Text

Forwards Const Appraisal Team Insp Rept 50-455/85-27 on 850819-30 & 0909-20.Significant Areas of Concern Cited Re Westinghouse Inability to Retrieve Radiographic Film for Certain ASME Components.Potential Enforcement Actions Encl
	ML20136C723
Person / Time
Site:	Byron
Issue date:	11/13/1985
From:	Taylor J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Reed C; COMMONWEALTH EDISON CO.
Shared Package
ML20136C727	List: ML20136C723; ML20136C758;
References
	NUDOCS 8511210137
	Download: ML20136C723 (9)
	v • d • e

i

p:rg#0

~g UNITED STATES

~

[ g NUCLEAR REGULATORY COMMISSION

g j WASHINGTON, D. C. 20555

eee* November 13, 1985

Docket No. 50-455

Comonwealth Edison Company

ATTN: Mr. Cordell Reed

Vice President

P. O. Box 767

Chicago, IL 60690

Gentlemen:

SUBJECT: CONSTRUCTION APPRAISAL TEAM INSPECTION 50-455/85-27

Enclosed is the report of the Construction Appraisal Team (CAT) inspection

conducted by the Office of Inspection and Enforcement (IE) on August 19-30 and

September 9-20, 1985 at the Byron Unit 2 Station. The Construction Appraisal

Team was composed of members of IE, Region III, and a number of consultants.

The inspection covered construction activities authorized by NRC Construction

Permit CPPR-131.

This inspection is the thirteenth in a series of construction appraisal

inspections conducted by the Office of Inspection and Enforcement. The

results of these inspections are being used to evaluate the management control

of construction activities and the quality of construction at nuclear plants.

The enclosed report identifies the areas examined during the inaection.

Within these areas, the effort consisted primarily of detailu inspection of

selected hardware subsequent to quality control inspections, a review of

selected portions of your Quality Assurance Program, examination of procedures

and records, and observation of work activities.

Appendix A to this letter is an Executive Sumary of the results of this

inspection and of conclusions reached by this office. The NRC CAT noted no

pervasive breakdown in meeting construction requirements in the samples of

installed hardware inspected by the team or in the ifcensee's project construc-

tion controls for managing the Byron Unit 2 Station.

Deficiencies noted by the NRC CAT indicate that a number of construction-

program seaknesses exist which warrant additional management attention. The

more significant areas of concern to the NRC CAT are: (1) the inability of

Westinghouse to retrieve radiographic film for certain ASME components for

which they had procurement responsibility, (2) a significant number of high

strength structural steel and equipment bolted connections were found not to

have specified torque values, and (3) the inadequate mounting of electrical

panels and switchgear, and the wiring of motor operated valves not in accord-

ance with approved design drawings.

We undcrstand that an evaluation of the findings of this inspection has been

made to determine the effect on Byron Unit 1 operations.

Ital

Copy to RCPB, IE

-

2- - .- 9

-

, j-

\

!

.

Connonwealth Edison Company -2- November 13, 1985

l

l Appendix B to this letter contains a list of potential enforcement actions

based on the NRC CAT inspection observations. These are being reviewed by the

'

,

Office of Inspection and Enforcement and the NRC Region III Office for

l appropriate action. In addition, Region III will be following your corrective

action for deficiencies identified during this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures

will be placed in the NRC Public Document Room. No reply to this letter is

required at this time. You will be required to respond to these findings

after a decision is made regarding appropriate enforcement action.

Should you have any questions concerning this inspection, please contact us or

the Region III Office.

Sincerely,

f

l

'

%Tay1 , Director

, fffice of Inspection and Enforcement

Enclosures: //

i

1. Appendix A, Executive Summary

2. Appendix B, Potential Enforcement Actions

3. Inspection Report

cc w/ enclosures: See next page

l

1 <

. --_-. - --. . __.. - -__ ._-- - _ - _ _

I

Commonwealth Edis:n Company -

3- Nov:mbar 13, 1985

cc w/ enclosures:

Dennis L. Farrar, Director Resident Inspector (Byron Station)

of Nuclear Licensing U.S. Nuclear Regulatory Commission

Commonwealth Edison Company 4448 German Church Road

P.O. Box 767 Byron, IL 61010

Chicago, IL 60630

Resident Inspector (Braidwuod Station)

Mr. V. I. Schlosser U.S. Nuclear Regulatory Commission

Project Manager RR #1, Box 79

Byron Station Braceville, IL 60407

P.O. Box 8

Byron, IL 61010

Mr. Gunnar Sorenson

Byron Station

Commonwealth Edison Company

P.O. Box B

Byron, IL 61010

Byron Power Station

ATTN: Mr. R. E. Querto

Plant Manager

P.O. Box B

Byron, IL 61010

Phyllis Dunton

Attorney General's Office

Northern Region

188 W. Randolph Suite 2315

Chicago, IL 60601

Ms. Olane Chavez, 0AARE/ SAFE

528 Gregory Street

Rockford, IL 61108

0. W. Cassel , Jr. , Esq.

109 N. Dearborn Street

Suite 1300

Chicago, IL 60602

Mr. H. S. Taylor, Head

Quality Assurance Division

Sargent & Lundy Company

55 E. Monroe Street

Chicago, IL 60603

,

0

,

!

l

i

,

-

'

Commonwealth Edison Company -4- November 13, 1985

DISTRIBUTION:

DCS (Docket No. 50-455)

NRC PDR

Local PDR

DI Reading

RCPB Reading

JMTaylor

RVollmer

JPartlow

RSpessard

BGrimes

EJordan

JAxelrad

HThompson

TNovak

BJYoungblooc'

MRushbrook

L01shan

WPaton

AE00

OELD

ACRS (10)

Regional Administrators

Regional Division Directors

HBoulden, OIA

SECY

OPE

OCA (3)

WDircks

HDenton

CAT Members

Resident Inspector

RHartfield

INPO

All Licensees (Distribution 1S)

g

RCPB:DI:IE

fl

RCPB:DI:IE DD/

I

IE DIR:

,

d

IE I Dh .

\ DI i

HWong/vj RHeishman RSpessard JPar ow C/ R' '1mer JT r

10/se/85 10 6 /85 10/g/85 1{/ /85 } / /85 16 85

l

., -

APPENDIX A

EXECUTIVE SUMMARY

An announced NRC Construction Appraisal Team (CAT) inspection was conducted at

Commonwealth Edison Company's (CECO) Byron Unit 2 Station, during the period

August 19-30 and September 9-20, 1985.

OVERALL CONCLUSIONS

Hardware and documentation for construction activities were generally in

accordance with requirements and licensee commitments. However, the NRC CAT

did identify a number of construction program weaknesses, which in most cases,

have resulted in hardware deficiencies that require additional management

attention. These include:

1. For two samples of radiographs for ASME components supplied by Westinghouse

(W) and stored in (W) facilities which were requested by the NRC CAT for

review, none were provided. This is indicative of a lack of retriev-

ability for ASME Code required documentation and raises questions whether

code documentation is available for the (W) supplied equipment. In

addition, the NRC CAT review of audits by CECO and (W) indicated that

audits had not addressed the area of retrievability of radiographs.

2. A significant number of A490 bolts used in structural steel connections

and equipment hold-down applications were found by the NRC CAT to have

less than specified torque values. Some of these connections are designed

to rely on bolt induced clamping forces to carry a portion of the expected

loads.

3. Examples were found in which the electric wiring for motor operated valves

were not in accordance with approved design drawings. This is of further

concern in that the method used for QC to accept these installations was

.through the use of a " speed memo" (which is an uncontrolled document that

does not receive the appropriate design review and approvals). Also in

the electrical area, the foundation mounting welds of several pieces of

Class 1E 4160V switchgear and 125V DC fuse panels were not in accordance

with design requirements.

The identified weaknesses require additional management attention to assure

that completed installations meet design requirements.

AREAS INSPECTED AND RESULTS

Electrical and Instrumentation Construction

The electrical and instrumentation samples inspected generally met the appif-

cable design requirements and installation specifications. However, several

discrepancies were identified including some which will require additional i

management attention.

A-1 )

i

l

_ _ ._. . _ _

f

Wiring workmanship deficiencies were observed in several Class IE components. l

Deficiencies included items such as, conductor bend radius, lug orientation and '

general configuration of wiring. The most significant concern involved

! deficiencies identified in QC accepted wiring for Class 1E valve opera-

tors. In this area over 50% of the sample exhibited wiring configurations

which were not in accordance with approved wiring diagrams.

Some electrical raceway installations were identified in which the FSAR

criteria for physical separation had not been met. Many of the deficiencies

involved the spatial relationship between Class IE and non-Class IE components.

The principal cause was the failure to translate FSAR requirements into

appropriate inspection procedures.

The inspection of several pieces of Unit 2 4160V switchgear and 125V DC fuse

panels indicates that hold-down welds do not meet requirements. The weld

deficiencies on the switchgear were identical to ones which had been found by

the licensee on switchgear of Unit 1, but had not been addressed on Unit 2

components.

Mechanical Construction

Piping, pipe supports / restraints, concrete expansion anchors, and mechanical

equipment were found to be in general conformance to design and installation

.

requirements.

The finding of undersize welds in structural support members and a relatively

large number of minor discrepancies in the heating, ventilating, and air condi-

tioning (HVAC) ducts and supports indicates that additional program review and

attention is needed. These areas were previously subjected to reinspection

without complete resolution of these discrepancies.

Welding and Nondestructive Examination

Welding and nondestructive examination activities were generally found to be

conducted in accordance with the governing codes and specifications. However,

a number of examples were identified where completed structural welds in pipe

whip restraints, structural steel and HVAC areas were smaller than specified in

the design drawings. The licensee has performed an engineering evaluation

concerning these findings and concluded that the welds are structurally

adequate for the intended application.

In the area of vendor supplied tanks and heat exchangers, some were found to

have undersized weld reinforcement in nozzle to shell and manway to shell

joints.

The NRC CAT inspectors also found radiographs for vendor supplied hardware that

did not have adequate coverage and/or had unacceptable weld quality. In

addition, film requested from the Westinghouse storage facility for review by

the NRC CAT were not provided.

Civil and Structural Construction

In the structural steel installation area no major hardware deficiencies were

identified. However, several minor design drawing deficiencies were identified

and a significant number of high strength bolted connections for structural

A-2

- - . - - - . .-.-

.

. . -- - - - .

l

steel and equipment supports did not meet inspection torque values. As a

result, connection clamping force requirements were not met.

4 Reinforced concrete construction in general was adequate. Inconsistencies with

embedment length requirements of concrete expansion unchors exist between the

concrete expansion anchor qualification report and field inspection procedures.

Data was not provided to determine whether sufficient preload exists in expan-

sion anchors for those cases in which washers were not welded to support

baseplates for oversized holes.

Masonry construction and prestressed, post-tensioned tendon installations

were generally acceptable.

Material Traceability and Control

In general the material traceability and control program was considered to be

satisfactory. Significant lack of traceability was found however, for fastener

materials, including assembly and mounting bolts for large vendor supplied

pumps / motors, bolts for battery racks, electrical switchgear and other equip-

ment; and bolts. attaching liVAC duct sections.

'

Design Change Control

Design change control was determined to be generally in conformance with

applicable requirements. In this area the most significant finding was the

- failure to verify that installations were in accordance to current drawings

'-

when out of date design drawings were identified.

Corrective Action Systems

The licensee's corrective action program was found to be generally acceptable,

except for concerns regarding failure to assure that fasteners of required

materials were furnished with certain vendor supplied equipment, audits failed

to assure that radiographs for welds on certain vendor supplied equipment were

retrievable as required, and failure to provide for effective specification

and control of preventive maintenance, particularly from the time of turnover

for testing until turnover for operation.

4

A-3

'

- . _ - - _ , . _

- - - _ _ .

- . , _ .

APPENDIX B

P0TENTIAL ENFORCEMENT ACTIONS

As a result of the NRC CAT inspection of August 19-30 and September 9-20, 1985,

at Byron Unit 2 Station, the following items are being referred to Region III

as Potential Enforcement Actions. Section references are to the detailed

portion of the inspection report.

1. 10 CFR 50, Appendix B, Criterion III as implemented by Commonwealth

Edison Company (CECO) Quality Assurance Manual (QAM), Quality Requirement

No. 3.0, requires that measures shall be established to assure that

applicable regulatory requirements and design basis are correctly

translated into specifications, drawings, procedures and instructions.

Contrary to the above, at the time of this inspection, the licensee's

program was not adequately implemented in that:

a. Splicing of Class 1E wiring in panels has occurred at Byron Station

contrary to the FSAR connitments to IEEE Standard 420, which prohi-

bits the use of wiring splices in panels. FSAR commitments had not

been translated into appropriate procedures and design documents.

(Section II.B.2.b.(6))

b. Approximately one-third of the total of A490 bolts tested by the NRC

CAT were found to be below the pretension required by AISC. Instal-

lation and inspection requirements had not been translated into

appropriate procedures for high strength bolted connections in

structural steel and nuclear steam supply system joints which require

pretension in the bolts. (Section V.B.I.b)

c. During the inspection, concrete expansion anchors were found which

did not meet the eight bolt diameter embedment depth. It could not

be shown that embedment length requirements for concrete expansion

anchors as specified in the concrete expansion anchor qualification

report had been translated into appropriate installation and inspec-

tion procedures. (Section V.B.2.b)

2. 10 CFR 50, Appendix B, Criterion VII, as implemented by CECO QAM, Quality

Requirement No. 7.0, requires measures be established to assure that

purchased equipment and services conform to the procurement documents.

Contrary to the above, at the time of this inspection, the NRC CAT

inspectors found several deficiencies in vendor supplied components. The

deficiencies included: radiographic film stored by the component supplier

in an off-site facility were not retrievable; undersized welds were

identified on tanks and heat exchangers; various vendor radiographs did

not have complete weld coverage or did not show the required weld quality;

and fasteners for various components (large pump-motor assemblies, battery

racks, switchgear cabinets, other electrical equipment, and HVAC equipment)

were not of the material required by specifications or drawings.

(Sections IV.B.11 and VI.B.I.b.(2))

B-1

3. 10 CFR 50, Appendix B, Criterion X, as implemented by CEC 0 QAM, Quality

Requirement 10.0, requires that a program for inspection of activities

be established and executed to verify conformance with documented

instructions, procedures, and drawings for accomplishing the activities.

Contrary.to the above, at the_ time of this inspection, the licensee's

inspection programs were not effectively implemented in that:

a. Unit 2 4160V switchgear and DC fuse panels were found not to be

installed in'accordance with requirements for seismic mounting of

Class IE equipment. (Section II.B.3.b.(4) and (6))

b. Some Class IE electrical raceways have not been installed in accord-

ance with FSAR commitments for electrical separation. (Section

II.B.1.b.(1))

c. Some Class IE motor operated valve terminations were not accomplished

in accordance with design documents in that wiring configurations did

not match those specified on approved wiring diagrams. (Section

II.B.3.b.(8))

-

B-2

. ... . - - -- .- . _ _ . .- - . ..

ML20136C723

Text

Navigation menu

Search