ML20040F301
| ML20040F301 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/08/1982 |
| From: | Lentine F COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20040F275 | List: |
| References | |
| NUDOCS 8202090057 | |
| Download: ML20040F301 (3) | |
Text
. % Comm:nwesith Edison QF Om First National Piara. Chicrgo, mentis Addr:ss Riply 12 Post Offico Box 767 Chicago Illinois 60690 Janua ry 8, 1982 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III
\\
U.S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Zion Station Units 1 and 2 Response to I.E.
Inspection Report Nos. 50-295/81-23 and 50-304/81-19 NRC Docket Nos. 50-295-and 50-304 Reference (a):
December 9, 1981, letter from R.
L. Spessard to Cordell Reed.
Dear Mr. Keppler:
Reference (a) contained the results of an inspection conducted by Messrs. J. E. Kohle r and J. R. Waters on August 1 through October 30, 1981, of activities at Zion Station.
During that inspection, certain activities appeared to be in noncompliance with NRC requirements.
Attachment A to this letter contains Common-wealth c: son's response to the Notice of Violation.
Reference (a) also requested an assessment of the e frect of using an uncalibrated torque wrench multiplier on work performed under I.E.Bulletin 79-02.
Our assessment is provided as follows.
At Zion Station, all expansion anchored base plates have the following minimum f actors of safety:
For wedge anchors - F.S.
)>
4 Fo r self-drilling - F. S. jp_ 5 These factors of safety are calculated for the SSE load condition (See D. L.
Peoples letter to J.
G. Keppler dated Feoruary 29, 1980).
These extremely conservative factors of safety are uti-lized to account for the inaccuracies of construction / installation.
Discussions with Station and contract personnel have revealed that multipliers were generally utilized on base plate assemblies that used one inch diameter expansion anchors.
One inch diameter expansion anchors account for approximately 1% of all expansion anchored base plates at Zion Station.
One case plate in this group has a f actor of safety 4.0.
The lowest f actor of safety for the remainder of this group is 4.4.
In addition, furtner discussions 4
with the contractor's quality co ; trol personnel revealed that upon making a quality control inspection on an expansion anchored base plate, multipliers were not used by the quality control department.
8202090057 820203 jag 11 M PDR ADDCK 05000295 O
p J. G. Keppler Janua ry 8, 1982 i
Furthermore, Commonwealth Edison has demonstrated through its expansion anchor test program that preload, or loss of preload (i.e. a specified torque level) is not required in an expansion anchor to withstand cyclic loadings (See E. D.
Swartz letter and report to J. G. v ppler dated August 26, 1981).
e Given the above, Commonwealth Edison has concluded that there are more than adequate conservatisms in the design and beha-vior of concrete expansion anchors to account for any misapplied torque values on a minimum number of expansion anchored base plates.
'To the best of my knowledge and belief the statements contained in this letter and attachment are true and correct.
In some respects these statements are not based on my personal know-ledge but upon information furnished by other Commonwealth Edison employees and contractors.
Sucn information has been reviewed in accordance with Company practice and I oelieve it to be reliable.
Please address any questions concerning this matter to this office.
Very truly yours, Yk F.
G. Lentine Nuclear Licensing Administrator cc:
Zion Resident Inspector 1m SUBSCRIBED AND SWORN to before me this f day of %2atA.u-1982.
f V
h k.
Notary Public 3174N
)
ATTACHMENT A l
Response-to Notice o f Violation j
Violation A
L I
~ 10 CFR 50, Appendix B, Criterion XII requires that measures be established to assure that tools and other measuring and testing h.
devices used in activities affecting quality are properly L
controlled, calibrated and adjusted at specified periods to L
maintain accuracy witnin necessary limits.
M i
Contrury to the above, there was no procedure for calibration of torque wrench multipliers used on-site nor was there evidence available to show that the torque wrench multipliers had been properly calibrated against recognized standards.
Corrective Action Taken and Results Achieved During the time period from May 1981 to the present, an investigation was conducted to determine the average percentile error on dif ferent torque wrench multipliers.
Based on this program and additional inputs, a program for multiplier calibrations is being developed.
In addition to the development of this program, a hydraulic torque wrench was purchased and put into service.
The hydraulic norque wrench does not utilize a multiplier.
This hydraulic torque wrench was used on the majority of safety ~related work during this time period.
Corrective-Action To Be Taken to Avoid Further Non-Compliance A torque wrench multiplier certification program is being developed.
This progrm will become part of the Maintenance Department Administrative Instructions.
Date When Full Compliance Will Be Met Implementation of the torque wrench multiplier certification l
program is dependent upon the delivery of the Electronic Torque System (ETS).
The ETS will be used for calibration checks of 2
torque wrench multipliers.
Full compliance will be achieved by April 1, 1982.
3174N
.