ML19321A895
| ML19321A895 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/09/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19321A889 | List: |
| References | |
| NUDOCS 8007240351 | |
| Download: ML19321A895 (4) | |
Text
/^\\
Commonwe:lth Edison l
one First National Plaza. Chicago, Ilknois ssj Address Reply to: Post Office Box 767 i
\\
j Chic *' >, tilinois 60690 July 9, 1980 Mr. James G. Meppler, Director Directorate of i 'pection and Enforcement - Region III U.S. Nuclaar Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to Notice of Violation IE Inspection Report 50-456/80-05 and 50-457/80-05 NRC Docket Nos. 50-456/457 Reference (a):
G.
Fiorelli letter to C. Reed dated June 5, 1980
Dear Mr. Keppler:
The following is in response to the inspection conducted by Mr. E.
W.
K.
Lee on April 29 and May 20, 1980 of activities at Braidwood Station Unit 1 and 2.
Reference (1) indicated that certain activities appeared to be in noncompliance with NRC requirements.
These activities are addressed in the enclosure to this letter.
Please refer any additional questions you may have on this matter to this office.
Very truly yours, fg$
D. L.
Peop Fe s Director of Nuclear Licensing LOD / rap Enclosure JUL 101980 5043A i
send o 35/
Enclosure Response to Notice of Violation The items of apparent noncompliance identified in Appendix A of the NRC letter dateo June 5, 1980 are responded to in the following paragraphs:
Item 1 On May 20, 1980, the inspector determined that actions had been taken to correct this item and to prevent recurrence.
Consequently, no reply to this noncompliance is required.
Item 2 10 CFR 50, Appendix B, Criterion IX states, that " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Commonwealth Edison Company Topical report No. CE-1A, Revision 10, Section 9 states, in part, that "For these processes, quality assurance is obtained through reliance on personnel qualification and procedure control in force as appropriate for processes being employed for a specific task in connection with plant contract work, maintenance. repairs, and modification."
Phillips, Getschow Company Procedure No. IA-MA-88, Revision 10, states, in part, that "... Stringer beading is preferred and ceaving with' coated electrodes shall be limited to approximately four times the core wire diameter.
NOTE:
For all inservice inspected piping, weaving of the electrode will be limited to approximately 3 times the core wire diameter..."
Contrary to the above, on May 20, 1980, the inspector established the following:
a.
The weld bead width of the Reactor Coolant System weld No. M-196 _P3-FW12 was between 5/8" to 1" and 1/8" diameter 9lectrodes were used.
b.
The weld bead width of the Reactor Coolant System weld No. M-196-LP1-FW2 was approximate 1v 3/4" wide and 3/32" and 1/8" diameter electrodes were uced.
c The weld bead width of the Safety Injection System we.1 J No. SI-6-FW7B was approximately 3/4" wide and 3/3 d diameter electrodes.ere used.
t.
Corrective Action Taken and Results Achieved The discrepancies identified in the subject infraction have been reviewed by the Commonwealth Edison Operational Analysis Department (OAD) and Station Nuclear Engineering Department (SNED).
The procedural requirement violated has been determined not to effect the mechanical adequacy of the welds in question.
Furthermore, this specific procedural requirement was imposed with the intention of improving the volumetric (UT) examination characteristics of the weld only.
Studies conducted by OAD indicate that the hoped for improvement in UT characteristics are in fact not supportable.
This is based on comparative tests performed on controlled weave welds which appear to have unchanged grain boundary characteristics from welds not so controlled.
Therefore, no remedial action is required for the welds in question.
Commonwealth Edison is reviewing the need for the controlled weave weld procedures which were violated.
These procedures may be revised to alleviate the more stringent requirement now in existence.
Until such time as this reassessment is complete, the existing procedure will be enforced.
Corrective Action to Avoid Further Noncompliance The piping contractor (Phillips Getchow) has issued a directive to the field with clear cut guidelines on the permissable bead width deposit per electrode size.
This directive has been supported with a training session for every welder employed.
These guidelines will remain in effect until such time as the underlying procedure requirement is reassessed.
Date of Full Compliance The contractor directive and welder training discussed above was completed as of July 1, 1980.
The elimination of the current procedural requirement will be completed as resources become available.
Since ti; reassessment of the weld specification does not effect the corrective action discussed above, no further response to this item is required.
Item 3 10 CFR 50, Appendix B, Criterion XIII, states, in part, that, "... Measures shall be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in acccordance with work and inspection instructions to prevent damage or. deterioration..."
Commonwealth Edison Company Topical Report No. CE-1-A, Revision 10, states, in part, that-"...
Written instructins for handling,~ preservation, storage, and shipping will be used to specffy special protective conditions necessary to prevent damage or deterioretion of materialE and equipment..."
a Phillips, Getschow Company Procedure No. QAP-3, Rev.ision 0, Paragraph 4.1.2 requires that E7018, E308, E309, E310 and E316 electrodes manufactured by McKay be stored in the holding oven at 2750F".
~
Contrary to the above, on May 20, 1980, the inspector established that E308 electrodes with heat Nos. 2877920 and 2197417, and electrodes for non nuclear work manufactured by McKay were stored at weld rod oven No. 12 in the welding material issuance station located at the Turbine Building.
The weld rod oven temperature was 1500F measured by a contact pyrometer.
Corrective Action Taken and Results Achieved The discrepant weld rod identified in this item was not used.
The material was disposed of and personnel responsible for controlling similar. rod were reinstructed on appropriate storage procedures.
Corrective Action Taken to Avoid Further Noncompliance All rod ovens were checked for calibration and results were documented.
In addition, tool room personnel were reinstructed on celd rod storage procedure.
Date of Full Compliance Full compliance was achieved on May 20, 1980.
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