IR 05000454/1981009
| ML20010E500 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/10/1981 |
| From: | Danielson D, Clay Johnson, Keating D, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010E493 | List: |
| References | |
| 50-454-81-09, 50-454-81-9, 50-455-81-08, 50-455-81-8, NUDOCS 8109040189 | |
| Download: ML20010E500 (6) | |
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U.S. NUCLEAR REGULATCRY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report Nos. 50-454/81-09; 50-455/81-08 Docket Nos. 50-454; 50-455 License Nos. CPPR-130; CPPR-13 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: July 29-31, 1981 7!'f/
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Inspectors:
I T. Yin
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0. E. Keating
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<Vl7 l2'l J
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t C. E. Johnson, RIV
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Accompanying Personnel:
D. H. Danielson (July 31, 1981 only)
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Approved By:
D. H. Danielson, Chief
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Materials and Processes Section Inspection Sun nan Inspection on July 29 - 31, 1981 (Report Nos. 50-45':/81-09; 50-455/81-08)
Areas Inspected:
Followup on previously identified inspection findings.
Inspection of installed piping suspension system components and review of installation and inspection records. The inspection involved a total of 48 inspector-hours on site by three NFC inspectors.
Results: Of the areas inspected, two apparent violations were identified.
(Failure to follow QC inspection procedures - Paragraph 2.a; Design modifi-cations were not receiving review and approval commensurate with the original design - Paragraph 2.b.)
8109040169 810824 PDR ADOCK 05000454 g
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DETAILS Persons Contacted
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Commonwealth Edison Company (CECO)
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I. Schlosser, Project Manager G. Sorensen, Construction Superintendent
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Tuetken, Assistant Construction Superintendent
- M. A. Stanish, QA Superintendent
- H. J. Kaczmarek, QA Engineer
- T. J. Poulos, Field Engineer R. B. Klingler, QA Supervisor Hunter Corporation (Hunter)
- M. L. Somsag, QA Supervisor A. T. Simon, QA Administration Supervisor Westinghouse Nuclear Energy Systems (W)
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- D. R. Graser, Manager, PDQII R. H. Walters, Hanger Engineer
- Deno*.es those attending the management exit meeting on July 31, 1981.
Licensee Action on Previously Identified Items (Closed) Noncompliance (454/80-05-01; 455/80-05-01):
Inadequate piping suspension system installation procedures.
The inspector reviewed the following Hunter procedures and considered the matter closed:
Site Implementation Procedure, SIP No. 2.201, " Design Control",
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Revision 6, dated April 14, 1981.
SIP No. 4.201, " Installation Verification", Revision 2, dated
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February 3, 1981.
i Site Work Instruction, SWI No. 2, " Installation of Hanger Specialty
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Items", Revision 2, dated April 7, 1981.
(0 pen) Noncompliance (454/80-05-02; 455/80-05-02):
Inadequate piping suspension system QC inspection program. The inspector reviewed the i
installation procedures and considered them to be acceptable. The same
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procedures used to perform QC inspection needed further review to assess applicability and adequacy.
(Closed) Noncompliance (454/80-05-03; 455/80-05-03): lise of inter-office memorandum in lieu of approved procedures. The insper: tor revicaed CECO audit of Hunter, No. 6-81-308.
The Hunter audit finding response, HC-QA-175,
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J stated that all SIP supplements, i.e., SIP 11.201, Revisica 3, SIP 20.5,
Revision 9; and SIP No. 20.513, Revision 6, were voided. The CECO surveil-lance No. 2870 substantiated the response. This item is closed.
(Closed) Noncompliance (454/80-05-05; 455/80-05-05): Mechanical snubbers that were damaged during installation. Based on licensee actions taken as of March 26, 19eJ, all installed snubbers were removed for exemination.
Among which, 61 were determined to be damaged and required repair or replacement. The repaired snubbers will be returned to their original functional condition, aad will be QC inspected and tested prior to rein-stallation.
(Closed) Noncompliance (454/80-05-06; 455/80-05-06): Lack of licensee audits of piping suspension program.
The inspector reviewed the follow-ing audit reports pertaining to piping suspension system design and installation:
a.
Ceco audit of Hunter Audit Report No. 6-80-244, dated April 9, 1980. The audit was performed at Byron site on March 19.,- April 3, 1980 to evaluate the effectiveness of Hunter Corporation fabrication.
and installation of small bore piping.
b.
Ceco audit of Hunter, Audit Report No. 6-80-258, dated June 11, 1980. The audit was performed at Byron site on May 21 - June 11, 1980. Audit areas included design control of large and small bore piping and hangers and large bore piping installation.
c.
CECO audit of Hunter, Audit Report No. 6-80-267, dated July 23, 1980. The audit was performed at Byron site on June 15-18, 21, and 23, 1980.
Parts of the audit included review of site QC inspections for hanger installations.
d.
CECO audic of Hunter, Audit Report No. 20-80-38, dated September 16, 1980. The audit was conducted at Byron site on September 8 - 10, 1980 to evaluate design control and design change control of piping systems.
e.
CECO audit of Hunter, Audit Report No. 6-81-330, dated July 17, 1981. The audit was performed on July 14-16, 1981.
In the area of pipe supports, three out of ten support assemblies previously inspected by Hunter were found to have deficiencies.
The audits performed appeared to be adequate. This item is considered to be closed.
Functional or Program Areas Inspected 1.
Change of A-Es for Design of Piping and Pipe Suspension Systems The original S&L responsibility for the subject activities has been i
divided as follows:
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a.
Since September, 1980, E was contracted by CECO to perform all large and small bore piping system design rsing computer calculations in Containment No. I and all piping systems within Auxiliary Building Area 5 except SX, CC, and FP systems. Extension of systems to the other areas up to the first anchor are also within the E work scope.
At present, there are approximately 40 technical personnel on site.
b.
Since March, 1981, Nuclear Power Services, Inc. (NPS) was contracted by S&L to perform 21/2" to 4" Class D, 200 F or above; 2" and below Class A, B, C, and D for Work Areas 1 through 4, and 6.
There are approximately 125 NPS personnel on site performing design using S&L design tables and charts.
c.
S&L maintained design responsibility for systems SX, CC, and FP in Auxiliary Building Area 5; 2 1/2" and above Classes A, B, and C; 2" and below associated with la ee subsystems; and 4" and above Class D with 200 F or above.
The inspector stated the FSAR should be changed to reflect the above design responsibility change. The NPS and y programs will be reviewed by the inspector during future inspections.
2.
Inspection of Snubber Installations The following snublet assemblies were observed by the inspector in the Unit 1 Containment. The mechanical snubber units are not installed, however, surrogates are installed at the intended locations in accord-ance with Hunter Procedure SWI, No. 2, Revision 2, dated April 7, 1981.
Hanger Drawing No. 1CV24031X, Revision 2 The snubber structural work was initiated on April 24, 1981, and com-pleted on May 21, 1981.
Inspection of NF weld was performed on June 30, 1981, however, no QC inspection was performed on the installed structural attachment assembly.
Component Support /CEA Discrepancy Report CTB 1390 requesting design change on the structural attachment assembly was gener-ated on May 29, 1981 subsequent to field design modification. CECO Field Change Request FCR-9561 issued on May 30, 1981 determined that the modi-fication was a major design change. Telephone approval from E engineering for the design change was obtained on May 30, 1981.
Hanger Drawing No. 1CV02003S, Revision 6 The snubber installation was initiated on February 10, 1981 and completed on February 12, 1981.
Inspection of structural welds was performed on May 30, 1981; however, no QC inspection was performed on the installed structural attachment assembly. Descrepancy Report CTB 1235 requesting design change on the structural attachment assembly was generated on April 4, 1981 subsequent to field design modification. FCR-4935 issued on April 6, 1981 determined that the modification was a major design l
change. Telephone approval from y engineering for the design change was obtained on April 6, 1981. The FCR was not included in the field work package.
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Hanger Drawing No. ICV 24024S, Revision 2 The snubber installation was initiated on March 18, 1981 and completed on March 19, 1981.
Inspection of structural welds was completed on May 5,1981; however, no QC inspection was performed on the installed structural attachment assembly. Discrepancy Report CTB 1159 requesting design change on the.tructural attachment assembly was generated on March 19, 1981 subsequent to field design modification. FCR-4787 issued on March 20, 1981 determined that the modification was a major design change. Telephone verification was made with y engineering on March 20, 1980 without rtating status of resolution or approval.
Subsequent to the hardware observation and document review, the inspector determined:
a.
The lack of timely QC inspection of installed piping suspension system components was in noncompliance with Hunter QA Program Site Implementation Procedure, SIP 4.201, " Installation Verifi-cation", Revision 2, dated February 3,1981, Paragraph 4.0,
" Inspection Classification," and Paragraph 5.0, " Inspection Implementation." These paragraphs require that verification of the adequacy of the work be accomplished employing a combination of inspections classified as Type I through Type 5 inspections.
Due to the nature of the work and the scheduling considerations, all installations will not require each Type 1 through 5 inspection; however, all inspections must be performed in sequence at each stage upon work completion. The inspector determined that QC failed to conduct containment snubber installation inspections per Type 2 inspection requirements. A Type 2 inspection is designed to identify items where the work is not in accordance with the criteria specified for the joining of individual items in an overall assembly. Overall assemblies are defined on the Construction Copy Drawings (CCD). The hardware inspection of a Type 2 inspection is required to include a review of corresponding Process Sheets, Rework Requests, etc., to assure that as-built data is complete and correct to the point of the inspection.
This is an apparent violation identified in Appendix A.
(454/81-09-01).
The inspector reviewed approximately ten hanger installation traveler packages
,f auxiliary building areas and determined that the deficiencies were restricted to snubber installations within the Unit 1 containment building.
b.
Field construction performing design modification prior to FCR review and approval is in noncompliance with CECO QA Manual Quality Procedure QP No. 3-2, " Design Change Control", Revision 8, dated December 29, 1980 including Attachment A, " Instructions for Processing FCRs".
This procedure requires that design evaluations of modification will be commensurate with those applied to the original design. It further requires that evidence of design evaluation and that review and use of alternative calculational methods to assure verification or-5-
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checking design adequacy, will be documented. Attachment A, Paragraph 5.5 states that, "For major field change requests which require immediate action, the Site Construction Superin-tendent, Station Construction Project Engineer, or Maintenance Assistant Superintendent or their designees, shall obtain verbal concurrences from the resonsible Project Engineering or Station Nuclear Engineering Department Project Engineer or the AE as appropriate. After receiving the above approvals, the Site Construction Superintendent, Station Construction Project Engineer, Maintenance Assistant Superintendent, or their designees may authorize the changes to be made by the site contrector. The Site Construction Superintendent, Station Construction Project Engineer, Maintenance Assistant Super-intendent, or their designees, shall.immediately have an FCR processed documenting the change, the assigred FCR number used to identify the requested change with engineering and the verbal approval of the change." Attachment A, Paragraph 5.6 states that, "For major field change requests which require immediate action and are more complex in nature (not resolvable through telephone communication) the Site Construction Superin-tendent, Station Construction Project Engineer, Maintenance Assistant Superintendent, or their designees, shall have the proposed FCR telecopied to the responsible Project Engineering or Station Nuclear Engineering (SNED) Project Engineer or the AE Project Manager, as appropriate.
In these cases, only one field change shall be included under one FCR. Disposition of the FCR shall be telecopied to the Site Construction Superin-tendent, Station Construction Project Engineer, or Maintenance Assistant Superintendent, by Er.gineering or the AE as appropriate.
Also, necessary supporting information (sketches, instructions, etc.) necessary for implementation of the FCR shall be telecopied back to the Site Construction Superintendent, Station construction
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Project Engineer, or Maintenance Assistant Superintendent immedi-
ately upon resolution and approval of the FCR."
This is an apparent violation identified in Appendix A.
(454/81-09-02).
Exit Interview
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The inspectors met with licensee representatives at the concJusion of the inspection. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the findings reported herein.
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