ML20140D465
| ML20140D465 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/10/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20140D403 | List: |
| References | |
| 9049N, NUDOCS 8412180537 | |
| Download: ML20140D465 (13) | |
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Commonwealth Edison j
one First National Plaa. Chicago. Illinors
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) Address Reply to. Post Office Box 767 N
,/ Chicago, Illinois 60690 August 10, 1984 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Braidwood Station Units 1 and 2 Response to Inspection Report Nos. 50-456/84-05 and 50-457/84-05 NRC Docket Nos. 50-456 and 50-457 Reference (a):
R.F. Warnick letter to Cordell Reed dated July 2, 1984.
Dear Mr. Keppler:
This letter is provided in response to the inspection conducted by Messrs. H. W. Kerch, R. H. Harris and R. M. Campbell of the Region I office on March 26 through April 6, and April 9 through 20 1984, of activities at our Braidwood Station. Reference (a)indicatedchakcertainactivities appeared to be in noncompliance with NRC requ.rements. The Commonwealth Edison Company response to the Notice of Violstion as appended to Reference (a) is provided in the Enclosure to this letter.
On page three of the Inspection Report attached to Reference (a),
the following statement is found, "An NRC inspector made a random selection of weldments which were intended to provide a representative sample of piping systems, components, pipe sizes, shop and field weldments fabricated to AWS 01.1 and ASE Classes 1, 2, and 3."
The Commonwealth Edison Compar/
disagrees with this characterization. As we discussed with Messrs. C. E.
Norelius and R. F. Warnick of your office on March 29 and 30,1984, we believe that the sample was chosen so as to include a disproportionate number of welds involving discrepancies requiring interpretation of weld acceptability where specific Conynonwealth Edison Level III resolution was necessary.
Our delay in submittal of this thirty-day response until August 10, 1984 was discussed with Mr. R. F. Warnick of your office on August 1,1984.
g Very t ly yours 8412180537 841213 PDR ADOCK 05000456 w-m G
PDR Dennis L. Farrar Director of Nuclear Licensing Im Enclosure AUG N
-cc: NFC Resident Inspector Braidwood 9049N i
ENCLOSURE C0f440NWEALTH E0ISON COWANY RE PONSE TO INTECTION REPORT 50-456/84-05 and 50-457/84-05 ITEM OF NONCOWLIAPCE A.
10 CFR 50, Appendix B, Criterion IX requires that special processes such as nondestructive testing, be accomplished in accordance with applicable codes. The Piping System Fabrication Specification 2741, paragraph 108.1 invokes the ASME III Code,1974 Edition, Summer 1975 Addenda, for the installation of piping systems.
The ASME III Code directs that nondestructive testing be accomplished in accordance with the ASNE V Code.
The ASME III Code requires that:
Paragraph T-263.1, penetrameters be placed adjacent to the weld seam and not in the area of interest.
Paragraph T-233.2, radiographs be free from mechanical, chemical or other blemishes that might mask or be confused with discontinuities.
Paragraph T-233.1, Part III of Recommended Practice SE-94 shall be used for film processing. SE-94, paragraph 20.10, recommends radiographic film fixers be adequately removed to assure archival quality film.
Contrary to the above, a review of ASME III Code piping radiographs on April 9 - 20, 1984, disclosed the following:
(1) Weld No. Q6056-CV-23-6, welds 6 and 8, had penetrameters placed in the area of interest.
(2) Weld No. Q6056-CV-23-6, weld 6, film stations 2 to 3, had mechanical, chemical, or other blemishes that might obscure discontinuities.
(3) Weld No. Q6056-CS-108-9-16, weld 6, had penetrameters placed in the area of interest.
(4) Weld Nos. Q6056-CV-23-6, weld 8, and Q6058-CS-78-16-2, welds 8, 9,10, and 11, have degenerated film quality from inadequate fixer removal and do not meet archival quality standards.
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. Response to Item A RES20NSE The Commonwealth Edison Company review of examples (1) and (3) indicate disagreement with the classifications of these conditions as examples of noncompliance. Our corrective actions taken in response to similar example (1) concerns at Byron Station address the example (1) issue at Braidwood Station.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (1)
In regards to Q6056-CV-23-6 weld no. 8, it was determined that an earlier Byron NRC Inspection 50-454/82-01; 50-455/82-01 Noncompliance 454/82-01-01 identified shop welds that had penetrameters in the weld on the radiographs. At that time, a review was conducted to determine the extent of this condition at both the Byron and Braidwood Sites (because the vendor performed work applicable to both construction permits). The results of this review performed between 1-20-82 and 2-18-82 determined that this condition also existed at the Braidwood Site. On February 2,1982, Commonwealth Edison submitted a Code Inquiry to Subcommittee V of the ASME Boiler Pressure Vessel Code and on September 17, 1982, the Committee approved Code Case
- 1914. On March 16, 1983, Commonwealth Edison advised Region III that, as stated above, the questioned practice was consistent with the intent of the Code. On April 4, 1983, Commonwealth Edison received a reply from Mr. R. L. Spessard that Region III had received Commonwealth Edison's letter of March 16,1983, and that the ASME response to the Code Inquiry would be forwarded to NRC Headquarters for evaluation by the NRC staff to determine if it qualifies for inclusion in the NRC's approved list of ASME Code Cases.
The present status of Noncompliance 454/82-01-01 was provided in NRC Region III Report 50-454/84-05 which stated that Region III is waiting for a response from NRC Headquarters for their evaluation to determine if it qualifies for inclusion in the approved list of ASHI Code Cases.
This status was also provided in Region III Report 50-454/84-13. Therefore, at this time, no additional action will be taken pending our receipt of a response from the NRC resolving Noncompliance 454/82-01-01.
In addition, a review of Spool No. Q6056-CV-23-6 weld no. 6 determined that the penetrameters are placed approximately 1/2" from the edge of the weld, well removed from the area of interest. Reference to notes taken by Comnonwealth Edison Company during the NRC exit meeting, indicates that Spool No.
Q6056-CV-23-6 weld no. 3 was the item addressed, as opposed to Spool No. Q6056-CV-23-6 weld no. 6.
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. However, an additional review of Spool No. Q6056-CV-23-6 weld no. 3, area 1-2, did not reveal the penetrameters to be in the area of interest, although penetrameter placement was immediately adjacent to the toe of the weld. Therefore, no additional action appears to be necessary.
(2) A review of Spool No. Q6056-CV-23-6 weld no. 3, station markers 2-3, in addition to Spool No. Q6056-CV-23-6 weld no. 6, determined that no mechanical, chemical, or other blemishes exist in the area of interest on either weld which obscures or interferes with proper interpretation. Based on the same review, Commonwealth Edison believes that no transverse indication exists on either weld, 3/8 of an inch from station marker #3. However, both welds will be incorporated into the formal Level III film review which is being conducted as part of Commonwealth Edison Nonconformance Report #605.
(See our corrective action concerning Item of Noncompliance B.)
(3) A review of Spool No. Q6056-CS-108-9-16 weld no. 6 and associated reader sheets determined that the reader sheet does state "Due to configuration of Weld-0-Let to pipe fitup, penetrameters were placed on the weld metal". Commonwealth Edison believes that the radiographer did meet the requirements of Paragraph T-262.2 of Section V (1974 Code edition) due to geometry and thus additional action is not required.
(4) Commonwealth Edison Nonconformance Report #606 has been issued to document and disposition the Southwest Fabricating film yellowing. Engineering has reviewed the NCR and proposed a program of corrective action to determine the extent of the film yellowing and actions that will be taken when results are tabulated.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIANCE (1) The placement of penetrameters across welds was discontinued by the fabricator for Byron and Braidwood work as of January 22, 1979. Further corrective action will not be taken pending NRC resolution of Noncompliance 454/82-01-01.
(2) Based on the presently available information, no further corrective action is deemed necessary at this time.
(3) Commonwealth Edison believes that no deficiency exists. No further corrective action is necessary.
(4) Pittsburgh Testing Lab (onsite NDE contractor) is performing testing of film for archive quality on a daily sample basis.
Additionally the radiograph turnover Procedure SQI-24 (Rev. 1) has been revised to require sample checking for film yellowing caused by inadequate fixer removal prior to turnover to the Station.
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> DATE OF FULL COWLIAPCE (1) In. regard.to Item 1 of this response, completion of any required corrective action is dependent on the Commonwealth Edison receipt of the NRC position related to Code Case #1914. It is requested that Region III follow-up on their inquiry to NRC Headquarters concerning this matter.
(2) The additional Level III review is expected to be completed by November 15, 1984.
(3) Full compliance has been achieved.
(4) The present expected date of resolution of NCR #606 is January 1, 1985.
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. ITEM OF NONCO WLIANCE B.
10 CFR 50, Appendix B, Criterion XV, requires that nonconforming items be identified, reviewed and dispositioned in accordance with documented procedures. The Site Quality Assurance Manual, Section 15, requires that Nonconforming Reports be written when material is believed to be nonconforming.
Contrary to the above, an NRC review of pipe wcld radiographs on April 9 thru 20,1984, disclosed that pipe welds Nos. M1962-LP3-FW-12, M1962-LP2-FW-2, M1962-LP3-FW-2, and M1962-LPl-FWil-R1 were identified as containing rejectable base metal indications but were not reported on nonconformance reports. These defects were not dispositioned in accordance with approved procedures.
Response to Item B CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Commonwealth Edison has issued Nonconformance Report #605 to more clearly document and disposition the subject base metal indications.
Additionally, cases where Commonwealth Edison Level III disposition was involved at the Braidwood site will be reviewed, re-evaluated, and properly docenented by another Level III. Any corrective actions which may be required as a result of this review will be tracked by NCR #605.
CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOW LIANCE The on-site NDE contractor Pittsburgh Testing Lab (PTL) was directed by Commonwealth Edison (via BRD #10,911) on April 13, 1984 to issue a separate report to the Phillips Getschow Company (the mechanical contractor) whenever base metal indications are encountered. Since that time, no additional base metal indications have been observed on radiographs by PTL. PTL has incorporated the Canmonwealth Edison directive into their radiography procedure. The site mechanical contractor's Q.A. Program Section 15 requires that nonconforming or indeterminant items be documented on a nonconformance report.
Therefore, our mechanical contractor's program does not require any revision.
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Future involvement by a' Level III outside the Pittsburgh Testing Lab '
or the Phillips Getschow Company organizations will be in accordance with the project procedure presently being developed. This procedure will address methods of documenting Level III reviews as well as more clearly identifying the organizations who should participate in such reviews.
DATE OF FULL COWLIANCE The Commonwealth Edison Level III review, re-evaluation, and documentation of the cases of previous Commonwealth Edison Level III disposition is expected to be completed by November 15, 1984.
The project procedure controlling future involvement of a Level.III outside the Pittsburgh Testing Lab or the Phillfps Getschow Company organizations is expected to be approved and issued by November 15, 1984.
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. ITEM OF N0tCO WLIAtCE C.
10 CFR 50, Appendix B, Criterion IX, directs that nondestructive testing be accomplished in accordance with appropriate codes. Die Piping System Installation Specification, F/L-2739, invokes the ASNE III Code, 1974 Edition, Summer 1975 Addenda. The ASME III Code directs that nondestructive testing be accomplished in accordance with ASME V Code.
The ASNE III Code, paragraph NC5320, directs that for sections of welds that are shown by radiography to contain any type of crack or zone of incomplete fusion they are to be classified as unacceptable.
The ASME V Code, paragraph T263.2, requires that the density of the radiograoh shall not vary by more than minus 15% or plus 30% in the area of interest relative to the density through the penetrameter.
Contrary to the above, an NRC review of pipe weld radiographs on April 9'20, 1984, disclosed the following:
(1) The ASME Class 2 welds Nos. WO44-FWilRS, CV17-FW2CRS, and SIl4-FW9 contained zones of incomplete fusion and cracks and were not rejected.
(2) Weld No. SIl3-FW15R1, film station 14, contained an area of weld drop through that exceeded the minus 15%, plus 30% film density requirements.
Response to Item C CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED (la) WO 44-FWilRS The film of Weld No. WO 44-FWilRS provided by the NRC was compared to Commonwealth Edison's radiograph. This comparison did reveal that the NRC radiographic technique identified an area of incomplete fusion. The Commonwealth Edison radiographic records on file did have sufficient sensitivity (as evident by the image of the required T-hole on the properly located penetrameter) to satisfy Code requirements. However, the area of incomplete fusion will oe repaired and subsequent re-inspection will be performed.
. It should be noted that an area within the same increment, (3-0), was previously accepted by Commonwealth Edison's Level III. However, the area accepted by Commonwealth Edison's Level III was different from the indication identified by the NRC's radiographic technique and was not questioned during the NRC inspection.
(lb) CV 17-FW2CRS Upon re-interpretation of the radiographs for Weld No.
CV 17-FW2CRS, Commonwealth Eoison agrees that a rejectable area of incomplete fusion does exist and the necessary repair and subsequent re-inspection will be performed.
(lc) SI 14-FW9 Due to the questionable indications contained in Weld No.
SI 14-FW9, Commonwealth Edison has determined that additional testing yielding greater sensitivity would be performed prior to making a final interpretation. As a result, the weld in question will be prepared and ultrasonically inspected. This will be followed by additional radiography of the weld and the results of both examinations will be compared.
Following the above examinations, a final disposition of the item and any necessary corrective actions will be taken. The results of this review as well as corrective action deemed necessary will be available for NRC review at the site.
(2) SI 13-FW15R1 Upon re-review of the radiographs for Weld No. SI 13-FW15R1, Commonwealth Edison agrees that the isolated area of the drop through does not meet the minimum density requirement; as dictated by the density of the properly located penetrameter.
As a result, Commonwealth Edison will perform subsequent radiography of the affected area and achieve densities that comply with ASE Section V, paragraph T-263.2.- If acceptable densities of the affected area cannot.be achieved, the item will be repaired and subsequent reinspection will be performed.
CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCG'PLIAPCE We believe the corrective actions that will be taken in response to PCR #605, in conjunction with the number of radiographs sampled by the NRC, sufficiently address the adequacy of previous work.
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. ~(la) This is believed to be a isolated occurance because as indicated on Page a, Section 2.2 of the Reference (a) Inspection Report, 34 welds were examined and no similar cases were identified. No further corrective action is deemed necessary.
(1b) The Independent Testing Agency and Mechanical Contractor will receive formal instruction that includes the necessary variables to address the concern of inadequate interpretation.
(1c) Welds at the site which involved a Commonwealth Edison Level III interpreter will be re-evaluated by another Level III. The results.of this review will be clearly documented and any subsequent actions will be addressed as part of Commonwealth Edison Company NCR #605.
(2) The Independent Testing Agency and Mechanical Contractor will receive additional formal instruction.
The NDE personnel of both the Independent Testing Agency and Mechanical Contractor will be made aware of the concerns and actions relating to this inspection. Additionally, a more formalized system of dispositioning disagreements between the Independent Testing Agency Level III and the Mechanical Contractor Level III will be implemented. Finally, future practices will require a clearly documented basis of acceptance by Commonwealth Edison Company Level III cersonnel in the event of a conflict.
DATE OF FULL COWLIANCE (la) It is expected that the area of incomplete fusion will be repaired and reinspected by September 3, 1984.
(1b) It is expected that the repair, reinspection, and additional formal instruction will be performed by September 3,1984.
(Ic) It is expected that NCR #605 will be dispositioned by November 15, 1984.
(2) It is expected that this weld will undergo additional radiography and be accepted or repaired by November 15, 1984.
Further, it is expected that the Independent Testig Agency and Mechanical Contractor will receive additional formal instruction by November 15, 1984.
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9 ITEM OF NDPCOWLIAICE:-
~ D.- 10.CFR 50, Appendix B,^ Criterion VI,. Document control requires that.
measures be established to control the issuance of documents such as
. drawings, including changes thereto, which prescribe activities
' affecting quality.. Site Procedure GO-3.13, Rev. 6, requires
' Engineering Change Notices (ECN's) to be adequately shown on des Q-documents.
Contrary:to the above, an NRC review during April 9-20, 1984, disclosed that the site licensee construction Quality Assurance operative working drawing file did-not reflect current revisions or ECN's on the drawings and these drawings were being used to verify.
quality related activities.
Response to Item ti RESM)NSE Commonwealth Edison belle /es that a non-compliance did not in fact exist but. rather a lack.of communications existed on the part of both Commonwealth. Edison and'NfC relative to this matter.
With ' respect to the matter of the Quality Assurance drawing file not
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reflecting current revisions, the following information should be considered:
Site Quality Assurance had previously identified the fact that some aperture cards were not current. A memo.was issued to the Site QA staff on January 5,1984 requiring that QA " verify that -
persons making prints using the aperture card reader / printer are making prints from cards of current revision. No prints are to be made from out-of-date cards". Because steps had been taken to assure'that prints were made from current revisions and.none of the prints given to the NRC inspector were of a previous revision, the comment that "the~ drawing file did not reflect i
current revision" as stated in Reference (a) is not accurate in our judgment.
During the course of the NRC inspection, a request for drawing's to inspect _ certain compone.ats was made to the-Quality Assurance Department. -This request was interpreted by the Quality
. Assurance inspector as a request for an informational /locational drawing to preplan:an inspection. Pertinent copies of the requested drawings were obtained from our aperture cards,-
. verified to be of a' current revision, and stamped. ' Applicable
~ECNs ano FCRs were noted'on the drawings at this time but due to l-the apparent misunderstanding on how the prints would be used,
' copies of _ applicable ECNs or FCRs were not also provided.
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. After the intended use of the drawings for inspection purposes was clarified, the Quality Assurance Inspector who provided the copies to the NRC Inspector took the step of obtaining the applicable FCRs and ECNs. Copies of these documents were provided to the NRC Inspector.
Commonwealth Edison believes the characterization of this item as the " third violation issued for the same problem" is unfair. We believe rather that this is an example of a misinterpreted request and a presumption that the NRC inspection team understood the control system that was in place at the time.
During the exit meeting, this was not presented as an item of non-compliance or comment, therefore, no attempt was made to respond or explain the circumstances surrounding this item. At the time that the concern was identified to Quality Assurance through the resident irspector, attempts were made to contact Mr. Kerch to clarify this matter. Due to the schedules of Mr.
Kerch and the site resident inspector, these efforts were not successful. Had a clear understanding of the NRC's request been obtained, the prints in question would have been initially issued including copies of applicable ECNs and FCRs.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED When Commonwealth Edison Site Quality Assurance was advised of the NRC's concern, a Hold Point was immediately placed on the issuance of print copies from Quality Assurance's aperture cards.
The Quality Assurance clerical group was actively involved in updating the file when the inspection team's request was received. This updating is now complete.
The control of aperture cards in the Site Quality T.ssurance Office is outlined in Site Quality Instruction (SQI) #7.
Because the handling of the prints for the NRC may not have been in strict accordance with SQI #7, the aperature card control instruction (Site Quality Instruction #7) has been revised to assure greater control of prints. The type and content of stamps applied to prints has been revised for clarity.
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. CC5tRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOWLIAFCE The revised SQI #7 contains sufficient control to prevent recurrence. This was completed by June 28, 1984.
Personnel having access to the aperature card file and printer are being trained in the requirements of SQI #7 Rev. 4.
DATE OF FULL COWLIAFCE Training on the revised SQI #7 (Rev. 4) has been completed.
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