IR 05000461/1986033

Insp Rept 50-461/86-33 on 860519-22.No Violation or Deviation Noted.Major Areas Inspected:Allegations Re Sys Turnover Packages.Allegations Unsubstantiated

ML20206Q911
Person / Time
Site:	Clinton
Issue date:	06/27/1986
From:	Hawkins F, Neisler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206Q908	List: IR 05000461/1986033 ML20206Q903
References
50-461-86-33, NUDOCS 8607070026
Download: ML20206Q911 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

i Report No. 50-461/86033(DRS)

Docket No. 50-461 Construction Permit No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Co1 ducted: May 19-22, 1986

Inspector: J. H. Neisler 27/ B(,

c Approved By: F. C. Hawkins, Chief (,/27/ B6 Quality Assurance Programs Datd '

Section Inspection e Sumary Inspection on Ma 19-22,19_86_ (Report No. 50-461L86033f DRS1)

Areas Inspectecf:yTnannounced spec 1B inspection oTB legation _

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Resiilts: No violations or deviations were identified.

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i DETAILS Persons Contacted

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IllinoisPower__C_ompanyjIP)

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• C. Gerstner, Executive Vice President

• H. Daniels, Project Manager

• E. Corrigan, Director, QE&V

. *J. Wilson, Plant Manager

• D. Shelton, Manager, NSED

• Connell, Manager, QA

• J. Greene, Manager, Start-up

• J. Weaver, Director, Licensing

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• R. Schaller, Director, Nuclear Training

• G. Miller, Director, Fiscal Management

• J. Perry, Manager, Nuclear PGM Coordinator

• G. Bell, Special Assistant Manager, SOM

• K. Baker, Supervisor, I&E Interface K. Hill, Training Coordinator S. Rason, Quality Assurance Engineer C. Tewksbury, Supervisor, Quality Control J. Puzauskas, Supervisor, QA Procurement T. Kubiak, Safe Team D. Schweikert, Manager, Compliance T. Butera, Supervisor, Electrical QC R. Baker, Supervisor, System Release and furnover T. Howser, SR&T Engineer S. Horne, SR&T Engineer W. Leigh, SR&T Engineer C. Clark, QC Inspector K. Bowyer, QC Inspector R. Weber, Supervisor, Quality Systems R. Campbell, Director Quality Systems and Audits

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Ba_ldwin Associates

• J. Wiley, Project Manager The inspector also contacted other persons including quality inspectors, engineers, operators, and document package reviewer * Denotes those persons attending the exit interview.

i Followup on Allegations (Closed) Allegation RIII-86-A-0013 An allegation was made concerning discrepancies in completed system turnover packages. Specifically, the individual alleged that drawing changes shown on the master drawings in the system release and

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turnover office were not identified in all completed turnover package The individual presented the NRC with a list of 27 systems with discrepant turnover packages, of which 20 were nonsafety-related system NRC Review The inspector interviewed personnel in the system release and turnover section, reviewed turnover packages, amendment procedures for turned-over systems, and Condition Report CR-1-86-02-09 The interviews revealed that the individual was assigned the task of auditing the master drawings against the drawings in the turnover packages. The individuals in this job assignment were to report any discrepancies to their supervisor for resolution. Other persons were assigned to audit the packages against the master drawings. The purpose of these audits was to identify discrepancies between the drawings in the turnover packages and the master drawings. Once the discrepancies were identified, turnover engineers evaluated the discrepancies between the packages and master drawings and they also initiated appropriate corrective action CR-1-86-02-087 was issued to document these discrepancie The inspector determined by review of the corrective actions, the discrepancy list, turnover packages, and turnover package amendments, that the licensee's corrective action was adequate. The inspector did not find any packages in which missing drawings resulted in systems having unverified component The individual had menti'ned that the Automatic Depressurization System turnover package had missing drawings. That system package contained a list of applicable drawings, instead of including copies of the drawings in the package. The inspector verified that the referenced drawings were included in the appropriate system packag Since all packages contained or made references to the appropriate drawings, the inspector does not believe that the perceived problem had any impact on the testing progra The individual filed an employment discrimination complaint with the U.S. Department of Labo The Department of Labor's (DOL)

investigation did not verify the alleger's discrimination complain Reference DOL letter April 17, 198 Conclusion:

The NRC inspector determined that the concerned individual was I assigned to review and find turnover package discrepancies, that some l discrepancies were identified and reported, and that appropriate '

corrective actions were initiated. The inspector also concluded that the required drawings were part of the package or we.re appropriately referenced. The actual practices and results were acceptable to the NRC. This allegation was not substantiate l

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b. (Closed) Allegation RIII-86-A-0026 This allegation consists of 12 separate concerns received by the NRC Resident Inspector's office at Clinton. The individual stated that his contract was soon to expire and that he wanted to relay his concerns to the NRC before he left the site. These concerns are as follows:

Concern 1 Training and qualification of craft personnel working for a major contractor, Stone and Webster (S&W), was inadequat NRC Review A similar issue was previously identified by the NRC Resident Inspector in late January and February 1986 prior to the receipt of this allegation (See NRC Inspection Report 50-461/86008). A Notice of Violation was issued documenting the lack of training for S&W craftsman at Clinton. The licensee took appropriate correction action and the NRC performed followup inspections and closed out this item (See NRC Inspection Reports 50-461/86017 and 50-461/86023).

Conclusion A similar issue was previously identified by the NRC as a violation and appropriate corrective actions taken by the licensee. No further actions are required by the licensee or planned by the NR Concern 2 The individual stated that the certification program for IP QC inspectors did not provide sufficient control to assure that an inspector assigned to a specific job was qualified to perform that job. The individual further stated that the licensee certifies their inspectors to broad disciplines and that the electrical discipline, as currently defined, includes I&C activitie NRC Review The NRC inspector reviewed licensee training procedures for Electrical and Mechanical Quality Control Level II inspectors. The two disciplines are trained to perform inspections of routine maintenance activities of electrical, n'echanical and I&C . systems. The NRC inspector's review of lesson plans and examination results for electrical inspectors also i revealed that the inspectors had been trained to inspect calibration activities, transmitters, transducers, printed circuit boards, isolator card removal / installation, sensors, relays, and electrostatic discharge protectors installation, all of which fall within the I&C inspector discipline. Mechanical inspectors are trained to inspect pressure, level and flow measuring devices. The training procedures provide for additional training for special inspection activities not covered in the routine training program. Examination of inspector certifications I

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revealed that the quality control inspectors had received the required training and were certified in the areas in which they perform inspection The NRC inspector determined, through his reviews and examinations and interviews with quality control personnel, that the licensee's quality control inspector program meets the requirements of applicable codes, standards and regulations. There is no regulatory limit on the number of inspection disciplines in which an individual may be certified to perform inspection Conclusion This allegation was not substantiated. The NRC inspector's review

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confirmed that IP QC inspectors were qualified to perform their job assignments and that quality control inspectors receive proper trainin Concern 3 The individual stated that the control, inspection and verification of parts under the IP QA program, as presently defined, is inadequat The individual referred to two memoranda that were used by inspectors as guidance for parts verification. He was concerned that there was no accept / reject criteria for the identification of part NRC Review The inspector reviewed Clinton Procedure QAP-510.04A02, Part B (Inspection Instructions). These instructions provide guidance for the QC inspector's verification of parts. Specifically, the field QC inspectors verify that the correct part is being used. They also verify that the item's stock code is identical to the stock code on the equipment identification number (EIN) printout, that a "like for like" replacement is used and that a "QC Accept" tag is attached to the part indicating that the item has been receipt inspecte One memorandum was issued to clarify the inspector's duties for parts inspection and the second was issued in advance of a procedure change that was made as a result of a management review of the inspection program as shown in the Record of Coordination meeting notes of November 13, 198 The individual had specifically comented on the lack of accept / reject

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criteria for parts. The only acceptance criteria necessary, "like for like" replacement, is given in the procedure. Any other acceptance criteria is used by engineering and procurement / receipt inspectors to determine that the correct part was ordered and received. The

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questionable acceptance criteria are not germane to the field quality control inspector's work; i.e., installation / modification activitie Conclusion Based upon the inspectors review of procedures and other documentation 5 j

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that shows the parts control program to be adequate, this allegation was not substantiate Concern 4 The individual stated that maintenance work requests (MWR) are i routinely issued by IP maintenance department without adequate instructions to perform either the work or QC inspections. The individual cited two MWRs that referenced literature that instructed i the user to use a certain brand of crimping tool. Conversely, maintenance personnel had used a different reference in selecting the crimping tool.

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NRC Review The inspector reviewed the MWRs and supporting documentation. The MWRs involved the replacement of an AMP size 16-14 AWG PIDG terminal lug. The AMP catalog recommended using a certain crimper manufactured by AMP. No AMP crimper of this type was available onsite; therefore, maintenance personnel used a crimper made by Daniels Manufacturing Corporation. The Daniels crimper had previously been qualified by the NSSS (GE) for use on their equipment. The equipment in question had been procured by the architect / engineer. The 'aniels crimper was

! qualified under Military Specification MIL-C-22502/S for use on 10-22 AWG AMP MIL-C-22502/5 and 10-22 AWG AMP terminal lugs. The architect engineer approved the use of the crimper to perform the work under these MWR Conclusion Because the tool used in the performance of this work was previously accepted by the NSSS, the architect engineer, and the Department of Defense and was found to be' acceptable to the NRC, this allegation was not substantiate Concern 5 The individual stated that quality assurance records related to activities controlled and inspected under MWRs did not provide sufficient objective evidence of quality.

j NRC Review The inspector reviewed completed MWR packages. The MWR lists the equipment identification number, work performed, parts / materials used--

by stock number, names / signatures of QA reviewer, supervisor reviewer, individual who performed the work, the foreman and dates. The MWR also lists procedures used, reports generated and applicable drawings.

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The procedures, reports and drawings are not included with the MWR packages, but they were readily retrievable at the time of the i inspection. The packages contain completed quality control inspection plans (QCIP) that had been signed and dated by the inspector who j performed the inspection. Inspection hold and witness points, including parts verification, had been completed and signed off. The

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Inspector determined that the objective evidence to support MWR and QCIP performance was either in the packages or was readily retrieveabl Conclusion Based on the NRC inspector's review of the MWR packages, this allegation was not substantiate Concern 6 The individual stated that there is little or no QC supervision on the second shif NRC Review The inspector interviewed QC supervisors and inspectors who stated that the assignment of supervisors and leads to the second shift was normally determined by the amount of work and the number of personnel on that shift. The inspector determined that QC supervisors and lead inspectors are presently assigned to the back shifts. The inspector also observed that the QC supervisor's home telephone number is available at the QC work area so that the supervisor is available to respond to problems the QC inspectors encounter on the second shif Additionally, there is no specific requirement to have a QC Supervisor on the second shif Conclusion '

The allegation was substantiated, in that there have been times when there was not a QC supervisor in the plant on the second shift; however, the inspector determined that supervision was available when needed or when the work load required assignment of additional personnel to the shift. Additionally, there is no specific require-ment that a QC Supervisor is required for second shif Concern 7 The individual stated that there has been insufficient inspection manpower assigned to the night shift to support ongoing work activitie NRC Review The inspector interviewed quality control supervisors and inspectors, and reviewed inspection records and inspector assignments. The persons interviewed stated that there had been a shortage of qualified (certified) inspectors between November 1985 and January 1986. When additional inspectors had become adequately trained and certified they could then be assigned to the shift. The interviews and review of records revealed that the backlog of inspections had increased, but there was no evidence to indicate that the quality of the inspections had suffered as a result of a temporary shortage of certified inspector .

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Conclusions This allegation was substantiated, in that there was a temporary shortage of inspectors on-shift; however, the licensee took prompt action.to certify additional inspectors and reduce the inspection backlog. Additionally, this shortage of QC personnel had no impact on the quality of inspection Concern 8 The individual stated that there had been no quality engineer (QE)

assigned to support the second shift. The QE's responsibilities are either not done or improperly performed by QC personnel when a job is initiated and worked on the second shif NRC Review The inspector reviewed procedural requirements and duties for the Qua1{ cy Engineer (QE). The Quality Engineer, in the context of this allegation, reviews and initials the Quality Control Inspection Plan (QCIP) prior to the initiation cf the inspection. The inspector's interviews with quality engineers established that support to the second shift involved either onsite presence or on-cell when neede Telephone lists of the on-call quality engineers were in the quality control inspectors' office area. The duty QE may designate another quality representative to initial the QCIP. The inspector determined by the reviews and interviews that the night shifts were adequately covered by QEs and that, presently, QEs are onsite during shifts when work is sufficient to require their presence. Additionally, there is no specific requirement for a Quality Engineer to be assigned to the second shif Conclusion Reviews of procedures and interviews with personnel, by the NRC inspector, revealed that QEs were assigned to support the second shift, although they are not always physically present. There is no specific requirement for QEs to be assigned to the second shif This allegation was not substantiate Concern 9 The individual stated that it was impossible to properly initiate a condition report (CR) or a nonconforming material report (NCMR) on the second shift due to failure of the plant Compliance Department to provide second shift coverage. The individual also stated that, whenever a CR is required, an inspector must obtain a CR number from the Compliance Department. Without a compliance representative on the second shift, no one can obtain the required numbe l NRC Review The NRC inspector reviewed Clinton Procedure No. 1016.01. Paragraph 8.4.1.1.1 states, "The Condition Report (CR) number should be assigned

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. and entered by Compliance when the CPS CONDITION REPORT is receive '

i However, if the originator feels it is necessary to have a number :

assigned prior to this time, the number may be obtained from Compliance during normal working hours. The procedure further states, "For

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those CRs written on backshifts or weekends, the CR numbers should be

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entered by Compliance on the next regular working day."  ;

j The NRC inspector reviewed work schedules showing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage by l the compliance section. The schedule shows compliance engineers to i be either onsite or on-call. The schedule is posted in the_QC j office. In addition, there is a compliance clerk on duty in.the plant during the second shift. .The inspector interviewed other QC inspectors who stated that they had been able to initiate CRs and i,

NCMRs on the second shift. The NRC inspector determined that CR and NCMRs can be. issued on the second shift, that procedures delineate j the methods of processing CRs and NCMRs during off-shifts and

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weekends, and compliance personnel are onsite or on-call when needed.

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j Conclusion j- Based on the NRC inspector's review of p'rocedures and interviews with '

compliance and QC personnel, this allegation was not substantiated.

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t The individual stated that a QC inspector had signed MWRs and QCIPs i for a Quality. Engineer-(QE) who was not onsite during the night shif .

NRC Review l The QE referred to in this allegation was the duty QE for the evening _

! shift. He was called by the plant staff and_ QC _ representative regarding the MWR and QCIP. Staff and-QC personnel explained the MWR-and the QCIP during the telephone conversation. Since the job.

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involved only the troubleshooting of the diesel generator maintenance

! switch, the QE authorized a QC inspector to initial the MWR and the

! QCIP. subject to later review by quality enginee_ ring. This was the approved practice at the time. Because a QE is presently assigned to each shift, this practice is _no longer in effect. Procedure QAI 510.01 now requires QEs to issue QCIPs and QC inspectors to review

and initial each plan. The NRC inspector determined that the QC i inspector signed the documents for the QE as stated by the individual, j but no procedures were violated at that time.

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! The allegation.was substantiated, ~in that-the QC inspector did sign I for the QE; however, the signing was authorized and was not in violation'of plant procedure '

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Concern 11 The individual stated that there was a lack of organizational

. independence between QA/QC and the line management organization. He

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described an incident of disagreemer.t between him and the plant ,

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The inspector reviewed the Clinton Quality Assurance Program described

!- in Chapter 17 of the FSAR and site procedures and detennined that there is adequate independence between the quality and production organizations at Clinto ,

The incident described by the individual happened when the alleger placed a HOLD tag to stop work on the MSIVs because of problems with seals and limit switches. While _the individual was preparing the

Condition Report, he was confronted by the plant manager who asked j what the problem was with the MSIVs and whether the individual could

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conditionally release the work. The NRC inspector interviewed witnesses to the incident. The interviewees felt that some of the l plant manager's statements and questions relative to the' stopping of i work on the MSIVs should have been directed to QC supervisors, not the Level II inspector. The Condition Report was issued and the problem was subsequently properly resolved. A conditional release of the work did not occur, and work was stopped. A short time later, j work was resumed.

i The NRC inspector reviewed the licensee's investigation report of the MSIV incident. The report did not reach a conclusion regarding the

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individual's claim of lack of independence or attempted intimidation.

1 As a result of interviews with plant personnel and reviews of J pertinent' documentation, the NRC inspector determined that there was-

adequate quality control independence.- Although the plant manager

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may have used poor judgement in his choice of words and actions, there was no evidence of a conscious attempt to intimidate the_QC I

ins'pecto Conclusion Based on interviews with personnel and review of relevant documentation by the NRC inspector, this allegation was. not substantiate Concern'12

The individual stated that the measuring and test equipment used to j

measure-motor running current on valves was improper for that-l application. An additional concern.was that the bus voltages were 1

! well in excess of.the motor. nameplate value of 460 volts.

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The inspector reviewed Condition Report CR-1-85-11-017. It documented

! the improper ~ use of the measuring equipment. The individual had

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stated that the meter accuracy was insufficient to ensure that the motor current did not exceed the limits established in the test

' procedure. The motor current was reviewed by the motor manufacturer who stated that motor currents will rise proportionally with increases in motor voltage, and because the system design was 480 volts nominal, higher currents would result from stator saturation and that a 30 percent overcurrent reading on true voltage was acceptable. Electric motors are designed for 10 percent of rated voltage. The motors in question could safely operate at 506 volts, which is well above the 493 volts stated by the individual. The architect / engineer and station engineering also reviewed CR-1-85-11-017 and concluded that no problem existe Conclusion

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Based on these reviews by the motor manufacturer, the architect /

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engineer, and station engineering, this allegation was not substantiate . Exit Interview The inspector net with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection and summarized the scope and findings of the inspection. The licensee acknowledged the inspector's comment 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 or processes as proprietar l

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