ML20215M208

Submits Natl Board Audit Team Final Rept of Phillips Getschow N-5 Data Rept Program for Unit 1,based on Audit Conducted During Nov & Dec 1986.Concerns Expressed Verbally Due to Difficulty in Comprehending Complexity of Program

ML20215M208
Person / Time
Site:	Braidwood
Issue date:	06/19/1987
From:	Lindbeck C, Siever R, Sullivan M NATIONAL BOARD OF BOILER & PRESSURE VESSEL INSPECTORS
To:	Bradley Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8706260312
Download: ML20215M208 (7)

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' Gli c National 1Bourb of Boiler aub $1rcanure llennel Ennpertorn D. A MCDONALD, Executive Director BOARD OF TRUSTEES 1055 CRUPPER AVENUE J.G.CVAR COLUMBUS. OH,0 43229 U.S A. State of Delaware M. L $NOW. JR. Chairman Nash n e, Tennessee Faone 614 868 8320 A. W DIAMOND S. M MATTHEWS. ist Wce Chairman d Labra or R D. CAT E 2n Chairman ta e hode islamJ A NN!VER S ABY .

3 "j u a June 19, 1987 W" Tirit1 %e2ul ap GV daEst,I.If Mr. Burt Davis, Regional Administrator U.S. Nuclear Regulatory Commission N[# Ys' QTji[

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Region III 799 Roosevelt Road DW ggg h- i Glen Ellyn, IL 60137 i

SUBJECT:

National Board Audit Team's Final Report of the Phillips Getschow'N-5 Data Report Program for Unit 1 Braidwood Nuclear, Power Station, Braidwood, Illinois FINAL REPORT

Dear Mr. Davis:

As requested, the National Board Audit Team undertook an audit of the j Phillips Getschow (PG Co.) N-5 Data. Report System. A sample of twelve completed N-5 packages selected.att random,for ASME Construction, Class 1, 2 and 3, were audited over a fifteen. (15) day period during November and December, 1986.

l This audit resulted in'the identification of eleven (11) findings. These findings were verbally transmitted to the NRC on February 18, 1987.

On April 9, 1987, the National D'oard' met lthe NRC in Glen Ellyn, Illinois to discuss the above mentioned findings and the proposed corrective action.

The Braidwood site was visited on April 10, 1987 by Messrs. C. S.

Lindbeck and R. Siever. The purpose of this visit was to verify the corrective action taken by CECO and PG Co. to close out the identified findings.

As a result of the April 10th visit, the National Board was able to close  ;

out all identified findings except findings 1, 3 and 11.

The National Board Audit Team agreed to research the ASME Code requirements regarding the inclusion of component support identification on Piping N-5 Data Reports. The results of this research resulted in the closure of finding 1.

The NRC agreed to follow the proposed corrective action to close findings 3 and 11. The NRC notified the National Board on June 15, 1987 that findings 3 and 11 had the agreed upon corrective action taken and these findings could be cleared.

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.This report identifies the findings and corrective actions taken to close these findings.

NA-8400 1. FINDING Code Case N-272 It is our opinion that the present documentation of the hanger installations does not meet the intent of NA-8400, Code Case N-272, or PG Co. QAP/BR-NS. If separate N-5's are used for piping systems and for

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component supports, the system N-5 should reference the component support N-5 unique identifying number and vice versa, instead of the term "Not Applicable" entered on the N-5 under Item 5 on Page 1.

RESPONSE

After a rereview and reevaluation, it was determined that PG Co. N-5 reports met ASME Code requirements, i

CORRECTIVE ACTION None Required.

This finding is closed.

NA-8416 2. FINDING ,

1 One piping subassembly (RE-3-1) manufactured by Southwest Fabricating & Welding Co.', Inc. (SWF) and two piping subassemblies (1RE57A-3/4" & 1RE25A-3") 3 installed by PG Co. are referenced on supplemental j records and are included in the written hydro boundaries; however, the subassemblies in question are not listed in the N-5 for 1RE-1.

RESPONSE

N-5 Data Report for 1RE-1 has been amended to. include I RE-3-1, 1RE57A-3/4" and 1RE25A-3". I CORRECTIVE ACTION An audit was performed of ten (10) additional systems and no deficiencies were identified and we have determined this was an isolated instance.

This finding is closed.

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Code Case N-272 3. FINDING Code Case N-272, which is used to justify not attaching all N-2, NPV-1 and NPP-1 data reports to the applicable Form N-5, is not referenced on the N-5 data reports.

RESPONSC CECO has revised the Design Specification L-2739 to allow the use of Para. NCA-8430 Summer 81 Addenda which incorporates the provisions of Code Case N-272.

CORRECTIVE ACTION An attachment sheet shall be attached to the N-5 data reports listing all Code Cases that may have been used.

This was verified by the NRC.

This finding is closed.

NA-4451 4. FINDING NA-4452 NA-4831/32 A review of the N-5 Data Pack for 1RY-1 disclosed that the package is missing construction documentation to support three Class 1 welds, one 45 ell, and one-piece of SA-376 Gr TP304 6" nom. pipe. The field welds in question are PG-3E, PG-3F and PG-3G, located within line 1RY01B-6". The reference drawing for this line is 1C-RV-5 Rev. B. Each one of the three welds in question is missing the following installation support documentation:

a) Field Fabrication Process & Data Sheet b) Temporary Attachment Control Sheet c) Liquid Penetrant Examination Report d) Weld Radiograph Inspection Report The National Board Audit Team is of the opinion that the Data Report for 1RY-1 is'not valid until these three construction packages are_ located, reviewed, and accepted per PG Co.'s QA program.

RESPONSE

Supplementary documentation was reviewed which allowed recreation of the' installation dccumentation for welds 3D, 3E and 3F. Multiple documents exist that allow for recreation of documents that are damaged cr lost.

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CORRECTIVE ACTION None required.

This finding is closed.

NA-4440 5. FINDING A review of the Field Fabrication Process and Data Sheets for line 1RYO1B-6", Drawing 1C-RY-5, disclosed the lining out of material specifications that have been entered on the FFP & D. The FFP & D for Weld Map No. IC-RY-5-2, joint number RY-5-FW2A, stated that SA-182 F304 material was to be joined to SA-182 F304 material. One of the SA-182 F304 entries was lined out and a handwritten entry of SA-376 TP304-6" pipe.was entered. This change was made on the FFP & D without date or initials of the person making'tne enange.

NA-4452 6. FINDING The above FFP & D recorded the changing of Welding Procedure Specification revision levels four years af ter the welding had been performed. The FFP & D had an original WPS entry of 1A-MA-88 Rev. 10. .This entry was made on 8/22/79. The work'that was carried out to this WPS was performed on 7/1/81 through 7/10/81, At some later date, WPS 1A-MA-88 Rev. 10 was lined out and a revision level of 8 was assigned to the WPS without an entry date for the change. At some even later date, the revision level of the WPS revision 8 was lined out and a revision level of 9 was assigned without an entry for the change.

Based on the information given on the FFP & D, the.

National Board Audit Team feels that document revision control in effect from 8/79 through 7/51 may not have been in compliance with the ASME Code.

NA-4452 7. FINDING NA-4530 The same FFP & D also recorded the assignment of the Visual Examination Procedure QAP-2 Rev. 1A to examine the weld. A review of the installation document.

package revealed that the visual. examination had been performed to QAP-2 Rev.' 1A on 7/8/81. However, at some later date, QAP-2 Rev. IA was lined out and a visual procedure of VE-01 Rev. 2 was assigned without an entry date for the change. On 11/18/85 the visual procedure VE-01 Rev. 2 was lined out and a revision level 0 was-assigned.

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1 RESPONSE (Items 5-7) j A review of additional documentation and field walk-down of the piping systems was performed to verify the changes ~made to the documentation reflected the field  ;

conditions and found acceptable. )

i The document control program in effect after 1981 j requires change control that will not allow changes j without the date and initials of the person making"the change.

CORRECTIVE ACTION  !

None required.

These findings are closed. l NA-4442 8. FINDING NA-8416 N-5 #1CS-1 referenced PG Co. Drawing IC-CS-5 Rev. F, at location C-7, shows 3/4" globe valve #1CS 074A (listed on M-5, Page 3, Item 5, Line 7) and piping 1CS55AA-3/4" between field welds 7E-1 and 7D-1, and 3/4" S.O.L. fitting to spool CS-5-7. 1CS55AA-3/4" is not listed under Piping Subassemblies on N-5, Pages 4 to 7, nor as additional material on Page 8. ,

NA-4442 9. FINDING l NA-8416 l Similarly, PG Co. Drawing IC-CS-6 Rev. F, at position A-7, shows 1CS55AB-3/4" and 3/4" S.O.L. fitting between 3/4" globe valve 1CS074B and spool CS-6-7, with no listing of piping subassembly or additional material.

a NA-4442 10. FINDING NA-8416 PG Co. Drawing 10-CS-6 Rev. F, Note 5, states "For-penetration information see Drawing 1PC-16A", which is not attached or listed on N-5, Page 2 drawings.

RESPONSE (Items 8-10)

After a review and reevaluation of PG Co.'u procedure it has been determined that this is an acceptable practice.

CORRECTIVE ACTION None required.

These findings are closed.

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NA-4442 11. FINDING l NA-4450 ICS-1 N-5 record package for CS-6 portion of this system'did not include an FC0 or other documents to document the modifications to this piping subassembly.

In order to assure material identification for modi _fied SWP subassemblies, the FCO's that directed and controlled the modificatica of the subassembly must be a part of the N-5 record package. Further, the use, existence, and maintenance of FCO's are an integral part of the PG Co. Material, Traceability and Verification Program.

RESPONSE

PG Co. has located the FCO's that verify the modifica-tions and will return them to the N-5 package.

CORRECTIVE ACTION CECO QA will require PG Co. to return all FCO's to the N-5 packages.

This item was verified by the NRC.

This finding is closed.

CONCLUSION It must be stated that in many instances, the problems identified occurred prior to 1981. Since 1981, the PG Co. QA program has been effective with rare exception.

In addition to the identified findings, the National Board expressed verbally to the NRC many concerns. These concerns were-primarily addressed because of the difficulty encountered trying to comprehend the complexity of the PG Co. program.

It is our opinion that the program is poorly written and very confusing and difficult for an outside auditor to absorb in the limited time allowed for performing an audit. However, there is no indication that the program, as written, does not meet ASME Code requirements.

l The National Board Audit Team would like to express their gratitude to both CECO and PG Co. for their cooperation in closing the identified findings. We would also like to compliment both organizations for the professionalism exhibited.

Finally, we would also like to thank the NRC for their able assistance in verifying closure of specific items.

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With the issuance of this report, the National Board considers this audit as complete and closed.

Again, we wish to thank you for the opportunity to perform this audit.

If we can be of further assistance again, please contact the Director of Inspections or Mr. D. J. Mcdonald, Executive Director.

Re. .ct 1 sub11 ed,

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Michael F. Sullivan Director of Inspections C. S. Lindbeck b' ~C. -

Robert Siever MFS:jl cc: D. J. Mcdonald C. W. Allison i

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