ML20062J601

Final Deficiency Rept Re Inadequate Instructions & Procedures for Const Welding of Temporary & Permanent Nonsafety Attachments.New Procedure Bap 2.21 Developed & Temporary Attachments Removed

ML20062J601
Person / Time
Site:	Clinton
Issue date:	10/24/1980
From:	Koch L ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, L14-80(10-24)-L, U-0192, U-192, NUDOCS 8011030470
Download: ML20062J601 (3)

Text

._ _ ._. =_ __ -

U-0192

/LLINDIS POWER COMPA:VY (~ ' ,, a Ll4-60(10-24)-L 2 .

C ,, _, ,, 500 south 27TH STFEET. DECATUR. ILLINOIS 62525 October 24, 1980 t

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~

Mr. J. G. Keppler 7 Director, Region III '

Office of Inspection and Enforcement U.S. liuclear Regulatory Commission b.IHIS DOCUMENT CONTA P00R QUAUTy PAGES .

Region III --

799 Roosevelt Road j ,

Glen Ellyn, Illinois 60137 l

Dear Mr. Keppier:

[

i Clinton Power Station Unit 1 ,

Docket No. 50-461 ,

Construction Permit No. CPPR-137 t

On September 24, 1980, Illinois Power Company verbally notified e Mr. H. M. Wescott of a potential reportable deficiencf involving [

welding of temporary and permanent ncn-safety attachments to certain '

~

safety-related structures and components. Illinois Power Company ,

has conducted an investigation of this matter and has determined that the deficiency is reportable under the provisions of 10CFR50. l 55(e) (i) . r k

1. Statement of Reportchle Deficiency ,

Instructions and procedures for construction welding 'of

) temporary and permanent non-safety attachments to certain

! safety-related structures in containment (containment liner,  ;

reacter pressure vessel pedestal, biological shield wall, and

zero degree support structure) were inadequate to properly r document the compliance of these welds to governing standards and codas (i . e. , AS

te , AWS) .

2. Investigation It was found that Baldwin Associates' procedures did not provide for adeqbate documentation of 1) the welding and removal of temporary attachments and 2) the welding of permanent non-safety j attachments to the containment liner and reactor pressure vessel F pedestal (governed by the ASME Boiler and Pressure Vessel Code),

the biological shield wall, and the containment zero degree structure (AWS Dl.1 is the specified code for these last two structures) .

On September 24, 1980, Illinois Pouer's' Supervisor-Construction QA issued a Stop Uork Order for all permanent non-seismic Category I and temporary attachnents to seismic Category I

structures and components in the containment building. Region q III was notified of the potential 50.55(e) on this date. g/0 5 10 q

8 0'110 3 O fh!> ,5

U-0192 L14-80(10-24)-L I

Mr. J. G. Keppler October 24, 1980 Page 2

' 3. Corrective Action 1

, Subsequent to the a cuance of the Stop Work, the following has 1

occurred

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! a. The architect engineer confirmed that the function of i interface welds between non-safety-related items and safety-

! related structures and co=ponents is non-nuclear-safety-i related, but the welds must meet the requirements of the j specified code (e.g., ASME, AUS) for the safety-related j structure.

f l b. The Contractor has been instructed to remove all temporary l attachments from the reactor pedestal, biological shield, 1 and zero degree structure and to perform liquid penetrant e

or magnetic particle examinations of the base metal per

! approved procedures,

c. The contractor is making "as-builts" for che permanent j non-safety-related attachments to the containment liner, j reactor pedestal, biological shield, and zero degree

! structure. Utilizing the "as-builts," the contractor will, j by the end of December, 1980, submit any appropriate

nonconformance reports for the engineer's disposition.

1

{ d. Existing temporary attachments to the containment liner

are either being removed with FE or PT performed on the i base metal or are being suitably reworked and documented

, } for leaving in place as an ASME Section III minor i permanent attachment.

c. The contractor has developed a new procedure, BAP 2.21, I

to control and document attachments to the containment liner, i

reactor pedestal, biological shield, and zero degree j structure.

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f. The contractor's procedure addressing interface welds i l between non-safety-related items and safety-related j structures and components (other than those itemized in

"e" above) has been revised to ensure that the require-j ments of the applicable specifications, codes, and

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standards are met.

1 g. The Stop Work Order for this work uas lifted in tuo l steps on October 9 and October 10, 1980.

4 Safety Imolications/ Significance l

The lack of sufficient documentation for the attachment work could not in itself have constitt.ted a direct safety hasard.

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+

U-0192

, Ll4- 8 0 (10- 24) -L i

Keppler Mr. J. G. October 24, 1980 Page 3 I

j 4 Safety 7molications/ Significance (continued) j It is assumed, houever, that had the procedures which failed i to produce adequate documentation been continued indefinitely, l a real unrecognized safety question could eventually have i occurred. The correcH.ve action described above should pre-

) vent such an occurrence.

This is the final report in accordance with the requirements of 10CrR50. 5 5 ( 2) . He trust that this report is sufficient for your analysis and evaluation of the deficiency and the corrective action.

Sincerely,

)a

'I L. J. Koch

^

q, j Vice President di s

cc: H. H. Livermore - NRC Resident Inspector Director, Office of I&E, Washington, Director-Quality Assurance D.rde"/ *

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