ML20134F773
| ML20134F773 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/15/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Gerstner W ILLINOIS POWER CO. |
| Shared Package | |
| ML20134F777 | List: |
| References | |
| NUDOCS 8508210246 | |
| Download: ML20134F773 (9) | |
See also: IR 05000461/1985030
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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August 15, 1985
Docket No. 50-461
Illinois Power Company
ATTN:
Mr. W. C. Gerstner
Executive Vice President
500 South 27th Street
Decatur, IL 62525
Gentlemen:
SUBJECT:
CONSTRUCTION APPRAISAL TEAM INSPECTION 50-461/85-30
Enclosed is the report of the Construction Appraisal Team (CAT) inspection
conducted by the Office of Inspection and Enforcement (IE) on May 20-31 and
June 10-21, 1985 at the Clinton Power Station site.
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-137.
This inspection is the twelfth 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 inspection.
Within
those areas, the effort consisted primarily of detailed inspection of selected
haioware 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 Summary 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 licensee's project construc-
tion controls for managing the Clinton Power Station.
In addition, the
Illinois Power Company's Overinspection Program was viewed as being effective
in identifying deficiencies which had eluded earlier first line inspection and
in providing an added measure of the quality of construction at the site.
However, deficiencies noted by the NRC CAT indicate that a number of construc-
tion program weaknesses exist which warrant additional management attention.
The major areas of concern to the NRC CAT are:
(1) ineffective control of work
performed by plant staff on systems and components af ter turnover from con-
struction, (2) examples of inadequate control of design documents including
ineffective corrective actions for previously identified design document
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control discrepancies, and (3) inadequate programs for the verification of
electrical separation,
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Copy to RCPB
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0500210246 050015
PDH
ADOCK 05000461
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Illinois Power Company
-2-
August 15, 1985
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 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,
-
-
-
N
d
ames M. Tay
r, Director
Office of I pection and Enforcement
Enclosures:
1.
Appendix A,
Executive Summary
2.
Appendix B,
Potential Enforcement Actions
3.
Inspection Report
cc w/ enclosures:
See next page
.
,
. - - - - - - - - - -
I
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Illinois Power Company
-2-
August 15, 1985
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 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,
.
s
ames M. Tay
, Director
Office of I pection and Enforcement
Enclosures:
1.
Appendix A,
Executive Summary
2.
Appendix B,
Potential Enforcement Actions
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3.
Inspection Report
l
cc w/ enclosures:
See next page
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.
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_
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Illinois Power Company
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August 15, 1985
cc w/ enclosures:
Illinois Department of Nuclear Safety
ATTN:
Mr. Gary N. Wright, Manager
1035 Outer Part Drive
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Springfield, IL 62704
Prairie Alliance
-
ATTN:
Jean Foy
511 West Nevada
Urbana, IL 61801
Allen Samelson
Assistant Attorney General
Environmental Control Division
Southern Region
500 South Second Street
Springfield, IL 62701
Richard Hubbard
MHB Technical Associates
1723 Hamilton Avenue
Suite K
San Jose, CA 95125
H. S. Taylor, Quality Assurance Division
Sargent & Lundy Engineers
5 E. Monroe Street
Chicago, IL 60603
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Illinois Power Company
-4-
August 15, 1985
DISTRIBUTION:
Dc5 (Docket No. 50-400)
NRC PDR
Local PDR
JMTaylor
RVollmer
JGPartlow
BKGrimes
EJordan
JAxelrad
HThompson
TNovak
WButler
BSiegal
RWarnick
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ACRS (10)
Regional Administrators
Regional Division Directors
HBoulden, OIA
SECY
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OCA (3)
WDircks
HDenton
CAT Team Members
Resident Inspector
All Licensees (Distribution IS)
RCPB:DI:IE*
RCPB:DI:IE* DD:DI:IE*
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Ill no s Power Company
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DISTRIBUTION:
DC5 (Docket No. 50-400)
NRC PDR
Local PDR
JMTaylor
RVollmer
JGPartlow
BKGr mes
Edordan
JAxelrad
HThompson
TNovak
WButler
BS egal
RWarn ck
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NHSS
ACRS (10)
Reg onal Adm n strators
Reg onal D v s on D rectors
HBoulden, 0IA
SECY
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OCA (3)
WD rcks
HDenton
CAT Team Members
Res dent Inspector
All Licensees (Distribution IS)
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APPENDIX A
EXECUTIVE SUMMARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at
Illinois Power Company's (IP) Clinton Power Station during the period May 20-31
and June 10-21, 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.
Control of work performed by plant staff on components after turnover from
construction requires improvement.
This is evidenced by the number of
deficiencies identified in the Maintenance Work Request (MWR) Program.
Three MWRs were found to have used unqualified wire and three MWRs did not
include, or properly document, the required quality control (QC) inspec-
tions.
Also of concern is the lack of control of entries into and the
number of errors found in IP's Startup Punchlist Tracking System.
2.
Current programs for verification of electrical separation require
improvement.
The number of raceway separation deficiencies identified
indicate that control of separation through design without inspection for
separation is not adequate and the current walkdown program has not been
effective.
The FSAR does not currently allow the use of analysis which is
now being used to justify reduced separation requirements.
3.
Examples were noted where design requirements were not implemented by
construction and verified by quality control activities.
This is indi-
cated by examples of hardware deficiencies identified in several areas.
For example, power cable terminations were not insulated as required,
tanks and heat exchangers were supplied with deficient welds, certain
snubber supports were not modelled as committed, and a number of pieces of
equipment were found to be mounted with bolts of a material grade other
than that specified.
4.
A number of document control discrepancies were found between the design
change data listed for a specification or drawing in the Document Manage-
ment System (DMS) and the design change documents actually posted with the
controlled construction specification or drawing.
This is of particular
concern since control of construction specifications and drawings, and
their computer data bases, is key in the management system established for
ensuring that current design documents are used in developing work pack-
ages for installation and inspection.
However, no resulting hardware
deficiencies were noted in a sample of related work checked by the team.
5.
Corrective action was not considered timely or sufficiently compreher.,ive
for deficiencies identified by the licensee in the testing of structural
fill.
Deficiencies were identified in the structural fill records related
to the lift thickness requirement of structural fill.
A-1
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.-_ _______ ___ _
.
An effort was made by the NRC CAT to assess the IP Overinspection (IPOI)
Program.
The NRC CAT noted fewer program or hardware deficiencies in areas
covered by the IPOI Program than in areas not covered by the IPOI Program.
These 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 appli-
cable design requirements and installation specifications.
However, several
discrepancies were identified including some which will require additional
management attention.
Electrical separation critt ia detailed in the CPS FSAR had not been met in
some raceway installations.
The review of related activities indicates that
existing design, quality verification and walkdown programs have not been
completely adequate to ass,re compliance with specified commitments, and that
personnel performing walkdown activities have not received adequate training
and acceptance criteria to assure that existing deficiencies will be identi-
fied.
Analysis to justify lessor spatial separation is also being used which
is inconsistent with current FSAR commitments.
Separation deficiencies also exist in vendor wiring installed in several
sections of the operator main control panels.
In this area, the use of flexi-
ble metallic conduit as a fire rated barrier, and the fire protection adequacy
of certain control room panels are items requiring further NRC evaluation.
A
number of deficiencies were also identified in vendor panels that have been
excluded from the special QC inspection program.
Work performed on Class 1E equipment by plant staff under the Maintenance Work
Request Program is not effectively controlled.
Examples of unperformed inspec-
tions and the use of unqualified wire in safety-related components were identi-
fied.
Design specification requirements were not, in some cases, implemented by the
construction and QC activities.
This was evidenced by several uninsulated
medium voltage terminations which were QC, and in one case IPOI, accepted
although design, installation and inspection documents required them to be
insulated.
Mechanical Construction
Piping, concrete expansion anchor installations, heating, ventilating and air
conditioning (HVAC) ducts and supports, and mechanical equipment were found to
be in general conformance to design and procedural requirements.
A-2
Discrepancies were identified in ASME and Class D pipe support / restraint
installations.
Greater attention to detail during inspections of Class D
.
supports appears necessary.
Potential damage and generic implications with
!
respect to PSA 35 snubber component congruity needs to be addressed.
A need
l
for additional reanalysis of two supports is evidenced by their incorrect
modelling.
Controls for ensuring the timely removal of temporary supports are
inadequate.
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
supports / restraints did not have the weld sizes specified by the Architect
Engineer.
Two of these examples were previously covered by IP Overinspection.
The licensee has performed an engineering evaluation concerning this problem
and concluded that the welds are structurally adequate for the intended appli-
cation.
In the area of vendor supplied tanks and heat exchangers a number of tanks were
found to have undersized weld reinforcements in nozzle to shell and manway to
shell welded joints.
The NRC CAT inspectors also found radiographs for welds in areas of the
containment liner and drywell wall which did not meet the specified acceptance
criteria.
The containment liner condition had been previously identified by
the licensee who, based upon a sample review, had conculded that no remedial
work was required.
Based on this and the fact that MT and vacuum box inspec-
tion had been applied, the CAT concurred with the licensee conclusion.
Civil and Structural Construction
The civil and structural construction areas were found to be adequate.
How-
ever, several deficiencies were identified.
The requirements in the FSAR and specifications for cadweld operator testing
frequency were not met. Certain structural fill records were found to be
inadequate relative to backfill lift thickness requirements in the FSAR.
In
addition, corrective actions taken by S&L for previously identified deficien-
cies in testing of cadweld operators and structural fill records were con-
sidered inadequate.
Two deficiencies were identified with the implementation of the IPOI Program in
that not all primary steel beams were properly identified per applicable
criteria for inspection and the torquing of bolts for slide connections was not
adequately inspected.
Material Traceability and Control
The licensee's materie traceability and control program was found to be
acceptable, except foi certain fastener hardware.
Lack of traceability was
found for some vendor supplied fastener materials, including bolts for large
pump-motor and skid-mounted pump-turbine assemblies, and mounting bolts for
HVAC control panel cabinets.
A-3
Design Change Control
The design change control program was determined to be generally in accordance
with site procedures with several exceptions. A number of discrepancies were
identified in the updating of a Civil and Structural Resident Engineer's
Project Procedures Manual.
A high rate of discrepancies was also found in the
active change documents listed in the Document Management System related to a
piping design specification and the change documents physically posted with
controlled copies of the specification.
A systematic weakness was identified in the current computer data base system.
The NRC CAT requests for and examinations of work packages associated with the
installation of structural steel and electrical cable tray support design
drawing requirements noted that the computer data base does not currently
satisfy the Baldwin Associates QA Manual objective for an index system which
will ensure the rapid and orderly identification and retrieval of records.
Corrective Action Systems
In general, corrective action measures were found to be acceptable.
However, a
high rate of errors was found with entries into the Startup Punch List.
These
included the listing of, unrelated corrective action documents against punch list
items, resulting in not identifying the closure against punch list items when
the related corrective action documents were completed.
In addition, correc-
tive actions implemented to correct deficiencies identified by IP QA audits in
the area of design document control had not been effective.
A number of nonconformances were found dispositioned use-as-is without evidence
to substantiate this disposition.
A-4
.
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APPENDIX B
POTENTIAL ENFORCEMENT ACTIONS
As a result of the NRC CAT inspection of May 20-31 and June 10-21, 1985, at
the Clinton Power Station site, 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 Illinois Power
Nuclear Power Construction (IPNPC) Quality Assurance Manual (QAM) Chapter
3, 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 two ASME Class 1 Nuclear
Steam Supply System snubber supports were found to have been modelled and
analyzed as rigid supports contrary to FSAR commitments to model them as
flexible supports.
(Section III.B.2)
2.
10 CFR 50, Appendix B, Criterion VI, as implemented by IPNPC QAM Chapter
6, requires that measures be established to assure that documents such as
instructions, procedures, and drawings, including changes thereto, are
distributed to and used at the location were the prescribed activity is
performed.
Contrary to the above, at the time of this inspection, BA document control
procedures were not properly implemented in that numerous discrepancies
were identified in the filing and updating of procedures in the Civil and
Structural Resident Engineer's copy of the BA Project Procedures Manual,
and in the posting of design change documents in specifications.
(Section
VII.B.1)
3.
10 CFR 50, Appendix B, Criterion VII, as implemented by IPNPC QAM Chapter
7, 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 inspec-
tors identified vendor procured tanks and heat exchangers that had been
accepted and installed with deficient welds.
They also identified various
vendor and contractor supplied radiographs which did not have the required
weld and film quality.
(Sections IV.B.9, 10, and 11)
4.
10 CFR 50, Appendix B, Criterion VIII, as implemented by IPNPC QAM
Chapter 8, requires that measures be established for control of
materials, parts and components to prevent the use of incorrect or
defective items.
Contrary to the above, at the time of this inspection, bolts for mounting
large pump-motors, pump turbine assemblies mounted on skids, and HVAC
control panel cabinets were not as required by the applicable drawings and
specifications.
(Section VI.B.1)
B-1
,
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5.
10 CFR 50, Appendix B, Criterion X, as implemented by IPNPC QAM Chapter
10, 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 they:
a.
Have not assured that safety-related electrical raceways have been
installed in accordance with FSAR commitments for electrical
separation.
(Section II.B.1)
b.
Have failed to assure that appropriate quality verifications are
conducted and that only qualified materials are used for work performed
under the Maintenance Work Request Program.
(Section II.B.2)
c.
Had not assured that safety-related SkV power cable terminations were
accomplished in accordance with design documents in that required
insulating materials had not been installed.
(Section II.B.2)
6.
10 CFR 50, Appendix B, Criterion XVI, as implemented by IPNPC QAM Chapter
16, requires that conditions determined to be adverse to quality are
promptly identified and corrected.
Contrary to the above, at the time of this inspection:
a.
NCR 31282 was incorrectly dispositioned by S&L as use-as-is based on
specification requirements having been met, when the specification
and FSAR requirements had not been met for cadweld operator testing
frequency.
(Section V.B.1)
b.
The resolution of NCR S-S-S-0006 and NCR 174 had not provided a
timely and comprehensive review of applicable soil test data to
ensure the FSAR commitments were met.
Corrective action taken for
NCR 174 had accepted structural fill placements using nuclear density
test data where the sand cone test data had failed which was contrary
to the project specifications.
Further the evaluation performed of
soils records did not identify or address that the inspection program
during that period had not provided for adequate records or assurance
that the structural fill was placed in 12 inch lifts as stated in the
FSAR.
(Section V.B.3)
B-2
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