ML20101D697

Final Deficiency Rept 55-84-17 Re Work Performed on GE Components.Initially Reported on 840723.Existing Means to Verify Quality Requirements of GE Documents Satisfactory. Condition Not Reportable Per 10CFR50.55(e)

ML20101D697
Person / Time
Site:	Clinton
Issue date:	12/06/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-17, U-10226, NUDOCS 8412240168
Download: ML20101D697 (5)

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1A.120 flLIN0/8 POWER COMPANY . U-1022 6 ffy CLINTON POWER STATION, P.O. BOX 678 CLINTON. ILLINOls 61727 December 6, 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:

Potential 10CFR50.55(e) Deficiency 55-84-17 Work Performed on General Electric Components

Dear Mr. Keppler:

.On July 23, 1984, Illinois Power Company notified Mr.

Jablonski, NRC Region III, (Ref: IP memorandum Y-21937, dated -

July 23, 1984) of a potentially reportable deficiency concerning '

work performed on General Electric components. This initial notification was followed by one (1) interim report (Ref: IP letter U-10196, D. P. Hall to J. G. Keppler, dated August 23, 1984). Illinois Power's investigation of the above issue is complete and has determined that the issue does not represent a t reportable deficiency under the provisions of 10CFR50.55(e).

This letter is submitted as a final report regarding this potentially reportable' deficiency. Attachment A provides the details of our investigation. .

i We trust that this final report provides you sufficient i background information to perform a general assessment of this .

i potentially reportable deficiency and adequately describes our  ;

overall' approach to resolve the issue. ,

Sincerely yours, l

D. P. Hall Vice President

RLC/ lag'(NRC2) i Attachment

~cc : NRC Resident Office, V-690 Director - Office of I&E, US NRC, Washington, DC 20555 ,  :

Illinois Department of Nuclear Safety i INPO' Records Center DEC 121984i i PD t$f0h4 }

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ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-17 Work Performed on General Electric Components Final Report Statement of Potentially Reaortable Deficiency (Withdrawn)Bac3 ground On July 21, 1984, Illinois Power issued Condition Report No.

1-84-07-070 concerning General Electric's (CE's) quality requirements pertaining to visual inspections and/or wire checks on GE design change documents (i.e., Field Disposition Instructions (FDIs) and Field Deviation Disposition Requests (FDDRs)).

General Electric's quality requirements have been incorporated into the Nuclear Control & Instrument Department (NC&ID) Procedures II GA-024, 025 and 026 for inspection of electrical work involving the following:

1. Power Generation Control Complex (PCCC) modification in the Control Room, and

2. GE safety related equipment modifications outside the Control Room.

These procedures have not been directly utilized by the Constructor, Baldwin Associates (BA), for work performed on GE components outside the Control Room. A traveler work package described in subsequent paragraphs is used.

GE has qualified their electrical equipment, both seismically and environmentally, based on workmanshia as outlined in NC&ID Procedures II GA-024, 025 and 026. Since t3e Constructor did not directly utilize the NC&ID procedures in the work travelers, GE felt that equipment could have been modified that may not meet GE's requirements for equipment qualification.

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w ATTACHMENT A (continued)

Investigation Results/ Corrective Action Illinois Power (IP) prepared and im31emented an investigation plan to determine the extent of this pro 31en at the Clinton Power Station (CPS). The investigation plan included:

1. Baldwin Associates' Procedures and Instructions were reviewed to identify any GE quality inspection requirements that had not been incorporated.

2. Applicable BA procedures were revised to resolve discrepancies identified by Item 1 above.

3. Baldwin Associates' Training Program, SAM 21, for electrical control and instrumentation work was evaluated.

4. All electrical FDDRs/FDIs incorporated into travelers involving work on safety related GE components were identified and reviewed to determine if additionni QC inspection / checks were needed to meet GE quality requirements. No additional QC requirements were identified.

Our investigation of this issue has shown that Baldwin Associates (BA) utilize Control Room Assembly Procedures (C.R.A.P.s) Nos. I through 8, and 10 through 25, which provide quality assurance requirements that are consistent with General Electric's II GA procedures. BA includes the applicable assembly procedures in their work travelers for Control Room modifica-tions. The assembly procedures have been expanded to include Nos. 1 through 30 and all have been approved by GE. Assembly Procedure No. 22 uns derived from GE's NC & ID Procedures II GA-024, 025 and 026. A comparison of these procedures noted only minor differences.

For modification work on safety-related electrical c equipment outside of the Control Room, BA uses a traveler work package. The traveler work package references the requirements of Sargent & Lundy's Electrical Installation Specification K-2999, and the following Baldwin Associate's procedures:

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ATTACHMENT A (continued)

- BAP-3.3.3, Cable Installation

- BAP-2.10, Equipment Installation

- BAP-3.3.7, PGCC Cable Installation / Termination

- BAP-3.3.9, Cable Protection Qualit control inspections were performed to Baldwin Associates'y Quality Control Instructions (QCI's) Nos. 404, 408, and 308. These QCI's have been incorporated into BAPs 2.10 and 3.3.3. Cable testing is performed, in accordance with GTP-40.

(C&IO Phase Test Procedures).

The electrical craft personnel performing installation work are trained to BA procedure TPS-126, Electrical Terminations.

Procedure TPS-126 covers installation practices as well as accept / reject criteria for electrical cable terminations.

Calibration requirements for tools, in addition to inspection hold points, are reviewed by the craft. The training instruction given to craft personnel also includes:

- Cable bending radius requirements

- Cable jacket and wire insulation stripping methods

- Terminal lug installation methods

- Tool selection

- Hardware requirements A comparison review of II GA-024, 025 and 026 with

associated BA work documents and procedures determined that BA conforms satisfactorily to GE's quality inspection requirements.

In order to help facilitate the final review of completed change documents, GE has requested BA to issue a more definitive procedure outlining the specific II GA inspection requirements, pertaining to equipment modifications performed outside of the control room.

The scope of the problem associated with the impicmentation of GE's quality requirements regarding visual inspections and wire checks for GE change documents has been determined to be minimal, since the means of verification and applicable documentation are availabic in the BA system. In order to make GE's inspection requirements, as contained in II GA Nos 024, 025, and 026, more visible, BA issued Assembly Procedure No. 32 for GE  ;

modification work performed outside of the control room. This l procedure will be included in BA's work travelers that are reviewed and approved by GE. Additionally, BA has updated Assembly Procedure No. 22, where appropriate, to assure full ,

compliance with GE quality requirements. i Page 3 of 4

• i ATTACHMENT A (continued)

Safety Implications / Significance Investigation of this potentially reportable deficiency has determined that the existing means of verifying the quality requirements for work associated with GE change documents are satisfactory.

Investigation of this potentially reportable issue is complete. Illinois Power Company has reviewed and evaluated the findings of the investigation and has determined that no i significant conditions, adverse to the safe operations of CPS were found. On this basis, the issue is considered to be not reportable under the provision of 10CFR50.55(e).

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