use either E60 or E70 Series electrode. Ward Affidavit at 17.

On the basis of the facts stated in the preceding paragraph, NRC Inspector Ward closed this violation in Inspection Report Nos.

50-456/85005 and 50-457/85005 (attached as Ex.9.C-3 to Ward Affidavit).

Applicant has in place adequate measures to ensure that weld filler metal is controlled properly. Equally important, there no longer is any question that the violation which forms the basis of Rorem Subcontention 9.C has no safety or design significance. Consequently, there is no genuine dispute as to any material fact concerning this subcontention and Applicant is entitled to a favorable decision on this subcontention as a matter of law. Accordingly, the Motion for Summary Disp.osition of Rorem Subcontention 9'.C should be granted.

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