IR 05000461/1986038

Safety Insp Rept 50-461/86-38 on 860519-21 & 0603-04.No Violation or Deviation Noted.Major Areas Inspected: Allegations & Resolution of 10CFR50.55(e) Items & Previous Insp Finding

ML20206P320
Person / Time
Site:	Clinton
Issue date:	06/26/1986
From:	Danielson D, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206P312	List: IR 05000461/1986038 ML20206P306
References
50-461-86-38, NUDOCS 8607020096
Download: ML20206P320 (8)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Report No. 50-461/86038(DRS)

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

Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name:

Clinton Power Station, Unit 1 Inspection At:

Clinton Site, Clinton, IL

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Inspection Conducted: May 19-21, and June 3-4, 1986

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Inspector K. D. Ward Date hfew Approved By:

D. H. Danielson, Chief MN Materials and Processes Section Date Inspection Summary Inspection on May 19-21, and June 3-4, 1986 (Report No. 50-461/86038(DRS))

Areas Inspected:

Unannounced special safety inspection of allegations, of the resolution of 50.55(e) items, and of a previous inspection finding.

Results: No violations or deviations were identified.

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8607020096 060626 PDR ADOCK 0D00

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DETAILS 1.

Persons Contacted Illinois Power Company _(IP)

• R. Cannon, Coordinator R. Lebkuecher, Staff Specialist J. Brownell, QA Specialist Nuclear Regulatory Comission_ (NRC)

• D. Keating, Senior Resident Inspector T. Gwynn, Senior Resident Inspector P. H11and, Resident Inspector P. Kaufman, Reactor Inspector B_al_dwin_ Associates J. Hawkins, Manager of Quality Assurance The inspector also contacted and interviewed other licensee and contractor employees.

• Denotes those attending the final exit interview on June 4, 1986.

2.

Licensee Action _on__ Unresolved Items (Closed)UnresolvedItem(461/85034-01): An NRC inspector visually examined cooling loop piping welds finding the following discrepancies:

weld spatter (Weld Nos. A7 and B7), rust (Weld Nos. 84, B6 and B8), and hamer marks (Weld No. A8). As a result, IP issued Condition Report No. 1-85-09-041 to evaluate the severity of these discrepancies. A reinspection of the conditions was performed by IP and those conditions determined to be unacceptable were documented on CPS Nonconfonning Material Report (NCMR) 1-1828. The unacceptable conditions were reworked and accepted. The sharp edges of the hamer marks were removed with a flapper wheel and the rust and spatter was removed by hand using scotch bright or an equivalent type of abrasive pad. NCMP 1-1828 was closed November 19, 1985. The NRC inspector reviewed the Condition Report, the NCMR and other related documentation. The actions taken by the licensee were found to be acceptable.

3.

Licensee Acti_on_ _on 10_gR 5_0._5_5(e,)__I_tems a.

(Closed)50.55(e)(461/85004-EE): Twenty seven butterfly dampers have defective fillet welds. The NRC inspector reviewed the final report dated August 7, 1985, related NCR's, investigation reports, PAPCC weld repair procedure and other related documentation. The deficiencies identified in this investigation were attributed to a lack of proper implementation of the requirements (base metal

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cleaning / operator technique) contained within the PAPCO Welding

Procedure Specification (Reference. PAPC0 Welding Procedure

Specification No.'1 Revision 1, dated September 27, 1977, and the PAPC0 Investigation Report).

Since the problem was identified as a possible generie welding deficiency for all dampers furnished

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by PAPCO, the evaluation for safety implication and significance

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included both pipe and duct mounted dampers.

PAPCO's Investigative

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Report summarizes that the pipe mounted dampers had areas where there was no fusion of the fillet weld between the flange and the body of the damper, and that all the pipe mounted dampers were i

repaired.

IP conducted a review to verify that repaired pipe mounted

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1-butterfly dampers were reinspected for adequate thorough fussion

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Subsequently, all 27 repaired

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butterfly dampers were reinspected and accepted by BA Technical l

Service /IP Vendor Surveillance, (Reference Activity Report

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No. 11129.17 and IOM No.'1713, dated July 30, 1985).

To prelude

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recurrence of this problem all future PAPC0 supplied items will be

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inspected upon receipt for weld discontinuities in accordance with

NSED Procedure P.2, Evaluation of Procurement Source, and Form P.2.3.

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The NRC inspector considers the actions taken by the licensee to be

acceptable.

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(Closed) 50.55(e) (461/85008-EE):

Flared bevel grove welds.

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NRC inspector reviewed Field Change Request No. 33230, the Sargent and

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Lundy's testing program and the program results, and other related documentation.

The condition involved the effective throat size for flare bevel groove welds made since March 3, 1983, which do not meet

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the requirements of Field Change Request (FCR) No. 33230, issued l

March 9, 1985.

The effective throat sizes for these welds were e

qualified by Technical Services in accordance with approved Procedure

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i Qualification Records (PQRs) AWS-5 and AWS-6.

The welds comply with

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j the requirements of AWS D1.1 (1977), but the effective throat was i

undersized when compared to the sizes required by FCR No. 33230.

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L response to an IPC request, Sargent and Lundy developed a testing i

program to obtain load test data on the welded joint configurations

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i for these flare bevel groove welds as installed. Test specimens were

prepared by Baldwin Associates and tested in accordance with the j.

program at the St. Louis Testing Laboratory.

Sargent and Lundy

evaluated tM test results and compared the results to the required

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i design strength of the welds. A review of the results determined that

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the welds have a minimum factor of safety of 1.5.

Therefore, these

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welds have sufficient strength needed for the components and systems i

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to perform the required safety function.

On September 12, 1985, NRC

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Region III was informed that IPC was withdrawing this potentially j

reportable deficiency based upon the results of IPCs initial investigation of the matter and evaluation of the identified

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deficiencies by Sargent and Lundy.

The actions taken by the licensee are acceptable.

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4.

Followup _on_ Allegations a.

(Closed) Allegation RIII-85-A-0182 On October 18, 1985, an individual made an allegation to the Clinton NRC Resident Inspector's Office and stated that Baldwin Associates NCR No. 35065 and No. 36609 were improperly dispositioned "Use-As-Is Type B."

These NCRs identified an apparent discrepancy with an

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installed piece of tube steel on Hanger No.1RB14504G. The condition J

description (Block 9) on NCR 35065 identified that Item No. 5 of Hanger No.1RB14504G is to be 2' 5" in length. The actual installed tube steel is 2' 6" in length. The individual identified two specific

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concerns as follows:

(1) The bill of material for this hanger installation clearly shows that a 2' 5" piece of tube steel (Item No. 6) was inspected by QC and released. The actual Item No. 6 installed in the field is 2' 6" in length. Where did the tube steel come from that is currently installed?

(2) The design drawing, M09-1001N, Sheet 3, Paragraph 70, allows for a tolerance of 1/8" for contractor fabricated auxiliary steel.

The "Use-As-Is" disposition states that "M09-1001N, Sheet 4, Paragraph II.7,U allows for a tolerance of 1" on a cantilever; therefore, no violation to design or procedure exists." The disposition identified a discrepancy in the design requirements which is not addressed by the dispositioning organization.

The individual stated that when these discrepancies were pointed out to the Nonconformance Review Group, NCR No. 35065 was closed and that NCR No. 36609 was written to try and obtain a satisfactory disposition.

However, the second NCR was dispositioned the same way.

NRC Review The NRC inspector reviewed a letter from IP dated January 2, 1986, i

regarding the IP review and the followup that was requested by RIII; NCR's No. 35065 and No. 36609; the bill of material; quality control inspection report; fabrication / installation traveler; and the drawings.

Concern No. 1 A review of the bill of material for Hanger No.1RB14504G and traveler H-RR-939-B confirned that a 2' 5" piece of tube steel was specified, inspected at the hbrication Shop and released for installation. The IP review of this. natter confirmed that a 2' 6" piece of tube steel was actually installed. Therefore, Concern (1), noted above was substantiated. However, the concern does not have safety significance for the following reasons:

The tube steel of concern is a cantilever member installed as part of hanger assembly No. 1RB14504G. Design drawings allow a 1" tolerance in cantilever members. Therefore, the installa-tion of a 2' 6" piece is acceptable for this installation.

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Completion of the hanger would not be possible had the installation proceeded with the original 2' 5" piece, due to the configuration of several welds in a limited space at the end of the cantilever. Therefore, the lengthening of the piece by one inch was necessary.

The installed 2' 6" piece has the same heat and receiving inspection

report number markings as the original 2' 5" piece, and is acceptable material for this installation.

Since permissible design tolerances were being met, fabrication of the longer 2' 6" piece can proceed without a design change document or a traveler revision. No procedural controls were violated.

Since applicable tolerances were complied with, and installed materials are adequate, the NRC inspector considers the actions taken by the licensee to be acceptable for Concern (1) above.

_C_oncern No. 2 A review of the two NCR dispositions, as well as design requirements specified in Sargent and Lundy Drawing No. M09-1001N, indicated that a discrepancy in design requirements, as indicated in the NCR disposition, does not exist.

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Paragraph 7.0 of Drawing No. M09-1001N (Sheet 3) requires the contractor to fabricate auxiliary steel to a specified design length with a tolerance of 1/8". Paragraph 7.0 of the same drawing (next sheet) provides the installer additional latitude in the final installation of a cantilever hanger to ensure that any attachments are maintained at the original distance from the free end of a cantilever member for loading considerations. This paragraph allows the lengthening of a cantilever member up to one inch to meet the attachment criteria. Therefore, a basic tolerance of 1/8" is specified in the design and with a special tolerance of 11" in the

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case of cantilever members.

Review of the NCRs indicated that the dispositions are appropriate to the circumstances, and the hangers were installed wit 11n the design requirements. Since a discrepancy in the design requirements was not found, the concern expressed in Concern (2) above was not substantiated. The inspector considers the actions taken by the licensee to be acceptable.

Conclusions Review of the NCRs indicated that the dispositions are appropriate to the circumstances, and the hangers were installed within the design requirements. Since a discrepancy in the design requirements was not found, the concern was not substantiated.

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Allegation RIII-85-A-0187 On October 24, 1985, an individual made an allegation to the Clinton NRC Resident Inspector's Office and stated that in the process of perfonning overinspection of containment penetrations FW1 and FW2, Main Feed Water penetrations f rom inside the drywell through contain-ment into the steam tunnel, the individual could not perform the visual inspection on one end of a 20" diameter guard pipe because he was approximately 20 feet from the end of the pipe. When he moved to the side where the head fitting is attached, he could inspect only one side of the full penetration weld. The individual was concerned that hydrostatic test inspections could not observe leakage at these weldments. He wrote two NCRs, No. 23601 and No. 23606, which stated that the inspection process was in viclation of Procedure BAP 2.37, Section 5.2.12, Paragraph "f."

Both NCRs were dispositioned

"Use-As-Is, Type B."

The individual then wrote NCR No. 25992 which covered the improper closure of an NCR. The disnsition of that NCR states that "the Use-As-Is disposition of the uriginal NCR is correct because there is only a procedural problem not a hardware problem."

The individual's overall concern is with Sargent and Lundy's (S&L)

justification of these dispositions. The individual stated that there appears to be a blanket disposition for all welds (FW 1 and FW 2) based on the disposition of FCR No. 28358.

The individual's second concern deals with pipe hanger location tolerances provided by S&L M09 drawings and actual field practices for locating pipe supports. The design drawings indicate tolerances to be used for installation of pipe supports, etc. Column lines are used for reference only. Actual practice indicates the opposite.

NRC Review C_oncern No. 1,

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The NRC inspector reviewed NCR No's. 23601, 23606 and 25992; Procedure BAP 2.37; FCR No. 28358; S&L M09 drawings; and other related documentation. NCRs 23601 and 23606 state that the inspection process was in violation of Procedure BAP 2.37, Section 5.2.12, Paragraph

"f".

This paragraph states the following:

"The QC P/M Inspector shall inspect the entire system during pressure testing to assure that all joints, connections, and all regions of high stress (e.g., regions around openings and thickness transition sections) are examined for leakage."

It should be noted that these inspection requirements pertained only to "high stress regions." The NCRs were dispositioned stating the area of concern was not considered a "high stress region" and the ANI er,d other quality groups accepted this "Use-As-Is" disposition.

FCR 28538 states that the area of concern, the inaccessible weld

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between the head fitting and the pipe, is not considered to be a

"high stress region." Also the FCR states that a paragraph was added to procedure BAP 2.37 to clarify that the weld between the head fitting and the pipe need not be examined.

Concern No. 2 The NRC inspector reviewed S&L's component support installation tolerance M09 drawings and Procedure BAP 3.2.5 and interviewed three individuals that worked with these drawings. The NRC inspector's review revealed that the specified tolerances were both practical and logical and the Baldwin procedure was found to be acceptable to the NRC. Additionally, the interviews revealed that site personnel who had also used these drawings daily, had no problems or concerns with the tolerances or the actual practices for locating pipe supports.

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A review of selected pipe support design drawings was conducted by the NRC and identified that column lines were being used to locate the actual component supports and were not being utilized for reference only. The NRC inspector's review also identified that the pipe

support design installation drawings used in conjunction with the M09 tolerance drawings were utilized in both the installation and inspection process to locate the component supports along the axis of the pipe. The Baldwin procedure identifies the responsibilities

and provides instructions for the work involved in the fabrication, rework, repair and inspection of supports. Additionally, the NRC has recently assessed the licensee's as-built program as related to IE Bulletin 79-14. " Seismic Analysis for As-Built Safety Related i

Piping Systems," and determined that the piping systems were constructed and seismically analyzed in accordance with the final design documents / requirements. Results of these inspections are documented in NRC Inspection Reports No. 50-461/85030 and No. 50-461/85056.

Conclusions The NRC inspector confirmed that the NCRs and the FCR were dispositioned properly and that Procedure BAP 2.37 was revised to clarify the requirements. The first concern was substantiated, however, procedural and design requirements were complied with and these requirements and the final results were found to be acceptable by the NRC inspector.

The second concern was not substantiated in that the pipe support drawings did not specify the column lines to be used for reference only. The installation drawings specified the actual location of the supports relative to the column lines. The NRC inspections of the

"as-built" condition of the plant confirmed that the installation

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was in fact in accordance with the design.

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General Comment Region III inspectors have investigated numerous allegations similar to those mentioned above and none of these have had an adverse effect on plant safety (see Inspection Reports No. 50-461/85002; 50-461/85007; 50-461/85008; 50-461/85009; 50-461/85015; 50-461/85018; 50-461/86012; 50-461/86017; 50-461/86019).

The above referenced allegations were in the 1985 and 1986 time frame.

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Exit Interview The inspector met with site representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection.

the inspector summarized the scope and findings of the inspection noted in this report.

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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