ML20154K777
| ML20154K777 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/04/1986 |
| From: | Steptoe P ISHAM, LINCOLN & BEALE |
| To: | Callihan A, Cole R, Grossman H Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-345 ALAB-143, OL, NUDOCS 8603110310 | |
| Download: ML20154K777 (162) | |
Text
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W D' % coaResea m ys ISHAM, LINCOLN & BEALE COUNSELORS AT LAW COLKETED THRE E FsRST NATIONAL Pt.AZA f M1(
i CHICAGO. WNOIS 60602 EDWAAD $ iSMAM 1872 NC2 WASHINGTON 0FFICE E's'Edif EE 1g gp-7 % %A'E.P' " *
, GTON O C 200J6 March 4, 1986 OCNiiIwl $0.51L1.
Herbert Grossman, Esq.
Chairman BRANCH Administrative Law Judge
' Atomic Safety and Licensing Board United States Nuclear Regulatory Commission Washington, D.C.
20555 Dr..A.
Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, Tennessee 3.7830 Dr. Richard F. Cole Administrative Law Judge Atomic Safety and Licensing Board United States Nuclear Regult. tory Commission Washington, D.C.
20555 Re:
In the Matter of Commonwealth Edison Company
'(Braidwood Station, Units 1.and 2)C-Docket Numbers 50-456'and 50-457C
Dear Administrative Judges:
Pursuant to the duty of full disclosure as articu-lated by the Appeal Board in Duke Power Company (William B.
McGuire Nuclear Station, Units 1 and 2), ALAB-143, 6 AEC 623 (1973), enclosed are copies of the recent NRC Construction Assessment Team (CAT) inspection for Byron Unit 2, and Com-monwealth Edison's response dated January 24, 1986.
While I have not performed a comprehensive review of the Byron Unit 2 CAT inspection report to determine each way in which it may be relevant to the issues in Braidwood, it appears that viola-tions 2 and 3b in that report, and Edison's responses to those violations, may be relevant to Intervenors' Amended Quality Assurance Contention, items 8.C and 10.D.
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] Adaress RIply to Post Office Box 767 WTED CORRESPONDENCt; (f Chicago, Illinois 60690 4
January 24, 1986 00(KETED USNRC Mr. James C. Keppler 82 MR -7 R2:21 Regional Administrator U.S. Nuclear Regulatory Commission gypg.
Region III 00CML Tmu s at Mcf.
799 Roosevelt Road BRANCH Glen Ellyn, IL 60137
Subject:
Byron Station Unit 2 IE Inspection Report No. 50-455/S5-027 References (a): November 13, 1985 letter from J. M. Taylor to Cordell Reed (b): December 12, 1985 letter from C. E. Morelius to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of the NRC Construction Appraisal Team (CAT) inspection conducted at Byron Station, Unit 2 on August 19-30, and September 9-20, 1985. During this inspection, certain activities were found in violation of NRC requirements. Attachment A to this letter contains Cominonwealth Edison's response to the Notice of Violation appended to reference (b).
Attacnment B to this letter addresses the three construction program weaknesses identified in the CAT report. On January 8, 1986, Conunonwealth Edison was granted a fourteen day extension on the due date for the response to the Notice of Violation.
With respect to certain findings identified during the CAT inspection, we do not believe these items represented a violation of NRC requirements. Our reasons for this are discussed in the detailed responses in Attachment A.
In these particular areas, we request the NRC to reconsider.
these items in light of the infoc1mation we have provided.
Please direct any questions regarding this matter to this office.
I Very truly yours, I
9---
L. Farrar l
Director of Nuclear Licensing t
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1m Attachments cc: Byron Resident Inspector 1155K l
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ATTACHMENT A VIOLATION la 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 splicing of Class IF wiring in panels has occurred at Byron Station contrary to the FSAR ccamitments to IEEE Standard 420, which prohibits the use of wiring splices in panels. FSAR commitments had not been translated into appropriate procedures and design documents.
RESPONSE
This concern was originally identified during the NRC CAT inspection at Braidwood Station (IE Inspection Report No. 50-456/84-44; 50-457/84-40, page II-13, copy attached).
In response to this concern, a discussion of conformance to IEEE 420-1973, including our use of cable splices within control switchboards, has been provided on page 8.1-14 of the FSAR.
An advanced copy of this FSAR revision was provided to the NRC in a February 6, 1985 letter from T. R. Tramm to H. R. Denton (copy attached).
During the Byron CAT inspection, a copy of this letter was furnished to the inspector.
Since our intent to formally revise the FSAR by way of amendment was committed to in the February 6,1985 letter referenced above, we believe this item would be more appropriately classified as an Unresolved Item pending issuance of the formal FSAR amendment.
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,jy The Braidwood Station FSAR commitment to IEEE Standard 42 prohibits the use of wire splices in Class 1E equipment.
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However, NRC CAT inspectors observed in-line butt splices 5
in numerous electrical panels.
As site procedures do not require the location of splices to be depicted on design documents, NRC CAT inspectors were unable to determine how extensively these splices have been utilized.
Additional-ly, the licensee had previously issued NCR-598 to document hardware deficiencies in installed butt splices and reported this condition to NRC Region III in accordance with 10 CFR 50.55(e).
The use of butt splices in Class 1E panels requires documentaticn in the FSAR as an exception to the IEEE standard.
The following are the isolated discrepancies noted by the NRC CAT inspector:
Conductor insulation damage on the orange conductor of cable IRH108-CIE in motor control center IAP21E, cubicle F3.
ICR-7610 was subsequently issued to document this condition.
Several terminal screws were found loose in the Diesel Generator Control Panel IA and in the Remote Shutdown Panel, section IPLO5J.
ICR's 7646, 7644, and 7643 were subsequently issued to document these condi-tions.
Internal motor lead T-9 was found damaged in motor operated valve ICSQO1A.
ICR-7867 was subsequettly issued to document this condition.
The red conductor of cable ISIO53-CIE, in motor operated valve ISI8802A, was excessively bent and not meeting minimum bend radius criteria.
ICR-7870 was subsequently issued to, document this condition.
(8) Seepage of 011 From Okonite Cable NRC CAT inspectors observed any oily substance seeping from jackets of numerous installed and terminated cables manufactured by the Okonite Company., This condition was observed in both Class IE and non-Class 1E cables in various Class 1E equipment throughout the facility (motor control centers, main control boards, control panels, motor operatr.d valves, etc.).
Information obtained from NRC Region III, Ceco, and S&L revealed the following:
In a letter dated October 4,1982, including an attacned engineering report (No. 364), the Okonite Company informed Ceco that, with reference to the identical condition identified at Byron Station, this seepage "will not affect the reliability or life of the cables."
II-13
@ One First National Plaza Chica;c titino.s Commonwrith Edis:n Address Re;;iy to Fest Othee Box 767 CNcago. I!hnois 60690 February 6, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. PAJclear Regulatory Cox11ssion Washington, DC 20555
Subject:
Byron Generating Station Units 1 and 2 Braidwood Generating Station thits 1 and 2 FSAR Changes NRC Docket tbs. 50-454/455 and 50-456/457
Dear Mr. Denton:
This letter provides advance copies of revised pages for the Byron /Braidwood FSAR. These changes are being made to provide more explicit descriptions of the design bases for these plants.
Enclosed is a revised page 8.1-14.
It now includes a discussion of conformance to IEEE 420-1973 with regard to the allowed use of cable splices within control switchboards. This change is being made to resolve a concern identified during a recent I&E inspection at Braidwood Station.
Also enclosed are revised pages E.20-1, E.20-la, and E.82-1 for Appendix E of the Byron /Braidwood FSAR. They now specify that the liquid source term used for shielding evaluation and environmental qualification of Byron and Braidwood doss not include noble gases. Fission solids are the dcminant contributor for long term doses so this does not significantly alter the radiological irrpact of postulated accidents.
Also included is a revised page E.21-3.
It specifies that backup sampling is not provided for hydrogen because of the large volume required.
These changes will be incorporated into the FSAR at the earliest opportunity.
Please direct questions regarding these matters to this office.
One signed original and fifteen cooles of this letter are provided for FRC review.
Very truly yours, r
wdbM r
,rt T. R. Tramm ttJclear Licensing Administrator 1m cc: Byron Resident Inspector Braidwood Resident Inspector C '? 3 ~dfl 1
B/B-ELki.
Ant.NDnLN~ 36 MAY 1952 The physical identification of safety-related equipment is discussed in Subsection 8.3.1.3.
8.1.15 Shared Emercency and Shutdesn Electric systems for Multi-Unit Nuclear Power Plants The criteria followed in designing the two unit station is that each unit shall operate independently of the other and malf unc-tion of equipment or operator error in one unit will not initiate a malf unction or error in the other unit nor af f ect the continued operation of the other unit.
8.1.16 Cualification of Class 1E Equiprent for vuelear Fewer Plants With regard to environmental qualification of instrumentation, control, and electrical equipment arportant to safety, the Applicant complies with the intent of IEEE 323-1974.
Additional inf ormation is provided in Section 3.11.
8.1.17 - Availability of Electric Power Sources i
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During ' abnormal electric power source configurations, plant operations _ are limited as described in Subsection 16.3/4. 6.
8.1.18 Conformance to IEEE 338-1975 (Periodse Testino of Nuclear Power Generating Station Class 1E Fower a nd Protection System) conformance to this standard is addressed in subsection 8.3.1.2 and 7.1. 2.19.
8.1.19 Conformance to IEEE 344-1971 (Fecom. mended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generatino Station) conformance to this Standard is addressed in Section 3.10.
8.1.20 Conferrance to IEEE 387-1972 (Criteria for Diesel Generator Units Applied as Standby Power Supplies f or Nuclear Power Generatino Stations)
Vendor qualification tests, preoperational testing, and periodic testing during norral plant operation cenform to those procedures described in this standard, except as neted in 3ctsections 8.3.1.2, 16.3/4.5, and chapter 14.0.
8.1.21 Conformance to IEEE 420-1973 (IEEE Trial-Use Guide for Class lE Control Switchboards for Nuclear Power Generating Stations)
Class lE control switchboards conform to this standard with the following clarification to Paragraph 4.6.1.2:
Splices may be used on individual conductors of field cables within switchboards for the purpose of extending individual conductors to their point of ternination.
8.1-14
o VIOLATION lb e
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.
t Contrary to the above, at the time of this inspection, the.
Licensee's program was not adequately implemented in that approximately one-third of the total A490 bolts tested by the NRC CAT were found to be below the pretension required by AISC.
Installation 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, g_RRECTIVE ACTION TAKEN AND RESULTS ACHIEVED 0
Structural Steel Connections There are sixty-five framing connections in the containment which have A490 bolts specified on design drawings. Twenty-nine of these connections are considered to be slip critical because the connection has slotted holes oriented parallel to the direction of the axial load.
These twenty-nine slip critical connections require some level of bolt pretensioning in order to transfer axial load.
The remaining thirty-six A490. connections have been qualified as bearing type connections, and therefore, bolt torque need not be verified.
The slip critical connections were reinspected to determine the actual in-place torque value for each bolt in the connection. The connections were then evaluated by reducing the capacity of the bolts based on the ratio of as-found torque to the specified torque. These reduced capacities were compared.to design loads and the connection design was found to be within specified limits and the connections remain slip resistant. Therefore, although the as-found pretension was below that specified under the applicable AISC provisions to provide the full load carrying capacity of the bolt, it was adequate to meet the design.
Although the actual installed bolt conditions were evaluated and found to be acceptable the bolts were brought up to specified pretension in order to restore margin.
1 Nuclear Steam Supply System (NSSS) Joints An engineering evaluation was performed to assess the adequacy of as-found bolt pretension in the MSSS supports.
The engineering evaluation shows that the as-found bolt pretension is adequate to preclude separation of connections under tension, and slip of friction type connections loaded in shear. Therefore, although the as-found pretension is below that specified under the applicable AISC provisions, it is adequate to meet the design.
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9 CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Structual Steel Connections Although certain installation and inspection requirements were translated into the contractor's procedure, the following enhancement has been made to the procedure.
Blount Brothers Work Procedure Number 21 has been revised to clarify the installation requirements of high strength bolts by the turn-of-nut method. Snus tightening shall progress from the most rigid part of the connection to the free edges, and then bolts of the connection shall be retightened in a similar manner as necessary until all bolts are snugtight and the connection is compacted.
NSSS Joints Although certain installation and inspection requirements were tranciated into contractor's procedures, the following enhancements have been made to the procedure for installation of NSSS support bolts requiring pretension.
(1) Hunter Procedure SIP 4.001, " Bolted Connections", has been revised to define snugtight as 15% of the torque required to achieve the final pretension. This definition of snustight will be used for future work on NSSS support high strength bolting.
(2) Connections which employ shims in the connected parts have been evaluated for their ability to achieve the required bolt pretension when tightened using turn-of-the-nut method. Where turn-of-the-nut method may not achieve the required pretension due to compressibi-lity of shims between the connected parts, the calibrated wrench method has been specified.
DATE WHEN FULL CONpLIANCE WILL BE ACHIEVED The engineering evaluations of the as-found condition of the structural steel connections and the NSSS joints were completed October 23, 1985.
The accessible bolts in the twenty-nine structural steel connections were retightened by October 14, 1985.
Hunter Procedure SIP 4.001 was revised on October 15, 1985 and approved on January 9, 1986. Blount Brothers Work Procedure No. 21 was revised on November 13, 1985 and approved on January 5, 1986.
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VIOLATION Ic 10 CFR'50, Appendix B, Criterion III as inylemented 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 during the inspection, concrete expansion anchors were found which did not meet the required bolt diameter embedmont depth.
It could not be shown that omt:dment length requirements for concrete expansion anchors as specified in the concrete expansion anchor qualification report had been translated into appropriate installation and inspection procedures.
RESPOWSE The Standard Specification for Concrete Expansion Anchor Work Form BY/PR/CEA, provides the installation and inspection requirements for concrete expansion anchors. Within this document is Figure 38-6, copy attached, which shows the embedded length (L ) measured from the surface of the concrete to the bottom of the expansion ring. The qualification report for concrete expansion anchors is entitled, " Report on Static Dynamic and Relaxation Testing of Expansion Anchors in Response to NRC IE Bulletin 79-02", dated July 20, 1981. We extracted two pages from Chapter III of this report, copy attached, which show the embedded length (1eb) measured from the surf ace of the concrete to the bottom of the expansion ring. This consistently defines the embedded length.
The inspection to verify embedded length is a measurement of the projection of the anchor beyond the concrete in the installed position.
Subtracting this measurement from the total anchor length establishes the embedded length. The installed position is defined as being after the anchor has been set by applying an installation torque.
As the torque is applied, the anchor slips slightly, pushing the expansion ring outward to produce the wedging force between the ring and concrete. During this setting action, it is assumed that the ring remains stationary as the back of the anchor approaches the expansion ring. The inspection for the embedded length is therefore, consistent with the qualification report.
Based on the foregoing, we believe embedmont length requirements were properly translated into appropriate installation and inspection procedures. We are not aware of any concrete expansion anchors found during
.the CAT inspection that did not meet the required embedmont length. We request the NRC to reconsider whether this is an example of violation of 10 CFR 50 Appendix B, Criterion III.
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CAGGENT O LUNDY Mai. (;
ATTACH 51ENT 1 a=oiweaoo cwicaso TABLE 38-2 MINIML'M EMBEDDED LENGTH, SPACING AND EDGE DISTANCE FOR EXPANSION ASCH0PS Nominal Minimum Embedded F.inimum Spacing Finimum Edge Distance Bolt Lene,th *
(inches)
(inches)
Diameter (inches)
(S)
(inch)
(Lc)
(ED)
(ES) 1/4 5/8 2.5 3.25 1.75 3/8 3
4.5 5
2.5 1/2 4
6 7
3.5 5/8 5
7.5 A.5 4.75 3/4 6
9 10 5
1 8
12 13 6.5
- Minus 1/16" tolerance is allowed.
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LINED OPENING >l2 S OR JOINT SURFACE ROUGH BETWEEN BLOCK AND CONCRETE CONCRETE OR BLOCK ED S
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ATTACHMENT 2
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REPORT ON STATIC, DY:UJ:1C !.::D EELAXATION TF.STI:10 OF EXPA'iSION /J:0!DRS IN RES~'ON0; TO NRC I.E. CUU.El'IN 79-02 JULY 20, 1931
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CHAl'TER III - MATF.?.IA1.S A.D TEFT SPECJ!!E!!S EXPA?:SIO:: l':CH0PS D,cseription of Concric Ty;cs.
In this expericental progra=,
four generic types of ex;sacion cnchors have been investigated.
The generic types are classified into the following ents orics: vedge, sleeve, self-drilling and drop-in.
All the generi types listed abova achieve 1 cad carrying capacity when e 3 coded by h:ving a wedge ecchanis: located at the bottom of the ancl.or.
The. wedge is expand:d against the side walls of the c=bedrant hele during the installation procedure.
Figure 3.1 J
shows the fcur generic types cf en: hors that were tested and also identifics the ranufacturer of the specific type irivestigated.
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For each anchor, the er. bed:en: depth has consictently been
.. -p g'l defined as the distance from the surface of the c beddtng r. steri:1 to the' bottor. of the expanding part.
Therefc c, in tha case of the.redge in the distance ircu the end of the ancher to thc y
and ciceve type e.nchart, surfste cf the cus.cding cturial does.ot rept ebent the cchede. cat depth.
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Tnc cas:: cent dcp;h is acf;ned en Pia. 3.1.
For the scif-dt illing and
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' ! drop-in typc' expansion enchcrc, the cecedtent depth is typically taken T'.ic aucunes that the anchor is as the length cf the anchor shc11. r b. flush with the cr. bedding surf ace. { %) 4. D IIT-1
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== A A a d .ou .o w u O N q_L l __ t MDh MD}- ITT-Phillip s : Slc.cve ITT-Phill'Ps' Hilti:IEU ] Self-Drilling (Drop-in) . -6 4 9 me Df-D 3 ^ u i t. S t '!l ';s ! A 1 u ~ ".a 4 G tj. 9j
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A = S.;rfa-c 9f c 3cedinf, ::sterial 26 " E' Sedrer.t epth 1 i [ l yjg, 3,1 Dc tails r.i." Ce*1r:ric E:. pen:icn /.r.che?J III-2 i L
VIOLATION 2 10 CFR 50, Appendix B Criterion VII, as implemented by CECO QAM, Quality Requirement No. 7.0, requires measures shall be established to assure that purchased material, 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. CORRECTIVE ACTION TAKEN AND RESULTS_ ACHIEVED This violation involves the radiographs for the Unit 2 component cooling surge tank and volume control tank. The component cooling surge tank was fabricated, inspected, tested and shipped from the Westinghouse Orange Plant. Radiography was required and performed in accordance with ASME Section III Class 3 requirements. This product line was transferred to other Westinghouse facilities and Westinghouse considers the radiographic filns for this tank to be lost in transit between facilities. Although the actual radiographs are not available, the original radiograph procedures, shooting sketches, and reader sheets which document the performance and acceptance of the radiography are available. The reader sheets are permanent records which can be copied and do not degrade with time. With respect to radiographs for the volume control tank. Westinghouse has confirmed that these films are present in their respective storage locations. Since the radiographs for the component cooling surge tank are not retrievable, the Westinghouse product Assurance Department conducted an inventory of the radiographs for Byron /Braidwood equipment for which they are responsible. The results of the inventory indicate that all radiographs that are required by Westinghouse quality release are either'in the Westinghouse storage facility or in their vendors' storage facilities with the exception of the component cooling surge tank. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Commonwealth Edison's Quality Assurance Department has added radiograph retrievability as a quality element in their next scheduled audit of Westinghouse. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVgD The Westinghouse inventory was completed October 18, 1985. 1155K
1 \\ \\ VIOLATION 2 (Cont'd) 10 CFR 50, Appendix B, Criterion VII, as implemented by CECO QAM, Quality Requirement No. 7.0, requires measures shall be established to assure that purchased material, 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: undersized welds were identified on tanks and heat exchangers. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED prior to the CAT inspection, undersized welds were identified by Commonwealth Edison on ten tanks and pressure vessels as a result of a walkdown performed in response to NRC Inforination Notice 85-33. Three Comunonwealth Edison nonconforinance reports (NOR's) were issued to track resolution of these deficiencies. These NCR's were evaluated by the project Engineering Department and the equipment vendors and the as-found condition of the components was found acceptable. During the CAT inspection, NRC inspectors identified additional tanks and pressure vessels with undersized welds. Hunter Corp. NR 1148 was issued to address these items and is currently under evaluation by Sargent & Lundy. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION I Although the undersized welds which have been identified thus far have been found to not be design significant, approximately 20 other potentially affected tanks and pressure vessels have been inspected and deficiencies which were identified have been included into the scope of NR 1143. The welds in approximately six additional potentially affected tanks are not optimally accessible at this stage of construction. If the results of the engineering evaluation of the other components in NR 1148 indicate that there are no undersized welds of design signift:ance, we do not believe any further inspection effort is warranted. DATE WHEN FULL COMPLTANCE WILL BE ACHIEVED The engineering disposition of Hunter Corp. NR 1148 is expected to be complete by June 30, 1986. 1155K
VIOLATIOLI (Cont'd) 10 CFR 50,' Appendix B, Criterion VII, as implemented by Ceco QAM, Quality Requirement No. 7.0, requires measures shall be established to assure i that purchased material, 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: various vendor radiographs did not have complete weld coverage or did not show the required weld quality. This response addresses the eight notes of Table IV-6 discussed on pages IV-21 and IV-22 of the CAT Inspection Report. Note 1 The film packet for one of the welds which should have contained film for r five intervals, contained film for only two intervals. The missing film for the other three intervals was later found and was reviewed with no problems identified.
RESPONSE
The film packet noted was previously transferred to the station vault l from the Quality Assurance Department and during the station's indexing and boxing of the film, the film was divided and separated. This l separation of documents was corrected during the CAT inspection and the complete set of film was reviewed and found acceptable by the CAT inspector. We believe we have demonstrated the required documents are retrievable and this item should not be concidered as an example of violation of 10 CFR 50, Appendix B, criterion VII. Note 2 The reader sheets with the film indicated that this film was for Braidwood components. Further investigation of documentation indicated that the items had originally been scheduled for Braidwood but had later been transferred to Byron.
RESPONSE
procurement specifications for Byron and Braidwood Stations are common documents. Materials and components which are procured under these common specifications are usable at either station. This component was originally planned for installation at Braidwood Station, but was subsequently transferred to Byron and installed. Transferring components from one site to the other is a common, acceptable practice. The transfer of this component from Braidwood to Byron was properly documented by Sargent & Lundy prior to the CAT inspection. A review of the reader sheets and associated film for this component indicated the weld's identification numbers and weld quality were acceptable. Therefore, we do not consider this item to be an example of violation of 10 CFR 50 Appendix B, Criterion VII and request the NRC to reconsider their disposition of this item.
Note 3 Reader sheets for weld WT 8549-64 were not in that packet but were found in film packet for weld WT 2158-64.
RESPONSE
A review of this item indicated that the reader sheet was inadvertently placed in the different packet (box). The radiographs are indexed by Sargent & Lundy transmittal numbers which, generally, list several different welds. Occasionally, it is not physically feasible to store all the radiographs and associated documentation in the same box. Therefore, when the CAT inspector requested a random sample of film associated with certain specifications, one box was provided. To preserve the randomness of the sample, the box selected was not reviewed to determine if the reader sheet was contained within the box prior to being presented to the CAT inspector. If the box would have been screened by plant personnel prior to being presented to the inspector, the misplaced reader sheet would have been included with the box selected. Therefore, we believe this item should not be considered an example of violation of 10 CFR 50, Appendix B, Criterion VII and request the NRC to reconsider their disposition of this item. Note 4 (1st paragraph) Circumferential seam 1Al-6 showed added weld metal on interval A-B dated June 20, 1977, however the added metal does not show in interval M-A ' dated June 23, 1977. CECO reviewed the film and returned it supposedly in proper order. However, due to two different identifications on the film, it was impossible to tell whether one or two welds were represented by these film. Subsequently, Ceco determined that the film actually were from only one weld, and that further repair in the M-A interval accounted for the difference in appearance of the two weld intervals.
RESPONSE
During the radiographic review, it appeared to the CAT inspector that weld metal was added subsequent to the initial acceptance of the weld. However, the proper indexing of the film package by plant personnel clearly demonstrated the sequence of repairs and resolved the inspector's concern. We do not consider this item to be an example of violation of 10 CFR 50, Appendix B, Criterion VII and request the NRC to reconrider their disposition of this item. Note 4 (2nd paragraph) On weld 1Al-1 (Job 2) interval 11-12 a linear indication, possibly a crack, was noted. Ceco then did an ultrasonic examination of the area. However, the performed examination was a longitudinal examination and is not acceptable for this type and location of indication. An NCR is being written. This indication is in vessel ICS01T (Byron 1).
' CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED This tank is a Unit I component and therefore, Action Item Record
- 6-85-351 was written to track resolution of this issue. The weld was re-radiographed, surface buffed and again re-radiographed. The indication was a surface condition, not a crack, which was removed during the buffing. The aforementioned repair film was subsequently reviewed by NRC Region III Inspector K. D. Ward and found acceptable.
CORRECTIVE ACTION TJKEN TO AVOID FURTHER VIOLATION We believe the presence or absence of this indication was a matter of judgment by Level III interpreters. As a conservative measure, the weld was re-radiographed and the indication was removed. Based on the large number of radiograph flims that were reviewed by the CAT and found acceptable (approximately 1980), we do not believe any further action is warranted. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The second re-radiograph, which showed the surface condition was removed, was completed on November 5,1985. Note 4 (3rd Paragraph) In vessel H1 tank 2 weld 3A'.-1 interval F-G at the end of the seam in the transverse weld, an indication was noted. However, when the film of the transverse weld were located they showed no indication of a problem in the area mentioned.
RESPONSE
The radiographing of the transverse weld was performed subsequent to the seam weld radiograph and no indication was noted in the transverse weld. The indication was considered a surface condition and was removed prior to radiographing the transverse weld. This is an acceptable practice and we do not consider this item to be an example of violation of 10 CFR 50, Appendix B, Criterion VII. Therefore, we request the NRC to reconsider their disposition of this item. Note 5 When the film was submitted, the reader sheets were so faint that it was impossible to read them. Subsequently, the original sheets in the QA file were produced and the film was read. No problems were noted.
. RESPONSE The onsite copy of the reader sheet for this film was reproduced from a document which was faintly printed. A better copy was made from the original reader sheets used for the initial review and acceptance by Sargent & Lundy. This legible copy was reviewed by the CAT inspector and found acceptable. We do not consider this item to be an example of violation of 10 CFR 50, Appendix B, Criterion VII and therefore request the NRC to reconsider their disposition of this item. Note 6 A 3/8 inch slag line was noted in the 2-3 interval. After reviewing the receiving and issuing documents, it was determined that the item had never been issued to the job for installation. CORRECTIVE ACTION TAKIN AND RESULTS ACHIEVED This component was a Unit 1 pipe hanger (M-1RC120115) which was eliminated from the piping design. Although this hanger was originally accepted for use, elimination of it from the design will prevent it from 4 being installed. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOf.ATION This hanger was the only component supplied by ITT Crinnell which required a radiographic exam. Therefore, we do not believe any further action is warranted. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED This component was eliminated from the design on February 15, 1980. Note 7 Area 3255-A OWK10D had a linear indication on each of the junction welds. Area 3244-A-2V2 OWIO7 TV2 had the penetrameter shim into the area of interest.
RESPONSE
These two components are non-safety related tanks. Purthermore, we believe these concerns resulted from a subjective judgment involving interpretation of radiographs. These radiographs were originally l reviewed by a Sargent & Lundy Level III interpreter and found acceptable. t In response to this concern identified during the CAT inspection, the
- radiographs were re-evaluated by Sargent & Lundy's Level III interpreter. With respect to tank OWK10D, the linear indication is considered to be a 1/4" long weld surface contour and is acceptable. The penetrameter shim in tank OWK07 is along the toe of the weld and does not impair the diagnostic capabilities of the radiograph. This is also considered acceptable. Therefore, we do not consider these items to be an example of violation of 10 CFR 50. Appendix B Criterion VII and request the NRC to reconsider their disposition of these items.
E019_.8 4901-9, weld 147 A-B, had an unacceptable slag line at Station A and the belt numbers appear to be inside the area of interest. Six welds did not have full coverage. The welds were identified as: 4901-9, - weld 103 G-H, weld 116 A-B, weld 160 G-H; 4901 welds 147 A-B and 160 C-H; and 4902, weld 75 B-C. Item 4901-1D, weld 103 G-H, also did not have full j coverage and there was a linear indication extending into the uncovered l area. l
RESPONSE
l With the aid of additional drawings incorporated into an approved Engineering Change Notice (ECN) that was not available at the time of the I CAT inspection, it can be demonstrated that the slag line and belt l numbers discussed above are located in the base retal. The slag inclusion was actually a surface blemish caused during the final surface preparation. This additional information was used by Sargent & Lundy during their initial review of the radiographs and was found acceptable. The additional drawings also demonstrate that the radiographs obtained the required coverage of the area of interest. The ECN and radiographs were subsequently reviewed by NRC Region III Inspector K. D. Ward and found acceptable. Therefore, we do not consider these concerns to be an example of violation of 10 CFR 50, Appendix B, Criterion VII and request j the NRC to reconsider their disposition of these items. i l l 1155K
VIOLATION 2 (Cont'd) 10 CFR 50, Appendix B, Criterion VII, as implemented by Ceco QAM, Quality kequirement No. 7.0, requires measures shall be established to assure that purchased material, 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: fasteners for various components (large pump-motor assemblies, battery racks, switchgear, other electrical equipment, and HVAC equipment) were not of the material required by specifications or drawings. CORRECTIVE ACTION TAKEW AND RESULTS ACHIEVED Lerne pume-Notor Assemblies Commonwealth Edison non-conformance report (NCR) F-1014 was issued to track resolution of the discrepancies regarding assembly and mounting bolts for large vendor supplied pump-motor assemblies. Sargent & Lundy and Westinghouse have reviewed the NCR and evaluated the installations where the as-found bolting either differed from specifications in design documents or could not be shown to meet the design specifications. Their conclusions are that the as-found bolting meets or exceeds the strength requirements intended by the design specifications, except for the motor-to-base bolts on the non-safety related positive displacement charging pump (2CV02P). Further analysis is necessary to determine the acceptability of the motor end-to-pump base bolts on the RHR pumps (2RH01PA and 2RH01PB) and the motor-to-skid bolts on centrifugal charging pump 2CV01PB. The motor-to-base bolts on pump 2CV02P will be replaced with bolts which can be shown to meet design specifications. If the analyses of tt.* motor end-to-pump base bolts on pumps 2RH01PA and 2RH01PB and the motor-to-skid bolts on pump 2CV01PB do not yield acceptable results, these bolts will also be replaced. ASTM A307 Bolts for Electrical and HVAC Roulement This issue concerns the installation of unmarked bolts in various components whose design requirements call for ASTM A307 bolts. The issue has been categorized into two subgroups: (1) unmarked bolts which worn site procured and installed by site contractors; and (2) unmarked bolts provided with vendor supplied equipment. Commonwealth Edison issued NCR's F-1001 and F-1012 to address these subgroups, respectively. As a result of these NCR's, a sampling plan has been devised to perform a Brinnell hardness test on unmarked bolts in a random selection of equipment in both subgroups. The correlation of Brinnell hardness to tensile strength will be used to establish the acceptance basis for the unmarked bolts. All semples have been taken and the data has been evaluated by Sargent & Lundy. The unmarked bolts have been found acceptable.
. l CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION Large Pump-Motor Assemblies l In October 1982, the Commonwealth Edison Co. Quality Assurance Manual was revised to require the random inspection of botting materials in all fabricated assemblies upon receipt of the equipment to assure compliance with design drawings. The equipment included in NCR F-1014 was received j prior to 1982. l l ASTM A307 Bolts for Electrical and HVAC Eaulpment on August 19, 1985, the Byron Project Construction superintendent issued l a letter to the applicable onsite contractors concerning NCR F-1001. This l 1etter directed the contractors to perform a sample inspection during receipt of future shipments of bolts to verify the bolts are marked per ASTM A307 requirements. The revision to the Quality Assurance Manual discussed above also addresses vendor supplied electrical and HVAC equipment similar to the i equipment included in NCR F-1012. The equipment included in NCR F-1012 l was received prior to 1982. I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Larne Pump-Motor Assemblies The motor-to-base bolts on pump 2CV02P will be replaced by May 1, 1986. l The analysis of the motor end-to-pump base bolts on pumps 2RH01PA and 2RN01PB and the motor-to-skid bolts on pump 2CV01PB will be completed by March 1, 1986. ASTM A307 Bolts for Electrical and NVAC Iquipment l Sargent & Lundy's evaluation of the Brinnell hardness data from the sample plan was completed on January 22, 1986. As a result of Sargent & Lundy's evaluation, the aforementioned unmarked bolts were determined to be acceptable. Commonwealth Edison NCR's F-1001 and F1012 were closed on January 24, 1986. l l I l l 1155K
VIOLATION 3a 10 CFR 50, Appendix B, Criterion I, as implemented by CECO QAM, Quality Requirement 10.0, requires that a program for inspection of activities shall 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 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. CORRECTIVE ACTION TAKEW AND RESULTS ACHTEVED 4160V Switchaear Commonwealth Edison nonconformance report (NCR) F-1005 was issued to document the nonconforming hold down welds on switchgear 2AP05E and 2AP06E. In addition, two field change requests (FCR's) were written. FCR F-26662 was written to allow revision of the hold down weld design from a four-sided weld to a two-sided weld. FCR F-26659 was written to allow an alternate hold down weld desitn where inspection was deterred due to the location of the two slots in the rear of the cubicles. These FCR's were evaluated by Sargent & Lundy and approved. The nonconforming hold down welds were repaired and reinspected. DC Fuse Panel Hatfield Electric Co. Discrepancy Report No. 7373 was issued to address the mounting weld configuration for DC fuse panel 2DC11J. The mounting welds were repaired and reworked to meet the weld configuration require-monts of the specification. This rework was reinspected and found acceptable. CORRECTIVE ACTION TAKEN TO AVOID FURTHER VIOLATION As a result of a stop work order regarding installation of electrical equipment that was issued in December, 1980, the installation and inspection practices in this area were significantly enhanced and became more prescriptive and rigorous. The switchgear and fuse panel discussed in this violation were installed prior to this overall upgrade to the electrical equipment installation process. Therefore, we believe current procedures and practices should be sufficient to prevent recurrence.
i i l l . ' DATE WHEN FULL COMPLIANCE WILL BE ACHIEVhJ NCR F-1005 concerning the hold down welds on switchgear 2AP05E and 2AP06E was closed on December 14, 1985. Discrepancy Report No. 7373 concerning the mounting weld configuration for DC fuse panel 2DC11J was closed on September 9, 1985. 4 1155K
VIOLATION 3b 10 CFR 50, Appendix B, Criterion X, as implemented by CECO QAM, Quality Requirement 10.0, requires that a program for inspection of activities shall 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 some Class 1E electrical raceways have not been installed in accordance with FSAR commitments for electrical separation.
RESPONSE
Commonwealth Edison commitments with regard to electrical separation are documented in Section 8.3 of the Byron /Braidwood FSAR. These commitments are supplemented with a description of conformance to NRC Regulatory Guide 1.75 which is documented in Appendix A of the FSAR. Byron's commitment to Regulatory Guide 1.75 allows for the use of analysis and/or test to justify separation distances less than those distances specifically stated in Section 8.3 of the FSAR. The use of analysis and/or test to justify electrical separation distances is also permitted in IEEE Standard 384-1974. Prior to this CAT inspection, a Sargent & Lundy analysis justifying " worst case" separation distances between safety related and non-safety related cables was submitted to NRR for review. The specific configuration which was chosen for a " worst case" analysis was one in which a separation distance was established between a safety-related and a non-safety related cable when one is in free air and the other is in a raceway. The analysis justified that a separation distance of less than one inch is acceptable between the cable and the raceway. This analysis was based on a test performed for Byron Station. The specific raceways which were identified by the CAT as being in violation of the FSAR commitments involved installations where either non-safety related conduits were installed with less than 12" vertical or 3" horizontal separation from safety related cable tray, or safety related conduits were installed with less than 12" vertical or 3" horizontal l separation from non-safety related cable tray. In order to satisfy the CAT inspector's concern for the type of l installations identified, the CAT was presented with Sargent & Lundy Calculation 4391/Q-15. " Justification of Electrical Separation Distance Between Safety Related and Non-Safety Related Raceways". This calculation is based on the same test report which was submitted to NRR for review and justifies that separation of less than 12" vertical or 3" horizontal, but greater than one inch, is acceptable between a safety related conduit and non-safety related cable tray or between a non-safety related conduit and a safety related cable tray, i
. ) Since Sargent & Lundy Calculation 4391/Q-15. as well as the calculation previously submitted to NRR, justifies separation of greater than one inch between safety related and non-safety related cable tray and conduit, the only specific electrical separation inspection requirement which is required to be in the electrical contractor's inspection procedures is the requirement to verify that one inch separation is maintained. Hatfield Electric Co. Quality Control Procedure 9B has a requirement that specifies one inch separation between cable tray and conduit installations. Based on the information provided above, we believe this item would be more appropriately classified as an Unresolved Item pending the outcome of NRR's review of the Sargent & Lundy analysis. 1155K
-s VIOLATION 3c 10 CFR 50, Appendix B Criterion X, as implemented by CECO QAM, Quality Requirement 10.0, requires that a program for inspection of activities shall be established and executed to verify conformance with documented instructions, procedures, and drawings for accomplishing tne activities. Contrary to the above, at the time of this inspection, the licensee's i inspection programs were not effectively implemented in that 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. CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED As a result of the examples of wiring discrepancies identified during the CAT inspection, the electrical installation contractor initiated nonconformance report (NCR) 1697 to address this concern. Twelve valves were reinspected under this NCR. The as-wired condition in each valve was examined and it was determined that the valves would perform their design function. This is because each valve was properly wired in accordance with the control schematic diagram which is the governing design document. We acknowledge that in four valves, the wiring was not in accordance with the wiring diagram for the valve. Since a wiring diagram is also a design document and is used for QC inspection purposes, the affected wiring diagrams were revised to reflect the as-wired condition of the four valves. CORRECTIVE ACTION TAXEN TO AVOID FURTHER VIOLATION Training sessions will be conducted for onsite electrical contractor inspection personnel to re-emphasize the procedural requirements for documenting the installation of field changes that affect design documents issued for construction. In addition, training sessions will also be conducted for appropriate onsite Commonwealth Edison personnel to re-emphasize the established guidelines and methods for installing and documenting field changes that affect wiring diagrams issued for construction. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Revisions to the affected wiring diagrams were initiated on October 21, 1985. The training sessions discussed above are expected to be completed by February 21, 1986. 1155K
ATTACHMENT B CONSTRUCTION PROGRAM WEAKNESS 1 For two samples of radiographs for ASNE 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.
RESPONSE
In response to this concern, the Commonwealth Edison Manager of Projects and the Westinghouse Manager of Commonwealth Edison Projects became involved. The Westinghouse Product Assurance Department was directed to conduct an inventory of radiographs for all Byron and Braidwood equipment for i which. Westinghouse is responsible. The results of the inventory indicated that all radiographs that are required by Westinghouse quality release are either in the Westinghouse storage facility or in their vendors' storage facilities with the exception of the component cooling surge tank. l Westinghouse considers these radiographs to be lost, however other documents related to these radiographs are available which support the acceptance of the radiography on this tank. l In addition, the Commonwealth Edison Quality Assurance Department has been directed to add radiograph retrievability as a quality element in their next scheduled audit of Westinghouse. They will check Westinghouse's audit activity in this area as well as their ability to retrieve radiographs. I We believe the appropriate level of management attention has been given to this issue and the actions taken address not only the Byron Project. but also the Braidwood Project. } 1155K
CONSTRUCTION PROGRAM WEAKNESS 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.
RESPONSE
As this issue was identified during the course of the CAT inspection, 'an engineering evaluation of the problem was performed. The evaluation considered the as-found condition of the affected bolted connections in Unit 2 structural steel and NSSS supports. The results of this evaluation indicated that the bolted connections found with torque values below the inspection torque had no design significance. Since Byron Unit I was operating at the time of this inspection, this concern was further evaluated to determine any potential effect on Unit ~ 1 operation. This was accomplished by applying the as-found torque values of the bolts in the affected Unit 2 connections to the corresponding bolted connection in Unit 1. From this evaluation, it was concluded that there should not be any hardware deficiencies of design significance in Unit 1. In order to further support this conclusion, a commitment was made to reinspect the corresponding bolted connections on Unit 1 during the next scheduled outage. This was accomplished during the October - December, 1985 outage. The as-found torque values in the corresponding Unit 1 structural steel bolted connections were similar to those found in Unit 2. The detailed engineering evaluation of these Unit 1 connections likewise concluded there was no design significance in the as-found condition. However, the bolts found to have torque values less than the inspection value were retensioned to restore margin. The as-found torque values in the corresponding Unit 1 NSSS support steel connections were similar to those found in Unit 2 except some of the Unit 1 bolts exhibited lower as-found torque values than the corresponding connections in Unit 2. Therefore, all Unit 1 connections of this type were reinspected. A detailed engineering evaluation of the as-found condition of all these connections concluded there was no design significance. Nevertheless, all the bolts found to have torque values less than the inspection value were retensioned to restore margin. Based on the discussion above for Unit 1 and the response to Violation Ib concerning Unit 2, we believe the appropriate level of management attention has been applied to this issue to assure that completed installations meet design requirements for bolted connections in structural steel and NSSS supports. j 1155K
I CONSTRUCTICN PROGRAM WEAKNESS 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 ares, the foundation mounting welds of several pieces of Class IE 4160V switchgear and 125V DC fuse panels were not in accordance with design requirements.
RESPONSE
Wirina for Motor Doerated Valves A number of motor operated valves identified by CAT inspectors contained wiring which was not terminated at the termination points identified on some design drawings. The as-found wiring terminations resulted in electrical circuitry which was functionally acceptable when compared to the control schematic diagram. However, the specific details of some termination points were not per the wiring diagram. These minor discre-pancies were corrected by revising the wiring diagrams to reflect the as-wired condition. t During the CAT inspection, an evaluation of the as-found Unit 2 wiring discrepancies on the corresponding Unit 1 valves resulted in the same conclusion. The valves would perform their design function. During the October - December, 1985 Unit 1 outage, the affected valves in Unit 1 were reinspected to confirm this. It was determined that all the valves' wiring was terminated per the wiring diagram, as well as per the control schematic diagram. The " speed memo" discussed above only provides wiring details which supplement design details shown on wiring diagrams. This memo does not provide any instructions or details which would result in a valve being wired such that it would not conform to approved wiring diagrams. Consequently, there is no requirement to control this memo as a design document. Based on the proceeding discussion, we have concluded that the completed installations of motor operated valves meet design requirements and no further management attention is warranted. Mountina of Electrical panels and Switchaear As identified in the CAT Inspection Report, deficiencies were observed by NRC inspectors in hold down welds associated with certain switchsaar units and a fuse panel. The report further stated that similar deficien-cies were previously identified by the licensee on Unit 1 equipment. These similar Unit 1 deficiencies had been identified as a result of the Quality Control Inspector Reinspection program which was a corrective
. Mountina of Electrical Panels and Switchaear (Cont'd) action program executed as a result of NRC Violation 50-454/82-05-19. That program was executed to verify that inspections performed by Quality control Inspectors prior to september. 1982 were valid inspections. The discrepancies found upon reinspection were evaluated and found to have no design significance. It was concluded that no further expansion of the reinspection effort was necessary. Further to this activity, as a result of the corrective actions taken in response to WRC Violation 50-454/80-25, the electrical installation procedures were revised in the 1981 time frame to be more prescriptive and detailed. As a result of the foregoing, we judge that no additional management action is warranted with regard to electrical equipment mounting and that completed installations in this area meet design requirements. 1155K
tr3 Cb,. 3 q CORRESPO q C. p us unneo ssAins ff 0, NUCLEAR REGULATORY COMMISSION ri f ( .e REGtON 111 e 5^ E 799 ROOSEVELT RO AD E ED 8 GLEN ELLYN. ILUNOIS 40137 ,g December 12, 1985 W W -7 R2:21 FFICE fsch4,, ;f Docket No. 50-454 F OcMET Docket No. 50-455 BRANC Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen: This refers to the Construction Appraisal Team (CAT) inspection (Report No. 50-455/85027) conducted by the Office of Inspection and Enforcement on August 19-39 and' September 9-20, 1985, of activities at Byron Nuclear Power Station, Unit 2, authorized by NRC Construction Permit No. CPPR 131. Inspection Report No. 50-455/85027 was issued November 13, 1985. During this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice. A written response is required. The CAT report identified three construction program weaknesses that require increased mitiaQement attention in the Executive Summary of Report No. 50-455/85027 under Overall Conclusions. Please address each of these concerns in your response. In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosure, and your response to this letter will be'placed in the NRC Public Document Room. The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. We will gladly discuss any questions you have concerning this inspection. Sincerely, Sha.dk T.DA Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
Notice of Violation See Attached Distribution
.g-Commonwealth Edison Company 2 December 12, 1985 Distribution cc w/ enclosure: D. ' L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager-Gunner Sorensen, Site Project Superintendent R. E. Querio, Plant Manager DCS/RSB (RIDS) Licensing Fee Management. Branch Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr., Esq. Diane Chavez, DAARE/ SAFE Steve Lewis, ELD L. 01shan, NRR LPM H. S. Taylor, Quality Assurance Division
NOTICE OF VIOLATION y Commonwealth Edison Company Docket No. 50-455 P.O. Box 767 Construction Permit No. CPPR-131 Chicago, IL 60690 As a result of the inspection conducted on August 19-30 and September 9-20, 1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR.Part 2, Appendix C), the following violations were identified (Section references are to the detailed portion of Inspection Report 50-455/85027): 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 commitments to IEEE Standard 420, which prohibits 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. Installation 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.1.b) During the inspection, concrete expansion anchors were found which c. did not meet the required 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 inspection procedures. (Section V.B.2.b) This is a Severity Level IV violation (Supplement II). (455/85027-01) 2. 10 CFR 50, Appendix B, Criterion VII, as implemented by Ceco QAM, Quality Requirements No. 7.0, requires measures shall be established to assure that purchased material, equipment, and services conform to the procurement documents.
Notice of Violation 2 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, other electrical equipment, and HVAC equipment) were not of the material required by specifications or drawings. (Sections IV.B.11 and VI.B.1.b(2)) This is a Severity Level IV violation (Supplement II). (455/85027-02) 3. 10 CFR 50, Appendix B, Criterion X, as implemented by CECO QAM, Quality Requirement 10.0, requires that a program for inspection of activities shall 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 1E electrical raceways have not been installed in accordance with FSAP. commitments for electrical separation. (Section II.B.1.b.(1)) c. Some Class 1E 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)) This is a Severity Level IV violation (Supplement II). (455/85027-03) Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. N4adL Y k December 12, 1985 Dated Charles E. Norelius, Director Division of Reactor Projects
r-e v f EU CORREsponogyg nua UNITED STATES 13 $ g NUCLEAR REGULATORY COMMISSION N I c WASHINC. TON, D. C. 20655 DO(,K[ T[D USNRC November 13, 1985 Docket No. 50-455 '82 MAR -7 R2 :21 gfFluW1!c..fD-OWfgCya Commonwealth Edisor. 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 inspection. Within these areas, the effort consisted primarily of detailed 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 Summary 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 licensee'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 weaknesses 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 understand that an evaluation of the findings of this inspection has been made to determine the effect on Byron Unit 1 operations.
t. ? Commonwealth Edison Company -2 November 13, 1985 Appendix B to this letter contains a list of potential enforcement actions based on the NRC CAT inspection observations. These art being reviewed by the Office of Inspection and Enforcement and the NRC Region III Office for 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, pier.se contact us or the Region III Office. Sincerely, f mes M. Tay1 , Director ffice of Inspection and Enforcement
Enclosures:
1. Appendix A, Executive Summary 2. Appendix B, Potential Enforcement Actions 3. Inspection Meport cc w/ enclosures: See next page
s v Commonwealth Edison Company November 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 (Braidwood Station) Mr. V. I. Schlosser U.S. Nuclear Regulatory Commission Project Manager RR #1, Box 79 Byron Station Bracev111e, IL 60407 P.O. Box B Byron, IL 61010 Mr. Gunnar Sorenson Byron Station Commonwealth Edison Company P.O. Box B Byron, IL 61010 Byron Power Statinn 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. Diane 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
APPENDIX A EXECUTIVE SUMARY 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 comitments. 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. Son 2 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 IE 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 appli-cable design requirements and installation specifications. However, several discrepancies were identified including some which will require additional management attention. A-1
Wiring workmanship deficiencies were observed in several Class IE components. 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 IE 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 No'ndestructive 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
steel and equipment supports did not meet inspection torque values. As a result, connection clamping force requirements were not met. Reinforced concrete construction in general was adequate. Inconsistencies with embedment length requirements of concrete expansion anchors exist between the concrete expansion anchor qualification report and field inspection procedures. Data was not provided to detemine 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 caterial 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 HVAC duct sections. Design Change Control Design change control was detemined 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. A-3
t t APPENDIX B POTENTIAL 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 !!! as Potential Enforcement Actions. Section references are to the detailed portion of the inspection report. 1. 10 CFR 50, Appendix B, Criterion !!! as implemented by Comonwealth 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 thir inspection, the licensee's program was not adequately implemented in that: a. Splicing of Class IE wiring in panels has occurred at Byron Station contrary to the FSAR comitments to IEEE Standard 420, which prohi-bits the use of wiring splices in panels. FSAR comitments 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 struct m l 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 in:,pectors 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 CECO 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 1E equipment. (SectionII.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.I.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
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT DIVISION OF INSPECTION PROGRAMS REACTOR CONSTRUCTION FROGRAMS BRANCH Report No.: 50-455/85-27 Docket No.: 50-455 Licensee: Coninonwealth Edison Company Facility Name: Byron Station, Unit 2 Inspection At: Byron, Illinois Inspection Conducted: August 19-30 and September 9-20, 1985 b /o/ r/tr Inspectors: H. J. Wong,%r. ReactofConstruction Engineer Date Signed Team Leader f_ u / k b ?' & J tabeler , G. B. grgieV, Sr/ Reactor \\gonstruction Engineer Date' Sighed A('. Lu whe/er G. C. Gower, Sr. Reactor Construction Engineer Date Signed Gf 771aMw iobe/er Jf A. Malloy, R ctor Inspector (Region III) Date Sfgned ?RA l0l/WW I. Remoto, Reactor Construction Engineer Date 51gned rs+fffho hh /P -/f f f H. W. Ptfillips, ReactoP Construction Engineer Date Signed Consultants: R. M. Compton, D. C. Ford, J. B. McConnack, O. P. Mallon, W. S. Marini, E. Y. Martindale, R. E. Serb, W. J. Sperko, Jr., and D. G. Whatley Approved By: U
- /f'/fa R~obert F. Heishman, Chief Date Signed Reactor Construction Programs Branch 1
TABLE OF CONTENTS TOPIC SECTION INSPECTION SCOPE AND OBJECTIVES...................................s,.. I ELECTRICAL AND INSTRUMENTATION CONSTRUCTION.......................... II MECHANICAL CONSTRUCTION.............................................. III WELDING AND NONDESTRUCTIVE EXAMINATION............................... IV CIVIL AND STRUCTURAL CONSTRUCTION.................................... V MATERIAL TRACEA8ILITY AND CONTR0L.................................... VI DESIGN CHANGE CONTR0L................................................ VII CORRECTIVE ACTION SYSTEMS............................................ VIII ATTACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED ATTACHMENT B - GLOSSARY OF ABBREVIATIONS
I. INSPECTION SCOPE AND OBJECTIVES The objective of this inspection was to evaluate the adequacy of construc-tion at the Byron Unit 2 Station. This objective was accomplished through review of the construction program, evaluation of project construction controls, and review of selected portions of the Quality Assurance Program, with emphasis on the installed hardware in the field. The scope and significance of identified problems were also determined., Within the areas examined, the inspection consisted of a detailed examina-tion of selected hardware subsequent to quality control inspections, a selective examination of procedures and representative records, and limited observation of in-process work. For each of the areas inspected, the following was determined: Were project construction controls adequate to assure quality construction? Was the hardware or product fabricated or installed as designed? Were quality verifications performed during the work process with app cable hold points? Was there adequate documentation to determine the acceptability of installed hardware or product? Are systems turned over to the startup organization in operable condition and are they being properly maintained? 1-1 P - a
a II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION A. Ob.iective The primary objective of the appraisal of electrical and instrumentation construction was to determine whether Class 1E components and systems were installed in accordance with regulatory requirements," Safety Analysis Report (SAR) commitments and approved vendor and construction specifications and drawings. Additional objectives were to determine whether procedures, instructions and drawings used to accomplish construction activities were adequate and whether quality related records accurately reflect the completed work. B. Discussion Within the broad categories of electrical and instrumentation construc-tion, attention was given to several specific areas. These included electrical cable, ract. ways and raceway supports, electrical equipment, and instrumentation cable and components. Additionally, an examination of components which comprise a selected process system was accomplished. A number of documents were generated by the licensee to record individual observations of the NRC Construction Appraisal Team (CAT) inspectors, these are referenced directly in the discussions that follow. 1. Electrical Raceway Installation a. Inspection Scope Fifty-seven segments of installed Class 1E cable tray representing a total length of about 1,100 feet, were selected from various plant areas for detailed examination by the NRC CAT inspectors. These segments were inspected for compilance to requirements relative to routing, location, separation, support spacing and configuration, identification, protection and physical loading. Additionally, 24 runs of installed conduit, with an aggregate length of about 850 feet, were inspected for compliance to specified requirements such as routing, location, separation, bend radii, support spacing and associated fittings. Over 25 raceway supports were examined in detail for such items as location, material, anchor spacing, weld quality, bolt torque and installed configuration. Also examined were over 120 concrete expansion anchors. See Table 11-1 for a listing of cable tray, conduit and raceway support samples. The following documents provided the basic acceptance criterla for the inspection: Sargent & Lundy (S&L) Specification F-2790 " Electrical Installa-l tion Work Byron Station - Units 1 and 2," Amendment 46. l !! 1
Hatfield Electric Company (HEco) Quality Control Procedure 9A, l l " Class ! Cable Pan Hanger Installation," Revision 13. l HEco Quality Control Procedure 98, " Class ! Cable Pan Installa-tion," Revision 15. HEco Quality Control Procedure 20. " Class ! Exposed Conduit System Installation," Revision 14. e S&L " Standard Specification for Concrete Expansion Anchor Work," Revision 6. b. Inspection Findines In the area of electrical raceway, the NRC CAT inspectors observed that, in general, Class 1E raceway installations were in accordance [ with applicable design criteria. Quality attributes such as material type, location, identification and installed configura-tion were found to be as shown on approved construction drawings. However, several design and/or construction deficiencies were identified and are discussed below. (1) Raceway separation l The Byron Station Final Safety Analysts Report (FSAR) Section 8.3.1.4.2 " Physical Separation Criteria" provides the basic i criteria for acceptable raceway and cable installations. This FSAR section describes commitments for physical arrangement. of I raceways pertaining to the requirements of Regulatory Guide i (RG) 1.75 for independence of redundant systems. In general, these F5AR criteria specify the physical separation l that must be maintained between components of redundant electrical divisions. Additionally, separation is required between components performing Class 1E and non-Class 1E I functions. The NRC CAT examination of electrical raceways indicates that a I number of installations are not in accordance with the FSAR I requirements. See Table !!-2 for a listing of specific raceway separation deficiencies. Many of the deficiencies identified involve the spatial relationship between Class 1E and non-Class 1E components, and are the result of a failure to translate relevant FSAR requirements into contractor inspection procedures. The NRC i CAT inspectors reviewed HEco Quality Control Procedure 98, l i l " Class I Cable Pan Installation," and noted that a requirement i of only 1 inch separation had been spectfled between cable tray i and condutt installations. Thie distance ia not in accordance with FSAR requirements which specify 12 inches vertical and 3 l inches horizontal separation. Consequently, many raceways [ which exhibit less than the FSAR required physical separation had not been identified by inspection personnel. t 11 2 i I
o I As a result of this observation the licensee has indicated I that a walkdown will be perfonned to ensure that deficiencies are identified. Procedure PI-88-53 will be implemented on a sampling basis to identify conduit to tray separation deficien-cies. Additionally, during the inspection Sargent A Lundy prepared the calculation 4391/19Q-15. " Justification of Electrical Separation Distance Between Safety-Related and Non-Safety-Related Raceways." This calculation was prepared to justify separation distances of less than 12 inches vertical and 3 inches horizontal between Class 1E conduits and non-Class IE cable trays or between Class IE cable trays and non-Class 1E conduits. This analysis will be presented to NdR for evalua-tion. Additional deficiencies were identified between raceway compo-nents which exhibited less than 1 inch of physical separa-tion. Several of these raceways contain cables required for Unit 1 operation and as such, were installed in the early stages of Unit 2 construction. A review of more recent coreatruction activities indicate that separation deficiencies i had been identified and documented by inspection personnel. As a result of these observations the licensee issued Conduit Separation Notification Reports CSNF-78 through CSNF-86 to identify and evaluate these conditions. In sumary, the review of construction activtties indicates that quality verification programs have not been adequate to assure that FSAR comitments relative to electrical separation have been met. Addltionally, recently completed analysis which provides technical justification for existing separation deficiencies will require additional evaluation by the NRC. (2) Electrical Conduit Wf th the exception of the specific deficiencies listed below the conduit sample inspected confonned to applicable design and installation requirements relative to such attributes as size, routing, identification and supports. Conformance to separa-tion requirements are discussed in Section !!.B.1.b.(1), i Raceway Separation, above. Conduit C2R3452 was found to be missing the required segrega-tion code marker at its entrance to junction box 2JB417R. Several damaged flexible condutts were observed which terminate at cubicle coolers 2VA035A and 2VA02SB. The damage to conduit 2VA035A had been previously identified by the licensee on OR-7261. However, damage to conduit 2VA0258 had not been documented. As a result of this observation Rework Request 6970 and 69/1 were issued to correct both deficiencies. i Damaged flexible conduit C2Rl!87 was observed at flow trans-mitter 2FT-415. The licensee subsequently issued Deficiency Report (OR)-8015 to document this condition. !! 3
l l I j No other deficiencies were identified in this area. (3) Raceway Supports The examination of raceway supports was accomplished for both conduit and cable tray applications. Attributes such as location, material type and sfre, anchor spacing, welds (location, site and general quality), and installed configura-tion were found to be in accordance with design requirements. During the examination of cable tray supports. NRC CAT inspec-tors identifled a loose attachment bolt on a horizontal member of support H060. As a result of this observation Ceco has l initiated DR-7810 to document and correct this condition. Cable tray support H011 contained one spring nut which had been improperly installed. The Ifcensee has issued Rework Request 07202 to document and correct this condition. Concrete expansion anchor deficiencies were identiffed on several raceway supports. These included items such as missing washers on supports W$-32 and WCA-1 and anchors which failed to exhibit the required torque on support WCA-1 and junction box 2JB126R. Although several deficiencies were identified in this area. NRC CA" inspectors consider them to be isolated and in general, the insta11atten of raceway supports was in accordance with requirements. c. Conclusions l Except as noted, raceway systems have been installed in accordance l with applicable design and installation requirements. Physical separation criteria detailed in the licensee's FSAR have not been maintained in a number of raceway installations. Many of the deficiencies identiffed involve the spatial relationship between Class !! and non-Class 1E components, and are the result of a fatture to translate relevant FSAR comitments into contractor inspection procedures. However, preliminary discussions with NRR and the results of recently completed tests and analysis by the Ifcensee indicate that lesser separation may be acceptable. This matter remains open pending NRC final review and evaluation. i l l !!-4
l l 2. Electrical Cable Installation l a. Inspection Scope The NRC CAT inspectors selected a sample of installed Class 1E-cable runs that had been previously accepted by Quality Control (QC) inspectors. The sample included high voltage, power, pontrol and instrumentation cabling. For each of the cable runs, physical inspection was made to ascertain compliance with appilcable design i criteria relative to size, type, location / routing, bend radii, protection, separation, identification and support. Additionally, the NRC CAT inspectors selected approximately 300 cable ends for examination. These were inspected to applicable i design and installation documents for items such as lug size and type, proper terminal point configuration, correct identification of cable and conductors, proper crimping of lugs or connectors and absence of insulation or jacket damage. See Table II-3 for a listing of cable terminations examined. The following high voltage and power cable, totaling about 1,500 feet, were selected from different systems, electrical trains and locations: Cable h 2RH001-P1E 3/C #2 5KV l 2RH008-P2E 3/C #2 SKV 25!001-PIE 3/C #2 SKV l 2AP288-PIE 3/C 500 MCM l 2RC085-P1E 3/C #6 600V The following control cables totaling approximately 1,050 feet were selected from different systems, electrical trains and locations: Cable h i 2RH010-C2E 9/C #14 600V 2MS284-CIE 1/C #4 600V 2MS315-C1E 9/C #14 600V l 2RC092-C1E 12/C #14 600V l 2RH037-C2E 12/C #14 600V l 25!398-C2E 1/C #14 600V The following instrument cable totaling approximately 1,050 feet were selected from different systems, electrical trains and locations: !!-5
i Cable Tray 2RC224"K4R 1 TW PR #16 600V 2RC428-K3R 1 TW PR #16 600V 3 2RY203-K2R 1 TW PR #16 600V 2RY210-K4R 1 TW PR #16 600V 2RC337-K1R 2 TW PR #16 600V 1 2RC376-K2R 1 TW PR #16 600V The following documents provided the basic acceptance criteria for the inspection: S&L Specification F-2790, " Electrical Installation Work Byron Station - Units 1 and 2," Amendment 46. HEco Quality Control Procedure 11 " Class 1 Cable Termination and Splicing," Revision 21. e HEco Quality Control Procedure 10 " Class ! Cable Installation," Revision 23. b. Inspection Findings I (1)-Routina i In general, the routing of Class IE cables through design designated raceway systems was found to be in accordance with i specified criteria. Each of the Class 1E cables examined by NRC CAT inspectors had been installed in accordance with the 1 routing detailed on the pull ticket. (2) Separation In general, separation of Class 1E cables was found to be in. accordance with requirements. Several separation deficiencies i were observed in cables and vendor wiring installed inside of i electrical equipment. However, for each of the deficiencies t l identified the licensee had previously initiated the appro-i priate documentation to assure that the condition was subse-quently evaluated or corrected. The NRC CAT inspectors reviewed the separation of " Quasi-safety-related" cables. These are described by Sargent & Lundy j as Class IE cables which have been identified with non-Class 1E segregation codes and in some instances have been routed in non-Class 1E raceways. (Classification and use of " Quasi- { safety-related" cables is discussed in Section II.B.2.b.(5) of this report). Based upon discussions with the licensee, Interface Review ) Reports (IRR) are prepared to assure proper separation of 1 " Quasi-safety-related" cables when they share an equipment i enclosure with Class IE cables. Cable Separation Criteria Violations (CSCV) are prepared for " Quasi-safety-related" l j cables which share a raceway with Class 1E cables.
- However,
} II-6 i
e NRC CAT inspectors noted that non-Class IE raceway does not receive Quality Control inspection, and as such, electrical separation would not have been verified for the routing of these " Quasi-safety related" circuits when routed in non-Class 1E conduits. NRC CAT inspectors concluded that, additional licensee attentior. is required to assure that these cables maintain the degree of physical separation specified by the FSAR. See Table II-4 for a listing of " Quasi-safety-related" cables. Section II.B.2.b.(5) " Cable Identification" of this report details additional concerns regarding " Quasi-safety-related" cables. (3) Power Cable Spacing and Dorating Byron Station power cable installations have been designed in accordance with Insulated Power Cable Engineers Association (IPCEA) publications P-46-426, 1962 " Power Cable Ampacities - Volume I - Cooper Conductors" and P-54-400, 1972 "Ampacities - Cables in Open Top Cable Trays." Power cables have been derated in accordance with the IPCEA standards such that cables sharing raceways may be in contact. No deficiencies were identified in this area. (4) Cable Damage No specific instances of Class IE cable damage were identified during the NRC CAT inspection. However, several Class IE cables were observed whose ends had not been taped or sealed after installation thus exposing conductor ends to the environ-ment and construction activities. While not a procedural requirement, NRC CAT inspectors consider this to be a workman-ship weakness in that the potential for cable damage is increased when cable ends remain unsealed. (5) Cable Identification The identification of Class 1E cable generally conformed to the applicable requirements and for most of the samples examined was found to be in accordance with applicable design criteria. However, one area of deficiency was identified and is discussed in the following section. The Byron Station FSAR section 8.3.1.3.4 describes requirements for cable identification as follows "...All power control and instrumentation cables are identified by a unique number of permanent color coded tags... The tags shall be color coded as in Table 8.3.4, allowing positive II-7
identification of safety related cables." Section 8.3.1.4.3 describas cable segregation codes and specifies that cables will be segregated based on the following categories: E = Engineered Safety Features 8 = Non-Safety-Related R = Reactor Trip N = Neutron Monitoring A = Associated Section 8.3.1.4.3 states, in part..."Each non-Class IE cable which has any part of it's length in a Division 11 (21) or 12 (22) tray, connects to a Class IE power system, shares an enclosure with a Class 1E circuit, or is not physically separated from Class IE cables by acceptable distance or barriers, is a division associated cable (Category A)." During the examination of Class 1E cables NRC CAT inspectors identified a number of "B" non safety-related cables which had been installed in Class IE raceways. Subsequent discussions with the licensee and Sargent & Lundy personnel disclosed that these were " Quasi-safety related" cables and were installed in accordance with design requirements. NRC CAT inspectors were not able to determine the function of these cables because they are not defined in the Byron Station FSAR or on approved design documents. However, based upon discussion with Sargent & Lundy personnel " Quasi-safety related" cables are described as cables which are part of a Class 1E circuit, (serving a safety-related function) and have a portion of their routing in the Turbine building. Thus, safety-related cables have been identified as non-safety-related, because they are routed in a Category II structure. NRC CAT inspectors concluded that this method of identification was not in accordance with the licensee's FSAR commitments which state that non-safety-related cables sharing an enclosure with safety-related cables become and are identified as division associated cable (Category A). Additional concerns regarding separation of " Quasi-safety-related" cables are discussed in Section II.B.2.b.2 of this report. See Table II-4 for a listing of " Quasi-safety-related" cables. As a result of this observation the licensee has proposed an amendment to the FSAR which would define the function and handling of these cables. (6) Terminations In general, cable termination activities performed by construction c rsonnel conformed to requirements. However, several construction deficiencies were identified and are 1 discussed in the sections which follow. l II-8 i
Termination of internal wires at terminal point TBR-24 of panel 2PA02J are improperly installed, due to spooning of terminal lugs. Subsequent to this observation the licensee has issued DR-7856 to document and correct this condition. The terminal lug on the "Wht" conductor of cable RIP 023 in panel 2AP02J was observed to be excessively bent at terminal point TPT-2. As a result of this observation the licensee has issued DR-7855 to correct this condition. Insulation on the "Blk" and "Wht" conductors of cable 2FW876 'was found cut to the bare conductor at terminal points TBR-1 and TBR-2 of panel 2PA02J. The licensee has issued DR-7854 to correct this condition. The "Bik" and "Wht" conductors of cable 2WO203 are landed on terminal points 32-3 and 32-7 instead of terminal points 33-2 and 33-7 as required on the approved design drawing 2-4054G, Revision F. Subsequent to this observation the licensee has issued DR-7857 to document and correct this condition. Several violations of conductor minimum bend radius require-ments were observed. These occurred predominantly in panel wireways, where there was congestion of field installed cable. Bend radius deficiencies were observed in several Class IE panels but occurred frequently in sections of the Main Control t Boards and the Diesel Generator Control panels. As a result of this observation the licensee issued the folicwing Discrepancy Reports 7852, 7853, 7858 and 7860. NRC CAT inspectors concluded, based upon the quantity and frequency of deficiencies identified that additional licensee attention will be required in this area to assure that Class IE wiring configurations conform to requirements and general workmanship standards. l During the examination of internal wiring in panel 2PA13J, one wire with a blue outer jacket was observed. This wire was i physically bundled with other Class IE wires within the panel. Further investigation disclosed that this wire is General Electric type SI58101, which is not qualified for Class IE service. As a result of this observation the licensee initiated the following actions: I - Rework Request 6937 was initiated to replace the j subject wire with a qualified length of wire. i - Analysis IRR-2EF088-1 was presented which justifies the bundling of this non-1E wire with the IE wiring within this panel. l l II-9
- Correspondence was produced which instructs field forces to use only two types of switchboard wire at the Byron site. These are: Vulkene E-11352-1 (with yellow outer jacket) which may be used for drain wire extentions; and Rockbestos Firewall SIS, which shall be used for all other applications. During the course of this inspection, NRC CAT inspectors found no additional instances of unqualified switchboard wire, and as such, have determined the above wiring to be an isolated case. During the examination of Class IE cable terminations NRC CAT inspectors identified numerous :onductors which contained in-line butt splices. The use of in-line butt splices is not consistent with the licensee's FSAR commitment to IEEE 420, which prohibits the use of wiring splices in panels. As a result of this observation the licensee has proposed an FSAR amendment to resolve this condition. The NRC CAT inspectors examined the installation and use of Raychem heat shrink in Class IE terminations. During the inspection several deficiencies were observed and are discussed below. NRC CAT inspectors reviewed drawing (6E-2-3503) which specifies the.use of Raychem heat shrink jacket tubing in Class 1E terminations. The drawing stipulates that use of this material is qualified by the following note: "To obtain the required qualified version of this tubing the purchase order must state the following: Raychem type WCSF-U shrinkable sleeve, documentation to include certification of compliance, (Raychem No. ~ ENGC-154) certifying that material has been tested to the requirements of IEEE 323-1974 and IEEE 383-1974 for aging, radiation, and local environment, as indicated on Raychem reports EDR 2001 and EDR 5019." NRC CAT inspectors observed that Raychem report EDR 5019 had tested type WCSF-N heat shrinkable tubing. However, the WCSF-U tubing specified on drawing (6E-2-3503) had not been tested by this report. Discussions with the manufacturer (Raychem) indicates that the chemical / physical makeup of both WCSF-N and WCSF-U are identical. However, WCSF-N tubing contains an additional l adhesive which is used to meet the requirements of Section 2.4.3 of IEEE 383 for environmental seal during LOCA l simulation. II-10 "r = ~ ~ w
Based upon these discussions and review of the applicable portions of IEEE 383 NRC CAT inspectors concluded that Raychem type WCSF-U tubing was not qualified for LOCA conditions and as such could not meet the requirements specified.on the licensee's design drawing. In connection with this issue NRC CAT inspectors reviewed the Certificate of Compliance provided with WCSF-U type material and observed that the vendor (Raychem) had certified qualification per the instructions of the design drawing mentioned above. Based upon the information and. discussions presented above, NRC CAT inspectors concluded that the Certificate of Compliance was in error in that, WCSF-U material does not meet the requirements of section 2.4.3 of IEEE 383. As a result of this observation the licensee has initiated a design change to correct the wording of the note on drawing GE-2-3503 and to assure that WCSF-U heat shrinkable sleeve will be used only as an outer jacket on nuclear qualified Class 1E terminations. Additional deficiencies were observed in activities associated with wiring of Class IE valve operators. This subject is discussed in detail is Section II.B.3.b.(8) of this report. c. Conclusions The identification and routing of some Class 1E cabling (" Quasi-safety-related) is not in accordance with FSAR commitments to j Regulatory Guide (RG) 1.75 for " Physical Independence of Redundant l Systems." Increased licensee attention is necessary in the workmanship of cabling and terminations in that some terminal lugs were improperly installed, insulation cut, improper termination points, and minimum bend radius violations. Although each instance was not individually significant, additional attention is warranted. The use of in-line butt splices on wiring in electrical panels is not in acco-dance with FSAR commitments. 3. Electrical Equipment Installation a. Inspection Scope Approximately 40 pieces of installed or partially installed electri-cal equipment and associated hardware items were inspected. Samples were selected based on system function and safety classification. The following specific electrical components were inspected in detail: l 11-11
(1) Motors The installation of five motors and associated hardware was inspected for such items as location, anchoring, grounding, identification and protection. The motors inspected were: Residual Heat Removal Pump Motor 2RS01PA Residual Heat Removal Pump Motor 2RH01PB Safety Injection Pump Motor 2SIO1PA Aux Feedwater Pump Motor 2AF01PA Component Cooling Pump Motor 2CC01PB (2) Electrical Penetration Assemblies The location, type, mounting and identification of these penetrations were compared with the installation drawings and vendor manual. The following containment penetration assemblies were inspected: 2SIO2E-2P2E Misc. Power 2NR01E-2KN Neutron Monitoring 2SIO4E-2C2E Control 2SIO3E-2C1E Misc. Control 2LV10E-2K2E ESF Instrumentation (3) Circuit Breakers Circuit breakers for the following class 1E motors were examined to determine compliance with design and installation documents for size, type, system interface and maintenance. Residual Heat Removal Pump Motor (Bus 241 Cub. 19) Safety Injection Pump Motor (Bus 242 Cub. 19) The use of circuit breakers with integral undervoltage trip attachments at this facility was also investigated. (4) Switchgear and Motor Control Centers The following switchgear and motor control centers were inspected: Motor Control Center 2AP25E - MCC231X2 Motor Control Center 2AP26E - MCC231X4 Motor Centrol Center 2AP28E - MCC232X4 4160V Switchgear 2AP05E 4160V Switchgear 2AP06E (5) Station Batteries and Racks The 125V battery rooms including the installed batteries, battery racks and associated equipment were inspected. The location, mounting, maintenance and environmental control for II-12
installation of the batteries were compared with the applicable requirements and quality records. 125V DC Battery 20C01EA, 2DC01EB 125V DC Battery 2DC02EA, 2DC02EB (6) 125V DC System Equipment The following equipment comprising portions of the 125V DC systems were inspected for compliance to design documents for such items as location, mounting (welds, concrete anchors and bolting) and proper configuration. Battery Charger 20C03E Battery Charger 2DC04E DC Distribution Panel 2DC05E DC Distribution Panel 20C06E DC Fuse Panel 2DC11J NSSS Static Inverter 2IP06E (7) Control Panels A number of Class IE electrical control panels were inspected for compliance to design requirements for items such as loca-tion, mounting and type. The panels inspected were: Main Control Board 2PM06J Main Control Board 2PM01J Diesel Generator Control Panel 2PLO8J Aux Relay Cabinet 2PA31J ~ Aux Relay Cabinet 2PA27J Remote Shutdown Panel 2PLO4J ( (8) Motor Operated Valves (MOVs) Five motor operated valves were examined in detail. 2RH8702-A 2RC8001-B 2518808-0 2SI8809-B 2C5019-B As the result of deficiencies identified in this area addi-tional MOVs were inspected and are discussed in the body of the report. The following documents provided the basic acceptance criteria for the inspections:
- S&L Specification F-2790, " Electrical Installation Work Byron Station - Units 1 and 2," Amendment 46.
- HEco Quality Control Procedure 12, " Installation of Class 1E Equipe.ent," Revision 8.
11-13 L
- HEco Quality Control Procedure 12A, " Modification of Class IE Equipment," Revision 10.
- S&L " Standard Specification for Concrete Expansion Anchor Work" Revision 6.
b. Inspection Findings (1) Motors In general, the installation of Class 1E motors was found to be in accordance with applicable design documents. Motors examined were of the size, typa and configuration specified and construction maintenance activities had been performed in accordance with approved procecures. However, deficiencies in the areas of motor mounting and post-construction maintenance activities were identified. 4 Reference Section VI " Material Traceability and Control," for a detailed discussion of these deficiencies. (2) Penetrations. Penetrations examined were found to have been Installed in i accordance with applicable design documents. Installation requirements including performance of required maintenance activities had been accomplished in accordance with approved construction procedures. I No construction or maintenance deficiencies were observed in this area. (3) Circuit Breakers The examination of the Westinghouse type 50DHP350 circuit breakers indicated that they had been purchased, installed and maintained in accordance with the applicable design documents. Important installation attributes such as proper alignment, main contact penetration and safety interlocks were verified by physical inspection and review of construction test records. Maintenance records were also reviewed and indicate that lubrication and set point verification had been performed. I NRC CAT inspectors also evaluated licensee initiated actions and review of NRC Information Notice 83-18 " Failures of the Undervoltage Trip Function of Reactor Trip System Breakers" and NRC Generic Letter 83-28 " Required Actions Based on j Generic Implications of Salem ATWS Events." Byron Station Units 1 & 2 will utilize the Westinghouse type DS-416 breakers in the Reactor Trip System. Review of supplemental actions to Generic Letter 83-28 indicates that the licensee will implement Westinghouse proposed corrective actions and will l ensure that all DS-416 reactor switchgear undervoltage i attachments are replaced with a new design and tested prior to II-14
the fuel load. This work will be controlled by Westinghouse. Field Change Notice (FCN) CBEM 10685. (4) Switchgear and Motor Control Centers In general, the installation of Class 1E Motor Control Centers was found to be in accordance with applicable requ,irements. However, examination of the Class IE 4160V switchgear units indicates that several construction deficiencies exist. During the examination of switchgear units 2AP05E and 2AP06E NRC CAT inspectors observed that hold down welds do not match the configuration detailed on approved design drawings. Detail 47 on drawing 0-3391C specifies a four sided weld at each of six locations per cubicle. Actual field configurations were found to have welds on only two sides. Additionally, a detailed examination of these welds indicates in some cases insufficient weld metal due to gaps between the embed plate and the equipment sheet metal. NRC CAT inspectors reviewed the associated QC inspection records for this equipment and observed that these deficiencies had not been identified by inspection personnel. Similar deficiencies were previously identified by the licensee on Unit 1 equipment. However, they had not been reviewed for impact on relevant Unit 2 equipment. As a result of this observation the licensee has initiated CECO Nonconformance Report (NCR) 1669 to document and correct this condition. (5) Station Batteries and Racks The condition of the battery rooms was found to be in good order, clean and free of debris. Ventilation systems were installed and in operation. Access to these areas was controlled by keyed entry, and the appropriate danger signs had been posted to prohibit smoking or open flames. The 125V batteries were examined and found to be in good condition. Maintenance activities were reviewed and, in general, had been performed in accordance with requirements. During the review of battery maintenance records, NRC CAT inspectors noted that intercell resistance data had exceeded the acceptance level of 150 micro-ohms between cells 46 and 47 of battery bank 212. The review of associated surveillance records indicates that this deficiency had been properly documented and the condition had been corrected in accordance with the requirements of Deviation Report 06-02-84 and Nuclear Work Request 811357. II-15 ...,.-,o
I The inspection of the 125V battery racks disclosed that indeterminate bolting materials had been used in the assembly process. This issue is discussed in detail in Section VI, " Material Traceability and Control," of this report. NRC CAT inspectors also identified two anchor bolts which did not have the required embedment length. Sargent & Lundy specification for concrete expansion anchors requires a minimum embedded length (La) of four inches for a 1/2 inch nominal bolt diameter. Two of the bolts examined exhibited (Le) of only-3 1/2 inches. Discussions with the. licensee indicate that original inspection requirements did not include verification of (Le), consequently, these deficiencies had not been identi-fled. As a result of this observation the licensee initiated a ] Deficiency Report to document and evaluate this condition. Based upon this evaluation it was determined that the anchors are structurally sound and will perform their intended t function in the existing configuration. No other deficiencies were identified in this area. (6) 125V DC System With the exception of the mounting deficiency discussed below, inspection of components which comprise portions of the 125V DC system disclosed no deficiencies relative to the installed configuration of the equipment. l During examination of 125V DC fuse panel 2DC11J NRC CAT inspectors observed that the mounting weld configuration did not match the details shown on approved design drawings. Detail 158 of drawing 0-3391K specifies a maximum spacing of 10 1/2 inches between weld edges. Actual field measurements indicate that seven of ten weld to weld dimensions exceed this spacing requirements, some by as much as seven inches. Discussions with the licensee indicates that these deficiencies may be the result of inadequate contractor interface and inspection responsibility changes. As a result of this observation the licensee has issued Deficiency Report 7373 to document and correct this condition. (7) Control Panels The control panels examined were installed in accordance with applicable design documents. No deficiencies were identified in this area. II-16
(8) Motor Operated Valves In general motor operated valve termination activities performed by construction personnel conformed to, requirements. However, several wiring deficiencies were observed and are discussed below. The NRC CAT inspectors examined seven motor operated valves and found five which contained wiring not terminated at the correct termination points. The internal jumpers from termination points 3C to 17C and internal jumpers on termination points 3L to 13C were installed on MOVs 2RL 8001D, 2RL 80020 and 2RC 80020. These terminations were in conflict with wiring diagrams 6E-42308, 6E-4230C and 6E-42300. Motor operated valve 2RC 8002D had termination points 11 (black / white) and 11C (blue / black) reversed on cable 2RC 171 (wiring diagram 6E-42300).' Motor operated valve 2CC-9438 had internal jumper termina-tion points 17 and 17C reversed and 18 and 18C reversed (wiring diagram 6E-2-4861, speed memo between Steve Bindernagel and Tom Lamb dated 1-23-84). NRC CAT inspectors reviewed relevant inspection reports and observed that Hatfield Quality Control inspectors had accepted the installation of these MOVs. During discussions with the NRC CAT, Hatfield inspection personnel indicated that this condition exists on numerous motor operated valves through the Byron site. Discussions with the assistant supervisor of OAD indicated that the MOV wiring configurations had not been modified since construction turnover to 0AD. As a result, NRC CAT inspectors concluded that inspection activities had not been adequate to assure the MOV wiring was in accordance with applicable design documents. In connection with this issue NRC CAT inspectors determined that inspection ov MOV wiring to termin'al points 17, 17C, 18 and 18C could not be accomplished without the aid of a speed memo dated January 23, 1984, from Steve Bindernagel to Tom Lamb. This memo provides wiring details which supple-ment design details shown on approved wiring diagrams. However, further investigation disclosed that the speed memo was uncontrolled and not incorporated into design documents or procedures. Consequently, this area and associated inspection activities merit additional attention by the licensee. II-17
s (9) Equipment Idenficiation The Byron Station FSAR section 8.3.1.3 " Physical Identification of Safety-Related Equipment" states, in part..." Color coded nameplates or labels are used to distinguish between Class 1E and non-Class IE components and between components of different division, as shown in Table 8.3-4." Divisional color coding and identification of Class IE equipment is required so that plant maintenance and operations personnel may readily identify components which serve Class 1E functions. During the examination of Class IE electrical equipment NRC CAT inspectors identified several components which had not been labeled in accordance with FSAR requirements. The Unit 2 Diesel Generator Control panels and certain Class IE devices mounted on the Unit 2 Fire Hazards panel have been identified with black and white labeling which would indicate a non-Class IE classification. As a result of this observation the licensee has issued Design Information Transmittal (DIT) BB-EPED-0051 which proposes to revise FSAR section 8.3.1.3 to read " Nameplates with engraved characters identify each item of safety-related equipment. Each nameplate is either color coded as in Table 8.3-4 or has black characters on a white background." This item will remain open pending further NRC evaluatian. c. Conclusions The mounting of several pieces of Class IE electrical equipment are not in accordance with design requirements. Components such as, the 4160V switchgear divisions 1 & 2 and the 125V DC fuse panel have been installed with hold down weld configurations which do not match the details shown on approved design drawings. A number of deficiencies were observed in QC accepted wiring for Class IE valve operators. In this area over 50% of the sample i examined exhibited wiring configurations which were not in accordance with approved wiring disgrams. Consequently, this area ( and associated inspection activities will require additional atten-I tion by the licensee. The identification labeling of several pieces of Class 1E electrical equipment is not in accordance with FSAR requirements. 4. Instrumentation Installation a. Inspection Scope The NRC CAT inspectors selected a sample of 13 completed runs of instrument piping, comprising about 940 feet, for a detailed examination in accordance with specification requirements and isometric drawings. II-18 l
Three instrumer.'. racks and 18 piping supports were examined for conformance with requirements includirg installed configuration, mounting details, material conformance, identification, and location. Additionally, a process system was elected for a detailed inspection of signal path routing and associated equipment. Thirteen instruments were examined for conformance with requirements for location, mounting details, and instrument type and range. The signal path of three instrument loops were traced from their process connections to their final output devices. Loops examined were Pressurizer Pressure Division I and II and Pressurizer Level Divi-sion II. Components inspected for each loop included sensing lines, pressure and level transmitters, signal conditioning and isolating devices, indicating and controlling instruments and the various connecting cable, electrical penetrations, panel wiring and terminal points along the signal path. Most instrument components wore examined for such attributes as type, range, output, identification, qualification, location, mounting and physical separation of redundant components. See Table II-5 for listing of piping runs, supports, racks, and instruments included in the sample. The following documents provided the acceptance criteria for the inspection:
- S&L Specification F-2739/L2739, " Piping System Installation,"
Amendment 8.
- Powers-Asco-Pope (PAP) Procedure QC-9, " Quality Verification Procedure," Revision 3.
- PAP Procedure FP-9, " Design Change / Field Routing Control,"
Revision 10.
- PAP Procedure FP-13, " Hanger Installation and Control,"
Revision 14.
- PAP Procedure FP-16, " Identification and Marking of Pipe and Comparents," Revision 12.
- PAP Procedure FP-19, "As-Built Drawings and Documentation,"
Revision 3. Applicable design drawings and change documents, b. Inspection Findings No deficiencies were identified by the NRC CAT inspectors in the sample of instruments, racks, piping runs, and supports inspected. II-19
- S c. Conclusions The NRC CAT inspectors determined that, based on the above selected sample, instrumentation, piping, and support installations conform to applicable design requirements. 4 h l I i l l i. I l l II-20 -~- .--.cr -=.m.,,,, ,.....w-,- .m..._._.nnm,n, - -.,g, ,,.,_r ,r,~-. ,.,-, --. ~,,,,,,,- --,.--rw -y.---.e,--
TA8LE II-1 RACEWAY INSPECTION SAMPLE Cable Tray: 21415A-PIE 2416CA-P1E 21424C-PIE 21327C-PIE ' 21326C-P1E 21334C-P1E 21333C-PIE 21330C-PIE 21329C-P1E 21328C-PIE 2R214-PIE 2R213-PIE 2525L-P1E 2513L-PIE 2761L-PIE 2511L-P1E 2R402-K1E 21891G-KIE 21890G-K1E 21889G-K1E 21884G-K1E 2R223-k1E 2SIO2E-P2E 21462N-P2E 21461MN-P2E 21460M-P2E 21458M-P2E 2914M-P2E 2912M-P2E 2910M-P2E 2908M-P2E 2906M-P2E 2905M-P2E 290ci-P2E 2898H-P2E 21536M-P2E 21537M-P2E 21539M-P2E 21540M-P2E 2R257K-C2E 2952K-C2E 2954K-C2E 2955K-C2E 2956K-C2E 2945K-C2E 2946K-C2E 2950K-C2E 2951K-C2E 2926K-C2E 2927K-C2E 2930K-C2E 2931K-C2E 2932K-C2E 2R301-C2E 21369K-C2E 21363K-C2E Cable Tray Supports: Support No. Drawing No. 305H1 3032H (W) H037 3052H (S) H022 3053H (L) H178 3062H (L) H010 3241H (H) H012 3254H (S) H001 3041H (K) II-21 l L
TABLE 11-1 (Continued) RACEWAY INSPECTION SAMPLE Conduit Supports: 2-3304-CC-32 2-3531A-WS-32 2-3321A-CC-24 2-3532A-WV-13 2-3321A-CC-250 2-3533A-TSS-1 2-3322A-CC-35 2-3534-CC-13 2-3511-TS2-1 2-3534-CP-3 2-3513A-WCP-6 2-3534A-FC-15 2-3521-CC-15 2-3543-FC-5 2-3521A-CC-60 2-3544A-CC-19 2-3521A-CS-32 2-3544A-FC-9 Conduits: C2A21A5 (PIE) 78' C2A21HO (P2E) 45' C2A2182 (P2E) 10' C2A0401 (P2E) 45' C2A1481 (K2R) 37' C2A2202 (C1E) 16' C2R2170 (PIE) 30' C2R2490 (C2E)' 23' l 2C2R3443 (C2E) 79' C2R3463 (CIE) 31' C2R2181 (C1E) 19' C2R2152 (C1E) 14' C2R1172 (P2E) 29' C2R3365 (C2E) 32' C2R3366 (P2E) 32' C2R4326 (KIR) 56' C2R4345 (P2E) 54' C2R4479 (C1E) 32' C2R4484 (PIE) 66' C2R3452 (C1E) 20' C2R1334 (PIE) 25' C2R2311 (P2E) 21' 2CR2225 (C2E) 12' C2R3207-(C2E) 6' II-22
e TABLE 11-2 SEPARATION FINDINGS Raceway segments listed in the A colums do not maintain required separation from the corresponding raceway segments in B columns. The(*)indi, cates physical separation of less than one inch between the two raceway segments. Column A Column B Column A Column B 2955L-C2E C0A32L3-2CIB 2955L-C2E C0A32L6-2C1B 29700-C2B 2955L-C2E C0A3328-2K1R 2956L-C2E C0A3215 29448-P2E
- C0A3215-IPIB 29448-P2E C0A33C6 29268-P2E
- C0A3384 29248-P2E 29268-P2E
- C0A3302 29228-P2E
- C0A3317-1C1B C0A3318-IC1B 29218-P2E
- 33JJ-1C1B 299228-P2E 29218-P2E
- C0A33JK-1CIB 21363K-C2E
- C2A-5103-2C1B 21363K-C2E C2A-51D2-2K18 2954K-C2E
- C0A3322-1C1B C0A3302 2926L-C2E C0A3384 2926L-C2E 2944A-P2E C0A3307 i
II-23
TABLE II-3 CABLE TERMINATION INSPECTION SAMPLE Fire Hazards Panel (2PL10J) Cables:
- 2MS668, 2FW920,
- 2FW921, 2MS666,
- 2RY431, 2RY433,
- 2FW918, 2FW919,
- 2RY430, 2RY432.
Process I & C Rack (2PA01J) Cables:
- 2FW705, 2FW704,
- 2RC350, 2RC355,
- 2RC360, 2RC365,
-2FW874,
- 2FW875, 2MS104,
- 2MS108, 2FW304,
- 2FWO38, 2SI653,
- 2CC288, 2IP007,
- 2LV079, 2RC342,
- 2RC336, 2MSO96,
- 2MS666, 2MS100,
- 2RC345, 2RC339,
- 2RY433, 2SI467,
- 2AB030, IFW919,
- IRC353, IRC538,
- 2RC363, 2RC368, 2RY432.
Process I & C Rack (2PA02J) Cables:
- 2FW707, 2FW706,
- 2RC372, 2RC391,
- 2RC396, 2RC401, 2FW876, 2FW877,
- 2M5116, 2M5668,
- 2MS122, 2FWO43,
- 2FWO48, 2SI654,
- 2CC290, 2IP023,
- 2LV080, 2RC383,
- 2RC377, 2MS113,
- 2MS119, 2RC386,
- 2RC380, 2RY202,
- 2FW921, 2RC375,
- 2RC394, 2RC399,
- 2RC404, 2RY204,
- 2RC406, 2FWO26.
E.S.F. Seq. & Act. Cabinet (2PA13J) Cables:
- 2EF027, 2EF029,
- 2EF086, 2EF028,
- 2EF031, 2EF026,
- 2SX313, 2EF023,
- 2EF083, 2EF037,
- 2EF034, 2EF036,
- 2EF035, 2EF038,
- 2EF033, 2EF096, 2EFG25.
E.S.F. Seq. & Act. Cabinet (2PA14J) Cables:
- 2EF043, 2EF045,
- 2EF087, 2EF064,
- 2EF044, 2SX314,
- 2EF041, IEF040,
- 2EF085, 2EF052,
- 2EF049, 2EF051,
- 2EF050, 2EF053,
- 2EF048, 2EF097, 2EF042.
Main Control Board (2PM06J) Cables:
- 2M5529, 2DC117,
- 2MS532, 2MS318,
- 2FW215, 2FW842,
- 2FW226, 2EF018,
- 2MS527, 20C126,
- 2MS524, 2FW227,
- 2MS519, 2MS356,
- 2M5531, 2SX008,
- 2SX010, 2SX465,
- 2SX312, 2SX232,
- 2SX033, 2SX009,
- 2MS275, 2MS288,
- 2FW570, 2FW279,
- 2FW775, 2AF008,
- 2AF011, 2AF009,
- 2AF248, 2AF147,
- 2AF019, 2SX065,
- 2WO203, 2CC023,
- 2CC241, ICC007,
- 2CC026, 2CC004,
- 2CC239, 2CC002,
- 2CC008, 2CC150,
- 2SX041, 2CC174,
- 2WO176, 2WO177,
- 2AF121, 2PS479,
- 2CC127, 2AF097,
- 2SX004, 2CC005,
- 2CC021, 2CS005,
- 2VP013, 2VP012,
- 2VP057, 2VP056,
- 2AF010, 2CC064,
- 2VPO40, 2C5034,
- 2EF014, 2SI654.
II-24
o TABLE II-3 (Continued) CABLE TERMINATION INSPECTION SAMPLE Diesel Generator Control Panel 2A (2PLO7J) Cables:
- 2DG194, 2DG031,
- 2DG028, 2DG147, 2DG030,'
- 20G027, 2DG154,
- 20G155, 2DG018,
- 2DG200, 2DG022,
- 2DG115, 2DG165, 2DG034,-
- 2DG169, 2DG083, 200062
- 200064, 2DG074,
- 2DG167, 2DG023,
- 200003, 2DG024,
- 2DG216, 2DG204,
- 2DG020, 2DJ126,
- 2DG120, 2DG219,
- 2DG218, 2DG113,
- 20G085, 2DG084,
- 20F114, 2DG026,
- 2DG029, 2DG011,
- 2DG010, 2DG009,
- 2DG012, 2DG013,
- 2DG014, 2DG162,
- 20G112, 20G086,
- 20G161, IDG033,
- 2DG032, 2DG025,
- 2DG073, 2DG071,
- 20G070, 2DG173,
- 2DG082, 2DG168,
- 200058, 2DG117,
- 2DG111, 200002,
- 2DG094, 2DG119,
- 2DG118, 2DG206,
- 2DG207, 2SX294,
- 2SX290, 2SX295,
- 200005, 2VD004.
Diesel Generator Control Panel 2B (2PLOO8J) Cables:
- 2DG066, 2DG195,
- 2DG063, 2DG038,
- 2DG065, 20G062,
- 2DG166, 2DG151,
- 2DG156, 2DG053,
- 2DG201, 2DG057,
- 2DG104, 2DG051,
- 2DG172, 2DG089,
- 200063, 200065,
- 2DG080, 2DG077,
- 2DG058, 2D0008,
- 2DG059, 2DG217,
- 2DG205, 2DG055,
- 20G141, 2DG135, 2DG221
- 2DG220, 2DG102,
- 2DG091, 20G090,
- 20G103, 20G061,
- 2DG064, 2DG043,
- 2DG044, 2DG045,
- 2DG046, 20G047,
- 2DG048, 2DG101,
- IDG164, 20G092,
- 20G163, 20G068,
- 2DG067, 20G060,
- 2DG079, 2DG170,
- 2DG076, 2DG176,
- 2DG088, 2DG171,
- 200059, 2DG109,
- 2DG100, 200007,
- 2DG096, 2DG134,
- 2DG133, 20G208,
- 2DG209, 2SX300,
- 2SX296, 2SX301, 200010,.
- 2VD010, 20G040,
- 2DG334, 20G042,
- 20G106, 20G150,
- 2DG052, 2DG054,
- 2DG041, 2DG050,
- 2DG225, 2DG177.
l 11-25
TABLE II-4 " QUASI-SAFETY-RELATED" CABLES Turbine Stop Valves 2EF065 2EF069 2EF066 2EF070 2EF067 2EF071 2EF068 2EF072 Turbine Pressure Switches 2EF073 2EF076 2EF074 2EF077 2EF075 2EF078 Feedwater Regulating and 2FW771 2FW269 2FW111 Bypass Regulating Valves 2FW777 2FW270 2FW123 2FW807 2FW271 2FW116 2FW773 2FW272 2FW137 2FW779 2FW110 2FW186 2FW808 2FW121 2FW145 2FW774 2FW115 2FW191 2FW780 2FW135 2FW153 2FW809 2FW185 2FW775 2FW722 2FW143 2FW776 2FW728 2FW190 2FW810 2FW151 Turbine Impulse Pressure 2MSO95 2MS112 Condenser Steam Dump Valves 2MS14B 2M5142 2MS174 2M5179 2MS153 2M5158 2M5177 2MS182 2MS155 2M5161 2M5180 2MS185 2MS156 2M5164 2MS183 2MS188 2MS159 2M5167 2MS186 2MS162 2M5170 2MS141 2MS165 2MS147 2MS173 2M5168 2MS171 2MS176 Steam Generator 2AS118 2AS127 2AS139 2AS128 2AS120 2AS129 2AS122 2AS131 2AS123 2AS132 II-26
TABLE II-5 INSTRUMENTATION INSPECTION SAMPLE Instrument Racks: 2PL81JA 2PL81JB 2PL67J Instrument Piping Supports: 2FT-0651-H143-6 2FIS-CC064-H237 2FT-0651-H215 2FT-CS-15-H153-1 2FT-660-H143-3 2FT-CS015-H153-2 2FT-660-H237 2FIS-611-H134-1 2LT-548-H234A 2LT-930-H244 2FT-445-H223 2FT-0657-H89E-13 2FT-415-H29A-6 2FT-0657-H234 2FT-415-H119A-23 2LT-528-H223 2FIS-CC064-H49-3 2FT-0654-H133-1 Instrument Piping Runs: T537-2FT-CS013 T992-2FT-0654 T548-2FIS-611 T995-2FT-0657 T538-2FT-CS015 T971-2FIS-CC064 T564-2LT-930 T988-2FT-415 T982-2FT-0651 T1008-2LT-0460 T990-2FT-660 T1053-2LT-548 T1015-2LT-556 . Instruments: 2FT-C5013 2FT-0654 2FIS-611 2FT-0657 2FT-CS015 2FIS-CC064 2LT-930 2FT-415 2FT-0651 2LT-0460 2FT-660 2LT-548 2LT-556 II-27
III. MECHANICAL CONSTRUCTION A. Objective The objective of the appraisal of mechanical construction was to determine if installed and Quality Control (QC) accepted mechanical items conformed to engineering design, regulatory requireme,nts and licensee commitments. B. Discussion The specific areas of mechanical construction evaluated were piping, pipe supports / restraints, concrete expansion anchors, heating, ventilat-ing and air conditioning (HVAC) systems and mechanical equipment. To accomplish the above objective, a field inspection of a sample of QC accepted hardware was performed in each area. In addition, certain programs, procedures and documentation were reviewed and responsible personnel were interviewed as required to support or clarify hardware inspection findings. 1. Piping a. Inspection Scope Piping depicted on the 15 Hunter Corporation (Hunter) drawings listed in Table III-1 was inspected by the NRC Construction Appraisal Team (CAT). Approximately 900 feet of large bore piping (greater than or equal to 2 inch diameter) was inspected. The piping was located in the Unit 2 Reactor Building, including the Steam Tunnel, and the Auxiliary Building. Component Cooling, Chemical and Volume Control, Feedwater, Main Steam and Reactor Coblant Systems piping were included. Pipe sizes ranged from 1/2 inch to 60 inches and classifications were ASME 1, 2 and 3. The piping was inspected for configuration (i.e., layout geometry, orientation and dimensions), component type and location, valve operator orientation, and support location, type and orientation. Additionally, site construction practices with regard to protection of installed hardware and maintenance of inservice inspection i clearance criteria were observed on a random basis. Design change l documents, including Engineering Change Notices (ECNs) and Field Change Requests (FCRs), were reviewed and compared to inspection data gathered in the field. The extent of this design change review is identified in Table III-1. All of the piping samples had been previously inspected and accepted by Hunter QC, Thirteen hydrostatic / pneumatic pressure test packages were reviewed for cumpliance with procedural and code requirements and 1 pneumatic test was witnessed. Items reviewed consisted of applied pressure, duration, pressure adjustment calculations, type of gauges used, test boundaries, Discrepancy Reports, Field Change Requests and documented instances of overpressurization. All nonconformance reports (NCRs) involving overpressurization at the site were reviewed. The training program for personnel engaged in the performance, supervision and review of hydrostatic / pneumatic testing III-1 . - - _-=-_
was reviewed. Table III-2 provides a listing of the test packages reviewed. Twenty-nine locations in Class 1 and 2 piping systems were selected as part of the NRC CAT sample to determine whether ASME requirements for pipe wall thickness were met. Seven different plant systems and 12 manufacturing firm's products were selected for the sample. The pipe wall thickness measurements were taken by ultrasonic methods with equipment and personnel provided by the licensee. The values obtained were compared against the minimum wall thickness require-ments specified by ASME (12.5 percent below nominal thickness). Several measurements were taken at each location. Seven of the locations were on elbows. See Table III-3 for details and observa-tions. The following documents provided the acceptance criteria and background information for the NRC CAT inspection: Hur.ter Corp. Site Implementation Procedure No. 4.201, " Installation Verification," Rev. 11. Hunter Corp. Site Implementation Procedure No. 2.201, " Design Control," Rev. 13. Nuclear Power Services, Inc. Work Procedure No. 3.09, "As-Built Piping Subsystem Preparation," Rev. F. Sargent & Lundy (S&L) Instruction PI-8B-26. " Procedure for Preparation and Submittal of Piping 'As-Built' Information," Rev. 4.
- 'S&L Instruction PI-BB-27, " Receipt Review, Reanalysis (Where Applicable), Redesign (Where Applicable) and 'As-Built' Piping Reconciliation," Rev. 4.
S&L Drawing No. M-535, " Piping General Notes, Byron Sta. Units 1 & 2," Rev. AJ. S&L Drawing No. M-679, " Single System General Notes, Byron Unit 1 & 2," Rev. D. S&L Drawing No. M-919, " Component Support Installation Guidelines and Tolerances" Sheet 4, Rev. L and Sheet 4A, Rev. D. Hunter Corp. Site Implementation Procedure No. 4.405, " Pressure Testing, Rev. 3. Hunter Corp. Site Implementation Procedure No. 4.406, " Piping Freeze Seals," Rev. 1. b. Inspection Findings In the review of piping, the NRC CAT inspectors found that in general piping met the design requirements; however, 3 minor discrepancies were found. The observations associated with specific III-2
piping drawings are listed in Table III-1 and described in the following paragraphs. The "as-built" dimension from a branch connection center line to the attached high point vent valve, Valve 2CC153, noted on the isometric drawing (Isometric Spool No. CC-52) was 1.25 inches. This dimension in the field measured 4.25 inches. This 3 inch discrepancy exceeds the inspection tolerance of 1 inch specified by S&L Dra6 ting M-679 and the dimensional accuracy requirements of 1 inch specified by the S&L as-building procedure, PI-BB-26. The dimension as depicted is not physically possible and was determined to be a drafting error. This error would probably have been detected during the as-built reconciliation effort since the distance shown obviously requires more than the specified 1.25 inches to accomodate the fittings included. All other design and as-built dimensions checked during the NRC CAT inspection were found to be within 1/8 inch of acceptance criteria. Isometric drawing for Spool No. S-CC-001-243 specifies a 2 inch, 45 degree socket elbow to be a 3000 psi rated fitting. The NRC CAT inspection found this elbow to be a 6000 psi fitting. Subsequent review by Hunter determined that the 6000 psi rating corresponded to design requirements and the traveler package installation records. Therefore, this discrepancy is attributable to drafting error. The The NRC CAT considers this discrepancy isolated sad not safety significant. The NRC CAT observed that one of four support points for a wood construction platform measuring approximately 4.0 ft. by 5.0 ft. was mounted on the operator for valve 2CV8106 (Ref. Isometric Spool No. CV-20). No damage was observed and because of the small size of the platform, damage was not likely. However, construction practices should prevent the potential damage of installed hardware. Hunter has on at least two previous occasions issued directives to its employees prohibiting the attachment of scaffolding to various types of hardware, including 2.0 inch and smaller pipe. The licensee should evaluate the need for additional precautions in this area and take appropriate action. Hydrostatic / pneumatic testing was found to meet the requirements of SIP-4.405 and code requirements. Of the hydrostatic / pneumatic test packages reviewed three NCRs were identified to have been issued as a result of overpressurizations during testing on Unit 2. In the review of NCR-860 it was observed that the list of pipe and com-ponents that had been subjected to overpressurization was incomplete in that Auxiliary Feedwater Pump 2AF01PB had not been included. The effect of this oversight is that S&L did not evaluate overpressuri-zation of this pump and consequently disposition of NCR-860 was incomplete. NCR-1136 was initiated to address this matter. Similar instances of testing overpressurizations on Unit 1, a total of 10 NCRs, were also reviewed by the NRC CAT inspectors. It was found by the NRC CAT inspectors that the pipe and component list in III-3
o NCR 1022 was also incomplete in that 3 Ifne segments and 8 valves had been left off the list. In this case however, S&L's evaluation of the NCR had included a review of the details and drawings perti-nent to the overpressurization and had developed a complete list that included the 3 Ifne segments and 8 valves. Review of S&L's methods and calculations to resolve th overpres-surizations appeared to be reasonable and technically adequate. However, the NRC CAT inspectors are concerned that procedures were not in place that would require that S&L perform an independent review, as was done in the one overpressurization case, to ensure that affected piping and components are included in the engineering evaluation. Regarding the 29 piping locations where ultrasonic thickness measurements were taken to verify minimum wall thickness values, the measurements were acceptable in that they exceeded the minimum wall values specified for the size and schedule of pipe involved. c. Conclusions Piping was found to generally conform to design documents. Engi-neering and inspection personnel were knowledgeable of procedures, requirements and responsibilities. With respect to hydrostatic / pneumatic testing, the overall program was found to be functioning in accordance with the procedural and code requirements. The noted failures to include pipe segments, valves and a pump on the NCR description of the overpressurization event are considered isolated cases. However, steps should be taken to ensure that any future overpressurizations receive an independent review so as to reduce the likelihood of the type of oversights identified by the NRC CAT inspectors. 2. Pipe Supports / Restraints a. Inspection Scope Twenty-five ASME Class 1, 2 and 3 and eight Class D pipe supports / restraints were selected for detailed inspection. These supports / restraints represented various types, sizes, systems and locations. All had been inspected and accepted by the mechanical contractor, Hunter Corp. These supports / restraints were inspected by the NRC CAT for proper configuration, clearances, member sizes, location, damage, weld size and proper fasteners. See Table III-4 for a listing of the inspection sample. In addition, approximately 60 other supports / restraints were observed at random in the field for obvious deficiencies such as loose or missing fasteners, improper clearances or angularity, improper locking devices, disassembled items, damage and improper concrete expansion anchor spacing. III-4
1 Docunentation packages for the supports /retraints in the primary 1 sampla were examined for completeness, accuracy and conformance to procedaral requirements. Drawing revisions and ECNs used in the 1 inspection were verified to be the latest design documents with vendor drawing / design change master lists. Acceptance criteria for these inspections were containdd in the following documents: 4 Hunter Corp. Site Implementation Procedure (SIP) 4.201, " Installation Verification," Rev. 11. Hunter Corp. Site Work Instruction (SWI) 2, " Installation of Hanger Speciality Items," Rev. 9. f S&L Drawing M-919, " Component Suppport' Installation Guidelines and Tolerances." ITT Grinnell and E1cen Metal Products catalogues and engineering specification sheets. Applicable design drawings and change documents b. Inspection Findings l At the time of this inspection, approximately 95 percent of the 1 approximately 11,000 large bore supports / restraints had been i installed and QC accepted. Approximately 70 percent of the i approximately~10,000 small bore supports / restraints had been l installed and QC accepted. No significant hardware discrepancies were identified in the NRC CAT inspection sample of supports / restraints, i Support material and configuration generally conformed to design requirements. Workmanship was good and QC inspections appeared to have been thorough. See Table III-5 for a summary of inspection I observations. l .i Five instances of loose strut locknuts were noted indicating a possible lack of attention to detail for this feature. Discussions with responsible personnel and review of procedures governing future l l support / restraint inspections (Type 4 and 79-14 walkdowns) indicate i that these discrepancies should be identified and corrected. However, because of the number of these discrepancies noted, the NRC i CAT inspectors considered that additional emphasis needs to be placed on proper installation and inspection of fasteners, l especially during the final walkdown inspections. t The NRC CAT inspectors had a concern with regard to pipe stress due 4.o point contact between a pipe saddle and pipe on a particular i restraint. It was determined that no specific inspection criteria i existed for this feature. Westinghouse engineering evaluated this specific installation as acceptable and developed and issued i ? III-5
criteria to be used for installation and inspection of this type of support / restraint detail. No discrepancies were noted in the review of documentation packages. The drawing revisions and design change documents used in the NRC CAT inspections were the latest design documents as evidenced in the current S&L and Westinghouse master lists. Twenty-thre'e of the supports / restraints in the primary sample had open ECNs that had not yet been incorporated onto the drawing. There were no discrepancies noted by the NRC CAT inspectors that would indicate inadequacies in implementation of the design change process with respect to supports / restraints. Discussions were held with responsible engineers relating to seismic interaction programs, design and inspection of Class D support / restraints and the piping thermal expansion test and inspection programs. No concerns were identified. c. Conclusions Pipe supports / restraints were found in general to be in conformance with drawing, design change and procedural requirements. Site engineering, construction and inspection personnel were knowledge-able of procedures, requirements and responsibilities. 3. Concrete Fxpansion Anchors a. Inspection Scope One hundred and six concrete expansion anchor bolts on 23 pipe supports /retraints were examined for proper length, marking, embedment depth, spacing, residual torque (an indication of anchor preload), damage and bolt hole to plate edge distance. Various systems, sizes and locations were included in the anchor sample. Table III-6 provides a listing of the anchors inspected. Anchors were torqued to the 15 day-3 month test torque specified in site procedures. This represented approximately 50-60 percent of installation torques. Acceptance criteria for these field inspections were contained in the following documents: Form BY/CEA, " Standard Specification for Concrete Expansion Anchor Work," Rev. 22. Hunter Corp. SIP 20.513, " Installation of Concrete Expansion Anchors," Rev. 16. Detail drawings for pipe supports / restraints, b. ' Inspection Findings Only three of the 106 anchor bolts required rotation to reach the test torque. Only one of these three required significant rotation to reach the full installation torque (2 turns). Even considering III-6
o that the test torques were relatively low, no significant installa-tion deficiency is indicated. All other characteristics examined were either within tolerance or had been previously identified and evaluated. c. Conclusions The concrete expansion anchors installed in pipe supports / restraints .were installed in accordance with design and procedural require-ments. 4. Heating, Ventilating and Air Conditioning (HVAC) a. Inspection Scope Twelve safety-related seismic HVAC duct supports and two fan sup-ports were inspected for configuration, dimensions, location, damage, weld size and member size. Due to the application of fire protection coating many of the auxiliary steel connections in the sample was not readily accessible for clip angle and weld size inspection. However, as a result of welding discrepancies noted on the accessable joints in this sample, the auxiliary steel connection details for an additional eight duct supports were examined for the specified weld size.1 Approximately 15 duct segments were also inspected for size, stiffener and support location, fasteners and joint makeup, damage and weld size. Five fire dampers were inspected for fusible links, specified location and type per drawing and damper list, sleeve to damper welding and damage or corrosion to blade operating mechanisms. The inspection of HVAC equipment is discussed in section III.B.5 of this report. See Table III-7 for observations and listing of supports and fire dampers inspected. The following documents provided the acceptance criteria for HVAC hardware installations: S&L Drawing M-1261, " Safety-Related HVAC Hanger Details." S&L Safety-Related HVAC Hanger Lists. Reliable Sheet Metal (RSM) Works, Inc. Procedure 23, "Installa-tion Verification," Rev. 2. 1 RSM Procedure 30A, " Bolted Connections," Rev. 4. i RSM SWI 2, " Inspection and Acceptance Criteria for Fire Damper i Assemblies (FDA)," Rev. 1. j S&L Specification F-2782. S&L Fire Damper List. ISee Section IV-B.6 for further details. l III-7 l
RSM Duct Construction Manual and Construction Details. HVAC duct design location drawings. b. Inspection Findings Severalminordimensional,orientationanddrawingdishrepancies were noted during the duct and fan support inspections. None of these were considered significant. Several undersize welds were identified on clip angle to tube steel and clip angle to in place steel welds for three duct supports. As a result of these observa-tions, the connection joints for eight additional duct supports were inspected. Five of these were also found to be undersize. Some of these welds were shop welds made off-site and may not have been inspected by site personnel; some were field welds that had been inspected by site personnel. Typically, welds specified to be 1/4 or 5/16 inch fillets were 1/16 to 1/8 undersize for one or more of the eight welds on each auxiliary steel installation. As a result of these findings nonconformance report NCR-118 was issued.2 From an overall standpoint the discrepancies noted were not considered to be major utructural concerns. However, the number of discrepancies noted in QC accepted hardware, most of which have already been through a complete reinspection program, is a concern. This indicates a need for additional management review and attention to detail by QC inspectors. The inspection of fire dampers identified one damper that was installed with a standard fusible link instead of the electro-thermal link required by the specification damner list. Licensee personnel indicated that the electro-thermal *. ink was not yet installed by the electrical contractor but was scheduled to be. A check of the companion Unit 1 damper revealed that the electro-thermal link there had been installed. Other damper features conformed to design requirements. With regard to duct inspections, one 73 inch long duct segment did not have stiffeners installed as required by the Cuct Brochure and Specification. Other attributes examined on duct work conformed to design requirements. c. Conclusions l The QC program failed te % ify support auxiliary steel connection l welds that did not mr6t esh. size requirements or, eight of 20 supports inspected by t..e J: ,:AT.2 i l 25ee Section IV-8.6 for a list of specific findings and disposition of NCR-118. l III-8
5. Mechanical Equipment a. Inspection Scope Seventeen pieces of equipment located in seven systems'were inspected for ASME class, capacity, temperature, pressure rating and for compliance with foundation details such as bolting. arrangement, number and size of bolts. Installation documentation Was checked for compliance with Quality Assurance / Quality Control (QA/QC) requirements. The inspection sample included pumps,' tanks, heat exchangers and HVAC cubicle coolers that were reported to be completely installed and QC accepted. Table III-8 provides a listing of inspected items. Listed below are the major documents that provided the acceptance criteria for inspection. Ahplicablevendordrawingsandfoundationdetails Vendor manuals Hunter Corp., SIP-4.000, " Control of Construction Processes," Rev. 14. Hunter Corp., SIP-4.001, " Bolted Connections," Rev. 2. Hunter Corp., SIP-4.201, " Installation Verification," Rev.11. Hunter Corp., SIP-6.001, " Visual Examination & Verification," Rev. 4. b. Inspection Findings Generally, the mechanical equipment inspected by the NRC CAT was procured and installed in accordance with vendor and design require-ments. However, a discrepancy was identified with four heat exchangers supplied by Westinghouse. It was observed that the installation procedures used by the installation contractor for tightening foundation bolts at the sliding end of these four heat exchangers was.not in agreement with the Westinghouse equipment manual. The Westinghouse manual states that these specific bolts should be backed off to allow for expansion, but the installation contractor's procedure states they are to be snug tight. To investigate this concern the licensee performed torque checks on the equipment foundation bolts and found some of the bolts to have been tightened to 250 to 280 ft-lbs; values considerably in excess of the 100 ft-Ibs assumed for a snugtight installation. The licensee subsequently issued ECN 27982 to eliminate bolt torquing requirements on specified sliding connections. Westinghouse correspondence (CAW-9141) states that these bolts should be backed off on Unit 2 shortly and on Unit 1 during the first refueling. Westinghouse has evaluated the present condition on Unit 1 and determined that it is acceptable to wait until fuel loading for corrective action. III-9
c. Conclusion Mechanical equipment installations, except certain heat exchanger sliding connections, generally conformed to design and installation requirements. Installation documentation reviewed was in accordance with requirments. III-10
TABLE III-1 PIPING INSPECTION SAMPLE Pipe Drawing Class Diameter Number Revision (ASME) (Inches) Notes Observation L'arge Bore: CC-52 4H 2 3 1 1k" as-built dim measures 4%" CC-57 4G 3 3 1 CC-61 4G 2 3 1, 2 CV-19 7N 2 4, 3 1 CV-20 6C 2 4, 3 Scaffolding supported by operator for Valve 2CV8106 FW-70 BG 2 6,4,3 FW-72 4D 2 3 Small Bore: S-CC-001-243 6 3 2,.3/4 3000# socket elbow specified is 6000# S-CC-001-253 IB 3 2 S-CV-001-212 28 1, 2 3/4 S-CV-001-233 IB 2 2 S-CV-001-292 1C 2 2 S-MS-001-224 78 2 1/2 S-RC-001-221 2C 1 2 S-RC-001-234 3A 1 3/4 NOTES: 1. Design changes specified by Engineering Change Notices and/or Field Change Requests identified at the revision block of this drawing were reviewed. The changes were compared to field data compiled during the NRC CAT inspection. 2. Piping located inside the heat exchanger cavity was not inspected by the NRC CAT. III-11
TABLE III-2 HYDROSTATIC / PNEUMATIC TEST PACKAGE SAMPLE Test Package ID System SG-21 Retest Main Steam - Fegdwater CS-37 Containment Spray BR-6 Beron Therm.-Gen. SX-102 Retest Essential Service Water PS-8 Process Sampling SI-26 Safety Injection CS-38 Containment Spray NT-3 Nitrogen D0-93 Diesel Oil IA-4 Instrument Air OG-11 Off-Gas RY-17 Reactor Coolant Pressurizer WM-4 Makeup Demin. 4 s III-12
1 TABLE III-3 PIPE WALL THICKNESS MEASUREMENTS Nominal / Minimal Wall 1 Manufacturer / Pipe Size / ASME Thickness 2 Measured Wall (Heat No.) Schedule Class (Inches) Thickness (Inches) SW (MRR 10264) 29" 1 2.425/2.330
- 2. 5 Sandvik (750557) 2"/160 1
.344/.301 .35 B&W (M1629) 8"/160 1 .906/.792 .91 B&W (M1656) 8"/160 1 .906/.792 .99 CE (8ZE260) 3" 1 .438/.383 .43 C-W (3109-8-2) 10"/140 1 1.00/.875 1.03 C-W (3109-8-2) 10"/140 1 1.00/.875 1.01 C-W (3109-12-2) 6"/160 1 .719/.629 .74 B&W (M-2417) 6"/160 1 .719/.629 .74 Cameron (L4328) 12"/140 1 1.125/.984 1.14 C-E (5835) 3"/160 1 .438/.383 .45 T-T (94584) 6" 2 3 1.59 T-F (EICL) 28" 2 1 3/16 1.30 USS (N15150) 8"/160 1 .906/.792 .94 USS (N15150) 8"/160 2 .906/.792 .91 USS (L45353) 16"/120 2 1.219/1.066 1.24 USS (L62803) 6"/120 2 .562/.491 .56 C-W (2799-4-2) 12"/40 2 .375/.328 .43 C-W (1210-3-2) 12"/40 2 .375/.328 .48 SWEPCO (8034857) 8"/40 2 .322/.281 .35 Armco (781055) 24"/40 2 .687/.601 .77 Armco (61266) 16"/STD.WT. 2 .375/.328 .43 III-13
. TABLE III-3 (Continu:d) PIPE WALL THICKNESS MEASUREMENTS Nominal / Minimal Wall 1 Manufacturer / Pipe Size / ASME Thickness 2Measured Wall (Heat No.) Schedule Class (Inches) Thickness (Inches) ASP (83540) 2"/160 1 .344/.301 .35 Elbow T-F (7297) 8"/160 1 .906/.792 1.03 Elbow T-F (ERPC) 12"/140 1 1.125/.984 1.27 Elbow T-F (JHZH) 12"/40 2 .375/.328 .40 Elbow T-F (JIFM) 8"/40 2 .322/.281 .35 Elbow T-T (713894) 24"/40 2 .687/.601 .88 Elbow G-W (624063) 16"/STD.WT. 2 .375/.328 .42 Elbow NOTES: 1 B&W - Babcock & Wilcox Tubular Products Division C-W - Curtis-Wright Corp. C-E - Combustion Engineering T-T - Tube Turns T-F - Taylor Forge USS - United States Steel SW - Southwest . ASP - Alloy Stainless Products 2 Thickness measurements were made by Krautkramer UT Instrument, Model USK6 SR. No. 27593-3926 using 3/8" and 1/2" diameter transducers. Couplant: Ultrajel; Operator: Ebasco level II. 3 Nonstandard part - bought to specified dimensions III-14
TABLE III-4 PIPE SUPPORT / RESTRAINT INSPECTION S MPLE Pipe Size S/R Number Tyge Class (Inches) location 2SIO1004X Box 1 10 Reactor 2SIl0003S Snubber 1 2 Reactor-2SIO403SX Strut 2 8 Reactor 2RY20011X U-bolt 2 3 Reactor 2RH02006X Strut 1 12 Reactor 2RC10008X Strut 1 3 Reactor 2SIO3025V Spring 2 8 Reactor 2SIO4019X Strut 2 10 Reactor 2RH06004V Spring 2 3 Aux. 2RH09B005A Anchor 2 2 Aux. 2RH04010X Strut 2 8 Aux. 2RH098012X U-bolt 2 2 Aux. 2SIO5035X Box 2 4 Aux. 2RYO90895 Snubber D 6 Reactor 2RY20013X Box D 3 Reactor 2RYO9020C Spring D 12 Reactor 2RYO90135 Snubber D 6 Reactor 2RYO8034X Strut D 4 Reactor 2RY08011X Strut D 4 Reactor 2RY08008X Strut D 4 Reactor 2CC22004X Strut 3 6 Reactor 2CC22009X Strut 3 6 Reactor 2RH07019V Spring 2 8 Aux. 2AB238013X U-bolt D 3 Aux. III-15
.i TABLE III-4 (C:ntinu:d) PIPE SUPPORT / RESTRAINT INSPECTION SAMPLE Pipe Size S/R Number Type Class (Inches) location 2SIO6239V Spring 2 24 Aux. I 2RH070135 Snubber 2 8 Aux. i 2RC11009X Strut 1 3 Reactor 1 I 2CC23015X Strut 3 4 Reactor l 2RC10009X Strut 1 3 Reactor } i 2RC10016X Strut 1 3 Reactor 2RC10020X Strut 1 2 Reactor i l 2RC11010X Strut 1 3 Reactor 2CC10001R Rod 3 8 Aux. i Reactor - Reactor Building f Aux. - Auxiliary Building l l l l I i f I i III-16
e. TABLE III-5 . PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS Support / Restraint Observations Primary Saa'ple t 2SIl0003X Weld length of rear bracket i to embed was 4 5/8 inches long vs. 5 1/2 specified l 2RYO8011X Loose strut locknut i 2RC11009X Unspread cotter pins j 2RC23015X Loose locknut I 2RC10016X Loose locknut t 2RC20020X Piece 2 oriented 90 degrees from specified position 2RC11010X Backed off locknut o Adjacent Sample I l 2CV65015, 2CV66017, Loose locknuts 2CC28010X, 2CV63019 2RC11011X, 2CCV15011 Unspread/ missing cotter pins l 2FW1900312, 2FW19009R Gaps between lubrite plate and restraining bars not per design tolerance [ I t I I I r t i t l I [ f III-17 l, t L
TABLE III-6 CONCRETE EXPANSION ANCHOR INSPECTION SAMPLE Support / Number-Diameter (Inches) Restraint of Anchors Inspected Observations 2RH02007X 12-3/4 One turned '.at 6 f t-lbs. 2FW93E010X 4-5/8 2MS918008A 4-1/2 2SI30A002X 12-3/8 2CV150135 4-3/4 2CV150415 4-1/2 2RC23034X 4-1/2 2RC908024X 4-1/2 One turned at 35 ft-Ibs 2CV130345 4-3/4 2CV09025X 4-1 2RC29002X 4-1/2 2MS948001 4-3/4 21YO94H4G20933 2-1/2 21YO94H4G20911 2-1/4 One turned at 30 ft-lbs 251938024 4-3/4 2 WOO 9A033X 4-1/2 2CS03B77X 4-3/4 25106223 4-1 2SX50009X 4-1 2SIO6259 4-1 One turned at 180 ft-Ibs 2AB62005R 4-3/4 2SIO6263X 8-5/8 2CS06010X 4-3/4 III-18 l
TABLE III-7 HVAC INSPECTION SAMPLES AND OBSERVATIONS Item Inspected Observations Duct Supports: H3856 Undersize auxiliary steel. welds. H3837 H3854 Duct spacer to horizontal member missing one of two welds.- H3855 H3853 H922 H2174 H3749 Undersize auxiliary steel welds. H3822 H3652 Undersize auxiliary steel welds. H1395 Discrepancy as to hanger type affecting horizontal member attachment. H8624 Minor dimensional / tolerance discrepancy. 1 Fan Supports: 2V003CA Incorrect brace orientation. 2VD01CA Missing washers on foundation bolts and foundation bolt spacing not per vendor drawing. Fire Dampers: 2VX03Y 2VD17YB 2VD17YA 2V063Y 2V053Y 15ee Section IV-B.6 for additional supports inspected !!!-19
TABLE III-7 (Continued) HVAC INSPECTION SAMPLES AND OBSERVATIONS Item Inspected Observations' Duct Segments: Fifteen segments shown on Segment M-1283-2-18 does not portions of drawings M-1281 have required stiffener. and M-1283. i f f i ( l !!!-20 l I L
o TABLE III-8 MECH'ANICAL EQUIPMENT SAMPLE. Boric Acid Transfer Pump 2A803P. Boric Acid Tank 2A803T Diesel Generator 011 Transfer Pump 20001Ph Diesel Generator Day Tank 20002TA Residual Heat Exchanger 2RH02AA Residual Heat Removal Pump 2RH01PA Letdown Reheat Heat Exchanger 28R03A -Letdown Heat Exchanger 2CV05A Volume Control Tank 2CV01T Excess Letdown Heat Exchanger 2CV01AA Seal Water Heat Exchanger 2CV02A Containment Spray Additive Tank 2CS01T Safety Injection Pump 2SIO1PA Safety Injection Pump Room Cubicle Cooler 2VA04SA Centrifugal Charging Pump 28 Cubicle Cooler 2VA0658 Safety Injection Pump Room Cubicle Cooler 2VA045A Centrifugal Charging Pump 2A Cubicle Cooler 2VA06SA III-21
o IV. WELDING AND NONDESTRUCTIVE EXAMINATION A. Objective The objective of the appraisal of welding and nondestructive examination (NDE) was to determine if Quality Control accepted work related to welding and NDE activities was controlled and perfomed in accordance with design requirements, Safety Analysis Report commitments, and applicable codes and specifications. An additional objective was to determine if personnel involved in welding and NDE activities were trained and qualified in accordance with established performance standards and applicable code requirements. B. Discussion To accomplish the above objectives, welds and welding details for piping; pipe supports / restraints; field and shop fabricated tanks; structural steel installations; heating, ventilating, and air condi-tioning (HVAC) installations; electrical supports; and instrumentation and control tubing and supports were inspected. The inspected welds were selected to provide a representative sample of the licensee's contractor welding activities in terms of welding processes used, materials welded and existing weld-joint configurations. Considera-tions such as physical location, difficulty of welding and limited accessibility were also used in the sample selection. Design changes related to welding such as increase or decrease of weld sizes and changes in the welding process or procedure were also reviewed for technical adequacy. NDE activities were appraised through the review of radiographs for both field and vendor fabricated welds, the review of NDE procedures and personnel qualifications, the inspection of the calibration status of NDE equipment and the witnessing of in-process NDE activities. The NRC Construction Appraisal Team (CAT) inspectors reviewed a sample of radiographic film in final storage in the vault of the licensee's facility. In addition, a sample of film for Westinghouse supplied components was requested for review which were stored in the Westinghouse storage facility. During the inspection of structural welds in the pipe whip restraint, structural and HVAC areas, the NRC CAT inspectors identified welds which did not meet some of the requirements specified by the AE Sargent & Lundy Engineers (S&L). S&L has evaluated most of these welds and determined that the welds are adequate for their intended application. Undersized weld reinforcements were also found in nozzle to shell joints (ASME Code Category D Joints) on tanks and heat exchangers. A detailed discussion concerning these welds is included later in this section. In the area of NDE, the NRC CAT inspectors requested to review a sample of radiographs which were stored at the Westinghouse storage facility. Two items were requested for review. Initially, the radiographs for the Boric Acid Transfer Pump (2AB03P) and the Let Dcwn Chiller Heat Exchanger (2BR03A) were requested. Westinghouse, however, provided IV-1
radiographs for the let Down Heat Exchanger and the Moderating Heat Exchanger which were fabricated by Atlas Industrial Manufacturing. A further review of the items requested established that the Boric Acid Transfer Pump and the Let Down Chiller were exempt from radiography because their wall thickness was less than the thickness requiring radiographic examination under the rules of the ASME Code for Class 3 components. As a result of this, the NRC CAT requested the ' radiographs for the Component Cooling Surge Tank (20C01T) and Volume Control Tank (2CV017). The film for the Component Surge Tank and Volume Control Tank were not received during the NRC CAT inspection period. The licensee stated that radiographs for these Westinghouse supplied components would be reviewed and further reviews performed to ensure that code requirements were met. The NRC CAT inspectors also identified some radiographs which showed that some welds did not have the required weld quality or the film or other documentation did not accurately identify the proper hardware. A detailed discussion concerning the welds and their associated deficiencies are provided later in this section. The welding and NDE activities were examined in order to ascertain compliance with the governing construction codes and specifications. This effort involved the review and inspection of the following contractors: Field Activities 1. Sargent & Lundy Engineers: Architect-Engineer. 2. Hunter Corporation: piping installation and piping supports / restraints, fire protection fabrication and installation. 3. Chicago Bridge and Iron Company (CB&I): containment liner and containment penetration fabrication and installation, pipe whip restraints. 4. Pittsburgh Des Moines Corporation (PDM): reactor pool fabrication and installation. 5. Reliable Sheet Metal (RSM): heating, ventilating and air conditioning. 6. Nuclear Installation Service Co. (NISCo): reactor internals modification and installation. 7. Powers-Arco-Pope (PAP): instrumentation installation and instrumentation supports. 8. Hatfield Electric Company (HECo): electrical installation and supports. 9. BlountBrothers(BBC): structural steel modification and erection.
- 10. Ebasco Services Inc.: preservice inspection and examination.
IV-2
o l Shop Fabrication 1 1. Southwest Fabricating & Welding Company, Inc.: shop fabricated piping spools. l 2. Harnischfeger Corporation: crane manufacturer. 1 l 3. Westinghouse: nuclear steam supply system. 4. Anchor / Darling Valve Company: valve manufacturer. ? 5. Teledyne Brown: NSSS supports fabricator. l l 6. Carrier Corporation:. chillers and coolers manufacturer. l 7. Phillips Steel Company: liquid radwaste evaporators supplier, i 8. Graver Corporation: tank fabricator. 9. Jamesbury Corporation: valve body supplier.
- 10. Dresser Industries: valve manufacturer, j
- 11. G8W Energy Product Corporation: spray eductors supplier.
1 i
- 12. TRW Mission Manufacturing Co.: containment spray system supplier.
l
- 13. Farr Company: reaction chamber filter supplier.
- 14. Continental Boiler:
return air riser supplier.
- 15. Yuba Heat Transfer Corporation: high pressure heater manufacturer.
l
- 16. McQuay Perfex Inc.: condenser shell and hot well tank shell l
supplier. l l
- 17. Pall Trinity Micro Corporation: cartridge filters supplier.
i
- 18. ACF Industries:. valve body supplier.
- 19. Cleaver Brooks:
steam boilers fabricator. l
- 20. Mannings Lewis: miscellaneous heat exchangers shell supplier.
- 21. Cooper-Bessemer:
air receiver tanks supplier.
- 22. Greer Hydraulics: pulsation damper suppliers.
- 23. ITT Grinnell:
snubber support assembly fabriutor.
- 24. Rockwell International: hydrogen recombiner manufacturer.
- 25. Atlas Industrial Manufacturing:
heat exchanger manufacturer. l l IV-3
- 26. W. J. Wooley Company: containment vessel hatches fabricator and supplier.
- 27. Bingham-Willamette: pump manufacturer.
- 28. Plant Management Corp.: surface condenser tanks supplier
- 29. Borg Warner: valve manufacturer
- 30. Aerojet Energy: expansion joints supplier The results of the inspection activities involving each of these areas and contractors are documented as follows:
1. Pipe and Pipe Support Fabrication a. Inspection Scope (1) Welding Activities The NRC CAT inspectors reviewed activities relating to fabri-cation in the areas of piping system welds, support / restraint 4 welds, welding procedures, welder qualifications, NDE proce-dures, personnel qualifications, and the review of radiographic film for shop and field fabricated welds. Field welding involving pipe fabrication was perfonned by Hunter. Southwest Fabricating and Welding supplied the shop fabricated piping spools. The NRC CAT inspected 47 pipe supports / restraints involving approximately 450 welds in order to verify conformance of welding to drawing requirements and confirm the visual acceptability of the welds. See Table IV-1 for a listing of supports subjected to detailed inspection. Additionally, another 22 supports / restraints involving 600 welds were visuall welds (y inspected to verify the quality of the completed See Table IV-2). The NRC CAT inspectors also inspected the welds on the lateral supports for Steam Generator #7. The NRC CAT inspection of piping welds consisted of visual inspection during walkdown of piping systems and inspection of pipe welds located near the supports / restraints being inspec-ted. Approximately 51 piping spools involving 1700 ASME Class 1, 2 and 3 welds were inspected. Twenty-four of those piping spools were subjected to detailed inspection which included the review of pertinent QC documentation while the remaining 27 spools were only visually inspected. Both field and shop welds were inspected in order to assure compliance with the requirements of the ASME Code. See Tables IV-3 and IV-4 for listings of piping spools inspected. In addition, 50 welding filler metal test reports, 45 welder qualification test records and 4 welding procedures were reviewed for compliance with appifcable specifications, procedures and the ASME Code requirements. IV-4
o (2) Nondestructive Examination Activities The NRC CAT inspection of NDE activities for the pipe fabri-cation area included the review of 89 shop and 63 field fabricated welds which involved 1953 film. Field NDE activi-ties are perfomed by an independent third party, Pittsburgh Testing Laboratory. In addition, 5 NDE procedures'and 6 NDE personnel qualification records were reviewed in order to verify compliance with the governing codes and specifications. Four NDE technicians were observed while performing in-process inspections and were evaluated for their ability to follow the applicable inspection procedures. Fifteen pieces of NDE equipment were inspected for calibration and one quality assurance NDE. procedure was reviewed for adequacy. b. Inspection Findings (1) Welding Activities In general, the inspected pipe and pipe supports / restraints welding activities were found to comply with the governing codes and specifications. However, minor discrepancies were identified involving undersized welds in pipe whip restraints. Twenty-nine of 1050 structural welds inspected, involving 69 pipe supports / restraints, were found to be deficient with respect to the specified acceptance criteria. Twenty-six of the inspected welds were undersized, two welds were short in length and one pipe did not have full contact with the contoured tube steel saddle. As a result of this finding the applicant issued Nonconformance Reports (NCRs) and the welds were subsequently determined to be adequate for the intended appiteation. See Table IV-1 for details. The inspection of the Steam Generator lateral support welds showed areas which were overground by 1/16 to 1/8 inch. Ofscrepancy Report QA-MISC-083 was written to document this condition. No deficient pipe welds were identified during this inspection. However, during the review of piping documentation, it was observed that the actual width of weld buildup on the inside surface of MS-56A, field weld 334, had not been documented adequately to confirm that all buildup was actually included in the radiograph of the adjacent butt weld. The review of the radiographs revealed an acceptable weld buildup condition. During the review of 50 Material Test Reports for welding filler metal, it was observed that the purchasing specifica-tions did not specifically address the requirements of ASME Section !!! pertaining to heat treated tensile strength and the minimum required impact test values. As a result, the test reports had not been reviewed against the applicable code requirements. Discrepancy Report QA-Misc-081 was issued and the welding filler metal test reports were reviewed against the applicable Code requirements. Subsequent reviews by Hunter and the NRC CAT inspectors did not reveal any unacceptable material. IV-S
^ (2) Nondestructive Examination Activities In general, the inspected NDE activities were found to comply with the appifcable codes and specificaticns. However, during the review of the radiographic film some minor irregularities were identified which involved the following five welds: Three Field Welds, P-1A-275FW14. CU-28FW2846 and OG-60-1 FW563 had one set of film and each film had artifacts in the area of interest. These conditions were not identified on the reader sheet by the interpreter or the S&L reviewer. The welds were re-radiographed and the weld quality was detennined to be acceptable. Field Weld RH-13FW135 station 30 had a linear indication. This was not recorded on the reader sheet. The weld was re-radiographed and the indication was determined to be an acceptable root surface condition. Shop Weld 51-43-2 Weld 4, conta'ined some views which were identified as being Weld 6. In other cases Weld 6 was crossed out and Weld 4 written instead. The dates on the weld 6 views did not correspond with the reader sheet dates and there was no explanation on the reader sheet to identify the correct status of the weld. After careful comparison of indications and film marks on a film-by-film basis it was detennined that the correct weld was radiographed in i its entirety and there were no rejectable indications in the area of interest. Oneultrasonic(UT)procedureQC-UT-1didnotstatehowthe inspector was to perform UT thickness calibrations. Section V of the ASME Code paragraph T-561 states that "The instrument shall be calibrated on a block of the same material and product fonn as the material to be measured." The procedure did not incorporate this Code requirement. However, the NDE manager ( stated that they do verify the calibration using the same material and product form as the material to be measured. The manager also stated that the procedure will be revised to t incorporate this requirement. c. Conclusions (1) Weldino Activities In general, the inspected welding activities were found to comply with the requirements of the applicable codes and specifications. However, the NRC CAT found structural welds on pipe supports and pipe whip restraints which did not meet the weld specifications. The conditions were evaluated by S&L and determined to be adequate for the intended appli-4 cation. IV-6
s (2) Nondestructive Examination In general, the inspected NDE activities were found to comply with the requirements of the governing codes and specifica-tiens. However, the NRC CAT inspectors found some film (1 weld) which was misidentified. Other film (3 welds) had artifacts in the area of interest and the readers sheets did not record these corditions. One weld has a linear indication not noted on the reader sheet. 2. Reactor Internals Modification and Installation a. Inspection Scope Approximately 25 welds on the improved rod cluster control guide tubes were visually inspected. The welds and documentation packages for the lower internals storage rack modifications were also reviewed. In addition, one welding procedure and the qualification test records for two welders were also reviewed for adequacy. The modification work was performed by NISCo. b. Inspection Findings and Conclusions No problems were identified in the area of inspected welding activities. Activities were found to meet the specified acceptance criteria. 3. Preservice Inspection (PSI) a. Inspection Scope Approximately 20 welds requiring preservice and inservice inspec-tions were visually inspected (VT) in order to verify compliance with the requirements of Section XI of the ASME Code. Four of those welds were also ultrasonically (UT) and liquid penetrant (LP) examined using the applicable project NDE procedures. Two closure plates and 2 welds were LP and VT examined in accordance with the original preservice requirements. In addition, the qualification test records for four NDE technicians were reviewed and 4 techni-cians were observed while performing UT and PT inspections. Three NDE procedures and 15 equipment calibration records were reviewed for adequacy. The NRC CAT inspectors also examined 30 thickness check reports and witnessed the performance of thickness measure-ments. The calibration of UT equipment for thickness measurements was also reviewed and witnessed. The preservice inspections were performed by Ebasco, b. Inspection Findings During the review of the Ebasco's UT thickness verification proce-dure, it was noted that the equipment is calibrated using a !!W Block. The !!W block (standard industry block) did not have any identification, therefore, it was not possible to determine the material and product form of the block. Section V of the ASME Code requirement T-561 states that: "The instrument shall be IV-7
calibrated on a block of the same material and product form as the material to be measured." As a result of this finding Ebasco inspected the b1nck by applying a magnet and determined that the block is made from an austenetic stainless steel material. Twenty (20) thickness reports were also reviewed. The ' review revealed that the tested pipes had 20 to 30 percent thicker pipe wall thickness that the minimum required design thickness. The thickness examinations are not an ASME Section XI requirement and the project perfoms these thickness checks as an additional verification of the minimum design thickness. c. Conclusions No problems were identified in the inspected preservice inspection activities. Activities were found to comply with the requirements of the governing codes and specifications. 4. Electrical Installation and Electrical Supports a. Inspection Scope The NRC CAT inspectors reviewed approximately 180 field and 50 shop welds in the area of electrical installation. Three welding pro-cedures and the qualification test records for seven welders were reviewed. In addition, the personnel qualification test records for four welding inspectors were also reviewed and two inspectors were observed and evaluated for their ability to follow the visual inspection procedures. The welding activities in the electrical area were perfomed by Hatfield Electric Company, b. Inspection Findings During the inspection of hanger H543 no weld detail drawing was found for the installed type of weld attachment. In addition, the weld joining the angle iron to the Tee shape section was found to have lack of fusion and insufficient throat. As a result of this finding NCR 1687 was issued and the weld detail was found to be acceptable. The review of radfographic flim for welder qualification testing revealed that the film for welder stamp #LG did not meet the requirements of the AWS D1.1 Structural Welding Code. Further examination of QC records established that this welder has welded a total of 18 hangers. The NRC CAT inspectors reinspected seven of these hangers and the Itcensee reinspected all 18 hangers. The inspected welds were found to be of acceptable quality. c. Conclusions With the exception of the minor discrepancies of one hanger and one welder qualification radiograph the inspected activities were found to comply with the applicable construction codes and specifications, i IV-8
5. Instrumentation Tubing Installation and Instrumentation Supports a. Inspection Scope Approximately 120 welds involving 18 instrumentation supports, 2 panels, and 30 tubing welds were visually inspected to ascertain compliance with the specified acceptance criteria. Seven welding procedures and qualification test records for seven welders were reviewed. NDE procedures and qualification records for five NDE inspectors were also reviewed. Two visual welding inspectors and one liquid penetrant inspector were observed and evaluated for their ability to follow the applicable inspection procedures. The welding in the instrumentation area was performed by Powers-Azco-Pope (PAP). b. Inspection Findings and Conclusions No deficiencies were identified in the area of instrumentation welding and NDE activities. Activities were found to comply with the applicable construction codes and specifications. 6. Heating. Ventilating and Air Conditioning Installation and supports a. Inspection Scope Approximately 140 welds involving 16 supports were inspected for compliance with the specified acceptance criteria. Three welding procedures and the qualification test records for six welders were reviewed. In addition, four personnel qualification test records were also reviewed and two welding inspectors were observed and evaluated for their ability to follow the visual inspection proce-dures. The welds on eight duct pieces, two air blowers, one air filter and four damsers were also included in this inspection. The welding in the MVAC area was performed by Reliable Sheet Metal (RSM). b. Inspection Findings During the inspection of duct piece M1285-4-44 a burn-through the duct was observed near the welded joint between the duct and the duct companion flange. As a result of this finding, RSM issued Discrepancy Report (DR) #M1285-4-7689 and the duct was repaired. On duct piece M1287-4-C-10 a three sided stiffener was found to be installed with staggered stitch welds 1 inch long on 11 inch centers instead of the required 1 inch long on 9 inch centers as specified on design drawings. As a result, OR #M1287-4-T690 was written and a four sided stiffener was added to correct the deficiency. It should be noted that both of these items had not been subjected to the Type 2 inspection which is performed by RSM after the first line QC inspection is completed. The NRC CAT inspectors identified auxiliary tube steel welded connections on eight hangers to be deficient with respect to the !V-9 L
specified acceptance criteria. The eight hangers and their associated welding deficiencies are listed below:
- Hanger H3824 - Undersized weld was found on the section end of the east clip to the tube steel connection.
- Hanger H3827 - Clip to tube steel weld was found to be undersized.
- Hanger H3749 - The return welds were found to be undersized.
- Hanger H3820 - The return welds and the top east weld to clip were found to be undersized.
- Hanger H3856 - East side of the auxiliary steel to clip weld was found to be undersized.
- Hanger H3652 - Top weld on east end clip to tube steel and the top return weld on the north clip were found to be undersized.
- Hanger H3754 - Vertical weld and top and bottom welds on tube steel were found to be undersized.
- Hanger H3753 - Clip to tube steel welds and north auxiliary steel return were found to be undersized.
As a result of these findings, RSM issued NCR 118. The deficiencies were reviewed by S&L and found to be adequate for the intended application. See Section !!! of this report for additional details, c. Conclusions With the exception of the findings (burn-through duct in one isolated case, deficient stitch welds and undersized welds in auxiliary steel connections) the inspected welding activities were found to comply with the appitcable codes and specifications. The undersized welds on auxiliary steel has been reviewed and been found acceptable by S&L. 7. Structural Steel Fabrication. Erection and Modification a. Inspection Scope Approximately 120 welds comprising 70 field and 50 shop welds involving 21 structural beams were visually inspected in order to ascertain compliance with the specified acceptance criteria. Five welding procedures and the qualification test records for six welders were reviewed. Visual inspection procedures and the qualification test records for four inspectors were also reviewed. Two welding inspectors were observed and evaluated for their ability to follow the visual inspection procedures. The structural steel I field welding was performed by Blount Brothers. American Bridge and Inland Steel Company supplied the structural steel to the project. IV-10
b. Inspection Findings No problems were identified in the area of inspected welding activi-ties involving the modification of structural steel. However, several original welds involving clip to beam web connection welds were found to be deficient. Specifically, the design drawings required fillet welds all around, while the connection was seal welded on the top and bottom of the clip angle due to coping of the beam web. The deficient connections are identified as follows: North end of beam A45788; West end of beam A45785; South end of beam 49982; and West end of Beam 8482. The connection on the left end of beam 43501 was found to be undersized with respect to the specified sizes on the design drawings. These welds were completed by American Bridge. As a result of these findings Discrepancy Reports Q3-946 and Q3-947 were issued. The deficiencies were reviewed by S&L and determined to be adequate for the intended application. c. Conclusions With the exception of the undersized clip angle to web welds the inspected welding activities were found to comply with the speci-fled requirements. The undersized welds were reviewed by S&L and determined to be adequate for the intended application. 8. Refueling Cavity Liner Fabrication a. Inspection Scope The NRC CAT inspectors visually inspected approximately 60 feet of welded seam and 12 slot welds on the Reactor Pool Liner. The attachment welds for six brackets and the welds on the reactor vessel head guide pin rack drive shaft tool brackets were also inspected in order to ascertain compif ance with the specified acceptance criteria. Two welding procedures and 3 welder qualifi-cation test records were reviewed for adequacy. In the area of NDE the NRC CAT reviewed the radiographs for 27 spot welds involving 54 film. The Refueling Cavity Liner fabrication was completed by PittsburghDesMoinesCorporation(PDM). b. Inspection Findings and Conclusions No discrepancies were identified in the areas of inspected welding and NDE activities. Activities were found to comply with the applicable construction codes and specifications. 9. Fire Protection System Fabrication and Installation a. I.nspection Scope Approximately 60 welds involving 10 pipe supports and 15 pipe welds involving 2 pipe spools were visually inspected. One welding IV-11
procedure and the qualification test records for two welders were also reviewed for adequacy. One Engineering Change Notice (ECN 247916) was reviewed for adequacy. This ECN pertained to increase of weld sizes on support 2FP2045X. 'The fire protection installation l was completed by Hunter. b. Inspection Findings and Conclusions No deficiencies were identified in the area of inspected welding and NDE activities. Activities were found to comply with the governing construction codes and specifications.
- 10. Containment Liner and Containment Penetration Installation a.
Inspection Scope The NRC CAT inspectors visually inspected approximately 40 feet of i liner seam, welds on two pad plates, the attachment welds for one Emergency Air Lock, the welds on an construction opening, and the attachment welds for two mechanical and two electrical penetrations. Two welding procedures and the qualification test records for two welders were also reviewed. In the area of NOE, the NRC CAT reviewed the radiographs for 197 feet of welded seam which involved 349 film. One radiographic examination procedure was also reviewed as a part of this inspection. The containment If ner and penetra-tions were installed by Chicago Bridge and Iron (C8&I). b. Inspection Findings l l No problems were identified in the area of inspected welding activities. However, during the review of radiographs the NRC CAT l inspectors identified welds which did not meet the required weld quality. The weld; and their associated deficiencies are Ifsted as follows: Weld (92-A)-(92-1)hadacrackattheendoftheweldnear station 0. This was not noted on the reader sheet. Weld 46-4-11 to 46-12-1 had a rejectable linear indication. The indication appeared on film RS3 and was not recorded on the reader sheet. The reader sheet recorded RS2 as being the final repair shot for the weld. c. Conclusions l In general, the inspected welding and NDE activities were found to comply with the governing codes and specifications. However, two welds were found to contain unacceptable indications. As a result of this finding, the applicant has committed to review and evaluate this item. i i IV-12 l l
l
- 11. Vendors and Shop Fabricators Other Than Those Previously Addressed a.
Inspection Scope The NRC CAT inspectors visually inspected six vendor supplied tanks and heat exchangers (See Table IV-5). In addition to the welds inspected and listed in Table IV-5, the NRC CAT inspect: ors reviewed radiographs related to work performed by 28 vendors which have supplied various equipment and hardware to the Byron Power Station project. A total of 350 feet of welded seam involving 889 radiographs and 28 welds involving 245 film were reviewed. The radiographs for 19 valves and pumps involving 304 film, and the radiographs for 60 spot welds involving 93 film were also reviewed for compliance with the governing codes and specifica-tions (See Table IV-6). b. Inspection Findinas During the inspection of tanks and heat exchangers supplied by the vendors listed in Table IV-5, the NRC CAT inspectors found that the size of the nozzle and manway weld reinforcement did not meet the requirements stated in the vendor drawings. In addition, the welds on some of the inspected supports were also found to be undersized. A total of six tanks and heat exchangers were found to deviate from the required drawing sizes. See Table IV-5 for details. The NRC has issued Information Notice 85-33 on the subject of undersized weld reinforcement in ASME Code nozzle to shell joints. As a result of the Information Notice, the licensee had inspected the nozzle welds on ten pressure vessels and tanks prior to this inspection. Undersized weld reinforcement on the nozzle to shell welds were identified on the ten tanks. The licensee issued NCRs on this issue. It was identified that some of these welds violate ASME Code requirements for minimum size of welds. In the area of NDE, the NRC CAT inspectors identified deficiencies relating to NDE documentation and radiographs supplied by vendors. Specifically, unacceptable indications were found in radiographs supplied by ITT Grinnell (one weld), Graver (one weld), Phillips Steel (two welds), and Teledyne Brown (one weld). Irregularities with the NDE documentation were noted in the documentation supplied by G&W Energy, Continental Boiler, Cleaver Brooks and Harnischfeger Corporation. See Table IV-6 for details. In addition, the film for the Component Cooling Surge Tank (2CC01T) and the Volume Control tank (2CV01T) which were stored by Westinghouse were not available to the NRC CAT inspectors for review during the inspection period. This indicates a lack of retriev-ability for ASME documentation. c. Conclusions In general, the inspected welding and NDE activities were found to comply with the requirements of the governing codes and specifica-tions. However, six tanks and heat exchangers were found to deviate from the requirements stated in the applicable drawings and specifi-cations. In addition, the radiographs and NDE documentation IV-13
supplied by vendors were found to be deficient with respect to the required quality. The film for two components supplied by Westinghouse were not provided during the inspection period. l I w 4 I e I t t IV-14
E { TABLE IV-1 LIST OF SUPPORTS WHICH WERE INSPECTED AGAINST DRAWING REQUIREMENTS 2SIO3001X 2SI13020X 2CC22004X 2SI42001X 2SI23003X 2RH02073X 2CC19018X 2CV03009S 2SIO3025V 2RYO60155 2SIO9006X 2RH02050X (6) 2SIO3041X 2CC23009X 2RH02069X 2SI26010X 2CC19013X (1) 2 WOO 2014X 2FWO5018X 2RYO90865 2FWO30125 2SI16020X 2FWO3008X 2RH02027X 2 WOO 3003X 2MS030795 2SXO8037X 2SIO6261X 2SIO6258X 2CS06033A 2SIO6263X 2SIO6262X 2CS03A099X 2CS104014A 2SIO6238X 2CS08020X 2SIO6241X 2SIO6236X 2CS01200X 2CV47044A 2CV74004X 2SIO3011X(6) 2SI9R5558 (2) (a) MS-P16 (a) RC-4-4 (3) (a) RY-7(4)(a) 2SI13R-655B (5) (a) NOTES: (1) 'Two fillet welds 1/2" short on length along web of W-section. Discrepancy Report DR-QC-2CC19003. See Section II of this report for additional discussion. (2) Ten welds under:;ized by more then 1/8". Whip restraint deleted prior to CAT inspection by Westinghouse. (3) Fnur welds 1/16" undersized one leg. NCR 1131. (4) Three 3/8" fillet welds undersized by 1/16" and short 3/8" on length. NCR 1133. (5) Nine welds undersized on one leg by as much as 3/8". NCR 1132. (6) Pipe not in full contact with contoured tube steel saddle. (a) Pipe Whip Restraints - shop welds only. IV-15
-m e a,% O-TABLE IV-2 SUPPORTS WHICH WERE VISUALLY INSPECTED 2CV74005 2CV7400X 2CV16034V CV28003X CV16033S 2SI30A029X 2SI30A003X 2FP02055X FW93E010A 2SIO3042X 2CV47079R 2RH20011X 2RH20010X 2RH10000G 2FWO8022X 2MS010795 2MS010745 2MS01205X 2MS01206X 2M505002C 2MS05001X 2MS05006R i IV-16
TABLE IV-3 LIST OF PIPING WHICH WAS VISUALLY INSPECTED ITEM DESCRIPTION PIPE SIZE (IN.) MATERIAL 2CV-44-2 Chemical Volume Control 3 Stainless Steel 2RC-16-2 Reactor Coolant 3 Stainless Steel 2FC-24-2 Fuel Pool Cooling 4 Stainless Steel 2RC-19-2 Reactor Coolant 4 Stainless Steel 2RC-0010231-1A Reactor Coolant 2 Stainless Steel 2RC-51-1 Reactor Coolant 3 Stainless Steel 251-37-3 Safety Injection 18, 24 Stainless Steel 2RH-9-4 Residual Heat Removal' 14 Stainless Steel 2CS-18-3 Containment Spray 12, 16 Stainless Steel 2CS-17-2 Containment Spray 18 Stainless Steel 2CS-17-4 Containment Spray 14, 16, 18 Stainless Steel 2RH-14-4 Residual Heat Removal 8 Stainless Steel 2CV-17-4 Chemical Volume Control 8 Stainless Steel S-CV-100-241 Chemical Volume Control 2 Stainless Steel S-CV-100-242 Chemical Volume Control 2 Stainless Steel S-CV-100-243 Chemical Volume Control 2 Stainless Steel 2SX-20-5 Essential Service Water 6 Carbon Steel 2SI-56-4 Safety Injection 3 Stainless Steel 2SI-37-2 Safety Injection 24 Stainless Steel 251-40-1 Safety Injection 8 Stainless Steel 2RC-13-3 Reactor Coolant 4 Stainless Steel 2FC-21-2 Fuel Pool Cooling 4 Stainless Steel 2RE-13-7 Containment Equipment Drain 4 Stainless Steel 2SI-32-3 Safety Injection 12 Stainless Steel 2RH-10-8 Residual Heat Removal 4 Stainless Steel 2RH-10-7 Residual Heat Removal 8 Stainless Steel 2RH-10-5 Residual Heat Removal 8 Stainless Steel l l l IV-17 l
TABLE IV-4 PORTIONS OF PIPING SYSTEMS VISUALLY EXAMINED AND FOR WHICH DOCUMENTATION WAS REVIEWED ITEM DESCRIPTION PIPE SIZE (IN.) MATERIAL 2MS-60-1 Main Steam 30 Carbon Steel 2MS-60-2 Main Steam 30 Carbon Steel 2MS-60-3 Main Steam 30 Carbon Steel 2MS-60-4 Main Steam 30 Carbon Steel 2MS-60-5 Main Steam 30, 12, 4 Carbon Steel 2MS-60-6 Main Steam 28 Carbon Steel 2MS-60-7 Main Steam 28, 6 Carbon Steel 2MS-60-8 Main Steam 8 Carbon Steel 2MS-60-9 Main Steam 8 Carbon Steel 2PC-78 Main Steam Penetration 30, 42 Carbon Steel 2FW-25-7 Feedwater 16 Carbon Steel 2FW-25-6 Feedwater 16 Carbon Steel 2FW-25-5 Feedwater 16 Carbon Steel 2FW-25-4 Feedwater 16 Carbon Steel 2CS-17-1 Containment Spray 16 Stainless Steel 2CS-17-2 Containment Spray 16 Stainless Steel 2CS-17-3 Containment Spray 16 Stainless Steel 2CS-17-4 Containment Spray 6, 14, 16 Stainless Steel 2CS-17-5 Containment Spray 14 Stainless Steel 2CS-16-1 Containment Spray 10, 8 Stainless Steel 2CS-16-2 Containment Spray 10 Stainless Steel 2CS-16-3 Containment Spray 10 Stainless Steel 2CS-16-4 Containment Spray 10 Stainless Steel 2CS-16-5 Containment Spray 10 Stainless Steel l l l l l l l l I IV-18 l t
TABLE IV-5 TANKS AND HEAT EXCHANGERS WHICH WERE VISUALLY INSPECTED ITEM MANUFACTURER Accumulator Tank 2SIO4TA (1) Southwest Fabricating and Welding Letdown Heat Exchanger 2CV01AA (2) Atlas Industrial Manufacturing Volume Control Tank 2CV01T (3) Lamco Industries, Inc. Component Cooling Surge Tank 2CC01T (4) Westinghouse Corporation Spray Additive Tank 2CS01T (5) Graver Tank Company Fuel Oil Day Storage Tank 20001TA (6) Chicago Bridge and Iron Company (1) Bolting ring fillet weld 1/16" undersized on one leg. NCR-1148 (2) One nozzle reinforcing fillet weld 1/8" undersized. NCR-1148 (3) One nozzle reinforcing fillet weld size 1/16",1/4" required. NCR-994. (4) Manway fillet welds undersized, nozzle welds undersized, saddle and stiffening ring fillet welds undersized. NCR-994. (5) Support leg fillet welds undersized. NCR-996. (6) Bolting. ring to tank fillet weld 1/16" undersized, stiffener fillets intermittently undersized, and two nozzle reinforcing fillets undersized. NCR-1148 IV-19
TABLE IV-6 VENDOR RADIOGRAPHS REVIEWED Valve Spot Feet of Contractor Welds Pumps Welds Welds Film Notes G8W Energy 5 56 (1) Products TRW Mission 8 48 Manufacturing Anchor Darling 2 55 Farr Company 7 94 Continental Boiler 8 8 (2) McQual Perfex 5 12 Pall Trinity 2 28 ACF Industries 1 20 Jamesbury Corp. 2 19 Cleaver Brooks 42 36 (3) Graver Corp. 75 180 (4) Yuba 59 120 Harnischfeger 19 63 (5) Dresser Industries 11 44 Bingham Willamette 1 62 Manning Lewis 1 1 Cooper-Bessemer 4 4 Carrier Corp. 9 9 Greer Hydraulics 8 32 ITT Grinnell 5 8 (6) W. J. Wooley 13 48 l Atlas Industrial 28 108 Plant Mangement Corp. 5 5 IV-20
I TABLE IV (Continued) VENDOR RADIOGRAPHS REVIEWED Valve Spot Feet of Cortractor Welds Pumps Welds Welds Film - Notes Phillips Steel 27 54 (7) Borg Warner 5 100 Teledyne Brown 96 204 (8) Rockwell Inter-5 71 national Aerojet Energy 3 42 NOTE-(1) The film packet for one of the welds which should have contained film for five intervals, contained film for only two intervals. The missing film for the other three intervals was later found and was reviewed with no problems identified. (2) The reader sheets with the film indicated that this film was for Braidwood components. Further investigation of documentation indicated that the items had originally been scheduled for Braidwood but had later been transferred to Byron. (3) Reader sheets for weld WT 8549-64 were not in that packet but were found in film packet for weld WT 2158-64. (4) Circumferential seam 1Al-6 showed added weld metal on interval A-B dated 1 June 20, 1977, however the added metal does not show in interval M-A l dated June 23, 1977. CECO reviewed the film and returned it supposedly in proper order. However due to two different identifications on the film, it was impossible to tell whether one or two welds were represented by these film. Subsequently, CECO determined that the film actually were from only one weld, and that further repair in the M-A interval accounted for the difference in appearance of the two weld intervals. On weld 1Al-1 (Job 2) interval 11-12 a linear indication, possibly a crack, was noted. CECO then did an ultrasonic examination of the area. However, the performed examination was a longitudinal examination and is not acceptable for this type and location of indication. An NCR is being l written. This indication is in vessel IC80!T (Byron 1). l l In vessel H1 tank 2 weld 3Al-1 interval F-G at the end of the seam in the transverse weld, an indication was noted. However, when the ' film of the transverse weld were located they showed no indication of a problem in the area mentioned. IV-21 1 1
TABLE IV (Continued) VENDOR RADIOGRAPHS REVIEWED NOTES: (5) When the film was submitted, the reader sheets were so faint that it was impossible to read them. Subsequently, the original sheets in the QA file were produced and the film was read. No problems were noted. (6) A 3/8 inch slag line was noted in the 2-3 interval. After reviewing the receiving and issuing documents, it was determined that the' item had never been issued to the job for installation. (7) Area 3255-A OWX10D had a linear indication on each of the junction welds. Area 3244-A-2V2 OWXO7 TV2 had the penetrameter shim into the area of interest. (8) 4901-9, weld 147 A-B, had an unacceptable slag line at station A and the belt numbers appears to be inside the area of interest. Six welds did not have full coverage. The welds were identified as: 4901-9, - weld 103 G-H, weld 116 A-B, weld 160 G-H; 4901 welds 147 A-B and 160 G-H; and 4902, weld 75 B-C. Item 4901-10, weld 103 G-H, also did not have full coverage and there was a linear indication extending into the uncovered area. IV-22
V. CIVIL AND STRUCTURAL CONSTRUCTION A. Objective The objective of the appraisal of civil and structural construction was to determine by evaluation and review of Quality Control (QC) accepted work and documentation whether civil and structural construction areas were completed in accordance with regulatory requirements, Safety Analysis Report commitments, and project specifications, drawings.and procedures. B. Discussion The specific areas of civil and structural construction evaluated were structural steel installation, high strength bolting for structural steel connections and Nuclear Steam Supply System (NSSS) support con-nections, general concrete surface quality, cadwelds,' concrete placements, concrete expansion anchor (CEA) qualification report, masonry and containment prestressed, post-tensioned tendons. A physical or hardware inspection and a review of QC documentation and field procedures were conducted for the following activities: structural steel installation, high strength bolting for structural steel connections and NSSS support connections, general concrete surface quality, masonry and containment prestressed post-tensioned tendons. For concrete expansion anchors, cadwelds, and concrete placement, this portion of the NRC Construction Appraisal Team (CAT) review was limited to a review of QC documentation and field procedures. The qualification report for CEAs was also reviewed. The installation of concrete expansion anchors was also reviewed in the mechanical and electrical construction areas (see Sections II and III). 1. Structural Steel Inspection 1 a. Inspection Scope Installed and QC accepted structural steel were inspected by the NRC CAT. Attributes inspected were member size, configuration, and bolted connections. For bolted connections, both friction and sliding connections were tested by using a calibrated torque wrench to determine whether the bolts had proper pretension. l The sample used in the structural steel verification for correct member size and configuration is described in Table V-1. A total i of 85 structural steel members and 38 connections were inspected. l High strength bolting for structural steel connections and NSSS l support connections which were checked for pretension are shown in Tables V-2 and V-3a, respectively. A total of 699 high strength l bolts were tested for proper pretension. These included 7/8 inch l diameter A325 and 1 inch and 1 1/8 inch diameter A490 bolts. As a i result of NRC CAT inspection findings, the licensee inspected additional A490 bolts for structural steel connections and NSSS support connections (See Table V-3b). The A325 bolts were sampled from structural steel connections. Test torque values were obtained V-1
by using a Skidmore Wilhelm tension tester to establish the proper i torque-tension relationship. In addition, a total of 62 bolts sampled from 17 sliding connections were checked for installation torque. The requirements and acceptance criteria for structural steel installation are included in the drawings listed in Tatile V-4 and in the following specifications and procedures: Blount Brothers QA/QC Work Procedures #21. " Structural Steel Fabrication, Repair, Modification and Erection," Rev. 16, May 8, 1984. Powers-Azco-Pope Procedure No. FP-21, " Bolted Connections," Rev. 2, June 17, 1983. Hunter Corporation' Site Implementation Procedure #4.001, "8olted Connections," Rev. #2, May 26, 1983. Pittsburgh Testing Laboratory Procedure No. QC-SR-1, " Structural Steel Inspection," Rev. #2, July 24, 1984. b.' Inspection Findings i For the 85 structural steel members and 38 connections, no signifi-cant hardware deficiencies were identified. There were seven minor 4 design drawing or hardware discrepancies. However, none of these resulted in a significant hardware deficiency and were evaluated to be acceptable in the installed condition. These findings are 4 described below. 4 Th'e seven minor design drawing or hardware discrepancies were: l 4 p 1. Design drawing (S-1015, Rev. AJ) showed a W14x90 was to be used for the radial beam (Modification No.94204) at radial line R42 1 of the Containment Unit 2 Building. However, a W14x78 was actually installed. Apparently, the original design drawing specifled a W14x78 which was not available at the time of i installation. Field Change Request (FCR) 696 was issued to allow the use of a W14x90 (which was readily available) instead 1 of the W14x78 originally specified. A change to the design 1-drawing to reflect the FCR was done. Following this, a W14x78 became available and was subsequently installed as originally intended. FCR 696 was voided, but followup was not done to l revise the design drawing to show the installed W14x78. There i j. was no hardware deficiency. 2. Design drawings incorrectly showe'd the left connection of Beam No. 94203 as Detail 2329-17 only. Based on comments from the NRC CAT inspectors, FCR 44354 was issued to correctly describe the actual connection as Detail 3 and Detail X on Drawing S-2228 and Detail 2329-17. There was no hardware deficiency. i 4 V-2 i
V 3. Beam No. 3.6AB1012N-2 had four abandoned flame-cut holes in the bottom flange at about mid-span. These four holes had not been identified previously. Deviation Report (DR) 949 was issued to correct this deficiency. The resolution was to plug weld the holes. 4. The top connection of the double angle brace to Biam No. 5AB1026N was to be a 10 bolt connection, but only 8 bolts were installed. The missing two bolts had not been identified previously. DR #Q3-951 was subsequently issued. Sargent and Lundy Engineers (S&L) evaluated the existing condition to be acceptable as-is; however, the 2 bolts missing would be installed. 5. The brace to column connection directly below Beam 8.6AB235 at elevation 467 was installed with four bolts in a six bolt connection and welded where the bolts had not been installed. Previously, FCR F-41049 had identified the as-built condition and was acceptable as-is. However, the FCR was not clearly incorporated onto the design drawing. The as-built condition (correctly shown on the FCR) was welded across the top 1 inch on both corners of the plate. However, on the design drawing it appears that the weld is to be across the entire top side of the plate. 6. The right end connection of Beam 8.6AB218R had been welded in lieu of bolted. However, the design drawings showed the connection as bolted. This condition was not identified previously. FCR F-44359 was issued to document the as-built condition on the design drawing. There was no hardware deficiency. 7. Beam 3.6AB1102N had a cope in the bottom side of the flange which did not meet the American Institute of Steel Construction (AISC) requirements for minimum 1/2 inch radius. Deviation Report for Correctable Items (ORC) No. 2C-374-23 was then issued to repair this condition to meet the AISC requirements. It was noted that the licensee had previously identified similar deficiencies as described above in the Quality Control Structural Steel Review (QCSSR) Program and in the resolution of NCR F-743 (reportable deficiency 82-08). For the installed torque inspection of 7/8 inch diameter A325 bolts, 294 and 185 bolts were sampled from the Containment Unit 2 and Auxiliary Building, respectively. Of these, 15 had been installed at torques significantly below the inspection torque values. Six (5-Containment and 1-Auxiliary Building) were installed with zero torque. In addition, two 7/8 inch diameter A307 bolts were used in a connection which should have been A325 bolts. See Table V-2. For the inspection of 1 1/8 inch diameter A490 bolts, 112 bolts in the Containment Unit 2 were inspected. Of these, 36 (approxi-mately 32%) were determined to be at torque levels significantly below the inspection torque value. It was determined by S&L that V-3
there are 29 connections requiring tension in the bolts to transfer axial loads. The licensee field tested the bolts on 25 of the 29 connections. The remaining four connections were determined to be inaccessible. It was detemined that 95 out of 228 (approximately 42%) bolts tested were significantly below the inspection torque. The lowest average torque value in a connection was 67% less than the average inspection torque. See Table V-2. For the 1 inch diameter A490 bolt inspection, 208 bolts were sampled from NSSS support connections. Of these, 49 (approximately 23%) were at torque levels significantly below the inspection torque value. The licensee field tested 56 additional bolts of the NSSS support connections. It was determined that 20 (approximately 36%) were at torque levels significantly below the inspection torque. See Table V-3a, b. S&L design drawings allow the substitution of M4x13 structural steel sections for W4x13 structural steel sections for pipe sup-ports. The resulting vertical weld configuration shown on the design documents for the M section is shorter than that for the original W section. The licensee indicated that a review would be conducted to show that this substitution would not cause an over-stress condition. The sliding connections were generally found to be acceptable. A few bolts were found to be installed at torque values below 50 ft-lbs. Installation requirements at the time of inspection specified the bolts be installed between 50 and 100 ft-lbs. c. Conclusion In general, structural steel installation was found acceptable. Although several design drawing and hardware discrepancies were identified, they were considered isolated cases.and did not signi-ficantly affect the installed hardware. A significant number of bolted connections were found by the NRC CAT inspectors to be below inspection torque levels indicating less tension in the bolts than specified by the American Institute of Steel Construction (AISC). The sliding connections were found to be acceptable. 2. Reinforced Concrete Construction l l a. Inspection Scope Reinforced concrete construction areas inspected were general surface quality, cadweld documentation, concrete pour packages and the qualification report for the wedge type concrete expansion anchors (CEAs). General concrete quality was examined from surrounding areas of completed concrete construction for conformance to site specifications. Cadweld documentation covering the initial site cadweld splicing production performed by Delta-Delta Midstates were reviewed. Cadweld documentation was also reviewed for the period covering June V-4 l
11', 1980 thru July 31, 1980, performed by Blount Brothers Corpora-tion. The qualification records for eight cadwelders of Delta-Delta Midstates were reviewed. The records showed proper qualification of cadwelders by visual and tensile testing in each position and bar size. The following cadweld records or QC documentation were reviewed: " Sample Selection Lcg" " Requests for Sister Splices T-Vertical" " Tensile and Visual Reports for Samples U-I" "Cadweld History T-Horizontal," thru December 31, 1977. "Cadwelding Cadweld History." Nine concrete pour packages were reviewed. A list of those reviewed is provided in Table V-5. Records reviewed and associated with the concrete placements were field concrete control log sheets, concrete placement checkout sheets, quality control report pre-placement checklists, quality control report surveillance of con-crete placement and compression tests of 6x12 inch concrete cylinders. The records were checked for adequate completion by the QC inspectors, the existence of senior QC inspectors' signature for evaluation of completed forms, and acceptable coverage of attributes by the documentation. The following qualification. test report for the wedge type CEAs was reviewed: Summary Report-Static, Dynamic and Relaxation Testing of Expansion Anchors in Response to Bulletin 79-02, July 20, 1981. The requirements and acceptance criteria for reinforced concrete construction are contained in the following drawing, specifications, and procedures: Orawing S-693, Rev. AF, " Auxiliary Building Floor Framing Plan El. 383 ft-0 inches Area 6." BY/BR/MCS, " Specification for Making and Inspecting Mechanical (Cadweld) Splices," Rev. 7 July 5, 1978." BY/BR/CEA, "BY/BR Standard Specification for Concrete Expansion Anchor Work Byron Units 1 and 2 and Braidwood Units 1 and 2." CECO Specification F/L-2722, " General Structures Work," Rev. 41, June 21, 1985. V-5
b. Inspection Findings General concrete surface quality was found to be acceptable. Concrete openings were being recorded on a Miscellaneous Opening Identification Walkdown computer log. No concrete opening or chip out was identified by the NRC CAT that was not either recorded on the miscellaneous opening computer log or field repaired with backup engineering evaluation by S&L. QC documentation kept for cadweld splicing pr'oduction by Delta-Delta Midstates did not clearly show that Part B.2.3.4 of the FSAR was met for tensile testing frequency. As a result, the licensee comitted to reconstruct the tensile testing sequence of each cadweld operator to verify that the FSAR comitments were met. Cadweld records provided for cadweld splices perfomed by Blount Brothers Corporation from June 11, 1980 to July 31, 1980 indicated that the tensile testing requirements were met. The concrete pour packages reviewed were found to meet FSAR, spect-fication and procedure requirements. Proper QC inspection attri-butes were listed in the documentation. The NRC CAT identified that in some cases for oversized holes in pipe support base plates, washers were not required by procedures to be welded to the base plate. These support assemblies rely on the induced friction between the mounted plates and concrete surface to prevent lateral movement of the pipe support. Tensile preload in the CEAs is critical for these supports. Neither the CEA qualifi-cation test report nor other documents provided by S&L provided a correlation between tensile preload in the CEAs and installed torque or the amount of residual tension in the CEA with time. The torque to preload relationship was determined using the Marks Engineering Handbook formula using a coefficient of friction of 0.3 and a correlation was made with test results from another site. However, this does not adequately demonstrate that the residual tension in the CEAs installed at Byron is sufficient to prevent excess 1ve pipe support movement. Using the formulas in the Marks Engineering Handbook with a low coefficient of friction will yield results that may not be conservative. The coe'ff cient of friction for steel on steel can be as high as 0.8. The preloads calculated using this coefficient would not be conservative. In the CEA qualifications test report the embedment depth of the concrete expansion bolts was measured from the bottom of the wedge to the face of the concrete. Site QC inspectors, however, measure the embedment depth from the bottom of the anchor to the face of the concrete. The difference between these measurements is approxi-mately one anchor bolt diameter. As a result, for all size CEAs except the 1/4 inch diameter ones, the embedment depth could be seven diameters instead of the eight diameters required by the qualification report. For the 1/4 inch diameter CEAs the embedment depth could be 2.25 diameters instead of the six diameters required V-6
4 by the qualification report. It appears that design requirements were not properly translated into installation and inspection procedures. c. Conclusions General concrete surface quality and concrete pour packages were found to be acceptable. The licensee has committed to reconstruct the cadweld records to verify conformance to FSAR, specification and procedure requirements for those performed by Delta-Delta Midstates. The licensee has not demonstrated that the installation torque for CEAs will produce adequate preload in the bolt when installed in materials similar to those used on site. It appears that the CEA embedment depth was not measured conserva-tively especially with the smaller anchors (i.e.,1/4 inch dia-meter). An evaluation of site practice and inspection methods should be made to ensure that the embedment depths are consistent with the qualification report. 3. Masonry Wall Construction a. Inspection Scope Masonry wall construction activities reviewed included controlling procedures, specifications, and inspection of installed masonry walls. For the installed masonry walls, the inspection concentrated on exterior column modifications. The masonry work reviewed was in the Auxiliary Building and incl.ded 4 column modifications and the inspection records for 3 masonry walls. The requirements and acceptance criteria for masonry construction and inspection are listed in Table V-6 and the following specification: Ceco Specification F/L-2722 " General Structures Work," Rev. 41, June 21, 1985. b. Inspection Findings and Conclusions Examination of inspection records and completed work showed that masonry wall installations generally conformed with design drawings and specifications. c. Conclusions In general, masonry walls inspected were found to be acceptable. 4. Prestressed Tendon Installation a. Inspection Scope The installation records of 15 prestressed tendons of the Contain-ment Unit 2 were reviewed for conformance to the project specifica-V-7
tion. The tendons reviewed were five vertical, five horizontal and five dome. The vertical, done and three of the six horizontal tendon galleries were inspected for evidence of leaking grease. The requirements and acceptance criteria used for inspection of prestressed, post-tensioned tendon installation were included in the following specification: CECO Specification F/L-2722 " General Structures Work," Rev. 41, June 21, 1985. b. Inspection Findings One horizontal grease cap was found to be leaking grease. The grease was collected, measured and found to be one-tenth of a gallon. This is within specification limits. In order to more accurately monitor the grease loss in any tendon, the licensee plans to revise procedures and keep a running log of grease loss in each tendon. c. Conclusions In general, the prestressed, post-tensioned system was found to be acceptable. l i V-8
TABLE V-1 STRUCTURAL STEEL INSTALLATION SAMPLE Approximate Elevation Building and Area Beam Brace Column Connection
- Containment Elev. 450 ft.
26 3 14 Unit 2 Area 5 and 8 Auxiliary Elev. 374 ft. 15 1 8 to 376 ft. Area 7 Elev. 383 ft. 11 3 3 8 to 401 ft. Area 7 Elev. 451 ft. 5 2 4 3 to 459 ft. Area 7 Elev. 467 ft. 6 3 Area 7 Elev. 477 ft. 4 1 1 2 Area 7 TOTALS BT 6 IT T
- This sample is separate from the high strength bolt torque sample.
V-9
TABLE V-2 HIGH STRENGTH BOLTING OF STRUCTURAL STEEL CONNECTIONS 1 7/8 inch diameter A325 bolts : No. of Bolts Number of Bolts Buildina Elevation Checked Found Unacceptable Comments Containment 401'ft. 52 None Sample taken from Unit 2 connections along radial lines R29, R31, R38 and R40. 407 ft. 24 6 - 1 each 9 0,250, Sample taken along 350 and 400 lines R39 and R40. ft-lbs; 2 9 300 ft-lbs. 412 ft. 99 3 - 1 each 9 250 Sample taken along and 300 ft-lbs; lines R22, R38, R39 1 9 400 ft-lbs. and R40. 426 ft. 119 4 - All four 9 0 Sample taken along ft-lbs. radial lines R22'thru R26 and R32 thru R34. Auxiliary 451 ft. 73 None Sample taken from column lines U21, V21 523 to 525. 459 ft. 85 1 - One 9 175 ft-lbs Sample taken from column lines U21, V21 and 57-23. two 7/8 inch dia. A307 bolts were installed where A325 bolts should have been. 467 ft. 27 1 - One 9 0 ft-lbs Sample taken from column lines U21 and V21. TOTAL M 16 3% found unacceptable V-10
a TABLE V (Continued) HIGH STRENGTH BOLTING OF STRUCTURAL STEEL CONNECTIONS 2 11/8 inch diameter A490 bolts No. of Bolts Number of Bolts Buildina Elevation Checked Found Unacceptable Comments .:ntainment 401 ft. 66 25 - One each 9 200, 38% found Unit 2 425, 550, 600, ' unacceptable. 625, 700, 825, Sample taken 850, 900, 1025, from connections 1050, 1125, along radial lines 1150 ft-lbs. R23, R25, R29, R31 Two each 9 300, R38 and R40. 525, 800 ft-lbs. Three 9 500 and 1200 ft-lbs. 407 ft. 14 8 - One each 9 250, 57% found 300, 600, 800, unacceptable. 1150 and 1200 Sample taken ft-lbs. Two 9 along radial 1175 ft-lbs. lines R23, R25, R31, R38 and R40. 412 ft. 32 3 - One @ 600 ft-lbs. Sample taken Two 9 750 ft-lbs. along radial lines R23, R25, R33, R38 and R40. TOTAL 112 '6 32% found unacceptable. NOTE: 1. Inspection torque value used was 425 ft-Ibs. 2. Inspection torque value used was 1250 ft-lbs. I V-11 ?
o TABLE V-3a HIGH STRENGTH BOLT INSTALLED TORQUE INSPECTION FOR CONNECTIONS OF NUCLEAR STEAM SUPPLY SYSTEM SUPPORTS 1 inch diameter A490 bolts:1 No. of Number Found Buildino Location Bolts Checked Unacceptable Comments Containment Steam 24 12 - 200 to 600 Unit 2 Generator ft-lbs. No. 5 Lower Lateral Support Steam 32 10 - 300 to 600 Generator .ft-lbs. No. 6 Lower Lateral Support Steam 24 24 - 100 to 700 Generator ft-lbs. No. 8 Lower Lateral Support Tower 28 2 - One each @ ~ Restraint 650 and 700 ft-lbs. TOTAL 108 48 44% found unacceptable. NOTE: 1. Inspection torque value used was 750 ft-lbs. V-12
TABLE V-3b . LICENSEE'S RESULTS OF. INDEPENDENT INSPECTION OF HIGH STRENGTH BOLTS OF NSSS SUPPORT CONNECTIONS Number of Bolts Not Accepted - Torque Value Bolt Size Number of Bolts Range for Bolts L" cation and Type Inspected Not Accepted 1 Comments C:ntainment: Pressurizer 1 1/4 inch 8 4 - 1050 to 1300 Column diameter ft-lbs. Support A490 No. 1 Pressurizer. I 1/4 inch 8 2 - 800 and 1200 C31umn diameter ft-lbs. Support A490 No. 2 Pressurizer 1 1/4 inch 8 3 - 1400 to 1425 Column diameter ft-lbs. Support A490 Ns. 3 Pressurizer 1 1/4. inch 8 1 - 800 ft-lbs Column diameter Support A490 No. 4 Pressurizer 1 1/2 inch 4 0 - Not Appli-Hydraulic torque Column diameter cable. wrench utilized. Support A490 N3. 1 Pressurizer 1 1/2 inch 4 1 - 2353 ft-lbs. Hydraulic torque Column diameter wrench utilized. Support A490 No. 2 Pressurizer 1 1/2 inch 4 0 - Not Appli-Hydraulic torque Column diameter cable. wrench utilized. Support A490 No. 3 Pressurizer 1 1/2 inch 4 1 - 2157 ft-lbs. Hydraulic torque C21umn diameter wrench utilized. Support A490 No. 4 V-13 _ _. ~. _ _ _ _ ._ +. -.. -
TABLE V-3b - (Continued) LICENSEE'S RESULTS OF INDEPENDENT INSPECTION OF HIGH STRENGTH BOLTS OF NSSS SUPPORT CONNECTIONS Number of Bolts Not Accepted - Torque Value Bolt Size Number of Bolts RangeforBolty Location and Type Inspected Not Accepted Comments Reactor 2 1/2 inch 8 8 - 3937 to 5118 Hydraulic torque Coolant diameter ft-lbs. wrench utilized. Pump A490 Loop No. 7 TOTAL 53-20 36% found unacceptable. NOTE: 1 Inspection torque values used were for 1-1/4, 1-1/2 and 2-1/2 inch diameter batts 1450, 4745 and 5570 ft-lbs, respectively. l V-14
TABLE V-4 DRAWINGS USED FOR STRUCTURAL STEEL INSPECTION American Bridge Drawing No. Rev. Order No. A251 B K6776 A252 D K6776 A281 D K6776 A410 A K6777 A419 A K6777 A423 A K6777 A424 A K6777 A528 0 K67777-X14 E216 D K6776 FWA503 C K6777-X14 585 E K6777 586 A K6777 588 0 K6777 589 A K6777 593 A K6777 1002 A K6777 1004 0 K6777 V-15
i TABLE V (Continued) DRAWINGS USED FOR STRUCTURAL STEEL INSPECTION Sargent and Lundy Engineers Drawing No. Rev. Title M-913 Sheet 35 Containment Building Pressure' Sensor Galleries S-482 E Auxiliary Building Standard Connection Details Sheet 2 S-686 AG Auxiliary Building Floor Framing Plan El. 374'-0" Area 7 S-687 W Auxiliary Building Floor Framing Plan El. 374'-0" Area 5 and 7 S-701 BT Auxiliary Building Floor Framing Plan El. 401'-0" Area 7 S-719 T Auxiliary Building Anchor Plate Schedule and Details S-764 R Auxiliary Building Foundation Sections and Details S-798 M Auxiliary Building Steel Column Schedule S-1015 AJ Containment Building Plan El. 461'-10" Areas 5 & 8 S-1322 AH Auxiliary Building Floor Framing Plan E1. 467'-0" Area 7 S-1330 Y Auxiliary Building Roof Framing Plan Area 7 S-1344 W Auxiliary Building Sections and Details S-1645 H Auxiliary Building Sections and Details S-2135 AF Typical Modification Details S-2138 5 Typical Modification Details S-2143 W Typical Modification Details S-2146-BY R Auxiliary Building Framing Modification Plan El. 374'-0" Area 7 S-2147-BY Y Auxiliary Building Framing Modification Plan El. 374'-0" V-16
.s TABLE V (Continued) DRAWINGS USED FOR STRUCTURAL STEEL INSPECTION Sargent and Lundy Engineers Drawing No. Rev. Title S-2152 AJ Auxiliary Building Framing Modification Schedule for El. 374' S-2160 AC Auxiliary Building Framing Modification Schedule for El. 374' S-2161 U Auxiliary Building Framing Modification Schedule E1. 374'-0" S-2171 Y Auxiliary Typical Modification Details S-2173-BY AC Auxiliary Building Framing Cover Plate Schedule S-2175-BY AC Auxiliary Building Framing Cover Plate Schedule S-2180 AW Auxiliary Building Framing Modification Schedule for E1. 375'-6"; 376'-0"; 391'-6"; 392'-0"; 394'-6"; 401'-0"; 409'-6"; 414'-0"; 415'-0"; 417'-0" S-2190 M Framing Modification Sections and Details S-2228 Z Containment Building Framing Modification Schedule for E1. 461'-10" S-2305 C Framing Modification Sections and Details S-2311 C Framing Modification Sections and Details S-2316 E Framing Modification Sectionr and Details S-2321 0 Framing Modification Sections and Details S-2329 E Framing Modification Sections and Details S-2343 D Framing Modification Sections and Details S-2346. C Framing Modification Sections and Details S-2348 E Framing Modification Sections and Details S-2359 C Framing Modification Sections and Details S-2396 B Framing Modification Sections and Details S-2397 D Framing Modification Sections and Details V-17
TABLE V-5 CONCRETE POUR PACKAGES REVIEWED Document Record No. Pour No. Description of Pour 5.02.01.01 2-A-353'-9"-7-F-1 1/3 Tendon Tunnel Slab 5.02.01.02 2-A-353'-9"-6-F-4 1/3 Tendon Tunnel Slab 5.02.01.03 2-A-353'-9"-5-F-4 1/3 Tendon Tunnel Slab 5.03.01.02 1-C-329'-4"-3-F-12 2/3 Auxiliary Building 1-C-329'-4"-2-F-11 Slab and Sumps 9 330 ft. elev. 1-C-324'-5"-4-F-22 1-C-324'-5"-3-F-22 5.04.01.04 1-D-401-0-1-F Part of Fuel Handling Building 2-D-401-0-2-F Foundation 4 L D V-18
+ TABLE V-6 DRAWINGS USED FOR MASONRY WALL INSPECTION l Dwo No. Rev./Date Title A220 BJ Auxiliary Building Upper Basement Floor Plan El. 8/4/85 364'-0" Area 3 A223 BE Auxiliary Building Upper Basement Floor Plan E1. 5/10/85 364'-0" Area 6 A224 K Auxiliary Building Upper Basement Floor Plan El. 3/1/79 364'-0" Area 7 S680 BF Auxiliary Building Floor Framing Plan E1. 364'-0" 8/9/85 Area 3 5682 BH Auxiliary Building Floor Framing Plan El. 364'-0" 6/21/85 Area 6 5683 AU Auxiliary Building Floor Framing Plan E1. 364'-0" 8/9/85 Area 7 S1141 AH Column Bracing Rows 6" and 30" 8/7/85 51727 AD Auxiliary Building Block Wall Steel Column Sections 1/19/84 and Details S1728 AG Auxiliary Building Block Wall Steel Column Sections '11/8/84 and Details S1730 AV Auxiliary Building Block Wall Steel Column Schedule 5/31/85 51738 G Auxiliary Building Block Wall Steel Column Sections 4/26/85 and Details V-19
6 VI. MATERIAL TRACEABILITY AND CONTROL A. Objective The objective of this portion of the NRC Construction Appraisal Team (CAT) inspection was to examine traceability and control of material and equipment, and to detennine the adequacy of the licensee's program relative to these activities. B. Discussion The method utilized to perform the inspection included selecting samples of various types of material and equipment for examination. Most of the samples were selected and identification markings were noted from installations in the plant. Some samples of installed material, such as cadweld sleeves, that were not accessible were selected from records. Also, some samples of delivered material, such as protective coating materials, not yet installed, were inspected in warehouses or shops. A total of 271 samples were examined to varying extents. Table VI-1, "Sumary of Samples," indicates the major contractors involved and the types of samples examined. Selected procedures from on-site organizations were reviewed, including the following: Comonwealth Edison Company (CECO)
- BSI-101, Purchase Request, Rev. 4.
- BSI-102, Material and Equipment Receiving, Receiving Inspection, Storage and Removal from Storage, Rev. 7.
- BSI-102a, Supplement A - Hatfield Receiving & Inspection of Site Requisitioned Material, Rev. 2.
- BSI-113, Storage Requirements and Surveillance Plan, Rev. O.
Hatfield Electric Company (HECo)
- Procedure No. 5, Class I Material and Equipment and Receiving and Inspection, Rev. 14.
- Procedure No.14, Handling and Storage of Safety Related Material and Equipment, Rev. 8.
Hunter Corporation (Hunter)
- SIP 3.102, Material and Services Procurement, Rev. 2.
- SIP 3.602, Material Receiving Inspection, Rev. 3.
- SIP 3.801 Storage of Mechanical Components and Materials, Rev. 5.
- SIP 3.802, Material Requisitions, Rev. 2.
VI-1
1 SIP.4.000, Control of Construction Processes, Rev. 14. Powers-Azco-Pope (PAP)
- FP-2, Control of Procurement and Requisition of Materials and Services, Rev. 4.
- FP-3, Material Receiving Inspection Control Rev.13.
- FP-4, Material Storage, Rev. 9.
- FP-16. Identification and Marking of Pipe and Components Rev.12.
Reliable Sheet Metal (RSM)
- Procedure No. 4, Field Material Receiving and Inspection', Rev. 7.
- Procedure No. 8. Storage of Components and Materials, Rev. 7.
- Procedure No. 30. Control of Construction Processes, Rev.1.
Midway Industrial (MIC)
- QCP-4, Container Marking and Material Control, Rev. 4.
Blount Brothers Company (BBC)
- Procedure No. 2, Procurement Control, Rev. 7.
- Procedure No. 10, " Receiving, Storage and Handling, Rev. 9.
A total of 271 samples were selected to verify traceability to: (1) the design drawings and specifications, and (2) the supply source. Verification was performed by review of drawings and procurement specifications, and by matching material and equipment markings with vendor certifications, other documentation and heat numbers. Table VI-2, " Sample Breakdown by Contractors," indicates the types and quantities of samples applicable to each contractor. Table VI-3, " Weld Filler Material Compliance," contains a list of weld filler material samples. The following sections describe the inspection results. 1. Material Traceability and Control a. Inspection Scope In addition to review of in-place procedures, the 271 samples of material and equipment were examined for traceability to drawings, specifications, procurement records, Certified Material Test Reports (CMTRs), Certificates of Conformance (C of Cs), heat numbers or other required documentation. Samples included equipment (electrical, mechanical and instruments), pipe, structural steel, weld joints, electrical cables, fasteners, and other materials as indicated in Table VI-2. VI-2
b. Inspection Findings In general, it was found that satisfactory procedures were in place for material traceability and for control of material at the site. Except for the lack of traceability for certain fastener materials, the material traceability program was found to be generally acceptable. The following observations were made by the NRC CAT inspector: (1) Sixteen samples of weld filler material listed in Table VI-3 were examined for traceability and compliance with specifica-tions and codes, and were found to be acceptable. Also, 11 weld filler material holding ovens in 8 issue stations were examined and found to meet requirements for temperature control and thermometer calibration records. In addition, 8 portable ovens were examined and found to be operating satisfactorily. (2) Some deficiencies were found regarding the traceability and control of equipment mounting bolts for large vendor-supplied ASME pump-motor assemblies, various electrical equipment, and HVAC equipment as follows: (a) Equipment assembly / mounting bolts for each of the 10 large vendor supplied pump-motor installations examined were found to have unmarked bolts or bolts with markings indicating incorrect or indeteminate materials. The discrepancies are as follows: Chemical Volume Positive Displacement Pump (2CV02P) - Motor mounting bolts required to be A325; no markings found. Chemical Volume Centifugal Charging Pump (2CV01PA) - Motor mounting bolts required to be SAE Grade 5; SAE Grade 8 found. Chemical Volume Centifugal Charging Pump (2CV01PB) - Motor mounting bolts required to be SAE Grade 5; unmarked bolts found. Residual Heat Removal Pumps (2RH01PA & PB) - Pump casing studs required to be SA 453, Grade. 660; untraceable marking "TP" found. Pump casing stud nuts required to be SA 194, Grade B6X; untraceable markings "7B" and "MR 5178" found. Motor base to motor casing bolts required to be A449, Grade 5; A325 bolts found. Containment Spray Pumps (2CS01PA 8 PB) - Casing stud nuts required to be SA 194, Grade 2H, Trace N-20; untraceable markings found. VI-3
l Motor mounting bolts to attachment required to be SA j 193, Grade B7; markings found indicate A325 or SA 325. Bolts from motor attachment to adaptor required to be SA 193, Grade 87; found A307 markings. Anchor bolts, per seismic report, should be A325; records indicate A36 installed. Records included a prior Sargent & Lundy analysis indicating that A36 is acceptable, but no design change was made. Auxiliary Feedwater Pump (2AF01PB) (diesel motor) - Bolts from gear box to skid required to be SAE Grade 5; markings found for A325. Requirement for anchor bolts not known; no markings found, records indicate A36 installed. Safety Injection Pumps (2SIO1PA & PB) - Pump mounting bolts indicated by Westinghouse Pump and Valve Engineering (memorandum revised 9/12/85) required to be SA 307; markings found indicated SAE Grade 5 installed. As a result of these CAT findings, the licensee issued Nonconformance Report'(NCR) No. F-1014 to initiate further examination of the discrepancies and corrective action. The numerous discrepancies between drawings, manuals, seismic qualification reports and markings on installed fasteners indicate a generic lack of attention to fastener details by the licensee and vendors. This matter requires management attention. (b) Equipment assembly / mounting bolts for certain electrical equipment were found to have unmarked bolts indicating indeterminate materials. The conditions are as follows: Battery rack assembly bolts in battery rooms 211 and 212 were inspected. It was found that of 460 bolts inspected, 69 were marked to indicate SAE Grade 5 material, and the rest were unmarked and thus were of indeterminate material. The licensee indicated l that ASTM A307 bolts were required, although docu-l mentation specifying the material required was not provided. Interconnection bolts for 4KV Switchgear cabinets (2AP06E) were inspected and some bolts were found marked to indicate A307 material, but others were unmarked and thus of indeterminate material. Assembly bolts for Fire Hazards Panel (2PL10J) were inspected and five were found to be properly marked for A307 material, but five of the ten bolts were unmarked and thus of indeterminate material. VI-4 t
As a result of these CAT findings, the licensee issued NRC No. F-1012 to initiate further review of the trace-ability of fasteners of various vendor supplied equip-ment and to provide for corrective action. It was noted that the licensee recently issued NCR No. F-1001- (August 16, 1985) to initiate review of site procured and contractor installed bolts which do not confonn to ASTM A307 requirements and to initiate corrective action. (c) Nuts for studs in the trapeze assembly portion of pipe hanger 2RYO5009 were specified to be of SA194, Grade 2H material. Markings found by the NRC CAT inspectors were not traceable. Records indicated that A307 nuts were installed. Four additional hangers: 2RY28002, 2RY28003, 2CV25021 and 2CV15016 were found to have nuts installed with proper 2H markings. The incorrect nuts on hanger 2RYO5009 is considered an isolated case. As a result of this CAT finding, the contractor (Hunter) issued NCR No. 1141 to initiate corrective action to replace the nuts on hanger 2RY05009. (d) Bolts for attaching HVAC Diesel Generator Service Room i Vent Fans 2VD02CA & B to adjacent duct sections were inspected. It was found that A307 bolts were required, but approximately 50% of the bolts were unmarked and thus material was indeterminate. The licensee stated that NCR No. F-1001 mentioned under VI.B.1.b(2)(b) above I was also applicable to this finding. l b. Conclusions In general, except for certain fastener hardware, the material traceability and control program was considered to be satisfactory. Significant lack of traceability was found for fastener materials, 4 i including assembly and mounting bolts for large vendor supplied pumps with motors mounted on skids; bolts for battery racks, switchgear cabinets and other electrical equipment; and bolts for HVAC equipment as noted above. l VI-5 I
.l l TABLE VI-1. SUMARY OF SAMPLES Contractors Activities No. of Samples Hatfield (HECo) Electrical 37 Hunter (Hunter) Piping / Mechanical 136 Powers-Azco-Pope (PAP) Instrumentation 43 Reliable Sheet Metal (RSM) HVAC 14 BlountBrothers(BBC) Structural 22 Chicago Bridge & Iron (CB&I) Containment Liner 8 ~ Midway Industrial (MIC) Coatings 11 TOTAL 271 l e e V!-6
TABLE VI-2 SAMPLE BREAKDOWN BY CONTRACTORS ITEM HEco HC* PAP RSM BBC CB&I MIC TOTAL 46 Equipment 14 19 10 3 29(L)** 21 8 Pipe 4(L) 4 Tubing 4(L) 2 2 Steel-Structural 5(L) 5 Steel-Rebar 5(L) 2 3 Steel-Plate 6(L) 1 5 Steel-Tube 6 4 2 Hangers / Supports 3 3 Embedments 16(L) Weld Filler Material 2 9 2 3 31 19 4 2 56 Weld Joints ElectricalCables(Reels) 5 5 53 Fasteners (Sets Installed) 6 44 3 8(L) Fasteners (Lots in Storage) 5 3 4(L) 4 Cadweld Sleeves 11 11(L) Coatings 5(L) Conduit 5 5(L) Cable Raceway 5 TOTALS 3T TH TJ T4 'Tl 8 TT '17T
- Hunter Corp.
- (L) = Lots l
VI-7 i
e s TABLE VI-3 WELD FILLER MATERIAL COMPLIANCE Material Heat No./ Compliance Designation & Size Material ID Comments E308-16 3/32" 74882 Acceptable E308-16 3/32" 11343 Acceptable E308-16 1/8" J1711 Acceptable E308L-16 5/32" 64901 Acceptable E309-16 3/32" 10440 Acceptable E309-16 3/32" Lot 90075-3 Acceptable E309-16 1/8" Lot 90069-1 Acceptable E502-16 3/32" 431C4621 Acceptable E502-16 1/8" 01P124 Acceptable E6010 3/16" 6455481 Acceptable E6010 5/32" LO2103 Acceptable E6010 5/32" 11270 Acceptable E7018 3/32" 34422 Acceptable E7018 1/8" 33641 Acceptable E7018 1/8" 40157441 Acceptable E7018 5/32" 402X9551 Acceptable VI-8
a VII. DESIGN CHANGE CONTROL A. Objective The primary objective of the appraisal of design change control was to determine whether design change activities were conductatd in com-pliance with regulatory requirements, Safety Analysis Report (SAR) commitments and approved licensee, architect-engineer and constructor procedures. An additional objective was to determine that hardware modifications described in a sample of design change documents were properly implemented in the field. B. Discussion 10 CFR 50, Appendix B, Criterion III " Design Control" and Criterion VI " Document Control" establish the overall regulatory requirements for design change control. These requirements are elaborated in Regulatory Guide (RG) 1.64, Rev. 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants" which endorses American National Standards Institute (ANSI) Standard N45.2.11-1974 " Quality Assurance Requirements for the Design of Nuclear Power Plants." The licensee's commitment to comply with RG 1.64 is stated in Appendix A of the Byron /Braidwood Stations Final Safety Analysis Report (FSAR). The areas of design change control evaluated by the NRC Construction Appraisal Team (CAT) inspectors were control of changes to design documents and control of design changes. In each of these areas, interviews were conducted with personnel responsible for the control of activities, procedures were reviewed, and a sample of the controlled documents was reviewed. In addition, a sample of the design changes which had been inspected and accepted by onsite contractor quality control personnel was verified in the field by the NRC CAT inspectors. 1. Control of Desian Documents The specific aspects of the control of design documents inspected were the availability to the users of the latest approved design documents and design change documents and the methods of assuring that approved changes not yet incorporated into design documents are provided to the users prior to work being performed. a. Inspection Scope (1) The following procedures related to distribution and control of design documents and design change documents were reviewed:
- Commonwealth Edison Company (Ceco) Quality Requirement (QR) 3.0 " Design Control," Rev. 15, August 15, 1984.
- Ceco QR 6.0, " Document Control," Rev. 9, August 15, 1984.
- Ceco Quality Procedure (QP) 6-1, " Distribution of Design Documents," Rev. 7, October,10, 1983.
VII-1
a
- CECO QP 6-2, " Procedure for Station Construction Department Design Document Control," Rev. 3, May 12, 1983.
- CECO Braidwood Nuclear Station Project Procedure PCD-03,
" Field Change Request," Rev. O, June 15, 1984.
- Sargent & Lundy Engineers (S&L) General Quality Assurance Procedure (GQ) 3.07, "Sargent & Lundy Drawings," Rev. 6, October 21, 1981.
- S&L GQ-3.13, " Engineering Change Notices," Rev. 6, October 21, 1981.
- S&L GQ-6.01, " Project Distribution List and Project File Indexes," Rev. 5, October 21, 1981.
- S&L Project Instruction for Byron /Braidwood (PI-BB) 29,
" Distribution and Control of Design Documents for S&L Field Personnel at the Byron /Braidwood Stations," Rev. 2, August 2, 1985.
- Hatfield Electric Company (HEco) Procedure No. 4. " Drawing Control," Rev. 13, April 10, 1985.
- Reliable Sheet Metal Works, Inc. (RSM) Procedure No. 7A,
" Document Control," Rev. 1, March 20, 1984.
- RSM Procedure No. 7, " Design Drawing and Design Change Control," Rev. 7, March 20, 1984.
- Powers-Azco-Pope (PAP) Field Operating Procedure FP-1,
" Document and Drawing Control," Rev. 6, August 29, 1984.
- Hunter Corporation Site Implementation Procedure 2.101,
" Document Control," Rev. 5, December 12, 1984. (2) Ceco and contractor Quality Assurance (QA) audit and sur-veillance reports concerning design document control were reviewed for findings, trends and corrective actions. (3) Ceco, S&L and contractor document control, engineering, construction and QA personnel were interviewed concerning distribution, control and use of design documents and design change documents, b. Inspection Findings S&L design documents and Engineering Change Notices (ECNs) are distributed by S&L to CECO, contractor and S&L organizations and personnel in accordance with PI-BB-29 and the S&L distribution lists. Field Change Requests (FCRs), which are Ceco design change documents, are distributed by the Ceco Project Construction Department (PCD) to S&L, contractor and Ceco organizations and personnel. VII-2
Ceco, S&L and the contractors each control the redistribution and use of design documents and design change documents within their l organizations in accordance with their separate and individual document control procedures. In general, receipt of design docu-ments is recorded on control cards or log sheets, the latest revisions of design documents and design change documents are issued i
- ~
to the (satellite) document control stations and the superseded revisions destroyed or stamped. All four contractors' (HEco, RSM, PAP and Hunter) document control systems reviewed by the NRC CAT J inspectors control the use of approved, unincorporated design change documents by annotating the design change identification numbers on the controlled copies of the affected design documents. i The Ceco PCD document control station is the " master" against which other document control station records were evaluated. Typically, j possible contractor discrepancies concerning the latest approved and issued revision of a design document and the corte;t annotated design change documents are resolved by comparison to the design i i documents and document receipt logs in the Ceco PCD Document Control 1 Station. The document control list (s), ECN status list and FCR status list are updated every 30 days in accordance with procedures; however, the PCD document control clerk maintains a more current master list by manually entering new issuances as they occur. i l (1) The NRC CAT inspectors reviewed approximately 200 S&L drawings } at the Ceco PCD document control station for legibility and correct indication of controlled status (no stamping). Sixty drawings were reviewed for correct revision and correct annotation of FCRs/ECNs against the S&L status list of 4 j drawings. No incorrect design document revisions were identified. i However, a large number of FCRs and ECNs were listed on i controlled drawings. The NRC CAT inspectors selected 6 l structural drawings which had 39 FCRs listed as open. Review l of the FCR master log indicated that 35 of the 39 FCRs had l 1 been incorporated. As a result, the inspectors identified a l concern that PCD was not deleting FCRs/ECNs from construction l j drawings in a timely manner after the FCR or ECN was incorporated into the drawing. Further review indicated that QA Surveillance Report No. 5872 had previously identified a similar concern. Ceco QA had commited to reauditing PCD's document control program during QA Audit No. 6-84-212. I However, a review of this audit by the NRC CAT inspectors i indicated that the concern of not deleting FCRs/ECNs from construction drawings in a timely manner had not been l addressed. Ceco QA conducted audit No. 6-85-204 during the l inspection period to address this concern. This audit revealed f that over 60 percent of the FCRs and ECNs listed on the drawings had already been incorporated. PCD has committed to remove all closed design changes posted on drawings by November 1, 1985. I l l i i VII-3 I
(2) The NRC CAT inspectors reviewed about 75 S&L design documents at five Hatfield Electric Company (HEco) document control stations in the Auxiliary Building, Containment Building and QC trailer for legibility and appropriate stamping (i.e., " controlled"). The revision numbers and FCRs/ECNs annotated were recorded for about 20 design documents and checked against the HECo master files. No incorrect design docume'nts were identified, although several cases were identified where field personnel had not deleted FCRs or ECNs from their controlled drawings. Inspection and installation records were reviewed by HEco and no outdated FCRs or ECNs were recorded as having been used in construction or inspection activities. The NRC CAT inspectors also reviewed document control audit and surveillances for procedure requirements and adequate . corrective actions. The following deficiences were noted: HEco Procedure No. 4 drawing " Drawing Control", states "Hatfield QA will perform a monthly surveillance of this procedure using Form HP-47". The surveillance reports for April and May 1985 could not be located. HEco performed three survelliances during the month of September to verify adequate document control. HECo special surveillance dated July 26, 1985, identified that HECo was not maintaining current mechanical drawings. Installation reports had not been reviewed to assure that installation was in accordance with the current drawings. HEco performed this review during the inspection period and determined that installations had been completed in accordance with current design documents. (3) The NRC CAT inspectors reviewed about 50 S&L design drawings at three Powers-Azco-Pope (PAP) document control stations, for legibility and correct stamping (i.e., " controlled"). The revision numbers and FCRs/ECNs annotated were recorded for about 15 design documents and checked against the PAP master i files. No incorrect design document revisions were identified. During the inspection a controlled copy of S&L Drawing No. GE-2-3543604, Rev. C had been maintained on the engineering stick file, however, the drafting controlled copy could not be located. Further review by PAP indicated that this drawing was voided. PAP stated that S&L electrical drawings were used for reference purposes and had not affected installation. PAP was subsequently removed from distribution of S&L electrical
- drawings, c.
Conclusion For the sample inspected, the control of design documents is considered adequate. i I i VII-4
o o, 2. Control of Design Change The specific aspects of the control of changes to design inspected by the NRC CAT were the change control systems for ECNs and FCRs, and the implementation and verification of the changes, a. Inspection Scope (1) The following procedures relating to the control of design changes were revieted:
- Ceco QR 3.0, " Design Control," Rev. 15, August 15, 1984.
- Ceco QP 3-1, " Design Control," Rev. 5, October 5, 1984.
- Ceco QP 3-2, " Design Change Control," Rev. 13, October 5, 1984.
- CECO PCD-02, " Engineering Change Notices," Rev. O. May 24, 1984.
- Ceco PCD-03, " Field Change Request," Rev. O, June 15, 1984.
- S&L GQ 3.07, "Sargent & Lundy Drawings," Rev. 6, October 21, 1981.
- S&L GQ 3.08, " Design Calculations," Rev. 5, January 31, 1985.
- S&L GQ 3.13. " Engineering Change Notices," Rev. 6, October 21, 1981.
- S&L PI-88-13. " Procedure for Processing Commonwealth Edison Company Field Change Requests (FCRs)," Rev. 12, September 27, 1984.
- S&L PI-BB-18, " Procedure for Handling Commonwealth Edison Company Field Change Requests Transmitting
'As-Built' Information," Rev. 1, May 7, 1984.
- S&L PI-88-23, "8yron/Braidwood Electrical Field Personnel,"
Rev. 7, October 25, 1983.
- S&L PI-BB-25, " Activities of the On-Site Structural Design Group," Rev. O, August 29, 1983.
- S&L PI-88-28, " Activities of the Byron /Braidwood Station Mechanical Engineering, Piping Design, Cupport Design and Analysis Field Personnel," Rev. 3, August 4, 1983.
- Westinghouse Electric Corporation (W) Instruction PE0-8-1.2, " Byron Unit 1 and Unit 2 Engineering Change Notices," Rev. O, April 1, 1985.
VII-5
- W Instruction PED-B-1.3, " Byron Unit 1 and Unit 2 Field Change Requests," Rev. O. April 1, 1985.
- Nuclear Power Services, Inc. (NPS) Procedure 3.0.5,
" Design Control - Revisions and Holds," Rev. D. July 23, 1985.
- HEco Procedure #29, " Field Initiated Requests for Design Changes," Rev. 8, January 30, 1985.
- RSM Procedure No. 7, " Design Drawing and Design Change Control," Rev. 7, March 20, 1984.
- PAP Field Operating Procedure FP-9, " Design Change / Field Routing Control," Rev. 10, April 17, 1984.
- Hunter Site Implementation Procedure 2.201, " Design Control,"
Rev. 13, June 11, 1984. (2) Ceco and contractor QA audit and surveillance reports con-cerning design change were reviewed for findings, trends and corrective actions. (3) Interviews were conducted with personnel from CECO, S&L, W, NPS, HECo, RSM, PAP and Hunter concerning initiation (origination), review, approval and implementation of design changes. b. Inspection Findings S&L has approximately 166 people in their Byron site organization, of whom about 145 are assigned in engineering and design groups. The majority of the engineering and design personnel are engaged in resolving field problems by clarifying design documents and making design changes. The contractors perform no engineering or design function; however, RSM, PAP and Hunter prepare supplementary drawings / sketches from S&L approved design drawings for use as aids in fabrication and construction. Generally, such aids are prepared by the contractor field engineers and both contractor engineering and QC personnel review them for conformance with the S&L approved drawings. Design changes are accomplished through design change documents such as FCRs, ECNs, Field Change Notices (FCNs) and through revision of design documents without an intermediate design change document. FCRs are a CECO design change document generally originated in the field by Ceco or contractor personnel and i approved by both Ceco and S&L. ECNs are an S&L design change l document originated in the field or S&L's Chicago office and l approved by S&L. FCNs are a Westinghouse Electric Corporation l (the nuclear steam supply system vendor) change document originated l and approved by offsite Westinghouse personnel. Roughly 42,000 i VII-6 i l
FCRs/ECNs have been issued for both units. Presently, an average of about 100 FCRs and 50 ECNs are being issued each month and the trend is decreasing. Problems, conflicts and items requiring clarification of the approved design documents identified by the contractors.are forwarded to S&L for resolution. HEco uses Field Problem Sheets, RSM uses Ventilation Field Problem Sheets, PAP uses Field Work Requests, and Hunter uses Piping and Support Field Problem Foms. These contractor documents are generally not controlled or considered QA documents. When resolution requires a design change, a FCR, ECN, or drawing revision is prepared and issued to the contractor. (1) Approximately 46 ECNs and FCRs were selected and reviewed for procedural compliance, adequacy of problem description and resolution. These ECNs and FCRs are listed in Table VII-1. One minor procedural deficiency was identified. The " Request Cla:s" blocks for " Limited Construction" or " Plant Modifica-tion" and " Major" or " Minor" changes were not checked on a number of FCRs. Examples are: FCR-70113, January 22, 1985 FCR-35607, April 30, 1985 FCR-35608, April 30, 1985 This appears to be inconsistent with the requirements of Attachment B to Ceco QR 3-2. (2) Six FCRs/ECNs for which the work had been completed and accepted by contractor QC were selected for verification. Prior to inspection of physical changes, the base design drawings, applicable change notices and backup calculations and QC inspection reports were reviewed by the NRC CAT inspectors. The physical changes were then inspected in the field to verify that the changes were implemented as described. Each design change was found to have been prcperly completed. FCR-35607 and 35608, April 30, 1985 - The change required additional mounting holes to support instrumentation. FCR 21637 August 11, 1983 - The change required the addition of a shuttle pan to support cables. ECN 22400, July 25, 1984 - The change required the addition of a flex hose to the Component Cooling System piping. Snubbers were eliminated and piping was rerouted. FCR 33510. September 20, 1984 - That change required screen stiffeners to be cut to facilitate installation of security bars. VII-7
O FCR-25855, March 18, 1985 - The change provided location and mounting of isolation transformers. (3) The calculations for about 28 ECNs/FCRs were reviewed for conformance~with applicable requirements. These ECNs and FCRs are denoted in Table VII-1 by an asterisk. All the calculations were changes to previously approved designs, and thus were in effect partial revisions to previous calculations. They consisted of both hand and computer calculations, involving mostly structural attachments, core drilling and pipe supports / restraints. Examples are: FCR 35607, April 30, 1985 ECN 22400, July 25, 1984 FCR 33510, September 20, 1984 The calculations were reviewed for technical adequacy, compliance with regulations and commitments and meeting procedure requirements. The calculations in the sample inspected were found to be prepared, checked and reviewed in conformance with procedural requirements. They had been reviewed and approved prior to the approval date on the ECNs/FCRs. No calculation errors were observed in the sample inspected. (4) In addition, the NRC CAT inspectors in the technical discipline areas reviewed approximately 50 design change documents (ECNs/FCRs). The design changes verified were selected after work had been completed and accepted by contractor QC. Each design change was reviewed for technical adequacy and the installation was verified in the field. c. Conclusions For the sample inspected, the control of the design change process is adequate. VII-8
TA8LE VII-1 Desian Chance Document Date Issued Responsible Contractor
- ECN 22400 07/25/84 Hunter
- ECN 244686
~10/14/84 Hunter
- ECN 245144 12/13/84 Hunter FCR 21637 08/11/82 HEco FCR 22915 06/07/83 HEco FCR 24976 06/11/84 HEco FCR 24979 06/12/84 HEco
-'y-
- FCR 25115 07/13/84 HEco
- FCR 25761 01/03/84 HEco FCR 25762 01/03/84 HEco FCR 25855 03/18/85 HEco
- FCR 25949 02/11/85 HEco
- FCR 25993 03/07/85 HEco FCR 26081 03/25/85 HEco FCR 30546 01/05/84 Hunter FCR 31994 04/20/84 Hunter
- FCR 33137 10/09/84 PAP
- FCR 33510 09/20/84 RSM FCR 33706 09/20/84 RSM FCR 33771 10/25/84 RSM
- FCR 34005 10/11/84 PAP FCR 34712 02/11/85 RSM FCR 34986 06/10/85 Hunter
- FCR 35081 02/21/85 RSM FCR 35377 04/05/85 RSM
- FCR 353/8 04/29/85 RSM FCR 35383 04/09/85 RSM
- FCR 35601 04/29/85 PAP
- FCR 35602 04/29/85 PAP
- FCR 35607 04/30/85 PAP "FCR 35608 04/30/85 PAP
- FCR 35706 05/23/85 RSM
- FCR 35732 06/26/85 RSM
- FCR 35827 05/17/85 PAP
- FCR 35833 05/29/85 PAP
- FCR 35834 05/29/85 PAP
- FCR 35835 05/31/85 PAP
- FCR 35914 07/30/85 RSM
- FCR 35935 08/13/85 RSM
- FCR 35970 06/12/85 PAP
- FCR 36017 08/12/85 PAP
- FCR 36018 08/12/85 PAP FCR 70111 01/21/85 Hunter
- FCR 70113 01/22/85 Hunter FCR 70114 01/23/85 Hunter FCR 70123 02/21/85 Hunter NOTES:
Hunter - Hunter Corporation HECO - Hatfield Electric Company PAP - Powers-Azco-Pope RSM - Reliable Sheet Metal Works, Inc.
- Indicates that calculations were reviewed.
VII-9
VIII. CORRECTIVE ACTION SYSTEMS A. Objective The objective of this portion of the NRC CAT inspection was to verify, through selected samples, whether measures were established and implemented to assure that nonconformances and other conditions adverse to quality were promptly identified and corrected. B. Discussion An examination was made of the licensee's program for identification and controf of nonconformances and corrective actions, including review of documents and inspection of some materf al/ equipment for verification of actual orrective actions in the plant. Items such as the following were reviemed: Procedures and organizational interfaces Trend analyses Audit and surveillance reports Nonconformanca reports Deviation reports Inspection repor*.s Control of actual material and equipment corrections in the plant Control of open nonconformances at turnover for testing or operation Table VIII-1, " Corrective Action Samples," contains a list of samples that were randomly selected. The following procedures of on-site organizations were found in place, and applicable portions pertaining to corrective action were reviewed: Coninonwealth Edison ' Company (Ceco)
- SQI-6, On Site Contractor Nonconformance Reports, Rev. O.
- SQI-7, QA Handling of CECO Nonconformance Reports, Rev.1.
- SQI-12, Byron Site QA Audits, Rev. 2.
- SQI-31, Byron QA Training Program, Rev.1.
- SQI-38 Performance and Reporting of Deficiency Trending Analysis by Site QA, Rev. 1.
Sargent and Lundy (S&L)
- GQ-16.01, Corrective Action Reports, Rev. 6.
VIII-1
m
- MAS-30 Technical Monitoring of Quality Related Design Activities, Rev. A.
Hatfield Electric Company (HEco)
- Quality Assurance Manual, Rev. 16.
- Procedure No. 1, Method of Preparing Procedures, Rev. 13.
- Procedure No. 6 Reporting Damaged or Nonconforming Material or Equipment, Rev. 14.
- Procedure No. 8 Audits. Rev. 5.
- Procedure No. 12. Installation of Class IE Equipment, Rev. 8.
Hunter Corporation (Hunter)
- Quality Assurance Manual Rev. 7.
- SIP-3.801, Storage of Mechanical Components and Materials, Rev. 5.
- $1P-4.201, Installation Verification, Rev.11.
- SIP-11.101, Nonconformance Processing, Rev. 4.
Powers-Arco-Pope (PAP)
- Quality Assurance Manual. Rev. 3.
- QC-4, Nonconformance Control Rev. 11.
- QC-5, Site Audit, Rev. 11.
Reliable Sheet Metal (RSM)
- Quality Assurance Manual, Rev. O.
- Procedure No. 5. Site Quality Assurance Audits Rev. 5.
- Procedure No. 10 Nonconformance and Corrective Action, Rev. 4.
- Procedure No. 23. Installation Verification, Rev. 2.
Blount Brothers Company (BBC) ' Quality Assurance Manual, Rev. 1. Pittsburgh Testing Laboratories (PTL)
- QC-1A-1 Internal Audits, Rev. 8.
- QC-CRN-1 Control and Reporting of Nonconformances Rev. 2.
VI!!-2
1. Corrective Action a. Inspection Scope A review was performed of applicable portions of project procedures. In addition to QA manuals and procedures, a total of 218 samples of corrective action documents were reviewed, and six material / equipment samples were inspected for verification of corrective actions in the plant. Table VIII-1, " Corrective Action Samples " contains a list of documents and materfal/ equip-ment samples that were randomly selected and inspected. b. Inspection Findings In general, it was found that satisfactory procedures were in place for corrective action systems to identify and control the correction of conditions adverse to quality at the site. Except for concerns discussed below, the corrective action systems and implementing measures were found to be acceptable. The six material / equipment samples requiring rework in the plant were inspected, and corrective action control was verified. (1) Numerous problems with fastener material discrepancies on large vendor-supplied ASME pump / motor assemblies and other vendor equipment were found by the NRC CAT for which effective corrective actions were not performed. See Section VI.8.1.b(2) for details. These problems indicate a lack of effective quality control at vendors' plants, and also a lack of vendor surveillance with attention to verification of proper fasteners prior to shipment. (2) Radiographs for certain ASME equipment were not provided by the vendor, Westinghouse Electric Company. Radiographs requested by NRC CAT inspectors had not been located during the inspection period. See Section IV.8.11.b for details. A review of audits perfonned by both Connonwealth Edison Company and Westinghouse Electric Company indicated that the retrievability of radiograph records had not been addressed during the audits. (3) A review of four Preoperational Test Release (turnover) packages revealed that the turnover procedure and release forms did not include a record of preventive maintenance status or any related deficiencies. In a limited review of the licensee's preventive maintenance program, it was found that the preventive maintenance program was fragmented among Ceco and contractor organizations, and that effective coordinated control was lacking. The preventive maintenance program for mechanical equipment was discussed with Hunter Quality Assurance (QA) personnel and CECO project construction, startup and operations personnel. VI!!-3
4 Shaft rotation records for the following five pumps were reviewed: 2CC01PA, 2CC01PB, 2CS01PA, 2CS01P8, 2AF01PA. l Hunter Procedure SIP-3.801, Storage of Mechanical Components and Materials, addresses maintenance of mechanical equipment prior to establishment of the full surveillance program at turnover to Ceco operations. This procedure does riot clearly define progrannatic requirements or responsibilities during wriods in which equipment is undergoing flushing or testing by the Ceco staff. Although the equipment has not yet been formally turned over to CECO at these stages, there is some confusion as to maintenance responsibility during this time frame. For example Hunter apparently terminates periodic pump / motor shaft rotations at the time of final coupling and alignment of pumps to motors. Normally this equipment would then be flushed by Ceco startup personnel and then turned over to CECO startup/ testing personnel. During these periods, regular pump operations and monitoring of basic parameters is conducted by test personnel. The NRC CAT inspectors identified that for the Containment Spray Pumps (2CS01PA ard 2CS01PB) the scheduled shaft rotation stopped in March and April of 1985, and due to flushing delays these pumps had not yet been flushed, run or otherwise monitored as of September 20, 1985. The Auxiliary Feedwater Pump (2AF01PA) was coupled and last rotated by Hunter in January 1985 and was flushed in May 1985 but has not been turned over to startup or run since then. The potential long term effects of this lack of r maintenance has not been addressed, and it does not appear that measures were in place to provide for an evaluation of this condition. The overall requirements and responsibilities of the preventive maintenance program need to be better defined for the interface period between construction and operation, c. Conclusions The Itcensee's corrective action program was found to be generally acceptable, except for the following concerns: a. Failure to assure that fasteners of required materials were furnished with vendor supplied equipment. b. Failure to assure that radiographs for certain vendor supplied equipment were properly stored and retrievable as required. c. Failure to provide for effective specification and performance of preventive maintenance, particularly from the time of turnover for testing until turnover for operation. VIII-4
c TABLE VIII-1 CORRECTIVE ACTION SAMPLES ITEMS QUANTITY EXAMINED Ceco S&L W HECO HC PAP RSM BBC PTL TOTAL 1 3 3 3 2 1 16 Trend Reports 3 Audit Reports 18 2 16 3 7 7 5 7 1 66 16 10 12 9 10 10 77 Nonconformance Reports 10 1 21 10 10 Deviation Reports 4 5 22 10 3 Inspection Reports 10 10 Surveillance Reports 6 2 2 1 1 Samples for Field Verification of Corrective Action 4 Turnover Packages 4 1 1 Unit Concept Report 1 1 Over Inspection Report TOTAL 35 2 16 42 35 32 22 26 14 218 Ceco = Comonwealth Edison Comapny S&L = Sargent and Lundy W = Westinghouse Electric Company HECo = Hatfield Electric Company HC = Hunter Corporation PAP = Pope-Arco-Pope RSM = Reliable Sheet Metal BBC = Blount Brothers Corporation PTL = Pittsburgh Testing Laboratories VI!!-5 u
.t.- ATTACHMENT A A. Persons Contacted The following list identifies licensee discipline coordinators and key individuals contacted during the inspection for each area. 1. Licensee Coordinators and Contacts Area Names Team Leader K. Ainger D. Tuetken Electrical and J. Sinder Instrumentation S. Vovos L. Stern Mechanical B. Moravec, J. Porter, B. Somsag, R. Irish D. Geddings Welding and NDE D. McCarty, E. Wolber J. Porter Civil and Structural J. Mihovilovich, R. Guse R. Hardison Material Traceability B. Klinger E. Briette Corrective Action Systems E. Martin D. Felz Design Change Controls B. Klinger, P. Donavin B. Byrne In addition to the above personnel, numerous other inspectors, engincers and supervisors were also contacted. B. Documents Reviewed The types of documents listed below were reviewed by the NRC CAT members to the extent necessary to satisfy the inspection objectives stated in Section I of this report. There are additional references within the body of the report to specific procedures, instructions, specifications and drawings. 1. Final Safety Analysis Report 2. Quality assurance manual 3. Quality assurance procedures and instructions AA-1
i 4. Quality control procedures 5. Administrative procedures 6. General electrical installation procedures and specifications 7. General instrumentation installation procedures 8. General piping and pipe support installation procedures an3 ' 5 specifications 9. General mechanical equipment installation procedures and specifications 10. General concrete specifications 11. As-built drawings 12. Welding and NDE procedures 13. Personnel qualification records 14. Material traceability procedures 15. Procedures for processing design changes 16. Procedures for document control 17. Procedures for controlling as-built drawings 18. Procedures for processing nonconformances AA-2
s ATTACHMENT B GLOSSARY OF ABBREVIATIONS AISC - American Institute of Steel Construction ANSI - American National Standards Institute ASME - American Society of Mechanical Engineers ASTM - American Society for Testing and Materials AWS - American Welding Society ATWS - Anticipated Transient Without Scram 88C - Blount Brothers Company 8Y/BR - Byron /8raidwood CAT - Construction Appraisal Team (NRC) C8&I - Chicago Bridge and Iron Company C of C - Certificate of Conformance CEA - Concrete Expansion Anchor Ceco - Comonwealth Edison Company CMTR - Certified Material Test Report CSCV - Cable Separation Criteria Violation CSNF - Conduct Separation Notification Report DIT - Design Information Transmittal DR - Deviation Report DRC - Deviation Report for Correctable Items ECN - Engineering Change Notice FCN - Field Change Notice FCR - Field Change Request GQ - General Quality HECo - Hatfield Electric Co. Hunter - Hunter Corp. HVAC - Heating, Ventilating and Air Conditioning IE -OfficeofInspectionandEnforcement(NRC) IEEE - Institute of Electrical and Electronic Engineers IPCEA - Insulated Power Cable Engineers Association IRR - Interface Review Report LP - Liquid Penetrant Inspection LOCA - Loss-of-Coolant Accident MIC - Midway Industrial Company MOV - Motor Operated Valve NCR - Nonconformance Report NDE - Nondestructive Examination N!SCo - Nuclear Installation Service Co. NPS - Nuclear Power Service Inc. NRR - Office of Nuclear Reactor Regulation (NRC) NRC - U. S. Nuclear Regulatory Comission NSSS - Nuclear Steam System Supplier 0AD - Operations Analysis Department PAP - Powers-Arco-Pope PCD - Project Construction Department PDM - Pittsburgh Des Moines Corp. PI Project Instruction - Byron /8raidwood PSAR - Preliminary Safety Evaluation Report PSI - Preservice Inspection PTL - Pittsburgh Testing Laboratories QA - Quality Assurance AB-1
QAM - Quality Assurance Manual QC - Quality Control QCSSR - Quality Control Structural Steel Review QP - Quality Procedure QR - Quality Requirement RG - Regulatory Guide (NRC) RSM - Reliable Sheet Metal Works, Inc. .SAR - Safety Analysis Report SIP - Site Implementation Procedure S&L .- Sargent and Lundy Engineers SWI - Site Work Instruction UT - Ultrasonic Inspection V - Volt VT - Visual Inspection W - Westinghouse Electric Corp. 1 e AB-2 .}}