ML20100F900
| ML20100F900 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/22/1985 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 55-84-02, 55-84-2, U-10259, NUDOCS 8504050322 | |
| Download: ML20100F900 (7) | |
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'ILLIN0/8 POWER COMPANY 1A.120 M
U-10259 CLINTON POWER STATION, P.O. box 678, CLINTON ILLINOIS 61727 March 22, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region-III U.S. Nuclear Regulatory Commission 799 Roosevelt' Road Glen'Ellyn, Illinois 60137 Subj ect:
Potential 10CFR50.55(e) Deficiency 55-84-02 Material Traceability
Dear Mr. Keppler:
On January 11, 1984, Illinois Power Cc,mpany notified Mr. R.
C. Knop, NRC Region III (ref:
IP memorandum Y-18980, 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 four (4) interim reports (ref:
IP letter U-10124,-D. P. Hall'to J. G. Keppler-dated February 14, 1984; IP' letter U-10157, D. P.
Hall to J. G. Keppler dated July 12,.1984;'and IP letter U-10207, t
D. P. Hall to J. G. Keppler dated October'18, 1984; and-IP.
letter U-10240,~D. P. Hall to J. G. Keppler dated January 18, 1985).
Our_ investigation of this. issue is continuing, t.nd this letter represents an interim. report inlaccordance with the~
requirements of 10CFR50:55(e)., Attachment A 'provides -the details of our' investigation tofdate.
We trust that this interim report provides you sufficient.
l background information.to perform a general assessment of this' potentially reportable 1 deficiency and adequately describes our
-overall approach'to resolve'this issu,e.
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i Sincerely yours, e
L 8504050322 850322 D
' Hall fA 0
yj.cePresident
.ns j'
RLC/lr-(SW)-
Attachment cc: - NRCLResident' Office-h Director,10ffice-of I&E, US NRC, Washington,jDC 20555 g
Illinois-Department of' Nuclear Safety gg7g 1
-INPO Records Center,
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~. e - o ATTACHMENT'A Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-02 Material Traceability Interim Report Statement of Potentially Reportable Deficiency l
A condition-potentially adverse to quality was identified in the area of. material traceability.
This concern is based on a 4
number of-Deviation Reports-(DRs), Nonconformance Reports 1(NCRs),
and. Quality Assurance audit findings, documenting problems.
related to-identification:and traceability of,'primarily electrical. hanger materials, installed-at CPS..
An investigation p
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, 1983, Illinois Power Quality Assurance issued Management Corrective Action Request (MCAR) Number.07 to identify an-adverse condition existing in the area'of' material j
traceability.
The= basis for issuance of MCAR'07 included:
1.
The untimely resolution of. Corrective Action-Request'(CAR) a Number 073, which identified a-material traceability problem.
This'problemLwas evidenced by.a.significant number
- of NCRs and DRs written to document electrical hanger-
' support' members installed with incorrect or' missing material
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' identification numbers. -These incorrect or missing
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identification. numbers resulted in the inability to verify
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that theninstalled materials were: correct.
2.
LAn Illinois Power Quality Assurance audit disclosed problems
-regarding; adherence to procedures related to material 1
. identification and' traceability.
LAn Investigation Plan-wastprepared'and implemented by-
.-Illinois Power Company:to' investigate and address the concerns 4
identified in the' area of-material identification and
. traceability.
ThefplanEincludedgthe!following actions:
.A review of historical data leading up-to issuance of_.MCAR.
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07 was performed to identify Lthe scope of past material-traceabil'ity l problems.:
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ATTACHMENT A (continued) 2.
A review of design requirements, specifications, procurement
_ procedures, and construction procedures was performed to evaluate adequacy of the CPS material identification /
traceability requirements and their implementation.
3.
A-list of specific hardware installations affected by the material traceability problem was_ 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.
The investigation has identified several areas where the 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 6.
ASME Section III, Subsection L:
Class 2 and 3, support i
materials 7.
Cable finger assemblies L
Corrective Action Baldwin Associates'-Procedure BAP_l.5 and appropriate.
subtier documents have 3een revised to provide clarification of the traceability regairements and preclude. recurrence of the material traceability problems.
. Changes in the procedures include'the requiretent'that permanent alant materials, upon receipt, will be identified by;hard marking or tagging.
3.
Discipline Superintendents are required to notify-QC prior to subdividing materials in order to verify that traceability is maintained through: installation.
Pag ~e 2 of 6
ATTACHMENT A (continued)
Training on the enchanced procedural controls was given to all' appropriate personnel, concurrent with the revision of applicable BAP procedures.
Additional-corrective actions taken to date include the following:
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The majority of new materials (structural shapes, plates, struts, strut fittings, bolts, etc.) will be purchased as
' safety related only.
1 1.
2.
Laydown yards are being reorganized to clearly segregate materials.
I 3.
Sampling and testing programs were developed and implemented i
to provide assurance that the installations made prior to the implementation of the revised BA procedures have utilized materials capable of meeting design requirements.
4.
A site purge of all non-traceable structural shapes, plates, j
and unmarked bolting material has been performed.
Certain structural shapes and plate. materials utilized in j
the fabrication of electrical supports were: identified as having incorrect anc missing heat or Receipt Inspection Report (RIR) numbers which are necessary for QC verification..
This item was i
partially resolved by the revision of appropriate procedures to require material'. verification in. future installations.
The remaining concern-is to provide assurance that the' installations 4
i made prior'to the implementation of the revised procedures have utilized materials caaable of meeting design requirements..A sampling program has 3een developed and implemented' utilizing
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MIL-STD-414'(Level V)..
Testing-was< performed on a representative population of electrical hangers with traceability problems identified on Deviation Reaorts (DRs) and Nonconformance Reports s'
(NCRs).
This? program established that the materials met the requirements of Sargent & Lundy (S&L) Specification, K-2999 (Ref.
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NCR 23422).
This testing also closed BA Corrective ~ Action Request (CAR). Number,073.
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. NCRs'10214,.10216, and 10217 indicated that Certificates of ComplianceLhad not been-validated for the B-line,'Superstrut, and 1
Unistrut materials used in the' fabrication of electric'al and instrumentation supports.
I The: concerns related.to-B-Line and Unistrut were resolved through BAQA' Survey Audits.
However,'those related to Superstrut remainedi and. sampling programs conducted by1the electrical
' discipline: demonstrated.that Superstrut materials met the-requirements of_S&L Specification K-2999 (Ref. NCR 12597 &
c12598).- Prior to these' sampling = programs, any Superstrut PageL3 ofI6 L
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T-ATTACHMENT A (continued) material used in the fabrication of an instrumentation support
.was. replaced with Unistrut.
Currently, all procurements of strut I
materials'are.made safety-related.
This, in conjunction with the sampling programs, allows all strut materials on site to be
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considered safety-related; and as such, are exempt from heat and
/or:RIR number: traceability.
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-The remaining item under investigation was a field fabricated bracket-(similar to Powerstrut Part #AB-213/214-W) in which:the identity of the triangular-shaped gusset plate was questioned.
Of the.150 brackets fabricated under traveler
- E1188,-22 have been located.
On all of these, the material was identified correctly (RIR No.).
This quantity / acceptance satisfies MIL-STD-105DL(Level II).
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-Baldwin Associates-Quality Engineering has qualified Hilti as a safety-related supplier. utilizing documentation obtained through the Coordinating Agency for Supplier Evaluation-(CASE) and other sources.
Past purchase ordera for Hilti bolts have been-evaluated.
The results of this evaluation determined that 4
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'the' materials and certifications meet the requirements of S&L
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1 Specification K-2944 (Ref. Letter Y-18116, dated January 29, j
1985).
A sampling program was developed and implemented in accordance with MIL-STD-414 (Level V) for testing of> electrical-l and HVAC unmarked ~(lacking manufacturers identification) A-307:
bolts.brequirements^ofA-307(Ref.NCR19789).The program established that the strengt The piping /
4 instrumentation discipline has been reviewed for the use of 3'
unmarked bolts 1(Ref. Letter JWH-65-84, dated 12/14/84).
Although
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s a shipment of unmarked bolts was issued to the~ field, testing has shown that these bolts met the strength requirements of A-307 (Ref. NCR'21931).
The Civil / Structural discipline completed
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their review for the use.of unmarked bolts.
The resu?.tsaof this review determined that there is no impcetJon-the installationc which may have used this material (Ref. Letter.CBR-06-85, dated 1-16-85).
S&L has-clarified the requirements for washer and shim stock with respect to. documentation,-identification,,and traceability via"their/ dispositions to FCRs'10556, 20742, 20988, 21476, and 24423.
BA procedures will.be. revised to address these require-ments ast applicable.
Shims utilized in bolted applications are acceptable, (material 1 type is not a concern in compressive'
. loading) however'those used in welded electrical hanger-installations were investigated in order to determine material:
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'weldability.. Chemical' analysis, as a minimum, was performed on L
those shims found in the' electrical. hanger installations removed for testing!perLthe electrical hanger test program.
This 2
t-analysis demonstrated the material weldability-(Ref. NCR'24659).
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ATTACHMENT A (continued)
Although no objective evidence has been found concerning improper materials identified with pink paint, the practice of marking ASME Section III, Subsection NF, Class 2 and 3 safety related items with pink paint was discontinued.
In lieu of this, items are being-identified with heat numbers and RIR numbers.
An evaluation of the Code requirements for material identification was performed in order to address concerns on past installations.
The evaluation concluded that the Code requirements were not met through this method of material identification.
BA has initiated Corrective Action Request (CAR) No. 222 in order to address the corrective action necessary to resolve this issue.
Finger assemblies for which the material traceability has been identified as indeterminate and documented via an NCR were tested in conjunction with the electrical support materials. This testing has demonstrated the materials met the requirements of S&L specifications K2949/2999 (Ref. Letter Y-26007, dated 12-18-84).
In summary, the problems associated with traceability were, in part, due to the lack of clarity and consistency in procedural requirements resulting in a lack of adherence to those procedures.
Therefore, several Baldwin Associates' Procedures (BAPs) (most notably BAP 1.5), associated Job' Instructions (JIs),
and Quality Control Instructions (QCIs) have been revised to prevent recurrence.
The changes included marking or tagging permanent plant materials, upon receipt and requiring the crafts to notify QC prior to subdividing materials in order _to maintain traceability through installation.
In addition, most materials (structural shapes, plates, strut, strut fittings, bolts, etc.)
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are purchased only safety-related.'This deletes the need for traceability after receipt inspection of particular items.
Steps have been taken to reorganize the laydown yards to clearly segregate materials and a purging of the site has-been performed to remove any non-traceable; structural shapes, plates, and unmarked bolting material.
All issues addressed by this investigation are considered complete except.t he issue concerning the practice of marking ASME III, Subsection NF, Class 2 and 3 safety-related items with_ pink maint and no other markings.
This issue is in'the process of being addressed and resolved by CAR No. 222.
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ATTACHMENT A (continued) 2 Safety Implications / Significance F
Illinois Power; Company's investigation of this potentially reportable deficiency is continuing. 'The safety implications and significance will be assessed after further background-information:is evaluated.
It-is anticipated that approximately r45 days will be necessary to complete our investigation, determine reportability and file a final report on the issue.
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- RLC/gs (SW)
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