ML19347C235

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Responds to NRC 800828 Ltr Re Violations Noted in IE Insp Rept 50-461/80-16.Corrective Actions:Sys Established to More Adequately Assure Each Design Document Used by Company Is Properly Reviewed
ML19347C235
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/19/1980
From: Koch L
ILLINOIS POWER CO.
To: Fiorelli G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19347C231 List:
References
U-0185, U-185, NUDOCS 8010170072
Download: ML19347C235 (3)


Text

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i U-0185  ;

037-80(09-19)-0  !

1 ILLINDIS POWER COMPANY ' ,

l 500 SOUTH 27TH STREET, DECATUR. ILLINOIS 62525 September 19, 1980 Mr. Gaston Fiorelli, Chief Reactor Construction and -

Engineering Support Branch

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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 August 28, 1980, which included a Notice of Violation and Inspection Report No. 4 50-461/80-16. Illinois Power Company's response for the three )

items of noncompliance cited is as follows:

1. Instructions, Procedures, and Drawings Uhe Notice of Infraction states, in part:

" Contrary to the above 250 containment rebar cadwelds were installed (fired) out of their normal position and vithout following the installation instruction dentted in the ERICO Catalog and Addenda of 1978."

Manufacturer's instructions (ERICO Catalog) for installing cadwelds permit the use of cadweld sleeves out of the normal position, but rec,mmend certain venting techniques to ensure ade- l quate fill of the sleeve with molten metal. Investigation of the l approximately 250 cadwelds in question, revealed that all met the visual inspection criteria and production tensile testing for the population was satisfactory; indicating that proper venting had occurred during installation. This investigation also revealed that the venting technique recommended in the 1978 Addenda of the ERICO Catalog had not been used. I Accordingly, Nonconformance Report (NCR) #3516 was issued to permit further evaluation of the questionable cadwelds. Disposi-tion of this NCR involved visual re-inspection of a percentage of the cadwelds and additional production tensile testing. All SEP 2 4 E00 8 Q103 79 g,q

Gaston Fiorelli September 19, 1980 reinspection results were satisfactory. Based on this additional inspection and testing, plus the acceptable original visual in-spections and re-inspections, the design engineer accepted the approximately 250 cadwelds.

To avoid recurrence of this type o; procedural noncompliance, cadweld operators and quality control inspectors have been instruc-ted on the proper technique for installing cadwelds in non-standard positions. This instruction has emphasized the manufacturer's cur-rent instruction for venting during the installation process.

These actions have been completed and the work is now con-sidered to be in full compliance with established requirements.

2. Instructions, Procedures, and Drawings The Notice of Infraction states, in part:

" Contrary to the above, 38 safety-related HVAC hangers in the 800' level of the Control Building were installed incorrectly and in disagreement with the disposition instructions of Nonconformance Report (NCR) 3030."

After discovery of three incorrect HVAC hanger attachments, a complete reinspection of all HVAC hangers with similar attachment details previously inspected in the 800' elevation of the Control l Building was conducted. Results of this reinspection are reflected l in Nonconformance Report Number 3515, dated August 6, 1980. Engin-eering disposition has been received and work has been completed.

Formal corrective action, (Baldwin Associates CAR #56) was taken to avoid further noncompliance of this nature. This included the establishment of a system to more adequately assure that each de- l sign document used by Zack Company is properly reviewed, controlled, and promptly distributed to cognizant personnel for incorporation into installation documents.

These actions have been completed, and when all hangers have been physically inspacted and accepted, the work will be in full compliance with established requirements. This should be completed by October 1, 1980.

1

Gncton Fiorelli September 19, 1980

3. Inspection The Notice of Infraction states, in part:
a. Zack QC incorrectly verified the faulty installation of 38 safety-related HVAC hangers in the 800' level of the Control Building.
b. Inspection records of the subject HVAC hangers do not reflect ongoing or completed work installations.

Records do not reflect current hanger component interchangeability status.

Caring the reinspection discussed in item 2 above, Zack Company Ouality Control identified the current status of each hanger.

Inspection records were up-dated to reflect this status. Hanger component interchangeability status is currently reflected on each individual hanger and will be verified during final inspections as work is completed.

Formal corrective action was taken to avoid further noncompli-ances of this nature. Action taken included a re-indoctrination of all Zack Company QC Personnel on inspection criteria, stressing that inspections are to be performed to the latest design documents and that material traceability must be maintained and documented. To ,

ensure that the latest design documents are available for inspection, )

design changes rre formally transmitted to the Zack Quality Control i Department, to La placed on a document reading board in the in-spectors' office trailer. The QC inspectors are required to review these documents and signify by initialing. The inspectors will then reference the applicable document (s) on the inspection record (s).

Secondly, as components of hangers are rep.' aced with stock material or interchanged, control numbers will be noted on fabrication tickets to enhance proper traceability. I These actions have been completed and the work is considered to be in full compliance with established requirements, I trust that the above eations constitute an acceptable response i and will satisfactorily complute our Corrective Action.

Sincerely, W

J, Koch Vice President cc: CPS /DRC Microfilm, i.-29 Director - IP Quality Assurance H. H. Livermore, NRC Resident Inspector

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