ML20197H382
| ML20197H382 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/12/1986 |
| From: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8605190157 | |
| Download: ML20197H382 (6) | |
See also: IR 05000455/1986027
Text
od 7?? 6
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.
MAY 121986
/
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I
Docket No. 50-454"
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Vice President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
Thank you for your letters dated January 24, and April 9,1986, informing us of
the steps you have taken in response to the results of the NRC Construction
Assessment Team (CAT) inspection forwarded in Inspection Report No. 50-455/85027
by letter dated November 13, 1985 and the Notice of Violation forwarded by our
letter dated December 12, 1985.
Your January 24, 1986 response was forwarded to the Office of Inspection and
Enforcement who lead the CAT inspection.
Your response has been reviewed and
we are in agreement on seven of the ten individual items used as examples of
violations. The specific items and our findings are summarized in Enclosure 1.
Our comments concerning the remaining violations are provided in Enclosure 2.
We will examine these matters during subsequent inspections.
Your cooperation with us is appreciated.
-
Sincerely,
"Orighrd cit ed hi 2. F. tia nic M
R. F. Warnick, Chief
Reactor Projects Branch 1
Enclosures: As stated
See Attached Distribution
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Commonwealth Edison
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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. Olshan, NRR LPM
H. S. faylor, Quality Assurance
Division
.
._
_
-_
. . _ _ - - .
_ _,.
_
__
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i'
. ENCLOSURE 1
l
SUMMARY
a
.
1.
Agree
Disagree
Violation No.
With Licensee
With Licensee
'
la - (Butt splices)
X*
3
lb - (Structural steel bolted
X
connections)
'
.
Ic - (CEA)
X
2 - (W radiographs)
X
i
1
-_(Tanks / heat exchangers)
X
- (Vendor radiographs)
X*
1
]
- (Component fasteners)
X
3a - (Electrical mounting
X
deficicacies)
3b - (Electrical separation)
X
.
3c - (MOV wiring)
X
i
Total
7
3
!
- Not an example of a violation
!
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,
1
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]
!
.
,
,
4
- - - -
- - - - - .
- - - - - -
. - - - - - - -
- - - . - - - .
. - -
- - .
- -
- -
-
- -
- -
.
-
. - -
-
. - .
.
- - .
. ~ - .
- .
- . - - .
. . - - - -
- - - - -
- -
- -
_ _ .
_.
. . _
.
__ _ __ _
,
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ENCLOSURE 2
,
VIOLATION Ic
As stated in the NRC CAT inspection report, the CEA qualification report and
site inspection procedures specify an embedded depth (Le) to be measured from
the concrete surface to the bottom of the expansion ring. However, in the
installed condition Le cannot be physically measured or derived indirectly.
!
Only if it is assumed that the expansion ring remains stationary as the back
!
of the anchor does not move all the way to the ring or the expansion ring also
moves towards the concrete surface as the bolt is tightened and the anchor is
measured (below the concrete surface) to be a distance of exactly the minimum
embedded depth, the actual Le (measured to the expansion ring) would be less
than the minimum embedded depth specified by the qualification report.
i
Tables 1 and 2 summarize some instances in which it appears that anchor bolts
1
may not meet the embedded depth specified by the qualification report. Tables 1
.l
and 2 reflect a (minus) 1/16 inch installation tolerance and physical measure-
4
ments of expansion anchor bolts made by the NRC CAT. The maximum deviation from
i
the specified embedded depth (including installation tolerances) is 11/16 inch.
We still consider that the anchor bolt qualification requirements have not been
adequately translated into appropriate installation and inspection procedures.
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4
4
1
4
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Table 1*
Maximum
Maximum
Calculated Difference
CEA
Between
Projections Length
Wedge and
Hanger
Below
Bottom
Minimum
No.
Diameter Length Concrete
Concrete
of CEA
Installed Le
Traveler 8601
1/4
3 1/4
2 1/4
1
3/8
5/8
WS-2
3/8
5
1 7/8
3 1/8
1/2
2 5/8
WS-35
3/8
5
1 5/8
3 3/8
1/2
2 7/8
WS-50
3/8
5
2 1/4
2 3/4
1/2
2 1/4
2CV130345
3/4
10
3 9/16
6 7/16
3/4
5 11/16
2FW93E010X
5/8
8 1/2
3 1/2
5
5/8
4 3/8
- All dimensions in inches
TABLE 2*
Adjusted
Difference in
Qualifica. Le for 1/16"
Minimum
Installed and
Hanger
Report
Installation
Installed Le Qual. Report
No.
Diameter
Le
Tolerance
From Table 1 Adjusted Le
Traveler 8601
1/4
3/4
11/16
5/8
1/16
WS-2
3/8
3
2 15/16
2 5/8
5/16
WS-35
3/8
3
2 15/16
2 7/8
1/16
,
WS-50
3/8
3
2 15/16
2 1/4
11/16
2CV130345
3/4
6
5 15/16
5 11/16
1/4
2FW93E010X
5/8
5
4 15/16
4 3/8
9/16
- All dimensions in inches
_.
_
o
.
VIOLATION 2 (Westinghouse Radiographs / Construction Weakness 1)
For the Unit 2 component cooling surge tank it has not been addressed how the
ASME Code requirements are being met without the availability and existence of
the radiographic film. An alternative is to reduce the joint efficiency from
100% to 75% which will then meet the ASME Section III rules. The use and
acceptance of a lower joint efficiency would then have to be evaluated. The
current response cannot be accepted because the ASME Code requirements have
not been met.
VIOLATION 3b
The Supplemental Safety Evaluation Report (SSER) transmitted to CECO in a
memorandum from V. S. Noonan, NRR dated February 25, 1986, the NRC staff's
evaluation of Byron /Braidwood electrical separation criteria.
In summary the
staff's conclusions were:
(1) Between safety-related and nonsafety-related raceway, the separation
distances of 12" vertical and 3" horizontal is adequate, and
(2) Between safety-related cables in free-air and nonsafety-related
raceway and for the case of nonsafety related cable in free-air and
safety-related raceway, contact is acceptable.
The NRC approved criteria should be the basis of QC inspection criteria.
However, your response maintains tnat the only raceway separation criteria
necessary is 1" between raceway. The QC criteria remains in conflict with
current FSAR and SSER statements.
Installations which do not meet the
separation criteria as defined in the SSER require identification and
evaluation.
We maintain that you had not established and still do not have inspection
procedures which verify conformance to the FSAR/SSER criteria for electrical
raceway separation. This violation remains valid.
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