ML20079H163

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Responds to NRC Re Noncompliance Noted in IE Insp Rept 50-461/83-15.Corrective Actions:Piping/Mechanical QC Insp Criteria Piping Sys Fabrication/Installation Procedure Revised to Clarify Insp Frequency
ML20079H163
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/10/1984
From: Hall D
ILLINOIS POWER CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20079H152 List:
References
0981-L, 981-L, U-10120, NUDOCS 8401230345
Download: ML20079H163 (2)


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0981-L ILLIN0/8 POWER 00MPANY fjy y.10120 CUNTON POMR STATION, P.O. BOX 678, CLINTON. ILLINOIS 61727 January 10, 1984 I

l-Docket No. 50-461 l

Mr. James.G. Keppler i

Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 f

Subject:

Amended Response to Notice of Violation dated September 29, 1983 NRC IE Inspection Report Number 50-461/83-15: ASME Piping Ovality

Dear Mr. Keppler:

This letter is an amended response to the Notice of Violation dated September 29, 1983, Inspection Report Number

'50-461/83-15.

The response which follows supersedes the response to Item B previously submitted by Illinois Power Company in a letter from D. P. Hall to J. G. Keppler, 0981-L, U-10104, dated October 27, 1983.

Also addressed in the response are the concerns identified by letter from J. F. Streeter to W. C.

Gerstner dated November 17, 1983.

Illinois Power Company's amended response to Item B of the Notice of Violation is as follows:

B.

The Notice of Violation states in part:

... instructions, procedures, or drawings did not I

require that measurements be performed for all 2" and under pipe bends to assure that the bends were in compliance with the 8% ovality tolerance.

Consequent-ly, sufficient records were not available to furnish evidence of acceptable bent pipe.

I I.

Corrective Action Taken and the Results Achieved Baldwin Associates Quality Control (BAQC) inspection of ASME pipe bends is included in the provisions of procedure QCI-302.

Although the procedure requires inspection for ovality, past BAQC practice was not to record measuring equipment data when inspection verified conformance to requirements.

Ovality within the tolerances of the ASME Code,Section III, was documented by BAQC inspector accep-tance on the inspection checklist or fabrication traveler.

l The single checklist entry denoted the acceptance of all attributes for the pipe bend.

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Mr.-James G. Keppler Page 2 January 10, 1984 Previous-inspections of ASME Code pipe bends are not supported by documentation of the measuring equipment used nor by the numerical value of ovclity.

To correct this matter, all ASME bends will be reinspected, and documentation will show the measuring equipment used by the c

inspector and the actual measurement for ovality.

A review has been performed to identify the applicable pipe bends

requiring reinspection.

II.. Corrective Action to be Taken to Avoid Further Noncompliance Procedure'QCI-30?.. Piping / Mechanical QC Inspection Criteria-Piping-Systems Fabrication / Installation, was revised October 4, 1983, Revision 3, to clarify the inspection frequency and to provide documentation of the calibrated measuring device used.

QCI-302 was further revised January 6, 1984, by

' Quality Procedure Change Request (QPCR)83-232 to require the inspector to record the actual measurement for ovality..

-Concurrent with processing the Revision 3 to QCI-302, BAQC conducted a training session for piping / mechanical

. inspectors.

The ASME Code,Section III, ovality tolerances for pipe bends were reiterated, and the proposed changes, later approved, to QCI-302 were presented.

Training was completed September 2, 1983.

Concurrent with processing QPCR 83-232 to QCI-302, BAQC conducted a training session for piping / mechanical inspectors.

The training addressed the documentation requirements for ovality inspection.

Training was completed December 2, 1983.

.III. Date When Full Compliance Will be Achieved Illinois Power Company was in full compliance on January 6, 1984.

I trust that our amended response is satisfactory to allow closure of the item of noncompliance identified in the Notice of Violation.

S 1

ours, D. P. Hall Vice President JRS/ lag cc:

Director, Office of I&E, Washington, D.C.

20555 NRC Resident Office Illinois Department of Nuclear Safety

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