ML20093A006

Final Deficiency Rept 55-83-02 Re Procedural Controls for Insp of Field Counterboring/Internal Grinding of safety- Related ASME Pipe.Initially Reported on 830113.Questionable Pipe Joints Documented on Nonconformance Repts

ML20093A006
Person / Time
Site:	Clinton
Issue date:	06/27/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1605-L, 55-83-02, 55-83-2, U-10174, NUDOCS 8407100006
Download: ML20093A006 (4)

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1605-L llLIN018 POWER COMPANY U-10174 CUNTON POWER STATION. P.O. 80x 678. CLINTON. ILLINOIS 61727 June 27, 1984 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevele Road Glen Ellyn, Illinois 60137

Subject:

10CFR50.55(c) 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(c) concerning procedural controls for inspection related of field ASME counterboring/

pipe. internal This initial grinding [ollowed notification was byof safety-five (5) interim reports (Ref: IP letter U-10029, D. P. Itall to J. G. Keppler dated February 16, 1983: IP Ictter U-10056, D. P.

Itall to J. G. Kep sler dated May 31, 1983: IP letter U-10088, D.

P. Itall to J. G. :Coppler dated September 6,1983: IP letter U-10111, D. P. Itall to J. G. Keppler dated December 20, 1983: and IP letter U-10137, D. P. Itall to J. G. Kepaler dated April 4, 1984). Our investigation has determined t)at this issue represents a reportable deficiency under the provisions of 10CFR50.55(c). This letter represents a final report in accordance with 10CFR50.55(c)(3) .

Statement of Reportable Deficiency

.While conducting a routine inspection, the Authorized Nuclear Inspector (ANI) observed that safety-reinted piping weld preparations requiring field counterboring were not being in-spected and documented by Baldwin Associates' (IP Contractor)

Quality Control (QC) or Technical Services (T/S) Departments, llad this situation gone uncorrected, incorrect field counterbored piping in violation of ASME Code requirements would have been installed at Clinton Power Station (CPS).

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J.-G. Keppler June 27, 1984 NRC Background / Investigation Results Subsequent to the discovery of this condition by the ANI, an 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 instructions did not provide clear guidance on the performance, inspection, and documentation needed for piping counter-bore / internal diameter grinding.

The investigation to date has identified 515 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 field 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 the piping counterbore bevel angle, position, and wall thickness, was satisfactorily qualified to a test procedure. A second technique is used to measure valve-to-pipe joint counterbores.

The counterbore condition of these joints is determined using vendor drawings and field measurement. 'To date, 95 joints have required rework. The rework was required due to incorrect bevel angle,-square cut geometry, and minimum wall violations. Noncon-formance Reports or Deviation Reports.have been written for the joints and an engineering disposition has been established for each.

An additional review of site documentation was completed on March 31, 1984, to verify that all field counterbored piping joints _have been identified and investigated to determine adequacy. ,

-Corrective Action The followingtactions have been taken to correct the problem

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and to' prevent. recurrence:

1. Further' piping weld fit-up and material identification inspections were deferred until the applicable proced-

'ures and instructions were revised and training was y performed. ,

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J. G. Kcppler June 27, 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 Associates 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 Engineer and the ASME Code.

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

. postulated that an abrupt or square cur counterb ore trans ii t on

J. G. Keppler June 27, 1984 NRC could result in a stress riser. Also, minimum wall violations could result in an over-stress condition. The cracking in some of the welds in question could be significant to the safety of operations of' CPS. On this basis, the issue is considered to be reportable under the provisions of 10CFR50.55(e).

We' trust that this final 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,

/

D. P. Hall Vice President RDW/cah cc: NRC Resident Office Director, Office of I&E, USNRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center