ML19318A541

Responds to NRC 800425 Ltr Re Violations Noted in IE Insp Repts 50-454/80-05 & 50-455/80-05.Corrective actions:safety- Related Hanger & Snubber Supplier Forwarded Revised Installation Instructions

ML19318A541
Person / Time
Site:	Byron
Issue date:	05/27/1980
From:	Peoples D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19318A540	List: ML19318A541
References
NUDOCS 8006230318
Download: ML19318A541 (10)

Text

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7 'N Commonwealth Edison

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_/ one First National Plaza. Chic +go. Illinois i Address Reply to: Post Office Box 767

/3 (,e/ Chicago Illinois 60690

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May 27, 1980 Mr James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commjssion 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 Response to IE Inspection Report 50-454/80-05 and 50-455/80-05 NRC Docket Nos. 50-454 and 50-455 Reference (a): April 25, 1980, letter to C. Reed from J. G. Keppler.

Dear Mr. Keppler:

Reference (a) contained the results of an inspection conducted by Mr. I. T. Yin of your of fice on March 25-26, 1980, of activities at Byron Station. During this inspection, certain activities appeared to be in noncompliance with NRC requirements.

Commonwealth Edison Company's response to the items of noncompliance are contained in Attachment A to this letter. Note that based on the additional information presented in response to Infraction #6, Commonwealth Edison requests that the basis for this infraction be reconsidered and that such reconsideration result in the infraction being withdrawn.

Please address any additional questions that you might have concerning this matter to this office.

Very truly yours, t

D. L. Peo es Director of Nuclear Licensing attachment 80062303(% 01880 4084A

NRC Docket Nos. 50-454/455 Attachment A INFRACTION #1 10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed in documented instructions, ,

procedures, or drawings ... and shall be accomplished in accordance with these instructions, procedures, or drawings."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 5 that "The quality assurance actions carried out for design, construction, testing, and operation activities will -

be described in documented instructions, procedures, drawings, specifications, or checklists. These documents will assist ',

personnel in assuring that important activities have been performed.

These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out."

Contrary to the above, the procedures established for installing safety related hangers and snubbers did not satisfy the above pro-gram in that manufacturer's installation requirements were not fully incorporated. ,

Corrective Action Taken and Results Achieved:

The safety related hanger and snubber supplier has forwarded its latest installation instructions which are as follows:

(1) ITT-G PHD-7594-1, Rev. 3, 10/12/79; (ii) ITT-G PE-217-1, Rev. O, 5/2/80; and (iii) ITT.G PHD-6511-8, Rev. O, 6/22/78.

The Site Work Instruction for Installation of Hanger Specialty Items has been revised to incorporate the latest instructions from the manufacturer for installation. This has been accomplished through the issuance of Site Work Instruction (SWI) No. 2, Revision 1.

The " Maintenance and Installation Manual ITT-Grinnell Fig. 306 and Fig. 307 Mechanical Shock and Sway Suppressor" ITT-G PHD-7594-1, Rev. 3, 10/12/79 does not contain any requirement for safety wire for the connection of the transition tube to the snubber. According to ITT-Grinnell personnel, this is no longer a requirement due to the use of high strength assembly screws.

Corrective Action Taken to Avoid Further Noncompliance:

Added emphasis will be placed on audits of instructions and procedures performed during 1980 by Commonwealth Edison Company to assure that site work instructions and procedures reflect the latest criteria.

Date When Full Compliance Will be Achieved:

! Full compliance will be achieved by June 2, 1980.

INFRACTION #2 10 CFR 50, Appendix B, Criterion X, states, in part, that "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activities."

Commonwealth Edison Company Topical Report CE-1-A " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 10 that "QA inspection ... will be conducted

... at the site during construction ... to verify conformance to ,

applicable drawings, instructions ... to verify quality". .

Contrary to the above, many installed hangers and snubbers had not s' been QC inspected. The inspection program did not include suf ficient requirements in the areas of verif'1 cation of piping suspension system location, configuration, and condition, and did not require timely inspections to ensure prompt corrective action.

Corrective Action Taken and Results Achieved:

Site Implementation Procedure No. 4.000 has been revised to incorporate more detailed in-process inspections, which are as -

follows:

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(1) Inspection of location of hanger attachment to the building structure; and (ii) Inspection of the completed installation of the assembly for compliance with the design drawing requirements and specific assembly instruction requirements.

Additionally, a Site Implementation Procedure No. 4.201,

" Installation Verification" has been generated which, for the area of component supports, initiates an inspection for hanger condition at time of completion of installation of all hangers in a given subsystem, and a reinspection for hanger condition at time of system inspection for turnover for operation. The inspection of location and inspection of completed installation, items (i) and (ii) above, are performed in-process, which is near term to the time of actual performance of the work.

Corrective Action Taken to Avoid Further Noncompliance:

Surveillance and audits will be conducted to assure that procedures are properly being implemented.

Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by June 2, 1980.

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INFRACTION #3 10 CFR 50, Appendix B, Criterion VI, states, in part, that " Measures shall De established to control the issuance of documents ...

including the changes thereto, which prescribe all activities .

affecting quality. These measures shall assure that documents, including changes, are reviewed ... and approved ... by authorized p??sonnel and are distributed to and used at the location where the pcsscribed activity is performed."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, date<j July 16, -

1979, states in Section 6, that "A document control system will be ,

used to assure that documents such as specifications, procedures, '.

and drawings are reviewed for adequacy and approved for release by authorized personnel. Such documents will be distributed to and used at the locations where the prescribed activity is performed.

Changes to these documents will be handled similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by the originating organization to another responsible organization."

Contrary to the above, the con. tractor used inter-office memorandum to document procedure change and as a result bypassed the established document control procedures.

Corrective Action Taken and Results Achieved:

The use of inter-office memoranda to document procedure changes had been discontinued ef fective 8/27/79 which was prior to the subject inspection. The changes contained in the subject memoranda, HC-QA-23 have been incorporated into the latest revision of the applicable procedures, and the memoranda have been removed from use.

Corrective Action Taken to Avoid Further Noncompliance:

Added emphasis will be placed on audits of instructions and procedures performed during 1980 by Commonwealth Edison Company to assure that site work instructions and procedures are not updated through the use of inter-office memoranda.

Date When Full Compliance Will Be Achieved:

Full compliance will be achieved by June 2, 1980.

INFRACTION #4 10 CFR 50, Appendix B, Criterion III, states, in part, that " measures

, shall be established to assure that applicable ... design basis ...

for those structures, systems, and components ... are correctly ,

. translated into ... drawings ...".

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 3 that "The fundamental vehicle for design control involves multi-level review and/or evaluation of design .

documents by individuals or groups other than the original designer .

or designer's immediate supervisor whose authority and responsibility -

are identified and controlled by written procedures. The design documents include, but are not limited to, system flow diagrams, 8 design and construction specifications, load capacity data sheets, design reports, equipment specifications, process drawings."

Contrary to the above, design details shown on several installation 3

drawings did not meet the manufacturer's design parameters, and questionable adjustment requirements were specified.

5 Corrective Action Taken and Results Achieved:

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Manufacturer's design parameters regarding design pin-to-pin

, dimensions have been revised during the course of the project.

1 Current design is based on the latest pin-to-pin dimensions provided g by the manufacturer.

3 Adjustments are not being specified beyond what is allowed by the 6 manufacturer. The initial issue of a drawing for an ITT Grinnell Figure 306 indicates the required pin-to-pin dimension. Revisions e to the analysis, for example, may require a change in setting within the adjustabla stroke for the snubber. The field would then be instructed by drawing revision to field adjust to the required revised pin-to-pin dimension, as indicated on the drawing. Consider, for example, the two examples of noncompliance delineated in Section 6.a and 6.b of Reference (a) .

a) For snubber M-1CV020055, a revision to the pin-to-pin dimension as indicated on Rev. A was required. Rev. B was issued instructing che field to adjust to the pin-to-pin dimension as indicated on Rev. B. The adjustment is consistent with the adjustment capability of the snubber.

b) For snubber drawings M-lCV01006S and M-1CV030185, the current manufacturer design pin-to-pin dimension is exceeded. The drawings were reviewed by ITT Grinnell and it was determined that the design was acceptable based on the actual design load for the snubbers.

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4 Corrective Action Taken to Avoid Further tJoncompliance:

A procedure is being finalized that will establish a review of all snubber drawings previously issued to insure that the current manufacturer's design requirements are met for all snubbers. The .

procedure will include. provisions for design reviews by the manufacturer (ITT Grinnell) to determine if specific deviations from stated pin-to-pin dimensions are acceptable.

Date When Full Compliance Will Be Achieved:

The review of snubber drawings will be completed by June 30, 1980. -

If necessary, adjustments will follow in a timely manner. ,

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4 INFRfCTION #5, 10 CFR 50, Appendix B, Criterion XII, . states', la part, that " Measures shall be established to control the .. . preservation of material and equipment in accordance with work and inspection instructions to -

prevent damage or deterioration".

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 13 that " Written instructions for handling, preservation, storage and shipping will be used to specify special

• protective conditions necessary to prevent damage or deterioration ,

, of materials and equipment". e Contrary to the above, several installed mechanical snubbers had not been properly protected and as a result hardware was damaged.

Corrective Action Taken and Results Achieved:

Effective March 26, 1980, the installation of safety related mechanical and hydraulic snubbers ceased, and removal of those mechanical ar,1 hydraulic snubbers that had been installed was

initiated. Ir.3tallation of mechanical and hydrmJ11c snubbers will j not be reinitiated until the building construction environment is

such that the exposure to damage is minimal, or until protection can a

be provided and maintained for installed snubbers.

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Corrective Action Taken to Avoid Further Noncompliance

No further action than that stated above is regelred to avoid further noncompliance.

I Date When Full Compliance Will Be Achieved:

j Jull compliance will be achieved by June 2, 1980.

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INFRACTION #6 10 CFR 50, Appendix B, Criterion XVIII, states, in part, that "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance ,

program and to de'. ermine the ef fectiveness of the program."

Commonwealth Edison Company Topical Report CE-1-A, " Quality Assurance Program for Nuclear Generating Stations", Revision 9, dated July 16, 1979, states in Section 18, that " Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors .

and vendors to verify the implementation and effectiveness of quality .

programs under their cognizance." ,

U Contrary v.o'the above, the licensee had not performed comprehensive audits on the site hanger contractor ta ensure program adequacy for the installation and inspection of the pipe suspension systems.

Commonwealth Edison Company Response:

i The Commonwealth Edison Company Quality Assurance Department implements a comprehensive system of scheduled audits which are conducted on a regular basis to verify compliance with all aspects of its Quality Assurance Program. In addition to verifying compliance to the Commonwealth Edison Quality Assurance Program, the audit system also includes a comprehensive coverage of Edison's contractors, vendors, suppliers, Architect Engineers and NSSS l vendors.

In regard to specific audits of the site hanger contractor to ensure program adequacy for the installation and inspection of the pipe suspension system, the Commonwealth Edison General Office Quality Assurance Department conducted an extensive audit of the adequacy of the installation of ASME Section III piping and hangers in mid 1978.

Specifically, on August 18, 21, and 22, 1978, an audit was conducted at Byron to check the correctness of the installation of ASME Section III piping and hangers for the Component Cooling (CC),

l Chemical and Volume Control (CV), and Essential Service Water (SX) systems. Dimensions were checked for forty-one pipe spools and all measurements were referenced back to the surveyors marks. The audit team concluded that the components, in the systems audited, were installed according to the approved drawings. Comparable audits were also conducted at the Breldwood and LaSalle Construction Sites.

During the period February 21 through February 27, 1979, a six man audit team from the General Of fice Quality Assurance Department ,

conducted an extensive audit of Sargent & Lundy primarily to examine I the ef fectiveness of design control and design review in connection I

with pipe supports for the Byron, Braidwood, and LaSalle Stations.

The audit team identified several deficiencies. For the Byron /Braidwood projects, it was found that calculations for the auxiliary steel for certain pipe supports were not documented and i

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that pipe support design documents issued prior to November, 1978, were not received, reviewed or processed by the Sargent & Lundy Structural Group. Both of the items resulted in extensive corrective action by Sargent & Lundy.

On May 22, 23, and 24, 1979, a seven man General Of fice Audit Team, accompanied by a consultant, Mr. R. N. Ferguson of the Energy, Inc.

who also did independent auditing, conducted an audit of the Byron Site. One of the major activities examined was the effectiveness of the Quality Control Inspection programs of the site contractors.

The team found that Hunter, the site piping and hanger contractor, .

was not performing Q.C. Inspections of piping supports other than .

the associated welding. There was evidence that Hunter Q.C. was ,

performing surveillances of hanger installations but the scope of the surveillances was limited. This deficient condition was cited 8 in the audit report.

On September 5, 6, and 7, 1979, a seven man General Office Audit Team conducted an audit of the Byron Site. One of the areas examined was to determine if the site contractors were performing in-process and final inspections for key work activities. The review of Hunter, the site piping and hanger contractor, showed that an extensive inspection program was established and implemented for key work activities. Records were examined which showed documented evidence of contractor Q.C. inspections in: welding, bolt torqueing, NDE, hydrostatic tests, pneumatic tests and pipe supports.

On September 15, 1979, Byron Site Q.A. conducted an audit of Hunter, and verified many items including (1) identification marks on components to assure proper piecas are installed, (2) surveillances and audits by Hunter to assure proper procedures are being followed for hanger installation work, and (3) the acceptability of hanger welds and final sign-off by Hunter Q.C. Inspectors.

On February 27, 28, and 29, 1980, and March 3, 1980, a five man General Ofice Audit Team conducted a follow-up audit of Sargent &

Lundy. During the audit, a check was made to evaluate the progress of documentating calculations for Byron /Braidwood pipe support auxiliary steel. The auditor found that approximately 5,600 of 8,400 safety-related supports had been reviewed for proper calculations and corrective action was proceeding adequately.

On March 19, 1980, Byron Site Q.A. conducted an audit of Hunter to evaluate the design and installation of small bore piping. The major emphasis was placed on organization, training, hanger drawing control and hanger field problems. Six deficiencies were identified including failure to properly protect snubbers in storage or those which were partially installed, as-built hanger drawings did not correctly reflect field conditions, Hunter surveillances did not identify rusty threads on hangers and weld inspections were not being done on a timely basis.

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In addition, during the period 4/19/79 to 3/6/80, Site Quality Assurance Engineers conducted 10 documented surveillances specifically covering hanger installation by Hunter Corporation.

For the most part, no significant problems were identified. During the total period that Hunter has been working at Byron, Site Q. A.

performed about 170 other surveillances envering all aspects of Hunter's work activity. Many of these surveillances involved activities related to the installation of pipe supports. Also, Site Q. A. has performed a total of 15 audits of Hunter as of March 6, 1980.

Commonwealth Edison is committed to a comprehensive system of audits .

to ensure adequate implementation of quality procedures, programs, .

and requirements. '

The audits and surveillances described above are part of Edison's program to fulfill this commitment. It appears r that during the inspection conducted by the NRC, the above listing of Edison involvement in auditing of hanger l'nstallation at Byron was not available in the chronological listing as detailed above.

Commonwealth Edison has implemented a comprehensive system of audits of all contractors and has performed comprehensive and meaningful audits of the piping and piping supports at Byron. Accordingly, it is requested that the basis for this infraction De reconsidered and that such reconsideration result in the infraction being withdrawn.

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