ML20076K838
| ML20076K838 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/06/1983 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 1605-L, U-10088, NUDOCS 8309150285 | |
| Download: ML20076K838 (4) | |
Text
s 1605-L ILLINUIS POWER COMPANY y_toogg gy CLINTON POWER STATION. P.O. box 678. CLINION. ILLINOIS 61727 September 6, 1983 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III 3
U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect :
Potential Deficiency 55-83-02 10CFR50.55(e)
Counterboring of Safety-Related Pipe
Dear Mr. Keppler:
On January 13, 1983, Illinois Power verbally notified Mr. F.
Jablonski, NRC Region III (ref:
IP memorandum Y-14090, 1605-L, dated January 13, 1983) of a potentially reportable deficiency per 10CFR50.55(e) concerning procedural controls for inspection of field counterboring/ internal grinding of safety-related pipe.
This initial notification was followed by two (2) interim reports (Ref:
IP letter U-10029, D. P. Hall to J, G. Keppler, dated February 16, 1983, file 1605-L and IP letter U-10056, D. P. Hall to J. G. Keppler, dated May 31, 1983, file 1605-L).
Our inves-tigation into this matter continues and this letter represents an interim report in accordance with 10CFR50.55(e)(3) for this potentially reportable deficiency.
Statement of Potentially Reportable Deficiency i
While conducting a routine inspection, the Authorized Nuclear Inspector (ANI) observed that safety-related piping weld preparations requiring field counterboring were not being in-spected and documented by Baldwin Associates' (IP Contractor)
Quality Control (QC) or Quality & Technical Services (T/S) l Departments.
Had this situation gone uncorrected, incorrect field counterbored piping may have been installed at CPS.
Our investigation has determined the number of piping joints without
(
counterbore inspection documentation and continues toward an l
assessment of the as-built condition of the piping and the l
potential for impact on the safety of operations of Clinton Power Station.
i Background / Investigation Results Subsequent to the discovery of this condition by the ANI, an Illinois Power Quality Assurance (IPQA) surveillance has
_ TEA 7 s 0 8309150285 830906 PDR ADOCK 05000461 S
J. G. Keppler September 6, 1983 NRC confirmed that required inspections were not always being conducted and documented for some of the field counterbored pipe.
When notified of this condition, Baldwin Associates Q&TS Department issued Corrective Action Request (CAR) Number 113.
Closer investigation by Illinois Power into this potential deficiency revealed that project procedures and instructions did not provide clear guidance on the performance, inspection, and documentation needed for piping counterbore, and consistency in inspection and subsequent inspection documentation for piping counterbore activities was not established.
The investigation has identified 346 piping joints having a nominal internal diameter difference of the joined pipes in excess of 1/16 inch, indicating the potential need for counter-boring.
To determine the internal geometry of these joints, an ultrasonic examination technique was developed by NDT Consultants.
This technique, employing transducers to measure the bevel angle, position, and wall thickness, was satisfactorily qualified to a test procedure.
Three hundred eighteen (318) pipe-to-pipe joints have been examined using NDT Consultants' ultrasonic technique. The remaining twenty-eight (28) are factory counterbored valve-to-pipe j oints.
The adequacy of these will be determined using ultrasonic examination, vendor drawings, and field measurement.
Eighty-four (84) o f the examined joints were diagnosed as having questionable counterbore geometries.
Deviation Reports have been written for the eighty-four (84) joints and an engineering disposition will be established for
- each, Further evaluation is necessary to determine the significance of these joint geometries and what, if any, remedial measures will be required.
Corrective Action (Interim)
Although the investigation of this potential deficiency is still in progress, the following actions have been taken to correct the problem and to prevent recurrence:
1.
Further weld fit-up and material identification in-spections were deferred unti] the applicable procedures and instructions wer( revised and training was per-formed.
2.
On January 4, 1983, the BA Piping Department conducted on-the-job training for craf t personnel involved with pipe counterbore.
3.
On January 12, 1983, the BA Q&TS Department conducted on-the-job training for T/S personnel, covering the assignment of the responsibilities for checking wall thickness and counterbore.
4.
BAP 2.14 was revised to address piping counterbore.
All new piping travelers contain a sequence for coun-terboring/ internal diameter grinding.
This action will
J. G. Keppler September 6, 1983 NRC preclude the possibility of counterboring being over-looked.
Further, this sequence is considered a Techni-cal Services hold point, therefore, inspection of counterbore will be performed and documented on the traveler.
In-process travelers are also being amended to include this step.
5.
BTS-405 has been revised to clarify the inspection and documentation requirements of piping counterbore.
Further, BA Technical Services has fabricated calibrat-ed inspection gauges to implement the counterbore inspection.
6.
QCI-302 and QCI-309 have been revised to address the inspection and documentation of piping counterbore.
7.
BAP 2.24 has been revised to include the requirements of QCI-309 which directs the inspection of counterbore on fire protection systems.
8.
BAP 2.26 was amended to include a hold point where Technical Services can verify counterbore of Augmented D piping.
Safety Implications / Significance Illinois Power Company's investigation to determine the as-built condition of those welded counterbored pipe joints not having inspection documentation is continuing.
Until this phase of the investigation is completed, an analysis of the safety implications of this potentially reportable deficiency cannot be performed.
It is anticipated that approximately ninety days will be necessary to further evaluate the as-built condition of welded counterbored pipe joints and to provide a final report on this issue.
We trust that this interim letter provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve the problem.
Sincerely yours, i
P. Hall Vice President 4
REC /km
e.
D, J. G. Keppler September 6, 1983 NRC cc:
NRC Resident Inspector Director, Office of I&E, USNRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center l