ML20214C496

Affidavit of Kd Ward Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 9.C.Related Info Encl

ML20214C496
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214C321	List: ML20214C317 ML20214C330 ML20214C334 ML20214C358 ML20214C380 ML20214C409 ML20214C439 ML20214C451 ML20214C468 ML20214C496 ML20214C514 ML20214C526 ML20214C552 ML20214C569 ML20214C580 ML20214C583 ML20214C596 ML20214C606 ML20214C628 ML20214C676
References
OL, NUDOCS 8602210156
Download: ML20214C496 (42)

Text

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UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COfWISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of C0fMONWEALTH EDISON COMPANY Docket Nos. 50-456 50-457 (Braidwood Station, Units 1 and 2 )

AFFIDAVIT OF KAVIN D. WARD IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR SupmARY DISPOSITION OF ROREM QA SUBCONTENTION 9.C I, Kavin D. Ward, being duly sworn, aver and state as follows:

1. I am employed by the U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Rd., Glen Ellyn, IL 60137 as a Reactor Inspector, Materials and Processes Section, Engineering Branch, DRS. A copy of my professional qualifications is attached hereto as v Exhibit 9.C-1.

2. As Reactor Inspector my duties consist of performing inspections on construction and operation of nuclear power plants in the fields of nondestructive examination (NDE) and welding to assure that said activities are conducted in accordance with regulatory requirements and licensee connitments and include making recommendations regarding appropriate enforcement action.

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 9.C. This subcontention states:

9. Contrary to Criterion IX, Control of Special Process, 10 C.F.R. Part 50, Appendix B, Connonwealth 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).

4. In preparing this Affidavit I have reviewed the following documents:

a. " Material Facts As To Which There Is No Genuine Issue to Be Heard" with regard to 9.C;

b. " Affidavit of Randall Kurtz (on Rorem QA Subcontention 9.C);"

c. " Affidavit of James W. Gieseker (on Rorem QA Subcontention9.C);"

d. NRC Inspection Reports No. 50-456/84-13; 50-457/84-13 and Nos. 50-456/85005 and 50-457/85005 (attached hereto as Exhibits 9.C-2 and 9.C-3);-and

e. Applicant's response to the notice of violation, dated September 21, 1984 (pertinent portions attached as Exhibit 9.C-4).

5. This violation was identified during a routine safety inspection conducted by NRC Inspectors L. G. McGregor and R. D. Schulz from June 5 through July 6, 1984. The inspectors reviewed over 300 withdrawal authorization forms and found that nine of these forms documented the release of No. 7018 weld rod, and E70 Series electrode, for use in cable pan welding. See Exhibit 9.C-2 attached.

6. L. K. Comstock took several steps to disposition this matter as '

is stated in the Applicant's Material Facts. ,

7. I reviewed the Applicant's final response dated September 21, 1984 (attached as Exhibit 9.C-4) and related NCRs, procedures, material test reports and documentation. The problems identified were the result of documentation errors. The heat numbers of the weld rods identified are traceable to valid certification documentation. The filler metal tensile strength of either type of electrode meets or exceeds the ,

requirements of AWS D1.1-75. Either rod that was used on these field installations was acceptable. The welders making the welds were qualified to use either electrode. In addition, any unacceptable welds would likely have been identified because 100% visual inspection of welding has always been required. L. K. Comstock Procedure 4.3.10, Revision D, dated August 12, 1984, titled, " Storage Issue and Control of Welding Material," now controls this activity, and requires a filler metal issue tab to be issued for each type and size of electrode and for each day's welding activity. Training in the procedure requirements was given to all affected personnel detailing the control of heat numbers and documentation practices for the filler metal issue tabs.

8. The material certification reports, together with Sargent &

Lundy's evaluation, establish that it 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. Design requirements would have been met in either case.

9. I closed this item in inspection Report Nos. 50-456/85-005 and .

50-457/85-005 (attached hereto as Exhibit 9.C-3). The basis upon which I closed this item was the effective impiementation of the Applicant's corrective action.

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Kavin D. Ward .

Sworn and subscribed before me this / % day of February,1986 4

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Notary Public My Commission expires: MrCommi:sicaE:; ins!!n.27,109 l

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4, Professional Qualifications .

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KAVIN D. WARD U. S. NUCLEAR REGULATORY C0PetISSION I am employed as a Reactor Inspector in the Region III, Material and

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Processes Section.

• O I received a B.S. degree in Mechanical Engineering from Pacific Western University Encino, California. I am also a Professional Engineer in Quality Engineering from the State of California.

I am assigned as a Reactor Inspector in Region III and have been since January, 1978. In this capacity I perform ins;iections in construction and operating facilities in accordance with Codes, Standards and Guides.

I observe tim / performance of welding and nondestructive examination (NDE)

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of support personnel evaluate and report upon appraisal of their '

qualifications and performance, pH marily in the fields of NDE and '

Participate in investigat)3ns involving or per'taining to

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welding.

nuclear facilities. 3 Prior to joining the Commission in January,'IG78, I worked 7 years for Bechtel Corporation, San Francisco, California. I held the position of

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Engineering Supervisor and was certified in various methods of NDE, including being a test examiner.

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From 1970 to 1971, I was employed by Nebraska Testing Lab as a Quality

• Assurance Manager.

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, From 1969 to 1970, I was employed by Peter Kiewit Cons. Company as a Quality Assu'rance Engineer.

From 1968 to.1969, I was employed by Phillips Petroleum Co. as a Quality Assurance Representative.

From 1966 to 1968 I was employed by Westinghouse Electric Co. as a NDE Technician.

From July 1946 to August 1966, I was in the United States Navy. While in the Navy, I attended several welding and NDE schools and served primarily aboard submarine tenders as a pipefitter, welder and NDE inspector.

Wrug UNITED STATES h

4 'k$ NUCLEAR REGULATORY COMMisslON REGION Ill O f 799 ROOSEVELT RO AO D CLEN ELLYN. It.LINOIS Gut 37

%, . .* . . . #g Exhibit,9.C-2 Aug ,.,i G84 Docket No. 50-456 .

DocketNo.50-457)qq.G Comonwealth 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 L. G. McGregor and R. D. Schulz of this office on June 5 through July 6,1984, of activities at Braidwood Nuclear Power Station, Units 1 and ?, 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 non-compliance 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 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 re-quirements 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 e .ter, 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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Commonwealth Edison Company 2 I

i We will gladly discuss any questions you have concerning this inspection.

Sincerely, 80rtsl.nal sitr. - " dCM' R. F. Warnick, Chief Projects Branch 1

Enclosures:

1. Appendix, Notice of -

Violation -

2. Inspection Reports No. 50-456/84-13(DRP);

No. 50-457/84-13(DRP) cc w/encis:

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 DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office, Environmental Control Division Jane Whicher, Esq.

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ney Warnick 08/01/84 I

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Appeadix NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on June 5 through July 6,1984, and in accordance with the General Policy and Procedures for NRC Enf6rcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

1. 10 CFR 21.31 states, "Each individual, corporation, partnership or other entity subject to the regulations in this part shall assure that each procurement document for a facility, or a basic component issued by him, her or it on or after January 6,1978 specifies, when applicable, that the provisions of 10 CFR Part 21 apply."

Contrary to the above, procurement documents, numbers 252162, 254434, 259782, 262155, 265347, and 270934 did not specify that the provisions of 10 CFR Part 21 apply for heat shrink tubing required to be in compliance with IEEE 383-1974 for aging, radiation, and LOCA environments.

This is a Severity Level V violation (Supplement II).

2. 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...using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Sargent and Lundy drawing 20E-0-3251, Revision AC and L. K. Comstock Procedure 4.3.3 dated January 29, 1982, require the use of E60 series weld rod for cable pan welds.

l Contrary to the above, nine L. K. Comstock filler metal withdrawal l authorization forms documented the release of E7018 weld rod for cable pan welds between May 25, 1982, and July 28, 1982.

l This is a Severity Level IV violation (Supplement II).

i Pursuant to the provisions of 10 CFR 2.201, you are required to submit to l 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) cor-rective action taken and the results achieved; (2) corrective action to be l

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App;ndix  ? 8I'. f.'c. 7 s

taken to avoid fdrther noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

a r .r. e .

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Dated 2FLuMk R. F. Warnick, Chief Projects Branch 1 l

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l U. S. NUCLEAR REGULATORY COPWISSION ,

. REGION III Report No. 50-456/84-13(DRP);50-457/84-13(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 Conducted: June 5 through July.6, 1984 Inspectors: i.. G. McGregor R. D. Schulz 4 Approved By: t0.Lprney,we W. L C~ //or,//</

Projects Section 1A D8te / '

Inspection Sumary Inspection on June 5 through July 6, 1984 (Report No. 50-456/84-13(DRP);

50-457/84-13(DRP)) '

Areas Inspected: Routine, unannounced safety inspection of licensee action on. construction deficiency reports and bulletins, plant tours, preventive main-tenance, spent fuel Storage racks, pipe supports, procurement, cable pan supports, audits, and reactor coolant pump supports. The inspection consisted of 164 inspector-hours onsite by two NRC inspectors including 4 inspector-hours onsite during off-shifts.

Results: Of the nine areas inspected, no item of noncompliance or deviations were identified in seven areas, two items of noncompliance were identified in the remaining areas, failure to specify the application of 10 CFR Part 21 to

,, procurement documents (paragraph 7) and failure to control weld rod for cable pan welding (paragraph 8).

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DETAILS

1. Persons Contacted Comonwealth Edison Company (CECO)

M. Wallace, Project Manager C. Schr-ceder, Licensing and Compliance Superintendent

• D. L. Shamblin, Construction Superintendent

• T. Quaka, Quality Assurance Supervisor L. Tapella, Engineer

• L. M. Kline, Licensing Compliance S. Hunsader, Quality Assurance Supervisor

- G. Fitzpatrick, Assistant Manager Quality Assurance Corporate

• J. Purrazzo, Engineer M. Curinka, Engineer

• C. J. Tomashek Startup Superintendent N. Tomis, 0AD Supervisory Engineer i J. Enger, Senior Buyer R. Milne, Field Engineer K. Steele, Electrical Supervisor E. R. Netzel, Quality Assurance Supervisor

• T. Ronkoske, Engineer

• R. Wrucke, Licensing Engineer

• M. Gorski, Engineer

• D. A. Boone, Engineer

. Phillips Getschow Company (PGCo)

T. G. O'Connor, Site Manager J. Carlson, Quality Control Supervisor L. J. Butler, Assistant Quality Control Supervisor M. Galloway, Assistant Project Engineer J. Strong, Quality Control Technician R. Tesmond, Quality Control Level II L. K. Comstock and Company, Inc. (LKC)

• I. Dewald, Quality control Manager L. G. Seese, Assistant Quality Control Manager Site R. M. Saklak, Ouality Control Supervisor R. Brown, Lead Inspector Mechanical R. Frisby, Level II Quality Control Inspector

• R. Seltman, Quality Assurance Engineer Pittsburgh Testing Laboratory (PTL)

T. Frazier, Assistant Site Manager R. Vanderhyden, Construction Engineer In addition, a number of other plant personnel were contacted.

• Denotes those personnel attending the exit interview.

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2. Licensee Action on Previously' Identified Items

a. 10 CFR 50.55(e) Items (Closed) 456/81-02; 457/81-02: During the stressing of a tendon on the Braidwood Unit I containment, a thread failure occurred between the shop anchorhead bushing and the stressing adapter due to both the lack of full thread engagement and undersized anchorhead threads.

Analysis showed that the in-place stressed anchorages are acceptable.

Corrective action for unstressed anchorages included a checkpoint in the stressing procedures to assure full thread engagement and measure-ments of all anchorage components prior to stressing.

(Closed) 456/82-02A; 457/82-02A: Fifteen fire dampers may not close due to a deficiency in the fusable link. The defective links have been replaced. All future dampers will be checked for proper link installation.

(Closed) 456/82-11; 457/82-11: A potential problem existed with regard to rigid snubber strut pins. Subsequently, tensile testing resulted in no defonnation of the pin material and no pins tested were found to have low yield strength. In addition, the pin is not considered to be a critical hanger component.

(0 pen) 456/83-15; 457/83-15: Pacific Scientific (PS) snubbers supplied with capstan springs may be defective and fail during a seismic event.

Subsequent testing and metallurgical evaluation revealed that the

, snubbers met design requirements and there is no reportable deficiency.

However, a PS letter dated February 10, 1984 reco wended that "due to the various potentially harsh environments on usage some snubbers might experience, these snubbers be the first to be inspected during nomally scheduled plant inservice or maintenance inspections." The inspector was unable to determine that the licensee had performed any evaluation or scheduled any of the snubbers for the first plant inservice or maintenance inspection. This item will remain open until the licensee addresses the PS recommendations.

b. IE Bulletins (Closed) IE Bulletin 83-01: Failure of Reactor Trip Breakers (Westinghouse 0B-50) to Open on Automatic Trip Signal. The inspector examined the licensee's action relative to the reactor scram breaker failures to determine whether a timely response was sent to the NRC, if the response addressed the appropriate technical questions, and whether the required actions had been accomplished. The Braidwood design incorporates four DS-416 rather than 08-50 breakers. In response to Bulletin 83-01 the licensee has received Westinghouse Change Notice (83) 823 which includes a procedure for changing the undervoltage trip assembly, mounting instructions and trip load and force checks for the breakers. The corrective action recommended by l the manufacturer will be completed by the licensee before fuel load and a review of the breaker maintenance program for conformance to recommended Westinghouse program will be implemented.

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( ( h. WC-2. b (C1'osed) IE Bulletin 83-06: Nonconforming Material Supplied by Tube Line Corporation. The licensee has reviewed the list of purchasing.

and receiving companies given in Attachments 2 and 3 of the bulletin and in addition has reviewed station purchasing records for material which may have been supplied by Tube Line. The search of records has shown that four 3-inch 150 pound RF W/N flanges were supplied to the Braidwood Station by the Joliet Valve Co. Two of these flanges were installed in the Boric Acid System and two were installed in the Containment Spray System. One flange has subsequently been removed from the Containment Spray System and the remaining three flanges will be replaced upon receipt of new flanges.

(Closed) IE Bulletin 83-07: Apparently Fraudulent Products Sold by Ray Miller, Inc. The licensee has addressed the subject bulletin by a review of corporate purchasing procedures with respect to the problems encountered with Ray Miller, Inc. and Tube Line Corporation (Bulletin 83-06 response). The licensee has reviewed the purchasing records for Braidwood Construction and Braidwood Operations Departments with no indication that material was purchased from Ray Miller, Inc.

Ceco reviewed its Quality Assurance procedures for review of purchase documents and found them to be adequate.

(Closed) IE Bulletin 83-08: Circuit Breakers with An Undervoltage Trip in Use in Safety-Related Applications Other Than the Reactor Scram System. A review completed by the CECO Braidwood technical staff has concluded that W type DB, W type DS and GE type AK-2 with undervoltage trip attachments are not used in safety-related applica-tions, outside the reactor scram system.

No items of noncompliance or deviations were identified.

3. Plant Tours The inspectors observed work activities in-progress, completed work, and plant status during general inspections of the plant. Observation of work included high strength bolting, safety-related pipe welding, anchor bolts, structural welds, and cable trays in the containments and auxiliary building. Particular note was taken of material identification, noncon-forming material identification, housekeeping, and equipment preservation.

Craft personnel were interviewed as such personnel were available in.the work areas. ,

No items of noncompliance or deviations were identified.

4. Preventive Maintenance The maintenance program for mechanical and electrical equipment was reviewed to assure that pump shafts were being periodically rotated, rotating equip-ment was lubricated, equipment was properly covered for protection from construction activities, insulation resistance testing was performed for motors and heat was being applied to electrical items, and desiccant,

' vapor inhibitors, or nitrogen purges were used to maintain proper humidity 4

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levels. The following pieces of installed equipment and their associated records were examined for the applicable elements stipulated above: ,

. 2CC01PA, Component Cooling Pump and Motor

. ICS01PA, Containment Spray Pump and Motor

. 2CS01PA, Containment Spray Pump and Motor

. 2AP73E, 480 Volt Switchgear Panel

. 2AP17E, 480 Volt Switchgear Panel

. 2RC01PB, Reactor Coolant Pump and Motor

. 2FWO1PA, Auxiliary Feedwater Motor

. 2CV04AA, Letdown Heat Exchanger

. 2FC01P, Spent Fuel Pit Pumps

. 2SX01PB, Essential Service Water Pump

. 0W001PA, Main Control Room Chilled Water Pump

. 0 WOO 1PB, Main Control Room Chilled Water Pump

. 1RH01PA, Residual Heat Removal Motor

. ISIO1PA, Safety Injection Motor .

. 2SIO1PA, Safety Injection Pump and Motor

. 2CV01PB, Centrifugal Charging Pump

. 2RH01PA, Residual Heat Removal Pump The inspector noted that the equipment was poorly covered for protection from construction activities. This is considered an open item (456/84-13-01; 457/84-13-01).

A review of Phillips, Getschow Co. Procedure, PGCP-37, Revision 1, Equipment Surveillance, revealed that equipment was divided into three categories:

. " Category A" - rotating equipment which requires periodic rotation and lubrication

. " Category B" - requires protective purge gas prior to attachment of piping systems

. " Category C" - other safety-related equipment.

Phillips, Getschow Co. quality control inspectors performed surveillances of mechanical equipment, but their inspections mainly involved documenta-tion checks and were on a limited, random basis, not being extensive enough to assure that all mechanical eouipment was properly maintained by the craftsmen. Although, based on the NRC sa'mple inspection, craf t records and maintenance appeared adequate, the mechanical equipment quality assurance organization needs to establish an inspection program to verify ~

adequate craft attention to the preventive maintenance function. Further-more, the inspector could not find inspection or surveillance records docu-menting that mechanical equipment quality control inspectors had witnessed .

any shaf t rotations or lubrications. Pending licensee review of this area, including considering the examination of all mechanical equipment to assure that the equipment has been properly maintained; and subsequent NRC review, mechanical equipment maintenance will remain unresolved (456/84-13-02; 457/84-13-02).

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The only mechanical items that required gas purges, as stipulated in pGCP-37, were the accumulators and the control room refrigeration units. Vapor inhibitors or the coating of internal parts was not a part of the mechanical contractor's preventive maintenance program. Options, especially for heat exchangers, employed by the nuclear industry include:

. Maintaining purges as long as possible prior to start-up and incorpora-tion into plant systems, and making piping connections last.

. The use of humidity indicators attached to or inside components.

. Desiccant used as vapor inhibitors.

. Internals specially coated by manufacturers for long term storage.

. Vapor inhibitors, such as Cortec VCI-319, used for extended storage periods since the inhibitors can be flushed from the system (water soluble).

Humidity conditions can become extremely high for equipment stored.in place as a result of concrete pours or other systems being flushed. The inspector has requested the licensee to assess the importance of these options considering the length of time items have not been in service.

Pending licensee assessment, this issue will remain open (456/84-13-03; 457/84-13-03).

The electrical contractor's (L. K. Comstock) preventive maintenance program was reviewed, including Procedure 4.10.2, Receiving and Storage, Revision A, and the inspector identified the following issues:

. Although Procedure 4.10.2 required that electrical equipment be checked to assure that heaters were properly working, L. K. Comstock did not have a list of the equipment that required heaters and the L. K. Comstock quality control inspector did not document which equip-ment was being . checked for heaters.

. The licensee did have a list of maintenance required for electrical equipment, such as covers to protect the equipment and the use of motor winding heaters, but this list was not included in any proce-dure nor was objective evidence provided to the inspector documenting that manufacturer recommendations for maintenance were included in j this list. L. K. Comstock's quality control organization was not

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i aware of the licensee's list.

The inspector has requested the licensee to review the electrical equipment maintenance requirements, taking into consideration manufacturer recomenda-tions and/or Sargent and Lundy recomendations. Subsequent to this review and the conclusions reached, the licensee should address L. K. Comstock's

! responsibility in assuring the maintenance of electrical equipment, including the quality control inspection function.

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( (' h f C= L The NRC will review the electrical maintenance program after:

. The licensee determines the adequacy of the electrical equipment maintenance program,

. The licensee conducts quality control inspections, if required,

. The licensee determines L. K. Comstock's responsibility in assuring maintenance of electrical equipment.

Pending these licensee actions and NRC review, the electrical equipment maintenance program will remain unresolved (456/84-13-04; 457/84-13-04).

1 No items of noncompliance or deviations were identified.

5. Spent Fuel Storage Racks The contractor that fabricated the 6x5 and 6x6 spent fuel storage racks was NUS Corporation. The inspector reviewed Specification F/L-2743, New And Spent Fuel Storage Racks dated January 7, 1976 through Amendment 2 dated June 28, 1983, and NUS Corporation Specification 5106-M-200 Revision C, which was approved by Sargent and Lundy on January 13, 1978. These two documents established the fabrication reoutrements for the storage racks.

The following drawings delineated the dimensional requirements and weld details:

. 5106M 2000 Revision 2

. 5106M 2001 Revision 7

. 5106M 2002 Revision 8 After reviewing these drawings, a 6x5 rack and a 6x6 rack were examined for confonnance to the drawings requirements, including:

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. Width and length dimensions

. Component dimensions - (shear plates, collar bars, corner support plates, module support plates, support beams, and gusset plates)

. Separation dimensions

. Structural welds - (gusset plate to beam welds, plate to beam welds, gusset plate to support plate welds, collar bar to support plate welds, and shear plate wolds)

One rack's flare plates at the end of the aligntmnt box were damaged and one rack's support beams, (quantity of two), were oeformed. The inspector identified these racks to the licensee and the licensee derumented these conditions for resolution. Pending licensee evaluation and currective action if necessary, and NRC review, the acceptance of these two spent fuel storage racks will remain unresolved (456/84-13-05; 457/84-13-05).

It was noted that the welds attaching the 79" long collar bar to the 3" x 83" support plate were not symmetrical. The pieces were connected by 9" long welds on the ends, and 3" long intermittent welds with centers I

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Pending this information being supplied to NRC and subsequent review, this weld detail will remain an open item (456/84-13-06; 457/84-13-06).

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The fabrication documentation was reviewed and the inspector identified the following items, which the licensee is presently investigating and evaluating for resolution:

. welding procedure qualifications as required by specification F/L-2743, identified as being used for specific welds or components,were not available for review.

. welder qualifications as required by specification F/L-2743, were not available for review.

. penetrant material test reports, as required by specification 5106-M-200, were not aveilable for review.

. NUS Visual Weld Inspection Procedure 763, Revision 1, was not available for review.

. the majority of the visual weld inspection records for the root and completed welds, as required by specification 5106-M-200, were not available for review.

. joint preparation inspection records for dimensional and cleanliness conformance, as required by specification 5106-M-200, were ndt available for review.

. surface roughness and interior edge inspection records, as required by specification 5106-M-200, were not available for review.

. penetrant test reports did not identify the specific components penetrant tested, nor if both the applicable root and final passes were inspected, as required by NUS Procedure 761, Revision 5, and specification 5106-M-200.

. the inspector was unable to trace the certified material test reports for the collar bars, as required by specification 5106-M-200, for the majority of the storage rack assemblies.

. The inspector was unable to trace the certified material test reports for the welding materials to the specific joints or components, as i required by specificaticns 5106-M-200 and F/L-2743.

. Penetrant Test Report, dated March 22, 1979, shop order 73913, was not traceable to a spent fuel storage rack assembly serial number.

The licensee stated that they believe adequate documentation does exist, but it may not be filed on site. Pending licensee investigation and sub-mittal of additional documentation to the NRC at the Braidwood site for 8

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No items of noncompliance or deviations were identified..

6. Pipe Suoports Twenty pipe supports were examined for conformance with the drawing requirements. Attributes checked included:

. Configuration

. Weld details

. Dimensional tolerances and offset gaps

. Location

. Correct components Identified below are the installed component supports which were examined, the type of support, location, and if applicable, an engineering change notice (ECN), which revised the installation:

Support Type Location ECN No.

M-1SX09044X sway-strut containment #1 16559 M-1SX08038X rigid containment #1 12196 M-ICV 05020R rigid containment #1 M-1CV05022X sway-strut containment #1 M-1CV05027R rigid containment' #1 M-1CV05021X sway-strut containment #1 M-1CV05099X sway-strut containment #1 M-1CV05023R sway-strut containment #1 M-lCV05024R sway-strut containment #1 M-1CV05025X sway-strut containment #1 M-1CV05026R rigid containment #1 M-1CV54004X sway-strut auxiliary building M-1CV54005R rigid auxiliary building M-1CV01028X rigid auxiliary building M-1CC03073R rigid auxiliary building M-1CC03136R sway-strut auxiliary building M-1CC03150X sway-strut auxiliary building 15907 M-1CV54001R rigid auxiliary building M-1CV54003X sway-strut auxiliary building M-1CC02136X sway-strut auxiliary building No items of noncompliance or deviations were identified.

7. Procurement Procurement documents specifying material for the electrical discipline were checked for technical adequacy, OA program requirements, 10 CFR 21 provisions, identification of items, and if the supplier was on the approved bidders list. In addition, Conronwealth Edison material receipt 9

I ( [(. f. C Z.

inspection reports and documentation, such as certified material test reports and certificates of conformance, were reviewed for conformance to the procurement documents. The following purchase orders and their associated receipt inspection documentation were examined:

Purchase Order No. Vendor Product Type 728208 Northern Ill. Steel ASTM A36 plate 249282 Northern Ill. Steel ASTM A36 plate 266483 Haggerty Steel Structural Steel 259707 Haggerty Steel Tube Steel, Plate 256493 Haggerty Steel Tube Steel, Plate 252162 Raychem Corp. Heat Shrink Tubing 254434 Raychem Corp. Heat Shrink Tubing 259782 Raychem Corp. Heat Shrink Tubing 262155 -

Raychem Corp. Heat Shrink Tubing 265347 Raychem Corp. Heat Shrink Tubing 270934 Raychem Corp. Heat Shrink Tubing 276436 Raychem Corp. Heat Shrink Tubing 256523 Raychem Corp. Heat Shrink Tubing 272787 Raychem Corp. Heat Shrink Tubing The procurement documents and receipt irspection records were in accordance with regulatory requirements with the exception of six orders placed with Raychem Corporation. The heat shrinkable tubing was ordered under the requirement that documentation shall include a certificate of compliance certifying that the material had been tested to the recuirements of IEEE 383-1974 for aging, radiation, and LOCA environment, as stipulated by Sargent and Lundy drawino 20-E-1-3503, dated February 1,1979, and L.K. Comstock Procedure 4.3'.9, Cable Termination Installation, Para-graph 3.11.5 - Lug to Bus Connection, 4160V and 6900V Connections. The certification for aging, radiation, and LOCA environment was received for

~

all the Raychem Corp. purchase orders delineated above. However, Raychem Corp. procurement documents, numbers 252162, 254434, 259782, 262155, 265347, and 270934 did not contain statements that 10 CFR Part 21, " Reporting of Defects And Noncompliance", applied to these heat shrink tubing orders.

10 CFR 21.31 Procurement Documents states: "Each individual, corporation, partnership or other entity subject to the regulations in this part shall assure that each procurement document for a facility, or a basic component issued by him, her or it on or after January 6,1978 specifies, when.appli-cable, that the provisions of 10 CFR Part 21 apply."

Detailed below are the procurement documents and their date of placement:

Procurement Document No. Date of Placement 252162 02/02/81 254434 08/03/81 259782 01/22/82 262155 04/14/82 265347 06/23/82 270934 11/22/82 10

( ( [ k. f. ( - L Failure to specify the application of 10 CFR Part 21 to these procurement documents is a violation of 10 CFR 21.31 (456/84-13-08; 457/84-13-08). ,

8. Cable Pan Supports The structural supports for ten cable pans located in the auxiliary building were examined for conformance to the drawings, including configuration, dimensions, and welding details. Detailed below are the cable pans and their applicable supports:

Cable Pan Support I.D. Type 21752J H-181 H-189 unistrut 21750J H-188 unistrut/breced 21747J H-185, H-186, H-187 unistrut/H-186 braced 21746J H-183, H-184, H-185 unistrut/H-183 braced 21779J H-160 tube steel 21777J H-170, H-171 unistrut 21772J H-137, H-138 tube steel /H-137 braced 21773J H-175 unistrut 21764J H-142 unistrut 21765J H-140 unistrut/ braced Documents utilized in the examinations included:

. Sargent and Lundy drawings 20E-0-360 series and 20E-0-380 series for welding details.

. Sargent and Lundy drawing 20E-0-3251, Cable Pan General Notes and Installation Details.

. Sargent and Lundy drawing 20-E-03278 for configuration.

. Sargent and Lundy Hanger List for dimensional requirements.

Subsequently, the inspector reviewed L. K. Comstock inspection reports for these cable pan installations, and Pittsburgh Testing Laboratory inspection reports that documented a 10% overview weld inspection. Procedu'res reviewed included L. K. Comstock Procedures 4.8.3, Weld Inspection and 4.3.10, Storage, Issue and Control of Welding Material. Inspection reports were in accordance with procedure requirements and the weld rod was found to be stored in accordance with the procedure requirements, including oven tem-perature adherence. However, the inspector discovered that weld rod was allowed to be stored overnight in the portable rod oven heaters, instead of being returned to the issue stations. There are approximately one-hundred portable ovens and quality control does not assure that these ovens are plugged in at night and furthermore, surplus weld rod should be returned to the issue stations in order that it may be signed out to a specific i

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__- .~ _.._. _ . _ , _ _ _ _ _ _ _ _ _ . , _ . . _ . _ _ . _ _ _ _ _ _ . . _ _ _ _ _ . _ _

( ( [f. f & Z, application / component for traceability control. The inspector discussed these points with the licensee and the licensee has decided that all .

surplus weld rod must be returned to an issue station after the days shift,

~

to facilitate optimum weld rod control. L. K. Comstock was notified of the licensee's decision and therefore, the inspector considers this issue closed.

Over 300 filler metal withdrawal authorizetion forms, which document the release of weld rod for electrical installations, were reviewed for the months of May 1982 through August 1982. This was the time frame the cable pans were installed. The filler metal authorization forms were specific as to the use of the weld rod, specifying one of the following on each form:

. conduit hangers

. cable support

. cable pan

. switchgear

. junction box hangers However, the forms did not specify the specific component the rod was used on and only listed general building locations, such as Auxiliary Building, elevation 463 feet. Nine filler metal withdrawal authorization forms documented the assignment of E7018 weld rod for cable pan welding, even though Sargent and Lundy drawing 20E-0-3251, Revision AC and L. K. Comstock Procedure 4.3.3, dated January 29, 1982, required the use of E60 Series weld rod for cable pan welds. Detailed below are the nine forms documenting the release of E7018 weld rod, by heat number, for cable pan welding:

Date of Designated Reouisition Area Heat No. Class 5/25/82 Auxiliary Bldg., 383' 411P4161 *E6013 5/25/82 Auxiliary Bldg. 411P4161 *E6013 5/26/82 Auxiliary Bldg. 411P4161 *E6013 6/9/82 Auxiliary Bldg., 383' 411P4161 *E6013 6/10/82 Containment #1, 426' 411P4161 E7018 6/11/82 Auxiliary Bldg., 426' 421P4461 E7018 Auxiliary Bldg., 426' 6/22/82 -

40259011 E7018 7/13/82 Auxiliary B'idg. , 463 ' 40259011 *E6013 7/28/82 Auxiliary Bldg., 439' 40259011 E7018

• Heat numbers 411P4161 and 40259011 were actually E7018 weld rod as i

the insrector reviewed the material certifications. The rod issue attendants apparently thought these heats of rod were E6013. Note that the same heats, 411P4161 and 40259011, were handed out as both E6013 and E7018 weld rod.

Failure to control the use of weld rod for cable pan welding is a violation of 10 CFR 50, Appendix B, Criterion IX (456/84-13-09; 457/84-13-09).

12'

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( ff. @ C-Z.

9. Audits Commonwealth Edison recent site audits were reviewed. Past NRC inspection findings identified deficiencies in the Braidwood Site audit program with regard to depth of audits and corrective action. The recent audits revealed significant improvement in audit technique, depth, identification of problem areas, corrective action, and actions to prevent recurrence. The audits met the regulatory requirements and were carried out with the purpose of identifying and correcting any deficiencies that could affect the safe operation of the plant. The audits reviewed and area covered are detailed below:

Audit Dates Area Discipline 6/11/84-6/16/84 Calibration, Measuring and HVAC Test Equipment Storage .

HVAC .

QC Inspections HVAC Welding / Weld Rod Control HVAC 4/17/84-4/27/84 Receiving and Material Piping Control Piping Storage Piping Housekeeping Piping Corrective Action Piping Small Bore Pipe Piping Piping / Support Layout Piping Support Installation Piping Material Traceability Piping 4/16/84-4/23/84 Identification and Control Electrical of Equipment and Components QC Inspector Qualifications Electrical Welding / Weld Rod Control Electrical Re-inspection Program Electrical The audits included both documentation (software) and installation (hardware) inspections.

No items of noncomoliance or deviations were identified.

10. Inspection of Reactor Coolant Pump Supports The inspector reviewed Sargent and Lundy design drawings No. S1107, S1109

" Reactor Coolant Pump Support" Plan Elevation 393'2" and Teledyne Brown Engineering Drawing No. 22287 "Byrcn/Braidwood Station N.S.S.S. Support Framing Reactor Coolant Pump Lateral Support Erection" and noted dis-crepancies between the as-built condition and the designed lateral support.

This lateral support modification affected ,iust reactor coolant pump number 2 in units one and two. The inspector reouested documentation to substantiate the nonconformance which resulted in the modification, the 13

. . ( I

[g,fc.=L Engineering Change Notice, the Design Change review and approval, material specifications, qualified welding procedures, Quality Control records and inspections, and welder qualifications. Additionally, the inspector will determine if this modification was also installed on the Byron reactor coolant pumps. This matter is considered an unresolved item and will be reviewed during future inspections -(50-456/84-13-10; 50-457/84-13-10).

11. Open Items Open items are matters which have been discussed with the licensee, j 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 and 5.

12. Unresolved Items Unresolved items are matters about wh.ich more information is required in order to ascertain whether they are acceptabl items, items of noncompliance, or deviations. Unresolved items disclosed durino the inspection are discussed in Paragraphs 4, 5 and 10.

13. Exit Interview The inspector met with licersee representatives (denoted under Persons Contacted) durine and at the conclusion of the inspection on July 6, 1984 The inspector summarized the scope and findings of the inspection.

The licensee acknowledged the information.

P r

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(~ Exhibit 9.C-3

{

ht4R 121985 Docket No. 50-456 /

Docket No. 50-457-ff-63 Connonwealth Edison Company ATTN: Mr. Cordell Reed Vice President -

Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety . inspection conducted by Mr. K. D. Ward of this office on February 19 and 20,1985, of activities at 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. L. Kline 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

' No items of noncompliance with NRC requirenents were identified during the course of this inspection.

In accordance with 10 CFR 2.790, a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room.

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( (~ h 9, C - 3 Commonwealth Edison Company 2 ,

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

,;;;;;,,1 tig.:d bf J70.ltfrisd J. J. Harrison, Chief Engineering Branch

Enclosures:

Inspection Reports No. 50-456/85-005; No. 50-457/85-005 cc w/encls:

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 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.

4

t ( S. fc- 3 U.S. NUCLEAR REGULATORY COMMISSION ,

REGION III .

Reports No. 50-456/85-005(DRS);50-457/85-005(DRS)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Connonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 Facility Name: Braidwood Station. Units 1 & 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: February 19 and 20,1985 ob?9Vl:=x Inspector K. D. Ward .8!/46 Date Approved By:

&km D. H. Danielson, Chief / /I Materials and Processes Section Date Inspection Summary Inspection on February 19 and 20,1985 (Reports No. 50-456/85-005(DRS);

50-457/85-005(DRS)

Areas Ins)ected: Special, unannounced safety fnspection to attend a meeting between T.1e National Board of Boiler and Pressure Vessel Inspectors and the NRC concerning activities to be conducted at Braidwood, to review actions on ,

previous inspection findings, and to inspect activities relating to an IE Bulletin. The inspection involved a total of 15 inspector hours by one NRC inspector.

Results: No items of noncompliance or deviations were identified.

(' ( h fV 3 DETAILS ,

1. Persons Contacted Personnel Present at the Meeting February 19, 1985 4

M. Sullivan, The National Board of Boiler and Pressure Vessel Inspectors R. Holt, The National Board of Boiler and Pressure Vessel Inspectors S. Lindbeck, The National Board of Boiler and Pressure Ves.iel Inspectors D. Danielson, Chief, Materials *and Processes Section, RIII, NRC '

L. McGregor, Senior Resident Inspector, NRC R. Schulz, Senior Resident Inspector, NRC W. Kropp, Resident Inspector, NRC K. Ward, Reactor Inspector, RIII, NRC Personnel Contacted for Other ThanlAbove Comonwealth Edison Company (CECO)

• L. Kline, Licensing and Compliance Supervisor C. Schroeder, Licensing and Compliance Superintendent T. D' Antonio, PTL Coordinator The inspector also contacted and interviewed other licensee and contractor personnel.

4

• Denotes the individual present at exit interview.

2. Licensee Action on Previous Inspection Findings

a. (Closed) Noncompliance (456/81-10-01; 457/81-10-01): Failure to install structural steel bolted connections according to specifi-cation requirements. The inspector reviewed the final response dated April 5,1982, drawings, NCRs and related documentation. .

The beams as originally installed by American Bridge were acceptable at the time of installation but were subsequently removed by another contractor during installation of piping and equipment. After reinstallation of the beams, no reinspection was performed.

I A sample reinspection of A-307 bolted connections was perfonned by the independent testing contractor to insure that this problem did not exist elsewhere in the plant. The safety-related A-307 anchor bolt connections at Braidwood were all in the auxiliary building and the fuel handling building. All accessible connections were inspected and were found to be installed in accordance with the Architect Engineer's specification. The steel-to-steel A-307 bolted connections in the containment buildings were also rechecked for conformance to a new torque specification from the Architect Engineer.

2

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e

! The NRC inspector agreed with the licensee actions and considers q this item closed. -

b. (Closed) Noncompliance (456/84-08-01;457/84-08-01): Failure to document fit-up inspections for structural steel welded components.

i The inspector reviewed the final response dated June 21, 1984, i procedures, NCR and related documentation. ~

l Napolean Steel Contractors Inc. (NSCI) performed structural steel welding activities from mid-1978 to mid-1982. Welding and welding inspection activities were controlled by Procedure #5 - Welding, Section 5-3.9 of Procedure #5 states the followup regarding fit-up:

" Base metal surfaces and edges to be welded shall be smooth, unifonn, l

and free from fins, tears, cracks, and other discontinuities which would adversely affect the quality or strength of the weld. Surfaces i to be welded and surfaces adjacent to a weld shall also be free from i

loose or thick scale, slag, rust, moisture, grease and other foreign

material that would prevent proper welding or produce objectionable fumes. Mill scale that can withsMnd vigorous wire brushing, a thin rust inhibitive coating, or antispatter compound may remain on the j surface to be welded. All oxygen cutting shall be done in accordance

with AWS D1.1-75, Section 3.2.2. Members to be welded shall be brought into correct alignment and held in position by bolts, clamps, ,

I wedges, guy lines, struts, other suitable devices, or by tack welds i

until welding has been completed. The use of jigs and fixtures is recommended where practicable. Suitable allowances shall be made j for warpage and shrinkage."

i CECO discussions with the fonner NSCI general foreman and QA/QC i inspectors disclosed they received training in Procedure #5.

! Additionally, these discussions disclosed welders received training

!' in Procedure #5 and Procedure #5 was at the work stations for quick reference. Thus, welding foremen, welders and quality control

) . inspectors were aware of the procedural fit-up requirements.

l A review of NSCI welder qualifications show that all welders were qualified for full penetration welding. This qualified them to perform partial penetration and fillet welding. All full j penetration welding was subject to ultrasonic examinations (UT);

therefore, fit-up problems would have been discovered. Partial l penetration welding was subject to magnetic particle examinations l (MT) of root and final passes. Fillet welding was subject to a

} final visual weld inspections. NSCI quality control inspectors did

' monitor, at suitable intervals, the use of the proper procedure, etc. This monitoring did include fit-up checks.

t

! During welding operations, Field Change Requests (FCRs) were i

generated by NSCI/Consnonwealth Edison when structural steel fit-up i

could not be suitably obtained. The extent of documenting welding

and welding inspection has changed significantly since 1982. These

" fit-up" inspections are now properly documented. Conunonwealth i

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( h f.C ~ 3 Edison is reasonably confident that proper structural steel fit-up -

was completed as part of the NSCI welding program. AWS welding programs were reviewed in 1983 by CECO to ensure that fit-up inspections are completed by other sites contractors. Although there was a failure to document " fit-up" inspections, it appears that sufficient controls were in place to assure proper " fit-up" and, therefore, the welds in question are acceptable.

The NRC inspector a' greed with the actions of the licensee and considers this item closed,

c. (Closed) Noncompliance (456/84-13-09;457/84-13-09): Failure to control the use of weld rod for cable pan welding. The inspector reviewed the final response dated September 21, 1984, and related NCRs, procedures, material test reports and documentation.

The problems identified were the result of documentation errors.

The heat numbers ofithe weld rods identified are traceable to valid certification docume.ntation. The filler metal tensile strength of either type of electrode meets or exceeds the requirements of AWS D1.1-75, either rod that was used on these field installations was acceptable. The welders making the welds were qualified to use either electrode. In addition, any unacceptable welds would have been identified because 100% visual inspection of welding has always been required.

L. K. Comstock Procedure 4.3.10, Revision D, dated August 12, 1984, titled, " Storage, Issue and Control of Welding Material," now controls this activity, and requires a filler metal issue tab to be issued for each type and size of electrode and for each days welding activity. Training to the procedure requirements was given to all affected personnel detailing the control of heat numbers and docurentation practices for the filler metal issue tabs. -

~

The NRC inspector agreed with the licensee actions and considers this item closed.

d. (Closed) Unresolved item (457/84-05-03): Inadequate QA and engineering review documentation of site radiographic report.

Westinghouse NCR #615 was issued which reported a radiographic find of shrinkage near the mid-wall of ESCO fitting 04567-4 and that it was in accordance with ASTM E-186, Category C, Type 1, Severity Level 2 criteria.

The area in question was re-radiographed in January 1985 to locate and identify the indications. The base metal indication was re-evaluated by the Ceco Chief Level III-A Examiner and the NRC inspector using ASTM E-186, Category C, Type 1 Severity Level 2 criteria. The indication was found to be within acceptance limits.

4

( ( h. Fc-3 The NRC inspector reviewed a NCR, radiographic reports, related -

documentation, agreed with the action taken by the licensee and considers this item closed.

e. (Closed) Unresolved item (457/84-05-04): Failure to perform archive storage test of film.

, It was verified that Pittsburgh Testing Lab (PTL) has been per-forming the daily archive quality storage tests of film and documenting the results on a weekly basis since April 20, 1984.

This was verified by review of the weekly Radiographic Productivity Report for the period of April 20, 1984, through December 31, 1984, and a sample of the archive quality test results. Based on this review, PTL is properly implementing letter BRD #10,950 to achieve quality testing and producing acceptable archive quality film.

The NRC inspector reviewed a surveillance report and related documentation, agreed with the actions of the licensee and con-siders the item closed.

f. (Closed) Unresolved item (456/84-09-02; 457/84-09-02): Deter-mination of piping foreign material identified on radiographic reports.

On May 12, 1984, Pittsburgh Testing Lab radiographed the subject piping spool, #CS-9-6, of Line #1CS12AB-3", between weld #130 and

1. 13G. This was perfonned to detennine if a foreign object iden-tified during previous radiography had been removed. This object, which appeared to be a wire brush in the original radiograph, was not evident in the radiograph taken by PTL on May 12, 1984. Based on the radiographs, it was detennined that the foreign object was physically removed from the spool.

A. meeting was held September 6, 1984, between Ceco and Pittsburgh

- Testing Laboratory (PTL) regarding foreign objects in pipe and the

.. following was agreed to:

Foreign objects resulting from the welding process but not interfering with proper interpretation of the weld will be recorded in the remarks portion of the radiographic reader sheet. Disposition of the weld being inspected will not be affected. Phillips, Getschow Co. will pursue removal of such objects, as deemed necessary by the owner.

Foreign objects resulting from the welding process which interfere with proper interpretation of the weld will be dispositioned as rejectable. Phillips, Getschow Co. will be responsible for removal of such objects and requesting Pittsburgh Testing Laboratory to re-radiograph the weld.

5

i ( [b f.C .~f Foreign objects not resulting from the welding process, ,

which do not interfere with proper interpretation of the weld, will be recorded in the remarks portion of the radiographic reader sheet. Disposition of the weld being inspected will not be affected. Phillips Getschow Co.

will be responsible for removal of the object and docu-menting this activity.

Foreign objects not resulting from the welding process, and interfering with proper interpretation of the weld will be dispositioned as rejectable. Phillips Getschow Co.

will be responsible for removal of the object, documenting this activity and requesting Pittsburgh Testing Laboratory to radiograph the weld.

The NRC inspector reviewed the radiographs, surveillance report and related documents, agreed with actions by the licensee and considers this item closed.

g. (Closed)Openitem(456/84-21-06;457/84-20-06): Spool in contact with stmetural beam.

A section of pipe was cut out and replaced with a new longer .

section of pipe. Weld RC-7 FW-1A was removed and new welds RC-7 FW-1B, RC-7 FWIC and RC-7 FWID were made.

The NRC inspector reviewed a field change order, drawings and related documentation, agreed with the action taken by the licensee and considers this item closed.

3. Licensee Action on IE Bulletin (IEB)

(Closed)IEB79-13, Revision 1(456/79-13-88;457/79-13-88): Cracking in feedwater system piping.

IEB 79-13. Revision 2, was closed in NRC Report 50-456/80-07; 50-457/80-07 and Revision 1 was inadvertently omitted. The NRC review was, however. -

completed during that inspection.

4. The National Board of Boiler and Pressure Inspectors Activities l Coninonwealth Edison, in a letter dated November 19, 1984, to the Executive Director, The National Board of Boiler and Pressure Vessel Inspectors (National Board), confirmed Comonwealth Edison's request for an audit of the ASME work at Braidwood Station by an audit team of the National Board. The purpose of the audit is to address specific NRC concerns about the ASME work at the Station. Any items discovered in the audit that are of a technical nature are to be simultaneously consnunicated to the NRC and Commonwealth Edison. As a result of the request, a meeting was held February 5,1985, between the National Board and representatives of Coninonwealth Edison where arrangements were made to begin the audit.

6

( ( 5.Ec-3 On February 19, 1985, the National Board audit team and the NRC held a meeting to discuss the various activities that the National Board

• was going to audit. (See attendance list in paragraph 1.) The audit is to be a comprehensive and complete independent audit of ASME Code construction and related activities of Comonwealth Edison and their subcontractors to demonstrate the quality of the construction and compliance with ASME Code requirements.

The NRC will be made aware of the various activities and findings of the National Board and will attend their exits with the licensee.

5. Radiography on Essential Water System Unit 1 The inspector reviewed radiographs which were identified by the Construction Assessment Team (CAT) on January 12, 1985, as being duplicate radiographs (one weld being radiographed twice using different weld numbers). Weld #W-4 was radiographed twice as weld #W-3 and #W-4. The radiography was performed by Southwest Fabricating and Welding Co., Inc. A piping spool consisting of four welds, #W-2, #W-3, #W-4 and #W-5, was welded together and all radiographed December 14, 1978. The welds in question #W-3 and #W-4 are 10" diameter and were welded approximately 71" apart.

CECO has initiated a NCR to investigate the subject. This item will be followed by the NRC in review of the Ceco response to the Construction Assessment Team's final report.

6. Exit Interview ,

The inspector met with site representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection. The inspector sumarized the scope and findings of the inspection noted in this report. The in-spector 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 documertt/

processes as proprietary.

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. Common alth ECson One First Natierr:I Pirn. Ct.tcago IHir.ois

/? Addr;ss R; ply 11 Post Othca Box '/67

- Chicago, likncis 60690 Exhibit 9.C-4 September 21, 1984 Mr. James G. Keppler Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Il 60137 Sub ject: Braidwood Station Units 1 and 2 Response to Inspection-Report'Nos. '

50-456/84-13 and 57f457/84-13 '

NRC Docket Nos. 50-456--and-90d7 Reference (a): R. F. Warnick letter to Cordell Reed dated August 7, 1984.

Dear Mr. Keppler:

This letter is provided in response to the inspection conducted by Messrs. L. G. McGregor and R. D. Schulz on June 5 through July 6, 1984 of activities at Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC requirements. The Commonwealth Edison Company response to the Notice of Violation as appended to Reference (a) is provided in the enclosure.

Our delay in submittal of this thirty-day report until September 21, 1984, was discussed with Mr. R. F. Warnick of your office on September 5, 1984. .

Very uly your ,

De nis L. Farrar Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector - Braidwood ggp 2 4 l

gg, g, (. 9/

ENCLOSURE -

COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 50-456/84-13 AND 50-457/84-13 456-457/84-13-08 '

ITEM OF NONCOMPLIANCE

1. 10 CFR 21.31 states, "Each individual, corporation, partnership or other entity subject to the regulations in this part shall assure that each procurement document for a facility, or a basic component issued by him, her or it on or after January 6, 1978 specifies, when applicable, that the provisions of 10 CFR Part 21 apply."

Contrary to the above, procurement documents, numbers 252162, 254434, 259782, 262155, 265347, and 270934 did not specify that the provisions of 10 CFR Part 21 apply for heat shrink tubing required to be in compliance with IEEE 383-1974 for aging, radiation, and LOCA environments.

RESPONSE

Commonwealth Edison Company agrees that the procurement documents identified were not stamped with the appropriate stamp. However, documentation receive'd with the subject heat shrink tubing did contain 10 CFR Part 21 reporting requirements. -

i l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

All procurement documents for the vendor in question have been

, reviewed for the applicability of 10 CFR Part 21.

Change orders have been issued to the appropriate procurement documents to include the 10 CFR Part 21 provisions.

I CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:

l The importance of including the required statements on procurement orders has been re-emphasized to review personnel.

Also, Quality Assurance Supervisory Personnel are providing an additional review of procurement orders.

[(. fC /

DATE OF FULL COMPLIANCE,: ,

Full compliance has been achieved.

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4 8 f. ( ~ Y COMMONWEALTH EDISON COMPANY RESPONSE TO INSPECTION REPORT 50-456/84-13 AND 50-457/84-13 456-457/84-13-09 ITEM OF NONCOMPLIANCEi

2. 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. ..using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."

Sargent and Lundy drawing 20E-0-3251, Revision AC and L. K.

Comstock Procedure 4.3.3 dated January 29, 1982, require the use of E60 series weld rod for cable pan welds.

Contrary to the above, 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, 1982.

RESPONSE

Commonwealth Edison agrees that a procedure violation occurred.

However, our review indicates.that the welds made with either-E60 or E70 series weldrod are technically acceptable and will not result in any hardware problems in the field for the following reasons:

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1. The heat numbers identified are acceptable heat numbers l traceable to valid certification papers.

' 2. The welds made utilizing either of these electrodes meets or exceeds the strength requirements specified by AWS Dl.1-1975.

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3. The welders making these welds were qualified to use either filler metal.

4. Welding always required a 100% visual inspection and any unacceptable welds would have been identified.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED:

LKC NCR #3275 has been issued to identify and disposition the procedure violation.

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[f. f- C - Y CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE:

L. K. Comstock Procedure 4.3.10, Storage, Issue and Control of Welding Material, has been revised to amplify and clarify the

, control of weld filler metal. Personnel responsible for weld rod control have been trained in this procedure revision.

DATE OF FULL COMPLIANCE:

• Disposition of NCR #3275 is expected by November 16, 1984.

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SUBCONTENTION 9.D Subcontention 9.D, as admitted in this proceeding, states:

9. Contrary to Criterion IX, " Control of Special Process, " of 10 C.F.R. Part 50, Appendix B, Comonwealth Edison Company has failed to ensure that measure be established to assure that special processes, including welding are ,

controlled with applicable codes, standards, specifications, criteria and other special requirements. -

D. [A] quality [ structural steel, flux core welding procedure.] was not approved for use by the Architect-Engineer, Sargent & Lundy, but was released for use in installation by the structural steel contractor and documented as being used for cover plate welds. Further-more, the welder documented as performing the welding was not qualified. In addition, RPS Division loop B, reactor records identifying the welder or welder filler metal utilized.

(The words in brackets represent corrections to Intervenors' misquotation of the NRC item of non-compliance set forth in Contention 9.D)

Subcontention 9.D actually consists of two separate events: (1) the alleged use of an unapproved structural steel welding procedure by an allegedly unqualified welder and (ii) the absence of a complete documentation package concerning an instrumentation piping socket weld

- joint. Applicant argues that neither of these events establishes a.

l failure to assure that welding processes are controlled.and accomplished in accordance with applicable requirements. See Application's Motion 9.D at 1-5. The Staff agrees and, for the reasons explained below, urges that the Motion for Sumary Disposition of Rorem Subcontention 9.D be granted.

The items which form the basis of Rorem Subcontention 9.D were identified in August 1984 during a routine inspection of Applicant's construction activities by Region III NRC Inspectors R.D. Schulz and L.G.

McGregor. See Affidavit of Kavin D. Ward In Support of NRC Staff's "

Response To Applicant's Motion for Sumary Dispositlon on Rorem QA Subcontention 9.D at 11 6, 14 (hereinafter " Ward Affidavit"). With respect to the first event, the apparent use of an unapproved structural steel welding procedure by an allegedly unqualified welder, the NRC inspectors identified an instance in which a welder apparently used a flux core arc welding (FCAW) procedure. See Inspection Report Nos. -

50-456/85017 and 50-457/85017 (attached as Ex.9.D-2 to Ward Affidavit).

Although this procedure had been preq"alified by the American Welding i

Society, it had not been approved for use at the Braidwood facility by the architect-engineer as required by the structural steel contractor's, G.K. Newburg, own procedures and by Applicant's quality assurance manual.

Ex. 9.D-2. Moreover, the NRC inspector learned that the welder involved was not qualified to use the FCAW procedure. Ex. 9.D-2.

These findings were brought to Applicant's attention by NRC Inspectors Schulz and McGregor and Applicant promptly launched an investigation into the matter. Ex. 9.D-2. As a first step, Applicant and G.K. Newburg, stopped work on all structural steel welding until the matter was resolved satisfactorily. Ex. 9.D-2.; Ward Affidavit at 16.

The welding package identified by the NRC inspectors was reviewed and the qualifications of the welder checked. Ward Affidavit at 17. That review i

indicated that the welder had not used the FCAW method called for by G.K.

Newburg but rather the shielded metal arc welding procedure (SMAW) which was in fact the correct procedure to use. Ward Affidavit at 112. The welder. was qualified to use this type of procedure. Id.

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1 Applicant also considered the hardware implication of this problem.

• It was found that no structu'ral steel welding deficiencies occurred as a result of G.K. Newburg's specification of an incorrect welding procedure.

Ward Affidavit at 113. To ensure that only the correct welding procedure would be used in the future, G.K. Newburg revised its quality assurance procedure to require'(i) that the proper Weld Process Sheet (WPS) be attached to each welding package and (ii) a hold po. int for quality control review and approval of all welding packages prior to the commencement of the welding activity. Ward Affidavit at 18. To provide additional assurance that the correct welding procedure had been used, Applicant's quality assurance personnel now are required to review G.K.

Newburg's review. M. Finally, all persor.ael affected by these procedural changes were given instruction and training regarding the new requirements. Ward Affidavit at 19.

The foregoing corre::tive actions taken by Applicant satisfactorily resolve the concerns expressed by the NRC Staff. For this reason, NRC Inspector Ward closed this item in . Inspection Report,Nos. 50-456/84040 and 50-457/84037. These facts refute Intervenor's allegation that l Applicant has failed t'o ensure that welding activities are properly controlled and conducted in accordance with applicable requirements.

Consequently, there is no genuine dispute regarding the safety significance of the item forming the basis of the first part of Rorem Subcontention 9.D and Applicant is entitled to a favorable decision on this aspect of the subcontention as a matter of law.

l Similarly, the Staff agrees that the second part of Rorem Subcontention 9.0 should be dismissed sumarily. This is because, even

if true, that allegation does not establish Applicant's failure to comply

• with 10 C.F.R. Part 50, Appendix B, Criterion IX.

The item forming the basis of this part of Subcontention 9.0 also was identified during a routine inspection by Region III NRC Inspectors R.D. Schulz and L.G. McGregor. During that inspection it was discovered that the weld package for two socket weld joints contained no information identifying either the welder.of the type of weld filler metal used. See Ex. 9.0-2; Ward Affidavit at 114. The inspector brought this matter to the attention of Applicant's piping contractor who imediately issued a nonconformance report (NCR) documenting this deficiency. See Ex. 9.D-2.

The NCR was dispositioned by removing the subject weld and installing another in its place. See Ward Affidavit at 115. All relevant information is fully documented in the new weld package. I d_. This action eliminates any questien concerning the integrity of the weld.

More significantly, the fact that the weld package lacked some of the necessary documentation does not establish that Applicant failed to assure that welding activities are properly controlled and accomplished in accordance with applicable procedures as required by 10 C.F.R Part 50, Appendix B, Criterion IX. The simple fact is, as noted by NRC Inspectors Schulz and McGregor, "The piping contractor's quality control office personnel had not performed a review of the completed document package for drawing 1FT-426 and probably would have identified this deficiency."

Ex. 9.D.-2. As NRC Inspector Ward states, the piping contractor's quality control inspection procedures "are designed to detect the type of

( problem identified by the NRC in this weld installation package." Ward Affidavit at 118.

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The Staff has reviewed Applicant's corrective action relating to '

this deficiency. Because the weld which lacked proper documentation was removed and replaced and because Applicant's quality control program is designed and implemented to detect any recurrence of this problem, the Staff concerns have been resolved satisfactorily. It is for these reasons that NRC Inspector Ward closed this matter in Inspection Report Nos. 50-456/84040 and 50-457/84037.

There is no genuine issue as to any material fact concerning the second part of Subcontention 9.D and Applicant is entitled to a favorable decision on this part of the subcontention as a matter of law.

Therefore, the Motion for Summary Disposition on Rorem Subcontention 9.D should be granted.

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