ML20136C723
| ML20136C723 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/13/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20136C727 | List: |
| References | |
| NUDOCS 8511210137 | |
| Download: ML20136C723 (9) | |
See also: IR 05000455/1985027
Text
i
p:rg#
0
~g
UNITED STATES
[
g
NUCLEAR REGULATORY COMMISSION
~
g
j
WASHINGTON, D. C. 20555
- eee*
November 13, 1985
Docket No. 50-455
Comonwealth Edison Company
ATTN: Mr. Cordell Reed
Vice President
P. O. Box 767
Chicago, IL 60690
Gentlemen:
SUBJECT: CONSTRUCTION APPRAISAL TEAM INSPECTION 50-455/85-27
Enclosed is the report of the Construction Appraisal Team (CAT) inspection
conducted by the Office of Inspection and Enforcement (IE) on August 19-30 and
September 9-20, 1985 at the Byron Unit 2 Station. The Construction Appraisal
Team was composed of members of IE, Region III, and a number of consultants.
The inspection covered construction activities authorized by NRC Construction
Permit CPPR-131.
This inspection is the thirteenth in a series of construction appraisal
inspections conducted by the Office of Inspection and Enforcement. The
results of these inspections are being used to evaluate the management control
of construction activities and the quality of construction at nuclear plants.
The enclosed report identifies the areas examined during the inaection.
Within these areas, the effort consisted primarily of detailu inspection of
selected hardware subsequent to quality control inspections, a review of
selected portions of your Quality Assurance Program, examination of procedures
and records, and observation of work activities.
Appendix A to this letter is an Executive Sumary of the results of this
inspection and of conclusions reached by this office. The NRC CAT noted no
pervasive breakdown in meeting construction requirements in the samples of
installed hardware inspected by the team or in the ifcensee's project construc-
tion controls for managing the Byron Unit 2 Station.
Deficiencies noted by the NRC CAT indicate that a number of construction-
program seaknesses exist which warrant additional management attention. The
more significant areas of concern to the NRC CAT are:
(1) the inability of
Westinghouse to retrieve radiographic film for certain ASME components for
which they had procurement responsibility, (2) a significant number of high
strength structural steel and equipment bolted connections were found not to
have specified torque values, and (3) the inadequate mounting of electrical
panels and switchgear, and the wiring of motor operated valves not in accord-
ance with approved design drawings.
We undcrstand that an evaluation of the findings of this inspection has been
made to determine the effect on Byron Unit 1 operations.
Ital
-
-
2-
-
.-
9
,
j-
-
\\
!
.
Connonwealth Edison Company
-2-
November 13, 1985
l
l
Appendix B to this letter contains a list of potential enforcement actions
'
based on the NRC CAT inspection observations. These are being reviewed by the
,
Office of Inspection and Enforcement and the NRC Region III Office for
l
appropriate action.
In addition, Region III will be following your corrective
action for deficiencies identified during this inspection.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the NRC Public Document Room.
No reply to this letter is
required at this time. You will be required to respond to these findings
after a decision is made regarding appropriate enforcement action.
Should you have any questions concerning this inspection, please contact us or
the Region III Office.
Sincerely,
f
%
'
l
Tay1
, Director
, fffice of Inspection and Enforcement
//
Enclosures:
i
1.
Appendix A, Executive Summary
2.
Appendix B, Potential Enforcement Actions
3.
Inspection Report
cc w/ enclosures: See next page
l
l
1
<
. --_-.
-
--.
. __.. - -__
._--
- _
- _ _
I
Commonwealth Edis:n Company
3-
Nov:mbar 13, 1985
-
cc w/ enclosures:
Dennis L. Farrar, Director
Resident Inspector (Byron Station)
of Nuclear Licensing
U.S. Nuclear Regulatory Commission
Commonwealth Edison Company
4448 German Church Road
P.O. Box 767
Byron, IL 61010
Chicago, IL 60630
Resident Inspector (Braidwuod Station)
Mr. V. I. Schlosser
U.S. Nuclear Regulatory Commission
Project Manager
RR #1, Box 79
Byron Station
Braceville, IL 60407
P.O. Box 8
Byron, IL 61010
Mr. Gunnar Sorenson
Byron Station
Commonwealth Edison Company
P.O. Box B
Byron, IL 61010
Byron Power Station
ATTN:
Mr. R. E. Querto
Plant Manager
P.O. Box B
Byron, IL 61010
Phyllis Dunton
Attorney General's Office
Northern Region
188 W. Randolph Suite 2315
Chicago, IL 60601
Ms. Olane Chavez, 0AARE/ SAFE
528 Gregory Street
Rockford, IL 61108
0. W. Cassel , Jr. , Esq.
109 N. Dearborn Street
Suite 1300
Chicago, IL 60602
Mr. H. S. Taylor, Head
Quality Assurance Division
Sargent & Lundy Company
55 E. Monroe Street
Chicago, IL 60603
,
0
,
!
!
!
l
i
-
,
Commonwealth Edison Company
-4-
November 13, 1985
'
DISTRIBUTION:
DCS (Docket No. 50-455)
NRC PDR
Local PDR
DI Reading
RCPB Reading
JMTaylor
RVollmer
JPartlow
RSpessard
BGrimes
EJordan
JAxelrad
HThompson
TNovak
BJYoungblooc'
MRushbrook
L01shan
WPaton
AE00
OELD
ACRS (10)
Regional Administrators
Regional Division Directors
HBoulden, OIA
SECY
OPE
OCA (3)
WDircks
HDenton
CAT Members
Resident Inspector
RHartfield
All Licensees (Distribution 1S)
g
fl
I
d
\\
RCPB:DI:IE
RCPB:DI:IE
DD/
DIR:
- IE I Dh .
DI
i
,
HWong/vj
RHeishman
RSpessard
JPar
ow
C/ R'
'1mer
JT
r
10/se/85
10 6 /85
10/g/85
1{/ /85
} / /85
16
85
l
.,
-
APPENDIX A
EXECUTIVE SUMMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at
Commonwealth Edison Company's (CECO) Byron Unit 2 Station, during the period
August 19-30 and September 9-20, 1985.
OVERALL CONCLUSIONS
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee commitments. However, the NRC CAT
did identify a number of construction program weaknesses, which in most cases,
have resulted in hardware deficiencies that require additional management
attention. These include:
1.
For two samples of radiographs for ASME components supplied by Westinghouse
(W) and stored in (W) facilities which were requested by the NRC CAT for
review, none were provided.
This is indicative of a lack of retriev-
ability for ASME Code required documentation and raises questions whether
code documentation is available for the (W) supplied equipment.
In
addition, the NRC CAT review of audits by CECO and (W) indicated that
audits had not addressed the area of retrievability of radiographs.
2.
A significant number of A490 bolts used in structural steel connections
and equipment hold-down applications were found by the NRC CAT to have
less than specified torque values. Some of these connections are designed
to rely on bolt induced clamping forces to carry a portion of the expected
loads.
3.
Examples were found in which the electric wiring for motor operated valves
were not in accordance with approved design drawings. This is of further
concern in that the method used for QC to accept these installations was
.through the use of a " speed memo" (which is an uncontrolled document that
does not receive the appropriate design review and approvals). Also in
the electrical area, the foundation mounting welds of several pieces of
Class 1E 4160V switchgear and 125V DC fuse panels were not in accordance
with design requirements.
The identified weaknesses require additional management attention to assure
that completed installations meet design requirements.
AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction
The electrical and instrumentation samples inspected generally met the appif-
cable design requirements and installation specifications. However, several
i
discrepancies were identified including some which will require additional
management attention.
A-1
_
_
._. .
_
_
f
Wiring workmanship deficiencies were observed in several Class IE components.
l
Deficiencies included items such as, conductor bend radius, lug orientation and
'
general configuration of wiring. The most significant concern involved
!
deficiencies identified in QC accepted wiring for Class 1E valve opera-
tors.
In this area over 50% of the sample exhibited wiring configurations
which were not in accordance with approved wiring diagrams.
Some electrical raceway installations were identified in which the FSAR
criteria for physical separation had not been met. Many of the deficiencies
involved the spatial relationship between Class IE and non-Class IE components.
The principal cause was the failure to translate FSAR requirements into
appropriate inspection procedures.
The inspection of several pieces of Unit 2 4160V switchgear and 125V DC fuse
panels indicates that hold-down welds do not meet requirements.
The weld
deficiencies on the switchgear were identical to ones which had been found by
the licensee on switchgear of Unit 1, but had not been addressed on Unit 2
components.
Mechanical Construction
Piping, pipe supports / restraints, concrete expansion anchors, and mechanical
equipment were found to be in general conformance to design and installation
requirements.
.
The finding of undersize welds in structural support members and a relatively
large number of minor discrepancies in the heating, ventilating, and air condi-
tioning (HVAC) ducts and supports indicates that additional program review and
attention is needed. These areas were previously subjected to reinspection
without complete resolution of these discrepancies.
Welding and Nondestructive Examination
Welding and nondestructive examination activities were generally found to be
conducted in accordance with the governing codes and specifications. However,
a number of examples were identified where completed structural welds in pipe
whip restraints, structural steel and HVAC areas were smaller than specified in
the design drawings. The licensee has performed an engineering evaluation
concerning these findings and concluded that the welds are structurally
adequate for the intended application.
In the area of vendor supplied tanks and heat exchangers, some were found to
have undersized weld reinforcement in nozzle to shell and manway to shell
joints.
The NRC CAT inspectors also found radiographs for vendor supplied hardware that
did not have adequate coverage and/or had unacceptable weld quality.
In
addition, film requested from the Westinghouse storage facility for review by
the NRC CAT were not provided.
Civil and Structural Construction
In the structural steel installation area no major hardware deficiencies were
identified.
However, several minor design drawing deficiencies were identified
and a significant number of high strength bolted connections for structural
A-2
-
-
.
- - - .
.-.
.
.
-
.
. --
-
-
-
.
l
steel and equipment supports did not meet inspection torque values. As a
result, connection clamping force requirements were not met.
Reinforced concrete construction in general was adequate.
Inconsistencies with
4
embedment length requirements of concrete expansion unchors exist between the
concrete expansion anchor qualification report and field inspection procedures.
Data was not provided to determine whether sufficient preload exists in expan-
sion anchors for those cases in which washers were not welded to support
baseplates for oversized holes.
Masonry construction and prestressed, post-tensioned tendon installations
were generally acceptable.
Material Traceability and Control
In general the material traceability and control program was considered to be
satisfactory.
Significant lack of traceability was found however, for fastener
materials, including assembly and mounting bolts for large vendor supplied
pumps / motors, bolts for battery racks, electrical switchgear and other equip-
ment; and bolts. attaching liVAC duct sections.
Design Change Control
'
Design change control was determined to be generally in conformance with
applicable requirements.
In this area the most significant finding was the
- failure to verify that installations were in accordance to current drawings
' -
when out of date design drawings were identified.
Corrective Action Systems
The licensee's corrective action program was found to be generally acceptable,
except for concerns regarding failure to assure that fasteners of required
materials were furnished with certain vendor supplied equipment, audits failed
to assure that radiographs for welds on certain vendor supplied equipment were
retrievable as required, and failure to provide for effective specification
and control of preventive maintenance, particularly from the time of turnover
for testing until turnover for operation.
4
A-3
'
.--
- . _ - - _ , .
_
-
- - _ _
.
- .
, _ .
APPENDIX B
P0TENTIAL ENFORCEMENT ACTIONS
As a result of the NRC CAT inspection of August 19-30 and September 9-20, 1985,
at Byron Unit 2 Station, the following items are being referred to Region III
as Potential Enforcement Actions. Section references are to the detailed
portion of the inspection report.
1.
10 CFR 50, Appendix B, Criterion III as implemented by Commonwealth
Edison Company (CECO) Quality Assurance Manual (QAM), Quality Requirement
No. 3.0, requires that measures shall be established to assure that
applicable regulatory requirements and design basis are correctly
translated into specifications, drawings, procedures and instructions.
Contrary to the above, at the time of this inspection, the licensee's
program was not adequately implemented in that:
a.
Splicing of Class 1E wiring in panels has occurred at Byron Station
contrary to the FSAR connitments to IEEE Standard 420, which prohi-
bits the use of wiring splices in panels.
FSAR commitments had not
been translated into appropriate procedures and design documents.
(Section II.B.2.b.(6))
b.
Approximately one-third of the total of A490 bolts tested by the NRC
CAT were found to be below the pretension required by AISC.
Instal-
lation and inspection requirements had not been translated into
appropriate procedures for high strength bolted connections in
structural steel and nuclear steam supply system joints which require
pretension in the bolts.
(Section V.B.I.b)
c.
During the inspection, concrete expansion anchors were found which
did not meet the eight bolt diameter embedment depth.
It could not
be shown that embedment length requirements for concrete expansion
anchors as specified in the concrete expansion anchor qualification
report had been translated into appropriate installation and inspec-
tion procedures.
(Section V.B.2.b)
2.
10 CFR 50, Appendix B, Criterion VII, as implemented by CECO QAM, Quality
Requirement No. 7.0, requires measures be established to assure that
purchased equipment and services conform to the procurement documents.
Contrary to the above, at the time of this inspection, the NRC CAT
inspectors found several deficiencies in vendor supplied components. The
deficiencies included:
radiographic film stored by the component supplier
in an off-site facility were not retrievable; undersized welds were
identified on tanks and heat exchangers; various vendor radiographs did
not have complete weld coverage or did not show the required weld quality;
and fasteners for various components (large pump-motor assemblies, battery
racks, switchgear cabinets, other electrical equipment, and HVAC equipment)
were not of the material required by specifications or drawings.
(Sections IV.B.11 and VI.B.I.b.(2))
B-1
3.
10 CFR 50, Appendix B, Criterion X, as implemented by CEC 0 QAM, Quality
Requirement 10.0, requires that a program for inspection of activities
be established and executed to verify conformance with documented
instructions, procedures, and drawings for accomplishing the activities.
Contrary.to the above, at the_ time of this inspection, the licensee's
inspection programs were not effectively implemented in that:
a.
Unit 2 4160V switchgear and DC fuse panels were found not to be
installed in'accordance with requirements for seismic mounting of
Class IE equipment.
(Section II.B.3.b.(4) and (6))
b.
Some Class IE electrical raceways have not been installed in accord-
ance with FSAR commitments for electrical separation.
(Section
II.B.1.b.(1))
c.
Some Class IE motor operated valve terminations were not accomplished
in accordance with design documents in that wiring configurations did
not match those specified on approved wiring diagrams.
(Section
II.B.3.b.(8))
-
B-2
..
.
...
.
-
-
--
.-
.
_ _ .
.- - .
..