ML20127D383
| ML20127D383 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/17/1985 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Samelson A ILLINOIS, STATE OF |
| References | |
| NUDOCS 8506240213 | |
| Download: ML20127D383 (7) | |
Text
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JUN 171986 Allen Samelson Assistant Attorney General Environmental Control Division State of Illinoi:
500 South 2nd Street Springfield, IL 62706
Dear Mr. Samelson:
This letter documents our meeting in Region III's office on May 9,1985. The meeting was about concerns you had regarding Illinois Power's Overinspection Program.
Enclosed is a synopsis of the meeting.
Thank you for sharing your concerns with us.
If you have any additional questions, please feel free to contact me or Robert F. Warnick of my staff at (3I2) 790-57I7.
Sincerely,
%h@ Signed by E.G. Greenman" C. E. Norelius, Director Division of Reactor Projects
Enclosure:
Synopsis of Meeting Between Region III and Illinois Attorney General cc w/ enclosure:
W. C. Gerstner, Executive Vice President DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Richard Hubbard l
Gary N. Wright, Manager Nuclear Facility Safety Jean Foy, Prairie Alliance H. S. Taylor, Quality Assurance l
Division J. Harrison, RIII l
J. Muffett, RIII
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ENCLOSURE SYN 0PSIS OF MEETING BETWEEN REGION III AND ILLIN0IS ATTORNEY GENERAL A meeting was held on May 9,1985, in the NRC RIII office with representatives of the Illinois Attorney General (IAG). The purpose of the meeting was to discuss matters relating to the Overinspection Program being implemented by Illinois Power (IP) at the Clinton site.
The meeting was held at the request of the IAG's office in accordance with the Joint Stipulation signed January 28, 1985.
Representing PIII were:
C. Norelius, R. Warnick, J. Harrison, J. Muffett, F. Jablonski, and T. Gwynn.
Representing the IAG were:
A. Samelson and R. Hubbard.
Mr. Hubbard opened the meeting at 1:00 p.m. by stating that the IAG's office did not have a general level of comfort regarding the findings being made by IP during overinspections and the resulting actions being taken by IP and RIII.
Mr. Hubbard stated that the IAG's office had concerns in basically four areas:
corrective action; personnel and personnel management; items important to safety but not safety-related; and general conduct of the overinspection. Mr.
Hubbard supplied the participants with a handout to aid in his presentation.
(Seeattachment.)
CORRECTIVE ACTION Mr. Hubbard expressed concern that IP was not addressing the IAG's question regarding the effectiveness of IP's corrective actions in identifying root causes of work related problems. He asked how 48,000 nonconforming attributes identified during overinspections had gotten through first line inspection if corrective action taken during the recovery period in 1982 and 1983 was effec-tive. He was concerned that IP's response to the deficiencies as not being safety significant would discourage QC inspectors from reporting problems if dispositions to nonconforming conditions were always "use as is."
!!r. Hubbard was concerned that the overinspection data had not been disaggregated by building, pipe size, elevation, or worker to make analysis of the data more meaningful.
Mr. Gwynn responded that RIII had asked IP to quantify old and new work but the data was erroneous; however, conformance rates were generally improved for new work. RIII stopped review of IP's request for change to the Overinspection Program pending resubmittal of corrected data by IP.
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- 2 PERSONNEL AND PERSONNEL MANAGEMENT Mr. Hubbard stated that there have been repeated audits by RIII which show qualifications of inspection personnel to be questionable; however, most times the actual work was deemed acceptable. Mr. Hubbard was concerned that if a requirement exists for a person to be qualified he should be qualified.
Mr. Hubbard also stated there was an ambience of communication problems, management problems, and acts of intimidation. The IAG's office is concerned that the large backlog of work and inspections may have created undue pressure to meet the schedule at the expense of safety.
Mr. Hubbard expressed concern that NRC's Office of Investigations (01) seemed to take a long time to complete investigations. Mr. Norelius responded that 01's investigation is in depth and the number of cases submitted to the Department of Justice has dramatically increased.
Mr. Hubbard commented on RIII Report 461/85013 about as-built criteria not being established or developed. Mr. Hubbard was concerned about who made technical decisions on nonconformance reports. He stated that only Sargent and Lundy or General Electric should be able to make dispositions, not IP, in accordance with Criterion II of Appendix B to 10 CFR 50.
Mr. Gwynn responded that IP has ultimate responsibility for the design but per Criterion III of 10 CFR 50 all nonconformances requiring engineering disposi-tion are done so by Sargent and Lundy or General Electric, as required, or by Illinois Power with designer oversight.
Mr. Hubbard expressed concern about heating, ventilation, and air conditioning (HVAC) and other problems mentioned in RIII Report 461/85004. Mr. Gwynn responded that there wasn't a problem with HVAC design but with implementation l
of the design.
ITEMS IMPORTANT TO SAFETY Mr. Hubbard was concerned about the limited inspection by RIII of items important to safety encompassed by the philosophy stated in General Design Criterion 1.
Mr. Gwynn responded that two systems important to safety -
radioactive waste and fire protection - were already included in the established QA program for safety-related items and were being overinspected.
IP has not asked for relief in those areas.
In addition, nonsafety-related Seismic Category II items installed over safety-related Seismic Category I items are also included in the Overinspection Program. Mr. Warnick responded that RIII would not redefine the Overinspection Program to include other systems important to safety.
. GENERAL CONDUCT OF OVERINSPECTION Mr. Samelson expressed concern with IP's proposed criteria of 10,000 attributes, and reliance on future testing activities for termination of a specific over-inspection area. Mr. Muffett responded that in some cases, such as hot and cold hanger settings, preoperational testing could be considered a viable criterion for making future decisions. -RIII expressed simiiar concerns to IP in correspondence with them regarding the same subjects.
Mr. Samelson was concerned about IP's engineering evaluations of design problems. Mr. Samelson also expressed concern with the post hoc justifications Sargent and Lundy had to make related to the Independent Design Review.
He wanted assurance that before any relief was given to overinspections, all discrepancies identified by Mr. Muffett would be rectified. A brief discussion concluded with a general statement that criteria for relief will not be automatic for any item.
It was agreed that there would be some generic aspects but case by case evaluations would be necessary for further relief from overinspection requirements.
Mr. Hubbard indicated that RIII should issue more items of noncompliance when warranted.
The meeting concluded at approximately 3:00 p.m.
The NRC staff expressed appreciation for the views of the State. With the exception of the "Important to Safety" recommendation, the staff indicated it was pursuing issues similar to those raised by the State.
ILLINOIS ATTORNEY GENERAL /NRC MEETING CLINTON QA/QC PROGRAM EFFECTIVENESS (5/9/85)
WIDESPREAD INDICATIONS OF DEFICIENCIES IN IP CORRECTIVE ACTION MEASURES Overinspection identified 48,745 nonconformances/only e
9.4 percent involving documentation.
Re Overinspection - common factor was lack of procedural e
compliance and lack of attention to detail (85-15).
e Misleading and/or false educational information supplied on resumes (85-15, 85-18, 85-5).
Provisions for as-built drawing program, including the e
responsibilities for development and maintenance of the drawings, had not been clearly established (85-16, 85-2).
Poor communication and management /potentially serious e
management problem in the BA DRG (85-8).
Incomplete / inadequate disposition being provided on e
NCR's by NSED (85-13).
e Failure to meet FSAR commitment (why no NRC noncompliance issued) (85-11, 85-4).
RECOMMENDATION ONCE IP ESTABLISHES QA/QC MEASURES, THEY MUST BE VIGOROUSLY ENFORCED.
NRC MUST INCREASE ENFORCEMENT ACTIVITIES.
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Table V-2 Nonconformances Within Nonconformance Types l
I' Number of Percent of Nonconforming Total Type Attribute Attributes Nonconformances Welding Weld size 8,081 16.6 Undercut 6,791 13.9 Overlap 2,379 4.9 Convexity 60 0.1 Concavity 105 0.2 Lack of fusion 1,184 2.4 Porosity 193 0.4 Slag 1,225 2.5 Crack ISS 0.4 Reinforcement 145 0.3 Transition 4
0.0 Subtotal 20,355 41.8 Installation Wrong hardware 1,142 2.3 R
Missing hardware 1,502 3.1 Loose hardware 2.t 93 5.1 Incomplete 253 0.5 Cold set 39 0.1 Orientation / configuration 1,019 2.1 Tolerance 3,630 7.4 Clearance / interference 310 0.6 Slope 50 0.1 Routing 22 0.0 Bending radius 74 0.2
% rong weld 1,S $9 3.8 Gaps 559 1.1 Thread engagement 108 0.2 Termination error 107 0.2 Subtotal 13,167 27.0
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Page 2 of 2 Table V-2 Nonconformances Within Nonconformance Types Number of Percent of Nonconforming Total Type Attribute Attributes Nonconformances Damage.
Arc strike 7,206 14.8
~
Grinding 534 1.1 Dent / bent / warped 576 1.2 Gouge / scratch / cuts 1,464 3.0 Bolt / nut broken 47 0.1 Coating missing 150 0.3 Defective material 190 Dirt / debris 0.4 S4 Protection 0.2 16 Rust 0.0 41 0.1 Holes 263 Gaps 0.5 85 0.2 Subtotal 10,656 21.9 R
Documentation ID missing / incorrect 3.SS 7 S.O Drawing incorrect 403 0.S Traceability 123 Inspection error 0.3 154 0.3 Subtotal 4,567 9.4 Total 48,745 100.6