IR 05000455/1985027
| ML20202D664 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/10/1986 |
| From: | Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Forney W NRC |
| Shared Package | |
| ML20202D636 | List: |
| References | |
| NUDOCS 8607140189 | |
| Download: ML20202D664 (7) | |
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p2 EEcoq UNITEo STATES
.k NUCLEAR REGULATORY COMMISSION
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REGloN 111 5{
-f 799 ROOSEVELT ROAD
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,o'g GLEN ELLYN, ILLINOIS 60137 4,
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June 10, 1986 MEMORANDUM FOR:
W. L. Forney, Chief Reactor Projects Section IA FROM:
J. M. Hinds, Jr., Senior Resident Inspector Byron Station SUBJECT:
CONSTRUCTION APPRAISAL TEAM (CAT) INSPECTION (50-455/85-27)
FINDINGS RESOLUTION.
REFERENCES:
a) December 12, 1985 memorandum from C. E. Norelius to Cordell Reed.
b) January 24, 1986 memorandum from D. L. Farrar to James G. Keppler.
c) March 31, 1986 memorandum from J. G. Partlow to C. E. Norelius.
d) April 9, 1986 memorandum from K. A. Ainger to James G. Keppler.
e) May 12, 1986 memorandum from R. F. Warnick to Cordell Reed.
The CAT inspection violations were forwarded to the licensee in Reference a).
The licensee's initial response to the CAT inspection violations was forwarded to Region III NRC in Reference b).
The initial licensee response was sent on to Partlow's shop by R. Lerch via Region III correspondence. Partlow's comments were returned to Region III in Reference c).
The licensee provided supplemental information on Violation 2b and 2d in Reference d).
Region III sent the licensee a "Thank you Letter" in Reference e).
I have reviewed this matter and enclosed my analysis in Enclosures 1 and 2.
Please note the " Action Required / Status" column on Enclosure I which identifies actions completed or remaining.
Enclosure 2 provides the details on each violation and sub-set of the violation.
The following is a summary of the CAT inspection violations :
1) Closed by R. Love in IER 455/86014:.3a and 3c.
2) Additional CECO response required: Ic and 3b.
3) Resident Inspector Office Action in IER 455/86016 (Malloy): la, Ib and 2c.
4) Region Based Specialist Inspector Action required 2a, 2b and 2d.
Based on nature of the regional office effort specified in the Partlow letter (Reference c)) e.g. sampling and reviewing radiographs, reviewing engineering evaluations of undersized pressure boundary welds and evaluating sample size and hardness rests of ASTM A307 bolts in 4) above, you are requested to coordinate with the appropriate Division of Reactor Safety, Engineering Branch Supervisors to schedule regional based inspections in the appropriate
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8607140189 860708 PDR ADOCK 050004 5 Q
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disciplines to resolve these matters.
Subject to receipt of satisfactory licensee responses, additional regional based inspections will be required to resolve the items in 2) above.
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M. Hinds, Senior Resident Inspector Byron Station cc w/ encl:
R. F. Warnick R. M. Lerch J. A. Malloy R. S. Love
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ENCLOSURE 1
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SUMMARY
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I Agree Action Required / Disagree Violation No.
With Licensee Status With Licensee
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la - (Butt splices)
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RIO Convert to UR
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pending FSAR Amdt.
i Ib - (Structural steel bolted X
RIO Close in 86016
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connections)
CECO response X
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"*9" **d
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2 e (W radiographs)
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CECO & RBI action X
I (Tanks / heat exchangers)
X
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C (Vendor radiographs)
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RIO Close in 86016 RBI action d (Component fasteners)
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3a - (Electrical mounting X
Closed I.ove 455/86014
deficiencies)
Co Ponse X
3b - (Electrical separation)
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3c - (MOV wiring)
X Closed Love 455/86014
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Total
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- Not an example of a violation
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RBI = Region Based Inspector RIO = Resident Inspector Office
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As a rissit af the 17.spection conducted on August 19-30 and September 9-20,
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1905, and la accordancs vita the Geners) Policy and Procedures fir NRC
' Eiforcement Actions, (10 CFR P rt 2. Appendix C), the faIlowing v1111tions
- were identified (Section rsfirencss are to the deta116d portion of Inspection 455/85-27-01
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Report 50-455/85027):
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10 CFR $0, Appendix B, Criterion III as implemented by Commonuealth Edison Company (CEto) Quality Assurance Manual (QAM), Quality Requirement No. 3.0. requires that measures shall be estabitshed to assure that applicable regulatory requirements and design basis are correctly
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transisted into specifications, drawings, procedures, and instructions.
Contrcry to the above, at the time of this inspection, the licensee *s program was not adequately taplemented in that; Spitcing of Class IE wiring in panels hn occurred at Byron station a.
vlotAT10N la (455/85-27-01a)
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Withdrawn as Violation contrary to the F5AR cotmitments to IEEE Standard 420, which prohibits the use of wiring spilces in panels. FSAR commitments had. Based en the Itceneae's proposed F54R change dated February 6, 1985, we agr RIO convert to U/R not been translated into appropriate precedures and design doceents. that this item should be changed to an unresolved Ites pending issuance of the PendinS (section 11.B.2.b.(6))
FSAR w.
455/86016 (Mallov)
b.
Approximately one-third of the total cf A490 bolts tested by the NRC VIOLATION lb (Construction Premram Weekness 2)(455/85-27-Olb)
CECO corrective
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CAT were found to be telow the pretension required by AISC.
InstaHatton and laspection requirements had not been transisted Sesed G: th3 I h m W e corrective set % (ig S r investigettons and action satisfactorily into appropriate procedures for high strength belted connections in structural steel and nuctur steen agply system jotats which require tesus. evaluations), we feel that the Ifconsee has satisfacterfly resolved this reso1ved issue RIO The licensee's roepense to Construction Program tesekness 2 al*e pretension in the bolts.
(Section V.O.1.b)
setlefacterfly resolved this issue for Unit 1.
closed in 455/86016 During the inspection, concrete expansion anchors were found which VIOLATION Ic (455/85-27-01c)
GL My)
c.
did not meet the required bolt diameter embedeent depth. It could not be shown that embedeent length requirements for concrete expansionAs stated in the Inc CAT inspectlen nport, the CEA quellfication report and Enchors as specified in the concrete expansion anchor quellfication elle inspection prara% specify an embedded depth (La) to be measured from report had been translated into appropriate installation and the conce audace to the bottaa of the egensten ring.
inspection procedures. (Section V.8.2.b)
futeHed conditlen Le cannot be physicaH : m ured er derived indirectly.
Newever, in the Only if it is assumed that the expensten ting ea.elas stationary as the back E
455/85-27-01
- '9"*3 ** """ ***g to the ring, can the esseured (derived) embedded depth of the ancher moves c2 if8'd L*-
Thi* **** Pti*a 8' $8saif8ceat in that if the back of the ancher does not move all the way to the ring er the expension ring r*
Q also moves temords the concrete surface as the belt is tightened and the the einfaum enhedded depth, the actual te (eassured to the expeuten rin0)a c:
- c would be less then the minis m ambedded depth specified by the quellfication tu report.
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Tables 1 and 2 sumertae same instances in which it appears that anchor bolts
any not meet the embedded depth spectfled by the qualification report.
1 and Z reflect a (einus) 1/16 fach insta11atten talerance and physical Tables O
asseurements of empensten ancher belts ande by the SAC CAT.
The nexleen deviatten frem the specified embedded depth (including fasta11stien
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talerances) Is 11/16 fach.
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tse still ceneider that the ancher helt que11ficetten requirements have not CECO response required been adequately translated into appropriate Installetten and inspection (Ma11oy) call Klinger precedures.
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RBI = Region Based Inspectors RIO = Resident Inspectors Office
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Au tth JU. Append 1m 8, Crit 2rion Vll, Es implementid by C[CS QAM, Quality VIOLATION 2 (Westinehouse Radioerechs/ Construction Weakness 1)
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Requirements No. 7.0, rsquirss metsures shall be $stablished to assurs that purchestd eatsflal, equipment, and sirvicts confirm to the For the Unit 2 component cooling surge tank, the Ilconsee has not addressed procurement cocuments.
how the ASIE Code requirements are being met without the avi11 ability and existenc3 cf the redlegraphic fill As an alternative, the Itcensee may choose
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Contrary to the above, at the time of this inspection, the NRC CAT to reduce the joint efficiency from 105 to 7M which will then meet the ASME inspectors found several deficiencies in vendor s@ piled components. The Section III rules. The'use and acceptance of a lower joint efficiency would deficiencies included: radiographic film stored try the component have to be evaluated by the licensee er Westinghouse and should be reviewed by supplier in an of f site facility were not retrievable; undersized welds the regional office. The current response from the Ilconsee cannot be accepted, CECO response were identitled on tarks and heat enchangers; various vendor radiographs because the ASIE Code requirements have not been met.(02.a.1)
. required did not have complete weld coverage or did not show the required weld
quality; and fasteners for various components (large pop-motor For the vehama control tank radfegraphs, the regional office should review the RBI review VCT RTs i
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tssemblies, battery racks, switchgear, other electrical equipment, and film for retrievability and acceptability of the weld and fils quality. The for retrievability HVAC equipment) were not of the material required by speciflCations or IEC CAT inspectors un not e to review the redlegraphs during the drawings. (Sections IV.B.11 and VI.S.I.b(2))
inspection period. (
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aCCep g gy.i An additional sample of Westinghouse redlegraphs any"be selected by the regional RBI sample w RTs to
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office to verify the adequacy of the corrective actions by the Ceco QA Department. verify CECO QA action:
ilhu (Welds on Tanks and Hut Exchanners)
455/85-27-02 V
I RBI review diSPosi-The licensee has not clearly established the defin tion of " dest signift-cance," which will be the basis for deciding whether additional spections tion of Hunter NR-i
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will be perfomed. The real questien te be resolved is whether (with the 1148 to assure engi-
undersized welds thus far identifled) the components attil meet ASIE Code requirements. The evaluation of the undersized pressure boundary welds must neering evals, made accomt fer, among other things, the design strusu and the A5fE Code minimum
& code regmts met.
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weld size based on meterial thicknesses. The disposition of Hunter Corporation p
ci IIR-1144 should be reviewed by the regional office when completed to assure that proper engineering evaluations are made and ASIE Code requirements are met. (2.b:
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vlotATIon2(vendermedicaraphg Withdrawn as viola-
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tion concerns satis-With regard to vendor radi aph deficiencies, based on the additional infor-M netton provided, the IIRC CA agrees with the licensee that these concerns have factorily resolved.
been satisfactorily resolved and are not examples of deficiencies.
(02.c)
R1n c i ne in 455/8601 VIOLATfbn 2 (Cameenent Fasteners)
(Malloy)
io Corrective actions and analysn have not been completed yet for bolts on pumps CECO response of
m 2ano1PA, 2nnolpe, and 2Cvoirs. The regionai office utii need to keep track of
- p this ites to assure complete resolution of the receining issues with these three 4/9/86 states engi-
t ptmps. For ASTM A307 belts on electrical and HVAC equipment, the region should neering analysis review the sampling plan fer the testing of unmerked bolts to detemine thether the sanele was _representa11vg of the equipment at the site. In-edMtTin,the on pumps is Complete
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recten should evaluate the hardness test results to verify that the unmarked
& bolts are accept-
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bolts are equivalent to ASTM A307 belts. The actions to prevent recurrence able. RBI determine are satisfactory. (02.d. )
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if sample of A307 bolts representative
& evaluate hardness tests to verify I
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equivalency.
RBI = Region Based Inspector RIO = Resident Inspector Office
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10 CFR 50. Appendia 8. Critsrion X. Es implemented by CECe QAM Quality
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Requirement 10.0. requirss that e program far inspection af activitiss shall be established and executed te verify confirmance with documented listructions. procedurss, and <rawings far accomplishing the tctivitits.
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Contrary to the above, at the time of this inspection, the licensee's
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IIspection programs were not effectively implemented in that Unit 2 4160V switchgear and CC fuse panels were found not to be VIOLAfl0N 3a (Constructica Proeram Weakness 3)
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installed in accordance with requirements for selseic mounting of Class it equipment. (Section ll.8.3.b(4) and (6))
The Itcensee's actions appear to correct the specific deficiencies with tte 4160V suttchgear and DC fuse panels. However, it appears that the licensee's corrective actions had not ackasuledged the generic tapitcations of this hAC CAT finding.
The licensee stated that as a result of a stop work order issued in December 1900, that installation and inspection practices more enhanced and became more prescriptive and rigorous. The switchgear,and DC fuse panels R. Love closed som testa 11ed prior to the Decador 1900 stop mort order. It would sue l
prudent for the Itcensee to perform a reinspection of electrical equipment 455/86014 April 24> 1986 mounted by solding installed before Secumber 1980. This action is further receamended dee to the fact that statlar deficiencies were previously identiftet by the licensee on Unit I equipment. The corrective action for the Unit I agulpment uns a reinspection program.
b.
Some Class IE electrical raceways have not been installed in VIOLATION 3b
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accordance with FSAR coenitments for electrical separation.
a (Section II.8.1.b.(1))
The Supplemental Safety Evaluetten Report (55ER) transmitted to the Itcensee
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in a esserendem from V. 5. Noonan. NRR dated February 25. 1986 the IEtC staff's evaluation of Tyren/Bretheed electrical separetton criteria. In seminary the i
staff's conclustens were:
455/85-27-03 (1) setmeen seeny-nined and nonsafety-related raceway the separattan distances of 12" vertical and 3* hortaental is adequate, and
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(2) Setmeen safety-related cables in free-air and nonsafety-related
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raceumy and for the case of nonsafety-related cable in free-air and
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safety-related recomey, contact is acceptable.
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i :o The NRC approved criteria should be the basis of the licensee's QC inspection tn criteria. Neuever, the licensee maintains that the only racemey separation
- y criteria necessary is 1* between racemey. The ifcensee's QC criteria remains In confilet with current FSAR and SSER statements. Installations which do not
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meet the separation criteria as defsned in the SSER require identification and CECO response required evaluetten by the licensee.
(Contact Elias)
'm We maintain that the Ifconsee had not estabitsbed and still does not have p
laspection procedores which verify conformance to the FSAR/SSER criteria for electrical recomey separation. We recommend this violation be maintained, t
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Some Cicss IE setir opercted vilve tcrainations were not accomplished VIOLATICII 3c (Construction Program ideakness 3)
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fa actsrdance uith design documents in that string configurctions
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die not match thos3 specified on apprsved ufring diagrams.
lie agre.e that functlenelly the valres would have operated ts litended la the
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(Section II.8.3.b(8))
ts-found utring' condition.
e The licensee's actions to revise affected ufrin
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diagrams and conduct trefning sessions for inspection personnel were appro g priate. Ide note that the licensee metatains that the * speed memo" is not considered a desip document in that using the " speed asmo" would not result in R. Love cyose3 a valve being ufred and not conforming to approved utring diagrams. However.
455/86014 ue also note that inspection personnel relied on the " speed osmo" in order to accept the ufring configuration. Therefore, it appears that the " speed sumo" April 24, 1986 455/85-27-03 8"*"l d ** * **"' "
properly cons 1dered.'d **d 88'P'd d** ** '55"re that dessen aspects are
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