IR 05000461/1986057

Insp Rept 50-461/86-57 on 860811-0915.No Violation or Deviation Noted.Major Areas Inspected:Actions on 10CFR50.55(e) & Repts,Allegation on Review,Site Surveillance Tours & Review of Turnover Processing

ML20215D496
Person / Time
Site:	Clinton
Issue date:	10/06/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215D344	List: IR 05000461/1986057 ML20215D341
References
50-461-86-57, NUDOCS 8610140174
Download: ML20215D496 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86057(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: August 11 through September 15, 1986 Inspector: D. E. Keating F. J. Jablonski Approved By:

90 f R. C. Knop, Chief /O [b Projects Section IB Date Inspection Summary Inspection on August 11 through September 15, 1986 (Report No. 50-461/86057(DRP))

Areas Inspected: Routine safety inspection by the resident and regional inspectors of construction completion activities including applicant action on 10 CFR 50.55(e) and 10 CFR 21 reports; review of an allegation; functional or program areas including site surveillance tours and review of turnover processin Results: Of the four areas inspected, no violations or deviations were identified. The applicant's activities and corrective actions were adequat e61006 PDR ADOCK 0500 g1 G

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DETAILS Persons Contacted Illinois Power Company (IP)

• D. Hall, Vice President

• J. Perry, Manager, Nuclear Program Coordination

• J. Cook, Assistant Plant Manager

• F. A. Spangenberg, Manager, Licensing and Safety

• J. Weaver, Director, Licensing and Safety

• R. Freeman, Assistant Plant Manager, Maintenance

• J. Greene, Manager, Nuclear Station Engineering

• H. Lane, Manager, Scheduling and Outage Management

• E. Corrigan, Director, Quality Engineering and Verification

• J. Fertic, Director, Systems and Audits A. Sherwood, Lead Construction, Quality Assurance Engineering T. Parrent, Construction, Quality Assurance Engineer R. Cannon, Licensing Specialist J. Brownell, Licensing Specialist T. Warnick, Licensing Specialist B. Weaver, Technical Advisor, Plant Construction Group R. Greer, Director, Outage Maintenance Program T. Kubiak, Safeteam S. Rasor, Supervisor, Quality Operations and Maintenance Sargent and Lundy Engineers (S&L)

J. Blattner, Site Structural Supervisor

• Denotes those attending the monthly exit meeting. Other applicant personnel were routinely contacted during the course of the inspectio . Applicant Action on 10 CFR 50.55(e) and 10 CFR>Part 21 Items (92700) Review of 10 CFR Part 21 Reports (1) (Closed) Part 21 (461/86004-PP) (21-86-01): Anchor Darling swing check valves missing lock weld Based upon notification to the NRC of a defect identified at several other plants, Anchor Darling notified the applicant of a potential defect on 150 lb. class and 300 lb. class swing check valves. The defect identified at the other sites involved missing lock welds on the hinge pin setscrews, at tne hinge su) port / hinge support capscrew interface, and the hinge support /)onnet interfac The inspector reviewed the vendor's recommendations and the applicant's actions concerning the inspection of these item Included in the review were the following:

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- Maintenance Work Requests (MWRs) C18201, 203, 207, 210 through 212, and 214 through 21 Procedure CPS 8120.05, Revision 3, Maintenance of Anchor Darling Swing Check Valve Specification K-2866A-0001, Anchor Darling Operating and Service Manual.

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Letter dated December 10, 1985, Anchor Darling to Baldwin Associate Letter Y-81057 dated June 12, 1986, Sheldon to Spangenberg, Resolution of Reportability for 10 CFR 21-86-0 The review of these records indicated that the necessary corrective actions had been taken and completed. This matter is close No violations or deviations were identified.

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(2) (Closed) 10 CFR 21 Report (461/86001-PP): Burndy-Husky fabricated electrical cable tray hangers with defective weld During a site surveillance, IPQA found deficiencies in welds on electrical cable tray hangers fabricated by the Burndy-Husky Company. The deficiencies were associated with a welding detail identified as DV-10 and included problems with weld length and spacing between welds. The scope of the problem was expanded by Baldwin Associates to include an inspection of all Burndy-Husky shop welds, approximately 11,000. Results of the inspections were placed in the following categories:

- Defective DV-10 welds, strut-to-strut, were documented on nonconformance/ deficiency reports and reworked to meet design requirement Defective strut-to-angle welds were evaluated by the

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architect engineer who visually examined a sample of cross-sectioned welds. The architect engineer determined that those strut-to-angle welds were sufficient in size to fulfill design load requirements.

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The inspector reviewed rect, !s contained in the IP file for this matter, 21-83-05. The records showed that all corrective actions have been completed. This matter is close No violations or deviations were identified.

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' Review of 10'CFR 50.55(e) Reports (92700)

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(1) (0 pen) 50.55(e)-Item (461/86008-EE): Improper installation-of Raychem insulation on splices in Class 1E circuit Region III was notified by IP of this problem on September 2, ,

1986. The following preliminary information was obtained by Region III from IP during discussions with them on September 9, 1986.

I~ As a result of problems with the installation of Raychem splices identified at other sites,.(IE Information Notice 86-53), IP conducted a limited inspection of Raychem splice Results of the inspection showed that a high percentage of the splices did not meet Raychem requirements and appeared to invalidate environmental qualifications of the splices. This problem has the potential to affect approximately 3000 splices involving power, control and instrument cables used on

solenoids, conduit seals, transmitters, junctions used in lieu of terminal blocks, and motor operated valves.

I An inspection plan was being developed by IP that included a sampling plan based on MIL-STD 105D, with inspections

documented on a 13 point examination form. It is believed i by IP that the inspections can be made without disturbing

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the splices. IP has made arrangements to perform " quick

tests" if significant problems are identified during the t inspections. In the remote chance that all 3000 splices will

have to be replaced, IP estimates the job will take 45 days to complete. IP has determined that there may be information-available to " qualify" the present Raychem splices on an i interim basis. Region III has determined that this problem

'will have to be resolved prior to Nuclear Heatup.

No violations or deviations were identifie I (2) (Closed) 50.55(e) Item (461/86001-EE(55-86-01): Improper

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packing /no packing installed in ASME safety related valves.

! Region III was notified by IP of this problem on May 6, 1986.

Based upon Condition Report (CR) 1-86-04-068, Revision 0, an

investigation was initiated. A sampling plan using MIL STD.

! 105D and a random number generator to select the valves was i' established and furnished to the investigation team by IP's Licensing and Safety Department. The criteria for establishing

. the lot size was l- Department (NSED)provided by the Nuclear Station Engineering

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The residcnt inspector reviewed the documents referred to, and j in addition, reviewed Start Up's (SU) report of activities in i

support of the investigation plan. A random sample of 80

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valves out of a total lot of 437 was verified against Storage

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MaintenanceInstructionsandRecords(SMIR) cards. Four valves

~out of the 80 sample valves inspected had packing which'could not be verified from the SMIR cards. Three of these, upon furtherinvestigation,hadMaintenanceWorkRequests(MWRs)

initiated during the course of repairing packing leaks. One valve of the 80 valves under'this investigation was found with temporary plastic packing rings installed. MWR C-13867 was issued to replace this packing. Letter Y-80976, B. K. Shite to

, F. A. Spangenberg, dated June 5, 1986, documents in detail the  ;

l investigation and corrective action taken regarding'this issue l and is the final report of the investigation tea Based on these reviews and IP's actions, the inspector

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concurred with IP's findings. No further action is warranted.

p No violations or deviations were identified.

. Review of Allegations (99014)

! (Closed) Allegation (RIII-86-A-0114/#196): Undersized welds in

reactor and falsified quality control documentation of those welds;

! nothing properly measured off survey markers. Safeteam was also  ;

i contacted regarding " control room bundles".

l Concern #1 i-Undersized welds on control rod guide tubes, QC inspections were

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not done and QC documentation was falsified to show inspections g were completed.

l Review

A review of this information by the inspector indicated that similar concerns had not been given to the Safeteam. However, l in discussions with the Senior Resident Inspector - Operations,.

' it was learned that a reexamination had been performed of 97 of the total 145 welds between the control rod drive (CRD) housings i and the reactor vessel (RV). General Electric (GE), the Nuclear ,

i Steam Supply System (NSSS) supplier, required this reexamination l as part of their installation specifications after completion of l- the RV cold hydrostatic test. The activities and results of this

reexamination were thoroughly reviewed and detailed reexamination did not identify any undersized welds in the RV or CRD housings.

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The inspection report referred to above also documented the l nondestructive examination (NDE) method used to evaluate the welds.

i This was a water washable liquid penetrant (PT) method. This l reexamination was performed by GE and evaluated by GE's Level III

examiners. Twenty-seven of ninety-seven welds examined were found

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to exhibit rejectable linear indications. Details of the repair of j these indications were covered in the same repor ;

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Only the.CRD-housings of the two outer rings were able to be reexamined and evaluated because the balance were inaccessible j

for reexamination. Inspection Report 50-461/85015, paragraph 11,

! also documents the verification of the original PT examinations

performed when the RV was fabricated.-

Conclusion Based on the information available and reviewed, this concern could not be substantiated. While the allegation of undersized welds was not substantiated, the applicant had previously identified welds on the CRD housings with linear indications. Further, a Field

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Deviation Disposition Request (FDDR) was initiated directing the method of surface conditioning required for the reexamination of

the indication. The method prescribed was within American Society 1 of Mechanical Engineers (ASME) code and American Society of Nondestructive Testing (ASNT) SNT-1A code requirements. The welds were repaired; therefore, no further inspections are required, i With the initiation of FDDR and subsequent weld repair, it was-concluded that inspections were conducted and documented.

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Concern #2

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Nothing properly measured off survey markers.

a Review This concern was the subject of a similar allegation (RIII-85-A-0093) which was inspected and documented in Inspection Report 50-461/85029 j (DRS), paragraoh 3.b, wherein it is stated that the resident

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inspector witnessed a survey of control elevation markers in the

auxiliary and control buildings. The control elevation markers were i found to be within practical surveying tolerances. There are no

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known instances of equipment or components being installed in locations exceeding requirements specified on-design drawings.

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Conclusion

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Since Inspection Report 50-461/85029 (DRS), paragraph 3.b. states that the allegation could not be substantiated, no further inspections are warranted.

j Concern #3

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l The individual who made allegations to the NRC also contacted the j- applicant's Safeteam regarding " control room bundles".

Review !

The inspector reviewed the Safeteam's printout which identified one i concern related to control room bundles. Safeteam No. 12196-B l dated July 8, 1985, was about two tiered, prefabricated cable ducts

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located under the control room floor which had metal plates separating the duct levels. Bundles of electrical conductors were installed within the cable ducts. This appears to be the source of the phrase " control room bundles."

The individual stated that "the plates were sealed in place in the factory with a room temperature vulcanizing (RTV) caulking compound as required to allow 'the fast gas' (Halon) fire protection system to work properly. After pulling approximately 90% of the cables (bundles) into the ducts. QC decided to pull out plates because QC had not seen them caulked at the factory."

A review of the Safeteam's finding indicated that General Electric (GE) had issued Electric Field Disposition Instruction No. SKFW, Revision 0, which stated that the RTV caulk was not factory installed; the caulking was to be applied subsequent to all cable and conduit routing installations; any plates installed were required to be removed as a part of the work sequence. These would have been plates.that were field installed by the site electrical contractor, Kelso-Burnnett. There were also requirements for Quality Assurance (QA) to perform visual checks of all work related to this equipment. These activities have been thoroughly addressed in SKFW, Revision 0, sections 1.4, 4.2.1, 4.3, and 4.3.24 respectivel Conclusions Based upon the information available and reviewed, this concern could not be substantiated. Therefore, no further inspections are warrante Subsequent to receiving the preceeding allegations the individual contacted Region III on August 7, 1986, in response to an NRC letter requesting clarification of previously supplied informatio The individual did not provide any specific information but expressed two concerns identified below as Concerns #4 and # Concern #4 The quality assurance for Baldwin Associates on the reinspection ,

program needs checkin '

Review Region III concluded its review and inspection of the Overinspection >

Program (reinspection) as documented in a letter to IP dated September 4, 1986. Excerpts from that letter are included belo " Based on Region III's review of Illinois Power Company's overinspection data and engineering evaluations, and Region III's independent inspection, review, and evaluation, it is concluded

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that the Overinspection Program was conducted in accordance with approved plans and procedures, and that none of the discrepant attributes identified during the overinspection had significant safety implications. Region III's review of the Overinspection Program is completed and the results are acceptable to us."-

Conclusion The allegation was not specific and could not be substantiate Further, RIII's extensive overview of the Overinspection Program concluded that the quality assurance effort by Baldwin Associates for the Overinspection Program met requirement Concern #5 The response from the Safeteam about pipe stress problems was

• inadequat Review Region III conducted an extensive review of seismic analysis for as-built safety related piping systems as documented in Inspection Reports 50-461/85030 and 85056. The attributes examined during the inspections that are essential to the seismic piping stress analysis include piping configuration, pipe support / restraint locations, design, function, and clearances. The inspections fulfilled the requirements described in IE Bulletins 79-14-BB, 79-14-1B, 79-14-28, and 79-14-38. No violations or deviations were identified in report 85030 or 8505 Conclusion Based on the review documented above it is concluded that there are no known pipe stress problems at Clinton Power Station; no further inspection is warrante b. (Closed) Allegation (RIII-86-A-0081/#187): On July 11, 1986, Region III submitted the following employee concerns to IP for their investigation and disposition. On July 24, 1986, IP notified Region III by letter U-600661 that their review and followup was complete The inspector reviewed IP's response to the concerns as documented belc Concern #1 Stone & Webster craftsmen were observed on or about May 5, 1986, using the Baldwin Associates test facility without any supervisio Due to the lack of supervision, the craftsmen were able to walk from test booth to test booth and possibly assist each other during welder qualification testing.

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Review The individual also gave this concern to the Safeteam organization on May 5, 1986. IP reviewed the Safeteam investigation files and concurred with Safeteam's conclusion. It.was generally substantiated by the Safeteam that the test booth supervisor did not remain in the test facility area 100% of the day. The supervisor's responsibilities caused him to occasionally leave the area for a few moments; however, other measures were taken to prevent cheating in the welding booths. For example, welding coupons were tack welded in place to prevent turning or tilting, a testing helper was in the area, the walls were transparent, and QC inspectors were present in the test facility most of the day.

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Results This concern, although substantiated, does not have significance in that there is no evidence that cheating occurred or is cheating expected to have been reasonably possible. The inspector does not have any further questions about this concer Concern #2 Stone & Webster did not have any controls over issuance of weld rod to welders, or controls of the rod after issuance as evidenced by weld rod caddies teing in the field for unspecified periods of tim Review Stone & Webster utilized IP procedure CPS No. 1509.04, " Control of Filler Materials". The procedure, approved on January 21, 1986, outlines the requirements for control and issuance of flux covered electrodes. Covered electrodes are allowed to be placed in portable heated ovens (electrode caddies) (Section 8.2.2). Section 8.3.2 of the procedure states that when covered electrodes are issued, they may be stored in electrode caddies during the entire welding operation. Section 8.3.2 further states that at the end of each shift the electrode caddies shall become the responsibility of the oncoming shift welder, or returned to the designated storage area if welding is completed.

, From Safeteam investigations, it was learned that this concern

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originated from an incident where a single rod caddy was not returned from the field. It was confirmed that one electrode caddy was inadvertently returned to Baldwin Associates instead of Stone &

Webste Results Stone & Webster did have procedures for controlling and issuing flux covered welding electrodes. The control of electrode caddies was appropriate even though one caddy was inadvertently returned to the

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wrong ~1ocation. Welds have been inspected by the NRC including

, the control of welding electrodes (Ir.spection Report 50-461/85008, section 3a(5); no violations were identifie ,

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. Inspection Report 50-461/85053 documented the review of Allegation RIII-85-A-109 which describes an unsubstantiated case of improper

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Conclusion

The-inspector agrees with IP's conclusion that Stone & Webster is -

- adequately controlling the processes of welder qualification and control of flux covered welding electrodes. Even though partially

- substantiated, the concerns do not have significance to safet No violations or deviations were identifie I c.- (0 pen)' Allegation (RIII-85-0113-03,#153): On June 28, 1985, an >

individual contacted the Clinton Resident Office. Four concerns were identified. Concern 1 deals with discriminatory termination  !

and is being reviewed by the U.S. Department of Labor. Concern 2 was reviewed as documented in Inspection Report'50-461/8601 This report deals with Concerns 3 and .

Concern #3

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Concern No. 3 states that production pressure was inhibiting the-writing of nonconformance reports (NCRs). Daily inspection record logs, maintained by individual Piping / Mechanical QC inspectors (QC P/M), were used by supervision to determine productivity levels. Use of the logs by supervision placed undue emphasis on production because inspectors would not write NCRs if the

! installation torque did not meet specification requirements for r'

- concrete expansion anchor bolts that secured J. C. White clamp Instead, a nearby craftsman would torque the anchor bolt and the inspector would proceed with the inspectio NRC Review

The inspector reviewed 25 travelers and 10 NCRs associated with

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these travelers; Baldwin Associates (BA) procedure BAP 3.2.5, Revision 9, Piping Component Supports; BAP 2.16, Concrete Expansion Anchor Work; and calibration records for the torque wrenches use The inspector determined that there had been three different methods

' used onsite for torquing concrete expansion anchor installations which were covered by procedure BAP 2.16. These were

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(1) QC P/M inspectors would verify installation torque.

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(2) QC P/M inspectors would have an assigned craftsman verify installation torque.

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e (3) A " HOLD" point would be assigned to the traveler for QC.P/M to

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witness, verify torque, initial and date, and record the actual torque value.

, Review of the procedure, the travelers, and the NCRs substantiated these facts. None of the NCRs reviewed were about torque problems.

1 There appeared to be no bypassing of procedural requirements for writing NCRs.

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The inspector interviewed five former QC P/M inspectors familiar with the installation work performed over a period of two years. These personnel indicated that, to their knowledge, the daily inspection L record logs had not been used as a production yard stick for individual inspectors; however, the logs had been used to forecast overall reduction in force projections based on work accomplished versus remaining work. None of the QC P/M inspectors stated that they had ever felt intimidated by the use of the daily logs nor of

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writing NCRs including those about torque problems. One inspector stated that he could tell how long it would take to work a traveler

! and the logs never interfered with him writing NCRs. As previously mentioned, the review of the NCRs showed that the inspectors had written NCRs, that is, production d'.d not appear to be put before

quality.

[ The concern regarding use of daily inspection logs has previously i been documented in Inspection Reports No. 50-461/85046 and N .

50-461/85065, Concern No. '

Results Based on the inspector's review of records and interviews with i

former QC P/M inspectors, it is concluded that production pressure did not inhibit QC P/M inspectors from writing NCRs, nor did the inspectors bypass the procedural and programmatic aspects of their activities. The use of the daily inspection record log was a management tool used to forecast personnel requirements based on remaining work. This concern could not be substantiated.

I Concern #4

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The individual also stated that the individual's supervisor had told

, the individual that inspections conducted on " type 0" hangers did not require a nonconformance report. The supervisor also told the i individual that the individual "should pass the hanger without 4 writing a nonconformance report as the deficiency would be corrected later".

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NRC Review The inspector determined through interviews with three remaining BA QC P/M inspectors and the individual's former supervisor, that " type 0" hangers were in fact balance of plant (B0P) hangers or_"other" t

hangers meaning "other than safety related". Unlike safety related installations, IP's Construction Quality Assurance Manual

! and the BAP procedures required that deficiencies identified on '

.non-safety related hangers and not supporting safety related piping

were the responsibility of BA Resident Engineering (RE) and th BA RE would review the deficiencies and disposition these deficiencie ,

BOP systems in seismic category I structures required a seismically designed hanger and by procedure these hangers required that NCRs be written on any identified deficiencies or. discrepancies. These

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requirements also applied to B0P systems that did not require '

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seismic hangers but could impair _the function of safety related j equipment in the event of LOCA (commonly known as II/I). ,

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A review of 20 travelers and the associated inspection check lists

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of_ BOP hangers in the category of "not affecting safety related 1 systems" indicated that noted discrepancies had been adequately <

dispositioned. In the categories of BOP systems in seismic category

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j I~ structures and BOP "II/I systems" the inspector reviewed a -

t random sample of 33 hanger drawings and a total of 35 NCRs. The  ;

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review indicated that discrepancies were identified on NCRs and i appropriately dispositioned.

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This concern was substantiated in that the individual's supervisor did direct the individual to " pass the hanger" without writing a ,

NCR. However, based upon review of procedures and discussions with

individuals cognizant of the types of inspections performed, (1)

) there was no safety significant condition that was not handled 1 properly, (2) the direction given to the individual was covered by l properly reviewed and approved procedures, and (3) no violation of *

i programmatic or procedural activities occurre Based upon the reviews performed and the interviews conducted, no further inspections are warranted.

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All technical issues regarding Allegation RIII-85-0113 have been

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No violations or deviations were identified.

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} ' Emergency Procedures Review (42452)

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The purpose of this portion of the inspection was to verify that annunciators for systems declared operable per the technical

specifications had been walked down according to Operations Standing f Order (0S0) 047 (refer to Inspection Report 50-461/86048, paragraph 5.c).

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050 047 directs that alarms be identified according to logic drawings, that alarm panels be correct per annunciator drawings, and that annunciator response procedures properly address all alarms per the annunciator drawing. The drawings utilized during the walkdown are reviewed including change documents such as ECN, FECN, NCMR, FCR, NCR, and FDDR-LHI. Changes made to the annunciators are controlled by the change document themselves, that is, systems may be declared operable even though the change on the change document had not been incorporate If a problem is identified during a review, it is documented on a Field Problem Report (FPR), according to Plant Modification Standing Order (PMS0)-016, for review and resolution by the Plant Technical Department or Nuclear Station Engineering Departmen The inspector reviewed the results of annunciator walkdowns made on three systems including diesel generators, high pressure core spray, and residual heat removal. None of the systems had any outstanding FPRs. The annunciator walkdowns for the above identified systems were done in accordance with OSO 04 No violations or deviations were identifie . Independent Inspection System Walkdowns (71707)

During this inspection period, the inspector assisted in the walkdown of the Screenhouse and Makeup Water Pump House (VH) and the Switchgear Heat

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Removal (VX) heating, ventilatir.g, and airconditioning (HVAC) system With exception of the finding listed below, the activities were documented in Inspection Report 50-461/8605 During the walkdown of the VX system on EL 781' Auxiliary Building, the inspector noted, on non-safety related vent duct M14626 located between Uninterruptable Power Supply (UPS) cabinets IA and 1B, that a seismic duct support on the IB side was unattached. Operational Quality Assurance (0PS QA) was notified. Maintenance Request No. C-18552 was initiated to reattach the restraint. This will be followed during a futtme inspectio (461/86057-01)

No violations or deviations were identifie . Site Surveillance Tours (42051C)

The inspector toured selected areas of the site at periodic intervals during the report period. Those tours assessed the general cleanliness of the site; storage and maintenance conditions of equipment and material being used in site construction; and potential for fire or other hazard It was noted that a trapeze pipe hanger, No. 1MC05026R located in the Low Pressure Core Spray room approximately 10' above Suppression Pool Cleanup pump 1A had no nuts attaching the trapeze portion of the hanger to the threaded rod. QA was notified of this conditio MR No. C-08312 was written identifying this condition. This will be followed during a future inspection. (461/86057-02)

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No violations or deviations were identifie . Open Items

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Open items are matters which have been discussed with the licensee,

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which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Two open items disclosed during the inspection are discussed in paragraphs 5 and 6.

I 8. Exit Meetings'(30703)

! The inspector met with applicant representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection on September 15, 1986. The inspector summarized the scope and findings of the inspection activities. 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 applicant did not identify any such documents / processes as proprietar !

The applicant acknowledged the inspection findings.

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