ML19338C311

Responds to NRC 800618 Ltr Re Violations Noted in IE Insp Repts 50-454/80-09 & 50-455/80-08.Corrective Actions:Carbon Steel Tube Sections Substituted for Galvanized Unistrut Members.Struts Will Be Coated

ML19338C311
Person / Time
Site:	Byron
Issue date:	07/18/1980
From:	Peoples D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19338C310	List: ML19338C311
References
NUDOCS 8008140377
Download: ML19338C311 (5)

Text

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. / /3C Commonwealth Edison one First Naisonal Plaza. Chicago, Ilknois (g ).

Oj j-Address R; ply 13: P:st Offica Box 767 Chicago, Illinois 60690 L W C N (j h ,

e July 18, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 Response to IE Inspection Report 50-454/80-09 and 50-455/80-08 NRC Docket Nos. 50-454 and 50-455 Reference (a): G. Fiorelli letter to C. Reed dated June 18, 1980

Dear Mr. Keppler:

Reference (a) contained the results of an inspection conducted by Mr. K. R. Naidu of your of fice on May 20-21, 1980, of activities at the Byron Nuclear Power Station, Units 1 and 2. -

During this inspection certain activities appeared to be in noncompliance with NRC requirements. Commonwealth Edison Company j responds to this item of noncompliance in the Attachment to this l

letter.

Please address any additional questions that you might have concerning this matter to this office.

Very truly yours, hk

. t D. L. Pe les l Director of Nuclear Licensing DLP:WFN: rap Attachment

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l ,8008140377 l 5154A_ , _ _ _ _

Attachment Response to Notice of Violation The item of apparent noncompliance identified in Appendix A of the NRC letter dated June 18, 1980, is responded to in the following paragraphs.

10 CFR 50, Appendix B, Criterion III, states, in part, that

" Measures shall be established to assure that applicable . . .

design basis . . . for those struct' ares, systems, and components

. . . are correctly translated into specifications, drawings, procedures, and instructions."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Paragraph 3.1 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures." The design documents include, but are not limited to, design and construction specifications, equipment specifications, and process drawings. Review of and evaluation by the Architect Engineer will assure that designs and materials will conform to the ASME Code and other applicable codes, standards, regulatory requirements, SAR commitments, and appropriate quality S' andards as applicable. .

Contrary to the above, it was determined that CECO did not ensure that Sargent and Lundy adequately translated the requirements in paragraphs 6.2.1.6 and 3.2.8.6.1 of the Byron PSAR and the requirements in Table 302.4 of S&L Specification 2831 into S&L Specification No. 2815 for electrical cable tray hanger supports in that corrosion protection was not specified for the exposed carbon steel material and exposed spot welds used in the installation of seismic Category 1 electrical cable tray hangar supports.

Corrective Action Taken And Results Achieved The NRC inspector referenced the requirements in paragraph 6.2.1.6 and 3.8.2.6.1 of the Byron PSAR and stated that they were inadequately translated into Specification F/L-2815 and that this was an item of noncompliance. Section 6.2.1.6 of the PSAR describes the coating systems that will be used in the containment and Section 3.8.2.6.1 refers to the AISC Manual of Steel Construction as one of the codes of practice used to establish standards of construction procedure. In this context, the noncompliance deals with the surface preparation and painting that is required on steel surfaces covered by fabrication Specification F/L-2815.

Specification F/L-2815 deals with electrical equipment hangers, fabrication and erection. Standard EB-ll5.0 B/B is part of this specification. The following requirements are noted in this standard.

a i

A. In Section 2.8.1 of this standard, it is stated that all components of hangers made from UNISTRUT members shall have a mil-galvanized finish. Therefore, coating requirements were not required for components addressed in this section.

B. In Section 2.8.2 of the EB Standard, the use of nongalvanized structural steel memberr or plates when the thickness is greater than 1/8" was allowed. In this context, the manufacturer of the hangers used carbon steel material for connecting UNISTRUT members. These are basically channel sections made of carbon steel. Although the " Field Finish Coating Work" Specification F/L-2831 would address these components, it is acknowledged that certain installed carbon steel connectors were not coated.

Sargent & Lundy has reviewed the corrosion rate anticipated using the 9th Edition of American Society for Metals ( ASM)

Handbook, Volume 1, " Properties and Selection: Iron and Steels,"

and determined that the corrosion in mi); for a 40-year life in a rural environment(Attached would beis8.5 mils and a copy for an of page 723industrial of the area would be 12 mils.

referenced document.) Since the containment environment is less corrosive than a rural environment, and since we have allowed in the design for the possible loss of thickness in the end plate connection members, we do not require that these end plaptf connections be painted. Sargent & Lundy will issue an Engineering Change Notice (ECN) to Specification F/L-2815 to eliminate the need for coating these connectors. .

In some other instances, a substitution was requested for The tube the use of tube sections instead of UNISTRUT members.

sections are carbon steel material. The request for this substitution came from the manufacturer and in some instances from Commonwealth Edison Company.- Also, auxiliary steel members have been installed without a shop primer coat. Specification F/L-2831 Table 302.4, requires that these carbon steel sections be painted.

Schedule 1, for the containment. structure on page 3-4, under all other miscellaneous steel, requires that bare metal (metal without a shop primer coat) have a surface preparation SL-SP1 and a coating system SL-CS2. As long as this work is done prior to fuel loading, this item, in our opinion, will not be in noncompliance. For the Auxiliary Building, on pages 3-6 of Specification F/L-2831, under Structural Equipment Supports, Pipe Supports, etc., it is required for steel without a shop primer coat that a surface preparation of SL-SP2 be performed and a coating meeting SL-CS4 be applied. If this work is done prior to fuel loading, this item, in our opinion, will not be in noncompliance.

In addition, the carbon steel tube sections substituted for galvanized UNISTRUT have been assessed. It is our intention to coat these struts in accordance with the requirements of Specification F/L-2831 prior to fuel loading, or on a component specific basis, perform a technical evaluation to confirm that sufficient corrosion allowance exists to preclude the need for field coating. Therefore,

all such struts will either be coated, or documentation will be provided justifying not coating specific struts or classes of struts.

C. In Section 2.8.6 of the EB Standard, it is required that "after fabrication . . . surfaces shall be repaired with a zinc-rich paint. . ." Section 4.1 of the EB Standard requires that field welds over galvanized surfaces be touched up with a suitable galvanizing repair product. Since repair spot welds of this type have been made by the supplier, it will be necessary to either coat the subject repair welds or demonstrate that the installed product is acceptable. UNISTRUT has been requested to provide an engineering assessment of the adequacy of the repair welds by October 15, 1980.

Corrective Action Taken To Avoid Further Noncompliance As was indicated above, Specification F/L-2831, " Field Finish Coating Work", would, in fact, address the coating requirements applicable to the discrepant components discussed.

However, in order to assure proper adherence to these coating requirements for the compoaents addressed in Specification F/L-2815, Sargent & Lundy has issued a clarification letter to the Commonwealth Edison Company Station Nuclear Engineering Department and to the Byron Site Construction Superintendent which clearly identifies the operative sections of Specification F/L-2815 and the applicable coating requirements in Specification F/L-2831. In addition, as described above, an ECN will be issued to eliminate the need for coating non-galvanized UNISTRUT connectors.

Date of Full Compliance Inasmuch as the " Field Finish Coating Work" Specification F/L-2831 requires coating be completed prior to completion of field work, the discrepant components addressed in this noncompliance and other similar areas will be identified and coating completed prior to fuel loading on the unit involved. This includes all carbon steel tube struts for which technical justification is not provided to eliminate field coating. In addition, all repair spot welds on UNISTRUT hangers will be identified and coated prior to fuel loading, unless the technical adequacy of the installed product is demonstrated. A technical assessment has been requested of the supplier which will be available by October 15, 1980.

5154A

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tallic Corrosion, Vol 4, .%:cw, Copper. w al i 1969, p 554 beanns steel (.3 he, carbon eteel auf. um mn. 3. B.Sanyal,G.K.Singhania and J.N.

f yr urs cuta um Nanda, Corrosion of Mc:a*.5 in :he 1m tso 5.6 115' 4.5 63 2.5 Tropics, Proceedings ofthe e n, ar: / ..

Kure Beach, NCM 7.5 142 530 21 450 17.6 245 9.7 ternational Congress on .'fe::::ic Panama Canal Zone 8 Corrosion, Vol.4, 3!ascow,19C3, p c

po.itions. !d.cuch not eue, remmble one another. m 245 m (soo tu tro*

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4. A. Gallicio, Galvanic Test Me:h:is, llandbook on Corrosion Testv g : .d Etatuation,W. Aitor(Ed.),Jche Wi.

illa C Corros1ons of struttural stools in various .

ley, New York,1971, p 143 Cnvironments (:lol 9) 5. D. P. Doyle and H. Godard. A P.s;!d Aversge reduction in thickae. , cure cas struoural strunur 1 M.ethod for Determining the C:- o.

copper I.*NS INS INS l'NS sivity of the Atmosphere at Arc.* 14 he, carbon Type of atmosphere yr steel steel K11510@ Kil430tel Kit &32fdl K115:8(e) cation, N:ture, Vol 200 (No. 4512j, 1.3 1.3 1.4 2.2 21 Dec 1963, p 1167 3.5 3.3 2.6 Industrial 1.5 2.1 1.7

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15.5 7.3 1.4 1.0 1.3 1.0 1.5 mospheric Exposure Tes:s. .'.fe::: x Semi. industrial 1.5 1.8 3.5 2.9 2.2 1.3 1.9 1,5 2.4 Corrosion-First Internc:is .a Cov (South Bend, pas 1.9 gress on Corrosion, But:arwo-;Ys, 4.6 3.2 1.8 2.7 7.5 lendon,1962, p 254 4.8 2.2 " 2.5 15.5 7.0 8. S. K. Coburn et of, Corresiveness of 2.5 "* 1.3 0.8 1.2 Various Atmospheric Tcs: Sites as Rural 1.4 1.2 1.8 (Potter County, PA) 3.5 2.0 1.7 1.1 Measured by Specimens off:ee;and 2.5 1.3 1.5 1.5 Iron, Metcl Corrosion in tk A: r.o.

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