ML20197H382

Ack Receipt of 860124 & 0409 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-455/86-27. NRC Concurs w/7 of 10 Items Cited in 860124 Response.Encl 2 Addresses Remaining Items

ML20197H382
Person / Time
Site:	Byron
Issue date:	05/12/1986
From:	Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8605190157
Download: ML20197H382 (6)

See also: IR 05000455/1986027

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MAY 121986

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Docket No. 50-454"

Commonwealth Edison Company

ATTN: Mr. Cordell Reed

Vice President

Post Office Box 767

Chicago, IL 60690

Gentlemen:

Thank you for your letters dated January 24, and April 9,1986, informing us of

the steps you have taken in response to the results of the NRC Construction

Assessment Team (CAT) inspection forwarded in Inspection Report No. 50-455/85027

by letter dated November 13, 1985 and the Notice of Violation forwarded by our

letter dated December 12, 1985.

Your January 24, 1986 response was forwarded to the Office of Inspection and

Enforcement who lead the CAT inspection. Your response has been reviewed and

we are in agreement on seven of the ten individual items used as examples of

violations. The specific items and our findings are summarized in Enclosure 1.

Our comments concerning the remaining violations are provided in Enclosure 2.

We will examine these matters during subsequent inspections.

Your cooperation with us is appreciated.

-

Sincerely,

"Orighrd cit ed hi 2. F. tia nic M

R. F. Warnick, Chief

Reactor Projects Branch 1

Enclosures: As stated

See Attached Distribution

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Commonwealth Edison 2

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Distribution

cc w/ enclosure:

D. L. Farrar, Director

of Nuclear Licensing

V. I. Schlosser, Project Manager

Gunner Sorensen, Site Project

Superintendent

R. E. Querio, Plant Manager

DCS/RSB (RIDS)

Licensing Fee Management Branch

Resident Inspector, RIII Byron

Resident Inspector, RIII

Braidwood

Phyllis Dunton, Attorney

General's Office, Environmental

Control Division

D. W. Cassel, Jr. , Esq.

Diane Chavez, DAARE/ SAFE

Steve Lewis, ELD

L. Olshan, NRR LPM

H. S. faylor, Quality Assurance

Division

.

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. ENCLOSURE 1

l SUMMARY

a .

1. Agree Disagree

Violation No. With Licensee With Licensee '

la - (Butt splices) X*

3

lb - (Structural steel bolted X

'

connections)

.

Ic - (CEA) X

2 - (W radiographs) X

i

1 -_(Tanks / heat exchangers) X

- (Vendor radiographs) X*

1

] - (Component fasteners) X

3a - (Electrical mounting X

deficicacies)

3b - (Electrical separation) X

.

3c - (MOV wiring) X

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Total

7 3

! *Not an example of a violation

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4

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ENCLOSURE 2

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VIOLATION Ic

As stated in the NRC CAT inspection report, the CEA qualification report and

site inspection procedures specify an embedded depth (Le) to be measured from

the concrete surface to the bottom of the expansion ring. However, in the

installed condition Le cannot be physically measured or derived indirectly.

! Only if it is assumed that the expansion ring remains stationary as the back

! of the anchor does not move all the way to the ring or the expansion ring also

moves towards the concrete surface as the bolt is tightened and the anchor is

measured (below the concrete surface) to be a distance of exactly the minimum

embedded depth, the actual Le (measured to the expansion ring) would be less

than the minimum embedded depth specified by the qualification report.

i Tables 1 and 2 summarize some instances in which it appears that anchor bolts

1 may not meet the embedded depth specified by the qualification report. Tables 1

.l and 2 reflect a (minus) 1/16 inch installation tolerance and physical measure-

4

ments of expansion anchor bolts made by the NRC CAT. The maximum deviation from

i the specified embedded depth (including installation tolerances) is 11/16 inch.

We still consider that the anchor bolt qualification requirements have not been

adequately translated into appropriate installation and inspection procedures.

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Table 1*

Maximum

Maximum Calculated Difference

CEA CEA Between

Projections Length Wedge and

Hanger CEA UT CEA Above Below Bottom Minimum

No. Diameter Length Concrete Concrete of CEA Installed Le

Traveler 8601 1/4 3 1/4 2 1/4 1 3/8 5/8

WS-2 3/8 5 1 7/8 3 1/8 1/2 2 5/8

WS-35 3/8 5 1 5/8 3 3/8 1/2 2 7/8

WS-50 3/8 5 2 1/4 2 3/4 1/2 2 1/4

2CV130345 3/4 10 3 9/16 6 7/16 3/4 5 11/16

2FW93E010X 5/8 8 1/2 3 1/2 5 5/8 4 3/8

• All dimensions in inches

TABLE 2*

Adjusted Difference in

Qualifica. Le for 1/16" Minimum Installed and

Hanger CEA Report Installation Installed Le Qual. Report

No. Diameter Le Tolerance From Table 1 Adjusted Le

Traveler 8601 1/4 3/4 11/16 5/8 1/16

WS-2 3/8 3 2 15/16 2 5/8 5/16

WS-35 3/8 3 2 15/16 2 7/8 1/16

,

WS-50 3/8 3 2 15/16 2 1/4 11/16

2CV130345 3/4 6 5 15/16 5 11/16 1/4

2FW93E010X 5/8 5 4 15/16 4 3/8 9/16

• All dimensions in inches

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VIOLATION 2 (Westinghouse Radiographs / Construction Weakness 1)

For the Unit 2 component cooling surge tank it has not been addressed how the

ASME Code requirements are being met without the availability and existence of

the radiographic film. An alternative is to reduce the joint efficiency from

100% to 75% which will then meet the ASME Section III rules. The use and

acceptance of a lower joint efficiency would then have to be evaluated. The

current response cannot be accepted because the ASME Code requirements have

not been met.

VIOLATION 3b

The Supplemental Safety Evaluation Report (SSER) transmitted to CECO in a

memorandum from V. S. Noonan, NRR dated February 25, 1986, the NRC staff's

evaluation of Byron /Braidwood electrical separation criteria. In summary the

staff's conclusions were:

(1) Between safety-related and nonsafety-related raceway, the separation

distances of 12" vertical and 3" horizontal is adequate, and

(2) Between safety-related cables in free-air and nonsafety-related

raceway and for the case of nonsafety related cable in free-air and

safety-related raceway, contact is acceptable.

The NRC approved criteria should be the basis of QC inspection criteria.

However, your response maintains tnat the only raceway separation criteria

necessary is 1" between raceway. The QC criteria remains in conflict with

current FSAR and SSER statements. Installations which do not meet the

separation criteria as defined in the SSER require identification and

evaluation.

We maintain that you had not established and still do not have inspection

procedures which verify conformance to the FSAR/SSER criteria for electrical

raceway separation. This violation remains valid.

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