ML20092N627
| ML20092N627 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/04/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20092N623 | List: |
| References | |
| 0981-L, 981-L, U-10159, NUDOCS 8407030354 | |
| Download: ML20092N627 (3) | |
Text
,_ _
g N..
l 0981-L r.
. til/N018 POWER COMPANY U-10159 CLINTON POWER LTATION, P.O. 80x 678. CLINTON, ILLINOIS 61727 June 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:
Response to Notice of Violation dated February 21, 1984, NRC IE Inspection Report Number 50-461/84-04
Dear Mr. Keppler:
This letter is in response to your Notice of Violation dated April 24, 1984, Inspection Re3 ort Number 50-461/84-04.
Illinois Power Compary's response to the two items of noncompliance is as follows:
1.
.The Notice of Violation states in part:
7 pe riser a.
The two installed load bolts of RHR 1
clamp M-IRH07105R were full length threaded rod
,/
threaded only at each end as called for on the rather than that of 1-3/4" diameter studs, drawing Bill of Material.
As a result of the incorrect installation, load bolt threads were located in shear plane of the riser clamp, in violation of the ASME Code.
b.
The installed load bolt on RHR pipe hanger clamp M-IRH05005V had threads located in the load bearing part of the shank (shear plane), in violation of the ASME Code.
I.
Corrective Action Taken and the Results Achieved Concurrent with the NRC inspection, Illinois Power Quality Assurance issued Surveillance Finding C-84-039 to documert the incorrect material installation of item la.
Nonconformance Report (NCR) 14968 was issued to identify the discrepant condition and to disposition the deficiency.
Subsequently, the licensee identified item lb and issued NCR 15334.
kDkk$b!!o$ oho!!t G
PDR JUN 7 1984
s Mr. Jcmes G. Keppler Page 2 Baldwin Associates Corrective Action Request (CAR) 157 was issued.to affect programmatic corrective action.
As required by CAR 157, a review of similar travelers for piping hangers was performed.
No additional instances of
' fastener substitution were identified.
- The cognizant design organization-(Basic Engineers) has reviewed the load capacity data calculations for the hanger configuration in question.
Hanger load capacity is adequate
.to allow load bolt threads in the shear plane.
The Architect / Engineer has accepted the conclusions of the
-design organization and has changed the design specification.
II.
Corrective Action to be Taken to Avoid Further Noncompliance A change to the design specification clarified the use of threaded _ fasteners subjected.to shear plane forces.
Appropriate inspection personnel have received training to re-emphasize that fastener threads are not allowed in the shear plane of ASME piping hangers except as permitted by design.
III.~Date When Full Compliance Will be Achieved Illinois Power Company is in compliance as of the date of this letter.
2.
The Notice of Violation states in part:
. Baldwin Associates Quality Control incorrectly invalidated.(closed in process) Nonconformance Report (NCR) 15334 on the basis of a subcontractor memo, thereby bypassing the specified NCR management corrective action' reviews and ASME Code requirdments.
The NCR identified a safety related strut pipe. hanger bolt loaded-in pure shear that had its-threads. located in the load bearing part_of the shank. ' The NCR also identified that the installed condition was contrary.to the_ requirements of~ASME Code,Section III, Subsection.,
NF, Paragraph 4722(b).
1 1 '.
Corrective Action Taken and the Ra'sults Achieved
~ -- s s
-Evaluation of'the cited condition resulted in the initiation ofc NCR 15976 to document:and disposition the improper closure of NCR 15334.
The required change to the des gn i
drawing was made, and NCR 15976 has be'en closed.
x.
' ~-
t m
_N~
Mr. Jcmes-G. Kcppler Page 3 a.
NCR-15334 was closed prematurely because of a zmisundersteading about the acceptability of the subcontractor (designer) memo.
The subcontractor memo was mistaken-for an endorsement of existing design documents.
Actually, the memo presented a new application for the identified pipe hangers.
The Architect / Engineer had not yet reviewed.the new application when NCR 15334 was closed in-process.- Subsequently, the information supplied by the subcontractor memo was incorporated into the design specifications.
II. - Corrective-Action-to be Taken to Avoid Further Noncompliance Procedure BAP 1.0, Nonconformances, was revised to include management in the decision process for Nonconformance Reports that are closed in-process.
.In addition, training has been presented which reiterates the requirements for in-process closure of Nonconformance Reports.
III. Date When Full Compliance Will Be Achieved Illinois Power Company is in compliance as of the date of this letter.
'I_ trust that our response is satisfactory to allow closure laf the items of noncompliance identified in the Notice of Violation.
Sincerely yours, D. P. Hall Vice President JJRS/ lag cc:
Director, Office of I&E, US NRC, Washington, DC 20555 NRC' Resident Office Illinois Department of Nuclear Safety i