ML19259B381
| ML19259B381 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/22/1979 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19259B379 | List: |
| References | |
| NUDOCS 7902090101 | |
| Download: ML19259B381 (5) | |
Text
Commonwealth Edison One First National Plata Chicago lihnois Address Reply to Post Office Box 767 Chicago. lilinois 60690 January 22, 1979 Mr. James G.
Keppler, Director Directorate of Inspection and Enforcement - Ragion III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Byron Station Units 1 and 2 Response to IE Inspection Report Nos. 50-454/78-09 and 50-455/78-09 NRC Docket Hos. 50-454 and 50-455 Reference (a) :
R.
F. Heishman letter to Byron Lee, Jr.
dated December 26, 1978
Dear Mr. Keppler:
Reference (a) transmitted an inspection report regarding an inspection conducted by Messrs. J. H. Neisler, E.
W. K. Lee and F.
C.
Hawkins of your office of activities at Byron Station.
That report identified an apparent item of noncompliance end two apparent deviations.
Our responses to the item of noncompliance and the deviations are contained in Attachmente 7. and B to this letter.
Please address any additional questions concerning this matter to this office.
Very truly yours,
(
Cordell Reed Assistant Vice-President attachments N
of,
.~
7902090 /6/
ATTACHMENT A NRC Docket Nos. 50-454/455 Infraction
(#78-09-03) 10 CFR 50 Appendix B, Criterion V, states, in part, that
" Activities affecting quality shall be prescribed by documented in-structions....and shall be accomplished in accordance with these instructions,...."
Commonwealth Edison Company Topical Report No. CE A, Revision 4, Sectiot 5, states, in part, that "The Quality Assurance actions carried out for design, construction.....will be described in documented instructions....
Those documents will assist personnel in assuring that important activities have been performed."
Hunter Corporation Site Implementing Procedure No. 3.801, Paragraph 6.4.C.4, states, that "Dessicant (if used) shall be inspected for continued effectiveness.
Westinghouse Electric Company Specification No. G-678853, Revision 2, Paragraph 7.2.4, states, in part, that "A desiccant shall be placed within the body of all carbon steel valves..."
~
Contrary to the above, on November 1, 1978, the inspector reviewed the Material Surveillance Criteria and Report dated August 10, 1978, for valves stored in all the four warehouses and established desiccants inside valves were not inspected for continued effectiveness.
Upon talking to the licensee and his contractor, it was the inspector s understanding that inspection of the desiccants inside valves has not been part of the normal surveillance program.
Corrective Action Taken and Results Achieved:
Valve manufacturers, Westinghouse, et al, package valve assemblies for outside storage or inside unheated storage.
To date all Westing-house supplied carbon steel valves, all Anderson Greenwood supplied carbon steel valves, all Anchor / Darling supplied carbon steel valves, and all Velan supplied carbon steel valves have been stored in beated warehouses.
Due to the utilization of a higher level of environmental storage, the necessity to perform inspections for lower levels of storage becomes superfluous.
Hunter Corporation Site Implementing Procedure No. 3.801 is being revised to clarify that inspection for desiccant effectiveness is required for valves stored outside or inside unheated enclosures and is not required for valves stored in heated warehouses.
I Attachmen A
NRC Docket Nos. 50-454/455 Page 2 Corrective Action Taken to Avoid Further Noncompliance All contractors have been advised to assure that procedures are followed when accomplishing surveillances and other safety related activities.
Date When Full Compliance Will Be Achieved 2/1/79
f ATTACHMENT B NRC Docket Nos. 50-434/455 Deviation (#78-09-04)
Byron /Braidwood PSAR, Table 3.2-2 committed to the requirements of Section III for the design and fabrication of piping.
ASME B&PV Code, ASME B&PV Code,Section III requires that welding be parformed in accordance with ASME B&PV Code,Section IX.
1974 Edition,Section III (including 1975 ASME, B&PV Code, (a)
Summer Addenda), Tables NC-2331-1 and ND-2331(a)-1 requires the Charpy V Notch (Cv) test specimens for material thickness over 1 " to 2 " inclusive to have a lateral expansion value of 40 mils.
above, on November :', 1978, the inspector Contrary to a.
established that the test coupon used in qualifying Hunter HC-KPS-5 Corporation Welding Procedure Specification (WPS) No.
was 2" thick and Calumet Associates Report No. C942-2 indicated that Cv test specimens No. 942-2B and No. 942-2C, taken from the heat affected zone has a lateral expansion value of 38 mils and 36 mils respectively.
(b)
ASME, B&PV Code, 1974 Edition,Section IX (including 1975 Summer Addenda) Paragraph QW-409.1, states, that "A change in the type of current or polarity, or an increase in the amperage or voltage" and Table QW-253 lists paragraph QW-409.1 as a Supplementary Essential Variable.
Contrary to b. above, on November 2, 1978, the inspector established that the voltage and amperage used in qualifying procedure WPS No. HC-WPS-5 exceeded the welding procedure range.
Corrective Action and Results Achieved:
(a)
Welding Procedure HC-WPS-5 has been revised to be used on To date work has not systems not requiring impact testing.
been performed on systems requiring impact testing.
(b)
The PQR is to be corrected to reflect the actual amperages and voltages used during qualification.
Since this procedure does not require notch toughness testing, the electrical characteristics are stated in ASME Section IX, Table QW-253 to be non-essential.
Thus, the electrical parameters in the Welding Procedure Specification do not have to be revised.
1 Attachment B NRC Docket Nos. 50-454/455 Corrective Action Taken to Avoid Further Non-Compliance:
(a)
All other welding procedures wnich are not to be used on material requiring impact testing, but had impact tests performed during qualifcation, were revised to indicate that the procedures were not to be used on material requiring impact testing.
Also, references to S&L Piping Design Tables for the Feed Water System and to Quality Group A, ASME Section III (which require impacts) were deleted.
A written inquiry has been made to ASME to clarify whether a procedure qualification test specimen must meet the mils lateral expansion required by Tables NC-2331-1 and ND-2331(a)-1 of ASME Section III for the thickness tested or the thickness to which the procedure is qualified.
(b)
The PQR will be corrected for the other welding procedures which used this test for qualification.
Date When Full Compliance Will Bo Achieved:
3/30/79