ML20195F270
| ML20195F270 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Byron |
| Issue date: | 05/30/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20151J031 | List: |
| References | |
| FOIA-87-866 NUDOCS 8606110788 | |
| Download: ML20195F270 (23) | |
See also: IR 05000455/1985027
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May 30, 1986
MEMORANDUM FOR:
C. E. Norelius, Director
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Division of Reactor Projects, Region III
FROM:
J. G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF THE NRC INSPECTION
PROGRAM BY REGION III AT BYRON UNIT 2 STATION
The Office of Inspection and Enforcement described to the Commission in
SECY-82-150A the assessment of the implementation of the NRC inspection
program in conjunction with Construction Appraisal Team (CAT) inspections.
Accordingly, we have examined Region III's implementation of the construction
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inspection program based on the August-September 1985 CAT inspection at the
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Byron Unit 2 Station. The results of the inspection were documented in
Inspection Report 50-455/85-27 dated November 13, 1985. The enclosure to this
memorandum documents the results of our assessment of the construction
inspection program implementation.
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ORIGINAL SIGNED BY:
wtEs AP>ARDW
J. G. Partlow, Director
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Division of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
1
Assessment
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J. Taylor, IE
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J. Keppler, Region III
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REGIONAL CONSTRUCTION INSPECTION PROGRAM
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ASSESSMENT - BYROTUNIT 2 STATION (R-]II)
I.
OBJECTIVE
The objective of this assessment is to evaluate Region III's implementa-
tion of the Light Water Reactor Inspection Program-Construction Phase
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(construction inspection program) and to make an overall assessment of the
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adequacy of Region III's oversight of construction activities at the Byron
Unit 2 site.
The Construction Appraisal Team (CAT) of the Division of Inspection
Programs conducted an announced construction inspection at the
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Comonwealth Edison Company's Byron Unit 2 Station during the period of
August 19-30 and September 9-20, 1985. While the predominant effort of
the inspection team was devoted to hardware inspection, the team also
evaluated the control of design changes and corrective actions.
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II. ASSESSMENT ACTIVITIES
A review was made of Region III inspection reports of the Byron Unit 2
Station, SALP reports, and construction deficiency reports to identify
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those deficiencies that were previously identified by Region III
inspectors or the licensee. The review included inspection reports of
1975 to 1985, applicable open items and violations and SALP reports for
the periods ending December 31, 1982 and April 30, 1984,
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To determine the inspection effort at Byron Unit 2, the inspection reports
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for 1975 through 1985 and the 766 Computer System inspection data were
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analyzed.
It was determined that Region III perfomed a total of 3996
manhours (through January 1986) of direct inspection effort at Byron Unit 2.
The site total inspection hours were compared to other sites in a similar
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stage of construction and the manhours were found to be comparable, thus
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indicating a satisfactory level of inspection effort at the site. Attach-
ment I graphically depicts the comparison of inspection hours. The
analysis of the inspection reports and 766 Computer System data indicated
that the construction inspection program was approximately 90 percent
complete at the start of the CAT inspection.
It should be noted that two sets of inspection hours are referenced in this
assessment due to the time frame in which the data was obtcined from the
766 data system. Both sets are consistent, however one set has been used
to compare other similar sites and the other is used in assessing the
inspection program effort solely at Byron Unit 2.
The Executive Sumnary and Potential Enforcement Actions of the Byron Unit
2 Station CAT inspection report (50-455/85-27) are provided as Appendix A
and Appendix B, respectively.
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III. ASSESSMENT FIN 91NGS
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A.
Electrical and Instrumentation Construction
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1.
CAT Findings
The NRC CAT inspectors found that mounting welds for several
pieces of Class 1E 4160V switchgcar and 125V DC fuse panels
were not in accordance with design requirements.
The wiring of some Class IE motor operated valves were found
by the NRC CAT inspectors not to be in accordance with
approved design drawings.
In addition, a "speed memo" (an
improper design change document) was used by QC to accept
the installations.
Some Class 1E electrical raceways were not installed in
accordance with FSAR commitments for ehetrical separation.
The splicing of Class 1E wiring in several panels was
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identified by the NRC CAT.
This is contrary to the
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licensee's FSAR commitments to IEEE 420, which prohibits
wiring splices in panels.
2.
Assessment
The region has performed several inspections in the area of
electrical components.
However, these inspections did not
select the same components with which the NRC CAT had
identified welding deficiencies.
Since the region's sample
was different than the NRC CAT it is understandable that
the deficiencies were not identified by the region.
It war noted that the licensee had previously identified the
same deficiency in electrical equipment for Unit 1.
However,
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the disposition of the resulting NCR did not address Unit 2
components.
This was the only example identified by the NRC
CAT which showed that Unit I deficiencies had not been
properly considered for potential effects on Unit 2.
The region has performed numerous inspections in the
electrical cable area.
These inspections covered areas
such as cable, cable tray, panels, MCCs, pump motors, and
breakers; however, it does not appear that motor operated
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valve terminations were selected for inspection.
Since the
region had not reviewed motor operated valve terminations,
it is understandable that the region had not identified
this deficiency previously.
The use of a "speed memo" by
QC personnel appeared to be an isolated incident.
In the area of electrical separation, the region has devoted
significant attention in identifying instances of separation
violations.
In addition, SALP reports for the periods
7/80-12/81 and 1/82-12/82 indicate Category 3 ratings in the
electrical area and highlight separation violations given to
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the utility (including the latest SALP report for the period
1/83-4/84).
The efforts of the region in this area have
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contributed to the advanced progress of the Wyle testing
program to demonstrate the acceptability of the Byron separa-
tion criteria.
However, the criteria in effect at the time
of the CAT inspection were not in accordance with FSAR
commitments.
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The region has performed three inspections related to butt
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splices (a 50.55(e) item) at Byron (Inspection Reports
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50-454/84-27, 50-455/84-19; 50-454/84-29, 50-455/84-21; and
50-454/84-72; 50-455/84-50).
However, these inspections had
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not identified the fact that wire splices in panels were not
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allowed by IEEE 420.
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3.
Recommendations
lhe region's inspections in this area are considered satisfac-
tory.
The region has stated t'1ey will continue to monitor the
status of the resolution of the electrical separation issue
(discussions being held with the licensee and NRR).
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B.
Mechanical Construction
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1.
CAT Findinas
The NRC CAT did not identify any significant deficiencies
related to the mechanical construction area.
2.
Assessment
The region's inspections have generally covered the area of
mechanical construction satisfactorily and included various
tanks, heat exchangers, pumps, HVAC activities, and other-
components.
The lack of significant CAT findings in this area
appears to indicate that the region's inspection efforts have
been effective in obtaining adequate licensee performance in
mechanical construction activities.
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3.
Recommendations
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There are no recommendations to be made at this time.
C.
Weldina - NDE
1.
CAT Findings
The NRC CAT requested radiographs for two ASME components
supplied by Westinghouse which were not retrievable.
In
addition, past audits by the licensee and Westinghcuse had
not addressed the area of retrievability of radiographs.
The NRC CAT inspectors identified undersized welds on vendor
supplied tanks and heat exchangers.
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The NRC CAT inspectors identified various vendor radiographs
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which did not have complete weld coverage or did not show
the required weld quality.
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2.
Ass _essment
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The review of regional inspection reports for 1983-1985
welding and NDE (gion has adequately covered the area of
shows that the re
including reactor coolant piping and
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supports, safety-related piping and supports, structural
steel,containmentandreactorinternals).
These
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inspections covered in-process activities and review of
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welding and NDE records.
The issue on undersized welds on vendor supplied tanks and
heat exchangers is the subject of Information Notice 85-33,
3.
Recommendation
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The region has satisfactorily implemented the inspection
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program in this area. There are no recommendations to be made,
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D.
Civil and Structural Construction
1.
CAT Findings
Approxinately one-third of the total of A490 bolts tested in
structural steel connections and equipment holddown applica-
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tions were found by the NRC CAT to be below the specified
pretension required by AISC.
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The NRC CAT inspectors found concrete expansion anchors
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which did not meet the required embedment depth specified in
the anchor bolt qualification report.
2.
Assessment
The NRC CAT identified the deficient bolt pretension condi-
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tions when performing a check of bolt torque using a cali-
brated torque wrench.
IE Bulletin 79-02 was issued regarding the design and instal-
lation of concrete expansion anchor bolts.
The Bulletin
specified the verification of proper installation, but did
not specify that installation procedures be compared to the
anchor bolt qualification test report. This is the first
instance thus far identified by the NRC CAT in which instal-
lation procedures did not match the qualification report.
The region has generally covered the area of civil
construction in the inspection of concrete, soils,
post-tensioned tendons, structural steel, and material
certifications. The region's findings were similar to
those of the CAT for those areas covered by both.
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3.
Recommendation
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The region's inspections in this area are considered
satisfactory.
There are no recommendations to be made.
E.
Material Traceability and Control
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1.
CAT Findings
The NRC CAT identified a significant lack of traceability
for fastener materials, including assembly and mounting
bolts for vendor supplied pumps / motors, and bolts for
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battery racks, switchgear, and HVAC duct sections.
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2.
Assessment
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The region's inspection efforts generally covered this
area by inspections in the QA area and the technical
disciplines, although vendor supplied components and
subparts were not emphasized.
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3.
Recommendation
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The region's inspection efforts in this area are satisfactory.
Since fastener traceability has been a problem at several sites,
IE has issued Information Notice 86-25 in this area.
F.
Design Change Control
1.
CAT Findi g
The NRC CAT inspector found that the licenses had not
verified whether installations were in accordance with
design drawings when out-of-date drawings were identified.
2.
Assessment
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The region's inspection efforts in this area were gen 6 rally
accomplished during reviews of the lice. .ee's QA program.
The region's efforts have been generally satisfactory in
assuring adequate licensee performance.
3.
5< commendation
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The regional inspections are considered adequate in the
design change control area.
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G.
Corrective Action Systems
1.
CAT Finding
The NRC CAT found that audits by the licensee and
Westinghouse failed to assure that radiographs for welds on
certain vendor supplied c uronents were retrievable.
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2.
Assessment / Recommendation
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The Region has generally reviewed this area through the
inspection of the Byron QA program including the regional
CAT inspection. The region's efforts were satisfactory.
See paragraph C above for discussion of vendor radiograph
retrievability audits.
IV.
REVIEW OF BYRON UNIT 2 CONSTRUCTION INSPECTION pRC3 RAM
A.
_S c_ ope
Inspection staff hours for Syron Unit 2 existing in the 766 system
from January 1,1975 through November 30, 1985 were retrieved along
with inspection report numbers, inspection dates, inspection proce-
dures used, data on completion status and the enforcement text.
The above data is summarized in Attachments II and III. Attachment
II contains a summary of the inspection staff hours and completion
status of the MC 2512 construction inspection program for Byron 2 and
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Attachment III is a more detailed presentation of the inspection
history by technical areas developed from the 766 systen data base.
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A sampling of inspection reports prepared by the region were
evaluated with respect to content, timely issuance and overall
completeness.
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The total inspection hours discussed in this section tre slightly
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different than those discussed in Section 11 above due' to the
difference in dates that the 766 system infomation was requested.
B.
Assessment
The analysis of the 766 system data indicates that 68 (or 45%) of
the construction inspection procedures (IPs) had staff hours charged
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to them and were considered closed (marked C or P) by the region (See
AttachmentII,SectionA).
Fifty-six of the IPs were recorded to be
between 0 and 25% complete.
Eight IPs were noted to bc 100% complete
but only having a total of one (1) hour charged to them. The number
of IPs between 0 to 25% complete is noteworthy, but not suprising in
that Byron Unit 2 is approximately 12 months from the scheduled OL
issuance date and the use of the NRC CAT inspection efforts may
significantly affect the present results.
The recent addition of an
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additional resident inspector at Byron should also show improvement
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in the completion status of the IPs. The eight IPs with a closed
status and only one hour charged against the IP are not considered
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significant in that these inspection hours have generally been in
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areas in which the Region has expended inspection hours in related
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IPs.
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Our review shows that several IPs have no hours charged to them and
in particular six instrumentation procedures and the eleven proce-
dures in welding /NDE are considered significant (see Attachment
II,SectionB). W recognize that the installation of instrumenta-
tion lines and components has not yet reached a significant level and
that further regional inspections may be planned. While the CAT
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inspection found the area of instrumentation to be relatively
trouble-free, deficiencies were identified in the area of welding /
NDE.
We note that inspections of structural welding, reactor coolant
pressure boundary piping and NDE were performed at Byron Unit 2 under
the 5505XB, 5506XB, 5507XB and 5517XB series of procedures.
While we
recognize there is some duplication of requirements between the
550XXB and the 551XXB procedures and in view of the deficiencies
identified in the area of welding /NDE, regional management should
assure themselves that the pertinent inspection rdquirements for
welding /NDE have been or will be completed.
Our evaluation shows a total of.3766 staff hours in the 766 system
(as of 11/30/85) deveted to construction inspection for Byron 2.
The
hours have been grouped into 19 inspection areas and are shown in
Attachment II, Section C.
This distribution highlights several areas
that appear unusual and may, from the standpoint, of hours and
percentage values, need to be looked at by the region. These are:
Design and As-Built, (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, <1%), Piping (56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br />, N1%),
Instrumentation (55 hours6.365741e-4 days <br />0.0153 hours <br />9.093915e-5 weeks <br />2.09275e-5 months <br />, s1%), Welding /NDE (175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, 5%) and
Independent Inspection (914 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.47777e-4 months <br />, 24%).
It is expected that some
of the approximately 2160 hours0.025 days <br />0.6 hours <br />0.00357 weeks <br />8.2188e-4 months <br /> of inspection time from the CAT
inspection at Byron 2 will apply to the above noted areas and affect
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the percentages.
The above findings have been discussed with the regional office and
they have generally acknowledged them.
The Region has made plans to
ensure that in the areas noted as not yet completed the pertinent
inspection requirements will be completed or that inspection require-
ments have been satisfied.
With respect to the division of staff inspection hours into the three
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major inspection areas of pregram/ procedure review, observation of
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work, and record review, 659 hours0.00763 days <br />0.183 hours <br />0.00109 weeks <br />2.507495e-4 months <br /> were devoted to record review
and 444 hours0.00514 days <br />0.123 hours <br />7.34127e-4 weeks <br />1.68942e-4 months <br /> shown as applied to observation of work.
The 426
hours, smallest among the three categories, were charged against
progran/ procedure review as would be expected on a second unit
(See Attachment II, Section D).
The 659 hours0.00763 days <br />0.183 hours <br />0.00109 weeks <br />2.507495e-4 months <br /> of record review
appears to be proportionately high; however, a closer look shows that
in the 659 hours0.00763 days <br />0.183 hours <br />0.00109 weeks <br />2.507495e-4 months <br /> of record review is a block of 280 hours0.00324 days <br />0.0778 hours <br />4.62963e-4 weeks <br />1.0654e-4 months <br /> charged
against IP 51066B that resulted from the IDI on Byron Unit 1.
Discussions with regional personnel confirmed the applicability of
these hours towards the review of records associated with electrical
component and cable installations on Unit 2.
The review of the inspection reports for Byron 2 indicates good
conformance with the MC 0610 in terms of content, timeliness of
report issuance and overall completeness.
Review of a sample of
the reports issued over the last couple of years indicates reasonable
detail, sufficient data to understand the issues and adequate techni-
cal depth. A check of 19 reports, selected at random and issued
since December 1983, shows an average of 17 days from the inspection
period to date of issue.
One report was noted to take 40 days but
there were several reports issued in the 10 to 12 day range.
Addi-
tionally, report cover letters, starting early 1985, indicate that
the region had changed to the new MC 0611 requirements regarding
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regional review of reports for proprietary information and immediate
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placement in the PDRs if appropriate.
C.
Recommendations
The information reviewed, which was current through November 30,
1985 indicates that the region has generally followed the construction
inspection program in MC 2512.
Notable exceptions are the six
inspection procedures relative to instrumentation and eleven
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procedures in the area of welding /NDE.
Also, the total inspection
staff hours devoted to design and as-builts and piping, up to this
point, appear relatively low.
It is recomended that the region
review the inspection efforts applied to the above mentioned areas,
including the contribution from the CAT inspection, to ensure these
areas have, or will, receive adequate inspection coverage. Our
discussions with the region have revealed that the region has
already made plans to perform additional inspections or is generally
satisfied that inspection requirements have been met.
V.
SAlp REPORTS
An analysis was made of the two most recent SALP reports, for the periods
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1982 and 1983-1984, for those areas that were common to both SALP and the
CAT inspection.
For the SALP period January 1982 through December 1982,
four areas were found to be Category 3 (Safety-Related Components, Support
Systems, Electrical Power Supply and Distribution, and Quality Assurance).
The other three areas rated were Category 1 (Licensing Activities) and
Category 2 ( Containment and Piping Systems).
The next SALP evaluatinn
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showed improvement and generally responsive corrective actions.
For the
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period January 1983 through April 1984, all construction related areas
were rated Category 2.
Generally, the CAT inspection findings are
consistent with the latest SALP ratings.
The bases of the SALP ratings were well documented and supported by the
regional inspection report findings.
Two areas (QC Inspector Reinspection
Program and Fire Protection) were given special emphasis in the latest
SALP report. These areas were noteworthy in that these were given ratings
of Categorj I and 3 respectively.
It is to the region's credit that these
aren were noted separately to highlight both positive and negative
performance by the licensee.
VI. OVERALL ASSESSMENT CONCLUSIONS
A review of the Byron Unit 2 inspection reports, SALP reports, and 766
Computer System data indicates that, generally, the construction inspec-
tion program and modules had been satisfactorily im
tion reports were written with the necessary scope,plemented.
The inspec-
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depth, and technical
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content and on the average were issued within the suggested time period.
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A few areas require additional attention to ensure that inspection modules
in the areas of instrumentation, welding /NDE, design and as-huilts, and
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piping have, or will, receive adequate inspection coverage.
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During the review of the region's implementation of the IE construction
inspection program, the inspection program procedures were informally
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evaluated. Generally the inspection procedures were adequate in specify-
ing the inspection activities in the various technical areas covered by
the CAT inspection.
Some CAT inspection findings suggest possible refine-
ments to the inspection procedures or the communication of the findings to
other IE offices.
Specifically these are:
(1) in welding /NDE, the review
of radiographic records and film from vendors storing this documentation
off-site; (2) communication of the radiographic deficiencies to the IE
Vendor Program Branch for their evaluation; and (3) in the structural
area, the inclusion of independent verification of bolt torque for struc-
tural steel connections.
A review of the CAT and regional inspection findings shows general agree-
ment. The region's effort in the electrical separation area are clearly
evident in the progress the licensee has made to justify the acceptability
of the Byron separation criteria.
The region should continue to monitor
the status of the resolution of this issue.
In addition, it is recom-
mended that the region place additional attention on the corrective
actions to the NRC CAT findings in the areas of radiographs stored in
a
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off-site facilities and fastener traceability.
A review of the latest sal.P reports indicates that the licensee's perform-
ance has improved in several areas and is supported by the NRC CAT find-
ings. This is indicative of effective efforts by the region in monitoring
the licensee's activities in several areas which have been common problems
at other sites (i.e. , piping, pipe supports and electrical separation).
Overall, the regional efforts to oversee the construction activities at
Byron Unit 2 are satisfactory. The implementation of the Construction
Inspection Program procedures also was satisfactory.
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APPENDIX A
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EXECUTIVE SUPMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at
Comenwealth Edison Company's (Ceco) Syron Unit 2 Station, during the period
August 19-30 and September 9-20, 1985.
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OVERALL CONCLUSIONS
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee consnitments. 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
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code documentation is available for the (W) supplied equipment.
In
addition, the NRC CAT review of audits by Ceco and (W) indicated that
audits had not addressed the area of retrievability of radiographs.
2.
A significant number of A490 bolts used in structural steel connections
and equipment hold down applications were found by the NRC CAT to have
less than specified torque values. Some of these connections are designed
to rely on bolt induced clacing forces to carry a portion of the expected
loads.
3.
Exaspies 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 125Y DC fuse par.els were not in accordance
with design requirements.
The identified weaknessac require additional management attention to assure
that completed installations meet design requirements.
AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction
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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.
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Wiring workmanship deficiencies were observed in several Class 1E components.
Deficiencies included items such as, conductor bend radius, lug orientation and
general configuration of wiring.
The most signtficant concern involved
deficiencies identified in QC accepted wiring for Class 1E valve opera-
In this area over 50% of the sample exhibited wiring configurations
tors.
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 1E and non-Class 1E 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
def tetencies on the switchgear were identical to ones which had been found by
the Itcensee on switchgear of Unit 1, but had not been addressed on Unit 2
components.
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Mechanical Construction
Piping, pipe supports / restraints, concrete expansion anchors, and ewchanical
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 ainer discrepancies in the heating, ventilating
and air condi-
tioning (HVAC) ducts and supports indicates that additional prog, ram review and
attention is needed.
without complete resolution of these discrepancies.These areas were previously subjected
Weldino and Mondestructive Examination
Welding and nondestructive examination activities were generally found to be
conducted in accordance with the governing codes and specifications.
However,
a nunter 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 ifcensee has perfortned an engineering evaluation
concerning these findings and concluded that the welds are structurally
adequate for the intended appItcation.
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 wert 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
'
.
d
l
A-2
_______________- _ ____
.
.
.
.
.
.
l
steel and equipment supports did not meet inspection torque values. 'As a
.
result, connection clamping force requirements were not ret.
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 detarmine whether sufficient preload exists in expan-
l
sien anchors for those cases in which washers were not welded to support
baseplates for oversized holes.
-
1
Masonry construction and prestressed, post-tensioned tendon installations
were generally acceptable.
Material Traceability and Control
In general the material traceability and control program was considered to be
satisfactory. Significant lack of traceability was found however, for fastener
materials, including assembly and mounting bolts for large vendor supplied
,
pumps / motors, bolts for battery racks, electrical switchgear and other equip-
ment; and bolts attaching HYAC duct sections.
r
.
Desicn Change Control
'
Design change control was determined to be generally in conformance with
!
applicable requirements.
In this area the most significant finding was the
failure to verify that installations were in accordance to current drawings
when out of date design drawings were identified.
Corrective Action Systems
The licensee's corrective action program was found to be generally acceptable,
except for concerns regarding failure to assure that fasteners of required
materials were furnished with certain vendor supplied equipment, audits failed
to assure that radiographs for welds on certain vender supplied eculpment were
.
!
retrievable as required, and failure to provide for effective spscification
and control of preventive maintenance, particularly from the time of turnover
i
for testing until turnover for operation.
i
<
l
A-3
.
_
_ - _
__ _
. _ _ _ _ _ _,
_ _ _ . _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . , _ _
-
,
_ _ _ -_ . - _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
o
.
.
.
.
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 ielspection report.
2.
10 CFR 50, Appendix B, Criterion !!! as implemented by Comonwealth
Edison Coepany (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.
Centrary to the above, at the time of this inspection, the licensee's
program was .T 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 comitJnents had not
been translated into appropriate procedures and design documents.
(section !!.B.2.b.(S))
b.
Approximately one-third of the total of A490 bolts tested by the NRC
CAT were found to be below the pretension required by A!SC.
Instal-
lation and inspection requirements had not been translated into
appropriate procedures for high strength bolted connections in
structural steel and nuclear steam supply system joints which require
pretension in the bolts.
(Section V.B.I.b)
'
c.
During the inspection, concrete expansion anchors were found which
did not meet the eight bolt diameter embedment depth.
It could not
be shown that embedment length requirements for concrete expansion
anchors as specified in the concrete expansion anchor Qualification
report had been translated into appropriate installation and inspec-
tion procedures.
(Section V.8.2.b)
2.
10 CFR 50, Appendix 8 Criter'on VII, as implemented by Ceco OAM, Quality
Requirement No. 7.0, requires measures be established to assure that
,
'
purchased equipment and services conform to the procurement documents.
Contrary to the above, at the time of this inspection, the NRC CAT
inspectors found several deficiencies in verafor supplied components. The
3
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 vender 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, o'her electrical equipment, and HVAC equipment)
were not of the material required by specifications or drawings.
(Sections IV.B.11 and VI.S.I.b.(2))
,
B-1
.
.
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-
- - - - - - .
.
- -
- .
- - -
--
-- -
---
- - - - -
.
.
.
.
.
.
3.
10 CFR 50. Appendix 8. Criterion X, as implemented by CEC 0 QAM. Quality
Requirement 10.0 requires that a program for inspection of activities
be established and executed to verify conformance with documented
instructions, procedures, and drawings for accomplishing the activities.
.
Contrary to the above, at the time of this inspection, the licenste's
inspection programs were not effectively implemented in that:
l
1'
a.
Unit 2 4160V switchgear and DC fuse panels were found not to be
installed in accordance with requirements for seismic mounting of
A
Class 1E equipment. (Section II.8.3.b.(4) and (6))
T
i
.
i
b.
Some Class 1E electrical raceways have not been installed in accord-
ance with FSAR commitments for electrical separation. (Section
1
!!.8.1.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
11.8.3.o.(8))
.
4
.
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'
B-2
.
-
.
.-
.
. _ _ - . -
-
- - -
-
--_
'
-
..
.
.
ATTACHMENT I
MC 2512 INSPECTION HOURS
COMPARISON OF BYRON 2 TO SELECTED SITES
13
,
12 -
,
11 -
,
10 -
9-
a
gg
8-
,
27
7-
.0$
=
$o
0-
I
'
h
5-
4624
E
3996
4
Ayerage
f
.
.
........
.
.
.........................
2861
3827 hours0.0443 days <br />1.063 hours <br />0.00633 weeks <br />0.00146 months <br />
3,
/
_
,
,
,
B-2
C-2
PV-2
Total Phone 2 Hours Through Jon 1986
,
B-2: Byron-2
PV-2:
Palo Verde-2
C-2: Catawba-2
i
t
l
l
l
.-
,
l
_ _ . _ _
-
.,
.
.
.
'
ATTACHMENT II
766 DATA SUMMARY
i
MC 2512 STATUS OF BYRON UNIT 2
Summary of Inspection Procedures (IPs) used versus procedures specified in
MC 2512, and staffhours expended and distributions.
Based on 766 Computer
'
System Data as of November 30, 1985.
'
A.
Distribution of IPs by Degree of Completion:
'
i
t
Total
i
Percent Completion
No.
Percent
l
,
Less than 25%*
56
37
25-50%
10
7
'
51-75%
3
2
1
-
76-99%
13
9
100%
68
45
I!i0
T6D
i
- Includes all IPs that do not have hours charged against them as of
f
11/30/85.
B.
Significant Inspection Procedures With No Hours Recorded in 766:
!
Instrumentation
52054B
52056B
520638
52064B
520658
52066B
!
Welding /NDE
550938
551518
!
55152B
55153B
j
55154B
3
55155B
'
55156B
e
55157B
55158B
55171B
s
551768
Containment Test
63050B
,
.
4
II-1
'
- -
- - - - - - - - - - - - -
.
.
C.
Total Hours Per Inspection Area for MC 2512:
.
Inspection Area
Hours
Percentage
Management Meetings
373
10
Quality Assurance
188
5
Design and As-Built
16
<1
Geotechnical
26
<1
Structural Concrete
183
5
Structural Steel / Supports
97
3
Piping
56
1
Mechanical Components
419
11
Electrical
468
12
Instrumentation
55
1
Containment Penetrations
9
<1
Welding /NDE
175
5
Containment Test
0
0
Fire Prevention / Protection
0
0
Inservice /Preservice Inspection
26
<1
Environmental Protection
27
<1
.
Followup
703
19
Independent Inspection
914
24
.
Miscellaneous
31
<1
3733
IUD (Approx)
D.
Phase 2 (Construction) Procedures Used and Total Hours:
Program
No. of Procedures Used
Recorded H_ours
110
3756
Distribution of Hours per IP Scope:
Hours
Percentage
Procedure Review IPs
426
28
Work Observation IPs
444
29
Records Review IPs
659
(IDI = 280)
43
I
1579
IM
i
W
i
II-2
. - .
.
.
..
. -
-
.-
.
.
ATTACHMENT III
INSPECTION PROGRAM HISTORY FOR BYRON UNIT 2
.
(A5 0F NOVEMBER 30, 1985)
A.
Civil and Structural Procedures
1.
Site Preparation
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
45051B
2
4
100
C
45053B
1
1
100
C
45055B
1
1
100
C
2.
Foundations
'
'
46051C
3
15
40
C
46053B
1
3
20
C
460558
1
2
100
C
-
3.
Containment (Structural Concrete)
47051B
4
44
100
C
47053B
1
12
100
C
47054B
3
9
100
C
47055B
3
13
100
C
47056B
2
38
100
C
4.
Containment (Prestressing)
~
47061B
8
18
100
C
47063B
5
13
80
47063C
1
24
20
47065B
3
12
80
2
5.
Containment (Steel Structures and Supports)
4B051B
5
23
100
P
480538
4
19
100
P
>
4B0558
5
21
100
P
6.
Safety-Related Structures (Structural Steel & Supports)
48061B
2
9
100
P
480638
3
10
100
C
4B064B
2
2
100
C
48065B
3
5
100
C
,
48066B
2
8
100
C
.
111-1
. _.
-
. . -
._
.
._
-
-
.
B.
Mechanical Construction Procedures
l
'
1.
Reactor Coolant Pressure Boundary Piping
Reported
i
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
49051B
2
6
100
C
49053B
3
4
100'
C
49054B
3
6
100
C
49055B
1
1
100
C
49056B
2
3
100
C
49061B
5
12
100
C
49063B
7
13
100
C
49065B
6
11
100
P
2.
Reactor Vessel Installation
.
50051B
3
3
100
C
~
50053B
1
-1
100
C
50055B
2
2
50
,
'
3.
Reactor Vessel Internals
50061B
3
7
100
C
50063B
3
3
100
C
50065B
4
4
100
C
4.
Safety-Related Components
50071B
5
14
100
C
50073B
6
10
100
'C
500748
3
6
100
C
500758
3
3
100
C
50076B
3
6
100
C
5.
Pipe Supports and Restraints
50090B
8
333
80
C.
Electrical and Instrumentation Construction Procedures
1.
Electrical Components and Systems
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
'
51051B
5
18
80
51053B
3
29
40
510548
3
10
30
51055B
2
5
30
51056B
2
14
50
III-2
]
'
,
.
- . .
__
.
- . . .
- .
- - -
.
.
2.
Electrical Cables and Terminations
l
Reported
l
Procedure
Number of
Total Staff
Percent
. Reported
'
Number
Inspections
Hours
Completion
Status
51061B
8
36
90
51063B
8
40
30
51065B
4
36
80
51066B
1
280
3.
Instrumentation Components and Systems
52051B
3
24
100
52053B
3
15
60
'
52055B
1
10
80
51061B
2
6
60
D.
Containment Penetration Procedures
i
53051B
2
3
100
C
'
'
53053B
2
3
100
C
'
53055B
2
3
100
C
'
'
, .
.
,
E.
Welding and NDE Procedures
i
1.
Containment Structural Steel Welding
Reported
Procedure
Number of
Total Staff
Percent
Reported
i
Number
Inspections
Hours
Completion
Status
55051B
3
4
100
C
i
l
55053B
6
24
60
1
55055B
3
6
90
l
2.
Safety-Related Structures Welding
550618
2
5
100
P
55063B
2
8
100
C
55064B
2
2
100
C
55065B
3
6
100
C
550668
2
3
100
C
,
3.
Reactor Coolant Pressure Boundary Pipe Welding
550718
2
3
100
C
55073B
3
10
100
C
55074B
2
7
100
C
55075B
1
1
100
C
550768
2
4
100
C
4
i
III-3
4
.
-
.
4.
Safety-Related Pipe Welding
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
55081B
3
4
100
C
55083B
9
18
100
C
55085B
8
11
100
C
5.
Reactor Coolant Loop Welding
55172B
3
9
100
C
55173B
3
4
100
C
55175B
2
7
100
C
551778
1
1
100
C
55178B
2
2
100
C
6.
Other Safety-Related Pipe Welding
55181B
1
6
100
P
55182B
2
8
100
C
55183B
2
7
100
C
-
55185B
1
1
100
C
55186B
1
3
100
C
551878
2
9
100
C
551B88
2
2
100
C
7.
Inservice / Pre-service Inspection
73051B
3
4
90
,
73052B
4
11
80
73053B
3
7
80
73055B
3
4
80
'
i
F.
Miscellaneous Inspection Procedures
1.
Meetings, QA, As-Built, Fire Protection / Prevention, Containment
SIT, and Environmental Protection Fuel Storage
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
,
30051B
1
4
100
C
30702B
20
161
30703B
99
208
35060B
1
30
80
C
35061B
1
39
100
C
35065B
1
13
40
C
351000
1
20
352006
1
86
100
C
37051B
2
4
50
C
37055B
1
12
50
C
50095B
1
2
100
C
III-4
__
-
_ _ _
- - .
_ - .
r
.
, , , . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . - . ,
......4
.... . . , .
o
o
'
.
I
2.
Followup and Independent Inspection
.
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
_ Completion
Status
927008
13
34
927018
48
212
92702B
31
286
927038
14
86
92704B
2
37
.
92705B
7
48
'
927068
78
914
92716B
2
24
,
L
.
.
i
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I
i
l
l
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111-5
L