ML20115H252

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Responds to NRC Re Violations Noted in Insp Rept 50-461/84-28.Corrective Actions:Insp Personnel Given Addl Training Emphasizing Design Requirements for Locating Single Attachments on Anchor Plates
ML20115H252
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/16/1985
From: Connell W
ILLINOIS POWER CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20115H243 List:
References
U-10239, NUDOCS 8504230034
Download: ML20115H252 (3)


Text

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l iLLINolS POWER COMPANY 1A.120 jfy Q2h suinon. p.o. eox s,s. cLanion. lLLINots 61727 January 16, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Response to Notice of Violation dated December 14, 1984, NRC IE Inspection Report No. 50-461/84-28

Dear Mr. Keppler:

This letter is in response to the Notice of Violation documented in NRC IE Inspection Report Number 50-461/84-28 dated December 14, 1984 concerning nonconforming conditions not being identified by quality control inspectors. Please refer to Attachment A for the details of our response.

I trust'that our response is sufficient to permit closing the item of noncompliance identified in the Notice of Violations.

Sincerely yours, Quality Assurance JRS/gs (NRCl)

Attachments cc: Director, Office of I&E, US NRC, Washington, DC 20555 NRC Resident Office Illinois Department of Nuclear Safety 8504230034 850220 JAN 181985 PDR ADOCK 05000461 G PDR ,

)

ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461

Subject:

-Piping Hanger Location on Anchor Plate The Notice of Violation states in part that:

...a program for inspection of activities affecting quality was_not pro'perly executed as demonstrated by the fact that NRC findings had not been identified by quality control inspections. The missed nonconforming condition was the failure to observe, record, and issue

. deficiencies against unsatisfactorily installed pipe supports.

I. ' Corrective Action Taken and the Results Achieved Illinois Power Company has evaluated the two examples cited by NRC IE Inspection Report- 50-461/84-28. Piping supports lRT-16051X and 1HP-03025G do exceed location tolerances for support attachment to anchor plate. Differences between the two installations, however, caused inspection personnel to apply the inspection criteria differently. Consequently, separate corrective action was directed at each problem.

1. Piping support 1RT-16051X is a single attachment to an anchor plate. Nonconformance Report (NCR) 22652 was issued to disposition the adverse condition. The licensee has determined that both first-line inspection and overinspection criteria accurately reflect design tolerances. A review of overinspection records has determined that this condition is not a recurring problem. Inspection personnel were given additional training on December 7, 1984 to emphasize the design tolerances.
2. Piping support 1HP-03025G is a double attachment to an anchor. plate.- NCR 66886 was issued to disposition the adverse condition. Investigation into the cause of the nonconformance has identified an ambiguity in design tolerances. First-line inspection is correctly applying the design tolerance'for locating the piping support to the anchor plate, while overinspection was misinterpreting the design tolerance.

Field Engineering Change Notice (FECN) 7048 was issued November 28, 1984 to provide additional tolerance for double attachments to anchor plates. Training in FECN 7048 was given to the applicable inspection personnel on_ December 21, 1984. Personnel who were not available Page 1 of 2

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for training on December 21, 1984 will receive training by January 18, 1985.

Double attachment piping supports accepted by overinspection will be reinspected in accordance with an approved sample plan. Completion of the sample plan is anticipated by February 22, 1985.

II. Corrective Action to be Taken to Avoid Further Noncompliance

1. Inspection personnel have been given additional training emphasizing the design requirements for locating single attachments on anchor plates. Because the condition is not a generic problem, no further corrective action is necessary.
2. FECN 7048 and the associated training have clarified the design criteria for locating piping support double attachments to a single anchor plate.

III. Date WNen Full Compliance Will Be Achieved Illinois Power Company will be in full compliance by January 18, 1985 when training is complete.

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