ML19347F776
| ML19347F776 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/21/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347F775 | List: |
| References | |
| 50-461-81-05, 50-461-81-5, NUDOCS 8105260279 | |
| Download: ML19347F776 (9) | |
Text
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Appendix A NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a result of the inspection conducted from February 9 through March 5, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
10 CFR 50, Appendix B, Criterion V, states that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances....."
The Illinois Power Company, Clinton Power Station, Preliminary Safety Analysis Report (PSAR), Amendment 32, dated August 20, 1975, Section 17.1.5.1 states that, " Formal procedures, instructions, and drawings shall be developed and used, as appropriate, for activities affecting quality. When appropriate, instructions or procedures, and drawings shall include applicable qualitative, and quantitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Contrary to the above:
The hanger installation / inspection tolerance procedure was a.
incomplete in that it did not cover all areas necessary to ensure proper installation and QC acceptance inspection.
b.
Specific inst ructions for installing mechanical snubbers was lacking.
The procedure for installing the penetration seismic guides was c.
not adequately detailed to control weld distortion.
This is a Severity Level IV violation (Supplement II).
t 2.
10 CFR 50, Appendix B, Criterion V, states tbit, " Activities affecting f
quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instruc-tions, procedures, or drawings."
The PSAR, Amendment 32, dated August 20, 1975, Section 17.1.5.1 states that, " Requirements for use of instructions, procedures, sketches, drawings, and related material to control activities which may affect 81e52602 y G
Appendix A quality are generated and implemented within using organizations.
Formal procedures, instructions, and drawings shall be developed and used, as appropriate, for activities affecting quality."
Contrary to the above in the area of pipe supports and restraints:
Eight out of the nine safety related and installed hangers, a.
struts, and snubbers observed by the inspector did not conform to the construction drawing requirements.
b.
The Reactor Water Cleanup pipe penetration seismic guide inside the guide pipe did not conform to tne design drawing clearance requirement.
This is a Severity Level V violation (Supplement II).
3.
10 CFR 50, Appendix B, Criterion X, states that, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instruction, procedures, and drawings for accomplishing the activity."
The PSAR, Amendment 8, dated March 15, 1974, Section 17.1.10.1 states that, "The organization responsible for fabrication, construction, or installation of parts, components, and systems shall prepare an inspection program responsive to the requirements established in the design and procurement documents."
Contrary to the above:
The existing hanger inspection program was inadequate in that it a.
did not provide for timely inspections to identify deficiencies and to initiate corrective actions to prevent recurrence, and it did not distinguish the inspection requirements for each phase of hanger installation.
b.
The traveler QC acceptance provision for the pipe penetration seismic guide was inadequate in that it did not provide for inspection measurements after component installation.
This is a Severity Level IV violation (Supplement II).
4.
10 CFR 50, Appendix B, Criterion XVIII, states that, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the ef fectiveness of the program."
Appendix A The PSAR, Amendment 8, dated March 15, 1974, Section 17.1.18.1 states that, " Requirements are established for a planned system of periodic audits which shall verify compliance with the quality assurance program and determine its effectiveness.... The audit system shall be sufficient to include the full range of activities covered by the scope of the applicable quality assurance program."
Contrary to the above, relative to pipe hanger design and installation activities, the licenser audit of the A-E, the licensee audit and surveillance of contractor site performance, and the contractor's internal audits were considered inadequate in that detailed hanger audit requirements were absence, problems were not prevented from recurring, and programmatic audit planning, scheduling, and implementa-tion was absent for on going safety related hanger installation and QC inspection activities.
This is a Severity Level IV violation (Supplement II).
5.
10 CFR 50, Appendix B, Criterion IX, states in part, that " Measures shall be established to assure that special processes, including welding,..., are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes,..."
The PSAR, Section 17.1.9.3 states, in part, "...IPC Quality Assurance shall periodically audit... contractors to assure that control of special processes is in accordance with requirements."
The ASME B&PV Code S-74, Article NA-4000, Subarticle NA-4411, states in part, that "The program shall include measures to control the issuance and disposition of documents, such as...,
instructions, procedures,..., including changes thereto, which prescribe the ac-tivities affecting quality. These measures shall assure that documents including changes..., and distributed to and used at the location where the prescribed activity is performed."
Contrary to the above, welding was not being accomplished in accordance with applicable codes, in that, controlled welding procedure specifica-l tions with the associated welding parameter sheets were not located at the prescribed activity (welding).
i This is a Severity Level V violation (Supplement II).
1
O Appendix A 6.
10 CFR 50, Appendix B, Criterion XVII states in part, that " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least....results of reviews...."
The PSAR, Section 17.1.17.1 states in part, that "... Records shall typically include verification of results of reviews, Contrary to the above, reviews of nonconformance reports, audits, and surveillances, for reportability pursuant to 10 CFR 50.55(e) are not being documented to enable verification of proper review.
This is a Severity Level V violation (Supplement II).
7.
10 CFR 50 Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality...are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
Illinois Power Company " Quality Assurance Manual", dated June 1, 1979, states, in part, "Coaditions adverse to quality shall be promptly iden-tified and corrected. For significant conditions adverse to quality, the corrective action shall include measures to preclude repetition, when appropriate."
Contrary to the above:
Neither prompt nor effective corrective action to preclude repeti-a.
tion was taken in response to the following audits and other documents concerning electrical hanger installation activities.
(1) Baldwin Associates (BA) Internal Audit Report I-134, dated January 22, 1980.
(2) BA Internal Audit Report I-137, dated February 19, 1980.
l (3) Corrective Action Request (CAR) number 049, dated March 3, 1980.
l (4) BA Internal Audit Report I-150, dated June 24, 1980.
(5) Site Surveillance Report No. S-313 dated August 18, 1980.
b.
The licensee failed to take prompt corrective action in response to a special QA Review of IEEE Environmental and Seismic Qualifica-tions, dated 9-17-80, which identified the current practice of granting unconditional acceptance status to components lacking quality documentation.
This is a Severity Level IV violation (Supplement II).
Appendix A 8.
10 CFR 50, Appendix B, Criterion III, states that, "The design control measure, shall provide for verifying or checking the adequacy of design...."
The PSAR, Amendment 8, dated March 15, 1974, Section 17.1.3.3 states that, "The design of structures, systems, and components is directly controlled within the various Sargent and Lundy design organizations...
Included are measures to assure... accomplishment of design verification with a detailed procedure for an independent de2ign review. This independent design review is performed by qualified personnel, independent of the design group...."
Contrary to the above:
The pipe suspension system components were fabricated and installed a.
prior to formal calculations (design verification) being performed and documented including review and approval by authorized personnel.
b.
Management failed to act to prevent further, fabrication and installa-tion of seismic supports when the apparent problem concerning lack of formal approval of calculations had been identified.
This is a Severity Level IV violation (Supplement II).
9.
10 CFR 5' Appendix B, Criterion II, states, in part, that "The quality assurance program shall provide control over activities affecting the quality of the identified...... components, to an extent consistent with their importance to safety."
Illinois Power Company " Quality Assurance Manual", dated Marc 30, 1979, states, in part, " Activities affecting quality and the conditions under which these activities are performed shall be controlled."
Contrary to the above, the licensee failed to provide quality assurance controls over the preparation, review, and approval of "As Built" electrical hanger d.awings prepared by IPC engineers. Furthermore, the licensee failed to establish which Quality Assurance organization uvild have functional control over the "As Built" electrical hanger progra.c.
As a result, activities affecting the quality of safety related hanger.:
were performed without approved procedures. For example:
The actual "As Built" hanger installation could not be determined l
a.
on six "As Built" electrical hanger drawings reviewed and approved for use by Sargent and Lundy (S&L), the Architect Engineer, due to conflicts in drawing dimensions and indeterminate dimension orienta-tion.
i b.
No program was established to ensure that approved "As Built" design parameters would be implemented into the base design documents. As j
a result, the use of an alternate hanger detail contrary to that specified in the base design criteria was approved.
This is a Severity Level IV violation (Supplement II).
L
Appendix A 10.
10 CFR 50 Appendix B, Criterion VI, states, in part, that " Measures shall be established to coatrol the issuance of documents, such as...... drawings, including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes......are distributed to and used at the location where the prescribed activity is performed."
Illinois Power Company " Quality Assurance Manual", dated June 1, 1979, states, in part, " Documents shall be...... distributed to/used at the location where the prescribed activity is performed. Measures shall be established to assure current revisions of documents are distributed to the point of use and are used."
Contrary to the above, changes and current revision to electrical drawings were not being used as follows:
a.
FCR 6385 was not listed on the field copy of Drawing E30-1003-02A-CPH, Revision C, as of February 24, 1981.
b.
FCR 7452 was not listed on the field copy of Drawing E30-1451-CPH, Revision C, as of February 24, 1981.
c.
FCR 7530 was not listed on the field copy of Drawing E30-1451-CPH, Revision C, as of February 24, 1981.
d.
FCR 7455 was not listed on the field copy of Drawing E28-1001-06A-EIH, Revision E, as of February 24, 1981.
e.
FCR 7455 was not listed on the field copy of Drawing E28-1001-06A-EIT, Revision D, as of February 24, 1981.
f.
Revision B to Drawing E28-1001-05A-CPH was being used in the field on February 26, 1981. Revision C was issued February 17, 1981.
I g.
Revision D to Drawing E28-1001-07A-EIH was being used in the field on February 24, 1981. Revision E was issued February 6, 1981.
l This is a Severity Level VI violation (Supplement II).
11.
10 CFR 50 Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, l
procedures, or drawings, of a type appropriate to the circumstances l
and shall be accomplished in accordance with these instructions, procedures, or drawings."
l Illinois Power Company " Quality Assurance Manual", dated June 1, 1979, states, in part, " Written procedures, instructions, and drawings shall
(
be developed and used, as appropriate, for activities affecting gaality."
l i
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Appendix A Contrary to the above, equipment receipt inspection activities affecting quality were not accomplished in accordance with written procedures as follows:
a.
Paragraph 6.9.1.3 of Baldwin Associates Procedure ( p) 2.3 states, in part, " Quality Control shall revise documentation related to the receipt of the items / materials, e.g. RIR, logs, etc., to reflect the return." Contrary to this, RIR S-11630, dated September 29, 1980, which documented the receipt of the electrical penetration primary header plate bolts was not revised to reflect the return of these bolts to Conax for rethreading.
b.
Paragraphs 112.11 and 112.11a of Sargent and Lundy Specifica-tion K-2978, state "In special cases, where all of the documentation may not be available at the time the equipment is ready for shipment, shipment to the site will be permitted under the following conditions:
upon written approvs1 of the Purchaser, a Certificate of Compliance shall be transmitted with the. shipment. Approval for use of a Cer-tificate of Compliance shall be obtained prior to shipment."
Paragraph 5.2.3. of BAP 2.20 states, in part, "The authorization shall be in letter form signed by the Manager of Quality Control and....shall form a part of the procurement documents." Contra ry to these requirements, Conax Corporation electrical penetrations were shipped to the licensee and a Certificate of Compliance was transmitted in lieu of complete documentation without prior written authorization.
c.
Paragraph 5.2.4. of BAP 2.20 states "Upon receipt of the authorized letter of compliance, items shall be placed on " Conditional Accept" status in accordance with BAP 2.3, for documentation requirements."
Contrary to this electrical penetrations IEE21E, IEE01E, and 4160V electrical switchgear IAP07E were not placed on " Conditional Accept" status nor were conditional accept tags attached as required by BAP 2.3.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twent-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved. Under the authority of Section 182 of the Atomic l
Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
i
'A April 21, 1981 Date James G. Keppler Director i
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Appendix B ITEMS REGARDING UNRESOLVED MATTER We have reviewed the Baldwin Associeces Procedure BAP 2.20, Revision 1, and Sargent and Lundy Engineers Specification No. K2628A relative to the control of documentation and release of safety related equipment for installation.
The following additional information is needed in order to. determine the acceptability of your documentation control program to the requirements of 10 CFR 50, Appendix B, Criteria VII and XV and ANSI N45.2, N45.2.2 and ANSI N45.2.13.
1Property "ANSI code" (as page type) with input value "ANSI N45.2.13.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
When will it be required to write an NCR for either insufficient or deficient dccumentation prior to conditional release of hardware at the site? The response should address both quality-related and engineering documentation required to satisfy procurement and spec-ification requirements.
2.
Describe the criteria used to determine how one differentiates between quality-related documentation and engineering documentation.
Provide a representative list of engineering-type documentation.
3.
Describe in detail when and how S&L determines the required engineering documentation that must be received at the site and found acceptable by BA.
Describe the extent of an independent review and verification of the BA prepared engineering documentation lists prior to release.
Include in your description the extent the list is signed, dated, and controlled to assure it can be properly tracked to maintain it current with hardware configuration and/or purchase order.
4.
Describe the involvement of the S&L QA or QC organization in the preparation of the engineering documentation list.
l 5.
Describe the extent the engineering documentation list delineates the specific engineering, technical, or specification requirements which must be met and which must be substantiated by documentation at the site. Describe the detail in which the received documentation must record engineering results in order to be found acceptable.
6.
Describe the contrels which assure the engineering document list is properly prepared and released prior to conditional release of the hardware.
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7.
Describe the procedural controls for maintaining control and accountabil-l ity (punch list / computer list) for incomplete or deficient documentation.
l Include in your description the specific information the punch lis' and/or computer program contains. Must the punch list and/or computer program i
identify incomplete or deficient engineering documen'.ation prior to con-l ditional release of hardware? Provide your rationale if it does not.
l Describe the controls to close out open items on the punch list and/or l
computer program in a timely manner.
Appendix B 8.
Describe in detail the specific responsibilities of the BA QA organiza-tion when it receives the completed quality and engineering check lists.
Does BA QA evaluate the results of both lists to verify all required objectives have been met, and is BA QA required to sign and date the lists attesting to such?
9.
Describe _the planning for requiring BA and IPC to audit and survey this overall program on a regularly scheduled basis.
10.
Describe the extent Mr. Ennon will evaluate the total program and conduct special surveillance to provide additional professional QA overview and input as to the workability and controllability of this program.
11.
Describe the role of IPC top management in overseeing this overall effort to assure it is properly managed and effective. How much will top manage-ment rely on QA in this regard?
12.
Does S&L intend to revise their specification requirement for the use of a " Certificate of Compliance" in lieu of missing documentation? If not, how will you comply with Paragraph 5.2.4 of BAP 2.207 13.
Will Paragrat h 17.1.)
of the CPS PSAR be revised? If not, will Para-graph 17.1 of the CPS FSAR which states that Paragraph 17.1 of the PSAR was fully implemented be revised?
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