ML20112J392

Final Deficiency Rept 55-84-22 Re Installation of Three Gallery Platforms Located in Screenhouse.Initially Reported on 841017.Issue Not Reportable Per 10CFR50.55(e)

ML20112J392
Person / Time
Site:	Clinton
Issue date:	03/19/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-22, U-10255, NUDOCS 8504050112
Download: ML20112J392 (5)

Text

__

.I 1-

" knB l

ILLINOl8 POWER 00MPANY fp Uf 39yg CLINTON PCMER STATION P.O. 80X 678, CLINTON, ILLINOIS 61727 March 19, 1985 Docket No. 50-461 I

Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Potential 10CFR50.55(e) Deficiency 55-84-22:

Screenhouse Gallery Platforms

Dear Mr. Keppler:

On October 17, 1984, Illinois Power Company notified Mr. F.

Jablonski, NRC Region III (Ref: IP Memorandum Y-25867, dated October 17, 1984) of a potentially reportable deficiency concerning the installation of three (3) gallery platforms ocated in the screenhouse. This initial notification was iollowed by one (1) interim report (ref: IP letter U-10224, D.

P. Hall to J. G. Keppler dated November 27, 1984). Illinois Power's investigation of this issue is complete. Our investigation into this matter has determined that this issue does not represent a reportable deficiency under the provisions of 10CFR50.55(e). This letter is submitted as a final re, ort in accordance with the requirements of 10CFR50.55(e). Attaciment A provides the details of our investigation.

We trust that this final report provides sufficient information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve this issue.

Sincerely yours,

. . Hall Vice President RLC/lr(LCF)

Attachment cc: NRC Resident Office Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of-Nuclear Safety INPO Records Center jp b)[) I 8504050112 850319

\ I gDR ADOCK05000ggi MAR 2 51985

\

e

' ATTACHMENT'A-Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-22:

Screenhouse Gallery Platforms

. Final Report

^

~ Statement of Potentially Reportable Deficiency During the conduct of a non-safety related concrete .

expansion anchor test program, it_was discovered that three (3)

Category 1 gallery platforms, located in the screenhouse, had ~

-been installed as non-safety related. An-investigation and evaluation of-this issue has been performed to determine the extent of the problem, root cause, effect.on installed hardware, and significance to the safety of operation of the Clinton Power Station.(CPS).

Background

Asfa result of a non-safety related concrete expansion anchor test program, a violation of bolt saacing requirements was noted for the concrete expansion anchors w31ch supported a gallery platform located in the screenhouse, elevation 707'6".

During :the performance of an evaluation of the load capacities for the bolt spacing violation, Baldwin Associates Civil /

Structural Engineering discovered that the gallery platform should have been-installed in accordance with the requirements for Category 1 structures / components.

Investigation-Results/ Corrective Action Preliminary investigation disclosed that a. total of three (3) Category'l platforms.were installed as non-safety related.

-Nonconformance Report (NCR) No. 22002'was issued to document

identified discrepancies.

Further investigation revealed that the gallery platforms have safety-related conduit: located directly below, and supported by these platforms. The handrails, of.the. platforms, encompass safety-related -piping, such that the' piping could be subjected to additional loads should the platform supports fail.

During.the dispositioning of-NCR No. 22002, Sargent & Lundy (S&L); requested verification of' installation. torques of the high

-strength bolts utilized for the gallery platforms, and inspection of the' structural welds for defects. NCR No. 24594 was 1 of 4 ,

. - - . - , - - - - . . - . . , - - _ ~ , - - . . - . - -

(

ATTACHMENT A

- (continu;d) initiated to document identified deficiencies. NCR No. 24840 was i initiated to document inadequate expansion anchor embedment, and l NCR No. 24987 to document expansion anchor installation torque i failure during the rework associated with NCR No. 24594. i Technical Requirements Sargent & Lundy's drawing No. M11-1004, Revision B, dated August 24, 1977, Circulating Water Screenhouse Gallery Framing, calls for the fabrication of three gallery platforms, at I elevation 711' - 0", in the Screenhouse, with the drawing  :

released per Specification K-2939, Preliminary Site Work, a non-safety-related Construction Technical Specification.

Revision C of drawing No. M11-1004, dated November 20, 1979, revised the elevation to 707' - 6", and released it per safety-related Specifications K-2947, Furnishing Structural Steel, and K-2948, Erecting Structural Steel. In addition, Revision C of drawing M11-1004, was stamped Category 1, "For Gallery Framing Only '.

Baldwin Associates (BA) Purchase Order (P.O.) No. C-14583 procured safety-related material from Bristol Steel & Iron Works on October 23, 1978. Rider #1 of P.O. No. C-14583, dated June 19, 1979, required all necessary safety-related documentation, i.e.: certificates of compliance, test reports, inspection reports, NDE records, etc., however Rider #1 was issued as Related."

"Non-Safe issued as ty' Safe ty-Related" .All subsequent riders to P.O. C-14583 are The material for P.O. C-14583 was received at Clinton Power Station on September 10, 1980. Non-Safety Receiving Inspection Report (RIR) No. N-11417, documents the acceptance of the material.

Investigation Results/ Corrective Action Illinois Power (IP) prepared and implemented an investigation plan to determine the extent of this problem at CPS. The investigation plan included:

1. A review of documentation was performed to determine the cause for the gallery platform steel being receipt inspected and installed as non-safety related.

2. An evaluation was performed by Illinois Power Quality Assurance and Nuclear Station Engineerin g Departments to determine if the gallery steel is usaile in a Category 1 structure.

3. A review was aerformed of Structural Travelers to ensure that this aroblem was limited to the three (3) identified screeniouse gallery platforms.

4. Sargent & Lundy performed a review for adequacy of the gallery platforms to carry design loads.

2 of 4

, ATTACHMENT A (ctntinu d)

The following items discuss the results of our investigation:

1. A review of documentation, i.e., RIR No. N-ll417, design drawings, and project specifications (K-Specs.),

was conducted to determine the cause for the gallery platform steel being receipt inspected and installed

under the non-safety program. Although the review of the documentation, as described in the Technical Requirements Section above could not be substantiated as the specific cause, it is considered a theory.

Discussions with BA Receiving, QC Receiving, Engineering, and craft personnel (ironworkers) possibly l involved in the receipt inspection or installation of i the gallery platform steel appear to support this theory. Since much of the structural steel in the screenhouse is non-safety, the assumption was probably made that the gallery platforms were also non-safety.

2. An evaluation of existing documentation was performed by Illinois Power Quality Assurance (IPQA) and Nuclear Station Engineering Department (NSED) to determine if the gallery platform steel was usable in a Category 1 i structure. IPQA obtained copies of the Certified i Material Test Reports (CMTRs) and Certificates of f

Compliance (C of C) for RIR N-11417 and requested NSED to evaluate the documentation package. NSED conducted the evaluation of the documentation package and l concluded that the material components supplied are in full compliance with applicable specification l

requirements for Category 1 structures.

3. Additional tests / rework was accomplished per the direction of S&L's disposition for NCRs 22002, 23162, 24594, 24840 and 24987, which were issued to document

, identified deficiencies associated with this investigation. Additionally, NCR 28369 was issued to document discrepancies noted during the QC final review of the associated rework travelers. All NCRs have been resolved in accordance with approved site procedures.

i 4. A sampling plan was developed by Baldwin Associates (BA) Civil Structural Engineering to review Structural Travelers and provide assurance that the problem is l limited to the three platforms identified. The sampling plan was expanded to perform a complete review of the safety-related gallery platforms in the Auxiliary, Containment, Control, Diesel Generator, 3 of 4

__-.-._-..__.---.A

. ATTACHMENT A (continuad)

Fuel, Radwaste, Screenhouse, and Turbine buildings.

This review was accomplished using the Structural l Travelers identified for all installed gallery platforms. During the course of the review, three Category 1 ladder platforms in Electrical Manhole No.

2, located between the screenhouse and powerblock, were found to have been installed as non-safety. NCR 26800 L was issued to document this condition and was resolved i in accordance with approved site procedures.

f A review of existing documentation for the electrical manhole ladder platforms, i.e., receiving inspection report S-13987, design drawings, and project specifications (K-Specs) was conducted. All necessary i documentation was found in receiving inspection report

! S-13987, i.e., certified Material Test Reports (CMTRs),

vendor inspection reports, receiving inspection reports, and vendor documentation review checklists.

Since the same personnel responsible for inspection or installation of the screenhouse gallery platforms were also responsible for the electrical manhole ladder platforms, the assumption, again, was possibly made that the ladder platforms were also non-safety.

5. Sargent & Lundy performed an engineering review of the screenhouse gallery platforms to determine whether a significant safety deficiency would have existed if the conditions described had not been identified and corrected. The evaluation conclusion was that even if the conditions described had gone uncorrected, the gallery platforms would not have failed, and therefore would not have adversely affected the safety of operations of CPS.

[ The deficiencies identified by inspection of the i electrical manhole ladder platforms, as required by the t disposition of NCR 26800, and documented by NCR 27423 were reviewed and evaluated by Sargent & Lundy with final disposition of use-as-is.

Safety Implications / Significance i Illinois Power's investigation of.this potentially reportable deficiency is complete. S&L has reviewed and evaluated the deficiencies' associated with this issue and has stated that.the identified deficiencies, had they gone

! uncorrected, would not have adversely affected the safety of

! operations of CPS.- On this basis, the issue is considered not to j be reportable under the provisions of 10CFR50.55(e).

1 4 of 4 l

f t _ _ _ _ _ .