ML20082D004

Interim Rept on Potential Deficiency 55-82-11 Re Incorrect Identification of Base Matl & Improper Weld Procedures on Pipe Hanger Travelers.Initially Reported on 821020.Final Rept Will Be Submitted within 90 Days

ML20082D004
Person / Time
Site:	Clinton
Issue date:	11/14/1983
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, 55-82-11, U-10106, NUDOCS 8311220286
Download: ML20082D004 (4)

Text

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16 05-L llLIN018 POWER COMPANY y_1910s ffy CLINTON POWER STATION P.O. BOX 678. CLINTON. ILLINOIS 61727 November 14, 1983 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Clen Ellyn, Illinois 60137

Subject:

Potential Deficiency 55-82-11 10 CFR50. 55 (e)

Incorrect Identification of Base Material'and Weld Procedures on Piping Hanger Travelers

Dear Mr. Keppler:

On October 20, 1982, Illinois Power Company notified Mr. F.

Jablonski, NRC Region III, (Ref: . IP memorandum Y 13999, 1605-L, dated October 20, 1982) of a potentially reportabl.: deficiency

.per 10CFR50.55(e) concerning the incorrect identification of base material and improper weld procedures on piping hanger travelers.

This notification was followed by four (4) interim reports (IP letter D. P. Hall to J. G. Keppler U-10010,1605-L, dated Novem-ber 19, 1982, IP letter D. P. Hall to J. G. Keppler U-10023, 1605-L, dated January 17, 1983, IP letter D. P. Hall to J.. G.

Keppler U-10051, 1605-L, dated April 27, 1983.and IP letter D. P.

Hall .to J. G. Keppler U-10078,1605-L, dated August 5,1983) .

Our investigation into this. matter continues, and this letter

~

represents an interim report per 10CFR50.55 (e)(3) .

STATEMENT OF POTENTIALLY REPORTABLE DEFICIENCY During final review of piping hanger installation travelers, it was discovered that incorrect base materials and improper weld procedures were identified on the travelers. This condition could potentially allow for incorrect welding and improper documentation of piping hanger installation.

. INVESTIGATION RESULTS/ BACKGROUND During a Baldwin Associates (IP Contractor) Technical Services Department' final review of piping hanger installation travelers, it was realized that the wrong embed plate base material and improper-procedures for welds between embed plates

.and piping hangers were identified on the documents. This error resulted in the issuance cf a Nonconformance Re rt (NCR-7725).

8311220286 831114 PDR ADOCK 05000461 h b

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Mr. Jcm:s G. Keppler Page 2 November 14, 1983

-As a result of NCR-7725, the Baldwin Associates (BA) Quality Assurance Department issued Corrective Action Requests CAR-105 and CAR-121 which addressed improper initiation by BA Engineering and improper initial review by BA Technical Services on an unde-termined number of piping travelers.

Upon investigation by Illinois Power into the problems identified by NCR-7725 and CARS-105 and 121, the following information was obtained:

1. Sargent & Lundy (CPS Architect-Engineer) design drawing S21-1001 allows the use of both ASTM A-36 and ASTM A-572 Grade 50 as embed plate material.

2. The BA Piping Department did not realize that an alternate type of material was allowed for embed plates. It was erroneously assumed that all embed plate material was ASTM A-36, subsequently, pipe hanger travelers were prepared identifying the embed base material as ASTM A-36. In reality, both ASTM A-36 and ASTM A-572 Grade 50 material were used.

3. The initial pipe hanger traveler review by BA Technical Services assigns a weld procedure to the traveler, based on the base materials identified on the document.

Therefore, if erroneous base material information is identified on travelers, the possibility of assigning an incorrect welding procedure exists.

4. The weld procedure for welding ASME SA-36 (pipe hanger material) to ASTM A-36 (embed material) is designated as N-1-1-A-lM. The weld procedure for welding ASME SA-36 to ASTM A-572 Grade 50 (embed material) is designated as N-ASTM-A-SP. As ASTM A-36 material was identified on the travelers, weld procedure N-1-1-A-lM was subsequently indicated on the travelers by BA Technical Services. It should be noted that since these two welding procedures utilize the same filler material and the same essential variables, the welds are acceptable even though an incorrect weld procedure was specified.

5. The welders who performed the welds in question were qualified to perform both procedures.

6. A review of traveler programs in the electrical, instrumentation, mechanical equipment, and HVAC disci-plines for weldments to embeds disclosed no welding procedure errors.

7. Investigation revealed that an ASME Code Case, N-71-10, states that an ASME weld procedure qualification (such as N-1-1-A-lM) with a base metal in one P-number and Group number (for ASTM A-36, P=1) qualifies for all other base metals in the same S-number and Group number (for ASTM A-572 Grade 50, S=1).

I:r. Jam s G. Kopplcr Page 3 November 14, 1983 An extensive review of pipe hanger travelers was completed to determine if similar problems exist in weldments to other base materials, such e.s structural steel. Approximately 9200 travel-ers and addendums representing nearly 7500 hangers were evaluated. Of these, approximately 3600 travelers will require revision to correct or clarify base materials and/or weld procedures. Although a large number of errors were identified, it was generally found that the assigned weld procedures were adequate for the actual base materials used. However, several cases were identified where the weld procedures used were inappropriate for the combination of base materials used.

Nonconformance Reports (NCRs) or Deviation Reports (DRs) have been written to document these problems and obtain disposition of the welds.

Another issue that has been identified through investigation of this potential deficiency concerns the materials used for fabrication of rear brackets for pipe hangers supplied by Basic Engineers for use at Clinton Power Station. The vendor's detail drawings indicate ASME SA-36 material for these brackets, how-ever, more recent Load Capacity Data Sheets indicate that alter-nate materials ASME SA-181, Grade II, ASME SA-515 Grade 70 and ASME SA-516 Grade 70 may have been used. The field weld proce-dures used would be correct even if these alternate materials had been used since the materials are of all P-1 group number.

CORRECTIVE ACTION Although investigation of this potential deficiency contin-ues, several actions are being taken to correct the problem and to prevent recurrence:

1. BA Piping Department has conducted department training relevant to traveler initiation and the importance of supplying correct material identification information on work related documents. This training was completed on December 22, 1982,

2. For those piping hanger travelers in which welds to embeds have not been started, BA Piping Department is indicating that embed base materials are either ASTM A-36 or ASTM A-572 Grade 50, and that the applicable weld procedure is either N-1-1-A-1M or N-ASTM-A-SP, to show that alternate materials and weld procedures exist. For those travelers where welding to embeds has been started or is complete, a copy of NCR-7725 is being included to correct the documents.

3. In those cases (other than welds to embeds) where an incorrect base material and weld procedure were identified on a traveler and the weld is in-process or complete, an NCR or DR has been written to obtain disposition of the weld and a copy will.be included in the traveler to correct the document. In those cases where documentation errors were identified through the

e Mr. Jam:s G. Keppler Page 4 November 14, 1983 review process and the welds have not been started, the travelers will be revised to identify the correct or alternate base materials and correct weld procedures that apply.

4. On December 12, 1982, Sargent & Lundy (CPS Architect Engineer) accepted the recommendation on NCR-7725 to accept the welds as-is. The Piping Specification, K-2882, has subsequently been amended to allow the use of Code Case N-71-10.

5. Upon completion of the traveler review and revision process, Baldwin Associates and Illinois Power Quality Assurance shall verify the adequacy of corrective action taken to correct documentation errors and to prevent recurrence. Corrective action is expected to be complete by December 1, 1983. Corrective action verification is expected to be complete within sixty (60) days of completion of corrective action.

SAFETY IMPLICATIONS / SIGNIFICANCE Although documentation er rs have been identified, it has been generally found that the .asociated weldments are acceptable. Cases identified to date where inappropriate weld procedures were used have been evaluated, and it was determined that no adverse impact on the safety of operations of CPS would have resulted had the error gone uncorrected. Approximately ninety (90) days will be necessary to comp'.ete the investigation, evaluate corrective action adequacy, and to file a final report on the subject.

We trust that this interim report provides you sufficient background information to perform a general assessment of this potential reportable deficiency and adequately describes our overall approach to resolve this problem.

Sincerely yours ,

D. P. Hall Vice President RDW/j f cc: Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety NRC Resident Office INPO Records Center