ML20214C514
| ML20214C514 | |
| 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: |
| References | |
| OL, NUDOCS 8602210160 | |
| Download: ML20214C514 (47) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos.
50-456
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50-457 (Braidwood Station, Units 1 cnd 2
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AFFIDAVIT OF KAVIN D. WARD IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR
SUMMARY
DISPOSITION OF ROREM QA SU8 CONTENTION 9.D 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 Exhibit 9.D-1.
2.
As Reactor Inspector my duties consist of performing inspections on construction and operation of nuclear power plants in the 4
fields of nondestructive examination (NDE) and welding to assure that said activities are conducted in accordance with regulatory requirements and licensee commitments, including 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.D. This subcontention states:
9.
Contrary to Criterion IX, " Control of Special Process," of 10 C.F.R. Part 50, Appendix B, 2221868!Bii8fjh6 0
1 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 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.
Furthermore, the welder documented as performing the welding was not qualified.
In addition, RPS Division loop B, reactor records identifying (The words in brackets represent the welder or welder filler metal utilized.
corrections to Intervenors' misquotation of the NRC item of non-compliance set forth in Contention 9.D.)
4.
Subcontention 9.D encompasses two separate events.
Event I involves the alleged use of an unapproved structural steel welding procedure by an allegedly unqualified welder.
Event II involves the absence of complete documentation for a socket weld joint for instrumentation piping. A separate statement of material facts as to each Event was submitted by Applicant.
5.
In preparing this Affidavit, I have reviewed the following documents:
a.
" Material Facts As To Which There is No Genuine Issue to be Heard" for both Events with regard to Subcontention 9.D; b.
" Affidavit of. John D. Carlson (on Rorem Q.A.
Subcontention9.D);"
i c.
" Affidavit of Cedric Reynolds (on Roren [ sic] Q.A.
S'ubcontention 9.D);"
i d.
NRC Inspection Reports Nos. 50-456/84-17; 50-457/84-17 and Nos. 50-456/84-40 and 50-457/84-37 (attached hereto as Exhibits 9.D-2 and 9.D-3); and e.
Applicant's Response to Inspection Report 84-17, dated November 28, 1984 (attached hereto as Exhibit 9.D-4).
6.
With respect to Event I, in early August,1984, an NRC inspector reviewing a Newberg SSIT package, concluded that Newberg had used an unapproved flux core arc welding (FCAW) procedure specification (WPS) and that the weld had been performed by a welder who was not l
qualified to use the FCAW WPS. On August 10, 1984, Newberg issued a stop war.k order for all welding being done by Newberg onsite. On August 14, 1984, Commonwealth Edison Company (" Applicant") issued a stop work order with respect to the same work. The Edison stop work order indicated that it was to renain in effect until the problem identified by NRC could be investigated and necessary corrective action taken to prevent recurrence.
r 7.
Newberg first conducted an investigation of the specific problem identified by NRC. This investigation included a. review of the problem SSIT package and an interview of the welder involved, including a review of the welder's qualifications.
l 8.
Newberg's quality procedures were revised.
In the revised procedures, Newberg established a hold point for QC review and approval of the SSIT packages.
This hold point occurred before welding commenced in the field. To provide further assurance that the correct WPS had been used, Edison QA established a hold point after the completed SSIT l
packages had been reviewed by Newberg QRC. These revised procedures were
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i i made applicable to those packages in process at the time of the stop work order as well as all subsequent packages.
9.
Steps were taken to retrain the engineers and iron workers in the welding program to the latest approved procedures and requirements.
Newberg also developed an ongoing training program designed to prevent recurrence of this type of problem. Newberg began attaching copies of the proper WPS to each SSIT package. This was done to provide easy reference by production, as well as by quality personnel reviewing the packages.
10.
In addition to the actions taken to prevent recurrence of the problem, steps were also taken to ensure that any problems existing in SSIT packages which had been previously completed were identified. A detailed final review was ensured for all future SSIT packages.
To accomplish this, Newberg instituted QCP 29.1.
Under this procedure, checklists were established against which the all SSIT packages were to
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be reviewed.
11.
Inspection Report Nos. 50-456/84-17 and 50-457/84-17 stated that the inspection of this item showed that action had been taken to correct the identified noncompliance and to prevent recurrence, r
consequently, no reply to the item was required.
I agreed with the report and the action taken.
I consider this item to be closed.
- 12. Based on the investigation, it was concluded that the welder L
had used the correct welding process, shielded metal are welding (SMAW),
i for the joint in question.
It was also determined that the welder was fully qualified for the SMAW process. However, it was found that Newberg Engineering had specified, in the SSIT, the use of a FCAW WPS rather than l
a SMAW WPS.
It was also determined that the specified WPS, while it was a procedure which was prequalified by the American Welding Society, had not been reviewed and approved by the Applicant and the Architect / Engineer's specifications for Braidwood. The welder had copied this incorrect WPS number onto the section of the SSIT package where the WPS that was actually used was to have been identified.
- 13. An analysis was also made to determine whether the documentation problems found in the SSIT packages were reflected in hardware problems in the field.
It was determined, after analysis by the Applicant and Newberg, that the SSIT documentation problem did not reflect any deficiencies in structural steel welding performed by GKN.
- 14. With respect to Event II, in an inspection conducted between July 7 and August 31, 1984, an NP.C inspector identified an incomplete weld installation package prepared by Phillips, Getschow Ccmpany.
See Exhibit 9.0-2.
The weld installation package did not contain information identifying the welder or the weld filler material that was used on an instrumentation piping weld.
15.
In order to investigate and correct the problem identified by the NRC, Phillips Getschow instituted an NCR. To disposition the NCR, Phillips, Getschow removed the subject weld and installed a new weld in its place. All relevant information concerning the new weld was fully documented in the weld installation package. At the time that the weld installation package problem was identif'ied, it was the responsibility of Phillips Getschow's QC Supervisor to assure that all information was properly recorded on the weld installation package pursuant to Quality Control Procedure QCP-88 (Revision 5). To prevent recurrence of a
, 1 similar problem, Phillips Getschow procedures were revised to make it the duty of production personnel to document relevant information concerning weld insta,llation. This procedure revision was reflected in Quality Control Rrocedure OCP-821. Under the revised procedures, Phillips Getschow QC had only review responsibilities.
- 16. The weld installation package identified by NRC as being incomplete had not yet been the subject of a final review by Phillips Getschow QC pursuant to QCP-830.
I reviewed the corrective action taken by Phillips Getschow to assure the quality of the subject weld and to prevent recurrence of similar problems and found the documentation acceptable.
17.
Inspection Report Nos. 50-456/84-17 and 50-457/84-17 (Exhibit 9.D-2) stated that the inspection of this item showed that action had been taken to correct the identified noncompliance and to prevent recurrence; consequently, no reply to the item was required.
I agreed with the report, and the action taken, and consider this item closed.
- 18. The incomplete weld installation package identified by NRC was scheduled for review by Phillips Getschow QC in the routine course of its 1
document inspection activities under QCP-830. Phillips Getschow QC inspection procedures are designed to detect the type of problem l
identified by the NRC in this weld installation package.
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I closed these items in inspection Report Nos. 50-456/84-40 and 50-457/84-37 (Exhibit 9.D-3) on the grounds of the effective.
Implementation of the Applicant's corrective action.
.i Kavin D. Ward Sworn and subscribed before me this /IM day of February,1986
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Professional Qualifications
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KAVIN D. WARD U. S. NUCLEAR REGULATORY COMMISSION I am employed as a Reactor Inspector in the Region III, Materials and Processes Section.
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 a'nd have been since January, 1978.
In this capacity I perform inspections in construction and operating facilities in accordance with Codes, Standards and Guides.
I observe the performance of welding and nondestructive examination (NDE) of support personnel evaluate and report upon appraisal of their qualifications and performance, primarily in the fields of NDE and welding.
Participate in investigations involving or pertaining to nuclear facilities.
Prior to joining the Commission in. January,1978, I worked 7 years for Bechtel Corporation, San Francisco, California.
I held the position of Engineering Supervisor and was certified in various methods of NDE, including being a test examiner.
From 1970 to 1971, I was employed by Nebraska Testing Lab as a Quality Assurance Manager.
From 1969 to 1970, I was employed by Peter Kiewit Cons. Company as a Quality Assurance Engineer.
From 1968 to 1969, I was employed by Phillips Petroleum Co. as a Quality i
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.
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION
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f 799 ROOSEVELT ROAD GLEN ELLYN. OLUNOIS Got M OCT 16 884 Docket No. 50-456 A1
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Docket No. 50-457 M Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President l
Post Office Box 767 l
Chicago, IL 60690 Gentlemen:
This refers to the routine safety inspection conducted by Messrs. L. G. McGregor, R. D. Schulz, and J. F. Schapker of this office on July 7 through August 31, 1984, of activities at Braidwood Nuclear Power Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and CPPR-133 and to the discussion of our findings with Mr. D. Shan.'lin at the conclusion of the inspection.
u 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 described in the enclosed Appendix.
With respect to item 3, the inspection showed that action had been taken to correct the identified noncompliance and to prevent recurrence.
Consequently, no reply to this item of noncompliance is required and we have no further questions regarding this matter at this time.
l Regarding the remaining items, a written response is required.
1 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 letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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EXHIBIT 9.0-2 l
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[/- [0- 1 Comonwealth Edison Company 2
GCT 161984 We will gla~dly discuss any questions you have concerning this inspection.
' Sincerely, 80riginal sig.:e '- '. 7. '.'rnick" R. F. Warnick, Chief Projects Branch 1
Enclosures:
1.
Appendix, Notice of Violation 2.
Inspection Reports No. 50-456/84-17(DRP);
No. 50-457/84-17(DRP) 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.
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Appendix NOTICE OF VIOLATION Comonsealth Edison Company
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Docket No. 50-456 Docket No. 50-457 As a result of the inspection conducted on July 7 through August 31, 1984, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
The C:::: onwealth Edison Quality Assurance Manual requires in Q. P.
No. 4-1 that bidders be approved and placed on the approved bidders list, that purchase orders be reviewed and accepted by the quality assurance department to assure that the necessary technical and quality requirements are included in the procurement documents, and that the procurement is being made from the plant location for which the Quality Assurance Program is approved.
Contrary to the above, on May 17, 1981 and July 9,1981, Comonwealth Edison placed purchase order numbers 730091 and 254379, respectively, with an unapproved bidder that did not have an approved quality assurance program.
The purchase orders were for the cleaning of 206,744 feet of safety-related piping, which was to be installed in ASME Section III, Class NC and ND systems and safety-related instrumentation. piping systems.
Furthennore, the purchase orders were not reviewed and accepted by the Comonwealth Edison Quality Assurance Department to assure that the l
necessary technical and quality requirements were addressed, and the purchase orders had no reference to quality assurance program requirements.
This is a Severity Level IV Violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion XV, states in part:
" Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations."
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Appendix 2
10 CFR 50, Appendix B, Criterion XVI, states in part:
" Measures shall be established to assure that conditions adverse to ouality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above. 337,350 feet of safety-related pipe was received in 1977 and rejected on April 9, 1979 due to rust, scale, and failure to cap the pipe ends. The pipe was not placed on hold to prevent withdrawal and installation in safety-related systems. As a result, some of the pipe was installed in the plant.
In addition, the rejected pipe was not properly dispositioned in that only 206,74.4 feet of pipe was chemically cleaned.
This is a Severity Level IV Violation (Supplement II).
3.
10 CFR 50, Appendix B, Criterion IX and the Comiconwealth Edison Quality Assurance Manual state in part that measures shall be established to assure that special processes, including welding are controlled and accomplished by qualified personnel using oualified procedures.
Structural Steel Quality Control Procedure, Section 1, QAM and QC Procedure Control, Revision 3, and the Comonwealth Edison Quality Assurance Manual, Q. P. No. 5.1 require in part that quality procedures be approved for use by the architect engineer.
Piping Welding Procedure IA-88-0, Revision 8, designated for use on drawing 1FT-426, Sheet 2, Revision B, requires the use of ER308 weld filler metal.
Contrary to the above:
a.
A quality structural steel, flux core welding procedure, 43GW-11 Revision 0, June 11, 1984, was not approved for use by the architect engineer, but was released for use in installation traveler Number 5832 by the structural steel contractor, and documented as being used for cover plate welds.
Furthermore, the welder documented as perfonning the welding, was not qualified to utilt e quality welding procedure,43GW-11, Revision 0, dated June 11, 1984.
b.
RPS Division Loop B, reactor coolant flow, completed socket weld joints, identified as FW21 and FW22 on drawing IFT-426, Sheet 2, Revision B, have no piping records identifying the welder or weld filler metal utilized for the pipe-elbow connections.
This is a Severity Level V Violation (Supplement II).
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Appendix 3
With respect to Item 3, the inspection showed that action had been taken to correct the identified item of noncompliance and to prevent recurrence.
Ccnsequently, no reply to this item of noncompliance is required and we have no further questions regardin'g this matter.
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance except Item 3:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved, your response time for good cause shown., Consideration may be given to extending OCT 161984 gp 74g Dated R. F. Warnick, Chief Projects Branch 1 l
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s U. S. NUCLEAR REGULATORY COPMISSION REGION III Report No. 50-456/84-17(DPR); 50-457/84-17(DPR)
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:
July 7, 1984 through August 31, 1984 Inspectors:
L. G. McGregor R. D. Schulz J. F. Schapker Approved By: W L.
ne Chief V
Projects Section IA Date Inspection Summary Inspection on July 7 through August 31, 1984 (Report No. 50-456/84-17(DPR);
50-457/84-17(DPR))
Areas Inspected:
Soutine, unannounced safety inspection of work activities observed during plant tours, items reported pursuant to 10 CFR 50.55(e),
r Inspection and Enforcement Bulletins, licensee action on previous inspection findings, structural steel and supports, and instrument piping and tubing.-
The inspection consisted of 128 inspector-hours onsite by three NRC inspectors including 13 inspector-hours onsite during off shifts.
Results:
Of the six areas inspected, no items of noncompliance were identified in the area of items reported pursuant to 10 CFR 50.55(e); Inspection and Enforce-ment Bulletins; and licensee action on previous inspection findings; two items of noncompliance were identified as a result of plant tours (deficiencies in the control of small bore piping, paragraph 2); and one item of noncompliance was t
identified (inadequate welding controls and insufficient records, paragraph 4 and
- 5) in the areas of structural steel and supports and instrument piping and tubing.
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- 2-DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
- M. Wallace, Project Manager
- G. Fitzpatrick, Assistant Manager Quality Assurance Corporate
- D. L. Shamblin, Construction Superintendent
- C. Schroeder, Licensing and Compliance Superintendent C. J. Tomashek, Startup Superintendent "T. Quaka, Quality Control Supervisor
- L. Tapella, Engineer G. Groth, Lead Mechanical Engineer J. Gieseker, Construction Supervisor S. Hunsader,. Quality Assurance Supervisor E. R. Wendorf, Project Field Engineering Mechanical Supervisor
- M. Poland, Field Engineer
- R. Rowland, Quality Assurance Inspector
- D. A. Boone, Field Engineer R. Wrucke, Licensing Engineer M. Gorski, Engineer
- L. K,line, Licensing Engineer C. Gray, Structural Engineer B. Pickell, Quality Assurance Engineer Phillips Getschow Company (PGCo)
T. G. O'Connor, Site Manager K. J. Hamilton, Consultant R. Hamilton, Welding Supervisor J. Carlson, Quality Control Supervisor J. Stewart, Project Engineer L. J. Butler, Assistant Quality Control Supervisor M. Galloway, Assistant Project Engineer J. Murphy, Administrative Assistant, Quality Control S. Hamilton, NDE-Level II M. Budzowski, Quality Control Foreman
- S. Forbes, Quality Assurance Coordinator G. K. Newberg Company (GKN)
- D. Craven, Project Manager
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- J. J. Hairston, Quality Assurance Manager D. Gorham, Quality Records Clerk F. Replogle, Quality Assurance Engineer C. Reynolds, Quality Assurance Engineer L. K. Comstock and Company, Inc. (LKC)
F. Rolan, Project Manager R. M. Saklak, Quality Control Supervisor l
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F. Forest, Site Manager T. Frazier, Assistant Site Manager
" Denotes those attending exit meeting on August 31, 1984.
2.
Plant Tours The inspectors observed work activities in progress, completed work, and plant status during general inspections of the plant.
Observation of work included structural high strength bolting, safety-related pipe welding, l
anchor bolts, structural welds, flange bolt-ups, and cable trays in the containments and auxiliary building.
Particular note was taken of material i
identification, nonconforming material identification, housekeeping, and equipment preservation.
Craft personnel were interviewed, as such personnel were available, in the work areas.
During one of the tours, a construction worker asked the Senior Construction Resident to investigate the installation of some small bore piping, identi-fied as heat number KD6751.
Subsequent investigation revealed that Common-wealth Edison notified the USNRC, by telephone, on June 21, 1984, of a 10 CFR 50.55(e) regarding wall thickness inadequacies for 2" S/80 pipe, heat number KD6751, and on July 20, 1984, submitted written notification in accordance with the thirty day reporting requirements.
The July 20 letter stated that the reduced wall thickness, which was primarily caused by pits and grooves, was the result of excessive corrosion and quantities of this pipe had been installed in various ASME and instrumentation safety related systems.
The letter included a section entitled " Analysis of Safety Impli-cation and Corrective Action Taken" which are detailed below:
Analysis of Safety Implication "The reduced wall thicknesses could result in certain. piping systems not meeting the code stress allowables.
If left undetected, this condi-tion could potentially result in pipe failure and negatively impact on its associated system safety functions."
Corrective Action Taken
" Commonwealth Edison Company NCR No. 633 has been initiated to address this problem.
Investigations conducted to date have indicated that this problem is limited to heat number KD6751 pipe.
That portion of this l
heat number which remains in storage has been placed on hold.
No release of this material will be authorized until measurements confirm that the l
pipe meets the minimum wall thickness requirements.
In order to determine the adequacy of pipe from this heat number which has already been installed, a program is being developed to measure, in detail, wall thicknesses of the most severely pitted or grooved pipe currently in storage.
Measurement results will be sent to Sargent and Lundy for evaluation and subsequent piping system assessments.
The 3
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extent of field inspections and rework will be determined based o'n the results of the Sargent and Lundy investigation.
When this lot of pipe was initially received, it was stored outdoors for an extended pe.riod of time which resulted in excessive corrosion.
i This condition was observed in the field and the pipe was subsequently chemically cleaned and stored' indoors.
A review has been conducted of the bulk storage of safety-related two inch and under carbon steel pipe by the Commonwealth Edison Company.
The results of this review indicate that present storage practices prevent excessive corrosion of pipe due to outdoor exposure.
A follow up report will be submitted following the initial investigation by Sargent and Lundy which is expected by October 1, 1984."
The Senior Construction Resident Inspector performed a detailed investig-ation and discovered that numerous heats of ASME Section III pipe were stored i
outdoors for extended periods of time and were subject to corrosion.
Commonwealth Edison had received the following heats of safety-related SA-106GR-B pipe in 1977:
Heat No.
Size / Schedule Quantity KD6830 2" S/80 5,709 feet i
KD6751 2" S/80 55,000 feet 273088 2" S/160 1,509 feet H07760, JD1571 1 1/2" S/80 54,390 feet HD7760 1 1/2" S/160 2,006 feet KD7115 1" S/80 59,145 feet KD7115 1" S/160 3,014 feet J01570 3/4" S/80 45,086 feet KD6830 1/2" S/80 38,341 feet H07643
.3/8" S/80 73,150 feet TOTAL 337,350 feet In an inspection report on April 9, 1979, the quality control department of the piping contractor rejected the pipe, detailed above, due to rust, scale, and failure to cap the ends of the pipe.
The pipe being uncapped allowed water and snow to settle on the inside of the pipe.
On April 23, 1979, the i
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piping contractor's Quality Assurance Manager wrote this memo to the piping j
contractor Quality Control Supervisor:
"It is my recommendation that all the two inch and under pipe on the i
east side of the railroad tracks outside of the Phillips, Getschow building be pickled to remove the extensive rust and scale buildup that occured during storage."
The Quality Control Supervisor replied on April 22, 1979, in memo form, stating:
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"Since CECO has ordered and purchased this* pipe, your recommendation has been forwarded through P.G.Co.
Engineering Department to Ceco.
for their disposition and resoli. tion."
tio action was taken by Commonwealth Edison or Phillips Getschow Compa,ny, the piping contractor, until May 5,1981 when Phillips Getschow Company initiated Nonconformance Report Number 569.
The nonconformance stated that the pipe listed below was unacceptable due to rust:
Size Sch Spec & Grade Quantity Heat #
2" 80 SA-106 GrB 47,850 FT KD 6751 2"
80 SA-106 GrB 888 FT KD 6830 2"
160 SA-106 GrB 1,550 FT 273088 1 1/2" 80 SA-106 Gr8 36,483'FT HD 7760 1 1/2"
. 160 SA-106 GrB 1,702 FT HD 7760 1 1/2" 80 SA-106 GrB 7,943 FT JD 1571 1"
80
'5A-106 GrB 45,402 FT KD 7115 3/4" 80 SA-106 GrB 41,860 FT JD 1570 1/2" 80 SA-106 GrB 31,472 FT KD 6830 3/8" 80 SA-106 GrB 77,064 FT, HD 7643 TOTAL - 292,164 FT On May 17, 1981 and July 9,1981, Commonwealth Ettison, on Purchase Order Numbers 730091 and 254379 respectively, sent the f9llowing SA-106 GrB, safety-related pipe to the H. H. Howard Corporation in Chicago, Illinois to be cleaned:
\\
uantity Heat No.
Size / Schedule Q
KD 6751 2" S/80 45,878 feet 273088 2" S/160
\\876 feet JD 1571, HD 7760 1 1/2" S/80 45,423 feet HD 7760 1 1/2" S/160 1,554 feet KD 7115 1" S/80 44,758 feet JD 1570 3/4" S/80 35,514 feet KD 6830 1/2" S/80 27,940 feet HD 7643 3/8" S/80 3,329 feet FD 7115 1" S/80 1,472 feet TOTAL - 206,744 feet The purchase orders stated the method to be used in cleaning the pipe which included:
Soak in bath of caustic soda at 160 degrees F until mill coating is removed.
Submerge pipe in 10 percent sulphuric acid at 160 - 180 degrees F to remove all scale and oxidation.
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Clear water rinse.
Submerge into wyandate #6 metal cleaner at 160 degrees F.
Air dry and inspect to make sure all scale and oxidation is removed.
Cover the ends of each bundle'with visqueen covering.
Examination of the purchase or@rs revealed:
a.
The vendor was not an approved bidder as required by the Comonwealth Edison Quality Assurance Manual which states in part in Q. P. No. 4-1, Request for Bid, Proposal Evaluation and Recomendation:
"Ouality Assurance shall verify that necessary technical and quality requirements are included, the proposed bidders are acceptable by verifying they are on the Approved Bidders 1.ist and the procurement is being made from the plant location for which the Quality Assurance Program is approved."
Approval of a vendor documents that the vendor has an approved quality assurance program and is capable of supplying products or services in accordance with standards required for the nuclear industry.
b.
The purchase orders were not reviewed and accepted by the Quality Assurance Department, which is required to be done by the Comonwealth Edison, Quality Assurance Manual in Q. P. No. 4-1.
Quality Assurance could not, therefore, assure that the necessary technical and quality requirements were included in the purchase orders. There were no references in the purchase orders to Quality Assurance program require-ments such as 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes.
10 CFR 50, Appendix B, states in.part in Criterion IV:
"To the extent necessary, procurement documents shall require contractors or subcontractors to provide a Quality Assurance program consistent with the pertinent provisions of this appendix."
Items a and b above are in violation of 10 CFR 50', Appendix B, Criterion V, Failure to Follow Procedures.
(456/84-17-01; 457/84-17-01)
Sumarijng the chronology of events:
Phillips Getschow Co. rejected on April 9, 1979, 337,350 feet of pipe due to rust.
No action was taken until May 5, 1981, when Phillips Getschow Co.
identified on Nonconformance Report No. 569 a total of 292,164 feet of unacceptable pipe due to rust, and dispositioned the 292,164 feet to be cleaned.
Purchase Order Number 730091, placed on May 17, 1981, and Purchase Order Number 254379, placed on July 9, 1981, provided for the cleaning of only 206,744 feet of pipe.
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dit. 9 p-z The investigation by the Senior Construction Resident revealed, as evidenced by the above dates, that Phillips Getschow Co. and Comonwealth Edison Company did not correct the rusted pipe condition in a timely manner.
Further-more, the licensee did not prevent the rusted pipe from being withdrawn from storage areas and. installed in safety-related systems.
Not only was heat j
number KD 6751, 2" S/80, installed.in safety-related systems as stated in i
the 10 CFR 50.55(e) report, but numerous other heats of pipe, identified as being in a rusted condition, were withdrawn and installed.
For example, 200 feet of heat number KD 680, 1/?" S/80 pipe was withdrawn for installation i
on February 16, 1981 for the essential service water system and another 200 feet was withdrawn on March 3,1981 for the same safety-related system.
The pipe identified on April 9, 1979 was not placed on hold to prevent with-drawal and installation.
Since 337,350 feet was identified 'as being in a rusted c'ondition and only 206,744 feet was cleaned, it is apparent that a significant amount of pipe has been installed, some of which is installed in safety-related systems.
Failure to control the rusted pipe is in violation of 10 CFR 50, Appendix B, Criterion XV and failure to correct the deficient condition is in violation of 10 CFR 50, Appendix B, Criterion XVI.
(456/84-17-02;457/84-17-02)
Phillips Getschow Company Nonconfonnance Reports Numbers 1294, 1524, 1525, and 1611 written on December 7, 1983, May 17, 1984, May 17, 1984, and June 13, 1984 respectively, identified 2" S/80 pipe, Heat No. KD 6751, with ribbon groove indications that caused the pipe to be rejectable for minimum wall violations.
Recent Connonwealth Edison analysis by their System Material Analysis Department stated that the pipe, (Heat KD 6751), experienced metal loss and pitting due to one or more of the following conditions:
ribbon groove indications, l
outdoor storage, and overpickling(cleaningvendor).
All of the pipe rejected on April 9,1979 was stored outdoors and 206,744 feet of aumerous heats were pickled. The Senior Construction Resident met with Comonwealth Edison representatives on August-20, 1984 and requested the licensee to address the following question:
What evidence exists to assure that the heats, other than KD 6751, l
identified on April 9,1979, do not have minimum wall deficiencies?
(Heat number KD 6751 was identified in the 10 CFR 50.55?e) report as having minimum wall violations.) A factor the licensee is taking into account is that apparently only heat number KD 6751 had ribbon groove indications which may have W tributed to the minimum wall deficiency.
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This question will remain an open item (456/84-17-03; 457/84-1?.03). The licensee needs to determine if the rusted condition is significant in rela-tion to. pitting and minimum wall violations for all the heats identified'on April 9,1979, and that the worst case wall tr.*ckness degradation can be or has been identified and analyzed for acceptability. At the close of the inspection the licensee believed that heat number KD 6751 contained pipe that failed to meet minimum wall thickness.
A positive factor is that although ASME and ASTM minimum wall is 121/2%
below nomina.1, many of the piping systems are overdesigned to allow wall reduction significantly below the 12 1/2% figure. This overdesign is being analy ed by the licensee and will be a factor in determining deficiency significance.
i During other plant tours, the NRC inspectors noticed that the flange bolt-ups of the piping contractor were heavily rusted around the thread areas of the bolts.
In addition, some of the essential service water flange bolt-ups were noted to have missing bolts and inadequate thread engagement. The Senior Construction Resident Inspector discussed these issues with the piping contractor's Quality Control supervisor and construction manager. The inspector learned that the piping contractor was aware of past bolting dccu-mentation deficiencies and a retro-fit program was in the process of being submitted to Connonwealth Edison that would address documentation deficiencies and would reconsend a visual retro-fit program to idantify the type of findings existing in the essential service water system.
Pending licensee evaluation and resolution with regard to flange bolting acceptability, this issue will remain open (456/84-17-04; 457/84-17-04). The present system of control by the piping contractor is adequate to assure correct bolt-ups.
3.
Items Reported Pursuant to 10 CFR 50.55(e)
The inspector examined the licensee's corrective actions relative to the deficiencies listed below:
(Closed) 456/83-06; 457/83-06:
Elcen Metal Products supplied spring hangers with a carbon content in excess of the applicable ASME B&PV Code,Section III, Subsection NF limit.
Replacement spring hangers were supplied for those hangers which did not meet the ASME Code. An evaluation and analysis of the balance of the variable spring hangers concluded that the hangers would meet the Load Capacity Data Sheet Specification and therefore are acceptable for use.
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(0 pen) 456/82-10; 457/82-10:
On November 19, 1982, a deficiency was reported regarding missing inspection records for structural bolted and welded connec-tions. An updated report on May 7, 1984 stated in part:
"The deficiency is limited to G. K. Newberg's installation of blockwall columns and miscellaneous structural steel in the Auxiliary Building.
A continued review of the records for bolted and welded inspection reports is being performed during the progress of the inspection program.
This continual review of records has identified a revised total of 1,282 weld connections of 2,0?8 total and 484 bolted connections of 825 total with missing inspection reports.
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Lack of independent inspection of these connections does not imply that the connections are in any way defective.
The safety implications can only be established with a case-by-case analysis of the as-found condi-tions of individual connections.
All of G. K. Newberg's accessible welded and bolted connections will be inspected.
Bolt and weld inspection on inaccessible connections will be on a statistical basis for those connections with missing records.
The existing statistical sampling plan has been utilized to establish a new sample in accordance with Military Standard 1050 for a multiple sampling method.
The acceptance criteria will be based on yielding a 95% confidence /
i 95% reliability level.
This program will verify installation using the same procedure requirements applied'during initial installation."
An additional report was submitted to the NRC on July 3,1984, which stated in part:
"A statistical sample of 180 inaccessible bolted and welded connections with missing records is being inspected utilizing Military Standard 1050.
Currently, all but 6 inaccessible weldad and bolted connections of the sample have been inspected.
The Commonwealth Edison Company has submitted 155 inspection reports out of the 180 sample total to Sargent & Lundy (S&L) for evaluation.
A total of 25 (which includes the 6 above) remain to be submitted.
As of June 19, 1984, S&L has evaluated 40 of the 155 submitted reports, and of these 40 evaluations, all were considered acceptable.
Commonwealth Edison is currently clarifying 19 reports to provide additional information. requested by S&L.
Because further clarification may be required concerning some items in order for S&L to complete their evaluation of the sampling, we now anticipate a final resolution by October 1,1984, at which time another interim or final report will be issued."
The Senior Construction Resident inve'stigated the circumstances and documen-tation concerning the blockwall columns and miscellaneous structural steel and discovered that Pittsburgh Testing Laboratory performed a statistical sample inspection of the welds, and of 708 welds inspected 356 welds were rejected for failing to meet the quality standards of the AWS D1.1, Structural Welding Code.
Deficiencies in the welding included such factors as craters, undercut, gaps, weld placement, alignment, and insufficient weld length.
The licensee committed to the AWS D1.1 Structural Welding Code in the FSAR, Volume 7.
The AWS D1.1 Structural Welding Code states in part in Section 6, Inspection, that the inspector shall make certain that the size, length, and location of all welds conform to the requirements of this code and further states that the inspector shall examine the work to make certain that it meets the requirements of Section 3, Workmanship.
Both Senior NRC Residents i
examined some of these welded connections and found the work to be deficient with regard to the AWS D1.1 Welding Code Standards and not representative of l
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other structural steel welding in the plant, which meets or surpasses AWS 01.1 Structural Welding Code quality standards.
The Senior Residents met with licensee representatives and requested the licensee to address the following questions:
1 (1) Since the AWS 01.1 Structural. Welding Code requires that all welds be inspected and the AWS D1.1 Code is an FSAR commitment, what is the licensee's justification for a sampling plan?
(2) Based on 356 welds rejected out of 708, (over 50%), how will a statis-tical sampling plan assure the worst case weld has been found, consi-dering the variables involved such as welder, welding procedure, and welder accessibility in completing the weld? The licensee stated in the 10 CFR 50.55(e) report, "The safety implications can only be established with a case-by-case analysis of the as-found conditions of individual connections."
(3) Since the licensee was aware that the welding did not meet the AWS D1.1 Structural Welding Code, why wasn't this communicated to the NRC in the May and July, 1984 10 CFR 50.55(e) reports?
Licensee management immediately responded to question (3), stating that the deficiencies with regard to the AWS D1.1 Code would have been reported in the final 10 CFR 50.55(e) report.
The licensee is presently reviewing the NRC inspector's concerns and evaluating the basis for only performing sample inspections of the welds and bolting connections.
An updated 10 CFR 50.55(e) is also being drafted for submittal to the NRC which will include statements with reference to AWS D1.1 Structural Welding Code deficiencies.
This ites will remain open (456/84-17-05; 457/84-17-05).
4.
Inspection and Enforcement Bulletins The inspector examined licensee actions relative to the Inspection and Enforcement Bulletins listed below:
(Closed) IE Bulletin 83-01:
Cracks in BWR Mark 1 Containment Vent Headers.
As Braidwood is a PWR, this bulletin is not applicable.
(Closed) IE Bulletin 84-02:
Failure of General Electric Type HFA Relays in Use in Class 1E Safety Systems.
All HFA relay coils used in non-safety-related applications have been replaced.
There are no safety-related systems containing HFA type relays at Braidwood Station.
(Closed) Follow-up on IE Bulletin 81-03 as requested by Region III Memorandum.
The Commonwealth Edison Company has taken an active role in heat exchangers and condenser cooling water systems at both nuclear and fossil fired stations.
During the 1970's, Corbicula sp. shell accumulation in piping systems was recognized as a potential hazard at the Kincaid Station.
At that time, acrolein and chlorine were known to cause mortality in Corbicula sp.
How-ever, plant effluent restrictions prohibited their effective use.
As a substitute, Zimmite ZM1000 was utilized without success.
Commonwealth 10
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l hD2 Edison's literature searches of the Oak Ridge National Laboratory computer files failed to provide either a theoretical or experimental solution to the Corbicula sp. infestation problem.
Since the beginning of Corbicula sp.'
infestations within CECO stations, the cleaning of and physical removal of clams from heat exchangers has been an effective means for maintaining heat exchanger performance.
The Commonwealth Edison Company is closely following the research being sponsored by EPRI and performed by Stone & Webster which is intended to lead to Corbicula sp. control.
CECO is particularly interested in the study which will create toxic biofouling surfaces through an application of an anti-foul paint containing tributyl tin floride (TBTF).
Ceco is also interested in the work that will be conducted by Murray State University which will determine the toxic effect on Corbicula sp. of TBTF pellets in cboling water systems.
The Commonwealth Edison Company is also evaluating the use of carbon dioxide (CO ) as a possible molluskicide.
The reason for selecting CO2 was based on 2
the fact that it has been used as a chemical to narcotise zooplankton and mollusks as well as fish by researchers.
In 1982, the first series of bioassays were performed at the Collins Station, in order to take advantage of the carbon dioxide treatment system, and in the Quad Cities Fish Lab where carbon dioxide, sodium hypochlorite and water flow rates could be varied.
Screening bicassay studies exposed adult Corbicula sp. to various concen-trations of CO in water temperatures of 13*-16* C.
After exposing class 2
to up to 500 mg/l CO2 for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Corbicula sp. were narcotised.
Corbicula sp. exposed to 500 mg/l for periods of time in access of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> resulted in 50% plus mortality at water temperatures of 13*-16* C.
The data collected during these tests at both Collins and Quad Cities suggests that adult size asiatic clams can be killed by carbon dioxide injection into continuously flowing systems and offers promise for controlling adult Corbicula sp. in service water systems.
Decreased performance in heat transfer equipment due to fouling can be detected by increases in the temperature of the cooled fluid either at the cooled fluid discharge or at the components which receive cooling from this medium.
An alternate means of fouling detection is the monitoring of the pressure drop across heat exchangers.
Flow blockages in heat transfer equipment effectively increases the resistance to fluid flow thereby creating a deviation from the design pressure drop.
Flow rate tests are another means for determining whether or not heat transfer equipment is operating at design flow rates and pressures.
If heat transfer equipment exhibits a tendency to become fouled by Corbicula sp., additional surveillance, cleaning or treatment programs will be consi-dered as appropriate.
In order to keep abreast of potentially changing conditions, the forebay of the cooling lake intake screenhouse will be surveyed at the Braidwood site on an annual basis, for the presence of Corbicula sp.
CECO has instituted an annual summer inspection program of the Braidwood coolant lake, and continues in its quest to find species of Corbicula.
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During the past three years no genus of Corbicula have been detected in the Braidwood coolant lake.
Heat transfer data (^T and 'P) and system flow requirement will also be monitored by the licensee to detect any decreasi in heat exchanger performance.
The extremely active role pursued by the licensee to identifying Corbicula existence and evaluating the different methods of controlling Corbicula and Mytilus is continuing at the Braidwood Station, and has accomplished the intent and requirements of IE Bulletin 81-03.
This site reinspection effort suggests that the Bulletin remain closed (Inspection Report 81-13) and followup inspection by Region III Environmental Inspectors continue to monitor the licensee program with regard to identifi-cation and control of these biological species which promote heat exchanger fouling.
5.
Licensee Action on Previously Identified Items (Closed) Unresolved Item 456/84-06-02; 457/84-06-02:
The inspectors
- con-cern involved the assurance that all required electrical installations were installed and inspected to the latest drawing revision.
L. K. Comstock Engineering is now reviewing each drawing revision to assure the work required by that revision is flagged to the production forces.
Additionally, plant areas, are walked down by engineers to determine whether installation reports are being submitted as required.
A final check is to be provided by a computer i
I system, which will list all components, such as conduit, supports, cable trays, required to be installed and status the components with regard to:
Latest drawing revision, Installation in accordance with the correct drawing revision, and Inspection in accordance with the correct drawing revision.
(Closed) Open Item (456/82-03-02; 457/82-03-02)
An agreement between the installer and the NOE contractor,, revealed some confusion on part of the installer and a discrepancy between a statement in the agreement and the actions of the Authorized Nuclear Inspector (ANI).
l The inspector reviewed the revised letter of agreement, dated 8-2-82, which clarifies the performance of surveillance activities of the NDE contractor by the ANI. Review of the ANI's surveillance records indicates scheduled surveillances are performed as required.
This item is considered closed.
(Closed) Open Item (456/82-03-06; 457/82-03-06)
Based on interviews of inspectors, it was apparent that some areas were in need of additional inspectors to ensure that a backlog of inspections does not exist and that increased work efforts do not compound the inspection program.
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fr.hD-t The inspector reviewed current inspection manpower in conjunction with craft persons.
The current Q.C. manpower has increased approximately two hundred percent, whereas the craftsmen have only increased twenty-five percent.
Based on this substantial increase in Q.C. manpower, the above i
item is considered resolved.
(Closed) Noncompliance (456/82 1; 457/82-01-01)
Contrary to drawing requirements, the stressing sequence for post tensioning i
was performed in the form of a letter from the contractor which was then approved ar.d used to control. the work.
The inspector reviewed a sample of tendon stressing cards and quality control records to verify that the tendons were stressed in accordance with procedure 70, revision 13, dated April 28, 1982, which specifies the proper sequencing; those performed out of sequence were properly recorded and approved on Field Change Request.
This item is considered closed.
(Closed) Noncompliance (50-456/82-03-04; 457/82-03-04)
The electrical contractor procedures did not provide adequate instructions in that L. K. Comstock (LKC) procedure 4.8.1, Inspection of Class 1E Safety Related Conduit Installations, did not address the inspection of caps / plugs in conduit to prevent foreign matter from entering the conduit.
LKC proce-dures 4.3.8, Cable Installation, and 4.8.8, Cable Installation Inspection, did not address electrical cable rework.
The above procedures have been revised and adequately address the inspectors findings.
This item is considered closed.
1 (Closed) Noncompliance (456/82-03-01; 457/82-03-01) l a.
On May 28,.1982, it was identified that Phillips Getschow Co. was not stamping and marking affected documents to annotate applicable ECN's.
This is contrary to Phillips Getschow Co. Construction Procedure PGCP-7.
The inspector selected a random sample of ECN's/FCR's and verified the applicable drawings were marked with the ECN/FCR or incorporated in the drawing.
One completed item was selected for field observation and verification of. work incorporated per applicable ECN.
This item is considered closed.
b.
On May 27, 1982, it was identified that the Phillips Getschow Co. (PGCo)
Quality Assurance Manager had not prepared a training requirement sheet for the Braidwood site during the first and second quarters of 1982.
This was contrary to PGC's Quality Assurance Procedure QAP-105A.
The inspector reviewed the revised procedure, training records and training matrix for compliance to training matrix requirements.
The training requirement sheet was completed to include the first two quarters of 1982 and kept current since that date.
This item is considered closed.
On June 2, 1982, it was identified that a L. K. Comstock and Co., Inc.
c.
(LKC) portable weld rod oven was not plugged in as required by LKC procedure 4.3.10.
The contractor initiated Q. C. surveillance of 13
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portable weld rod ovens on a weekly basis.
The inspector reviewed the weld rod surveillance reports for July 82 through July 84.-
The surveil-lance has been perfonned a minimum of twice a week and appears to have resolved this deficiency. The inspector perfonned a surveillance of
- the auxiliary building to observe that LKC portable weld rod ovens were properly engaged and calibrated, no deficiencies were noted. This item is considered closed.
d.
On June 1,1982, it was identified that weld stub barrels in the auxi-liary, containment, and containment air lock areas had abundant amounts of unbent weld rods, as well as weld stub barrels at Cribs #3 and #4 not being secured or welded shut. A stub barrel in the Unit one air lock was also noted to be unlocked. This is contrary to Phillips Getschow Co. Quality Control Procedure QCP B.8.
The inspector toured the containment and auxiliary buildings to observe weld rod control and proper securing of weld rod stub barrels.
No uncontrolled weld rod was observed and all stub barrels were padlocked.
This item is considered closed.
6.
Structural Steel and Supports The following documents were reviewed:
Specification F/L-2722, General Structures Work through Revision 32, May 16, 1984.
Gust K. Newberg Quality Control Procedure Section 55, Revision 0, AWS Visual Welding Inspection including Appendix I, Visual Weld Acceptance Criteria.
The NRC inspector found the documents to be in compliance with the AWS DI.1, Structural Welding Code and regulatory requirements.
Two completed structural steel traveler packages, which document the com-pleted work, were reviewed in the Gust K. Newberg site office. One instal-lation traveler, No. 5706, was for a bolted, structural beam connection in Containment 2, outside the secondary shield wall. The other installation traveler, No. 5832, involved welding cover plates to beam 74210, and was also located in containment 2.
Documentation checks included:
Storage release requisitions, Material test reports, Magnetic particle test reports.
Ultrasonic test reports, Welding procedure qualifications Welder qualifications, Material traceability (weld filler metal),
j Plumbness, alignment, Thread projection, Welding acceptability, Drawing conformance, l
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Fit-up gap dimensions, and Quality control inspector certification.
No deficiencies were identified with regard to Traveler No. 5706; however, the inspector identified deficiencies for Traveler No. 5832.
The quality welding procedures authorized for.use by Newberg engineering personnel on April 12,1984, included quality welding procedure 43GW-11, Revision 0, June 11, 1984 This flux core arc welding procedure had not been approved for use by Sargent and Lundy, the architect engineer, as required by Gust K. I:awberg Quality Control Procedure, Section 1, QAM and QC Procedure Control, Revision 3; and the Commonwealth Edison Quality Assurance Manual, Q. P. No. 5-1.
Furthermore, the quality welding procedure 43GW-11 was docu-mented in the Field Verification Section as being used, and a welder (A-4),
I who was not qualified for flux core welding, was documented as being the welder _that performed the welding in accordance with the flux core procedure 43GW-11. The inspector brought these findings to the attention of the licensee and the licensee subsequently proceeded with their own investigation.
On August 10, 1984, after investigating the issues the licensee stopped all structural steel welding and notified the NRC of a potential 10 CFR 50.SS(e) report which included the following licensee findings:
"A review of Gust K. Newberg welding has revealed some inconsistencies in the GKN welding program.
Those inconsistencies identified initially include:
(1) GKN engineers specifying AWS weld process specifications that had not been incorporated into GKN welding procedure for flux core welding, (2) GKN ironworkers welding to AWS prequalified details that were not approved by Sargent & Lundy for the flux core procedure or were not specified by the GKN engineer and (3) GKN ironworkers listed procedures on travelers packages as being used that they did not use.
Initial investigation has indicated that this problem is confined to flux core arc welds on some cover plate installations in Unit 1 and Unit 2 Containments and box beam end connection modifications in Unit 1 Containment which total a maximum 272 packages out of 6500 packages done since November 1982."
i On August 20th, after reviewing the traveler packages and re-training engineering and craft personnel, the stop work order was lifted by the licensee.
Failure to control structural welding is in violation of 10 CFR 50, Appendix B, Criterian IX.
(456/84-17-06;457/84-17-06)
However, licensee corrective action was prompt and thorough.
The inspector also examined support steel to beam-walding and support steel to beam-bolting in Containment 2.
Beams examined included beam number 94204 and beam number 5280.
The welding and bolting was in accordance with traveler and drawing requirements, and material used was traceable to certificates of compliance or certified material test reports.
Welders were interviewed and appeared to be knowledgeable in AWS D1.1 code requirements. The meterial release storage areas were surveyed and the inspector discovered that material was withdrawn by craft personnel instead of being released by a warehouse supervisor. Although all the material was 15 i
properly identified for release, it is difficult to assure that each and every craftsman selects the correct material without designated personnel i
respons.ible for correct material issuance.
Quality control assures the correct material was used after installation, but an optimum system assures that the correct material is selected for installation.
The inspector discussed this issue with the licensee and the licensee decided to appoint warehouse supervisors who would be responsible to sign out the material for the correct application. The inspector considers this issue closed.
7.
Instrument Piping and Tubing The instrument pipe and tubing installation program was reviewed for compliance with the ASME Boiler and Pressure Vessel Code,Section III, 1974, Summer of 1975; Sargent and Lundy Specification L-2739, and regulatory requirements.
Procedures reviewed included:
I'GCP-30, Installation of ASME Section III and Safety Related Instrument and Instrument Lines, Revision 7 QCP-832, Instrumentation Retrofit Verification (I.R.V.) Program, Revision 2.
Procedure PGCP-30, Revision 7, was implemented in February 1984, and the installation contractor realized there were shortcomings in previous i
instrument procedures regarding verification of installations, such as the pitch of the line.
Therefore, the retrofit program was instituted 1
to assure that all safety related instrumentation was installed properly.
The inspector did not identify any deficiencies in the installation or retrofit programs.
Three 1/2" nominal instrument lines were randomly selected for inspection.
The lines inspected for proper installation are designated below:
RPS Division Loop B, Reactor Coolant Flow Line, Drawing IFT-426 a.
d Sheet 2, Revision B - Unit 1 Containment.
i b.
Control Room System, Chilled Water Pressure Controller Line, Drawing OPC W0020 Sheet 2, Revision C - Unit 1 Auxiliary Building.
I Control Room System, Chilled Water Pressure Indicating Line, c.
l Drawing OPI-WOO 29, Sheet 2, Revision 0 - Unit 1 Auxiliary Building.
Attributes checked included:
separation criteria line properly pitched i
installation clearance separation color code identification material traceability drawing conformance 16
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Drawing OPI-WOO 29 conta.ined a statement " pitch pipe 1/2" per foot if possible".
This statement is not definitive with regard to avoiding an unacceptable amount of negative slope or preventing traps. The retro-fit program which provides pitch checks for all work prior to February 1984 would assure correct pitch installations but the issue date of this drawing was April 19, 1984 The inspector has requested the licensee to review and evaluate all drawings that contain the statement, " pitch' pipe 1/2" per foot if possible", which were issued after January 31, 1984, and evaluate the need to re-inspect the installations. This is considered an open item (456/84-17-07; 457/84-17-07).
The NRC inspector did not observe any problems with the pitch of the three instrument lines he examined. Subsequently, the inspector reviewed the documentation packages for these installations, which included assuring that the welder and welding procedures were qualified in accordance with the ASME Boiler and Pressure Vessel Code,Section IX; and that the weld filler metal was traceable. Piping Welding Procedure IA-88-0, Revision 8, designated for use on drawing IFT-426, Sheet 2, Revision B, required the use of ER308 weld filler metal. RPS Division loop B, reactor coolant flow, completed socket weld joints, identified as FWP1 and FW22 on drawing IFT-426, Sheet 2, Revision B, had no piping records identifying the welder or weld filler metal utilized for the pipe-elbow connections.
Failure to control j
1 welding is a violation of 10 CFR 50, Appendix B, Criterion IX.
(456/84-17-08; 457/84-17-08).
Upon notification of this finding, the piping contractor immediately docu-1 mented this nonconformance for disposition on Nonconformance Report Number i
1886. The piping contractor's quality control office personnel had not performed a review of the completed document package for drawing IFT-426 and probably would have identified this deficiency.
8.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2, 3, and 7.
9.
BCAP Meeting On August 8, 1984, R. F. Warnick met with Messrs. T. J. Maiman and M. J. Wallace of the Commonwealth Edison Company (CECO) to discuss the i
NRC coments on the BCAP transmitted to CECO by letter dated July 27, 1984 (Keppler to O' Conner). Messrs. Maiman and Wallace informed Mr. Warnick of the current status of activities at the Byron and Braidwood Stations.
Warnick explained Region III's current, temporary organizational change to give increased RIII management and resource attention to the Byron l
inspection program, preparation of hearing testimony, and near tem operating license (NTOL) activities. The temporary organization consists of three resident inspectors and a project inspector reporting to a section chief who reports to the Acting Director, Byron Project, who has no other responsibilities, and reports directly to the Regional Administrator.
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h(Q-b The majority of the meeting was spent answering Ceco questions about the NRC comments and discussing the protocol.
Warnick explained that the 15, general' comments covered areas that the NRC will also be looking at during the Construction Assessment Team (CAT) inspection or other NRC RIII inspec-tions.
Weaknesses in these areas have been identified, at other plant sites, in previous CAT inspections:
Ceco should establish measures (whether in or outside of BCAP) to assure itself that similar weaknesses do not exist at Braidwood.
The date of September 6,1984, was proposed for the first BCAP status meeting.
10.
Exit Interview The inspector met with licensee representatives (denoted under Persons Contacted) during and at the conclusion of the inspection on August 31, 1984.
The inspector summarized the scope and findings of the inspection.
The licensee acknowledged the information.
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(ibthh 9.0d JAN 181985 Docket No. 50-456 Docket No. 50-457 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 December 19-20, 1984, ar.d January 8-9, 1985, of activities at Braiowood Station, Units I and 2, authorized by NRC Construction Perr:its l
No. CPPR-132 and No. CPPR-133 and to the discus.sion of our findings with Mr. C. Schroeder and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective exairination of procedures and representative records, observations, and interviews with personnel.
ho items of noncompliance with NRC requirements were identified during the course of this inspection.
In accordance with 10 CFR 2.790(a), a ccpy of this letter and the enclosuro(s) will be placed in the NRC Public Document Roor unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information centained therein within thirty days cf the date of this letter. Such application must be consistent with the re-quirements of E.790(b)(1).
If we do not hear from you in this regard within the specified periods noted above, a ccpy of this letter and the enclosed inspection report will be placed in the Public Locument Room.
i Exhibit 9.D-3 l
6 p.3 i
Comonwealth Edison Company 2
We will gladly discuss any questions you have concerning this inspection.
Sincerely, Criginal Signed by W. S. Little [
J. J. Harrison, Chief Engineering Branch
Enclosures:
Inspection Report No. 50-456/84-40 DRS ;
No. 50-457/84-37 DRS cc w/ encl:
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 DPB/ Document Control Desk (RIDS)
Resident Inspector, RIII Braidwooo Resident Inspector, RIII Byron Phyllis Dunton, Attorney General's Office. Environmental Control Division D. W. Cassel, Jr., Esq.
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.90 M'3 U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-456/84-40(DRS);50-457/84-37(DRS)
Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPFR-133 Licensea: Corronwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Narre: Braidwood Station, Units 1 & 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted: December 19-20, 1584, and January 8-9, 1965 L
Inspector K. D. Ward D-Date 5
M1 Approved By:
D. a. Danielson, Chief Materials and Processes Section Date Inspection Summary Inspection cr. December 19-20,1984, and Jan';ary 8-9, 1985 (Reports No. 50-456/84-40(DRS); 50-457/84-37(DRS))
Areas Inspected: Special, unannounced inspection of previous inspection fincings, preservice inspection activities and allegations. The inspection involved a total of 28 inspector hours by one NRC inspector.
Results: ho items of noncompliance or deviations were identified.
- 5. f.12-3 DETAILS 1.
Persons Contacted Comonwealth Ecison Company (CECO)
- C. Schroeder, Licensing and Compliance Superintendent
- L. Kline, Licensing and Compliance Supervisor M. Wallace, Project Manager G. Groth, Lead Mechanical Engineer l
R. Gardner, PSI Coordinator, Level III F. Farr, Field Engineer Phillip Getchow Company (PGCo)
J. Hamond, Field Superintendent E. Ullrich, QC Supervisor The inspector also contacted and interviewed other licensee and contractor personnel.
- Denotes those present at exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (456/83-08-03; 457/83-08-03): Failure to a.
control welding materials. The inspector reviewed the final response dateo September 22, 1983, inter-office memo re-instructing the proper method of controlling the weld rod, a directive requiring each con-tractor to re-instruct their personnel on the proper control of the l
welo rod and other documentation related to the subject.
All suspect weld rod was discarded and craft personnel in the field were re-instructed in the proper method of controlling weld rod.
l The Project Construction Department issued a site directive to all contractors. The directive required each contractor to re-instruct i
their personnel on the proper control of weld rod.
The inspector agreed with the results and considered this item closed.
b..
(Closed)honcompliance(456/84-17-06;457/8.4-17-06):
Failure to control welding structural steel. RIII Inspection Report No.
50-456/84-17; 60-457/84-17 stated that the inspection of this item showed that action had been taken to correct the identified noncom-pliance and to prevent recurrence, consequently, no reply to the item was required.
The inspector agreed with the report and the action taken and considers this iter closed, (Closed) Noncompliance (456/84-17-08;457/84-17-08):
Failure to c.
control welding for two socket welds in instrumentation piping.
RIII Inspection Report Nos. 50-456/84-17(DRS);50-457/84-17(DRS) stated that the inspection of this iter showed that action had been l
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- h. @D-3 taken to correct the identified noncompliance and to prevent recur-rence, consequently, no reply to this item was required. The inspector agreed with the report and the action taken and considers this item closed.
d.
(Closed) Unresolved Item (456/84-08-09; 457/84-08-09): Welding-records incomplete. The inspector reviewed " Field Fabrication Process" and data sheets (FFP&D) delineating where field inspectors and office technicians sign the fom. The FFP10 sheets and weld rod issue slips that were reviewed by the inspector did not show discre-pancies between dates when inspection steps were signed and the actual inspections. A tally sheet was prepared by the licensee that explained the concerns. The inspector found this acceptable and considers this item closed.
3.
Preservice Inspection (PSI) i The inspector reviewed the certification documents relative to ultrasonic l
instruments, calibration blocks, transoucers and couplant.
The inspector also reviewed several NDE personnel certifications in accordance with SNT-TC-1A, data reports, and audits of the PSI activities by Ceco and the Hartford Steam Boiler Inspection and Insurance Company.
The inspector observed the work and had discussions with personnel during review of the ultrasonic examinations (UT) of some carbon steel reactor coolant pump bolts. These observation ~s included calibrations, performance 4
of the examinations, and the documentation. The ultrasonic examinations were perfomed in accordance with Ceco Procedure, " Ultrasonic Inspection 4
of 4.5" Diameter, 35" Long Carbon Steel Reactor Coolant Pump Bolts.."
BWVP 1900-3, Revision 1.
The UT was a shear wave innersion technique with the use of a specially designed probe which was inserted in the bolts bore hole.
The UT was perfomed with the bolts in position and within the water filled bore holes only. However, the UT may also be performed for such bolts when they are removed from the components. The complete inside diameter (ID) surface of the bore holes were scanned with a specially designed transducer which was capable of detecting outside diameter (00) surface cracks. The inspector found this examination acceptable and no items of noncompliance or deviations were identified.
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4.
Allegations (Closed)AllegationNo.RIII-84-0016: On February 2,1%4, a former pipefitter at Braidwood telephoned the Region III Office.
The alleger had been employed by Phillips-Getschow Company (PGCo) on several occasions during 1979-1981 and reported the following allegations:
a.
Allegation The alleger claimed that pipefitters and supervisors for PGCo were unqualified. The alleger's basis for the claim was that most i
l pipefitters were working under a union pemit ar.c had never served an apprenticeship like the alleger had.
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i SY.fD-3 NRC Findings There is no requirement that contractors hire only pipefitters that have served a union apprenticeship or any other standard set of requirements, but there are qualification requirements for pipefitter welders that they must meet before they perform safety-related work. At Braidwood, pipefitters were employed by the PGCo. CECO takes no credit for union craftsmen training or qualification to detemine welder qualifications.
Each welder is specifically qualified on site.
The inspector reviewed several PGCo weld travelers that were initiated for safety-related installations. The welder's symbol number, date the weld was performed, and weld procedure utilized were.noted. Each welder is assigned a unique symbol number.
When a welder perfoms a weld operation, he places his symbol number on the traveler and stamps his symbol number adjacent to the weld with a metal stamp. This symbol number is never re-issued to a different person. This information was compared to the welder's qualification records to detemine if the welder was qualified to the procedure utilized on the date the welding was performed. No deviations were identified. Also, the inspector reviewed several welder qualification records. All welder qualifications reviewed were founc acceptable.
The following actions are taken by Ceco to assure pipefitters performing safety-related work are qualified and perfoming their work in an acceptable manner.
In general Ceco witnesses 100% of the bend tests for welder qualification.
All radiograph (RT) for welder qualification and for production welds is perfomed by Pittsburg Testing Laboratory (PTL).
PTL also perfomed all the magnetic i
particle examinations (MT) of the production welds in 1979-1981.
PTL & PGCo perfoms MT at the present time.
All contractor welder qualifications are reviewed by the Ceco welding engineer.
In 1979-1981 Ceco perfonned 17 audits.
The inspector reviewed several of the audit reports.
CECO QA personnel perform approximately 9 audits in the i
area of welder qualifications each year. The inspector reviewed several of the audit reports.
PGCo QA personnel perform two audits in the area of welder qualification each year.
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PGCo QC personnel perform visual examination (VT) on all welds, and where required, a liquid penetrant examination (PT) is performed.
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69D-3 This allegation could not be substantiated and is considered closed.
b.
Aliegation The alleger spoke of a pipe improperly installed with a "come along," mishandling of pipes causing the pipe bevels to be banged, and pipes installed backwards. According to the alleger a 98 ton steam pipe serving a heat exchanger unit was installed backwards by a crew of unqualified college students working at Braidwood during their surriner vacation. The alleger could not provide any specific information (e.g., systems, locations, etc).
NRC Findings "Come alongs" are used to install pipe as a standard industrial practice.
Pipe bevels are inspected by QC inspectors prior to welding to make sure that the bevels are acceptable.
The maximum weight for a steam pipe serving a heat exchanger unit is 20 ton according to responsible site engineers.
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Steam piping serving a heat exchanger unit come in spools and they could not be installed backwards. The spools are identified, prints are used and QC inspected. The spools would only fit one way.
College students have worked at Braidwocd during their susiner vacations as pipefitter apprentices.
In ir. stalling large spool sections there could be 5 college students (pipefitter apprentices) with 15 qualified journeymen personnel. A pipefitter apprentice is a helper. He cannot work alone and perfonns no welding.
The inspector interviewed several personnel that were on site from i
1979-1981. hone of these individuals were aware of this problem or i
i expressed concern in this area.
This allegation could not be substantiated and is considered closed.
c.
Allegation The alleger stated he had heard that a named individual was working as a quality control inspector at Braidwood. The alleger had previously worked with the named individual at a non-nuclear facility i
and considered the named individual to be a poor worker.
The alleger questioned the named individual's capacity and capabilities as an inspector if he was an incapable non-nuclear pipefitter.
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fi 90 -3 NRC Findings The inspector reviewed a list of all PGCo QC personnel that have been on site (310 personnel) and could not find the named individual.
There was a similarly spelled name that started working for PGCo on
, site April 1979, and is still on site as a pipefitter welder.
The similarly spelled name has not been a QC inspector at Braidwood.
The inspector reviewed his qualifications and interviewed various personnel that knew the individual and how he performed his work.
The inspector found the similarly spelled name's qualifications to be acceptable and that the individual has done an acceptable job.
This allegation could not be substantiated and is considered closed.
5.
Exit Interview The inspector met with site representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection.
The inspector summarized the scope and findings of the inspection noted in thi: report.
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commonw==nn maison g/ c h s
! y one rirsi u.f i piar, cn.c go m no.2
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I gp. <f Acoress Repi, to P;st Offica Box 767 Chicago. llhnois 60690 e
November 28, 1984 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to Inspection Report Nos. 50-456/84-17 and 50-457/84-17 NRC Docket Nos. 50-456 and 50-457 Reference (a):
R. F. Warnick letter to Cordell Reed dated October 16, 1984.
Dear Mr. Keppler:
This letter is provided in response to the inspection conducted by Messrs. L. G. McGregor, R. D. Schulz and J. F. Schapker of your office on July 7 through August 31, 1984, of activities at our Braidwood Station. Reference (a) indicated that certain activities appeared to be in noncompliance with NRC l
requirements. The Conmonwealth Edison Company response to the Notice of l
Violation as appended tg Reference (a) is provided in the Enclosure to this i
letter. As noted in Reference (a), no response to the Notice of Violation Item 3 was required. The delay in providing this response was discussed with Mr. P. R. Pelke of your. office on Noventer 15, 1984 Should you or your staff have any questions regarding this matter please contact, this office.
hs, Very ltrul y 1
G
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Dennis L. Farrar J
Director of Nuclear Licensing Enclosure cc: NRC Resident Inspector - Braidwood Exhibit 9.D-4 HOM 2 9
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_ RESPONSE TO INSPECTION REPORT 50-456/84-17 AFO 50-457/84-17 456/84-17-01; 457/84-17-01 ITEM OF NONCO W LIANCE 1.
10 CFR 50, Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
The Commonwealth Edison Quality Assurance Manual requires in Q.P. No.
4-1 that bidders be approved and placed on the approved bidders list, that purchase orders be reviewed and accepted by the quality assurance department to assure that the necessary technical and quality requirements are included in the procurement documents, and that the procurement is being made from the plant location for which the Quality Assurance Program is approved.
Contrary to the above, on May 17, 1981 and July 9,1981, Conunonwealth Edison placed purchase order numbers 730091 and 254379, respectively, with an unapproved bidder that did not have an approved quality assurance program. The purchase orders were for the cleaning of 206,744 feet of safety-related piping, which was to be installed in ASE Section III, Class NC and PO systems and safety-related instrunentation piping systems. Furthermore, the purchase orders were not reviewed and accepted by the Commenwealth Edison Quality Assurance Department to assure that the necessary technical and quality requirements were addressed, and the purchase orders had no reference to quality assurance program requirements.
RESPONSE
l The chemical cleaning process was intended to remove rust and scale I
without affecting the pipe; as such, the process was purchased as a standard non-safety related commercial service. As a non-safety I
related item, these purchase orders did not require review by Quality Assurance nor was the vendor required to have a Quality Assurance Program.
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RESPONSE TO INSPECTION REPORT
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50-456/84-17 APO 50-457/84-17 456/84-17-01; 457/84-17-01 Provisions were made to maintain heat traceability during the chemical cleaning process by heat code stamping each piece of pipe to be cleaned. All return shipments cf chemically cleaned pipe were received on Comonwealth Edison Material Receipt Reports and were subject to receipt inspection. The process used for chemical cleaning, although not processed as a vendor procedure, was reviewed l
with Sargent & Lundy on FCR L-1450 on April 22, 1981.
CORRECTIVE ACTION TAKEN APO RESULTS ACHIEVED Safety related two inch and under pipe that was cleaned on purchase orders 730091 and 254379 have been @mted on cr-- y, wealth Edison NCR 633 Rev. 1.
This item has also been reported to the NRC as 10 i
CFR Part 50.55(e) Report 84-10. The corrective action program for this item will include an analysis of the effects on the pipe by the chemical cleaning process.
i ACTION TAKEN TO AVOID FLRTFER N0rCDfLIAPCE i
The imortance of services connected with safety-related items and components has been emphasized to both Project Construction and Quality Assurance groups at the site. To further ensure that the proper purchase requirements are instituted on future purchase oroers, Braidwood Project Procedure PCD-07 " Site Purchasing Instructions" has been issued and iglemented. PCD-07 requires that requests for material, equipment and services delineate the quality requirements and appropriate reasons for the purchase. Review of purchase requests is completed by Construction Supervisors and Quality Assurance to ensure that the necessary requirements (FSAR, Quality Assurance Manual, Safety Related, etc.) are met.
DATE OF FULL COWLIANCE Project Procedure PCD-07 was issued November 8,1984. Training on this procedure was held on November 9, 1984. Full compliance has been achieved.
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h fD-Y RESPONSE TO INSPECTICN REPORT 50-456/84-17 Ato 50-457/84-17 456/84-17-02; 457/84-17-02 ITEM OF NONCD>R.IANCE 2.
10 CFR 50, Appendix B, Criterion XV, states in part:
" Measures shall be established to control materials, parts or components which do not
~
conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations."
10 CFR 50, Appendix B, Criterion XVI, states in part:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above, 337,350 feet of safety-related pipe was received in 1977 and rejected on April 9,1919 due to rust, scale, and failure to cap the pipe ends. The pipe was not placed on hold to prevent withdrawal and installation in safety-related systems. As a result, some of the pipe was installed in the plant.
In addition, the rejected pipe was not properly dispositioned in that only 206,744 feet of pipe was chemically cleaned.
RESPONSE
Commonwealth Edison acknowledges the fact the subject pipe was not placed on hold to prevent withdrawal and installation after a concern was raised that it was observed to have excessive corrosion. Much of the pipe was chemically cleaned. Both pipe that was and waas not chemically cleaned was installed in the plant.
It should be noted that Commonwealth Edison Company had initially identified the potential reduced wall problems with one heat number of pipe and was taking corrective steps, including determination of the scope of the issue, when NRC reviewed the issue and identified the noncompliance.
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4U-V RESPONSE TO INSPECTION REPORT 50-456/84-17 Ato 50-457/84-17 456/84-17-02; 457/84-17-02 CORRECTIE ACTION TAKEN APO RESULTS ACHIEVED To document and disposition the subject pipe, Commonwealth Edison NCR 633 Rev. I was issued to address all two (2) inch and under pipe received in 1977 from Guyon Alloys on Purchase Order 207003.
This item was reported to PRC and is being tracked by 10 CFR 50.55(e)
Report EM-10. Commonwealth Edison and Sargent and Lundy are presently developing a program to disposition the installed pipe and evaluate the effects of chemical cleaning. All suspect pipe in storage has been identified and placed on hold. Corrective action will be taken and reported pursuant to 10 CFR 50.55(e) Report 84-10.
ACTION TAKEN TO PREVENT FURTER tOCOWLIAPCE Phillips Getschow Procedure QCP B4 relating to material storage and control has been revised and enhanced since 1981. The revisions include receipt inspections, visual inspection of ends, visual inspection for rust and scale, dimensional check of wall thickness, verification of placement of protective covers, requirements for Level III outdoor storage, disposition of nonconforming materials found in storage and monitoring of storage areas. The monitoring requirements of this procedure will be effective in identifying and correcting problem conditions.
DATE OF FlLL COWLIANCE l
l Phillips Getschow Procedure QCP 84 revisions have been implemented.
l This item of noncompliance is considered closed by Commonwealth l
Edison Conpany with the dispositioning of pipe in question being tracked by 10 CFR 50.55(e) Report 84-10.
A follow up report on the 10 CFR 50.55(e) corrective action program is expected to be submitted by December 15, 1984.
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SUBCONTENTION 10.F Subcontention 10.F, as admitted in this proceeding, states as follows:
- 10. Contrary to Criterion X, " Inspection" of 10 CFR Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that a program for inspection of activities affecting quality was established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.
F.
Electrical Contractor, Comstock, inspected and accepted a junction box which was later deter-mined to have deficiencies in the location of the anchors used for mounting of the junction box. Anchors were accepted even though they were 3" frc.m the required location specified by Sargent & Lundy Drawing 20E-1-3571.
In its Motion for Sumary Disposition, Applicant concedes that the incident which forms the basis for Subcontention 10F represents a viola-tion of Criterion X of 10 C.F.R. Part 50, Appendix 8.
However, Applicant i
argues that the incident is an isolated one, and thus there is no genuine issue of material fact to be heard with respect to this subcontention.
Applicant's Motion, 10.F at 3-5.
The Staff agrees.
The improper location of an anchor on Junction Box IJB217R, the f
subject of this subcontention, was identified by Mr. Wayne J. Kropp, Resident Inspector for Construction at the Braidwood facility during a i
routine inspection. Affidavit of Wayne J. Kropp in Support of NRC Staff's Response to Applicant's Motion for Sumary Disposition of Rorem QA Subcontention 10.F at 111, 5 [ hereinafter Kropp Affidavit].
As the Resident Inspector for Construction, Mr. Kropp is responsible for inspecting the construction activities at the Braidwood site to determine 1
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- 102 -
s wh ther they are being performed in compliance with applicable codes, standards and regulatory requirements.,J_d. at 12.
During his routine inspection Mr. Kropp attempted to verify that
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selected electrical equipment was installed in accordance with design Ii requirements.
Kropp Affidavit at 1 S.
As part of this inspection i
Mr. Kropp examined three junction boxes.
He looked at their location, welding, cable bend radius, separation, mounting configuration and 9
as-built dimensions. M. This inspection revealed that the Electrical Contractor, L. K) Comstock (LKC), had inspected and accepted one of the I
i junction boxes even though the bottom concrete expansion anchor was located three inches closer to the bottom of the junction box than the Sargent & Lundy drawings specified that it should be. M.
After this inspection LKC issued Nonconformance Report 4139 to track and document the identified deficiency.
In addition, all cf the inspec tion activities in the area of junction boxes and equipment of the LKC inspector who had originally inspected' the junction box were halted. LKC then evaluated the remainder of his work in this area.
Kropp Affidavit, g
at i 6.
Applicant determined that the inspector had, inspected a total of seven safety-rela,ted junction boxes since his certi$ cation as an inspector. M. These seven junction boxes were reinspected by another certified LKC inspector. This inspector did not find any deficiencies in the reinspected junction boxes. M.
Mr. Kropp verified that NCR 4139 had been issuedo Kropp Affidavit a,
at 1 7.
Mr. -Xropp also inspected two of the reinspec'ted junction boxes
'in order to judge the effectiveness of the reinspection.
He determined s
that there were no dimensional problems with these junction boxes and, s
- 103 -
therefore, concluded that the reinspection effort was acceptable. M.
Based on the Applicant's effective implementation of the corrective actions discussed above, Mr. Kropp closed this item. M. at 18.
More recently Mr. Kropp inspected five more junction boxes.
He did not find any deficiencies with respect to these junction boxes.
Kropp Affidavit at 1 9.
Based on the original reinspection of the work of the LKC inspector who had erroneously inspected the junction box which is the subject of this contention, Mr. Kropp concluded that this was an isolated incident involving one LKC inspector.
His subsequent inspections of junction boxes have reinforced this determination. M.at110.
There-fore, the Staff agrees with Applicant that the incident described in Subcontention 10.F was an isolated incident, and does not demonstrate a failure of Applicant to have a program for the inspection of activities affecting quality. None of the infomation available to the Staff indicates a failure of Applicant's inspections of junction boxes to l
identify problems.
Intervenor has not presented any infomation to the contrary during discovery.
The,refore, there are no genuine issues of i
material fact to be heard regarding this subcontention, and App,licant is
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entitled to a favorable decision on this subcontention as a matter of 1
l law. The Staff concludes, based on the above, that Applicant's Motion for Summary Disposition of Subcontention 10F should be granted.
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