IR 05000454/1986036

Insp Repts 50-454/86-36 & 50-455/86-30 on 860915-1030. Violations Noted:Failure to Identify & Correct Nonconforming Conditions on safety-related Pipe Hangers

ML20214P159
Person / Time
Site:	Byron
Issue date:	11/28/1986
From:	Danielson D, Liu W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214P058	List: IR 05000454/1986036 ML20214P055 ML20214P105
References
50-454-86-36, 50-455-86-30, IEB-79-14, NUDOCS 8612040095
Download: ML20214P159 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/86036(DRS); 50-455/86030(DRS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois Inspection Conducted: September 15 through October 30, 1986 Inspector: . C. Liu &f \( Tdf66 Date Approved By:

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. H. Danielson, Chief ll!1A[86 Materials and Processes Section Dats Inspection Summary Inspection on September 15 through October 30, 1986 (Reports No. 50-454/86036(DRS); 50-455/86030 (DRS))

Areas Inspected: Seismic analysis for as-built safety related piping systems (IE Bulletin 79-14); verification of as-built conditions associated with piping systems (37051); testing of piping support and restraint systems (70370);

vibration tests (70331); SER review in conjunction with the piping vibration test program (SER Section 3.9.2.1); licensee actions on previous enforcement matters; and licensee actions on 10 CFR 50.55(e) items (92700).

Results: One violation was identified - failure to identify and correct nonconforming conditions on safety-related pipe hangers, Paragraph %20gg h G

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DETAILS 1. Persons Contacted Commonwealth Edison Company (CECO)

• R. Querio, Station Manager

• R. Moravec, Project Construction Assistant Superintendent

• R. Ward, Services Superintendent

• G. Schwartz, Assistant Superintendent, Maintenance

• E. Martin, Quality Assurance Superintendent

• Klinger, Project QC Supervisor

• P. Donavin, Field Engineering Coorainator

• J. Woldridge, Quality Assurance Supervisor

• P. O'Neill, QC Supervisor

• T. Joyce, Assistant Superintendent, Technical Services

• W. Burkamper, Quality Assurance Superintendent

• F. Hornbeak, Technical Staff Supervisor D. Geddings, Project Construction Engineer J. Ewald, Technical Staff Engineer J. Ventimiglia, System Test Engineer Sargent and Lundy Engineers (S&L)

• J. Meister, Overall Field Coordinator K. Kloecker, Structural Field Coordinator H. Chang, Senior System Engineer Westinghouse Electric Corporation (W)

• Pitluk, Manager, Structural Analysis Mobile Unit (SAMU)

R. Manz, Piping Manager R. Patel, Senior Engineer J. Amin, Senior Engineer G. Orlowski, Engineer Hunter Corporation M. Somsag, Quality Assurance Supervisor K. Jagman, Quality Assurance Assistant

• Denotes those attending the final exit interview on October 30, 198 . Licensee Action on Previous Enforcement Matters (Closed) Violation (454/84-51-03, 455/84-35-04): Inadequate procedures for determining the clearance between pipe and unsealed penetrations; retesting of steam generator snubbers based on unapproved procedures; and field cut of EAM without approved procedures. CECO's letter of response dated May 10, 1985, was reviewed and determined to be acceptabl __

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G The inspector held discussions with licensee's representatives and examined the corrective actions as stated in the letter of respons The inspector concluded that CECO had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar. circumstance The corrective actions identified in the letter of response have been implemente b. (Closed) Violation (454/84-51-04, 455/84-35-05): Piping as-built dimension inspections failed to identify instances where the tolerances had been exceeded. In addition, prior to February 15, 1983, as-built measurements were taken by personnel who were not certified Q.C. inspectors. CECO's letter of response dated May 10, 1985, was reviewed and determined to be acceptable. The inspector held discussions with licensee's representatives and examined the corrective actions as stated in the letter of response. The inspector concluded that CECO had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar circumstances. The corrective actions identified in the letter of response have been implemente c. (Closed) Unresolved Item (455/84-35-03): Effects on pipe insulation which was installed after completion of piping clearance inspection and measurement. CECO has revised the applicable work procedures to address the NRC inspector's concern. These included Nuclear Power Service (NPS) Work Procedure No. 3.0.9, Hunter Corporation Site Training Instruction No. 8 and Site Implementation Procedure 4.201, Westinghouse Hot Functional Testing and Limited Clearance Investigation Procedure, and S&L Instruction PI-BB-40. Further, the NRC inspector reviewed more than 10 deficiency reports associated with the evaluation of potential thermal interferences with insulation. The licensee's corrective actions with respect to the NRC inspector's concern appeared to be adequat This item is considered close d. (Closed) Unresolved Item (455/84-35-06): Verification of energy absorbing material (EAM) test specimen during cutting. The licensee representative performed a surveillance on December 11-13, 1984, and was not aware that Hexcel had deviated from the EAM cutting plan required by the S&L specification. Subsequent to the NRC inspection, a letter was issued by S&L on February 3,1986, to accept the EAM cutting plan. This item is considered resolve e. (Closed) Unresolved Item (455/84-35-07): Comments on S&L procedure This item addressed NRC concerns that Procedure MAS-30 did not previously prescribe how to resolve engineering staff recommendations in a timely manner; and that QA Procedure GQ-3.08 permitted the use of external, source of information as design input which might

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. compromise with NRC requirements and licensee commitment Consequently, S&L has revised the aforementioned procedures in response to the above concerns and la presently. implementing these

! procedures. This item is considered closed, (Closed) Unresolved Item (455/84-28-02): Future.NRC review of activities associated.with the ITT-G proposed steam generator snubber (SGS) modifications. This concern was resolved as a result  !

of activities conducted by the NRC inspector and described in  !

Inspection Reports No. 50-454/85044 and No. 50-455/85043. This item is considered close , Licensee Actions on 50.55(e) Items (92700) (Closed) Item 84-05 (455/84-05-EE): On June 28, 1984, CECO notified i Region III of a deficiency report concerning the unsatisfactory l operation during confirmatory testing of the steam generator snubbers supplied by the Boeing Company. The final report was submitted to

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l Region III dated August 12, 1986. The NRC inspector reviewed the .

{- final report and determined it to be acceptable. The inspector held '

, discussions with licensee representatives and reviewed supporting i documentation to verify that corrective actions identified in the report were adequate and complete. This item is considered close *

( (Closed) Item 84-07 (455/84-07-EE): Crush strength of energy [

] absorbing material (EAM) used in pipe whip restraints. On October 30, i

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1984, Ceco notified Region III of a deficiency report regarding the crush strength of EAM used in the whip restraints. The final report

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was submitted on March 11, 1985. This report identified 21 whip

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restraints to be replaced with new EAM for each unit of Byron Statio '

The revised final report was submitted on October 17, 1986.- This

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report deleted four whip restraints to provide construction, operation, i and maintenance cost savings. As a result, the final number of whip

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' restraints became 17 for each unit of the facility. The NRC inspector ,

held discussions with licensee representatives and-reviewed related  :

, documentation to ensure that the corrective actions identified in the '

report were adequately completed. This item is considered close . Safety Evaluation Report (SER) Section'3.9.2.1 Review and Followup (92719)

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(Closed) Open Item 455/83000-13: Piping vibration test program. This 1

item addressed concerns that acceptance criteria for piping stress be {

established under steady-state vibrational conditions; that the test '

program consisted of a mixture of instrumental measurements and visual observation by qualified personnel; that initial clearances for whip restraints be .hecked and evaluated; and that snubber operability be i ensured through a program of preservice examination and preoperational i

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testing. The inspector held discussions with licensee representatives, reviewed supporting documentation, and observed representative samples  :

of work to ensure that adequate actions associated with the aforementioned concerns have been implemented. This item is considered close >

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5. Verification of As-Built Conditions (Unit 2) (37051)

The NRC inspector randomly selected the following safety-related piping isometric drawings and pipe hanger drawings for a verification inspection to determine whether the as-built conditions are consistent with the design document Piping Isometric Drawing N Piping System CC-52 Componer.t Cooling CV-18 Chemical and Volume Control RC-13 Reactor Coolant SI-25 Safety Injection Pipe Hanger N Piping System 2CC39014X, Revision A Component Cooling (CC)

2CC39023X, Revision B CC 2CC39026X, Revision B CC 2CC39028X, Revision B CC 2CV08017X, Revision B Chemical and Volume Control (CV)

Pipe Hanger N Piping System 2CV08018X, Revision E CV 2CV08019X, Revision B CV 2CV08021X, Revision D CV 2RY06003X, Revision B Reactor Coolant (RC)

2RYO6007X, Revision B RC 2RY06008X, Revision B RC 2RYO6034X, Revision B RC 2SIO3008X, Revision B Safety Injection (SI)

2SIO3009S, Revision 8 SI 2SIO3011X, Revision 8 SI 2SIO3041X, Revision A SI The relevant portions of the above piping systems were inspected with respect to the corresponding isometric drawings for general configuration, location, and dimension. Further, the aforementioned 16 pipe hangers were also inspected against their detail drawings for configuration, identification, location, fastener installation, clearances, member size, weld size, and damage / protection. In general, the appearance of the piping systems was good and the pipe hangers were installed in accordance with design documents with the exception of five hangers identified below:

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Pipe Hanger N Piping System 2CS06039X, Revision B Containment Spray (CS)

2CSO9010X, Pevision B CS 2CV38A043X, Revision B Chemical and Volume Control (CV)

2CV15059X, Revision A CV 2CC39023X, Revision B Component Cooling The above five pipe hangers along with the other hangers were visually examined by the NRC inspector during a field walkdown inspection conducted in August and in September 1986. The five pipe hangers were found to have loose nuts in the hanger installations. All of the five hangers had previously been inspected by the licensee's QC inspectors during the Type 4 final inspectio In accordance with licensee's component support installation guidelines M-919 the aforementioned loose / Jam nuts should have been wrench tight or snug tight, which is defined as the tightness attained from a few impacts of an impact wrench or the full effort of a man using an ordinary spud wrench. Further, Appendix B of 10 CFR 50, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality, such as deficiencies and nonconformances are promptly idertified and corrected.

l The licensee had not identified the aforementioned five hangers with loose nuts prior to the NRC inspection. This matter is identified as Violation 455/86030-0 Subsequent to the identification of the above hanger problems, the licensee promptly initiated a sample program to evaluate loose nuts for safety-related pipe hangers. The sample covered field inspections of 128 pipe hangers with a total of 390 threaded connections. A total of six loose nuts and one missing lock nut were identified. The deficiency rate was 1.8 percent. The identified deficiencies had been evaluated and found to be insignificant in terms of design requirements. All deficiencies have been documented and corrected to their design condition The NRC inspector found no other loose nuts in the hanger installation Consequently, no reply to this violation is required and the inspector has no further questions regarding this matte Within the areas inspected, one violation was identifie . IE Bulletin 79-14, Seismic Analysis for As-Built Safety-related Piping Systems (Unit 2) Document and Procedure Review The NRC inspector reviewed the relevant portions r/ the following documents and procedures pertaining to as-built pipe supports and piping systems to determine whether appropriate procedures have been

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established and whether they comply with NRC requirements and the licensee commitments. The NRC inspector noted that the procedures and instructions appeared to be acceptable in terms of performing work activi, ties associated with hanger installation and inspectio . _ _

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NPS Work Procedure No. 3.0.9, As-Built Piping Subsystem Preparation, Revision F, June 26, 198 S&L Project Instruction PI-BB-26, Procedure for

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Preparation and Submittal of Piping As-Built Information, Revision 4, August 20, 198 S&L Project Instruction PI-BB-27, Receipt, Review, Reanalysis, Redesign, and As-Built Piping Reconciliation, Revision 4, March 18, 198 S&L Design Specification for Component Supports, Revision 4, April 7, 198 '

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Hunter Corporation Site Training Instruction STI No. 8, Instruction for the Preparation, Field Use, and Review of the Component Support Type 4 Checklist, Revision 0, June 5, 198 Hunter Corporation Site Implementation Procedure SIP No. 4.201, Installation Verification, Revision 12, October 17, 1985, b. Review of Piping Stress Analysis The NRC inspector randomly selected the following safety-related piping systems for a verification inspection to determine whether the latest stress analyses are consistent with the as-built condition Subsystem N Piping System 2AF02 Auxiliary Feed Water 2CC39 Component Cooling 2RYO6 Reactor Coolant 2SIO3 Safety Injection 2SX12 Essential Service Water The relevant portions of the stress analyses associated with the above piping systems were inspected with respect to seismic application, support location, dimension, and valve orientatio It was found that the analysis methods used for the stress analyses were generally conservative. This included the use of low damping values and the enveloped seismic response spectra at various location Further, the analytical results were evaluated with respect to the allowable stresses to ensure that code requirements are being me c. Review of 3upport Design Calculations The NRC inspector randomly selected the following support design calculations for review to determine whether the design calculations were adequately performed in accordance with established procedure . , . . .

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. 4 Pipe Support (Hanger) N Piping System 2CC39014X, Revision A ComponentCooling(CC)

2CC39023X, Revision B '

CC 2CC39028X, Revision B . CC 2RY06003X, Revision B /

Reactor Coolant (RY)

2RY06007X, Revision B RY -

2RY06034X, Revision RY 2SIO3009S, Revision B' Safety Injection (SI)

2SIO3011X, Revision B SI 2SIO3041X, Revision A SI The relevant portions of the design calculations for the above supports were reviewed for conformance to analysis criteria, applicable codes, NRC requiiements and licensee commitment In addition, these design calculations were evaluated during the review for thoroughness, clarity, consistency, and accuracy. In general, the design calculations appeared to be adequately performed in accordance with licensee commitments and NRC requirements. Further, design load verifications were,also performed by the NRC inspector to ensure that pipe hanger designs werd consistent with the corresponding piping stress analyses.

. Review of Piping Isometric Drawing <

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During the inspection, the NRC inspector noted that Hanger No. 2AF04070V was shown on Hunter. Isometric Drawing FW-70,

, Revision 8J. The hanger number followed with a letter V shown in a rectangular box indicated as-built information. The letter V represents a variable spring hanger in accordance with licensee's instruction. A field inspection of this hanger revealed th~at it was a rigid support. The design calculation for this hanger was verified to be consistent with the field installation. The NRC inspector held discussions with licensee representatives regarding the inconsistent information for the aforementioned pipe Fhnger. The licensee indicated that the type of hanger shows on the isometric drawing was only for information purposes'and was not for detailed analysi Further, it was determined that Hunter Site Implementation Procedure SIP No. 2.504, Isometric and Spool Drawing. Control, Revision 3, would be revised to include a new sentence to Paragraph 4.1. as follows:

" Component Support number designations, when added as directed by the Owner, can include the support type designation (alpah suffix) as optional information. The type designation,

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when included, need not be updated'if changed by subsequent designs. In order to determine the support type, refer to the latest specific support detail drawing."

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As a result of the above procedure revision which was completed by the licensee, the NRC inspector had no further questions regarding the aforementioned concer Within the areas inspected, no violations or deviations were identifie . Testing Piping Support and Restraint Systems (70370) Review of Test Programs and Procedures The NRC inspector reviewed the relevant portions of the following documents and procedures pertaining to test programs to determine whether appropriate procedures have been established and whether they comply with NRC requirements and the licensee commitments. The NRC inspector noted that the documents and procedures reviewed appeared to be acceptable in terms of work activities associated with the test progra Preoperational Test Program No. 2.028.60, Thermal Expansion - Primary Side (EM), Revision 2, April 8, 198 Test Review Board, Pre-Test Review of Test Program 2.28.60, Revision 2, April 17, 198 Project Engineering Department Review and Approval of Preoperational Test Results for Test 2.28.60, July 11,198 Test Review Board, Review and Approval of Post Test Results for Test 2.28.60, June 25, 198 Westinghouse Review and Comment on Test Program 2.028.60, Revision 2, April 14, 1986 (SAMU1-16876).

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S&L Review and Comment on Test Program 2.028.60, Revision 2, April 15, 1986 (SLBF-7175).

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Procedure 2BVS 7.8-1, Visual Examination of Safety Related Snubbers, Revision 0, June 16, 198 Procedure 2BVS, 7.8-2, Functional Testing of Safety Related Mechanical and Hydraulic Snubbers, Revision 0, June 20, 198 Preoperational Test Results Evaluation The NRC inspector reviewed the following preoperational test results pertaining to the safety-related piping systems to determine whether the results had adequately been reviewed and evaluated in accordance with licensee procedures and NRC requirement The NRC inspector noted that licensee's evaluations with respect to the test results appeared to be acceptable in terms of identifying potential problems and providing resolutions to these problem _ _ _ _ . __ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ __ __ - _ _ _

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(1) Test Evaluation Against Acceptance Criterion J' Acceptance Criterion.4.1 requires that the piping and I ,

ccmponents shall not be constrained from expanding or contracting. The licensee's verification regarding this criterio'n was performed by conducting visual examinations of piping and supports at various temperature plateaus during heatup and cooldown. If evidence of a problem was noted

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during the testing, the problem was written and was evaluated by engineering personnel who also provided recommended

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resolutions to the area of concerns. A total of 471 potential

. thermal growth interference data sheets were generated and were evaluated by the licensee during the course of the testin (2) Test Evaluation Against Acceptance Criterion , Acceptance Criterion 4.2 requires that the operating temperature snubber movements should be within i 25% or i 1/4 inch, whichever l 1s greater, of calculated values. A total of 139 snubber i t movements were recorded by the licensee, of which 51 were outside the expected range of the acceptance criterion. Further evaluations were performed by the licensee in accordance with -

the applicable procedures / instruction l (3) Test Evaluation Against Acceptance Criterion Acceptance Criterion 4.3 requires that during heatup and for systems whose maximum operating temperature is not attained, actual values should be within 50% or i 1/4 inch, whichever is greater, of calculated values. The licensee identified 20 out of the 139 snubber movements recorded were outside the l expected range of the acceptance criterio (4) Piping Subsystem Summary

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The following is a brief summary of the subsystem information generated by the licensee'during the course of the test Subsystems examined: 126

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Deficiency items written: 1208

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Thermal interferences written: 471

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Support measurements taken: 199 Within the areas inspected, no violations or deviations were identifie (

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8. Vibration Test, Preoperational Test Procedure Review (70331) : Review of Test Programs and Procedures-

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The NRC inspector reviewed the relevant portions of the following documents and procedures associated with the test program to determine whether appropriate procedures have been established and whether they comply with NRC requirements and the itcensee commitments. The NRC inspector noted that.the documents and procedures reviewed appeared to be acceptable in terms of meeting

.NRC requirements and the licensee commitment Preoperational Test Program 2.28.62, Pipe Vibration, Revision 1, April 30, 198 Test Review Board,. Pre-Test Review of Pipe Vibration 2.28.62, Revision 1, February 10, 198 Project Engineering Department Review and Approval of Preoperational Test Results for Test 2.28.62, -

September 30, 198 Test Review Board, Review and Approval of Post Test Results for Test _2.28.62, September. 10, 198 Preservice/ Inservice Testing,. Program Plan for Pumps, Revision 5, April 11, 198 Preoperational Test Results Evaluation

The NRC inspector reviewed the following peroperational test results pertaining to the safety-related piping systems to determine whether the results had adequately been reviewed and evaluated in accordance with licensee procedures and NRC~ requirements. The NRC inspector found that licensee's evaluations with respect to the test results appeared to be acceptable in terms of meeting NRC requirements and

.the licensee commitment (1) Evaluation Against Acceptance Criteria The pipe vibration was conducted under steady state and normal operating condition. A piping section was considered acceptable if measured vibrations were within the established acceptance criteria. The calculated limit and measured level of vibration were compared to determine the' acceptance or rejection of the piping subsyste In the cases where the pip ng was rejected or the measured vibrations exceeded the i

allowable, a detailed analysis was required to determine whether retesting / corrective action was needed to ensure system integrit .

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(2) Evaluation for Pipe Vibrations During the course of the test evaluation, the licensee generated a total of 52 vibration problems to qualify the ten safety-related piping systems in accordance with licensee's established acceptance criteria. Results of the problem evaluation revealed that 16 problems were identified to have excessive vibrations outside the acceptance criteria. As a result, the licensee performed a detailed analysis for each of the above 16 problems. Consequently, two problems (9.10.Al and 9.10.A2) were required to have design changes and one problem (9.1.A8) was determined to have support modification resulting from the detailed analyse The NRC inspector reviewed the relevant portions of the aforementioned problem evaluations with respect-to the applicable procedures, acceptance criteria, and code requirements. The NRC inspector found that licensee's evaluations regarding the above identified problems were adequately addressed and well documented in accordance with the established procedure (3) Review of Pump Vibrations The NRC inspector reviewed the relevant portions of the Ceco preservice/ inservice testing program plan for pumps to determine whether appropriate procedures have been established and whether they comply with NRC requirements and the licensee commitments. The NRC inspector found that.the procedures contained in the program appeared to be acceptable in terms of performing vibration measurements and evaluation of vibration performanc Within the areas inspected, no violations or deviations were identifie . Exit Interview The inspector met with site representatives (denoted in Persons Contacted Paragraph) at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection noted in this report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar