ML20071C911
| ML20071C911 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/18/1983 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20071C909 | List: |
| References | |
| 0981-L, 981-L, NUDOCS 8303080263 | |
| Download: ML20071C911 (4) | |
Text
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i-o 0981-L ILLIN0/8 POWER COMPANY U-10030 IP CLINTON POWER STATION, P.O. BOX 678, CLINTON, ILLINOls 61727 February 18, 1983
~ Docket No. 50-461 Mr. R. C. Knop Chief Projects Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Response to Notice of Violation dated January 18, 1983 and NRC IE Inspection Report 82-20
Dear Mr. Knop:
This letter is in response to your Notice of Violation dated January 18, 1963 and Inspection Report Number 50-461/82-20.
Illinois Power Company's response to the Notica af Violation is as follows:
The Notice of Violation states in part:
" Contrary to the above, the design analysis of the emergency diesel engine exhaust piping did not include bellows expansion joint pressure thrust calculations."
1.
Corrective Action Taken and the Results Achieved As a result of 3 argent & Lundy's (S&L) design re-evaluation and record check, it was confirmed that insufficient bellows expansion joint considerations were factored into the overall system stress analysis.
The re-evaluation included reanalysis of the three diesel generator exhaust piping systems and associated bellows using the correct exhaust pressure in relation to the postulated plant events listed in the System Design Specification.
Service Level A, B, and C loads were recalculated using a 0.2 psig exhaust pressure.
Service level D loads were recalculated using the design value of 5.0 psig.
The loads from the reanalysis are still within the design capacity of the supports.
The support drawings will be revised by March 31, 1983 to reflect the revised loads given in the amended stress report.
The present design calculations identify the resulting torsional effects imposed at the installed bellows.
A 8303080263 830301 PDR ADOCK 05000461 0
PDR FEB 2 41983
F i ^.
Mr.. R. C.' Knop Page 2 February 18, 1983 re-evaluation of the torsional loadings imposed on the bellows reconfirmed the adequacy of the bellows for these loads.
The overall system stability has been verified through review of the existing calculations of the total system.
Tie bars are not included.in the design since the bellows absorb axial movement.
Lateral stability of the support arrangement has been confirmed.
II.
Corrective Action to be Taken to Avoid Further Noncompliance The Sargent & Lundy PIPSYS Training Manual, now in use, was revised in mid-1982 to include requirements for modeling expansion joint bellows and for considering the pressure thrust loads for uncied expansion joints.
Illinois Power believes that implementation of the revised manual will be sufficient to avoid further noncompliance.
III. Date When Full Compliance Will Be Achieved Illinois Power will be in full compilance by March 31, 1983.
Inspection Report Number 82-20 identified five open items for which a written response is required.
Illinois Power Company's response to.these items is as follows:
A.
82-20-02 Baldwin Weld Procedure Specification booklets.are not subject'to the necessary controls.
This problem has been previously identified by Illinois Power QA surveil-lance finding C-82-049 dated October 10, 1982.
I
Response
Corrective action, being taken in accordance with finding C-82-049, is to revise procedure BAP 2.0, Document Control, l
to control the distribution of booklets.
The revised procedure and the associated training will prevent recurrence of this problem.
The procedure revision was completed February 11, 1983.
Issuance of controlled l
booklets to craft and inspection personnel will be l
completed March 4, 1983.
i B.
82-20-03 The NRC IE inspector determined that isometric drawings and sketches used for installation do not contain system flow arrows or flow direction.
1
[
pr. R.'C.
Knop.
.Page 3.
February'18,. 1983
. Response:
This weakness had been previously identified by Illinois Power.
A review, by S&L, of the contractor's. isometric
. piping drawings was. initiated as a result of an Illinois Power identified 10CFR50.55(e) Deficiency-(82-10). The review is being conducted in accordance with S&L Project
' Instruction PI-CP-040, S&L Review of. Contractors' Isometric
-Piping-Drawings, which~ includes the requirement for review for' flow direction.
This drawing review constitutes action to avoid recurrence.
Sargent & Lundy's review of piping isometric drawings will be completed by April 1, 1983.
When the design review is complete, BA will' revise procedure BAP 2.14.~ Fabrication / Installation of Items, Systems, Components and Component Supports, and associated job instructions to clearly define'that the piping isometrics, reviewed by Sargent & Lundy, are the drawings to be used for installation.
C.
82-20-04. Marking of socket welds.for fit-up inspection to assure the approximate 1/16" gap, required by ASME Code,
.Section III,_was questioned by the NRC IE inspector.
Response
Procedure BTS-405, Procedure Specification for Visual Inspection of Weldments, requires inspection of fit-up but
-does not prescribe any verification of~the 1/16" gap after welding.
ASME Code,Section III does not require verification of the gap after' welding is complete; therefore, such verification is not a project requiretaent.
The 1/16" gap will continue to be verified at fit-up.
D.
82-20-05 The current practice of inspection of skewed fillet welds, mainly used on hanger supports (piping, i
electrical, and HVAC) was questioned by the NRC'IE inspec-l tor due to inaccessibility and lack of means to accurately determine adequacy of weld types and sizes.
Response
Corrective action was to suspend initial and final reviews of travelers with skewed fillet welds and'to stop inspection of-skewed fillet welds'until resolution by the design organization.
Additional corrective' action will be scheduled-as necessary to implement specific provicions of the resolution which is due~ March 2, 1983.
E.
82-20-06 Baldwin personnel were verifying wall thickness for pre-service inspection weld joints without using a controlled procedure.
. _, ~. _ -,. _.. _, _ _.. _ _. _ _ _ _. _ _,. _ _ _ _ _ _ _. _,.. _ - _ _. _
c
.i l
Mr.,R. C. Knop Pcge 4 February 18,_1983
Response
Corrective action was to generate procedure BTSI-012, Instructions for the Usage of Inspection Devices, to include the manufacturer s instructions which were used to perform this test.
The procedure includes those items from
-the training program which already certified and documented the training / certification of the persons using the digital ultrasonic device.
Training on the new procedure BTSI-012 was completed and the procedure released for construction December 28, 1982.
No further corrective action is necessary.
I trust that our response is satisfactory to allow closure of the item of noncompliance and the open items identified in Inspection Report Number 82-20.
I hereby affirm that the information in this 2
letter is correct to the best of my knowledge.
Sincerely yours,
. Hall Vice President cc:
J. G. Keppler (Regional Administrator, Region III)
Director, Office of Inspection and Enforcement, Washington, D. C.
l NRC Resident Inspector Illinois Department of Nuclear Safety IP Ifanager - Quality Assurance l