ML20083K448

Interim Deficiency Rept 55-83-02 Re Procedural Controls for Insp of Field Counterboring/Internal Grinding of safety- Related ASME Pipe.Initially Reported on 830113.Investigation to Be Completed in Approx 90 Days

ML20083K448
Person / Time
Site:	Clinton
Issue date:	04/04/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-83-02, 55-83-2, U-10137, NUDOCS 8404160177
Download: ML20083K448 (4)

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/LL/NOIS POWER COMPANY U-10137 CLINTON POWER STATION P.O. POX 678. CLINTON. ILLINOIS 61727 April 4, 1984 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

10CFR50.55(e) Deficiency 55-83-02 Counterboring of Safety-Related ASME Pipe

Dear Mr. Keppler:

On January 13, 1983, Illinois Power (IP) 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 ASME pipe. This initial notification was followed by four (4) interim reports (Ref: IP letter U-10029, D. P. Hall to J. G. Keppler dated February 16, 1983; IP letter U-10056, D. P.

Hall to J. G. Keppler dated May 31, 1983; IP letter U-10088, D.

P. Hall to J. G. Keppler dated September 6, 1983; and IP letter U-10111, D. P. Hall to J. G. Keppler dated December 20, 1983).

Our investigation has determined that this issue represents a reportable deficiency under the provisions of 10CFR50.55(e).

This letter represents an interim report in accordance with 10CFR50.55(e)(3).

Statement of Reportable Deficiency 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 documcated by Baldwin Associates' (IP Contractor)

. Quality Control'(QC) or Technical Services (T/S) Departments.

Had this situation gone uncorrected, incorrect field counterbored piping in violation of ASME Ccde requirements would have been installed at Clinton Power Station (CPS).

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NY 'J. G. Keppler April 4, 1984 NRC Background / Investigation Results Subsequent to the discovery of this condition by the ANI, an t

IP. Quality Assurance surveillance confirmed that required

' inspections were not always being conducted and documented for some of the field counterbored pipe. When notified of this condition, the Baldwin Associates Quality Assurance Department issued Corrective Action Request (CAR) Number 113. Closer investigation by IP revealed that project procedures and

.._ A instructions did not provide clear guidance on the performance, b ;y inspection, and documentation needed for piping counter-

. bore / internal diameter grinding.

? The investigation to date has identified 467 piping joints having.a nominal internal diameter difference in excess of 1/16 inch, or where a manufacturer's shop counterbore may have been

. modified by Baldwin Associates, indicating the potential need for 7 field i counterboring. To determine the internal geometry of these joints,---two investigation. techniques were developed. The first uses;an" ultrasonic examination technique developed by NDT Consultants. This technique, employing transducers to measure s ~

,the3 piping.counterbore bevel angle, position, and wall thickness, wasisatisfactorily qualified to a test procedure. A second technique' is used to. measure valve-to-pipe joint counterbores.

The' .counterbore7 condition of these joints is determined using "i vendoradrawin'gs and field measurement. To date, approximately coneihundred five (105)Ljoints have been diagnosed as having

_ l questionable counterbore geometries. The. questionable geometries t . Jinclude(incorrect-bevel angle,. square. cut geometry, and minimum og" ~

,  ; wall 5 violations. TNonconformancecReports or Deviation Reports thave- been written for the .j oints and an. engineering disposition f- Eisibeingiest'ablished/forieacht ,

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. :An addition'alireview of site documentation was-completed on

%~w  : March?31', 198.4,>to verify;thatcall field 3counterbored-piping W'- Joints haveDbeensidentifie'd andEinvestigate_d to determine-

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ia'dequacy& ,The1results ofEthis< additional 4 review arer presently

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J. G. Keppler April 4, 1984 NRC

2. On January 4, 1983, the Baldwin Associates (BA) Piping Department conducted on-the-job training for craf t personnel involved with pipe counterbore.

3. On January 12, 1983, the BA TS Department conducted on-the-job training for Technical Services personnel, covering the assignment of the responsibilities for checking wall thickness and counterbore.

4. Baldwin Ascociates Procedure BAP 2.14 was revised to address piping counterbore. All new piping travelers contain a sequence for counterboring/ internal diameter grinding. This action will preclude the possibility of counterboring being overlooked. Further, this sequence is considered a Technical Services hold point, there-fore, inspection of counterbore will be performed and documented on the traveler. In-process travelers are also being amended to include this step.

5. Technical Services Procedure BTS-405 was revised to clarify the inspection and documentation requirements of piping counterbore. Further, BA Technical Services has fabricated calibrated inspection gauges to imple-ment the counterbore inspection.

6. Quality _ Control Instructions QCI-302 and QCI-309 have been revised to address the inspection and documenta-tion of piping counterbore.

7. Baldwin Associates Procedure BAP 2.24 has been revised to include the requirements of QCI-309 which directs the inspection of counterbore on fire protection piping systems.

8. Baldwin Associates Procedure BAP 2.26 was amended to include a hold point where Technical Services can verify counterbore of Augmented D' piping.

9. _The pipe joints identified as having questionable internal geometries have been documented on Nonconform-ance Reports or Deviation Reports. Resolution of these reports will assure that pipe. joints welded under the previous program meet the requirements of the Architect I

Engineer and the ASME Code.

Safety Implications / Significance Illino'is Power's investigation into the actual affects of the incorrect counterbore geometries have not conclusively shown that the weld. integrity was affected. However,'it can be pos-

,- tulated that an abrupt or square cut counterbore transition could result in a stress riser. Also,_ minimum wall violations could I- .

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• n I i :J G..Keppler April 4, 1984

-NRC

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' result'in an over-stress condition. The cracking in some of the welds.in question could be significant to the safety of operat-

' ions:of CPS. On this basis, the issue is considered to be

. -reportable under the provisions of 10CFR50.55(e).

It is expected that Illinois Power's investigation of this

'iss~ue~will be. complete in approximately ninety (90) days. We trustuthat this interim report provides you sufficient information

..to perform a general assessment of this reportable deficiency and

" adequately describes our approach to resolve the issue.

Sincerely yours,

. . Hall Vice President RDW/ lag ~

' E ' cc:: NRC Resident.0ffice

'; Director, Officetof I&E, USNRC,. Washington, DC .20555 Illinois-Department.of Nuclear Safety INPO Records Cente'r Y

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