IR 05000461/1985063
| ML20137E067 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/10/1986 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137E025 | List: |
| References | |
| 50-461-85-63, NUDOCS 8601170158 | |
| Download: ML20137E067 (26) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/85063(DRP)
Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525
- Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: November 18 through December 16, 1985
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Inspectors: T. P. Gwynn P. L. Hiland D. E. Keating J. F. Schapker F. J. Jablonski
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Approv;d By: T. P. Gwynn, Chief Reactor Projects Section 1B
/-/0-8b Date Inspection Summary Inspection on November 18 through December 16 1985 (Report No. 50-461/05063(DRP))
Areas Inspected: Routine safety inspection by resident and regional based inspectors of construction and preoperational testing activities including applicant action on previous inspection findings; review of 10CFR21 reports; review of 10CFR50.55(e) reports; employee concerns; review of allegations; fDR A DR G
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- functional or program areas (including site surveillance tours, administrative procedures review, operational staffing, and installation of safety related
' components); regional requests (including use of licensed reactor operators in
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l supervisory positions,. record verification program termination request, and structuralJsteel overinspection scope review); independent inspection effort
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- (emergency plan dress rehearsal exercise); and site activities of interes L The -inspection involved 267 ; inspector-hours onsite by three resident and two regional based ~ inspectors including 10 inspector hours onsite during off shift Results: Of the 14 areas inspected, one-violation was identified. The violation involved failure to follow procedures for control of construction drawing changes. The violation was not safety significant since no plant hardware was affected and it appeared to be an isolated document control proble . ,
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DETAILS l i
1. . Personnel Contacted Illinois Power Company D. - Antonelli, Director - Plant Operations
, G. Bell, Director, Construction and Procurement Quality Assurance (QA)
B. Calhoun,-Quality Projects Coordinator, IP QA R. Campbell, Director - Quality Systems and Audits, QA
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E. Corrigan, Director - Quality Engineering and Verification, QA
- H. Daniels, Project-Manage ' L. Davis, ' Supervisor, Document Control, Nuclear Support (NS)
. *S. Fisher,. Manager, NS L*W. Gerstner, Executive Vice President ~
J. Greene, Manager --Startup (SU)
- Hall, Vice President, Nuclear D. Holesinger, Director - Startup Test, SU
- D.' Holtzscher, Director - Safety Analysis, Licensing and Safety (L&S)
J.JJones, Supervisor - Mechanical Maintenance E..Kant, Assistant Manager, Nuclear Station Engineering (NSE)
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J. Loomis, Construction Manager
- J. Miller, Director - Startup Programs, SU R.;Morgenstern, Director - Plant Technical H. Nodine, Supervisor, Control and Instrumentation
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J.'Palchak, Supervisor - Plant Support Services
- J. Perry, Manager - Nuclear Program Coordination
.S. Rasor, Supervisor - Construction QA S. Richey, Director - Maintenance
- R. Schaller, Director - Nuclear Training
-*D. Shelton, Manager - NSE F. Spangenberg, Manager - L&S
- J. Wilson, Manager - CPS F. Worrell, Supervisor - Plant Operations
.Baldwin Associates (BA)
M. Daniell, Manager, Technical Services B. Fraser, NDE Engineer, Level II R. Greer, Manager - Quality and Technical Services E. Rosol, Project Manager D. Selva, QA Engineer
- J. Thompson, Manager - Quality Engineering Soyland/Wipco J. Greenwood, Manager - Power Supply
- Denotes those attending the monthly exit meetin ,
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The inspectors also contacted others of the construction project and operations staff .- Applicant Action On Previous Inspection Findings (92701/92702) (Closed) Violation (461/85030-03): The NRC Construction Appraisal Team (CAT) identified vendor procured tanks and heat exchangers that had been accepted and installed with deficient welds. CAT also identified various vendor and contractor supplied radiographs which did not have the required weld or film qualit The' inspector reviewed and verified the corrective actions described in IP Letter U-600282 to'NRC dated September 30, 1985, including inspection and nonconformance report dispositions generated to resolve the discrepancies. The inspector reviewed radiographs and respective radiographic reader sheets for the contractor supplied radiographs which did not have the required weld or film qualit The ' applicant's corrective action dispositions were adequate to resolve the ASME code deficiencie The applicant's corrective action to prevent recurrence was also reviewed including the Maintenance Request Program which adequately prescribed the necessary procurement requirements, review of required documentation, and receiving inspection of nuclear parts and equipmen This item is close No violations or deviations were identifie (Closed) Unresolved Item (461/85032-02): Skewed socket weld engagemen Inspection Report No. 50-461/85032, paragraph 5, documented the inspection of allegation RIII-85-A-0116 dealing with socket weld fitup. Two items of concern were left as one unresolved item, as follows:
-(1) Will socket weld fitup with angularity approaching 10 degrees compromise the integrity of the socket weld by " bottoming out" the pipe in the socket (similar to a fully engaged socket)
thereby resulting in potential cracking of the weld during the weldment cooling / solidification process? The inspector noted that the socket welds in question were generally ASME Class 3 which do not require nondestructive examination (other than a final visual inspection).
(2) What is the source document (code or standard) which permits angularity greater than the normal tolerances of piping inserted into the socket?
The inspector reviewed the applicant's report and architect engineer's evaluations concerning socket weld angular engagements (Attachment 3).
The inspector also reviewed seven radiographs of worst case examples ,
of misaligned socket welds (this review included inspections of the l
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I socket radiographs for evidence'of. grinding to facilitate fit up of !
- the_ skewed socket welds), performed visual inspection of one hundred '
randomly selected socket welds, reviewed the applicant's inspection ;
-reports of the 1171 socket welds referenced in Attachment 3, and concluded that skewed socket engagement does not pose a code or safety
~v iolation. .No evidence of grinding the sockets was observed. This item is close Additional concerns were provided~concerning socket welding and are addressed in paragraph 6c. of this repor No violations or deviations were identifie ' (Closed) Open item (461/85032-01): Review of two CPS Condition Reports revealed conditions which appeared to be similar to conditions previously_ reported by IP under 10CFR50.55(e). The condition reports were about the control of design change documents, and had not been dispositioned at the time of the inspection. This item was opened to provide for review of the dispositioned condition report .The inspector reviewed corrective actions taken as a result of condition reports 1-85-01-085 and 1-85-01-088. Design change controls have been up graded. The' corrective actions appeared to be appropriate for the conditions reported. In addition, the conditions were reviewed by IP for reportability under 10CFR50.55(e)
.and were found to be not reportable. This item is close No violations or deviations were identifie (Closed) Violation (461/85042-03): Controls for identifying and evaluating potential interactions involving electrical separation violations were not adequately proceduralized in Sargent & Lundy
'(S&L) Procedure PI-CP-034, Revision The ~ inspector reviewed the applicant's response to the Notice of
' Violation described in IP letter U-600285 to NRC dated October 18, 1985, and verified the following corrective action to the identified
' deficiencies:
(1) Advance Procedure Change (APC) No. 5 to Nuclear Station Engineering Department (NSED) instruction ME-2, Revision 0, revised'the Potential Interaction Report (PIR) form to include assignment of electrical separation reports to the S&L responsible division (EPED).
-(2) S&L instruction PI-CP-034 was changed in Revision 5 to delineate the requirement for the Electrical Department to reference the calculation number used in dispositioning PIRs (reference PI-CP-034, Revision 5,. paragraph 4.2.1.4). The inspector reviewed PIR No. L-57 and L-63, both dispositioned December 11, i 1985, and verified that reference to the calculation number was annotated on the PIR.
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(3) S&L instruction PI-CP-034, Revision 5, paragraph 4.2. delineates the provision for dispositioning PIRs by electrical analysi (4) S&L instruction PI-CP-034, Revision 5, paragraph 4.2. delineates the technique when dispositioning more than one interaction. The inspector noted that PIR No. L-57 and L-63 documented multiple interactions which received different dispositions in accordance with the revised procedur The inspector verified that corrective action, as stated in the applicant's response to the Notice of Violation, was complete This item is close No violations or deviations were identifie . Review of 10CFR21 Reports (92716) (Closed) Part 21 Report (461/80002-PP/IP #21-80-04): Potential for Reactor Protection System to not complete its protective function if flexible conduit is not properly grounded. Failure to provide an adequate ground path for flexible conduit could prevent fuse operation from short circuits and thereby prevent the fail safe function, de-energized to operate, of the Reactor Protection Syste The inspector reviewed General Electric (GE) Field Disposition Instruction (FDI) SKJC, Revisions 0 and 1, which described the actions necessary for grounding the conduits. The inspector also reviewed IPQA Surveillance Report Q24-82 (1-13)-L conducted to verify implementation of the FD As a result of the surveillance, Nonconformance Report (NCR) 6156 was writte The NCR was disposi-tioned, implemented, and reinspected. Region III inspection of conduit grounding activities is documented in Inspection Report No. 50-461/8302 This matter is close (Closed) Part 21 Report (461/81001-PP/IP #21-81-04): Installation of incorrect reactor vessel water level transmitters and trip unit The inspector reviewed records of the actions taken to resolve this problem. The inspector also observed that the four installed reactor vessel water level transmitters, B21-N080 A, B, C and D, were Rosemount Model 1153DB4P Those transmitters were narrow range, 0-150 inches of water, and environmentally qualified as require This matter is close (Closed) Part 21 Report (461/83005-PP/IP #21-82-11): Okonite cable oil leakag The inspector reviewed records of the actions taken to resolve this matter. This Part 21 report resolution was previously reviewed by the inspector. The resolution was rejected by the inspector because
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an engineering evaluation had not been made to show that there was l no possibility for misoperation of Class 1E equipment if the Okonite
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cable ends were not sealed as recommended by the manufacturer. IP Memorandum HRL-432-85 indicated that there was no interface between
. Class 1E equipment and the cables with an oil seepage problem. The
!- inspector had no further questions about this item. This matter'is-closed.
n (Closed) Part 21 Report (461/83006-PP/IP #21-83-09): Automatic l Depressurization System (ADS) digital signal conditioner card fuse l
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Fuse failure occurred during Construction and' Initial Operation ,
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(C&IO)_ testing of the ADS syste The inspector reviewed records of the actions taken to resolve this matter, including GE Field Deviation Disposition Request (FDDR) LHI-777 Revision 2, which
~ described the actions performed by GE to correct the fuse failure The FDDR final disposition stated that no site QA was required ,
because the work was completed in San Jose. The work done by GE
, in San Jose was to include a test of each affected circuit card by
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the Terradyne card tester according to IP letter U-10091 sent to NRC on September 19, 198 IP audit Q33-84-05 was supposed to verify that the Terradyne tests were performed; however, due to time and manpower restraints, the tests were not evaluate Since-the fuse failure occurred during C&IO testing of the ADS system the inspector asked to see_the results of the ADS C&IO tests made subse-quent to the GE changes. The test results of PTP-N8-02 concluded that the function / operation of the circuit cards was satisfactor On this basis, the inspector concluded that the GE repairs were satisfactory. This matter is close 'No violations or deviations were identified.
I Review of 10CFR50.55(e) Reports (92700) (Closed) 50.55(e) Item (461/84001-EE): Inadequate control of field design change dispositions between the Clinton site and the architect-engineer Sargent and Lundy (S&L). This matter was initially reported *
to the NRC January 11, 1984. On July 23, 1985, IP reported that based on their completed review of the subject, a reportable deficiency did not exist. There were no hardware deficiencies which could have adversely affected the safety of operation of Clinton Power Station.
( A review of the IP file on this matter, by the inspector, confirmed that several thousand change documents had been reviewed by IP,
! BA, and S&L. No hardware deficiencies were identified; however, i
weaknesses in the design change control program were identified which l- have been corrected. A computer data base was used to track design j drawing change documents, and revisions were made to BA and S&L l ' procedures. The inspector agreed with IP's cor.::1usion that there was L not a significant breakdown in the QA Program. Although the procedures used by IP, BA, and S&L were not coordinated, none of the l.
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, deficiencies adversely:affected the safety of operation of the Clinton Power Station. This matter is close '(Closed) 50.55(e) Item (461/84021-EE): Improper battery charger electrical lug crimp This matter was initially reported to the NRC on October 17,- 1984.On February 28, 1985, IP reported:to the NRC that-based on their completed review of the subject, a reportable
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deficiency did exist, that is, if the improper lug crimping had gone uncorrected, the battery chargers could malfunctio The inspector determined, by review of applicable records, that all
. required repair and rework was completed.for the four safety related battery. chargers supplied by Power Conversion Product Based on those repairs, the battery chargers should not malfunction because of
. improperly lugged electrical conductors. A vender representative had inspected the battery charger electrical lug crimps and concluded that the problems originated during the manufacturing process. Docu-mentation from the vendor indicated that the problem was isolated to those battery chargers manufactured in 1979 for IP and did not represent a generic problem reportable to the NRC per the requirements of 10CFR21. This matter is close No violations or-deviations were identifie . . Employee Concerns (99014)
The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period. Those concerns related to regulated activities were documented by the inspectors and submitted to Region II .Three concerns were transmitted to the regional office during this report perio . Review Of Allegations (99014) (Closed) Allegations (RIII-85-A-0079/#136; RIII-85-A-0086/#137; RIII-85-A-0095/#141; and RIII-85-A-0096/#142): Over the period April-May 1985, Region III received 46 allegations from four individuals who perceived problems with the fabrication of electrical supports or review of documentation under the Record Verification Program. On July 2, 1985, in accordance with NRC policy, Region III forwarded the 46 allegations to IP for their review and disposition (Attachment 1). Attachment 1 included Region III's expectations for IP's analysis of the allegations and outlined specific items which IP was to address during their revie Senior Region III and IP management met at the Clinton site on July 11, 1985, to discuss the allegations and IP's plan for investigating them. On October 9,1985, IP notified Region III that the investigation of the 46 allegations was completed and provided a summary of their investigation results, IP letter U-600290, for Region III's review (Attachment 2).
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NRC Review This inspection had three purposes:
(1) Review IP's overall approach to the conduct of their investigation of the 46 allegation (2) Conduct a sample inspection of the 46 allegations to determine if IP's investigation was adequate and comprehensive enough to establish the basis for Region III to conclude that all 46 allegations had been adequately investigated by I (3) Determine if appropriate action was taken by IP to address
. specific concerns and root causes of any identified problem Two inspectors reviewed IP's overall approach to the investigation of the 46 allegations. The inspectors verified that IP had accurately determined the issues, prepared and utilized individual allegation investigation plans, and utilized appropriate personnel
.to perform the investigations. The inspectors noted that one allegation (No. 11) was assigned to an individual who acted as chairman of a 10CFR50.55(e) investigation, which was the subject of the allegation. The inspectors noted that the allegation concerned implementation of required corrective action as a result of the 10CFR50.55(e) investigation; not investigation No. 11 itself. The inspectors concluded that personnel utilized to perform the investi-gations were qualified and sufficiently independent to conduct the
. investigation. In addition, the inspectors reviewed several volumes of documentation supporting IP's investigations.- The inspectors determined that IP had analyzed the 46 allegations and separated them int'o 18 generic categories. IP's investigation resulted in some allegations being fully or partially substantiated, that is, true; however, none of the conditions described by the substantiated allegations resulted in inadequate hardware or records. IP's investigation identified weaknesses in administrative controls for fabrication of electrical items and review of documentation. Those weaknesses were resolved by IP through use of established corrective action procedure In accordance with previous direction, the inspectors selected 7 of the 46 allegations for a detailed review. The selected allegations are described in Attachment 2 as " Employee Concerns" 11, 16, 22, 33, 36; 41, and 46, which included 13 of the 18 generic categories mentioned above and shown in Table 1 of Attachment 2. The inspectors determined that IP investigative techniques included review of procedures, records, and other documents; observation of hardware and work locations; and detailed, documented interviews conducted in reference to pre-established questions. The seven allegations
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reviewed by the inspectors showed that the IP investigations properly focused on the allegations, correctly established the validity and significance of the allegations, properly analyzed the allegations for similarities, and appropriately recommended corrective action where necessary. The inspectors determined that all IP identified corrective actions had been implemente . _ _ _ - _-_-__- _ _ -
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R-p" -Specific actions taken in the area of fabricating electrical supports
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included training of construction perscnnel in the controis utilized
'for items fabricated'in the electrical fabrication shop, and use of n -correct methods to document deficiencies in order to avoid circum-V venting-the established nonconformance reporting syste 'Most of the alleged improper documentation review activities occurred late in 1984 and early 1985. The problems were caused by strained
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interpersonal relationships between reviewers and supervisio Several significant management improvements have occurred in the Baldwin Associates (BA) Document Review Group (DRG) as' described below:'
- Management of the DRG was changed from BAQA to IPQA
-* Changes were made in supervisory and management personnel.within the DRG. Personnel with proven supervisory / management experience were obtained/ retained, and weak supervisors were reassigned or laid of * Second shift DRG was eliminated to enhance communications between DRG reviewers and management, pc.:: r ol o' -Methods of communications were improved within the DR Employees were provided with descriptions of duties, and weekly group meetings were initiate * Training to improve skills was_provided to lead record reviewer * Groups within the DRG were reorganized and consolidated to improve communications and provide people with the most effective supervisio * The Generic Resolution (GR) program was improved by incorporating GRs in the review checklists where practica * The Manager - IPQA, and the Clinton Power Station have initiated a program of talks with site personnel at all levels to enhance vertical communication and specifically to cover allegation Based on results of interviews by the IP personnel, who conducted the
. investigations, the document review problems have been satisfactorily corrected, that is, none of the persons interviewed had any serious problems with the BA DR _ _ . .
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l Conclusion Based on the' inspectors' overall review of IP's investigative
. approach and resulting actions, and the detailed inspection of the 7 allegations, it is concluded that all 46 investigations conducted by IP were adequate and the identified weaknesses were ;
appropriately corrected. Although several allegations wer <
. substantiated, none was safety significant. IP's findings and-results were consistent with those made by Region III as documented 9 .in Inspection Report 50-461/85008. These matters are close LNo violations or deviations were identified, (Closed) Allegation (RIII-85-A-0175/#170): Unspecified hangers are i mislocated in the containment building; therefore, there is a concern about the compentence of the survey cre The type of hangers was not specified; however, the person making .
the allegation was a QC electrical inspector. No other specific !
information was provided by the alleger; therefore, it was inferred by the NRC inspector that the mislocated hangers were electrica i The problem of mislocated electrical hangers has been reviewed by F Hoe n da<cribed in the attachment to Inspection Report 50-461/8301 The NRC reviewed several hunured nonconforw nce repuri.. at. cept.ed "a3 is" and concluded that the greatest single problem was with the mislocation of electrical hangers apparently caused by not correcting embed locations during early stages of construction. The noncon-formance reports were properly dispositioned "as is", that is, mislocations had no impact on.the function of the electrical hanger There is no reason for NRC to believe that other mislocated hangers would be treated any different. Inspection Report No. 50-461/85029 described a similar allegation, RIII 85-A-0093, concerning surveyed controlled elevations being off by up to 1-1/2 inches. That
allegation was not substantiated. This matter is close No violations or deviations were identifie j (Closed) Allegation (RIII-85-A-0116/#155): On October 1, 1985, Region III submitted the following employee concerns to IP for their investigation and disposition. On November 1, 1985, IP ;
notified Region III by letter U-600309 that their review and '
followup was completed (Attachment 4).
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Each employee concern is listed below. The inspector reviewed IP's ;
response to each employee concern described in Attachement 4, and
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documented the results of that review belo !
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Concern No. 1
"It is possible that'many instrumentation lines are almost closed
.with ' sugar'. A thorough flush could not take place. The welding ;
procedure used to weld ' Cajon' fittings to .065" wall instrumentation i
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7 tubing, NP-8-8-BS, was' defective. 'It is not possible to make
. consistently good welds on this wall thickness using the minimum requirements of this procedure,Li.e., 300 F. maximum interpass 3- > temperature,.50 amps minimum, and no internal purge."
Applicant's Response ,
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Concern No. 2
" Acceptable welds were produced by making welds in tacks about 1/4" long and cooling with water mist to ambient temperature between L
tacks. This method was not used for the bulk of field welding ~on this material at Clinton."
Applicant's Response See Attachment ' Concern No. 3
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" Radiographs of welds 1-IS-912-4, 1-CM-9-5-92Q1, 1-CM-905-2Q1,
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ICM-905-91, and 1-SM-906-5Q2 revealed severe burn-thru~and internal restrictions."
= Applicant's Response-See Attachment 4.
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NRC Review The NRC inspector reviewed these three concerns and the applicant's
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' response The NRC previously addressed the " sugaring" of instrument
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tubing in Inspection Report No. 50-461/84036, paragraph The phenomenon of sugaring occurs when stainless steel materials are heated to the melting point in the presence of oxygen. This burning of the metal leaves a black oxide deposit on the weld.
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These welds are made using the Gas Tungsten Arc Welding proces During welding, the outside of the weld is protected from oxidization by an inert gas cover which flows from the welding torch. The joint type (socket weld) being used for the instrument lines typically does not require an inert gas purge on the inside of the pipe.
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As a result of the alleger's concerns, the Baldwin Associates Welding Engineer, at the request of the Manager of Technical Services, performed a review of the welding procedure. Using the procedure NP-8-8-BS, weldsents were made to test the parameters given in the procedure. All weldments were visually inspected and accepted per the ASME Code Section III and Baldwin's procedure BTS-405-R-1 This evaluation served to prove that the procedure was capable of producing welds without causing sugarin !
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As a result of this evaluation,.it was decided to give'the welders additional' training to enhance their individual welding techniques.
r -The training consisted of schooling the welders in techniques to reduce heat input and thus reduce the occurrence of sugarin Since there is no acceptance or rejection criteria addressing sugaring,.Sargent & Lundy was asked to evaluate the impact on design. Samples were removed from the field and sent to S&L for
- evaluation. S&L selected the 10 " worst case" samples and sent them ..
to St. Louis Testing Laboratories for destructive testin All *
samples passed a 3300 psi hydrostatic test, which twice exceeds the reactor vessel hydrostatic test pressure of 1563 psi. Additionally,
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all 10 samples when tensile tested failed'outside the socket weld area at a tensile force greater than the minimum required. This indicates that the sugaring did not have an impact on desig In addition, the inspector reviewed the radiographs of the five
,a socket welds referenced in the alleger's concern No. 3. No " burn
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thru" was evident; however, some melt thru was apparent on three of-the five welds. The melt thru and sugaring was not significant in that the restriction imposed by the weld condition would not impair its function. The inspector visually inspected 50 randomly selected socket welds within the containment and auxiliary buildings; the welds observed complied with visual acceptance criteria of the cod No evidence of grinding of the sockets was observed. Radiography of socket welds is not required by the code; the radiographs performed were for information to provide further assurance that the melt thru or sugaring experienced in the weld was not detrimental to the function of the socket weld.
- . The applicant's review and action taken was adequate to assure that
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the alleger's concerns were not detrimental to the function of the socket welds or the instrument line and that the weld procedure was adequate. These concerns are considered resolved, and have no safety significanc Concern No. 4
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" Minimum wall thickness violations may exitt. Training given inspectors on the use of D-Meters would result in inaccurate
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readings (readings that would indicate the material was thicker than actual). The training was not modified after this problem
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was brought to the attention of BA."
h l The following information was provided by the applicant in response L to this concern:
Applicant's Response See Attachment 4.
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NRC Review The NRC inspector reviewed the employee's concern and the applicant's response. As a result of this review, the inspector requested additional information for assurance that no minimum wall violations could exist as a result of the difference in velocity settings as addressed in the applicant's response. The applicant provided the additional data included as Attachment 5 to this repor The review and actions taken by the applicant were adequate to assure that the concerns about violating minimum wall thickness requirements were unfounde Conclusion The applicant's response to the four employee concerns was adequate to assure that there were no apparent safety or code violations resulting from the concerns. These items are close No violations or deviations were identifie d. (Closed) Allegation (RIII-85-A-0196-01/#174-01): (Note: This allegation consisted of seven sub parts; only one is considered here.) An individual alleged that document transmittals being sent to field document control station Q-2/VT were not being posted against controlled documents as required. The responsible document control technician, according to the alleger, was signing off the transmittal slip and returning it without making required postings to safety related controlled document NRC Review The inspector reviewed the governing procedures used for Document Control at the Clinton Power Station. Baldwin Associates Procedure (BAP) 2.0, Document Control, and BAP 2.0.1, Instructions for Main-taining Project Drawings, define the method used by BA to control design documents. Posting was defined in BAP 2.0, paragraph 2.7 as
" Annotation of documents by marking to indicate an approved design change document number . . .".
Field station Q-2/VT was being utilized by BA Quality Assurance, BA Quality Engineering, and BA Field Verification personnel. The inspector selected 17 recent transmittals to field document control station Q-2/VT for review. The transmittals selected included new drawing revisions and requirements for posting approved change documents against current drawing revisions. The types of change documents requiring posting were Field Change Requests (FCRs),
Nonconformance Reports (NCRs), Engineering Change Notices (ECNs),
v i Field Engineering Change Notices (FECNs). The inspector
' .ntified the following discrepancies:
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1Transsittal Number Discrepancies
, .J-12381 FCR 43386 not-posted against E29-1002-01A EI FCR 43386 not posted against E29-1002-01A EIH
, FECN 12432 not posted against E30-1005-01A EI FECN 12432 not posted against E30-1005-01A EIH J-1238 NCR 20835 not deleted from E30-1005-05A EH J-12383~ FCR 43561 not posted against E29-1002-03A-EI FCR 43561 not posted against 129-1603-08-EI J-12384 ECN 6196 not posted against E03-0PLO8J/sht. 79 ECN 6196 not posted against E03-0PLO8J/sht. 84 J-12396 FECN 8006 not posted against E27-1607-EIH
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FCR 43426 not posted against E27-1002-038-EI
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FCR 42952 not posted against E27-1004-04A-EI J-12397 FECN 12316 not posted against E03-1EE29E FECN 12316 not posted against E03-IFP00/sht.40 FECN 12467 not posted against E03-IP662
- FCR 43035 not posted against E03-IP868 The applicant was informed of the discrepancies noted by the-inspector and conducted their own review. Illinois Power Quality Assurance (IPQA) Surveillance Report CQ-01701, dated December 12, 1985, delineates the review conducted by the applicant and corrective action take Site Document Control reviewed 502 drawings maintained at the Q-2/VT station. A total of 333 discrepancies were identified on 161 of these drawings. A majority of these discrepancies (259) were attributed to one Field Document Control Technician. In addition to the Q-2/VT station review, Site Document Control selected five document change transmittals from each field document control technician's work log. A total of ten errors were identified in 723 documents reviewe This error rate indicated to the inspector that the posting problem identified at the Q-2/VT station was not evident elsewher The potential hardware impact due to the identified document control
' discrepancies was investigated by IPQA. This investigation focused on the use of design drawings at the Q-2/VT document control station and a review of closed travelers to assure implementation and inspec-tion per the design change documents. The IPQA review concluded that the change documents not being posted on design documents at the Q-2/VT station had no impact on hardware. The basis for this conclusion was the fact that BA Quality Control personnel indicated that specific design attributes (FCRs, FECNs, ECNs, etc.) from the traveler package were used in conjunction with the design drawings to conduct field inspections. In addition, the IPQA review of closed travelers indicated that the design change documents were implemente . _ - - __ __ _ _ - - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ __ - _ __--_ __ _ _ _ _ _ ___
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Conclusion This allegation was substantiate The requirements of BAP 2.0.1, paragraph 5.5, were not properly implemented for change documents issued against a drawing, as evidenced by the discrepancies noted abov This is in violation of 10 CFR 50, Appendix B, Criterion V, as implemented by the Illinois Power Company Construction Quality Assurance Manual, chapter 5, which requires that written procedures, instructions, and drawings be developed and used for activities affecting quality (461/85063-01).
The inspector noted that field document control station Q-2/VT was closed, and the Field Document Control Technician was removed from duty. A comprehensive review of work documents at other field document control stations was performed and the results indicate the identified problem was isolated to station Q-2/VT. The investigation by IPQA did not identify any hardware impact due to the lack of posting design change documents on design drawings at the Q-2/VT station. Based on the above corrective action and the results of the IPQA surveillance report, no further action on this item is require This item is close One violation was identifie . Functional or Program Areas Inspected Site Surveillance Tours (71302/60501)
At. periodic intervals during the report period, surveillance tours of selected areas of the site were performed. Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of equipment and material being used in site construction; potential for fire or other hazards which might have a deleterinus effect on personnel or equipment; storage conditions of new fuel; and to witness construction, maintenance, and preoperational testing activities in progres The inspector continued to follow the applicant's progress in the maintenance of the main steam isolation valves. The activities observed were consistent with findings previously documented in Inspection Report 50-461/85053, paragraph The inspectors observed significant actions by the applicant to upgrade the cleanliness of the containment building and drywell in preparation for the structural integrity test and integrated leak rate testing. Those actions included removal of scaffolding, placement of permanent gratings, cleaning of cable trays, cleaning of all accessible areas, imposition of upgraded access controls, removal of temporary flooring over the suppression pool, and other similar actions. General cleanliness in the containment building improved substantially as a result of these action:.
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Thel inspectors regularly toured the new fuel storage area to assess the storage condition of the new fuel, fire protection, and security controls. One minor access control deficiency was identified by the applicant. Prompt corrective action by senior management personnel-was eviden During> routine tours of the control room, the inspector noted that certain tag out log sheets reflected poor record keeping practice In particular, there were blank spaces that were not filled out, incomplete entries, and minimally legible entries. The poor record i keeping practices did not impair the ability of the inspector to assess the. status of plant equipment controlled by the logs. These
. minor discrepancies were discussed with operations department super-vision who took prompt action to upgrade record keeping practice Subsequent observations of similar logs did not identify any :
additional concerns. The inspector had no further questions regarding this matte .
No violations or deviations were identifie Administrative Procedures Review (42400) 1 This inspection continued a review (see inspection reports
- 50-461/85005, paragraph 9 and 50-461/85012, paragraph 5) of procedures to be used in the plant operations phase to confirm that the scope of the plant procedures system is adequate to control
safety related plant operations within applicable regulatory !
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requirements, and to verify the adequacy of management controls in implementing and maintaining a viable procedure syste (1) Procedures Reviewed l \
(a) CPS No. 1401.01, Operations Department Organization, Responsibilities and Minimum Qualifications, revision 5 dated August 29, 1985 ,
l (b) CPS No. 0AP1401.045, Shift Turnover and Relief, revision 2 ;
dated November 8, 1982 :
(c) CPS No. 0AP1401.05S, Main Control Room - Conduct of Personnel, revision 3 dated November 18, 1982 i (2) Results i
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! The procedures reviewed were generally consistent with ;
regulatory requirements. However, three specific matters were ;
discussed with cognizant supervision as follows:
! (a) Several procedural references to the " Control Room" were !
made in CPS 0AP1401.055. However, the limits of the-
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' control room were not specifically defined by the applicable procedures. In particular, paragraph 8. l
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- stated "A senior reactor operator shall be present in the control room during Startup, Hot Shutdown, and Power Operations (Conditions 1, 2 and 3)"; paragraph 8. ". stated "The senior reactor operator shall not leave the control room until properly relieved by another licensed senior operator"; and paragraph 8.5.6 stated, "In an emergency the operator at the controls may proceed into l
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the crosshatched area . . . for a short period of time, to
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take actions at any main control room panel." The size of i
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the Clinton Power Generation Control Complex is large and ,
several areas adjoining the area defined as "at the
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controls" could be loosely interpreted as being inside the " control room," including the shift supervisor's office, i the computer room, the technical support center, the ;
operations support center, etc. The inspector commented 1
, that plant operations supervision should consider defining the actual limits of the " control room."
(b) CPS OAP1401.05S made reference to the " Control Room Supervisor" position which was not defined in the station administrative procedures. CPS 1401.01, " Operations Department Organization, Responsibilities and Minimum Qualifications," Revision 5, identified he operations department organizational structure; there was no reference '
to a " Control Room Supervisor". Discussion with cognizant ;
personnel revealed that this position was equivalent to the
"Line Assistant Shift Supervisor" defined in CPS 1401.01 which is an SR0 positio (c) CPS OAP 1401.05S made reference to CPS 1401.06S which has 3 subsequently been deleted from the station procedures manua '
The Director - Plant Operations stated that the operations department administrative procedures were currently being ;
rewritten and that the above inspector observations would be considered during the revision process. This information -
was sufficient to address the inspectors' concer No violations or deviations were identifie ;
i Operational Staffina (36301) l
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This inspection was performed to verify that the applicants current ,
operational staffing plan was in accordance with the FSAR and proposed :
i Technical Specifications; that staff positions were filled; and that l staff qualifications were adequate for their designated assignment ;
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This inspection included Ifcensed and unlicensed plant operators, l
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technicians, mechanics, electricians, welding and nondestructive testing personnel, and QA/QC staf ;
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Review and verification of specific areas in the Operating Organization was accomplished prior to this inspection. The results of these prior reviews are presented in the following reports:
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Inspection Report 50-461/85017: Chemistry and Radiochemistry Management Control and Organization Inspection Raport 50-461/85023: Maintenanc Inspection Report 50-461/85028: Radiological Protection, Organizations, Staffing, and Qualification Inspection Report 50-461/85052: Radiological Protection
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NUREG-0853, Safety Evaluation Report, Supplement 5: Plant Operating Staff, Levels, Qualification, and Expe,ienc One or more of the above reports included verification of the minimum educational, experience, and qualification requirements for the Manager-Clinton Power Station, Assistant Manager-Clinton Power Station, Director of Plant Operations, Supervisor of Chemistry, Supervisor of Control and Instrumentation, Director of Plant Maintenance, Director of Nuclear Training, Director of Radiation Protection, and Plant Technical Directo (1) Documentation Reviewed (a) IPC Nuc1 car Organization Staffing Plan, Revision 7, dated August 30, 198 (b) CPS Organization Chart (IP Memo SBF-0366-85), dated November 1, 198 (c) CPS No. 0AP150203N, Personnel Qualifications for Maintenance Activities, Revision 2, dated July 16, 198 (d) FSAR, Chapter 13, Conduct of Operations, Amendment 35, dated October 198 (2) Discut-ir,,lesults (a) The inspector reviewed the mechanical maintenance department's current staffing plan and the adequacy of present qualifications. Illinois Power Company's Procedure CPS No. 0AP1502.03N, Personnel Qualifications for Maintenance Activities, delineated the qualification, training, and retraining requirements of Maintenance personne b
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The inspector interviewed the applicant's Mechanical Maintenance Supervisor to ascertain current mechanical maintenance capabilities.The inspector noted that all positions in the mechanical maintenance department were fille The qualification matrix (Appendix A to CPS No. 0AP1502.03N), available in the mechanical maintenance supervisor's office, provided documented evidence of the training program applicable to mechanical maintenance personnel. Review of the matrix and discussion with the Mechanical Maintenance Supervisor indicated that a continuing program of both general and specialized training was provide This information was adequate to demonstrate that stfficient numbers of qualified maintenance techni-clans were available to support routine maintenance tasks during operation of Clinton Power Station. The Mechanical Maintenance Supervisor stated that additional personnel would be available for non-routine maintenance and outage work through IP's maintenance contract with Stone and Webster Engineering Company and other specialty contract The inspector verified that the procedure for Personnel Qualifications for Maintenance Activities (0AP150203N)
met the requirements of ANSI /ANS 3.1-1978. The inspector concluded that training was completed by the mechanical maintenance department in accordance with the applicant's procedure (b) Operating organization structure and staffing was reviewed in reference to Chapter 13 of the FSAR. The technical support organization as delineated by the CPS Organiza-tion Chart (IP Memo. SBF-0366-85), was in agreement with Figure 13.1-1A of the FSAR, Amendment 35. There were unfilled positions; however, none was for required control room operators, assistant shift supervisors, or shift supervisor (c) The applicant was committed in Section 13.1 of the FSAR to ANSI /ANS 3.1-1978, which defines operational staff qualifications. The inspector reviewed a selective sample of personnel qualifications for the following job classifications:
Control Room Operator (2)
Unit Attendant (2)
Control and Instrumentation Technician (2)
Repairman (2)
Welders (2)
Electricians (2)
NDE (2)
Quality Control Inspectors (2)
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The inspector reviewed training files, personnel files, and IPQA certification files to verify background history of the selected sampl For the personnel sampled above, the inspector verified qualifications, education, technical training, and related job experience met the requirements of ANSI /ANS 3.1-197 At the conclusion of the inspection period, this review was still in progress. Additional reviews in this functional area will be documented in a subsequent inspection repor No violations or deviations were identifie d. Installation of Safety Related Components (MSRV) (50073C)
This inspection was performed to verify that activities relative to the installation of the Main Steam Relief Valves (MSRV) were being accomplished in accordance with NRC requirements, FSAR commitments, and applicant procedure The inspector witnessed the uncrating and inspection of two MSRVs in the IP warehouse. Minor scra'.ches and gouges were identified on the raised face portion of both the inlet and discharge flanges of these valve Additional valves were inspected by the applicant. A total of thirteen NCRs were written identifying these conditions. The following NCRs were reviewed by the inspector: NCR 38293, 38306, 38307, 38399 through 38402, 38430 through 38432, and 38446 through 38448. The disposition of the conditions identified in these NCRs was to clean the raised face of each flange and polish with an Arkansas ston This was based upon the recommendation of Flexitalic Corporation, the manufacturer and supplier of the gasket material for these valve The NCR disposition appeared adequate for the observed condition The following procedures were reviewed to determine the requirements for installation and protection of this equipment:
- BAP 2.7, Housekeeping, Revision 8, dated June 28, 1985
- BAP 2.10, Equipment Installation, Revision 11, dated September 9, 1985
- DAP 2.11, Rigging Hoisting, Handling, Revision 8, dated September 10, 1984
- BAP 2.36, Processing System Completion Requests (SCR's),
Revision 2, dated February 26, 1985
- BAF 3.2.2, Construction Cleaning and Closure Tagging, Revisien 10, dated December 13, 1985
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The following equipment and location drawings were reviewed: (1)
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Sargent and Lundy drawing M05-1002-1, Revision 1, and (2) General L Electric drawings 767E262 and 131C896
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, The inspector reviewed traveler 821-044 and witnessed the final
. torquing of the inlet flange of valve 1821-F0470. The inspector
. verified that the pneumatic torque wrench had been calibrated, was-within the time frame of the calibration period, and that the proper air pressure was being used. -QC hold points were properly signed and dated. ~Particular attention was given to Step 10 which was in process at this time. This' step covered flange torquing require-L ments. A final torque value of 1400 ft.-lbs. was achieved in four increments of 40%, 70%, 90%, and 100%.. QC sign-off for each increment was required. The inspector witnessed these' sign-off The inspector witnessed the fit up of valve 1B21-F051C. A problem developed with bolt hole alignment between the valve' outlet flange and the discharge spool piece flange. A traveler was written to allow loosening of bolts attaching the spool piece to the discharge elbow to allow rotation to permit final fit up of the MSR Because of the pending structural integrity test scheduled for December 26, 1985, all installation work in the drywell has cease Work on MSRV installation is scheouled to resume on January 8, 198 The inspector reviewed provisions for storage of the two valves installed. The valves were adequately protected and supported. The installation of these valves is a major construction item and will be further reviewed by the inspector during a future inspectio '
No violations or deviations were identifie .
- Regional Requests (92705)
, Use'of Licensed' Reactor Operators in Supervisory Positions Region III requested that the inspector review the applicant's administrative procedures to assure that a violation identified at another nuclear power plant was not evident at CP The violation involved the use of reactor operator (RO) licensed personnel to supervise the activities of other licensed reactor operators. In accordance with 10CFR50.54(m)(2)ili, a licensed senior reactor operator (SRO) is required to be present in the control room at all times in operational conditions 1, 2, and In accordance with 10CFR50.54(e) a SRO is defined as an individual whodirectsthelicensedactivitIesoflicensedoperator The administrative' procedures of the facility in violation of these requirements allowed a " Supervising Control Operator" who was a licensed RO to direct the activities of other R0 licensed personne , -..- - - -
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The inspector reviewed operations department administrative procedures s 'and interviewed cognizant operations department supervision. In all
! cases,Lthe applicant's administrative procedures reviewed reflected 9 the requirements of the. applicable regulations. The Director, Plant 0perations,. confirmed the intent of the CPS Operations Department administrative procedures that a licensed SRO direct the activities of other licensed personnel. Some minor discrepancies identified during this review were documented in paragraph 7.b abov No violations or deviations were identifie = Record Verification' Program Termination Request On November 15, 1985, the applicant submitted proposed changes to the IP Record Verification program. The proposed changes included
- termination of the program for most record commodities. The applicant requested that Region III provide comments to and concur in the proposed change The_ inspector assisted Region III in review of the proposed program changes.and provided comments to Region III. A letter responding to the proposed program changes was sent to Illinois' Power Company on December 16, 198 No violations or deviations were identified.' Structural Steel Overinspection Scope Review (92705)
The inspector completed the review of the scope of overinspection for structural steel and the applicant's justification for not inspecting certain structural steel applications. Information relevant to this matter has been previously documented in Inspection i Reports 50-461/85032 (paragraph 12.c.(1)), 50-461/85042 (paragraph 2.j.) and 50-461/85053 (paragraph 6.). Inspection Report 50-461/85042 requested IP to provide a written response to Region III concerning the scope of structural steel overinspection. This was done in Letter-U-60031, D. P. Hall to C. E. Norelius, dated November 27, 198 The inspector reviewed the letter referred to above and discussed its contents with cognizant applicant personnel. Thejustification for discontinuing further structural steel inspections under the overinspection program and the method outlined for future inspections that may be required because of modifications, appeared to be satisfactory and met the intent of this progra No violations or deviations were identifie O ,
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, Independent Inspection Effort: Emergency Plan Dress Rehearsal Exercise \
(82301)
'g The inspector observed the conduct of an emergency plan dress rehearsal
- " exercise on November 19, 1985. The exercise was conducted by the applicant in preparation for the full scale graded exercise scheduled for
- December 4, 1985 (refer to paragraph 10.c. of this report). The inspector observed the exercise to familiarize the inspector with the capabilities of the applicant's emergency response organization; to familiarize the inspector with the operation of the applicant's emergency response facili-ties; and to assess the readiness of the applicant for the December 4, 1985 full scale graded emergency plan exercis The inspector observed the actions of the applicant's emergency response organization in the control room simulator (used during the drill instead of the actual control room to minimize disruption to ongoing plant activities) and in the technical support center adjacent to the control roor The inspector also observed a critique held in the technical support center after the exercis Several observations were discussed
with the applicant's drill evaluators and with cognizant management personne No findings were identified since this exercise was preparatory the
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graded emergency plan exercis No violations or deviations were identifie . Site Activities Of Interest (71302/92705) Emergency Preparedness Implementation Appraisal (71302)
NRC Region III and the Office of Inspection and Enforcement, assisted
- by contractors from Battelle Northwest Laboratories, completed an emergency preparedness implementation appraisal inspection on November- 21, 1985. The inspection was intended to assess the readiness of the applicant's emergency response personnel and facilities to respond to emergency conditions onsite and to provide protective action recommendations to state and public official Results of this inspection were discussed with the applicant in an exit meeting on November 21, 1985. The inspection team identified approximately 47 open items requiring action by the applican Overinspection Program Status (92705)
On November 23, 1985, Region III concurred in IP's request to terminate Overinspection of conduit, conduit supports, cable tray, cable tray supports, cable, cable terminations, HVAC duct, and duct supports._ IP subsequently terminated overinspection in the requested commodities. These activities had previously been suspended by IP, ,
,, at their risk, pending completion of Region III action on their !
termination request )
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i The-following Overinspection Program status was determined after l discussion with'IP management on December 5, 1985: !
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Approximate Quantity Commodity Remaining To Be Inspected Structural Beams 11 Electrical Equipment 230 Mechanical Equipment 78 Fire Protection / Augmented Class D Items 50 Instrumentation 31
- Completion of the above inspections'had been restrained by turnover
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from construction; completion was' forecast for early Decembe c.- Full Scale Emergency Plan Graded Exercise (71302)
On December 4,.1985, th'e' applicant conducted a full scale exercise of the CPS emergency plan. The exercise was observed by teams from the NRC (onsite response) and the Federal Emergency Management Agency (FEMA) (offsite response). The exercise was intended to assess the preparedness of the applicant and applicable state and local govern- >
-ments to act to protect the health and safety of the public in the event of a major. emergency at CP The applicant was fully successful in the conduct of the exercis Five FEMA open items will be reviewed during the next scheduled full scale exercise; six NRC open items will_ require some action on the ,
part of the applicant or the NRC (three prior to fuel load and three at the next site exercise). There were no significant discrepancies
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identifie No violations or deviations were identifie . Exit Meetings (30703)
The inspectors met with applicant representatives (denoted in Paragraph 1)
throughout the inspection and at the conclusion of the inspection on December-16, 1985. The inspectors summarized the scope and findings of ,
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the inspection activitie The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewd by the inspectors during the inspection. The *
applicant did not i6bntify any such documents / processes as proprietar The applicant acknowledged the inspection finding ,
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The resident inspectors attended exit meetings' held between Region III and/or_ headquarters based inspectors-and the applicant as follows:
' Inspector (s) Date Phillips, Loposer, Smith, Hawley',
Meck, Brown, Schultz,.Snell November 21, 1985 Lombardo, Carbonaro, Miller November 21, 1985 Kaufman - November 25, 1985 Snell, Phillips, Foster- December 6, 1985 Norton December 12, 1985 Key- December 13, 1985 Attachments: Ltr, J. G. Keppler to Illinois Power Company dtd July ~2, 1985, w/ enclosure Ltr, U-600290, D. P. Hall to J. G. Keppler
'dtd October 9, 1985, Subject: Investigation of Employee Concerns by Illinois Power Illinois Power Response to Unresolved Item 461/85032-02,." Skewed Socket Weld Engagement" Ltr, U-600309, D. P. Hall to J. G. Keppler dtd November 1,1985, Subject: Licensee Investigation of Employee Concerns Supplemental Information to Concern No. 4 Re: IP Letter U-600309 26