ML20207N028

Responds to Violation 455/85-27-1c Noted in Const Appraisal Team Insp Rept 50-455/85-27 & Provides Supplemental Response to Violation 455/85-27-02.Corrective Actions:Qa Dept Audited Radiograph Retrievability at Westinghouse

ML20207N028
Person / Time
Site:	Byron
Issue date:	10/29/1986
From:	Hunsader S COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
2342K, NUDOCS 8701130400
Download: ML20207N028 (17)

Text

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! - 3 One First Nabonal Plaza, Chicago. lilinois

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/ Address Reply to: Post Omco Box 767 Oct ber 29, 1986 Nd Chicago. lilinois 60690 0767 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Connaission Region III 799 Roosevelt Road i Glen Ellyn, IL. 60137

Subject:

Byron Station Unit 2 NRC CAT Inspection IE Inspection Report No. 50-455/85-27 NRC Docket No. 50-455

References:

(a) January 24, 1986 letter from D.L. Farrar to J.G. Keppler (b) May 12, 1986 letter from R.F. Warnick to C. Reed (c) September 26, 1986 letter from K.A. Ainger to J.G. Keppler

Dear Mr. Keppler:

s Reference (a) provided Commonwealth Edison's response to the inspection report of the NRC Construction Appraisal Team (CAT). Reference (b) included NRC Region III's unresolved issue concerning violation 455/85-27-Ic, that the anchor bolt qualification requirements had not been adequately translated into appropriate installation and inspection procedures with regard to the required embedded length of the anchor. Attachment A provides the response to this issue and qualifies the acceptability of the Concrete Expansion Anchor installations.

Reference (c) provided an update of Commonwealth Edison's actions with respect to the radiographic film which was not retrievable. In reference (c) it was stated that Westinghouse had developed an action plan to account for the mislocated radiographs and that the results of their review would be provided to you by October 15, 1986. In a meeting held at Region III with Messrs. J. Harrison and J. Jacobson of your staff and Mr. K.J. Hansing of Commonwealth Edison Q.A. on October 14 1986, the results of the Westinghouse review were discussed as well as the Commonwealth Edison QA audit results.

Attachment B provides the supplemental response to violation 455/85-27-02.

Please direct any questions regarding these items to this office.

Very truly yours, 8701130400 861029 PDR ADOCK 05000455 G PDR jg I S.C. Hunsader Nuclear Licensing Administrator K I .

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10-20-86

, ,, ATTACHMENT A

, Byron Unit 2

. o Response to the NRC Construction Assessment Team Concern on Concrete Expansion Anchors Violation 455/85-027-01c

Reference:

Letter from R. F. Warnick (Nuclear Regulatory Commission) to Cordell Reed (Commonwealth Edison Company) dated May 12, 1986.

Introduction and Executive Summarv In the referenced letter, NRC Region III informed Commonwealth Edison Company that there remains an unresolved issue regarding Concrete Expansion Anchors (CEA) from the NRC Construction Assessment Team (CAT) inspection at Byron Unit 2. The NRC CAT considers that the anchor bolt qualification requirements have not been adequately translated into appropriate installation and inspection procedures with regard to the required embedded length of the anchor.

The qualification tests, installation specification, and contractor--

installation procedures are all consistent in the method of defining the embedded leng t* from the concrete surface to the bottom of the expansion wedges. Thus, the qualification requirements have been properly translated into the installation procedures.

The real NRC CAT concern is for the independent inspection ot the embedded length. As acknowledged by CAT, it is not pcssible to precisely determine the location of the CEA wedges af ter the 1

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. . . ATTAC10fENT A  !

anchor has been torqued due to the movement of the anchor necessary l to expand the wedges and " set" the anchor. The method' used by .

Pittsburgh Testing Laboratory to verify embedded length is illustrated in the example in Figure 1. This method accounts for the anchor movement, which may be up to one anchor diameter.

The CAT notes that their may be little or no anchor movement to set the anchor and thus the method of verifying ~ Le may be unconservative. The concern is illustrated in Figure 2. However, it is known that the anchor has to move in order to set the anchor.

The amount of movement depends on the small variables existing in the materials and installation process.

To resolve the CAT concern it has been conservatively assumed that there is no movement of the anchor when it is torqued and set. The embedded length to the expansion ring was determined by subtracting the length of the anchor projecting below the expansion wedges from the total embedded length of the anchor

, as measured by PTL.

For 3/8" diameter and larger anchors, which have a specified embedded length of 8 diameters, the concrete pullout capacity with the reduced embedded length is greater than the anchor capacity determined in the qualification tests. Thus, the ultimate capacity of the anchors is not affected.

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. . ATTACHMENT A For 1/4" diameter anchors, which have shorter embedment lengths, a sample of 60 assemblies was chosen for evaluation. This sample included 20 assemblies from contractors in each of the mechanical, electrical, and structural areas. The PTL inspection reports were reviewed and the reported embedded lengths were reduced by the amount of anchor projection below the expansion wedges, using the same conservative assumption that the anchor did not have to move to set the wedges. Of the 612 individual anchors in the 60 assemblies, 47 anchors had reduced embedment lengths shorter that the 5/8" required by the specification. For these ,

anchors, the actual loads were compared to the reduced ultimate capacity and in all cases the factor of safety is in excess of 4.

Based on the evaluations which were performed and that are summarized above, the CAT concern should be closed.

The various points sommarized above are explained in more detail in the'following sections.

Requirements for Embedded Length & CAT Concern The concrete expansion anchor installation and inspection specifica-tions, the contractor installation procedure, and the qualification test installation requirements are all consistent in that the embedded length, Le, is determined from the concrete surface to the bottom of the expansion wedges prior to torquing the anchor.

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ATTACHMENT A Article 3.1.10C of Specification BY/BR/CEA states'"...Le shall be to the untorqued position of the expansion rihg." The contractor work procedures, based on the specification, use the same method for defining Le. The results of the qualification tests are summarized in " Report on Static, Dynamic and Relaxation Testing of Expansion Anchors in Response to NRC I.E. Bulletin 79-02,"

dated July 20, 1981. Chapter III of this report states ". . .For each anchor, the embedment depth has consistently been defined as the distance from the surface of the embedding material to the bottom of the expansion ring." . Chapter.V d.etails how the tests were performed, and, under " Anchor Installat. ion," states

"...After cleaning the loose dust from the embedment hole, an unused anchor was inserted into the embedment hole and driven to the intended embedment depth. Anchor installation was completed by applying the magnitude of the installation torque." Thus, it can be seen that the specification, contractor work procedures, and the qualification tests are identical with respect to the definition of anchor embedded length, Le.

The CAT team acknowledges that it is not possible to determine the location of the expansion wedges af ter torquing the anchor.

Thus, it is not possible to precisely verify the embedded length, Le, from the top of the conrete to the bottom of the expansion wedges, after torque. The contractor installation procedures and documentation of installation provides assurance that the minimum Le, before torque, is achieved.

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ATTACHMENT A The Pittsburgh Testing Laboratory inspection af ter anchor torquing accounts for the anchor movement necessary to set the anchor and is a practical means of monitoring contractors conformance with the specification. This process is illustrated in the attached Figure 1.

The concern posed by CAT is that an anchor inspected by PTL may be accepted, but could be slightly short of the required Le.

CAT assumes the anchor is set in the hole at less than the minimum Le with little or no slippage occurring during torquing and setting of anchor. This concern is iliustrated in Figure 2.

To address this concern, the embedded length reported by the independent inspection agency at Byron (Pittsburgh Testing Laboratory) has been reduced by the amount of the anchor projection below the expansion wedges. This is a very conservative assumption,

,since movement must occur when the anchor is tightened to the required installation torque in order to expand the wedges and set the anchor. The following sections show th'e evaluations which were performed.

Evaluation of 3/8" Diameter and Larger Anchors For 3/8" diameter and larger anchors, the required embedded length ~

is equal to 8 anchor diameters. This length was reduced by the amount of anchor projection below the expansion wedges for the 5

ATTACHMENT A anchor in the.untorqued position. The ultimate pullout ~ capacities of the concrete were calculated for the reduced embedment lengths. .

The ultimate capacities of anchors . embedded 8 diameters, as determined from the tests, were compared to the concrete pullout capacities at the reduced embedment length. In all cases, the pullout capacity is greater than the qualification test ultimate capacities.

Table 1 summarizes the results of this evaluation.

Evaluation of'l/4" Diameter Anchors For 1/4" diameter anchors with a required embedment length of

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3/8", a sample of 60 assemblies was selected for evaluation.

Twenty assemblies were chosen from work installed by contractors in each of the mechanical, electrical, and structural areas.

The reported embedded length (Le) on the PTL inspection reports were conservatively adjusted by the anchor projection below the expansion wedges in the untorqued position, that is 3/8". All anchors with an adjusted Le of -less than the required 5/8" were '

evaluated for the actual loads and in all cases the factor of safety against the ultimate anchor capacity was greater than

4. Table 2 summarizes the number of assemblies and anchors which were reviewed. ,

Clarification / Corrections of CAT Findinos The CAT examined a number of C2A installations at Byron and found a few anchors which, using the assumption that the anchor does 6 .

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5 ATTAC10ENT A not move when it is torqued and set, might be slightly short .

of the specified embedment length. These CAT finding are summarized in Reference 1. Two corrections should be made to this data:

1. The anchor identified as Traveler 8601 has an " adjusted minimum installed Le" of 5/8". This value is greater than the specified Le of 5/8" minus 1/16" tolerance or 9/16".

Thus, Traveller 8601 should not have been reported as being a concern in Enclosure 2 of Reference 1.

2. A WS-50 support was reported by CAT as having an " adjusted minimum installed Le" of 2-1/4". Pittsburgh Testing Laboratory inspection reports show a minimum Le of 3-1/16" for one of the two anchors in this assembly. PTL also. reinspected this assembly June' 2, 1986, and again found a minimum Le o f 3-1/16" . The "adjustd minimum installed Le" reported by CAT should be 3-1/16" minus 1/2" or 2-9/16". The maximum theoretical deviation from specified Le for this anchor is thus 3/8" not the 11/16" stated in Enclosure 2 of Reference 1.

Conclusion The contractor installation procedures, which are identical to the installaticn specifications and CEA qualification test require-ments for CEA embedded lengths, assures that the anchors are being properly installed at Byron.

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ATTACHMENT A The method of verification of anchor length af ter anchor torquing used by PTL is a practical means of ver'ifying contractor compliance with the installation requirements. This method accounts for the anchor movement necessary to set the anchor. To address ,

NRC CAT concerns that this method is not always conservatice, evaluations have been performed using embedded lengths which have been conservatively reduced by the amount of anchor projection below the expansion wedges. In actual practice this reduction is much less because of the movement of the anchor necessary to set the wedges. For 3/8" diameter and larger anchors, the evaluation shows that the ultimate capacity is not affected. .

For 1/4" diameter anchors, an evaluation of a sample of 60 assemblies, which included 612 anchors, was performed. Some of the anchors in the sample were theoretically short of the specified embedment length of 5/8". ' All were evaluated for the actual loads and reduced embedment lengths and found to have a factor of safety in excess of 4 against the ultimate. anchor capacity.

Based on these evaluations, the NRC should close the CAT concern a

on Concrete Expansion Anchors.

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ATTACHMENT A TABLE 1 Concre te Expansion Anchors Comparison of Ultimate Capacities for 3/8" Diameter and Larger Anchors Anchor Le E L U L RED. p T Diame ter (in.) (in.) (in.) (lb.) (lb.)

3/8" 3 1/2 2-1/2 4550 4100 1/2" 4 1/2 3-1/2 8840 8100 5/8" 5 5/8 4-3/8 13800 12000 3/4" 6 3/4 5-l/4 19900 16500 1" 8 1 7- 35400 22000 L, - Minimum Embedment Length E -

Expansion Cone Length (See Figure 2)

L -

Reduced Embedment Length conservatively assuming that RED there is no movement of the anchor during the torquing -

and se tting process = L-e -E g Up -

Ultimate Concrete Pullout Capacity using L RED U Ultimate Anchor Capacity from the qualification test results

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4 ATTACHMENT TABLE 2 '

Concrete Expansion Anchors Summary of Review of 1/4" Diameter Anchors

1. Anchors With i Anchors With Total i BRED. .>  ! RED. I !

Contractor i Assemblies Anchors Note il Note il Mechanical 20 106 106 0 Electrical 20 78 58 20 Structural 20 428 401 27 Total 60 612 565 47 4

Note #1: L RED * - Reduced embedment length determined by taking the embedment length reported by the inspection agency and subtracting the full expansion cone length (Er.) . This conservatively assumes that there is No movement of the anchor when it 4 5/8" is torqued and set. All anchors with L were qualified for the actual loads and !hduced R ultimate capacities. The factor of safety against the ultimate capacity is in excess -

of 4.

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'ATTACIDfENT A

, FIGURE I ,

INSTALL ATION AND INSPECTION OF C. E. A RELATED TO EMBEDDED LENGTH 1/2*9 CONCRETE EXPANSION ANCHOR " "

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L] o o BEFORE TORCUE AFTER TOROUE

1. Contactor sets anchor such that The independent inspection agency (PTL) wedges will be deeper than the monitors contractor conformance with minimum specified Le. regard to embedment length as follows:

2. Contractor torques the anchor. 1. Total anchor length (L) is determined The anchor is drawn thru the f rom the length code on the anchor wedges to expand the wedges or by ultrasonic test. The projection against the concrete and set (P) of the anchor above concrete is the anchor. measured. The dimension from top of concrete to bottom of anchor is calculated

.The maximum slipppage allowed as X = L-P.

by the specification is one .

anchor diameter. Le before torque is approximately equal to the X dimension atter torque duee In the example shown above, for to the slippage required to expand a 1/2" diameter anchor the minimum the wedges and set the anchor.

specified Le is 4".

2. The calculated X value is compared (Note Normally the contractor to the specified Le to determine the will set the anchor in the anchor acceptability.

• hole so that the actual embedment is greater than Le in order to minimize In the example shown above the total i rejection and rework). length L, is 6" the projection P is 1-3/4" and the dimesion from top of concrete to bottom of anchor is 4-1/4" is greater than the specified Le of 4". -

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ATTACHMENT A FIGURE 2 ILLUSTRATION OF CAT CONCERN ON C.E. A. EMBEDDED LENGTH C l/2*$ CONCRETE

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EXPANSION - -

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,( L BEFORE TORQUE AFTER TOROUE (NO SLIPPAGE)

This example illustrates the CAT concern.

1. An anchor is assumed to be installed in the hole short of the required 4" Le.

torque). (before

2. The length is verified by PTL (after torque). The dimension from the concrete sur- '

face to the bottom of the anchor is calculated to be 4-1/4" which is acceptable when compared to the required Le of 4". Thus, CAT is concerned that PTL is inspecting and accepting anchors which may not meet the Le requirement before torque. This is based on the CAT assumption of little or no anchor slippage during anchor torquing.

However, slippage is necessary to expand the wedges and set the anchor.

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ATTACHMENT'I'

. SUPPLEMENTAL RESPONSE TO 455/85027-02

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10CFR50, 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:

As committed to in response dated 1/24/86 from D. Farrar to J. Keppler, .

the Commonwealth Edison 4uality Assurance Department audited radiograph retrievability at Westinghouse. As a result.of this audit, additional radiographic flim store'd by Westinghouse vendors was found not to be retrievable. This. population of unretrievable film is identified in Tables 1-3. Table 1 identifies ASME Code radiographs where the' required-10 year retention period for the film has expired. Table 2 identifies ASME Code radiographs where the 10 year retention period has not expired. Table 3 Identifies the non-ASME Code radiographs which were

. Identified as unretrievable.

For the items identified in Table 1, retention of the radiographic film is no longer required as the 10 year period has expired and.no volumetric ISI is required for these items. The records for these items include radiograph reader sheets, ASME Code Data Reports signed by the Authorized Nuclear Inspector and Westinghouse Quality Releases signed by the Westinghouse Quality, Representative all attesting to the acceptability '

of the radiographs.

While the retention period for items in Table 2 have not expired, the quality of the items and acceptability of the radiographs is evidenced by the radiograph reader sheets, ASME Code Data Reports and Westinghouse Qualitt Releases. None of the items in table 2 require volumetric ISI.

The quality of items identified in table 3 and acceptability of their radiographs is documented in the rdiograph reader sheets and the Westinghouse Quality Releases.

Corrective Action Taken to Avoid Further V1'olation: " ,,

Westinghouse has retrieved radiographic film previously stored by vendors and placed it under their direct control.

Date When Full Compliance Will be Achieved:

Westinghouse completed the retrieval of radiographic film on September 30, 1986.

. , P ATTACHMENT B 4 Tablo - 1

, ASME Code Items - 10 Year Retention Period Expired ,

CERT DATE

$UPPLIER DESCRIPTION tiffd W SPIN # CQQL 111 DATA REPORT R RT READER SHT BYRON 1 - CAE &

LAMCO Fuel Transfer 805 FHSTTT Class MC No 09/23/76 01/12/77 04/22/76  !

Tube N-2 RECo. Recycle Evap. 2307.70 BRDMRE Class 3 No 08/12/76 02/14/77 7/13 & 23/76 .

Demin. N-1A 2308.70 BRDMRE Class 3 No 06/03/76 06/04/76 06/03/76 -

N-1A f COPES-VULCAN Control Valve 7310-95283-247-1 (Tag #) Class 2 No 08/20/75 09/09/75' 08/18/75 Loop Fill Reg. I-HVC-184 NPV-1  :

Control Valve 7310-95283-211-1 (Tag #) Class 2 No 08/16/76 08/18/76 01/22/76 Excess Letdown 1-8143 NPV-1 l Heat Exchanger RYRON 2 - CBE LAMCO Fuel Transfer 806 FHSTTT Class MC No 09/23/76 01/12/77 04/22/76 Tube N-2 COPES VULCAN Control Valve 7310-95284-211-1 (Tag #) Class 2 No 07/12/76 07/15/76

• 02/19/75 Excess Letdown 2-8143 NPV-1 10/15/75 Heat Exchanger 0996R [

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f ASNE Cod 2 Items - 10 Y.;cr R:tsr.tlon P riod Not Empired CERT DATE f

• SUPPLIER DESCRIPTION tiffaf W SPIhr CW)E lil DATA REPORT g.L RT READER SHT i B(RON 1 - CAE Component Cooling 19A6128-1 CCATCC Class 3 Visual 05/26n7 06/03n7 1-2n7

• f W HTD Surge Tank N-1A 1 6 2500-1 Control valve 7310-95283-228-1 (Tag #) Class 2 No 04/12n7 04/14n7 01/06n7 f COPES-/ULCAN 1-TCV-129 NPV-1

Letdown Regen.

1 Heat Exchanger (I.D.) l ITT-GRINNELL Diaphram Valves 74-1657-22-1 4 x 920 Class 2 No 03/16n7 03/18 n7 03/03n 7 j (CV System) 74-1657-22-2 4 x 920 NPV-1 No 03/16n7 03/18n7 03/03n7 -

i 74-1657-22-3 e 4 x 92D No 03/16/77 03/18/77 03/03/77 i 76-11871-2-1 4 x 920 No 07/12n7 07/19n7 , .04/13n7 SyRON 2 - CBE I Component Cooling 19A6129-1 CCATCC Class 3 Visual 05/26n7 06/03n7 1-Sn7 7 W HTD Surge Tank N-IA I 6 2500-1 [

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FISHER- Butterfly Valves 8F207880 88A740 Class 2 NO 05/24n8 06/05n8 06/16n5 CONTINENTAL (RH System) BF207881 8BA74D NPV-1 . 05/22n8 06/05n8 01/13/75 l

8F207882 88A74R 05/31/78 06/05/78 02/18/75 l

1 BF207883 88A74R 05/24n8 06/05n8 02/25n5 1

l' COPES-VULCAN Control Valve 7310-95284-228-1 (Tag #) Class 2 No 04/19n7 06/17n7 12/16/76 l Letdown Regen 2TCV-129 NPV-1 4 l Heat Exchanger i

j BRAIDWOOD 1 - CCE j Component Cooling 19A6130-1 CCATCC .

Class 3 Visual 06/24/77 07/11n7 1-6n7 ,!

W HTD Surge Tank N-1A I h 2500-1 }

Diaphram Valve 74-10068-16-11 (I.D.) Class 2 No 11/16n6 11/18/76 11/0106  !

l ITT-GRINNELL (CVCS or Spent 2X92D NPV-1

l Fuel System) f BRAIDWOOD 2 - CDE Component Cooling 19A6131-1 CCATCC Class 3 Visual 06/24 n7 07/11n7 3-Sn7 i W HTD N-1A I W 2500-1 d Surge Tank , ,

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Tablo - 3 Non-ASME Cod) Items f CERT DATE lufTLIIB DESCRIPTION Bffd W SPIN # CODE lil DATA REPORT & RT READER felf' BYRON 1 - CAE Integrated Head 4208 NC FHIHHR No No N/A 10/11/78 09/21/78 SPEEDWAY Lift Rig (Sling Block)

SYRON 2 - CBE No No N/A 08/01/78 04/19/78 SPEEDWAY R. V. Internal 3797NC FHSTIR Left Rig (Sling Block) {

FHIHHR No No N/A 12/21/78 12/04/78 Integrated Head 4209NC Left Rig (Sling Block) ,

i BRAIDWOOD 1 - CCE I No No N/A 09/20/78 06/20/78 i' SPEEDWAY R.V. Internals 3798 NC FHSTIR '

Lift Rig t

(Sling Block) i 4210 NC FHIHHR No No N/A 11/20/78 11/01/78 Integrated Head Left Rig .

(Sling Block) ,

7730-01 ICELTC No No N/A 11/07/77 9-10/77 W-ELHIRA Incore Thermocouples thru (Scrapped-replaced) 7730-71 BaalDWOOD 2 - CAE No No N/A 09/25/79 03/01/79 SPEEDWAY R.V. Internals 3799NC FHSTIR Lift Rig (Sling Block) 7748-01 ICELTC No No N/A 12/21/77 11/77 W-ELHIRA Incore Thermocouples thru (Scrapped-replaced) 7748-71

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