ML20093H996
| ML20093H996 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/12/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1605-L, 55-84-02, 55-84-2, U-10157, NUDOCS 8407250477 | |
| Download: ML20093H996 (4) | |
Text
..
6 bo910 1605-L llLIN018 POWER COMPANY g
U-10157 i
CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 July 12, 1984 Docket No. 50-461
'f Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission i
799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Potential 10CFR50.55(e) Deficiency 55-84-02 Material Traceability
Dear Mr. Keppler:
On January 11, 1984, Illinois Power Company notified Mr. R. C. Knop, NRC Region III (ref:
IP memorandum Y-18980, 4
dated January 11, 1984) of a potentially reportable deficiency per'10CFR50.55(e) concerning material traceability at the Clinton Power Station (CPS).
This initial notification was followed by one (1) interim report (ref: IP letter U-10124, D. P. Hall to J. G. Keppler dated February 14, 1984).
Our investigation of this issue is continuing, and this letter represents an interim report in accordance with the requirements of 10CFR50.55(e).
Statement of Potentially Reportable Deficiency A condition potentially adverse to quality was identified in the area of material traceability.
This concern is based on a j
number of Deviation Reports '(DRs), Nonconformance Reports (NCRs),
4 and Quality Assurance audit findings, documenting problems related to identification and traceability of electrical hanger materials installed at CPS.
An investigation and evaluation of this issue is being performed to determine the extent of this problem, root causes, effect on installed hardware, and significance on the safety of operation of CPS.
Investigation Results/ Background i
On December 20, 1984, Illinois Power Quality Assurance issued Management Corrective Action Request (MCAR) Number 07 to identify an adverse condition existing in the area of material traceability.
The bases for issuance of MCAR 07 included:
4
\\9 B407250477 840712 T,g'g?f
- ii j
PDR ADOCK 05000461 up S
I Mr. James G. Krppler Page 2 July 12, 1984 1.
The untimely resolution of Corrective Action Request (CAR) l Number 073, which identified a material traceability problem.
This problem was evidenced by a significant number of NCRs and DRs written to document electrical hanger L
support members installed with incorrect or missing material identification numbers.
These incorrect or missing identification numbers resulted in the inability to verify that the installed materials were correct.
2.
An Illinois Power Quality Assurance audit disclosed problems regarding adherence to procedures related to material identification and traceability.
An Investigation Plan was prepared and implemented by Illinois Power Company to investigate and address the concerns identified in the area of material identification and traceability.
The plan included the following actions:
1.
A review of historical data leading up to issuance of MCAR 07 has been performed to identify the scope of past material traceability problems.
2.
A review of design requirements, specifications, procurement procedures, and construction procedures is being performed to evaluate adequacy of the CPS Material Traceability Program requirements and their implementation.
3.
A list of specific hardware installations affected by the material traceability problem is being compiled and categorized.
4.
Data collected in steps 1, 2, and 3 above is being analyzed to determine the scope, root causes, and the significance of the issue.
5.
Corrective action for identified hardware / software deficiencies and their root causes is being determined and implemented.
s The investigation, to date, has identified several areas where ths implementation of material traceability requirements is unclear or is in question.
These areas include:
1.
Structural plates and shapes used in electrical supports 2.
Electrical strut and strut fittings 3.
Concrete expansion anchor bolts 4.
ASTM A-307 bolts 5.
Washer and shim stock material
Mr. James G. Keppler Page 3 July 12, 1984 6.
ASME Subsection NF, Class 2 and 3, support materials The problems associated with material traceability were, in part, due to the lack of clarity and consistency in the procedural requirements.
These procedural deficiencies resulted in the lack of adherence to procedures.
Corrective Action (Interim)
Baldwin Associates Procedure BAP 1.5 and appropriate subtier documents have been revised to provide clarification of the traceability requirements and preclude recurrence of the material traceability problems.
Changes in the procedures include the requirement that permanent plant materials, upon receipt, will be identified by hard marking or tagging.
Discipline Superintendents are required to notify QC prior to subdividing materials in order to verify that traceability is maintained through installation.
Training on the enhanced procedural controls was given to all appropriate personnel, concurrent with the revision of applicabic BAP procedures.
Additional corrective action taken to date include the following:
1.
The majority of new materials (structural shapes, plates, struts, strut fittings, bolts, etc.) will be purchased as safety related only.
2.
Laydown yards are being reorganized to clearly segregate materials.
3.
Sampling and testing programs are being developed to provide assurance that the installations made prior to the implementation of the revised BA procedures have utilized materials capabic of meeting design requirements.
4.
The practice of marking ASME III-Subsection NF, Class 2 and 3 safety related items with pink paint was discontinued.
In lieu of this, items will be identified with heat numbers and RIR numbers.
5.
A site purge of all non-traceable structural shapes, plates, and unmarked bo?. ting material has been performed.
Sa!cty Implications / Significance Illinois Powee Company's investigation of this potentially reportable deficicqcy is continuing.
The safety implications and significance vill be assessed after further background information is evaluated.
It is anticipated that approximately
=
Mr. James G..Keppler Page 4 July 12, 1984 six (6) additional months will be necessary to complete our
' investigation and to file a final report on this issue.
Illinois i:
Power intends to provide you with an update of this investigation in approximately ninety (90) days.
We trust that this interim report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve this issue.
Sincerely yours, D. P. Hall Vice President RLC/ lag cc:
NRC Resident Office Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of~ Nuclear Safety INPO Records Center