ML20127K338

Responds to Violations Noted in Insp Repts 50-454/84-71, 50-455/84-49,50-456/84-43 & 50-457/84-39.Corrective Actions: Technical Support Documentation for SDS-E37 Will Be Microfilmed to Ensure Retrievability

ML20127K338
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	04/15/1985
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
9973N, NUDOCS 8505220096
Download: ML20127K338 (4)

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.( '7 Address R; ply 12: Post Offica Box 767

%( / Chicago. Illinois 60690 April 15, 1985 Mr. James G. Keppler Regional ~ Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL' 60137

Subject:

Byron Station Units 1.and 2 Braidwood Station Units 1 and 2

.IE' Inspection' Report Nos.'50-454/84-71; 50-455/84-49; 50-456/84-43; 50-457/84-39 Reference (a): March 15, 1985 letter from J. F. Streete'r 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 uly yours,

_ _ ,_ _ _ -w-D. L. Farrar Director of Nuclear Licensing 1m cc

Byron Resident Inspector Braidwood. Resident Inspector Attachment ~

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. , . ATTACl+ENT A

~q IRESPONSE TO NOTICE OF VIOLATION

> VIOLATION 1 _

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f 10 CFR-50,; Appendix B, Criterion XVIILrequires that records,to

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_ furnish evidence of activities affecting quality.be' identifiable and

= nretrievable.,

The CECO Corporate Qualit'y Assurance Manual and the CECO Quality; i Assurance Procedures Manual- commit to. the above 10 CFR; Appendix B require-

? .ments inLSection'17. The CECO Corporate Quality Assurance. Manual states,.

" Quality.- Assurance records will be ~ stored in a' predetermined location as :

.c jnecessary 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-af -which provided the original Justification for the g factor design = methodology r_ 'and maritude were not retrievable.

' CORRECTIVE ACTION TAKEN-AND RESULTS ACHIEVED ,

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JAdditional calculations, in addition to the 1982 supplementary. .

calculations,:were performed to justify the g factor methodology. .Asta result, (oftheadditionalcalculations,revisedg.factorparametersweredeveloped.

Support desips where the_ g factor' was used were identified and. reviewed.- In' ithose cases where the. support design using the g factor methodology'was not

' bounded by the revised g factor parameters, detailed individual.' calculations

'. ;were performed which showed that the support designs were within code.

fm allowable stresses.

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. CORRECTIVE ACTIONS TO AVOID FURTER NONCOWLIANCE Structural Design Standard for Mechanical Component Support Steel.

' Framing ~(SDS-E37)!is the document us?d by Sargent & Lundy (S&L) to govern Jtheir design of mechanical component.2upports. S&L issued a notification of l revision-(NORDS-32) to SOS-E37 on Decrinber 26, 1984. ~. NORDS-32 incorporates M -

irevised. bounding' parameters for g fa: tor' methodology to be used-in conjunction fwith the simplified analysis procedure in Section 37.6.3 of SDS-E37.- NORDS-32 I 'was distributed;to each engineer in S&L's Structural Engineering Division.

NORDS-32 was discussed in-Structural-Department and Structural Engineering

Division meetings which are held for dissemination of information such as

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this. In _ addition, the. technical support documentation for-SDS-E37 will be microfilmed to ensure retrievability.

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-The other' Structural Engineering Design Standards are being reviewed

, to assure _that adequate technical support. documentation is available, that the documentation meets QA requirements, that it has been microfilmed and will

therefore be retrievable..

c DATE WHEN FULL COWLIANCE WILL BE ACHIEVED o.

NORDS-32 was issued on Decenter 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 completed on Februtry 13, 1985. .The technical. support documentation

.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 9973N ,

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' VIOLATION 2-10 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-l' 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 FSAR identifies the slenderness ratio (KL/r) for structural steel members as a-controlled design parameter for compression members.

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.

CORRECTIVE ACTION TAKEN AND RESlLTS 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 designs were reviewed and it was determined that the slenderness ratios met the limits stated in NORDS-28.

CORRECTIVE ACTION TAKEN TO AVOID FURTER NONCOWLIANCE NORDS-28 was distributed to each engineer in S&L's Structural -

Engineering Division and was discussed at Structural Department and Structural

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Engineering Division Meetings. .The other Structural Design Standards that govern the design of safety-related supports for other components such as cable' trays, condui*.s, and piping have been reviewed and it was determined that these documents contained appropriate limits for slenderness ratios.

DATE WHEN FlLL COWLIANCE 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 designs to assure that slenderness ratios met the limits stated in

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NORDS.-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.

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