IR 05000454/1980025
| ML19347F704 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/17/1981 |
| From: | Gardner R, Richard Lee, Naidu K, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347F699 | List: |
| References | |
| 50-454-80-25, 50-455-80-23, NUDOCS 8105260077 | |
| Download: ML19347F704 (17) | |
Text
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.rSU U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Reports No. 50-454/80-25; 50-455/80-23
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Docket Nos. 50-454; 50-455 Licenses No..CPPR-130; CPPR-131
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Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Nuclear Generating Station, Units 1 and 2 Inspecti n At: Byron Construction Site, Byron, IL Inspection Conducted: December 15-19, 22-23, and 31, 1980; January 9 and 12, and March 27, 1981-(G, M
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Inspectors:
K. R. Naidu
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A $h R. Gardner Y// 7
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Other Accocipanying Personnel:
J. Boone C. Braund
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Reviewed By:
C. C. Williams, Chief 7Nf
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Plant Systems Section Inspection Summary Inspection on December 15-19, 22-23, 1980 and January 9 and 12, and March 27, 1981 (Reports No. 50-454/80-25; No. 50-455/80-23)
Areas Inspected: Review of electrical contractors QA implementing pro-cedures, observation of electrical installation activities, review of nonconformance reports, review of QA records, review of instrumentation installation specifications and procedures and observation of installed instrument lines. This inspectiot. involved a total of'144 inspector-hours on site by three NRC inspectors.
Rbsults: Of the five areas inspected, seven items of noncompliance were identified.
Criterion II - failure to comply with Quality Assurance program for design, construction, purchase, and installation of a safety-related component - Paragraph 5.f; Criterion V - examples of failure to establish
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procedures and failure to follow procedures - Paragraphs 3.b, 4.c, 4.g, 4.h, and /.a(1); Criterion III - examples of inadequate translation of design criteria such as FSAR commitments and standard requirements into drawings and specifications -' Paragraphs 4.f and 7.a(1); Criterion X -
examples of inadequate inspections and inadequate inspection requirements 2 Paragraphs 3.c and 4.d; Criterion XIII - examples of poor housekeeping
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- Paragraph 4.e; Criterion XV - examples of inadequate identification of nonconforming material - Paragraphs 5.a, 5.b, 5.c, 5.d, and 5.e; Criterion XVI - examples of inadequate corrective action - Paragraphs 3.d, 4.a, and 5.e.
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DETAILS 1.
Persons Contacted
a.
Inspection at Byren on December 15 19 and 22-23, 1980.
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Commonwealth Edison Company (CECut
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J. T. McIntire, Quality _ Assurance Supervisor G. E. Smith, Station Construction Electrical G. Sorensen, Construction Superintendent R. B. Klingler, Quality Assurance Engineer, Electrical R. Tuetkin, Station Construction Mechanical L. S. Combs. Quality Assurance. Inspector Hatfield Electric Company (HEC)
W. Gratza, Quality Assurance Supervisor Pope Asco Power Company (PAP)
J. H. Mai, Project Manager The inspectors also contacted other licensee and contractor personnel during the course of the' inspection.
b.
Management Meeting Attendees on December 31, 1980 Commonwealth Edison Company (CECO)
C. Reed, Vice President, Nuclear Operations J. Maley, Manager of Projects V. I. Schlosser, Project Manager, Byron /Braidwood W.'J. Schewski, Manager.of Quality Assurance G. F. Marcus, Director of Quality Assurance J. T. McIntire, Quality Assurance Supervisor G. Sorensen, Construction Superintendent G. E. Smith, Station Construction Electrical L. A. Bower, Project Engineering J. R. Lies, Project Engineering R. B. Klingler, Quality Assurance Engineer,-Electrical J. Westermeir, Project Engineer Sargent and Lundy (S&L)
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R. Treece, Senior Project Engineer Electrical M. Mensinger, Electrical Engineer
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Management Meeting Attendees on January 9,1981
, Commonwealth Edison Company (Ceco)
C. Reed, Vice President, Nuclear Operations J. Maley, Manager of Projects
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V. I. Schlosser, Project Manager, Byron /Braidwood
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W. J. Schewski, Manager of Quality Assurance J. S. Abel, Licensing Director J. Deress, Project Eagineer Sargent and Lundy (S&L)
M. Mensinger, Electrical Engineer d.
Management Meeting Attendees on January 12,1.81 Commonwealth Edison Company (CECO)
J. Maley, Manager of Projects
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V. I. Schlosser, Project Manager, Byron /Braidwood J. S. Abel, Licensing Director e.
Enforcement Conference Attendees on March 27, 1981 Commonwealth Edison Company (CECO)
C. Reed, Vice President, Nuclear Operations T. Tramm, Nuclear License Administrator J. S. Abel, Licensing Director
V. I. Schlosser, Project Manager, Byron /Braidwood J. J. Maley, Manager of Projects W. J. Shewski, Manager of Qaality Assurance L. A. Bowen, Project Engineering J. T. Westermeier, Project Engineering J. J. Dennehy, Project Engineering 2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (454/80-15-01; 455/80-14-01):
it was previously reported that IE Headquarters was being consulced on the classification of pressurizer heater cables and associated equipment.
NRC Headquarters has ruled that only the interface components connecting the pressurizer heaters to the emergency bus are required to be safety related, which can be accomplished by using a Class IE-
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breaker at the Class IE switchgear. The recommendation does not indicate that all other equipeent involved with connecting the pres--
surizer heaters to the emergency bus must be safety related in order
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to meet the requirements of NUREG-0578. The stated power supply
requirement for preselected pressurizer heaters will be verified-4-
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during the; normal'SAR review by NRR_for plants under. construction.
Since Byron.is in.the'early stages of'SAR review,-the upgrading of the pressurizer heater power supply must be implemented in accordance with.the schedules. outlined in NUREG-0660._
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3.
Review of Quality Assurance Implementing-Procedures In Use During This Inspection
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The inspectors' reviewed the Sargent and LundyL(S&L):Insta11ation'
Specification F-2790 for installing cables,fconduits and~ raceways and the relevant QA/QC procedures of Hatfield Electric Company (HEC)
and determined:the following:
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a.
S&L: Specification F-2790 references S&L Standard STD-EA-121'
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which requires the conduits to be prepared for cable pulling by being swabbed,: checked with a mandrel and. protected with. plugs in accordance with S&L Standard STD-EF-103. Although this requirement is reflected in the electrical contractor's procedure-(HEC Procedure No. 2, Paragraph 5.15), there is no provision on
electrical inspection checklists for QC verification that this.
activity has been performed.
The inspectors informed the licensee that this.is an unresolved item pending review of the revised procedure (454/80-25-01; 455/80-23-01).
b.
S&L Standard STD-EA-121 has a requirementifor cold weather'
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cable installation which requires, before cable pulling, the cable reel to' be stored at a specified' temperature and.for a specific length of time as recommended by the cabic manufacturer.
Although cables supplied by at least two cable manufacturers are used at the Byron site, this requirement has'only been addressed (HEC Procedure No. 10) as a minimum installation temperature for -
cables manufactured by the Okonite Company. HEC Procedure No.-1-0
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does not address the storage time or temperature necessary to l
increase cable reel temperatures to the cable pulling tempera-l ture, nor does it address requirements to document ambient or l
cable temperatures prior to cable pulling during cold weather conditions.
The inspectors informed the licensee that the absence of a
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l-procedure reflecting the manufacturer's requirements to pre-condition cables stored in extreme cold weather prior to cable pulling is an example of an item of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50 Appendix B
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-(454/80-25-02; 455/80-23-02).
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Item 3 of Appendix E to HEC Procedure No. 10: states, "The cable must be free of kinks, twists, gouges, scratches, or other items
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of apparent damage."
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Acceptance / rejection criteria had not been established for the above requirement.. Appendix E is used by the contractor _QC inspectors to perform surveillance of cable installation. The inspector' observed three instances of damaged cables, ICC005, ISI211, and IRD277 which had not been reported.
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The inspectors informed the licensee that the absence of accept-ance/ rejection criteria on inspection checklists is an example of an item of noncompliance, contrary to the requirements of Criterion X of 10 CFR 50 Appendix-B (454/80-25-03; 455/80-23-03).
d.
The inspectors. informed the licensee that the following deviations from commitments and IEEE Standard requirements were not promptly identified and corrected:
The commitments in Paragraph 8.3.1.4.1.1.b of the Byron FSAR and the requirements in Paragraph 5.1.1.3(2) of IEEE 384-1974 require the installed cables to be below the side rails of the cable tray.
The inspectors observed cables in cable trays 12015C-CIE, 11724A-C2B, 11728A-C2B, 11731A-C2B and 11544A-C2B above the side rails. Several of the identified cables were not safety related; however, their installation illustrates site construction practices which could adversely affect safety related construction activities.
The inspectors informed the licensee that the failure to promptly identify and correct deviations to specified commitments is an example of an item of noncompliance, contrary to the requirements of Criterion XVI of 10 CFR 50 Appendix B (454/80-25-04; 455/80-23-04).
4.
Observation of Electrical Work Activities The inspectors observed redundant Essential Control Power Class a.
IE cables, identified as ISI234 and ISI257, which had been installed in the Auxiliary building, and determined the following:
(1) The size and type cables pulled were as specified on the applicable S&L cable pull cards.
(2) The latest approved drawings and work procedures appear to have been used.
(3) Cable trays appeared to be grounded.
(4) Cable tray supports, support anchorages and tray support
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welds appeared to be as specified.
(5) Cable ISI257 was not routed as specified on the applicable cable pull card. Cable ISI257 was incorrectly routed
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through cable tray 11464Q-C2E instead of through specified-6-
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tray ~11469V-C2E. The inspectors reviewed the relevant inspection record dated October 9,1980, and determined that
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the record did not indicate the actual cable installation as required by Paragraph 402.22.a of S&L Specification F-2790 and Paragraph 3.3.of S&L Standard STD-EA-122. The. inspectors
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observed that' measures were not established by the licensee to identify and_ document instances of cable routing devia-tions from cable routing cards.
The absence.of measures to identify and. document. cable routing deviations is an example of an item of noncompliance, contrary to the requirements of Criterion XVI.of 10 CFR Appendix B (454/80-25-05).
b.
The inspectors observed the installation of a cable identified
- as.1W0117 between Motor Control _ Center (MCC), IAP22E-131X3-and Chiller Unit, 0W0010A-A and determined the following:
(1) The size and type of cable pulled was as specified on the cable pull sheet.
(2) The raceway was clean.
(3) Contractor QC inspections had been made to ascertain loca-tions where the cable might be subjected to abrasion or unusual strain. The NRC inspectors observed that workmen were stationed at sufficient intervals to guard _against damage to the cable as required by Paragraph 2.3 of S&L Standard STD-EA-122.
(4) Cable trays were identified as required by Paragraph 2.5 of S&L Standard STD-EA-122.
(5) The cable was being routed as designated in the' cable tabulation as required by Paragraph 3.3 of S&L Standard STD-EA-122.
(6) During installation the cable was not bent beyond the radial limitations recommended by the cable manufacturer as required by-Paragraph 3.11 of S&L Standard STD-EA-121.
(7) The length of the cable was short; as such it was laid
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without the benefit of special rigs.
c.
The inspectors observed that one end of a cable identified as
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ISIO42 at junction box IJB164A at elevation 385 in the Auxiliary Building was not sealed. This condition is contrary to the requirement in Paragraph 8A of S&L Standard STD-EA-121 which states, " Cable ends shall not be left unsealed. Ends of all
cables, paper and varnished cambric insulated cables in particular, shall be capped and sealed from the atmosphere as promptly as possible after being pulled into place."
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1he inspectors informed the licensee that the-failure to seal the cable end is an example of an item of eancompliance, contrary to the requirements of Criterion V of 10 CFR 50 Appendix B (454/80-25-06).
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d.
The inspectors observed that there were sharp edges in cable tray 12015C-CIE in the Upper Cable Spreading Room and.in. cable tray 1920F-C2E in the Auxiliary Diesel Generator Cable Tunnel Room.
Cables were installed in these trays.
This condition is contrary to the requirement in Paragraph 2.1 of S&L Standard STD-EA-122 which states in part, "Before pulling cables, the cable trays,... shall be thoroughly inspected and cleaned. Any materials, abrasions, sharp edges, or weld projections that might cause damage to cable-sheaths or jackets during pulling operations shall be removed."
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The above sharp edges in cable tray 12015C-CIE may have damaged
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cables ICC005 and ISI211. Small nicks were observed in the outer jackets of these cables. These cables were not identified as damaged prior to the NRC inspection.
The inspectors informed the licensee that the failure to perform an adequate inspection is an example of an. item of noncompliance, contrary to the requirements of Criterion X of 10 CFR 50 Appen-dix B (454/80-25-07).
e.
The inspectors abserved housekeeping inside cable trays.and in the Auxiliary Diesel Generator Cable Tunnel (ADGCT) hoom. The inspectors observed:
(1) Paper cartons, paper and other combustible material 'in the ADGCT Room. Subsequent to this observation, the licensee took action to remove the above items.
I (2) Two scaffold supports lying on cables inside cable tray 11455Q-C2E at elevation 432 in the Auxiliary Building.
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(3) Loose nails in cable tray 12030C CIE installed in the Upper Cable Spreading Room.
r (4) A ladder in cable tray 12103D-CIB installed in the Upper Cable Spreading Room.
(5) Pipe in cable tray 11706A-C2B installed in the Lower Cable
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Spreading Room.
(6) Chisel in cable trays 1702C-P2B and 1920E-P2E in the ADGCT.
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(7) Partially consumed weldrods in cable tray 11464Q-C2E at elevation 439 in the Auxiliary Building.
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b The inspectors informed the li:ensee that the above housekeeping conditions are an item of nonccepliance, contrary to the require-ments of Criterion XIII of 10 CFR 50 Appendix B (454/80-25-08).
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The inspectors observed that, in general, separation criteria
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were not observed at the exit points from which cables in cable trays located in the Lower Cable Spreading Room enter panels installed directly above in the Control Room. The inspectors observed that' contrary to the requirements of Paragraph 402.22.d of S&L Specification F-2790 and Paragraph,4.6.1 of IEEE 384-1974, safety related cables and non-safety related cables were bundled together at these locations. The following are specific examples:
(1) Safety related control cable INR167-C2E from tray 11774J-C2E bundled with non-safety related control cables 1NR158-C2B, INR159-C2B, INR161-C2B from tray 11774A-C2B.
(2) Safety related control cables ISI195-C2E, ISI181-C2E, 1RH043-C2E,.1VP082-C2E, IVP038-C2E, IAF041-C2E from tray 11769J-C2E bundled with non-safety related control cables IAN025-C2B and 1AN022-C2B from tray 11769A-C2B.
(3) Safety related' control cables ICC055-C2E, ICS044-C2E, IAF041-C2E, IVP038-C2E, IVP033-C2E and ICC014-C2E from tray 11769J-C2E bundled with non-safety related instrumentation cables 1SI462-K2B, ICC121-K2B, ISX174-K2B and ICC123-K2B from tray 11769S-K2B.
(4) Safety related control' cable 1AP045-C2E in tray.11734J-C2E looped around non-safety related control cable 1AP108-C2B-where it exits tray 11734A-C2B.
(5) Safety related control cable ICC240-C2E from tray 11766J-C2E bundled with non-safety related instrumentation cables ISI463-K2B, 1SI450-K2B, ISI451-K2B and ISI444-K2B from tray 11766S-K2B.
(6) Safety related control cables 1RC201-C2E, IRC190-C2E, IRC157-C2E, IRC168-C2E, IRC054-C2E, IRC033-C2E and 1RD169-C2E from tray 11725J-C2E bundled with non-safety related control cables IAN069-C2B, 1AN067-C2B, 1AN017-C2B and 1AN068-C2B from tray 11725A-C2B.
This matter was discussed with representatives of the licensee and S&L; their position is that the cable jacket provides the
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separation distance. This matter was referred to NRR for resolution. After review, NRR concurred with the Region III position that the separation criteria of IEEE 384-1974 were not
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met.
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'The inspectors informed the licensee, subsequent to the inspection, that the bundling of the above non-safety related cables with safety related cables is an example of an item of noncompliance, contrary to the requirements of Criterion.III of 10 CFR 50 Appendix B (454/80-25-09; 455/80-23-05).
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The inspectors observed that conduit 1 C2E.at tray 11750J-C2E in the Lower Cable Spreading Room had no support between the tray and the conduit bend. This condition is contrary to the require-ments of Paragraph 7.1.4 of S&L Standard EB-146 which states, in part, " Conduit bends shall be supported on each side of the bend."
The inspectors informed the licensee that the lack of the conduit support due to failure to follow procedures is an example of an item of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50 Appendix B (454/80-25-10).
h.
The inspectors observed several cables in the Auxiliary Diesel Generator Cable Tunnel Room and in the Lower Cable Spreading Room which were partially pulled with the tree length of the cable coiled, tied together with rope, and' suspended from cable tray hanger supports. The cables had been temporarily coiled pending routing through conduits. The diameters of the inner turns of these cables were measured and were determined to be less than the minimum bending radii prescribed in Appendix D of HEC Procedure No. 10.
The cables observed were:
Auxiliary Diesel Generator Cable Tunnel Room IMS320-C2E; 2/C; 14 gauge; connecting Solenoid B on globe valve IMS101A to Control Board PM06J.
IMS335-C2E; 2/C; 14 gauge; connecting Solenoid B on globe valve IMS101D to Control Board PM06J.
IMS330-C2E; 2/C; 14 gauge; connecting Solenoid B on globe valve IMS101C to Control Board PM06J.
IMS325-C2E; 2/C; 14 gauge; connecting Solenoid B on globe valve IMS101B to Control Board PM06J.
Lower Cable Spreading Rooc
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IAP383-C2E coiled at riser 103 The inspectors informed the licensee that the above examples of failure to follow procedures constitute an example of an ite-
of noncompliance, contrary to the requirements of Criterion V of 10 CFR 50 Appendix B (454/80-25-11).
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5.
Review of Nonconformance Reports The inspectors reviewed approximately 75 Nonconformance Reports (NCRs)'
and had the following comments regarding the NCRs listed below:
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a.
NCR F-580 dated December.il,-1980, identifies several instances
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where the cable separation requirements specified in IEEE 384-1974 were tot being met relative to safety and non-sah 'y related-cables. Specifically, in the following safety relt.
3. equipment, the non-safety related and safety related cables were not separated:
1AP98E; 480 volt substation IAPOSE; 4160 volt Bus 141 1AP06E; 4160 volt Bus.142 2AP05E; 4160 volt Bus 241 2AP06E; 4160 volt Bus 242 The inspectors observed that " Hold" tags were not attached to the equipment as required by Paragraph 14.2.3 of CECO Topical Report No. CE-1-A to identify the nonconforming condition. The switchgear buses were energized and being operated.
b.
NCR F-562 dated October 14, 1980, identifies that ASME electrical penetrations were being installed by a non-ASME certificate holder (HEC) under S&L Specification F-2790.
Cause of nonconformance was the improper assignment of installing ASME Section III pressure boundary parts to HEC by S&L.
The inspectors observed that " Hold" tags were not attached to the penetrations as required by Paragraph 14.2.3 of CECO Topical Report No. CE-1-A to identify the nonconforming condition.
c.
NCR F-545 dated August 8, 1980, identifies that welds on
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structural members of the main control board do not meet the inspection requirements of American Welding Society Code D1.1.
The licensee authorized his independent inspection agency, Pittsburgh Testing Ltboratory (PTL), to inspect these welds.
Several unacceptable welds were identified.
The inspectors observed that " Hold" tags were not attached to the main control board panels as required by Paragraph 14.2.3 of CECO Topical Report No. CE-1-A.
The inspectors observed that selected portions of the main control board panels were engergized.
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d.
NCR F-539 dated July 22, 1980 identifies th :t the minimum bending radii were violated while pulling 1/C 350 MCM cables identified as IDC089 and IDC030. S&L Standard EA-122 specifies a minimum
i bending radius of 18 inches while a nine inch bending radius was
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used.
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Furthermore, the inspectors observed that the nonconforming status of these cables were not readily_ identif0:d with " Hold" tags as required by Paragraph 14.2.3 of CECO Topical Report No.
CE-1-A. -The inspectors observed that'the panels connected to these cables were energized.
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The inspectors informed the
' ensee that review of the above NCRs and observation of the component. they addrested indicated that CEcc failed-to identify nonconforming components as required by Paragraph 14.2.3 of CECO' Topical Report No. CE-1-A and that this was example of an item of noncompliance, contrary to the requirements of Criterion XV of 10 CFR 50 Appendix B (454/80-25-12).
e.
NCR F-529 cated July 9, 1980, identifies that welds on' cable pan bent plate stiffeners do not conform to Item 4.3.1 of S&L Standard STD-EB-701. Also that the length and spacing of the welds do not conform to the specification requirements. Cause of nonconformance was attributed to the fabrication shop not'following S&L Standard STD-EB-701. The only corrective action recommended was for S&L to analyze the minimum acceptable weld requirements. The inspectors observed that " Hold" tags were not applied to the cable trays with questionable welds. Further, it was determinei that comprehensive inspections were not performed to determine the extent of the proolem in terms of weld quality, and in the context of the scope
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of this open item, definitive corrective actions were not prompt.
The inspectors informed the licensee that failure to take adequate corrective action in a timely manner to resolve the nonconfor.ning situation identified in NCR F-529 and failure to apply " Hold" tags to the cable orays identified in NCR F-529 constitute examples of items of noncompliance, contrary to the requirements of Criterion XV and Criterion XVI of 10 CFR 50 Appendix B (454/80-25-13).
f.
NCR F-578 dated December 10, 1980, identifies that cable' entrance frames were designed without engineering approval, built without an approved QA program, purchased without QA approval, and have been installed on seismic Category I safety related equipment identifed as IPA 03J. Equipment IPA 03J was originally qualified to seismic Category I requirements without the above cable frame.
During this inspection, this matter was discussed in detail with the responsible site construction and quality assurance personnel.
As a result of these discussions, it appears that Byron site construction management personnel circumvented quality assurance
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requirements and directives involving the design, purchase, use, and installation of a nonconforming seismic Category 1 electrical coaponent. To this extent this item requires CECO management
examination to determine what comprehensive measures to preclude recurrence (if any) are necessary.
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'The above condition constitutes.an item of noncompliance, contrary
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to the requirements of Criterion II 20 CFR Part 50' Appendix B.
(454/80-25-14)
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6.
Review of QA Records h
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c The inspectors: reviewed the records relative to the 5 KV power cables procured from Okonite Cable Company per Sargent and Lundy Specifica-tion F-2851. The following'are a comparison of the requirements and
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their respective test reports which are' supposed to confirm that the requirements were met. _ (These test reports are reviewed and approved by S&L before they are sent to the site).
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Paragraph 110.11.a.A requires a Certified Material Test Report a.
which the licensee stated was not available.
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Paragraph 110.11.a.L requires material identification 'and marking.
There appears to be a discrepancy: The' Quality Assurance Trace-ability Schematic references the "QC Length Number as 65900B"'
whereas the certificate of conformance, the Inspection Sheet for.
Wire and' Cables, and the Physical Test Report indicates that the QC Length Number is 63900B.
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c.
Paragraph 110.12.a2 states, "The certification should be'suffi-cient to specifie 'y identify the purchased material or equipment, such as ' y the pu..tase order number, consultant's specification number, station number, unit number and equipment-tag (s) number."
Certificate of conformance (Okonite Company) dated February 1, 1979, states that the materials used in 1222 feet of three-
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conductor 1/0AWG (19 stranded) bare copper, strand shield 0.140 inches Okoguard, 0.050 inches Okolon printed color code, cabled, rubber fillers, taped 0.110 inches Okolon, SKV was tested during
manufacture and the materials met or exceeded the applicabl~e.
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requirements. The COC did not state the station number or the-unit number as required in'the above paragraph.
d.
Paragraph 114 requires the following:
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The tests required for the cable shall include but not necessarily be limited to the following:
Spark test of Insulation after vulcanizing.
r Hi-Voltage AC test.
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Insulation resistance test.
- Hi-Voltage DC test.
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DC Conductor resistance test.
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Jacket and Insulation thickness.
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Tests reportsifrom Okonite indicate;that:
. Spark test of insulation after vulcanizing was performed.
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The cable successfully withstood 16KV AC for-five-minutes.
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Insulation resistance test was' performed.
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The cable.successfully withstood 40KV DC:for 15 minutes.
Test results of DC Conductor ~ resistance test.
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The. measured thickness of jacket and insulation.
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The inspector inforrad the licensee that, although the documentation; was reviewed, approved and sent to the site as. complete, the documen-tation was incomplete for the following-reasons:
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A Certified Material Testireport as required-in Paragraph
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110.11.a.A was not available.
The Quality Assurance Traceability Schematic references the QC Length Number as 65900B where as other documents in-this folder reference the'QC Length Number as 63900B.
The certificate-of conformanc'e from Okonite Company'did-not state the station number or the unit number as required in Paragraph 110.12.a2.
The inspector informed the licensee that this matter is'an' unresolved.
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item pending further review at a later date (454/80-25-15; 455/80-23-06).
7.
Review of Instrumentation Installation - Specifications and Procedures Units 1 and 2 The requirements for instrument insta11ationLis covered in,S&L'Specifi-cation F-2906. The cognizant installation contractor is Pope As;) Power i:
Company (PAP). S&L provides isometric drawings from which PAP develops detailed drawings, fabricates and installs instrumentation lines.
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The inspectors observed installed instrument lines and determined:
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a.
(1) The minimum separation criteria for redundant impulse'.
p sensing lines as specified in Paragraph 7.1.2 of the Byron PSAR was not being implemented through translation-into
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drawings, specifications and instructions.
The inspectors informed.the licensee that the: failure to-
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c translate the PSAR commitments into drawings, specifications,
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and instructions is an' item of noncompliance, contrary to the requirements of Criterion III of 10 CFR'50 Appendix B-(454/80-25-16).
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(2) Installed instrument sensing lines were not identified.as required by Paragraph 302.2b of S&L Specification F-2906 which states, in part, "After installation, all instrument sensing lines shall be identified with. color coded metal tags to denote system separation requirements."
Further,
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the installation procedures did not include this requirement nor were the contractor personne1' aware of this requirement.
The inspectors informed the licensee that the above instance of failure to follow procedures is an example of an item of noncompliance, contrary to the requirements of Criterion-V -
of 10 CFR 50 Appendix B (454/80-25-17).
b.
The requirements of S&L Specification F-2906 were' clarified in a meeting in Region III between the inspectors, representatives of the licensee (R. Tuetkin and R. Farr), and a representative of PAP (J. Mai) on January 9,1981, following completion of the onsite inspection activities. The issues considered were as follows:
(1) Lack of reference to IEEE 384 and IEEE 279.
Paragraph 108 of S&L Specification F-2906 does not specify compliance to IEEE 384 and IEEE 279. CECO is committed to-these standards in the FSAR. The licensee stated that an Engineering Change Notice -(ECN) will be issued to incorporate these standards.
(refer to Paragraph 7.a.(1)).
(2)
Implementation of separation criteria.
The licensee stated that the S&L Specification and the contractors current procedures will be revised to reflect the required separation criteria.
(refer to Paragraph 7.a.(1)).
(3) Design basis for missile protection and jet impingement.
The licensee stated that, subsequent to the NRC inspection, S&L is establishing the design basis for. instrument line routing taking into consideration jet impingement and missile protection separation criteria. This resolves the NRC concern.
(4) Class II over Class I installation.
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The licensee stated that the requirements of Paragraph 302.~.e of S&L Specification F-2906 are met by S&L factoring in the loading requirements for all hangers. Furthermore, the
licensee stated that he is now aware (subsequent to the NRC inspection) that the 18 inches separation' criteria will not allow the use of the same hanger for redundant lines. This resolves the NRC concern.
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(5) Timely inspections of installed lines.-
The-licensee stated.that the requirements of Paragraph 306.2.a!
of'S&L Specification F-2906 would be implemented by completing inspections prior' to submitting the completed Traveler. package to S&L for final approval. _This will resolve the NRC concern.
(6) Interpretation of Paragraph '401.4'.d.4 of S&L Specification F-2906.
The licensee stated that S&L is in-the process of defining
" hazards" and ~will' supply design documents informing the contractor of design. criteria. This will resolve the.NRC concern.
(7) Instrument line sloping requirements.
The-licensee stated that an ECN_has been' written _ changing the.
sensing line slope dimensions outlined in paragraph 401.5.c of S&L Specification F-2906. Single line piping will have no
slope requirements while dual line dimensions will be reduced.
This resolves the NRC concern.
(8) Requirements for Shut-off Valve Installation.
The licensee stated that the secondary shut-off valves have not been received on site so are not installed at this time.
This is an interim resolution of the NRC concern.
(9) Stainless Steel Pipe Clamps.
The licensee stated that the instrument sensing lines are considered static lines designed _ for an ambient temperature condition. Thus, the requirement of. Paragraph 403.2.d of S&L Specification F-2906 specifying the use of stainless steel pipe clamps on pipes for which temperature exceeds 500'F is not a requirement on these lines. The licensee i
stated that there are short periods of time during which'
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instrument sensing line temperature of 500*F is reached i
or exceeded. The inspectors have no further questions'at E
this time. This response resolves the NRC concern.
l-(10) Instrument Line Tagging Conflict.
The licensee stated that instrument lines would be identified
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j 2n accordance with specifications.
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(11) Acceptance / Rejection Criteria.
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The licensee stated that a review and clarification of acceptance / rejection criteria for weld sizes would be performed and furnished on inspection checklists. This l'
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v response is an interim resolution of.an NRC concern related to previously! identified item No. 454/80-04.
8.
~ Unresolved Items Unresolved items are matters about' which more information 'is required
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in order to ascertain whether they are acceptable items, items of noncompliance, or deviationss Unresolved' items disclosed during this inspection are discussed in Paragraphs 3.a and 6.
9.
Exit Interview
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The inspectors and representatives of Region III management met with licensee management representatives (denoted in Paragraph-1) on December 31, 1980, and January 9, 1981. The Region III staff sum-marized the purpose and findings of the inspection.- The licensee acknowledged-the findings reported therein.
An enforcement conference was held on March 27, 1981, with' licensee-
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management representatives (denoted in Paragraph 1) to discuss the specific items of noncompliance, the licensee's corrective actions and the enforcement options available to the NRC.
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