IR 05000461/1985056

Insp Rept 50-461/85-56 on 851022-25,30-31 & 1125-27. Violation Noted:Failure to Perform Required Seismic Design Evaluation/Review Per IE Bulletin 79-14

ML20138R331
Person / Time
Site:	Clinton
Issue date:	12/27/1985
From:	Danielson D, Kaufman P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138R315	List: IR 05000461/1985056 ML20138R313 ML20138R323
References
50-461-85-56, IEB-79-14, NUDOCS 8512310180
Download: ML20138R331 (6)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/85056(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company 500 South 27th Street Decatur, Illinois 62525 Facility Name: Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, Illinois Inspection Conducted: October 22-25, 30, 31, and November 25-27, 1985 b7L0w k

/2h7/dT Inspector:

P. D. Kaufman p

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Approved By:

D. H. Danielson, Chief

/h27)W Materials and Processes Section Date

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Inspection Summary

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Inspection on October 22-25, 30, 31, and November 25-27, 1985 (Report No. 50-461/85056(DRS)

Areas Inspected: Routine, unannounced safety inspection of the implementation of actions set forth in IE-Bulletin 79-14, and followup on previous inspection findings. The inspection involved a total of 60 inspector-hours onsite by one NRC inspector, including 12 inspector-hours of in-office review.

Results: Of the areas inspected, one violation was identified (failure to perform required seismic design evaluation / review - Paragraph 4.b).

8512310180 851227 ADOCK 050 g 1 PDR

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

• D. Hall, Vice President

• J. D. Palmer, Director, Configuration Management

• J. Loomis, Construction Manager

• D. G. Tucker, Lead Commitment Control Engineer

• H. Daniels, Jr., Project Manager

• D. C. Shelton, Manager, NSED

• H. R. Lane, Director, Design Engineering

• J. Perry, Manager, Nuclear Program Coordinator

• K. A. Baker, Acting Supervisor, I&E Interface

• F. S. Spangenberg, Manager, Licensing & Safety

• W. Connell, Manager, Quality Assurance

• S. R. Bell, Supervising Engineer Baldwin Associates, Inc. (BA)

L. Campbell, Techiiical Assistant /TPRG R. W. Greer, Manager, Q&TS P. Adams, QC Inspector, P/M J. DeVine, Assistant Piping Engineer R. Neeb, Senior Piping Engineer J. Poulos, Senior Engineer, B0P

• J. Thompson, QE Manager

• E. P. Rosol, Project Manager C. L. Solter, TPRG Engineer B. S. Auer, Technical Assistant /TPRG Sargent and Lundy Engineers (S&L)

• D. Schopfer, Project Site Manager S. Raupp, Structural Engineering Supervisor P. Odisho, Project Engineer, EMD R. Suslick, Project Manager J. Blattner, Mechanical Engineering Supervisor Stone and Webster Engineering Corporation (S&W)

P. H. Seidel, Manager, TPRG

• Denotes those attending the exit meeting on November 27, 1985.

2.

Licensee Action on Previous Inspection Findings (Closed) Violation (461/84-28-01): Failure of QA/QC to observe and document nonconforming conditions relative to pipe support structural attachments to expansion anchor base plates. The NRC inspector reviewed

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Field Engineering Change Notice (FECN) 7048, which was issued to provide additional tolerances for double attachments to baseplates. The required training given to BA's piping / mechanical inspectors in FECN 7048 tolerances was examined by the NRC inspector. Additionally, the licensee conducted a 100 percent reinspection of all pipe supports with double attachments to baseplates, since a sufficient number of discrepancies were identified

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with double attachments to baseplates during the sampling plan reinspection program.

3.

Licensee Action on IE Bulletins (Closed) IE Bulletin 79-14, Revision 1, Revision 2, and Revision 3 (461/79-14-8B,461/79-14-1B,461/79-14-2B,461/79-14-38):

" Seismic Analysis for As-Built Safety-Related Piping Systems." The licensee has responded to the bulletin, and the bases for closure of the bulletin is contained in Paragraph 4 of this report.

4.

IE Bulletin 79-14 Activities The implementation and verification of the licensee's as-built program as related to IE Bulletin 79-14 requirements was recently reviewed by the NRC Construction Appraisal Team.(CAT). Results of the inspection are documented in RIII Inspection Report No. 50-461/85030. The attributes examined during the CAT inspection and this inspection that are essential to the seismic piping stress analysis included:

piping configuration; pipe

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support / restraint locations, design, function, and clearances; and valve and valve operator locations and orientation. Assessment of these attributes was required to verify that the safety-related piping systems were constructed and seismically analyzed in accordance with the final design documents /rcquirements.

a.

Review of Walkdown and Engineering Evaluation Procedures The licensee's procedures, specifications, and instruction drawings relative to the generation and reconciliation of the safety-related piping systems' as-built design documents reviewed by the NRC inspector included the following:

IP Nuclear Station Engineering Department Procedure (IPNSED) D.3,

"N-5 Data Report Preparation and Certification," Revision 4.

IP Nuclear Station Engineering Department Procedure D.4, " Review of Design Documents for ASME,Section III, Piping," Revision 8.

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BA Procedure (BAP) 2.17, " System /Sub-System Turnover,"

Revision 11, Change D.

BA Procedure (BAP) 1.3, " Code Reports and Nameplates,"

Revision 4, Change C.

IPNSED Procedure B.3, " Review of Stress / Design Reports, Revision 1.

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IP Corporate Nuclear Production Procedure CNP 2.02, " Stress

Reports (NS-3260) N-5 Forms," Revision 1.

BA Procedure (BAP) 3.2.5, " Piping Component Supports,"

Revision 8, Change E.

BA Procedure (BAP) 2.14 " Fabrication / Installation of Items, Systems, and Components," Revision 11, Change D.

BA Procedure (BAP) 3.2.9, "79-14 Verification Program, Revision 1.

Sargent and Lundy Engineers (S&L) Project Instruction PI-CP-028,

" Field Installation Data Required to Pemit Confirmation of Piping Subsystem Analysis," Revision 2.

S&L Project Instruction PI-CP-030, " Preparation and Review of Piping Document Packages," Revision 2, Procedural Deviation PD No. 65.

S&L Quality Assurance Manual, GQ-3.08, " Design Calculations,"

Revision 5, Notification No. 084, dated July 31, 1985.

The procedures, specifications, and instruction drawings were determined to be consistent with regulatory requirements and licensee commitments relative to IE Bulletin 79-14, " Seismic Analysis for As-Built Safety-Related Piping Systems."

No violations or deviations were identified.

b.

Safety-Related As-Built Piping System Walkdown Portions of piping systems were randomly selected for assessing the adequacy of the licensee's as-built walkdown inspection and design verification program. The NRC inspector's review only encompassed as-built subsystem packages from the following two safety-related piping systems, since the CAT inspection was just recently completed:

System Title Subsystem No.

Residual Heat Removal System 1RH-13, Revision 9L Low Pressure Core Spray System 1LP-03, Revision 12L The as-built subsystem walkdown packages were comprised of, but not limited to, the following documents / drawings:

Sargent and Lundy Engineers (S&L) Support Design Drawings Contractor Piping Fabrication Isometric Drawings S&L Analytical Drawings S&L P& ids (M05 series drawings)

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Any outstanding design change documents - (FCRs, DRRs, ECNs,

FECNs, DRRs, and NCRs)

The NRC inspector conducted system as-built verification walkdowns of the following assembled documentation / drawings selected from the above two safety-related piping systems.

Pipe Support / Restraint Drawings ILP-3001R ILP-3010R ILP-3002R ILP-3011X ILP-30035 ILP-3012X ILP-3004X ILP-3013X 1LP-3005R 1LP-3014R ILP-3006S ILP-3015S 1LP-3007R ILP-3016S ILP-3008G ILP-3019R ILP-3009X-1RH-16036X 1RH-160355 1RH-16031X 1RH-16022X 1RH-16020R 1RH-16021R 1RH-16034S 1RH-16023X Piping Layout Isometric Drawings M06-1075, Sheet 2, Revision AL M06-1075, Sheet 3, Revision R M06-1075, Sheet 24, Revision Z M06-1075, Sheet 14, Revision V M06-1075, Sheet 18, Revision AB M06-1073, Sheet 1, Revision AK M06-1073, Sheet 2, Revision AA M06-1073, Sheet 3 Revision AA Process and Instrumentation Diagram (P&ID) Drawings M05-1075, Revision U 4 inch RHR line No. 1RH19AA and 1RH19BA from 14 inch line No. IRH02AA to 6 inch line No. 1RH27C.

M05-1073, Revision U 20 inch LPCS line No. ILP01B from penetration IMC-32 to LPCS pump 1E 21C001.

In general, the installed / erected piping runs and supports inspected were found to be constructed in accordance with the applicable design drawings and procedural requirements for the attributes verified.

However, while conducting the as-built verification walkdowns the NRC inspector observed a mechanical snubber raar bracket for pipe support 1RH-160355 welded to the yoke of ASME Code Class 2, Anchor / Darling Limitorque valve number 1E12-F064A.

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The licensee was requested to-compile the latest design / installation documentation relative to this particular pipe support. The Sargent and Lundy (S&L) support design Revision F to the drawing was coninen-surate with the as-installed support configuration. The licensee and S&L were then queried as to whether the valve manufacturer was cognizant of this added appurtenance to their seismic qualified safety-related component. The NRC inspector was presented copies of the S&L and Anchor / Darling correspondence, which permitted the snubber attachment to the valve yoke.

Upon further review into the seismic design qualification calculations to justify this modification to the valve, which is tabulated in Table 3.9-5 of the FSAR as a Balance of Plant (EOP) safety-related mechanical " active" valve, the NRC inspector determined that neither S&L nor Anchor / Darling had performed the required seismic or operability analysis / evaluation to requalify the " active" valve with the added attachment to assure that proper operation of the component would still be maintained and verify that the stresses of the component would be less than the allowable stress requirements permitted by the ASME Boiler and Pressure Vessel Code,Section III.

The licensee was informed that failure to verify plant design to design requirements, as specified in the FSAR and Project Design Criteria, is a violation of Criterion III of 10 CFR 50, Appendix B (461/85056-01).

5.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

on November 27, 1985 and discussed the scope and findings of this inspection. 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 proprietary,

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