IR 05000461/1980004
| ML19310A537 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/21/1980 |
| From: | Knop R, Naidu K, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19310A535 | List: |
| References | |
| 50-461-80-04, 50-461-80-4, NUDOCS 8006200124 | |
| Download: ML19310A537 (15) | |
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U.S_ NUCLEAR REGULATORY COMMISSION
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OFFILE OF INSPECTION AND ENFORCEMENT
REGION III
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Report No. 50-461/80-04 Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:
Clinton Unit 1 Inspection At:
Clinton Power Station, Clinton, IL Inspection Conducted: March 25-28, 1980
$ C W u,f e Inspectors:
H. M. Wescott
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K. Naidu bI 4 /f/fd Y
a/.n w AC I
Approved By:
R. C.
nop, Chief, O/ jd Projects Section 1
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Inspection Summary Inspection on March 25-28, 1980 (Report No. 50-461/80-04)
Areas Inspected: Routine annou-eed inspection: followup of previously identified unresolved items ar.d noncompliances, IE Bulletins and Circulars, Reactor Vessel installati QA records, electrical (components and systems)
QA implementing procedures, electrical observation of work activities, electrical review of QA records, and review SRV radiographs. The inspec-tion involved a total of 48 inspector-hours by three NRC inspectors.
Results: Of the seven areas inspected, one item of noncompliance was identified (infraction - requirements not correctly translated into drawings and specifications).
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DETAILS Persons Contacted (
Principal Licensee Employees Illinois Power Company (IPC)
- R. J. Canfield, Site Construction Manager
- E. E. Connon, Assistant Director Construction
- L.
Dozier, Construction
- J. F. Hampton, Supervisor Construction QA
- D. E. Korneman, Supervisor Mechanical Construction G. Wueller, Licensing Manager Baldwin Associates
- W. J. Harrington Project Manager
- R. K. Hartley, Senior QA Engineer
- J. R. Holding, QA Manager
- J. Lane, Senior Electrical QC Engineer l
- J. Linehan, Manager QC
- M. W. Merritt, QCE Engineer
- T. Selva, Manager Technical Services
- J. Smart, Senior QA Engineer
- H. R. Swift, Assistant Project Manager
- T. Walker, QC Engineer x
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- S. G. Hall, Site QC
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- W. R. Perrault, Manager QCE-V & PC
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The inspector also talked with and interviewed several other licensee and i
s his contractor's employees, including members of the technical services
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staff, QC and QA personnel and craftsmen.
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- Denotes those present at the exit interview.
Licensee Action on Previously Identified Items (Closed) Infraction (461/78-05-02) Unqualified personnel performing liquid penetrant examination on safety related pipe welds. An inner office memorandum dated May 31, 1978, from the Manager of Baldwin Associates was effective immediately after the inspector's finding stated that all required NDE personnel will be qualified and certified prior to performing NDE.
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(Closed) Unresolved Item (461/78-05-15) Unclear how end gap spacing of
rebar inspection is accomplished and documented. The inspector reviewed Baldwin Associates Procedure BAP 3.1.5, Embedments/ Reinforcing Steel /
Cadwelding, Revision 7, dated February 25, 1980, paragraph 5.9.1 which states that inspections are to be conducted on a random basis at least twice per week and document these inspections on the QC Cadwelder's Technique Inspection Report, Form JV-609. The inspector further re-viewed Form JV-609 files for 1979 and 1980. These reports reflect tnat
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cadweld splices are inspected per BAP 3.1.5.
This item is considered closed.
(Open) Nomcompliance (461/79-11-01) U.S. Testing personnel did not meet the required experience requirements. UST Procedure TQ-1 did not meet the intent of ANSI N45.2.6.
The inspector reviewed the following:
1.
Letter, IPC to NRC RIII U-0121, Q37-80 (01-15)-9, dated January 15, 1980.
2.
Letter, IPC to NRC, RIII U-0114, Q37-79 (12-26)-9, dated December 26, 1979.
3.
U.S. Testing Co., Inc. Procedure UST-TQ-1,Section V, Revision 10, dated January 21, 1980, paragraph 3.0, " Education and Experience",
appears to reflect the requirements of ANSI N5.2.6-1973.
4.
UST TQ-1, Revision 10, " Training and Qualification of Inspection and Test Personnel Examinations". Examinations have been prepared that has not been administered.
5.
QCP-6, " Training of Personnel" Revision 5, dated January 30, 1980.
6.
Four (4) personnel files of Level I and II examiners.
This item remains open pending the licensee's completion of their commitments in IPC letter to NRC U-0121, Q37-80 (01-15)-9, dated January 15, 1980.
(Closed) Unresolved Item (461/80-02-02) Calibration requirements for weld rod caddies. The inspector reviewed a report by the Authorized Nuclear Inspector dated February 26, 1980 wherein 20 caddies had been i
checked to verify ~ temperatures. The highest reading was 158 F and the lowest was 133 F.
The inspector also reviewed Technical Services Instruction No. 008, " Weld Rod Caddy Temperature Monitoring" to be done in accordance with BTS 402, Revision 14, dated which requires that minimum of 20 caddies be checked per month. This item is considered closed.
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(Closed) Unresolved Item (461/80-02-03) No documentation to enable verification that IE Bulletins and Circulars recommended action had-3-
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been taken. The inspector reviewed Generation Engineering Department
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Procedure No. 19, " Processing of Inspection and Enforcement (IE)
Bulletins / Circulars /Information Notices", Revision 0, dated February 20, 1980 and IE Bulletins, Circulars, and Information Notices status sheet dated February 21, 1980. The inspector determined that the systein for tracking IE Bulletins, Circulars, and Information Notices was acceptable.
This item is considered closed.
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Section I Prepared by:
K. R. Naidu Reviewed by:
D. W. Hayes 1.
Review of Quality Assurance Procedures for Electrical Components and Instruments The inspector reviewed the following procedure's and determined that they were acceptable:
Procedure BAP 2.3 titled, " Receiving and Issuance" which spec-a.
ifies the requirements for receipt inspection.
b.
Procedure BAP 2.4 titled, " Storage and Maintenance" which outlines the requirements for storage levels A, B, C, and D.
Provisions to obtain special storage requirements for special equipment are available.
c.
A " Raceway Card" is used to determine the installation of cable raceways with provisions to reference the relevant drawing. QC inspectors use an installation inspection check-list to document the results of the inspection whcich include the following:
(1) Identification of the raceway / conduit at 15' maximum intervals.
(2)
Installation meets the drawings.
(3) Proper size and type of the raceway including the support.
(4) Torquing of the bolts meets the requirements specified in S&L Specification K-2999; for eg. recommended torque for 3/8" diameter bolt is 19-25 foot pounds.
(5) Installed raceway is grounded.
The implementation of the raceway inspection checklist could not be verified because inspections were not completed.
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No items of noncompliance were identified.
2.
Observation of Installed Electrical Equipment The inspector observed safety related 4.16KV switchgear stored a.
in an enclosed warehouse. The housekeeping in the warehouse-5-
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was acceptable. The switchgear is to be installed as per
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Westinghouse drawing 3711A70 " Mounting" details for 4.16 KV seismic applications which include the following details:
(1) Foundation support for attaching the switchgear.
(2) Foundation support for propping the switchgear.
(3) Foundation finished floor line for circuit breaker roll out under switchgear.
(4) Foundation rough floor line.
(5) 0.500-13 SAE grade bolts are to be used at specified intervals to hold down the switchgear.
Sargent & Lundy (S&L) drawing E05-1005 "4.16 KV Switchgear" provides the base mounting details.
A traveller was being finalized to reflect the installation sequence and the QC inspection hold points. The inspector verified that the installed 'U' channels to which the switch-gear would be bolted met the general requirements of the drawing.
b.
The inspector observed that several non-safety related 480V unit substations (480V US) and 480 volt motor control centers (480V McC's) had been installed. Safety related 480V US and 480V MCC's are currently being stored in an enclosed warehouse in an acceptable manner. To ensure that adequate instructions and drawings exist to install the safety related switchgear in the near future, the NRC inspector verified whether the in-stalled switchgear met the drawing requirements. The S&L drawing E05-1200 sheet 2, " Electrical Installation General Note and Details for 480V Switchgear" shows the switchgear to be welded to the embedded angle. A note reads, " Plug weld all holes" and references the manufacturer's (ITE) drawings which show four holes at the bottom of the switchgear, two each the front and rear of the base of the switchgear. The note, which is the only instruction / specification, which should have translated the requirementsof the Preliminary Safety Analysis Report (PSAR) does not specify the American Welding Society (AWS) code to be used for qualifying the Weld Procedure Spec-ification (WPS) and for inspecting the welds. The Clinton PSAR in paragraph 3.8.5.2 on page 3.8-39 titled, " Applicable Codes, Standards and Specifications" refers to Table 3.8-4 which on page 3.8-61 lists the AWS Dl.1-72 for structural welding. The NRC inspector accompanied by licensee personnel visually inspected the 480V US in the warehouse and established that there were:
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In the Front Base of the Cubicle
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.Two 7/16" square holes Two 3/4" diameter holes The above holes can be welded to the embedded 3" wide angle below the cubicle.
Two 3/4" diameter holes with it's center 2 3/4" from the front of the cubicle.
In the Rear of the Cubicle Two 3/4" diameter holes which could be welded to th* 3" wide angle embedded below the switchgear to the embeddes ngle iron.
One protection cover on one non-safety related 480V US was removed and the NRC inspector along with the contractor's personnel observed that the two 7/16" square holes including the two 3/4" round holes in the front of the cubicle and the two 3/4" holes in the rear of the cubicle were welded to the embedded angle. The section of the cubicle with the trans-former was attached to the embedded angle with a fillet weld and appeared acceptable. The inspector informed the licensee that the manufacturer's recommendations were not clear and the S&L drawing did not specify the exact number of holes which should be welded to the embedded angle. Furthermore, the inspector stated that "Plugwelding" 3/4" diameter holes is not acceptable according to paragraph 2.8.2 of the American Welding Society (AWS) Code D1.1 - 72 which states, "The minimum diameter of the hole for a plug weld shall be no less than the thickness of the part containing it plus 5/16" (8mm) preferably i
rounded to the next greater odd 1/16" (1.6 mm). The maximum diameter of the hole for a plug weld shall not be greater than 2 1/4 times the thickness of the weld.
Summarizing, the inspector informed the licensee that the following examples were contrary to the requirements of Criterion III of 10 CFR 50, Appendix B.
(1) Failure to ensure that Sargent and Lundy, the Architect Engineer provided accurate instructions as to the number of holes which should be welded to the embedded angle.
(2) Failure to ensure that the AE translated the PSAR re-quirements stated in paragraph 3.8.5.2 by specifying the AWSD1.1-72 code for welding and inspection critieria in the drawings / instructions.
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One item of noncompliance was identified in the above area.
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(50-461/80-04-01) Infraction 3.
Review of QA Records The inspector reviewed the QA records relative to 4.16KV switchgear identified as 1A1 and 1B1 supplied by Westinghouse. The records consisted of the following:
a.'
Receipt' Inspection Records (RIR) No. S-6889 dated July 10, 1979 and S-6747 dated June 25, 1979 indicate that safety related switchgear 1A1 and IB1 were received on site with acceptable documentation. Nonconformance Report (NCR) No.
2251 was generated to document that in
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cubicle in 1A1 switchgear the high voltage shield sticks in the 'up' posi-tion. NCR No. 2196 indicates that in cubicle in IB1 switch-gear, the high voltage shield sticks in the 'up' position and that some of the welds were not painted.
b.
A certificate of compliance from Westinghouse indicates that 4.16 KV switchgear 1A1 and IB1 was designed, manufactured, inspected, and tested in accordance with S&L Specification K-2968.
c.
Certified Test Reports dated February 21, 1970 indicate that switchgear IAI and IB1 were tested to Westinghouse Test Spec T-347888G and included the following tests:
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(1) SKV bus was tested at 19KV.
(2) Equipment and circuits at 60 volts or below received insulation test of 500 volts 60 cycles for one minute.
(3) All other equipment received 1500 volts, 60 cycles for one minute.
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d.
Current transformer test reports dated August 9, 1978 indicate the primary / secondary ratios, the insulation test, 400V induced potential and 50 Hertz excitation at 10 amperes.
e.
Voltage transformer test reports May 22, 1979 indicate that the ratio tests were performed; insulation tests high voltage to low voltage 19000 volts in sixty' seconds, low voltage to core
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2500 volts for sixty seconds.
f.
Two source inspections were performed on February 27, 1979 and June 5,.1979 at the Westinghouse East Pittsburgh facility where the 4.16KV switchgear was manufactured. The inspection
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reports indicate that several tests were witnessed by the inspectors. 'Several discrepancies were documented.
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reported that' corrective action was initiated. During receipt
inspection on site, the switchgear was reinspected to verify that the discrepancies identified during the source inspection were corrected; NCR's were generated documenting instan.ces where the deficiencies were not corrected such as the high voltage shields sticking open in two cubicles. Environmental and seismic qualificatica records are being reviewed by S&L and will be sent to the site after completion.
No items of noncompliance were identified in the above area.
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Section II Prepared by:
K. D. Ward Reviewed by:
D. H. Danielson, Chief Engineering Support Section 2 Review of Safety Relief Valve Radiographs On site there are 24 valves with approximately 80 film per valve. The
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valves were to have been radiographed in accordance with ASME Section III, 1974 Edition, Winter 1976 Addenda and Dikkers Radiographic Procedure EB-0940101 Revision 6, approved by G.E. June 21, 1977. The radiography was performed by G. Dikkers and Company, N.V. in Hengelo, Netherlands.
The licensee's P. O. states that the valves were to be in accordance with ASME Section III, 1974 Edition Summer 1976 Addenda.
Illinois Power Company requested an informal review of the radiographs by Baldwin Associates. Two Level II and one Level III in radiography reviewed all radiographs, 100% on all 24 valves. The Level III and the Level II present while the RIII inspector was on site informed the inspector that their findings were basically the same as his on all 24 valves and that they did not meet the Code. The procedure for per-forming the radiography was not on site but was in San Jose, California at G.E.
The inspector reviewed the radiographs on assembly No. 160792, Part No. 08.24.8/2, Cap No. 11.278/3, Liner 64.078/1, Cover 55/178/1, and Disc No. 62.16.8/4B.
The following discrepancies were found in ap-proximately 25% of the radiographs reviewed.
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Density down to.6 and up to 6. plus.
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The -15+30% density requirements were not met.
(G.E. also agreed that item 1. and 2. were found in the radiographs and did not meet the Code.)
3.
Areas were not masked, therefore the thin edges were burned out and could not be read.
4.
Because of where the location markers were located and the density, it'was impossible to verify that the valves were radiographed 100%.
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In some areas, a small area approximately 4" x 4" would be radio-graphed with lead location markers, lead ID markers, and the pen-etrameters all in the area offof interest, although there would have been room to locate all the information on a block adjacent to'the piece which would have helped mask the area of interest.
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There were areas where the penetrameters were larger than the original size because of the unacceptable geometric unsharpness.
7.
Some areas had a penetrameter in a radiograph that was smaller than required, indicating that the penetrameters were film side penetra-meters, and there was no lead "F" identifying that the penetrameter was really film side.
8.
There were several artifacts, scratches, dents, crimps, etc.
9.
Films were missing not covering certain areas of interest, although the Dikkers reader sheet stated that area of interest was acceptable.
10.
When errors were made on the identification of the radiograph a grease pencil was used to mark out the mistake. The marking could be removed very easily.
11.
There were repairs made but there were no original radiographs or a record of the number of repairs made.
A meeting was held April 3, 1980, at the NRC Headquarters in Bethesda, Maryland between GE and NRC to discuss the radiographs of the Dikkers safety relief valve castings.
The licensee informed the personnel pre-sent that no defects were found, two or four films out of 80 for each valve could not be read and no position at this time has been made..This is contrary to the information that the inspector received at the site.
At the conclusion of the meeting, the NRC informed the personnel present that each licensee would have to supply to NRR, a report justifying the acceptability of each valve.
This is an unresolved item pending review by NRR.
(50-461/80-04-02)
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Section III Prepared by:
H.~M. Wescott Reviewed by:
R. C. Knop, CLief Projects Section 1 1.
IE Bulletins, Circulars, Follow-Up The inspector reviewed IE Bulletins and Circulars to verify that they were received by the licensee and reviewed and took appropriate action, as follows.
IE Bulletins 76-06 " Diaphragm Failures in Air Operated Auxiliary Actuators for SRV's".
The status sheet indicates that SRV's for Clinton Power Station do not have diaphragm operators, dated March 24, 1980.
1 78-03 " Potential Explosive Gas Mixture Accumulations Associated
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With BWR Off Gas System Operations". The status sheet states that Clinton Power Station has the latest design per AID 43-79 (which covers this bulletin),' dated March 24, 1980.
78-09 "BWR Leakage Paths Associated With Inadequate Drywell Closure".
The status sheet states that when procedure is drafted, the bulletin actions will be considered for inclusion, dated March 11, 1980.
78-14 " Deterioration of BUNA-N Components in ASCO Solenoids". The status sheet indicates that this item has been turned over to opera-tion (open.)
79-05 " Nuclear Incident at Three Mile Island Unit 2".
(TMI Supplements).
79-08 "TMI Events Relevant to BWR's".
The licensee has established a TMI task force to comply with TMI Bulletin requirements (details of actions engineering changes etc. handled by the task force). The licensee is also a participating member of TMI BWR owners group.
79-12 "Short Period Scrams at BWR's".
The status sheet indicates that action is underway with GE operating procedures addressing these matters as will operator training.
79-13 " Cracking in Feedwater System Piping". This bulletin applies
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to PWR's.
The status sheet discusses pipe crack problems peculiar to BWR's.
79-17 " Pipe Cracks in Stagnant Borated Water System at PWR's".
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79-21 " Temperature Effects on Level Measurements". This applies to
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PWR's only. BWR's'were to respond to a separate letter on the subject.
Letter was sent out in July 1979.
79-24 " Frozen Lines". The status sheet indicates that all lines, equipment, or tanks are buried or otherwise freeze protected.
IE Circulars 77-01 " Malfunction of Limitorque Valve Operators". The status sheet' indicates that areas of concern will be addressed in operat-ing procedures:and-in general housekeeping procedures.
77-05 " Liquid Entrapment in Valve Bonnets". The status sheet states that, forwarded to S&L by S-1554 dated May 9, 1979. Subsequent telecons indicates they were using as design input.
77-10 " Vacuum Conditions Resulting in Damage to Liquid Process Tanks".
This item remains open.
77-11 " Leakage of Containment Isolation Valves". The status sheet indicates that this has been evaluated.
Specification requirements
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for butterfly valves and dampers satisfy concerns. CPS maintenance made aware of long term problem potential.
77-12 " Dropped Fuel Assemblies at BWR's".
Action started. This item open.
78-13 "Inoperability of Service Water Pumps".
The status sheet states that we have a warming line and operating procedures to prevent this condition.
78-14 "HPCI Turbine Reversing Chamber Hold Down Bolting". The status sheet indicates that IPC does not have HPCI turbine.
78-15 " Tilting Disc Check Valve Failures". The status sheet states, refer to letter 5-2746 dated March 10, 1980 to S&L requesting in-formation.
78-16 "Limitorque Valve Actuators". This item turned over to engineering and operations. No action at this time.
78-19 " Manual Override (by pass) of Safety System Actuation Signals".
. The status sheet indicates that, a review of design will be made to determine if problem could exist for CPS.
79-04 " Lose Locking Nut on Limitorque Valve Operators". This item remains open.
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79-05 " Moisture Leakage in Standard Wire Conductors". The status sheet indicates that the AE is investigating problem relative to transmitters and motors.
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79-07 " Unexpected Speed Increase of Reactor Recirculating System
M-G Set".
The status sheet indicates this is not applicable as CPS has single speed M-G set incorporating a flow control valve.
79-10 "Pipefittings Manufactured from Unacceptable Material"'. The status sheet states, see letter RLN-59-77 dated July 14, 1979. We have none of the affected fittings.
79-11 " Design / Construction Interface Problem". The status sheet states, we have adequate communications in the form of specified drawing reviews as evidenced by our equipment fittings.
In addi-tion, our units are not mirror image units. They are nearly identical as practical.
79-12 " Potential Diesel Generator Turbocharger Problem". The status sheet indicates no feedback as yet.
79-13 " Replacement of Diesel Fire Pump Starting Contactor". The status sheet indicates that the new switch has been ordered and the technical manual has been updated.
79-18 " Proper Installation of Target Rock SRV's".
CPS does not employ target rock valves.
79-19 " Loose Locking Devices on Ingersoll Rand Pumps".
The status sheet indicates that CPS uses Byron-backson pumps.
79-22 " Stroke Time
..er Operated Relief Valves". For PWR's only.
79-23 " Motor Starters and Contactors Failed to Operate". The status sheet indicates not applicable.
79-24 " Proper Installation and Calibration of Core Spray Pipe Break Detection Equipment on BWR's".
The status sheet indicates that this is a GE generic problem. Fix has been recommended. Applicability to CPS will be determined and appropriate action taken.
No items of noncompliance or deviations were identified in this area of the inspection.
2.
Review of QA Records-Installation of Reactor Vessel
.The inspector reviewed quality related records relative to reactor vessel installation to ascertain that the records reflect accom-plishment consistent with NRC requirements and PSAR commitments, as follows:
a.
Completed Check Lists (1) Erection of Eantry crane, Procedure 101, Revision 2.
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(2) Hoist checkout, Procedure 106, Revision 1.
(3) Verification of test weights.
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(4) Procedure for 762 ton load test of gantry crane at the containment building, No. 102, Revision 3.
b.
Procedures (1) RPV from the construction pad to a position beneath the containment gantry crane No. 104, Revision 3.
(2) Setting the RPV in it's, final-position in the containment building, No. 103.
c.
Magnetic Particle Test Report, U.S. Testing Company, Inc.
(1) Shackle pin and shackle.
(2) Lifting device.
(3)
U.T. examination of welds, gantry crane structures.
d.
Mechanical Report No. 2389, Dated Octcber 12, 1979 Cleaning of i
e.
NDE Personnel Certification Record, U.S. Testing Company, Tr.
f.
NCR No. 2723 w/ letter from S&L (SLS-I-2408) concerning qua.stion-able tensioning of reactor tie down bolts.
g.
Northwest Testing Laboratories Materiel Certification for Bolting Material dated April 16, 1979, ASME SA540, Grade 423,
Class 4, E4340-Hsteel test bar, Heat No.
65263.
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Baldwin Associates Document VA-2, nevision 1, dated Septesber 6, i
1979, Vessel Alignment for RPV on Pedestal.
Exit Interview The inspectors met with licensee representatives (denoted by an asterick and Persons Contacted) at the conclusion of the inspection on Marr.h 27, 1980. The inspectors summarized the purpose and findings of the inspec-tion. The licensee acknewledged the information.
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