IR 05000454/1980015
| ML19347B127 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/27/1980 |
| From: | Hayes D, Naidu K, Schapker J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347B121 | List: |
| References | |
| 50-454-80-15, 50-455-80-14, NUDOCS 8010010620 | |
| Download: ML19347B127 (9) | |
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V U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-454/80-15; 50-455/80-14 Docket Nos. 50-454; 50-455 Licenses No. CPPR-130; CPPR-131 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name:
Byron Nuclear Power Plant, Units 1 and 2 Inspection At:
Byron Site, Byron, IL Inspection Conducted: August 5-7 and 12, 1980 f,
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Inspectors:
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g Other Accompanying Personnel:
A. J. Mateo Supervising Nuclear Technologist Philipping Atomic Energy Commission ddtw6 fw L
Approved By: h.d. Hayes, Chef b/d 7[$'0
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Engineering Support Section 1 Inspection Summary Inspection on August 5-7 and 12, 1980 (Reports No. 50-454/80-15; 50-455/80-14)
Areas Inspected: Observation of installed safety related electrical equipment, instrumentation, and nondestructive examination of instrument line welds. The inspection involved a total of 26 inspection-hours onsite by two NRC i spectors.
Results: One item of noncompliance was identified in the seven areas nspected.
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DETAILS
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Commonwealth Edison Company (CECO)
G. Sorenson, Project Superintendent H. Harger, Station Construction Engineer R. B. Klinger, Quality Assurance Engineer H. O. Kaminsky, Quality Assurance Engineer
- J.
J. McIntire, Quality Assurance Supervsior
- J.
Mihovilovich, Lead Structural Engineer J. T. Porter, Sr. Quality Assurance Inspector
- R.
Tuetkin, Lead Mechanical Engineer
- G. E. Smith, Lead Electrical Engineer
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R. Choinard, Quality Assurance Engineer Pope Company (PAP)
- C.
Blenstroub, Quality Control Supervisor
- P. K. Botts, Quality Manager
- M. Donohoe, Project Engineer
- J. Mai, Project Manager
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Pittsburgh Testing Laboratory (PTL)
F. Schluter, NDE Supervisor J. Troutman, Site Manager M. Troutman, NDE Technician
- Denotes those who were not present at the exit interview conducted on August 7,1980.
- Denotes those present at the exit interview conducted on August 12, 1980. The inspectors also contacted other contractor and licensee personnel during the course of the inspection.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-454/80-12-02; 50-455/80-11-02). Mortar cube samples collected from the mortar mix to which water was added were tested; the compression test results exceeded the specified 2500 psi.
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SECTION I
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Prepared By K. R. Naidu Reviewed By D. W. Hayes Functional or Program Areas Inspected 1.
Observation of Installed Electrical Equipment The inspector observed the installation of the following electrical equipment:
a.
125 volt battery and battery racks. This equipment was supplied by Gould and installed per Gould drawings 062831D, sheets 1 and 2 of 3 and 062813C, sheet 3 of 3.
Notes on the drawings specify:
(1) Post connections to be attached with 5/16" - 18 x 2-1/2" long brass stud and 2 5/16" - 18 lead coated brass nuts (2) Terminal lugs and inter rack cable connection lugs to be attached with 1/2"-13 x 1-1/4" long stainless steel hexagonal bolts, nuts, and washers (3) Torque was specified to be 8.3 i.3 ft. Ibs.
Paragraph 201.9 of Sargent and Lundy Specification F-2819 for storage batteries and racks specifies the racks to be "of all steel construction with non-aging equalizing plastic or molded rubber covers for the battery rails and shall be painted with a minimum of two coats of acid resisting gray paint".
The inspector observed that there was no indication that the hardware used to assemble the battery racks was of acid resisting type.
The inspector stated and the licensee agreed that even though measures were established to protect the steel components of the battery racks against acid corrosion after installation, no measures were established to either specify acid resistant hardware or protect the current carbon steel hardware against corrosion. The inspector informed the licensee that inadequate measures were established to specific requirements for hardware to withstand without deterioration acid atmosphere was an item of noncompliance contrary to the requirements of Criterion V of 10 CFR 50 Appendix B.
The licensee took immediate corrective action to initiate development of requirements for the bolts, nuts, and hardware for the seismic Category I battery racks and revised requirements on station battery surveillance procedure to include battery rack hardware.
b.
The installed penetrations for the Reactor Coolant Pump cables and the Pressurizer heater cables.
These penetrations were-3-
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supplied by Conax; a pressure gauge mounted on the penetration
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indicates that positive pressure was being maintained inside the penetration. The penetration is equipped with an integrator valve, which, when opened, subjects the "0" ring seal to the same pressure; a drop in the pressure will indicate that the "0" ring seal is leaking.
The integrator valve was opened on one penetration and no leak was detected.
c.
Cables for the pressurizer heaters had been pulled to the pressurizer and were being prepared for termination.
d.
Pressurizer Heater Unit Substations (PHUS) backup groups 1RY01EA, IRY01EB, IRY01ED, and control group 1RY01EC had been installed.
This equipment has been identified as safety related. The unit substations feed the heaters through distribution cabinets which are not identified as safety related. The licensee checked with S&L and informed the inspector that the PHUS will be removed from the safety related equipment list. All the PNUS are being supplied from a non-safety related bus.
The question of classification of pressurizer heater cables and associated equipment is being referred to NRC headquarters for resolution.
(454/80-15-01; 455/80-14-01).
One item of noncompliance was identified in the above area.
2.
Review of Instrumentation Installation Activities Powers Azco Pope Company (PAP), a joint venture of the Powers Regulator Company (Powers), AZCO and the Pope Companies perform the instrumentation installation activities. Powers provides the engineering personnel who do onsite engineering including field routing of instrumentation tubing and design of instrument tu.ing hangers and panels utilizing guidelines established by S&L. AZCO contributes the QA program and the "N" stamp privileges. Powers provides the project management and manpower. The inspector reviewed PAP QA Manual and determined the following:
a.
Organization (1) Organizational structure and functional relationships as defined appear acceptable.
(2) The responsibilities and duties of QA and QC personnel are inde-pendent from personnel having cost or scheduling responsibilities.
(3)
In a letter dated December 22, 1979, the president of AZCO assigned the "Stop Work" authority to the Quality Manager.
(4)
Indoctrination / training program is performed to procedure QC-1, Revision 3, dated March 12, 1980.
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b.
Audit a
(1) Procedure No. QC-5 addresses site audits by the site Quality Manager. An audit schedule was available; some of the audits were overdue because of changes in the Quality Assurance per-sonnel. PAP Quality Manager assured the inspectors that the overdue audits will be completed in the next 3 months.
Paragraph 7-1 of the procedure provides for a management audit by AZCO's QA manager annually, c.
Quality Requirements (1) Quality requirements are translated into material requisitions which undergo review by PAP and a further review by the licensee, prior to procurement by the licensee.
(2) Receipt inspections are performed by PAPS QC inspectors, the results are documented in a " Receiving Inspection Checklist".
Attributes examined include packaging, visual / dimensional checks, shipping damage, and material certifications.
(3) Paragraph 401.5a of Specification 2906 permits the contractor to field run sensing lines to meet the necessary separation criteria subject to the final approval of the consulting engineers.
(4) Travellers have been established with hold / inspection points.
(5) Selected procedures were reviewed and determined complete, approved, and controlled.
d.
Inspections In process and visual weld inspections are performed by PAP QC inspectors. Liquid penetrant tests on welds are performed by Pittsburgh Testing Laboratories (PTL), the licensee's independent testing agency.
No items of noncompliance were identified in the above areas.
3.
Observation of Storage Areas a.
Cable Storage Yard The inspectors walked around the cable storage yard and observed that the cable reels were stored on dunnage. All the cable ends were capped.
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b.
Instrument Storage
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The inspectors observed the various instruments stored in the warehouse.
Instruments are bench tested by the licensee to verify operability and are calibrated.
Some of the instruments which failed bench testing were not appropriately identified and segregated. Further, review indicated no procedural requirements existed for tagging and segregating instruments identified as noncomforming during bench testing. The inspector informed the licensee that this was another example of failure to meet require-ments of Criterion V of 10 CFR 50 Appendix B as identified on paragraph 1.a above. The licensee stated that a program was initiated to bench test instruments to verify operability and inadvertently did not establish measures to segregate and dis-position instruments identified to be nonconforming during this testing. Prior to the conclusion c. the inspection, the noncon-forming instruments were tagged anu segregated; procedural re-quirements were being established to handle such nonconforming instruments.
(454/80-15-01; 455/80-14-01)
One example of an item of noncompliance was identified in the above area.
4.
Observation of Instrument Installation Activities The inspectors observed the various activities inside the containment and the auxiliary building and determined the following:
a.
Local instrument panel IPL66JR1 was installed at elevation 377 as indicated on drawing M-821, Revision D, " Instrument Locations Elevation 377'-0" Reactor Containment".
1/2" lines IRC40LB, IRC40YB, IRC40XB, and IRC40KB have been partially installed and welded to the panel.
b.
The lines IRC40XB (high) and IRC40KB (low) are routed to Steam Generator (SG) IB and lines IRC40LB and IRC40YB go to SG IC as
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per S&L drawings M-60, Revision S, Sheet 1 of 8, and M-2060, Revision E, Sheet 1 of 11.
c.
Systems Control's (the panel manufacturer) drawing 6577-MIPL66J specifies that the panels are to be anchored to the embed with a 3/8" size fillet weld. Weld procedure (WPS) ANISL(B) qualified to ASME Section IX was used to weld the panel.
d.
Visual weld inspections are to be performed to procedure QC-3, Revision 2.
e.
WPS AN8TSL was used to weld the socket welds on the 1/2" stain-less steel tubing between the panels and the root valves.
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f.
The inspectors observed the partial installation of lines ISI
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15AB and ISI C&AB to the suction and discharge sides of the safety injection pump ISIO1PA; the installation is in accordance to drawing M-826, Sheet 6.
Even though drawing M-61 shows that line ISI C7AB is connected to a pressure indicator IPI-SI 044, the drawing M-828 Sheet 6 does not show this detail. PAP has documented this on an Instrument Installation Problem (IIP) #77 dated June 17, 1980 and informed Sargent&Lundy. PAP was verbally informed to locate IPI S1044 alongside of instrument IPT SIO47; this change is to be incorporated in the next drawing revision.
A similar problem is identified on SI pump IS01PB2.
g.
Instrument racks are designed by PAP with guidelines provided by S&L; Drawing M-106-IPI-SIO44-H235 indicates the panel for instru-ments SI-044, a five way valve manifold, a pressure indicator and a flow indicator.
Installation of the panel is complete; the tubing to the instruments is incomplete.
h.
The inspectors observed the installation of lines ICC68CB and ICC68AB to IFT-688 installed on rack M-56; these lines are in the component cooling water system.
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In all the above cases, the inspectors examined the socket welds and determined them acceptable; the socket weld reference punch marks were visible on the sockets and the tubes, indicating that the tube was retracted 1/16" minimum from the socket after full insertion.
5.
Review of Inspection Records The inspection records on the installation of instrument racks IPL66JR indicate that inspections were not performed. The inspectors observed and the licensee / contractor personnel concurred that the size of one of the welds anchoring the instrument panel was below that specified; the inspector stated that this condition should have been identified in a timely manner and corrected. The inspector stated that failure to establish measures to conduct inspections in a timely manner was another example of the item of noncompliance contrary to Criterion V of 10 CFR 50 Appendix B as identified in paragraph 1.a above. The licensee initiated immediate corrective action to revise the existing procedures. The implementation of IE,rocedures will be reviewed during a subsequent inspection. (454/80-15-01; 455/80-14-01)
One example of an item of noncompliance identified in paragraph 1.a above was identified in the above area.
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SECTION II
Prepared By J. F. Schapker Reviewed By D. H. Danielson 1.
Observation of Nondestructive Examination The inspector witnessed liquid penetrant examination of (PT) feed water instrumentation line identified as #1FWO7AA-3/4, weld numbers 84, 85, 86, 88, 90, 113, and 115. Examination personnel certifications and penetrant material certifications were verified.
Pittsburgh Testing Lab (PTL), the licensee's independent testing laboratory, liquid pene-trant procedure #QC-PT-1, Revision 2 dated February 13, 1978 with field change #BY-20 dated June 16, 1980 was utilized.
In this connection, the inspector also reviewed Commonwealth Edison letter No. BY 5178 dated June 12, 1980, addressed to PTL's site manager concerning the liquid
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penetrant examination of ASME Class 1, 2 and 3 welds, and determined that the contents are in wrporated in the PTL procedure referenced above. Essentially the letter clarifies the criteria for determining the " weld area" for ASME Section III Class 1, 2" and under socket welds; Class 2, 2 1/2" and larger butt welds; Class 2, 2" and under socket welds; and Class 3, 2-1/2" and larger butt welds.
Class 1, 2-1/2" and larger butt welds as stipulated in the Code to include 1/2" on each side of the weld.
The remainder of the referenced weld types are vague in that the Code states that the weld will be examined, and no reference as to overlap as required by Class 1, 2-1/2" and larger butt welds.
Commonwealth Edison, in order to determine the extent of the weld and heat effected zone, collected weld samples and macro etched the same. The results were the following:
(1) for socket welds 2" and under, the Heat Affect Zone (HAZ) was less than 1/64"; (2) for butt welds on 2-1/2" and larger piping the HAZ was less than 1/8".
As a result of this examination, the licensee determined that 1/16" for socket and 1/8" for butt welds overlap of the weld would provide adequate coverage of the weld for liquid penetrant examination.
The inspector discussed the referenced letter including the procedure amendment with the licensee representatives and conveyed the following comments:
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l Although the above procedure is in compliance with ASME Section a.
III, the dimensions of 1/16" and 1/8" for overlap of liquid penetrant examination is not practical to use as a reliable tool.
It is often very difficult to determine the edge of a weld due to mechanical preparation for NDE.
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Heat affected zones are very seldom consistent and depend on the welding variables and are almost impossible to detect visually without the aid of an etchant.
c.
In the interest of quality and safety of the component, it would be more practical to use a more conservative number such an 1/4" for socket and 1/2" for butt welds for overlap to,sssure the weld
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has been properly examined.
s The inspector also discussed the applicability of the above PT procedure to the incore instrumentation piping and the socket welds. The licer.see stated that incore instrumentation is governed by Westinghouse liquid Penetrant Specification, PS 595139, Quality level A.
Review of this specification indicates that PS 595139 specifies the following acceptance criteria:
a.
The weld would be examined, plus 0.5" on each edge of the weld b.
No indications are allowed The above requirement for the examination of the incore instrument piping examination is considered to have the highest quality standard practical in compliance with 10 CFR 50, Appendix A, Criterion 30.
No items of noncompliance or deviations were identified in the above area.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items identified during this inspection are discussed in Section I, Paragraph 1.
Exit Interview The inspectors met with licensee representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection and outlined the scope of the inspection along with a summarization of the results.
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