IR 05000454/1986017

Safety Insp Repts 50-454/86-17 & 50-455/86-15 on 860424-0502.No Violations or Deviations Noted.Major Areas Inspected:Alleged Hiring of Unqualified Inspector & Ultrasonic Indications in Steam Generators

ML20155J375
Person / Time
Site:	Byron
Issue date:	05/15/1986
From:	Danielson D, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155J365	List: IR 05000454/1986017 ML20155J359
References
50-454-86-17, 50-455-86-15, NUDOCS 8605230235
Download: ML20155J375 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/86017(DRS); 50-455/86015(DRS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: April 24, 29-30 and May 1-2, 1986 Inspector:

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K. D. Ward ypygg Date lYYM' T (W D. H. Danielson, Chief

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[/g Approved By:

Materials and Processes Date Section Inspection Summary Inspection on April 24, 29-30 and May 1-2, 1986 (Reports No. 50-454/86017(DRS);

No. 50-455/86015(DRS))

Areas Inspected: Announced, special safety inspection of an allegation which concerned the alleged hiring of unqualified inspectors, resolution of a 50.55(e) item and previous inspection findings, and final disposition of ultrasonic indications observed in the steam generators and pressurize Results: No violations or deviations were identifie _ . . _ _ _ . -a

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• E. Martin, QA Superintendent

• G. Sorenson, Project Construction Manager

• R. Klingler,-Project QC Supervi3or

• J. Woldridge, QA Supervisor

• R. Moravec, Project Mechanical Supervisor

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• E. Briette, QA Engineer

• Wolber, QA Inspector J. Porter, Construction Supervisor Reliable Sheet Metal Works (RSM)

R. Irish, Corporate QA Manager Hunter Corporation (HC)

M. Farris, QA Auditor EBASCO Services, Incorporated, (EBASCO)

T. Pederson, level III, NDE Nuclear Regulatory Commission (NRC)

J. Hinds, Jr. , Senior Resident Inspector The inspector also contacted and interviewed other licensee and contractor employee * Denotes those individuals attending the final exit interview on May 2, 198 . Licensee Action on Violations (Closed) Violation (454/85-11-02): Unqualified welder and inadequate preheat procedures. The NRC inspector reviewed the final report dated September 5, 1985, associated Nonconformance Reports (NR's),

procedures and other related documents. Reliable Sheet Metal (RSM)

welding procedures dated prior to August 1982, did not address preheat as required by AWS D1.1 and the current welding procedures did not address the AWS D1.1 required 150 F preheat for members with thickness greater than 1 1/2" up to 2 1/2". RSM has welded to structural steel members in this thickness rang In accordance with AWS D1.1, exclusion of an essential variable such as preheat

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a requires qualification of the welding procedures. Since the welding proceoures were not qualified, RSM initiated Nonconformance Report No. 93 to resolve the deffetency by qualifying the procedures. This

, NR was closed by RSM on June 24, 1985, following successful qualifica-

, tion of the procedures. By test, Reliable Sheet Metal qualified welds made to structural steel without the required preheat in accordance with AWS D1.1. This qualification demonstrated that an acceptable weld joint was made using past procedures without prehea Reliable Sheet Metal procedures used for welding to structural steel have been revised to incorporate the requirements of preheat in

,, accordance with AWS D1.1. All production supervisory and welding personnel have been trained to these current preheat requirement RSM. issued Nonconformance Report No. 96 on April 18, 1985, this NR

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l L was subsequently closed May 13, 1985, to document and resolve the unqualified welder issues. A documentation search by RSM showed that al.1 GMAW welds performed by this welder on plate were fillet welds. The welder was given the qualification test for this type of welding and successfully passed the test. Based on the results of the qualification test, the items welded by this welder were

, dispositioned "use as is." Additionally,' all welds made during the lapse in qualification were visually inspected by qualified !

visual weld inspectors. Currently, Reliable Sheet Metal procedures require that a review of all active welders is done every six months to ensure proper activity levels in each process in accordance with AWS D1.1. The NRC inspector considers the actions taken by the licensee to be acceptabl (Closed) Violation (454/85011-03): Inadequate welding of Reactor Containment Fan Cooler (RCFC). The NRC inspector reviewed the final report dated September 5,1985, associated NR's, weld maps, and other related documentation. After Hunter Corporation (Mechanical Contractor) improperly closed the original Ncnconformance Report (NR 185), they initiated a new nonconforn:ance on March 6,1985 l (NR 1042). During review of NR 1042 by CECO, it was determined that the channel members and drain pans are not used to support the RCFC

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coils and are not required to function during a LOCA. As a result they have been reclassified as nonsafety-related. The remaining

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stpuctufal safety-related welds were mapoed by Hunter QC inspectors

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in March, 1985, and found by Sargent rrd Lundy engineers to be adequate to perform their intended ranc+ f on. Final disposition on the RCFC installation was "use ts i " & a result of the safety reclassification change for the c actv 1 embers and drain pans and the previous safety-related welu mappa.J calculation A review of all Hunter nonconformances was made by CECO to determine if other similar premature closure of deficiencies had occurred. This review

identified no further deficiencie Additionally, the Hunter QA audit and surveillance program have been enhanced to assure that all deficiencies identified by either an

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audit or surveillance would be corrected prior to closeout by the respective report. The NRC inspector considers the actions taken by the licensee to be acceptabl . Licensee Action on Unresolved and Open Items (Closed) Unresolved Item (455/85-31-01): Drawing changes are required to reflect the correct weld designation. Weld W2 on the manufacturers records sheet for spool piece Q6050 RH-60RR (R4-14-1) was reassigned and replaced with Weld W7. On November 7, 1985, the licensee issued letters to Hunter Corporation and EBASCO Services Incorporated which directed changes to be made to the site drawings to reflect actual i

conditions found on the spool piece. The NRC inspector reviewed the letters and changes on the drawings and considers the licensee's j action to be acceptable.

l j (Closed) Unresolved Item (455/85-31-03): There was no approved i

procedure that referenced the use of the Delta Technique (used to determine ultrasonic beam angle) that was being used. The weldments identified were No. 2RH01AB-12 "J3 and 2RH01AB-12" J3 The proper contour and the thickness of the area for the actual welds are documente Also, EBASCO NDE Procedure No. ISI-UT-578-1, Revision 1, Addenda No. 2 has been revised to specify the Delta Technique. The NRC inspector reviewed the procedure and related documentation and considers the licensee's actions to be acceptabl (Closed) Open Item (454/85011-01): Material with incomplete Certified Material Test Reports (CMTR). CECO Audit No. 6-85-201 found that certification for the galvanized coating of structural steel to ASTM A123 was not available onsit Further, the audit found that certification for the coating of sheet steel to ASTM A525, G90 was not available for approximately 30% of the sheet steel. During the audit, Reliable Sheet Metal Works, Incorporated (RSM) stated that some of the missing documentation may be on file in the RSM corporate office. Nonconformance Report No. 97 was  ;

initiated by RSM to resolve this deficiency. All material certifica-tions were reviewed and where certifications were missing, vendors were required to send either specific certifications for specific l affected heat numbers or send generic certifications for all material based upon submitted purchase order numbers or invoice l numbers. The NRC inspector reviewed a related audit, NR No. 97 and material certifications and considers the licensee's actions to be acceptabl (Closed) Open Item (454/85001-04): The licensee committed to review the following items which were included in a welders diary:

• " Filler Pieces" were used to plug gaps in the HVAC Duct FCR's and DR's were issued, they were investigated by CECO )

and found to be welded properly and were accepted as-i .. .

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• Questionable documentation on ten hangers. The ten hangers were found to be nonsafety-related and a welder number was not required to be documented. A CECO investigation showed that the correct welder number was documented on the fabrication tickets and that he was a qualified welde * Questionable documentation of welder training record Three welders signed the training record after the training was completed, and should have signed prior to the training. A CECO investigation showed that there was no falsification of training record The licensee also reviewed the welders diary to ensure that all questionable items had been addresse The NRC inspector also reviewed the welders diary and all the questionable items were addressed. The NRC inspector also reviewed FCR's, DR's fabrication tickets, QA surveillance and related documentation and considers licensee's actions to be acceptabl e. (Closed) Unresolved Item (454/86009-01; 455/86008-01): Sargent and Lundy (S&L) used inappropriate analytical techniques to reconcile as-built piping / support configurations. As requested during the previous exit meeting, 20 additional subsystems were randomly selected and reviewed by S&L. The review was for the acceptability of either the engineering judgement and/or the method utilized in dispositioning piping / support out-of-tolerance conditions. The scope and results of the review are documented in S&L's interoffice memoranda from A. A. Dermenjian to S. E. Azzazy dated March 24, 1986 and from S. E. Azzazy to A. A. Dermenjian dated April 11, 1986, respectivel The NRC inspector reviewed the above documentation and chose the three following subsystems for a confirmatory review:

2AF-14 1FW-10 200-02 No concerns were found during the revie As further confirmation, an additional five new reconciliation calculations were reviewed by the NRC inspecto (1) EMD-049890 " Addendum to Stress Report," 1WO-26, Revision 03F (2) EMD-050538 " Addendum to Stress Report," 1AF-08, Revision 07F (3) EMD-049482 " Addendum to Stress Report," 1MS-05 dated November 11, 198 (4) EMD-049489 " Addendum to Stress Report," 1CS-04, Revision 00F m

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(5) EMD-049272 " Addendum to Stress Report" 1RH-08, Revision 03F In all cases, for the above subsystems, appropriate analytical techniques were used to reconcile the as-built configuratio Based on the above review this item is considered close . Licensee Action on a 10 CFR 50.55(e) Item (Closed) 50.55(e) Item (455/83003-EE): NSSS support steel installatio During a Hunter and CECO review of the as-built location of the Unit 2 Reactor Coolant Pump and Steam Generator Support Columns, it was determined that the columns were not installed within the tolerances specified on the Sargent and Lundy Design Drawing S-110 The tolerances specified were referenced to dimensions from the building structure, while the actual installation was performed with respect to the installed equipment location. These deficiencies were documented on CECO NCR Nos. F-750 and F-80 A review was performed by Sargent and Lundy to evaluate the impact of CECO NCR Nos. F-750 and F-803 on plant design and safety. This review provided revision tolerances for the installation of NSSS support steel, the steam generator, Reactor Coolant pump, and pressurizer column and lateral support installations were verified using the new tolerance Sargent and Lundy was requested to perform a detailed analysis of the

"as-built" situation regarding the columns at Braidwood which are the same as Byron. Two columns were found to have the potential to reach their rotational limi After the NRC inspector reviewed the "as-built" configuration and calculations, he posed three questions for the licensee to address. They were:

• Is the change in stiffness due to modification of the base attachment design significant?

• If the column reaches the rotational limit and is forced to end will this be design significant?

• The cross over pipe is not extremely close to the support colum Will there be significant thermal effects on either the column or the piping?

In addition, Westinghouse Electric Corporation was asked to review the

"as-built" configuration in response to the three questions and to review the "as-built" configuration in relation to any significant design concerns which may develop based on their experienc The three questions were adequately answered in a letter from Mr. J. L. Tain of Westinghouse Electric Corporation to Mr. D. L. Leone of Sargent and Lundy on July 9, 1985. In addition, a letter from J. L. Tain to D. L. Leone on September 12, 1985, stated the following: " Westinghouse has reviewed the as-built condition of the reactor coolant pump columns as described in your letters and finds it acceptable."

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The NRC inspector reviewed NCR's, field changes, drawings and final inspection reports and the other documents noted above and considers the actions taken by the licensee to be acceptabl . Final Disposition of Ultrasonic Indications Identified in Steam Generators and Pressurizer After completion of.the official preservice inspection of the Byron Unit 2 steam generators and pressurizer,12 indications in component welds remained unacceptable to ASME Section XI requirement Supplemental examinations, weld sampling and metallurgical analyses, performed prior to the official inspection, identified the indication sources as very small, innocuous slag inclusions. CECO stated that such inclusions are expected to have insignificant effect on vessel weld integrit Due to the location of the indications, their removal and subsequent weld repair involves potential significant risk to vessel integrity. As a result, CECO does not intend to remove the 12 indications per ASME Section XI preservice inspection requirement Fracture mechanics analyses of the Byron Unit 2 steam generators and pressurizer has been performed. The 12 unacceptable indications have been plotted on flaw evaluation handbook charts developed from the fracture mechanics analyses. The handbook charts identify the critical flaw sizes for each weld. The NRC inspector reviewed the charts and found them to be acceptabl The NRC inspector performed an inspection in August 1985 (See NRC-Inspection Report No. 50-455/85040) of the steam generator shel This inspection included observing ultrasonic examinations (UT)

and visually examining problem areas inside the steam generato A final report will be sent when resolution of this issue is reached with NRC/NRR. This is an Open Item 455/86015-0 . Allegation (Closed) No. RIII-86-A-0007: Alleged hiring of unqualified inspector Region III received from the Federal Bureau of Investigation (FBI), which was contacted by a former employee of Pittsburgh Testing Laboratory (PTL)

who had made the following allegation:

During the period of March to June 1984 the alleger was employed by PTL onsite. In his judgement many of the inspectors did not appear to be competent. He reviewed certification documentation and determined these inspectors had been certified as qualified by PTL. He further determined some of the apparently unqualified personnel were relatives of CECO employees. The alleger stated that he made an effort to transfer or terminate some of the unqualified inspector I 7 )

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a NRC Review The NRC inspector contacted the alleger by telephone to obtain clarifica-tion of the allegations that he had originally stated verbally to the FBI. The alleger stated he had furnished the FBI with all of the names of the unqualified personnel, including relatives of CECO employees and that the NRC inspector should call the FBI for further informatio The NRC inspector contacted the cognizant individual at the FBI and was informed the alleger did not provide any documentation or names of unqualified personnel or names of personnel that the alleger made an effort to transfer or terminate. The FBI believed that the alleger was only concerned with Nondestructive Examination (NDE) inspector The NRC inspector interviewed the CECO QA Superintendent and the CECO Contracts Administrator who were on site from March to June 1984. The individuals stated that they knew of the following people that were relatives of CECO and PTL personnel:

CECO, Clerk, " Wife," - PTL, Inspector, " Husband"

CECO, QA Inspector, " Husband," - PTL, Clerk, " Wife"

CECO, Clerk, " Wife," - PTL, Film Processor, " Husband"

CECO, Station Manager, " Brother," - PTL, Documentation Technician,

" Brother"

CECO, Assistant QC Supervisor, " Brother," - PTL Clerk, " Sister" While quality control inspectors are required to be certified / qualified in accordance with ANSI N45.2.6 or SNT-TC-1A, other employees such as clerks, film processors and documentation technicians, are not required to be certified under or qualified to any nationally recognized standar The inspector reviewed the certifications for the quality control / quality assurance inspectors identified above and found each to be qualified under ANSI N45.2.6 and/or SNT-TC-1 The NRC inspector reviewed the 1984 organization charts of PTL and requested a list of PTL personnel that were terminated from March to June 198 Several individuals were transferred to various sites or quit for other employment. Also one individual was layed-off due to a reduction in force and two individuals were terminated because of absenteeis The NRC inspector reviewed a memo from the CECO QA Superintendent to the PTL Site Manager of PTL dated February 3,1984. The memo stated that an audit trend analysis of 10 CFR 50, Appendix B criteria had been conducted in the area of personnel certifications and that personnel had made errors in following the procedures while conducting various testing activitie u

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The PTL Site Manager wrote a letter to CECO's QA Superintendent dated April 24, 1984, stating that the following corrective action measures are being taken:

All personnel were recertified under the new program in compliance with CECO letter, dated March 17, 1984, and PTL Instruction Sheet IS-BY-49-PQ, Revision *

Personnel qualification packages are constantly reviewed and update *

Supervisors are exercising more care to make sure that only properly and currently qualified and certified personnel are conducting test activities and documentational revie *

Organizational changes are made that will allow supervisory personnel to conduct more surveillances on personnel conducting test / inspection activitie The PTL Site Manager also committed to the following action to prevent recurrence:

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Personnel qualification packages will be reviewed and updated on constant basis. Supervisors will survey test / inspection activities to verify that the personnel are in fact performing and documenting test activities in compliance with applicable procedure Supervisors will also make sure that only properly qualified, trained and certified personnel will conduct test activities or documentaticnal revie The NRC inspector reviewed a Ceco QA surveillance report and a Ceco routine QA general office audit of PTL certifications conducted in June 1984. The audit found that there were inconsistencies in the certification packages which made the packages confusing even when reviewed by qualified personnel. To resolve this concern PTL proposed a program to clarify the certification packages and make the packages consistent. The certification packages are now in a " story book" for They are all easy to follow and consist of the following:

Certifications

Resumes

Verifications

Client Approval

Eye Exam

Training Record

Examination Record

Certification Record

Exams

Miscellaneous Past Records

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The NRC inspector reviewed certifications of 53 PTL inspectors and technicians that were onsite from January 1, 1984, to September 1, 1984, and found them all to be acceptable. These inspectors and technicians were qualified / certified in the following method / areas:

Radiography

Ultrasonics

Magnetic Particles

Li<;uid Penetrant

Electrical

Structural

Mechanical

Concrete Field

Receiving

Cadweld

Calibration

Soils La *

Document Review / Evaluation

Verification

Soils Field

Batch Plant

Physical La The following organizations also reviewed the above PTL personnel certifications:

CECO, QA Inspector, Lead Auditor, Level II QA Inspector

CECO, QA Engineer Level II QA Inspector

CECO, General Office Auditors

PTL, Level III

PTL, Audits by PTL site personnel

PTL, Corporate Auditors

National Board audits

Hunter Corporation performs QA audits on PTL

ANI 100% on NDE personnel

NRC The NRC inspector also reviewed PTL's qualification / certification procedures and found them to be acceptabl Additionally, a special Region III team inspection conducted in March and April 1982 revealed personnel qualification / certification deficiencies which resulted in an item of noncompliance. Specifically, Byron site contractors had deviated from commitments to Regulatory Guide 1.58 stated in the FSAR, the Commonwealth Edison Company Quality Assurance Program and ANSI N45.2.6-1978 NRC Inspection Reports No. 50-454/82-05; No. 50-455/82-04).

In response to the identified problems CECO took action to upgrade the contractors QA/QC programs and to assure that inspectors working at Byron after September,1982 were properly certified. CECO submitted the final

" Report on the Byron QC Inspector Reinspection Program," dated February, 1984 to Region III on February 24, 198 L

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Based upon Region III inspections and a review of " Report on the Byron QC Inspector Reinspection Program," dated February,1984 it was concluded that the licensee had taken adequate corrective action to resolve the noncompliance and the matter was closed (See NRC Inspection Reports No. 50-454/84-13; No. 50-455/84-0 Conclusions The NRC inspector found all the PTL inspectors that were onsite from January 1,-1984, to September 30, 1984, to be qualified. This allegation could not be substantiated and is considered close . Exit Meeting The inspector met with site representative (denoted in Persons Contacted paragraph) at the conclusion of the inspection. The inspector summarized the scope and findings fo the inspection noted in this report. The inspector also discussed the likely informational content of the inspector report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents /

processes as proprietar <