ML19320D558

Responds to NRC 800520 Ltr Re Violations Noted in IE Insp Rept 50-461/80-06.Corrective Actions:Inspectors Reinstructed on Visual Insp & Bend Test Requirements

ML19320D558
Person / Time
Site:	Clinton
Issue date:	06/17/1980
From:	Gerstner W ILLINOIS POWER CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19320D556	List: ML19320D558
References
Q37-80(06-17)-6, Q37-80(6-17)-6, NUDOCS 8007210521
Download: ML19320D558 (4)

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j. /LLIN0/S POWER 00MPANY U-0147 Q37-80(06-17)-6 500 SOUTH 27TH STREET, DECATUR, ILLINOIS 62525 June 17, 1980

- Mr. Gaston Fiorelli, Chief

' Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Fiorelli:

This is in response to your letter dated May 20, 1980, which included a Notice of Violation and Inspection Report 50-461/80-06.

Illinois Power Company's response for the four items of noncompliance is as follows:

1. Handling, Storage, and Shipping The Notice of Infraction states, in part:

Contrary to the above, requirements for the preservation and maintenance of equipment removed from the warehouse and stored in-place or installed in the plant are not addressed in Procedure BAP 2.4, " Storage and Maintenance."

Baldwin Associates Procedure-BAP 2.4, " Storage and Maintenance,"

has been revised to clearly include material and equipment stored in-place and installed, within the scope of the construc-tion stage storage and maintenance program. The change should ensure that in-plant storage levels and maintenance require-ments, as recommended by appropriate manufacturers, are met throughout plant construction. This change was issued and implemented on June 3, 1980.

As partially verified by the NRC inspector during the course of the inspection, equipment storage levels and maintenance requirements were being met, even though BAP 2.4 did not specifically state this requiremant for in-plant equipment.

Investigation revealed that the storage and maintenance program was being extended to in-plant equipment. Further, it was determined that the omission of applicable words from the scope statement of the procedure was en isolated instance of oversight.

To avoid recurrence,, greater care will be exercised by BA and IP supervision in reviewing the scope statements for future procedures.

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-[ Q37-80(06-17)-6 Mr. Gaston Fiorelli June 17, 1980 Page 2

-2. Quality Assurance Program The Notice of Infraction star.es, in part:

' Contrary to the above, IP Quality Assurance Program did not provide control of the site settlement monitoring program which was inadvertently identified as non-Category I on Drawing S20-1004, Revision C. The results of the monitoring program are required to assure that the founda-tion for Category I structures are providing their intended function and within the limits established for the structure design. basis.

As stated in the Notice of Violation, no response to this item is required. The settlement monitoring program has been desig-nated Category I and is being carried out under an applicable QA-program.

Illinois Power takes exception to the Commission's statement that the site settlement program was inadvertently classified as non-Category I. In July, 1977, when the program was implemented, based on the regulations and an engineering eval-uation, it was not considered necessary to categorize the settlement program as seismic Category I. A controlled program' was undertaken solely for assurance that the soils associated with the seismic Category I foundations of the station structures behaved as expected.

3. Control of Purchased Material, Equipment, and Services The Notice of Infraction states, in part:

Contrary to:the above, measures were not established to assure conformance to procurement documents, in that the NRC inspector identified the following_ conditions on embedded plates accepted by the fabricator and in storage on site:

a. Automatic machine welded studs with manual welded repairs which had not been tested as required by AWS.

b. Studs on embedded plates had been bent greater than the maximum bend of 30 .

c. Studs broken or partially broken off.

d. Studs wiahout the required 3600 weld flash that were not bend-tested according to AWS.

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] Q37-80(06-17)-6 Mr. Gaston Fiorelli June 17, 1980 Page 3 To correct what woulu < gear to be inadequate vendor inspection and testing of studs on embed plates supplied by Rockwell Engineering, an extensive reinspection of embed plates in storage was conducted. Approximately forty percent of all embed plates in storage were visually inspected, which included 12,962 individual studs. Bend tests were performed on the nine (9) studs, which did not clearly meet visual inspection, plus thirty-nine additional randomly selected studs. One (1) stud failed the bend test. This single failure is not considered to be significant. These inspections, tests, and evaluations--completed on April 21, 1980--were reviewed by the NRC inspector during a recent visit and found acceptable.

To avoid future non-compliances of this type, Rockwell Engineering has committed to internal corrective actions to reinstruct If inspectors on visual inspection and bend test requirements.

future fabrication for Clinton is performed at Rockwell's manu-facturing facility, a surveillance will be conducted by Baldwin

' Associates Quality Control to verify conformance with procure-ment documents.

4. Audits The Notice of Deficiency states, in part:

Contrary to the above, applicable elements of the Quality Assurance program have not been audited annually, in that General Electric Company has been involved in directing the installation activities of the reactor internals at the Clinton site for greater than one year and has not been audited by the licensee.

As confirmed by the inspector during the course of the inspection, all aspects of General Electric's design and fabrication activities associated with Clinton Power Station, except those technical direction activities at the construction site, have been audited annually by Illinois Power throughout the design and construction phase. The GE activities at the construction site have been closely followed by Illinois Power Construction Quality Assurance surveillances, which are fully documented. A formal audit of General Electric activities at the Clinton site was conducted this past week, which constitutes the date for completion of specific corrective action.

A complete review of the scope of Illinois Power Company's formal audit program has been conducted to ensure completeness. This

. review confirmed that this program is in full compliance with auditing commitments.

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-Q37-80(06-17)-6

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Mr.!Gaston-Fiorelli June 17, 1980 Page 4 I trust that-:the above actions constitute an acceptable response and will satisfactorily complete our corrective action. .

Sincerely, ,

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, us, m W. C. Gerstner Executive Vice President di cc: CPS /DRC,'T-29 H. H. Livermore, NRC Resident Inspector f

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