ML20214C380

Affidavit of JW Muffett Supporting Staff Response to Applicant 851220 Motion for Summary Disposition of Rorem QA Subcontention 5.C.Related Info Encl

ML20214C380
Person / Time
Site:	Braidwood
Issue date:	02/13/1986
From:	Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214C321	List: ML20214C317 ML20214C330 ML20214C334 ML20214C358 ML20214C380 ML20214C409 ML20214C439 ML20214C451 ML20214C468 ML20214C496 ML20214C514 ML20214C526 ML20214C552 ML20214C569 ML20214C580 ML20214C583 ML20214C596 ML20214C606 ML20214C628 ML20214C676
References
OL, NUDOCS 8602210117
Download: ML20214C380 (34)

Text

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-456

) 50-457 (Braidwood Station,' Units 1 and 2 )

AFFIDAVIT OF JAMES W. MUFFETT IN SUPPORT OF NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF ROREM QA SUBCONTENTION 5.C I, James W. Muffett, being duly sworn, depose and state as follows:

1. I am employed as a Reactor Inspector (Mechanical Engineer) by the U.S. Nuclear Regulatory Commission (NRC), Region III, 799 Roosevelt Rd, Glen Ellyn, IL 60137. I have been employed by the NRC in this capacity since August 1983. A copy of my Statement of Professional Qualifications is attached hereto as Exhibit 5.C-1 to this affidavit.

2. As a Reactor Inspector, I am primarily responsible for reviewing the design of and performing inspections of mechanical and -

~

structural components.

3. The purpose of this Affidavit is to support the NRC Staff's response to Applicant's Motion For Summary Disposition of Rorem QA Subcontention 5.C. This subcontention states as follows:

5. Contrary to Criterion III, " Design Control,"

of 10 C.F.R. Part 50, , Appendix B, Comonwealth Edison Company has failed to establish measures to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions including provisions to assure that appropriate quality standards are specified in l

8602210117 86021046 PDR G

ADOCK O y

design documents and the deviations from such -

standards are controlled. Applicant has also f, ailed to requirement that measures are established for the identification and control of design interfaces and for the coordination among participating. design organizations, that the measures include the establishment of procedures among participating design organizations for the r,eview, approval, release, distribution, and revision of documents involving design interfaces; and that the design control measures provide for verifying or checking the adequacy of design,-

such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

C. Edison employed designs for safety-related HVAC duct supports based on Chapter E36.0 of S&L's Structural Standard Document which did not limit the slenderness ratio for ceiling mounted duct supports. (Inspection Report No. 85-43/39, Exh. 19.)

4. In preparing this Affidavit I reviewed the following materials:

a. Applicant's Statement of " Material Facts As To Which There Is No Genuine Issue To Be Heard;"

b. Testimony of Kenneth T. Kostal (On Rorem Q. A.

e; Subcontention 5 C)

c. Inspection Report Nos. 50-456/84043 and 50-457/84039;

d. Applicants Response to Inspection Report Nos. 50-456/84043 and 50-457/84039;

e. Inspection Report Nos. 50-456/85040 ar.d 50-457/85040

5. I identified the violation upon which Rorem Subcontention 5.C

, is based. The violation was identified during an inspection conducted by me to address concerns raised by an expert witness during the remanded licensing hearing for the Byron Station. During the inspection I

discovered that Chapter E36.0 of Sargent & Lundy's Structural Standards ,

Document ("SSD") did not contain a limit on slenderness ratio for ceiling mounted HVAC duct supports. Upon further inspection, I determined that all other sections of the SSD contained the necessary guidance on maximum allowable slenderness ratios.

6. In that the appropriate limitation on slenderness ratio for ceiling mounted HVAC duct supports was not included in the design specification for these items, the Applicant was in violation of 10 CFR Part 50, Appendix B, Criterion III. The circumstances surrounding this violation are discussed more fully in Inspection Report Nos. 50-456/85043 and 50-457/84039, the pertinent portions of which are attached as Exhibit 5.C-2 to this Affidavit.

7. In its response to Inspection Report Nos. 50-456/84043 and 50-457/84039, Applicant proposed to take a number of corrective actions.

These actions include (i) reevaluation of existing designs to determine structural adequacy (ii) revision of Chapter E36.0 to incorporate the limit on slenderness ratio (iii) review of its Structural Standard Docu-ment for omission of similar requirements. Exhibit 5.C-4.

( 8. I reviewed and evaluated Applicant's proposed corrective action plan and am satisfied that the plan contained proposed corrective actions l

sufficient to remedy the effects of the violation and render the j possibility of recurrence minimal.

i 9. I verified the implementation of the corrective actions described in Paragraph 7 and on that basis closed this matter in i

Inspection Report Nos. 50-456/85040 and 50-457/85039, the pertinent part of which is attached as Exhibit 5.C-3 to this Affidavit.

i L

10. The violation that forms the basis of Rorem Subcontention 5.C -

represents an isolated incident of failure to incorporate a single design parameter in a design specification. For this reason, this violation does not represent a significant breakdown in Applicant's quality assurance program. Consequently, I agree with Applicant that there is no genuine issue to be litigated regarding Rorem Subcontention 5.C.

e=

"- hy '

James W. Muffett M Sworn and subscribed before me thisi15 day of February,1986

( -

L .

.r

. u _Y.: .

Notary Public ..

My Commission expires:

htlrll $ C-f Professional Qualifications ,

JAMES W. MUFFETT Organization: Region III

Title:

Reactor Inspector (Mechanical)

Birth Date: January 5, 1950 Education: B.S. Physics, Purdue University 1972 M.S. Mechanical Engineering University of Idaho 1978 Reg'istration: Professional Engineer, Illinois, Indiana, Minnesota Experience:

1983 - Present Reactor Inspector - Responsible for inspection of reactor under construction and in operation.

1981 - 1983 Engineering Manager - Managed mechanical design and analysis group with staff of 20 (NuTech).

1980 - 1981 Product Engineer - Responsible for development of advanced design methods. (International Harvester) 1978 - 1980 Senior Engineer - Responsible for development and application of advanced design methods. (Cummins Engine Co., Inc.)

1975 - 1978 Group Leader - Leader of piping analysis group which performed piping analysis for LOFT reactor at Idaho National Engineering Lab. (EG & G Idaho) 1972 - 1975 Stress Analyst - Performed piping stress analysis, support design and field interface duties at various nuclear power stations. (Sargent & Lundy) e 4

f

/s~ UNITED STATES f4W fc-2 g NUCLEAR REGULATORY COMMISSION y a REG 80N lli 79e ROOSEVELT ROAD -

GLEN sLLYN. 8LLINots 00137 March 15, 1985 Docket No. 50-454 Docket No. 50-455 Docket No. 50-456 -

Docket No. 50-457 A Commonwealth Edison Company ATTN: Mr. Cordell Reed -

Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safety inspection conducted by Messrs. J. W. Muffett, K. D. Ward, R. S. Love, J. A. Jacobson, and J. Schapker, of this office on September 24, 1984 through February 4,1985, of activities at Sargent & Lundy Engineers, Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, authorized by NRC Operating License NPF-37, and NRC Construction Permits CPPR-131, CPPR-132, and CPPR-133. The inspection was conducted to review concerns expressed by an expert witness who appeared on behalf of the Inter-venors during the remanded Atomic Safety Licensing Board hearing for the Byron Station operating license.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel. The report also contains your responses to the

, questions asked by this office regarding the concerns.

During this inspection, certain of your activitie~ s appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.

A written response is required.

In addition to the noncompliances, a number of design practices were found to be in need of improvement. During the inspection appropriate corrective actions were taken by your architect engineer to effect the needed improve-ments in the design process. The positive attitude exhibited by you and your architect engineer toward the prompt resolution of all issues and the willingness to implement improvements in the design process are encouraging.

' In accordance with 10 CFR 2.790(.n), a copy of this letter and the enclosures will be placed in the NRC Public Document Room.

l e., - ,v_--- ....n,,.-_.--,,--__,,n

& Cc-2. 1 Commonwealth Edison Company 2

• 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.

Sincerely, 4

y MM-J. F. Streeter, Director Byron Project Division

Enclosures:

1. Appendix, Notice of Violation

2. Inspection Reports No. 50-454/84-71(DRS);

No. 50-455/84-49(DRS);

No. 50-456/84-43(DRS);

No. 50-457/84-39(DRS)

cc w/encis:

D. L. Farrar. Director of Nuclear Licensing V. I. Schlosser Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querio, Station l Superintendent DDB/ Document Control Desk (RIDS)

Resident Inspector, RIII Syron

~

l Resident Inspector, RIII *'

Braidwood Phyllis Dunton, Attorney General's Office, Environmental I

Control Division D. W. Cassel, Jr. , Esq.

Diane Chavez DAARE/ SAFE W. Paton, ELD t L. 01shan, NRR LPM M. Wallace, Project Manager

, 8. Shamblin, Construction Superintendent

! J. F. Gudac, Station i

Superintendent C. W. Schroeder, Licensing and Compliance Superintendent j H. S. Taylor, Quality Assurance Division. S&L I

l

Appendix '

\

, NOTICE OF VIOLATION i

Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2 50-456; 50-457 As a result of the inspection conducted on September 24, 1984 through 1

February 4,1985, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2 Appendix C), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVII requires that records to furnish evidence of activities affecting quality be identifiable and retrievable.

i The Ceco Corporate Quality Assurance Manual and the Ceco Quality Assurance Procedures Manual commit to the above 10 CFR, Appendix B requirements in Section 17. The Ceco Corporate Quality Assurance Manual states, " Quality Assurance records will be stored in a predetermined location as necessary to meet the requirements of applicable standards, codes and regulatory agencies and shall be accessible to Edison."

Contrary to the above, the Sargent & Lundy Engineers calculations which provided the original justification for the 5 factor design methodology and magnitude were not retrievable.

j This is a Severity Level IV violation (Supplement II)

(454/84-71-01(DRS); 455/84-49-01(DRS); 456/84-43-01(DRS);

! 457/84-39-01(DRS)).

2. 10 CFR 50, Appendix 8, Criterion III requires 'that design control measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled."

Ceco Quality Procedure Q.P. No. 3-1 requires that "... design requirements, including regulatory requirements, codes and standards be utilized in the development of specifications, drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to in the FSAR identifies the slenderness ratio (KL/r) for structural steel members as a controlled design parameter for compression members.

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Appendix 2 Contrary to the above, CECO employed designs.for safety-related HVAC duct supports based on Chapter E36.0, " Safety-Related HVAC Duct Supports " of S&L's Structural Standard Document which did not limit the slenderness ratio (KL/r) for ceiling mounted duct supports.

This is a Severity Level V violation (Supplement II)

(454/84-71-02(DRS); 455/84-49-02(DRS); 456/84-43-02(ORS);

457/84-39-02(DR3)).

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 item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

March 15, 1985 -

Dated J. F. Streeter, Director Byron Project Division

CM Furthermore, the AISC Specification for Structural Joints using ASTM A325 or A490 Solts requires that holes be 1/16" in diameter larger than the bolt .

diamete'. r The calculations in question show that for a %" e bolt, a 9/32" s

. hole was provided. This is a 1/32" difference which 13 conservative when compared to AISC recommendations.

i i NRC Review and Conclusion Regarding Concern C.6.c It is , theoretically true that slightly different bearing stresses will be developed when the bolt is not centered in the hole. In this case, the loads and stresses are very small and refining the calculation to account for this o effect will not change the result.

Concern C.6.d 1

. Based on review of Drawing 6E-0-33938, " Category I Conduit Supports - Typical Support and Load Tables," support Type CF & MCF (floor to ceiling), and Type CC & CP maximum load tables, it appears that the KL/r for many of those shown exceeds 200.

i l

Licensee Response to Concern C.6.d The allowable load tables shown on Sargent & Lundy design drawing 6E-0-33938,

" Category I Conduit Supports - Typical Support and Load Tables," are designed l based on AISC Specifications as stated in FSAR Section 3.10.3.2.2 (page 3.10-6) and not on any undocumented information contained in the Unistrut Catalog.

There is no effective length factor "K" to consider since the member types j indicated CC, CP, CF, and MCF are tension members, as demonstrated by the connection details provided on the design drawings.

! According to AISC Commentary Section 1.6, the last paragraph, "The slenderness l limitations recommended for tension members are not essential to the structural

integrity of such members; they merely afford a degree of stiffness such that

undesirable lateral movement (' slapping' or vibration) will be avoided. These i limitations are not mandatory." -

i l The attached sketch shows hanger H056 on drawing 6/20-E-1-3052 which is the cable tray hanger that was alleged to have a KL/r ratio exceeding allowable

! limits.

l l The vertical member has a calculated KL/r value of 192. The internal diagonal has a calculated KL/r value of 208.

Although the internal diagonal has a KL/r value slightly higher than 200, it l 1s a secondary member in the sense that it does not carry gravity loads (i.e.,

l cable or tray weight) and is not required for stability of the hanger. This diagonal only resists lateral loads due to a seismic event. The Ibads are of short duration and are reversible. Therefore, the local buckling 'due to this short term transient will not effect the overall behavior or structural i

integrity of the support.

76 i

i

The allowable axial stresses for this hanger were calculated using Equation 1.5-2 from the AISC Specifications, which states: -

F, , 12*2 E 2 23(KL/r)

Iha actual KL/r ratios for the hanger were used in this equation, and the allowable stresses were reduced accordingly.

In addition, this hanger is top supported and is a tension type system.

Therefore, this hanger will not locally buckle. However, if local buckling should occur in this type of system, the diagonal would be restored to its original configuration due to the vertical gravity load and the reversible longitudinal loads.

NRC Review and Conclusion Recarding Cnneern C.6.d The members mentioned in this concern all have the potential to be placed in compression by a seismic event. The diagonal braces and "out-of plane" braces will only be loaded during a seismic event. The AISC Manual to which the licensee committed in the FSAR states that "The slenderness ratio, KL/r, of compression members shall not exceed 200." Thirty-eight hangers having members which will experience compressive load and which have KL/r in excess of 200 have been identified at Byron and 41 at Braidwood. All of these hangers on Byron 1 and some on Byron 2 were repaired prior to fuel loading and the j majority of the repairs were inspected by the Staff. The following Byron 1 repaired hangers were inspected and found to be acceptable:

HVAC Supports l Hanaer Drawing 322 M-1311-5 1108 1313-5 1110 1313-5 2214 1326-4 2233 1326-4 2237 1326-4 218 1310-6 607 1312-2 791 1312-7 3899 1323-10 3901 1323-10 323 1311-5 77

dr C C - 1.-

Cable Tray Hancers Hanaer Drawing 443 E-0-3033 H069 1-3052 H103 1-3052 .

-- H063 1-3052 H056 1-3052 H090 1-3052 H118 1-3052 70H1 0-3031 H004 1-3053 H8 1-3251 H9 1-3254 H10 1-3251 HS 1-3251 H6 1-3251 During a February 5,1985 meeting between the licensee, Sargent & Lundy Engineers, NRR, and Region III, all parties agreed that the KL/r limitation in the AISC Manual does not affect the stability or strength of the ceiling mounted members which experience compressive loads only during a seismic event.

However, failure to reflect the KL/r ratio limit of the AISC Manual in the documents governing design in this area is a violation of 10 CFR Part 50, Appendix B, Criterion III, which requires the appropriate quality standards and code provisions to be specified in design standards (454/84-71-02(DRS);

455/84-49-02(DRS); 456/84-43-02(ORS); 457/84-39-02(DRS)).

The licensee agreed to submit a change of the FSAR to NRR which will indicate the licensee's exception to the AISC KL/r limitation. The licensee will not pursue modifying the hangers on Byron 2 and Braidwood 1 and 2 having KL/r ratios greater than 200.

Concern C.6.e Based on review of Drawing 6E-0-3393E, the load table for steel conduit seems

.to disagree with the table in the Unistrut Catalog, Page 113.

Licensee Response to Concern C.6.e See Response B.2.aa.

NRC Review and Conclusion Regardino Concern C.6.e See NRC Review and Conclusion Regarding Concern 8.2.aa.

• Concern C.7 An NRC letter dated September 30, 1983, to Commonwealth Edison Company con-cerning Integrated Design Inspection 50-454/83-32 has a calculation which is difficult to follow on Pages 4-11 in the last two paragraphs.

l 78

8/vif f.c- 3 NOV 221985 ,

Docket No. 50-456 Docket No. 50-457 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted by Messrs. J. Jacobson and J. Muffett of this office on August 19, 22, September 17-19, and i October 3-4, 16-18, 24, 1985, of activities at Braidwood Station, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-132 and No. CPPR-133 and to the discussion of our findings with Mr. C. Schroeder and others at the i

conclusion of the inspection.

, The enclosed copy of our inspection report identifies areas examined during

. the inspection. Within these areas, the inspection consisted of a selective j examination of procedures and representative records, obssrvations, and interviews with personnel, i.

No violations of NRC requirements were identified during the course of this inspection.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.

We will gladly discuss any questions you have concerning.this inspection..

Sincerely,

~

j ce;,:.1t;;:dbh'JIJ.;hrt::n J. J. Harrison, Chief Engineering Branch

Enclosure:

Inspection Report No. 50-456/85040(DRS);

, No. 50-457/85039(DRS)

See Attached Distribution i

'i i

[K [ C- 3 Commonwealth Edison Company 2 NOV 2 21985 Distribution cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing M. Wallace', Project Manager D. Shamblin, Construction Superintendent J. F. Gudac, Plant Manager C. W. Schroeder, Licensing and Compliance Superintendent DCS/RSS (RIDS)

Licensing Fee Management Branch

'l Resident Inspector, RIII '

Braidwood Resident Inspector, RIII Byron Ph/111s Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr. , Esq.

J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division E. Chan, ELD J. Stevens, NRR The Honorable Herbert Grossman, ASLB The Honorable A. Dixon Callihan, ASLB The Honorable Richard F. Cole, ASLB i

1

_. . .-.= _ _ _ _ _ . - _ _ . _

6c C, C- 3 .

4 i-U.S. NUCLEAR REGULATORY COPWISSION REGION III

^

Reports No. 50-456/85040(DRS);50-457/85039(DRS) i Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: ' Commonwealth Edison Company i Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 '

Inspection At: Braidwood Site, Braidwood, IL e Inspection Conducted: August 19, 22, September 17-19, and October 3-4, 16-18, 24, 1985 W:

Inspectors M . Jacobson W

it s a//4-J Date d%E

a. nuffett ola./s,,

Date

& *0l::-

Approved By: D. H. Danielson, Chief l'/&1//f~

. Materials and Processes Section Date i

Inspection Summary Inspection on August 19. 22. September 17-19, and October 3-4. 16-18, 24. 1985 (Reports No. 50-456/85040(DRS): 50-457/85039tDRS)?

j Areas Inspected: Announced safety inspection of icensee actions concerning previous inspection findings and one 50.55(e) ites. The inspection involved a total of 122 inspector-hours by two NRC inspectors.

Resu1*s: No violations or deviations were found.

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b f.C-3 DETAILS

1. Persons Contacted Commonwealth Edison (Ceco)

M. Wall' ace, Project Manager

• C. Schroeder, Project Licensing and Compliance Superintendent

, *D. Shamblin, Project Construction Superintendent P. Barnes, Project Licensing W. Vahle, Project Field Engineering Manager J. Dierbeck, Project Field Engineer

• E. Fitzpatrick, Assistant Manager of Quality Assurance l The inspectors also contacted and interviewed other licensee and

. contractor employees.

• Denotes those attending the final exit interview at the Braidwood Station on October 24, 1985.

, 2. Licensee Action on Previous Inspection Findings

a. (Closed) Open Item (456/84-36-04): Improperly qualified welding procedure for L. K. Comstock (electrical contractor) welding of galvanized material. To preclude the possibility of any questionable work arising from a failure to remove the galvanize coating before welding, the licensee instructed L. K. Comstock to qualify a procedure for welding with the galvanized coating in place.

The NRC inspector reviewed the Procedure Qualification Test Records No. LKCE-PQR-084, 085, 086, and 087. These tests were conducted in the flat, horizontal, vertical and overhead positions with the galvanize coating in place. Performance of these qualification tests are considered a technically acceptable method of closing this item.

b. (Closed) Open Item (456/840'21-04; 457/8'4020-04): Questionable certification of a L. K. Comstock (electrical contractor) welder.

l A review of the qualification tests performed by Welder No.11 was i

conducted with results as follows:

Welder No.11 originally qualified for carbon steel welding on July 28, 1978.

l Welder No.11 left the jobsite and returned on April 16, 1981.

At this time he was retested and again qualified for carbon steel welding.

l

, Welder No. 11 was tested for stainless steel welding on May 18, l and May 20, 1981, failing both tests.

Welder No. 11 was given additional training and retested l successfully for stainless steel on May 21, 1981.

i 6

l 2

f f

i Welder No. 11 again left the jobsite and returned on May 23, 4

1983. He was retested on this date and failed to requalify. .

Based on the above review, Welder No.11 was properly qualified during the periods in which he performed safety related welding for L. K. Comstock

c. (Closed) Violation (456/84021-01; 457/84020-01): Safety-related structural steel fillet welds were visually examined for acceptance 1 in the painted condition. A 1005 review of the Napolean (structural j

contractor) Visual Weld Reports was conducted by Pittsburg Testing

! Laboratory (PTL). Visual Weld Report Nos. 709, 711, 713, 716, and i 717 encompassing 122 welds were identified as being performed through paint. These inspections were performed by a single inspector during a nine day period in~1980. These inspections were performed through  !

paint at the direction of Ceco Site Quality Assurance and are deemed  !

to be an isolated occurrence. All paint was removed and the welds were reinspected to correct this deficiency. To prevent recurrence, PTL was directed to perform first line weld inspection only in the

{ unpainted condition. The NRC inspector reviewed PTL Nonconformance j Report No. 191, Revision 1 documenting the resolution of this item ,

and found it acceptable.

d. (Closed) Violation (456/83009-10(c); 457/83009-10(c)): Pullman Sheet Metal (PSM) Procedure B10.2.F, " Visual Weld Inspection", did j not require a documented inspection of base metal surfaces and edges 4 prior to welding. Section 3 of the AWS D1.1-77 Code, entitled l " Workmanship," states in part that surfaces and edges to be welded shall be smooth, uniform, and free from discontinuities which would l adversely affect weld quality.

i PSM procedures require inspection of shop fabricated items at the

time of shipping and inspection of materials for field fabricated i items at the time of receipt at the Braidwood site. Jobsite

{ fabricated items are saw cut, which virtually eliminates the.

i likelihood of irregular edges. In addition, the PSM welding j procedures require jnspection of the welding surface by the welder i before welding is commenced.

l To further demonstrate weld quality, the licensee performed a weld sample test program. The sample program consisted of tensile tests on 82 welded joint samples removed from the HVAC as-welded construction at the Braidwood Station. The results of this test program demonstrated that test failure loads were larger than the design allowable loads by at least 505.

1 i Based on a review of the above information and an inspection of in l excess of 300 HVAC welds performed by the NRC inspector, it was . ,

l concluded that the lack of a documented inspection of base metal surfaces and edges prior to welding had no design significant effect l

on weld quality.

i l 3 l

g6 G- 3

e. (Closed) Violation (456/84043-01;457/84039-01): During an inspection related to allegations concerning Byron /Braidwood design activities,'

it was detemined that Sargent and Lundy did not have retrievable design basis records for the "p" factor dethodology employed in the design of auxiliary steel for pipe supports. This was a violation of 10 CFR 50, Appendix B, Criterion XVII. (See NRC Inspection Report No. 50-454/84-71 fordetails). In response to this violation the design basis for the "p" factor methodology was recreated. All supports designed using the "9" factor methodology were reviewed for ,

compliance with the new "p" factor parameters or specific detailed hsign calculations were perfomed to verify the acceptability of the supports. In addition, the Structural Design Standard for Mechanical Component Support Steel Framing (SDS-E37) was revised. Also, a review of other technical support documentation was performed to assure that the design bases were retrievable. An inspection was perfomed concerning these actions and all were found acceptable.

f. (Closed) Violation (456/84043-02;457/84039-02): During an inspection related to allegations concerning Byron /Braidwood design activities, it was detemined that the AISC (American Institute of Steel Construction) limit for slenderness ratio (KL/R) had not been incorporated into the Structural Design Standard, Chapter E 36.0,

" Safety-Related HVAC Duct Supports " for ceiling mounted duct supports. This was a violation of 10 CFR 50, Appendix 8 Criterion III. (See NRC Inspection Report No. 50-454/84-71 for i details.) In response SDS, E 36.0 was revised to incorporate the limit on slenderness ratio (KL/R) and existing designs were reviewed for compliance with the limit on slenderness ratio. An inspection ,

of the revisions to SDE. E 36.0 and the review of existing designs was perfomed and found acceptable.

g. (Closed) Violation (456/83009-02(8); 457/83009)-02(B)): NRC Inspection Report No. 50-456/83-09; 50-457/83-09 found that the licerisee was not in compliance with the Quality Assurance Manual, '

Revision 77 Q.P. No. 7-1 which is a violation of 10 CFR 50,. Appendix B Criterion V. This violation concerned the lack of receipt inspection of wall thickne',s and diameter of piping. As a corrective j action, the inspection requirement was incorporated into QCP-84, j Revision 4, which was approved for use on January 23, 1984.

j Subsequent to the violation, the licensee inspected piping received l prior to July 28, 1983, for wall thickness violations. To provide i an addition assurance that piping currently in storage had received the dimensional inspection, the NRC inspectors perfonned independent dimensional inspections of piping in storage using a Digital i Thickness Measurement device. The results of this independent l inspection are as follows:

i 1

i l 4

. h S C- 3 No. Min.

i Size Heat No. Type Lengths Measurements Acceptance 2" Sch 80 U71443 SA-106 3 .221, .221, .222, .191

.224, .228, .228,

.226, .220, .223,

.220, .218, .221,

.232, .228 11" Sch 80 187312 SA-106 3 .235, .226 222, .175

.224, .209, .206,

.210, .218, .206,

.199, .200, .186,

.184, .187 li" Sch 80 204272 SA-106 4 .224, .230, .206 .175

.206 208, .198,

.200, .206, .207,

. .218 3/4" Sch 80 169031 SA-106 3 .156, .156, .155, .135

.151, .148, .152,

.167, .160 159 2" Sch 160 74001 SA-106 3 .350, .350, .348, .300

.335, .335, .337,

.349, .348, .348 5

[f .5 C - 3 No. Min.

Size Heat No. Type Lengths Measurements Acceptance 1" Sch 80 204891 SA-106 3 .195, .190, .186, .157

.209, .212, .209,

.208, .210, .214 2" Sch 80 18497 SA-106 1 .244, .250, .242, .191

.229, .240, .236 11" Sch 80 B16497 SA-312TP304 3 .206, .201, .201, .175

.203, .201, .200,

.209, .202, .200

~

2" Sch 80 462774 SA-312TP304 3 .212, .212, .210, .191

.210, .211, .212,

.210, .212, .213

! 3/4" Sch 80 470382 SA-312TP304 1 .115, .124 .99 11" Sch 80 462800 SA-312TP304 3 .147, .147, .146, .127

.152, .148, .149,

.142, .144, .146 11" Sch 160 463001 SA-312TP304 3 .271, .268, .271, .246

.274, .273, .273,

.270, .268, .264 6

$/ f c.- 3 No. Min.

Size Heat No. ,, Type Lengths Measurements Acceptance 2" Sch 80 24257 SA-312TP304 3 .211, .211, .211, .191

.210, .210. 210,

.220, .220, .220 2" S/160 462843 SA-312TP304 3 .324, .325, .324, .300

.332, .331, .331,

.335, .340, .336 The NRC inspector reviewed QCP-84, Revision 4 and found it acceptable, in addition, all measurtments of wall thickness perfonned by the licensee and the NRC inspectors were acceptable.

h. (Closed) Open Item (456/85019-03; 457/85020-03): During an inspection of BCAP documentation and engineering analysis the inspector discovered a BCAP observation form which stated that a crack had been discovered in a cable tray support weld. Subsequent to the initial observation, the original BCAP inspector changed the observation to a " shrinkage line." A decision was made that the NRC would inspect this weld in a subsequent inspection. (See NRC Inspection Report No. 50-456/85019; 50-457/85020 fordetails).

During this inspection the weld was inspected by the NRC inspectors.

The weld contained no cracks and was acceptable.

1. (Closed)OpenItem(456/84034-02;457/84032-02): This item. concerns a Pullman Sheet Metal inspection procedure pennitting transverse cracks to remain in the weld. Inspection Procedure PSM-WP-307, Addendum A, was prepared by Pullman Sheet Metal (PSM) and subsequently was accepted by S&L on March 3, 1981. This inspection procedure was used by PSM to reinspect a random sample of 200 ducts.

These inspections were used to disposition CECO NCR L-246 which concerned inspection of silicon bronze welt, with respect to overlap and weld profile. Production inspections were not perfonned using this procedure. Current PSM weld inspection procedures do not permit cracks of any orientation.

AWS DI.1 " Structural Welding Code," allows the use of alternate acceptance criteria, provided they are based on engineering evaluation. The acceptance of PSM-WP-307, Addendum A, was based on tensile testing of welds containing transverse cracks, as documented in a letter from PSM dated February 10, 1981. To 7

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[$ S C- 3 supplement the data provided in 1981, S&L reviewed the results of 80 tensile tests performed in 1983. This review has shown that this -

specific type of transverse cracks in silicon bronze welds, used for the HVAC applications in question, has no significant effect on the ability of the welds to perfom their design function. The NRC inspector reviewed the basis for acceptance of this inspection procedure and its limited application and found it acceptable.

3. Licensee Action on 50.55(e) Items (Closed)50.55(e) Item (456/83004-EE;457/83004-EE)

This item concerns the use of Jam nuts in sliding structural connections. The inspector reviewed a sample of the design analyses of the sliding connections for the Byron and Braidwood containment i buildings. In addition, selected exa;nples of sliding connections utilizing jam nuts were inspected. Both the design analyses and the

• installations inspected were acceptable.

4. Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1),

on October 24, 1985, and sumarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector. The licensee did not identify any such documents or processes as proprietary, e

8

Commonwo. 6h Edison C- One Forst Peat.onal Plaza. Chcago. latences ./ Q OO Address Fleply to. Post Ottece Box 767 Checago, liimois 60690 April 15, 1985 Mr. James G. Keppler Regional Administrator ,

U.S. Nuclear Regulatory Comission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station thits 1 and 2 Braidwood Station Units 1 and 2 IE Inspection r 50-454/84-71; 50-455/84-49; 56/84-4 50-457/84-39 Reference (a): March 15, 1985 letter from J. F. Streeter to Cordell Reed.

Dear Mr. Keppler:

Reference (a) provided the results of inspections by Messrs.

Muffett, Ward, Love, Jacobson, and Schapker at Sargent & Lundy Engineers and Byron and Braidwood Stations from September 24, 1984 to February 4, 1985.

During these inspections, certain activities were found to be not in compliance with NRC requirements. Attachment A to this letter contains Commonwealth Edison Company's response to the Notice of Violation which was appended to reference (a).

Please direct any questions regarding this matter to this office.

Very y yours, l ,- _ _ _ _

D. L. Farrar Director of Nuclear Licensing im cc: Byron Resident Inspector Braidwood Resident Inspector Attachment EPR16885 .

h S C'Y ATTAC M NT A - -

RESPONSE TO NOTICE OF VIQ.ATION VIOLATION 1 10 CFR 50, Appendix B, Criterion XVII requires that records to furnish evidence of activities affecting quality be identifiable and retrievable.

The CECO Corporate Quality As'surance Manual and the Ceco Quality Assurance Procedures Manual commit to the above 10 CFR, Appendix B require-ments in Section 17. The CECO Corporate Quality Assurance Mancal states,

" Quality Assurance records will be stored in a predetermined location as necessary to meet the requirements of applicable standards, codes and regulatory agencies and shall be accessible to Edison."

Contrary to the above, the Sargent & Lundy Engineers calculations which provided the original justification for the g factor desip methodology and napitude were not retrievable.

CORRECTIVE ACTION TAKEN APO RESLA.TS ACHIEVED Additional calculations, in addition to the 1982 supplementary calculations, were performed to justify the g factor methodology. As a result of the additional calculations, revised g factor parameters were developed.

Support desirs where the g factor was used were identified and reviewed. In those cases where the support desi p using the g factor methodology was not bounded by the revised g factor parameters, detailed individual calculations were performed which showed that the support desips were within code i allowable stresses.

_ CORRECTIVE ACTIONS TO AVOID FURTER NONCOPPLIANCE Structural Design Standard for Mechanical Component Support Steel Framing (SDS-E37) is the document used by Sargent & Lundy (S&L) to govern their desip of mechanical component supports. S&L issued a notification of revision (NORDS-32) to SDS-E37 on December 26, 1984. NORDS-32 incorporates revised bounding parameters for g factor methodology to be used in conjunction with the simplified analysis procedure in Section 37.6.3 of SDS-E37. NORDS-32 was distributed to each engineer in S&L's Structural Engineering Division.

PG DS-32 was discussed in Structural Department and Structural Engineering Division meetings which are held for dissemination of information such as this. In addition, the technical support @==ntation for SDS-E37 will be microfilmed to ensure retrievability.

. [f SC */

c ,

The cther Structural Engineering Design Standards are being reviewed to assure that adequate technical support documentation is available, that the

@ =antation meets QA requirements, that it has been microfilmed and will therefore be retrievable.

DATE WHEN FlLL COWLIAPCE WILL EE ACHIEVED NCRDS-32 was issued on Decenber 26, 1984. The review of Byron and Braidwood to assure that support designs using the g factor methodology either met the revised g factor bounds or have detailed individual calculations in place was coupleted on February 13, 1985. The technical support @ =antation for SDS-E37 will be microfilmed by June 30, 1985. The technical support documentation for the other Structural Engineering Design Standards will be reviewed, microfilmed and made fully retrievable by June 30, 1985.

i l

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9973N

l Y- bf. [ C - 1l VIOLATION 2 I

10 CFR 50, Appendix B, Criterion III requires that design control measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

CECO Quality Procedure QP No. 3-1 requires that "... design require-ments, including regulatory requirements, codes and standards be utilized in the development of specifications, drawings, procedures, and instructions."

The AISC Steel Construction Manual (Section 1.8) committed to in the t

FSAR identifies the slenderness ratio (KL/r) for structural steel menbers as a controlled design parameter for conpression menbers.

l Contrary to the above, CECO employed designs for safety-related HVM qy S&L's Structural Standard Document which did not limit tne slenderness (KL/r) for ceiling mounted duct supports.

CORRECTIVE ACTION TAKEN AND RESILTS ACHIEVED A notification of revision (NORDS-28 dated October 31, 1984) was issued to SDS-E36, the Structural Steel Standard for Safety-Related Duct Supports.

NORDS-28 limits the slenderness ratio for ceiling mounted duct supports. Safety-related duct support desi ps were reviewed and it was determined that the slenderness ratios met the limits stated in NORCS-28.

CORRECTIVE ACTION TAXEN TO AVOID FURTER NOPC0bPLIAPCE NORD S28 was distributed to each engineer in S&L's Structural Engineering Division and was discussed at Structural Department and Structural Engineering Division Meetings. The other Structural Design Standards that govern the design of safety-related supports for other components such as cable trays, conduits, and piping have been reviewed and it was determined that these documents contained appropriate limits for slende: ness ratios.

DATE WEN Fli.L CORIAPCE WILL BE ACHIEVED The corrective action has been completed. NORDS-28 was issued on October 31, 1984. The review of Byron and Braidwood safety-related HVAC duct support desips to assure that slenderness ratios met t:w limits stated in NDRDS-28 was completed on January 31, 1985. The review of the other Structural Design Standards for safety-related supports to verify they contained appropriate slenderness ratio limits was completed by October 31, 1984.

9973N

f S*$ d@ -Y 5 Commonwealth EGeon [f g c - y one First National Plats. Chicago. Ilhnoes

> ' Address Reply to. Post Othce Box 767 Chicago, Mhnois 60690 April 22, 1985

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K:.igfy.;q g.g;g: .;. . :<:g: ..W ,

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Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region.III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Generating Station Units 1 and 2 Braidwood Generating Station Units 1 and 2 Design Concerns I&E Inspection Report Nos. 50-454/84-71, 50-455/84-49, 50-456/84-43 and 50-457/84-39 References (a): October 22, 1984 letter from L. O. DelGeorge .

to J. G. Keppler.

(b): Deceeer 11, 1984 letter from T. R. Tram to J. G. Keppler.

1 (c): March 15, 1985 letter from J. F. Streeter l

to Cordell Reed.

t

Dear Mr. Keppler:

This' letter provides for the record corrected pages for two letters which were previously supplied by Comonwealth Edison to the NRC. This information relates to the tac's investigation of design concerns expressed by an Intervenor's expert witness which was documented in reference (a).

These revisions are submitted to fulfill commitments made during the PRC investigation. They contain no new information.

On Thursday, January 31, 1985, Mr. T. G. Longlais of Sargent &

Lundy, met with Mr. J. Muffett of tac Region III to discuss the support mee er that was reported to have a slenderness ratio (Kl/r) over 300. Mr.

Longlais stated that based upon further review of hanger nurter S-2214 cn drawing M-1326-4, the revised Kl/r value is 291. This revision was due to the selection of an original K value of 2.0, which ignored the presence of a brace. The brace provides lateral support and a 1.2 value for K is more apprcpriate. Page 15 of reference (a) has been appropriately revised. It is enclosed and is labeled " Table 1".

APR2: 1985

. $1 SC~Y J. G. Keppler I

' April 22, 1985*

Also enclosed are revised pages 15 and 16 of the attachment to reference (b). Typographical errors have been corrected.

Please direct further questions regarding these matters to this Very truly yours, .

K '[, hjw- - -

T. R. Tramm Nuclear Licensing Administrator 1m Attachnurit e

9997N 1

1 I

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' TABLE 1 s .

BYRON - UNIT 1

\

!b HVAC MEMBER SLENDERNESS RATIO SURVEY .

TENSION SYSTEM (CEILING MOUNTED)

Drawing Member K1-Serial Floor Number Hanger

• Type r Number Elev. M- Number 1 2 3 4

• f, F, f, .

(ksi) (ksi) Fa Al 364-0

• 1311-5 S-322 X 237 1.33 4.27 0.31 A2

. X 237 1.33 4.27 0.31 A3 401-0 1313-3 S-1210 X 2$2 1.12 5.33 0.25 A4 .

X 212 1.12 5.33 0.21 A5 401-0 1313'3 S-1211 X 219 0.20 4.97 0.04 A6 .

X 219 , 0.20 4.97 0.04 A7 401-0 1313-5 S-1104 X 285 0.47 2.96 0.16 A8 .

X 285 0.47 2.96 0.16 A9 401-0 1313-5 S-1108 X 219 1.75 4.98 0.35 A10 X 219 1.75 4.98 0.35

. All 401-0 1313-5 S-1110 X 245 0.29 3.98 0.07 A12 X 245 0.29 3.98 0.07 .

A13 463-5 1326-4 S-2214 X 291 0.36 1.76 0.20 A14 X 291 0.36 1.76 0.20 NOTE: Pa is based on 1.6 x AISC equation 1.5-2

• All of these hangers are located in the Auxiliary Buidling.

'S.

& [ C - '+ '

r

e. Load Direction

,The most critical applied piping load is a load cr a', ting torsion on a member. The 5 factor does' not account for this

~

effec.t and thuh, separate hand calculations must be performed t to account for this effect. -

1 An applied vertical piping load on a member produces no tor-sion and thus, a load from any tolerance creating. torsion -

changes a torsional stress from On to some finite number i

which theoretically is an infinite percentage increase; whereas, i

a load from any tolerance causing torsion on a member already designed for an applied piping load that produces torsion i

will have a substantially lower percentage increase than

, one with a vertically applied loading producing no torsion.

All (factor calculations were performed with the most conser-

-vative direction of the applied piping load - the direction i

vertical to the member. In an actual calculation where the actual applied piping load is at an angle' to the member, the components of this loading are considered in a manually performed detailed analysis.

1 .

f. Load magnitude various magnitudes of loadings were selected to assure I R D

15.

5 o

. M S c-Y

= 1.0 or as close as possible This has the same effect R

as ensuring that various loading magnitudes were considered.

Tables 15.1 and 15.2 summarizes the calculations,p*erformed, ,

andadetaileddiscussionontheresultsobtainedhollows.

e.

, e e

e 0

e e

e 9

9 9

O M

0 98 e O

e e

16.

SEBCONTENTION 6.F ,

Rorem QA Subcontention 6.F, as admitted :n this proceeding, states as follows:

6. Contrary to Criterion V, " Instruction, Pro-cedure and Drawings," of 10 CFR Part 50, Appendix B, Coninonwealth Edison Company has failed to ensure that activities affecting quality are prescribed by documented instruc-tions, procedures, or drawings, and are accomplished in accordance with these instructions, procedures, or drawings.

, F. In June 1984, Phillips Getschow, piping contractor, found piping that violated minimum wall requirers:nts. This defect was not reported to owner in accordance with 10 CFR 21.21. (Inspection Report 84-21/20, Exhibit 20.)

In its Motion for Sunenary Disposition, Applicant acknowledges that the failure of Phillips Getschow to submit a report to Comonwealth Edison regarding this deficiency pursuant to 10 C.F.R. Part 21 and QAP-110 is a violation of Criterion V of 10 C.F.R. Part 50, Appendix B.

Applicant's Motion 6.F at 6. However, Applicant argues that the deficiency which Phillips Getschow failed to report under QAP-110,was of a limited nature and that the incident has no significant implications for the quality of the Braidwood facility, and concludes that the item of noncocpliance, the failure to report, was an isolated occurrence.

Applicant's Motion 6.F at 7 and 11. Therefore, according to Applicant there is no genuine issue of material fact to be heard with respect to this subcontention. Applicant's Motion, 6.F at 12. The Staff agrees.

The failure of Phillips Getschow to notify the Applicant of a potential 10 C.F.R. Part 21 deficiency, the subject of this

subcontention, was identified by Region III NRC Inspector Robert D. ,

Schulz during a routine unannounced documentation review of the material traceability program. Affidavit of Robert D. Schulz in Support of NRC

• Staff's Response to Applicant's Motion for Sumary Disposit. ion of Rorem QA Subcontention 6.F at 1 5. See also Exhibit 6.F-2. Phillips Getschow Co. Procedure QAP-110 " Reporting of Defects and Noncompliance," requires that such incidents (a minimum wall violation in this case) be reported on Form PG/QA-15-7. Schulz Affidavit 6.F at 11 5 and 6. Failure to report this item of noncompliance precluded notification of the pipe supplier or manufacturer so that delivery of defective pipe to other nuclear sites could be prevented. M.

Subsequent to the issuance of the NRC inspection report (Exhibit 6.F-2) the Applicant took corrective action which included notifying the pipe supplier of the deficiency and reinstructing Phillips

, Getschow piping personnel regarding their reporting responsibilities to _

the Applicant. Schulz Affidavit 6.F at 17. Mr. Schulz verified that under the current procedure, Phillips Getschow performs a documented review of all NCRs for rep 6rtability under 10 C.F.R. Part 21. M.

Mr. Schulz determined that the Applicant's co.rrective actions involving supplier notification and reinstruction were appropriate. Based on this determination he closed the item in NRC Inspection Report Nos. 50-450/85007 and 50-457/85007. See Ex. 6.F-3. The Staff agrees with the Applicant that the incident described in Subcontention 6.F was an isolated incident of failure of one contractor to report a single deficiency pursuant to procedures and does not represent a pervasive breakdown in the Applicant's QA program. None of the information

,- --un ,- , - - , , - --. - - - . - - - - - ,- - . - , - - - - , . - - --- -,

available to the Staff indicates any subsequent failure to comply with ,

10 C.F.R. Part 21 reporting requirements. Intervenor has not provided any information during discovery which supports a contrary view.

Therefore, there are no genuine issues of material fact to be heard regarding this subcontention and Applicant is entitled to a favorable decision on this subcontention as a matter of law. Based on the dis-cussion above, the Staff concludes that Applicant's Motion for Summary Disposition of Subcontention 6.F should be granted.

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