ML20100B656
| ML20100B656 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/20/1985 |
| From: | Connell W ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-10250, NUDOCS 8503280504 | |
| Download: ML20100B656 (4) | |
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ILLINDIS POWER COMPANY 1A 120 CLINTON RSA O, P.O. BOX 678. CLINTON, ILLINOIS 61727 February 20, 1985 Docket No. 50-461 s.
Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, II. 60137 Subj ect:
Notice of Violation, dated December 4, 1984, NRC IE Inspection Report Number 50-461/84-30.
Dear Mr. Keppler,
This letter is in reference to the Illinois Power Company response, U-10238, dated January 9, 1985, to the Notice of Violation, dated December 4, 1984, NRC IE Report number 50-461/84-30, concerning the nonconforming installation of concrete expansion anchors.
Illinois Power Company is providing an update on the status of the corrective actions and completion dates thereof.
Please see Attachment A for the details of this update.
I trust that this information is satisfactory to maintain
- compliance with regulatory requirements.
Sincerely yours,
QC Melh&Y W.
onnell Manager - Quality Assurance JB/lr (NRC1)
Attachment cc:
Director, Office of I&E, US NRC, Washington, DC 20555 NRC Resident Office Illinois Department of Nuclear Safety kh D
1 FEB211985
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ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461
Subject:
~ Installation of Concrete Expansion Anchors The Notice of Violation states that piping support traveler
- H-D0-751-I, Supplement.3, Revision 6, has numerous examples-tof failure to follow applicable instructions, procedures, and drawings.
Violations include failure to properly document the nonconforming installation of concrete expansion anchors, failure to verify concrete expansion anchor torque, and failure to inspect new work.
'I.
Corrective Action Taken and the Results Achieved
- 1..
Illinois Power Company; performed an investigation into the circumstances surrounding the installation of piping hanger 1D018010G, traveler H-D0-751-I, Supplement 3..
Several. violations of procedural requirements were identified and documented by IPQA Surveillance Findings C-84-310 through C-84-317.
The violations of procedures are categorized as failure to perform required inspections, failure to correctly differentiate a design change condition from a nonconforming condition, failure to correctly identify incomplete or inadequate documentation, and replacement of concrete expansion anchors without adequate procedures or design documents.
. 2.
The installation of CEAs for hanger 1D018010G was not in accordance with design.
The nonconforming condition is identified by CPS Nonconforming Material Report 1-0338.
Violation of the minimum embedment requirements is documented by CPS Condition Report 1-84-12-018.
3.
Criteria for the installation of concrete expansion anchors addressed only the requirement for replacing failed anchors.
Work on hanger 1D018010G involved replacing an anchor with insufficient embedment,Lan activity not addressed by design or procedures.
Performance of this uncontrolled activity was documented on IPQA Surveillance Finding C-84-313.
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ATTACHMENT A (continued) 4.
IPQA Surveillance Finding C-84-311 identifies the failure to correctly identify the inadequate documentation for this activity.
II.
Corrective Action to be Taken to Avoid Further Noncompliance In order to correct the specific problems identified in this case, the following will be accomplished:
1.
The IPQA Surveillance Findings C-84-310 through 317 will be completed in accordance with established procedures.
Inspection personnel will be retrained in the procedural requirements for inspecting CEA installation.
Redundancy between BAP 2.16 and BAP 3.2.5, Piping Component Supports, has been eliminated by procedure revisions.
Baldwin Associates Engineering personnel able to initiate field change documents and inspection personnel shall be retrained in the project guidelines for distinguishing the need for a design change document from the need for a nonconformance report.
Training will be completed by February 22, 1985, and the activity will be documented.
i 2.
Disposition of the specific nonconformance will be accomplished in accordance with established procedures.
Installation procedure BAP 2.16 has been revised to establish requirements to achieve minimum embedment of CEAs.
3.
Sargent & Lundy has provided design criteria for the replacement of concrete expansion anchors having insufficient embedment.
BAP 2.16 has been revised to incorporate this criteria.
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' Attachment A (continued) 4.
Baldwin Associates has identified the individual who orginally reviewed traveler H-DO-751-I.
All similar travelers reviewed by the individual will be rereviewed by a level II Document Reviewer.
The results of this review will be analyzed and further training will be provided, if warranted.
Corrective action completion date February 15, 1985.
In addition to dealing with.the specifics and resultant corrective action from the Notice of Violation, Illinois Power Company has conducted an in-depth review of the specification, procurement, receiving and issuance, installation and inspection, and training of personnel for anchor bolts.
This activity provides assurance that the program has been reviewed for clarity and completeness and that personnel are properly trained in performing these activities.
III. Date When Full Compliance Will be Achieved Illinois Power Company will be in full compliance on February 28, 1985.
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