ML20134F773

Forwards Const Appraisal Team Insp Rept 50-461/85-30 on 850520-31 & 0610-21,executive Summary & Potential Enforcement Actions

ML20134F773
Person / Time
Site:	Clinton
Issue date:	08/15/1985
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Gerstner W ILLINOIS POWER CO.
Shared Package
ML20134F777	List: ML20134F773 ML20134F787
References
NUDOCS 8508210246
Download: ML20134F773 (9)

See also: IR 05000461/1985030

Text

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UNITED STATES

[<. y,, g NUCLEAR REGULATORY COMMISSION

g p WASHING ton, D. C. 20555

%...../ August 15, 1985

Docket No. 50-461

Illinois Power Company

ATTN: Mr. W. C. Gerstner

Executive Vice President

500 South 27th Street

Decatur, IL 62525

Gentlemen:

SUBJECT: CONSTRUCTION APPRAISAL TEAM INSPECTION 50-461/85-30

Enclosed is the report of the Construction Appraisal Team (CAT) inspection

conducted by the Office of Inspection and Enforcement (IE) on May 20-31 and

June 10-21, 1985 at the Clinton Power Station site. The Construction Appraisal

Team was composed of members of IE, Region III, and a number of consultants.

The inspection covered construction activities authorized by NRC Construction

Permit CPPR-137.

This inspection is the twelfth in a series of construction appraisal inspections

conducted by the Office of Inspection and Enforcement. The results of these

inspections are being used to evaluate the management control of construction

activities and the quality of construction at nuclear plants.

The enclosed report identifies the areas examined during the inspection. Within

those areas, the effort consisted primarily of detailed inspection of selected

haioware subsequent to quality control inspections, a review of selected

portions of your Quality Assurance Program, examination of procedures and

records, and observation of work activities.

Appendix A to this letter is an Executive Summary of the results of this

inspection and of conclusions reached by this office. The NRC CAT noted no

pervasive breakdown in meeting construction requirements in the samples of

installed hardware inspected by the team or in the licensee's project construc-

tion controls for managing the Clinton Power Station. In addition, the

Illinois Power Company's Overinspection Program was viewed as being effective

in identifying deficiencies which had eluded earlier first line inspection and

in providing an added measure of the quality of construction at the site.

However, deficiencies noted by the NRC CAT indicate that a number of construc-

tion program weaknesses exist which warrant additional management attention.

The major areas of concern to the NRC CAT are: (1) ineffective control of work

performed by plant staff on systems and components af ter turnover from con-

struction, (2) examples of inadequate control of design documents including

ineffective corrective actions for previously identified design document

l control discrepancies, and (3) inadequate programs for the verification of

electrical separation,

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Copy to RCPB  ;

0500210246 050015

PDH ADOCK 05000461 l.

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Illinois Power Company -2- August 15, 1985

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Appendix B to this letter contains a list of potential enforcement actions based

on the NRC CAT inspection observations. These are being reviewed by the Office ,

of Inspection and Enforcement and the NRC Region III Office for appropriate l

action. In addition, Region III will be following your corrective action for '

deficiencies identified during this inspection. .

I

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures

will be placed in the NRC Public Document Room. No reply to this letter is

required at this time. You will be required to respond to these findings after

a decision is made regarding appropriate enforcement action.  ;

Should you have any questions concerning this inspection, please contact us or

the Region III Office.

Sincerely, -

-

-

d N

ames M. Tay r, Director

Office of I pection and Enforcement

Enclosures:

1. Appendix A, Executive Summary

2. Appendix B, Potential Enforcement Actions

3. Inspection Report

cc w/ enclosures: See next page

.

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Illinois Power Company -2- August 15, 1985

Appendix B to this letter contains a list of potential enforcement actions based

on the NRC CAT inspection observations. These are being reviewed by the Office -

of Inspection and Enforcement and the NRC Region III Office for appropriate

action. In addition, Region III will be following your corrective action for

deficiencies identified during this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures

will be placed in the NRC Public Document Room. No reply to this letter is

required at this time. You will be required to respond to these findings after

a decision is made regarding appropriate enforcement action.

.Should you have any questions concerning this inspection, please contact us or

the Region III Office.

Sincerely,

.

s

ames M. Tay , Director

Office of I pection and Enforcement

Enclosures:

1. Appendix A, Executive Summary

2. Appendix B, Potential Enforcement Actions

l 3. Inspection Report

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cc w/ enclosures: See next page

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Illinois Power Company -3- August 15, 1985

cc w/ enclosures:

Illinois Department of Nuclear Safety

ATTN: Mr. Gary N. Wright, Manager

1035 Outer Part Drive

l Springfield, IL 62704

Prairie Alliance -

ATTN: Jean Foy

511 West Nevada

Urbana, IL 61801

Allen Samelson

Assistant Attorney General

Environmental Control Division

Southern Region

500 South Second Street *

Springfield, IL 62701

Richard Hubbard

MHB Technical Associates

1723 Hamilton Avenue

Suite K

San Jose, CA 95125

H. S. Taylor, Quality Assurance Division

Sargent & Lundy Engineers

5 E. Monroe Street

Chicago, IL 60603

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Illinois Power Company -4- August 15, 1985

DISTRIBUTION:

Dc5 (Docket No. 50-400)

NRC PDR

Local PDR

JMTaylor

RVollmer

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BKGrimes

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NSIC

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Regional Administrators

Regional Division Directors

HBoulden, OIA

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OCA (3)

WDircks

HDenton

CAT Team Members

Resident Inspector

INPO

All Licensees (Distribution IS)

RCPB:DI:IE* RCPB:DI:IE* DD:DI:IE* DIR:DI:IE* DD:IE* If s,

MPeranich/vj RHeishman RSpessard JPartlow RVollmer JTaylor

08/ /85 08/ /85 08/ /85 08/ /85 08/g /85 08/gr785

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Ill no s Power Company -4-

DISTRIBUTION:

DC5 (Docket No. 50-400)

NRC PDR

Local PDR

JMTaylor

RVollmer

JGPartlow

BKGr mes

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JAxelrad

HThompson

TNovak

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BS egal

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NSIC

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Reg onal Adm n strators

Reg onal D v s on D rectors

HBoulden, 0IA

SECY

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OCA (3)

WD rcks

HDenton

CAT Team Members

Res dent Inspector

INPO

All Licensees (Distribution IS)

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MPeranich/vj RHelshman RSp'e sard JPa low RV61)mer JTaylor

08/4 /85 08/ /85 08/ /85 08 /85 08/ /85

08/{/85

APPENDIX A

EXECUTIVE SUMMARY

An announced NRC Construction Appraisal Team (CAT) inspection was conducted at

Illinois Power Company's (IP) Clinton Power Station during the period May 20-31

and June 10-21, 1985.

OVERALL CONCLUSIONS

Hardware and documentation for construction activities were generally in

accordance with requirements and licensee commitments. However, the NRC CAT

did identify a number of construction program weaknesses, which in most cases,

have resulted in hardware deficiencies that require additional management

attention. These include:

1. Control of work performed by plant staff on components after turnover from

construction requires improvement. This is evidenced by the number of

deficiencies identified in the Maintenance Work Request (MWR) Program.

Three MWRs were found to have used unqualified wire and three MWRs did not

include, or properly document, the required quality control (QC) inspec-

tions. Also of concern is the lack of control of entries into and the

number of errors found in IP's Startup Punchlist Tracking System.

2. Current programs for verification of electrical separation require

improvement. The number of raceway separation deficiencies identified

indicate that control of separation through design without inspection for

separation is not adequate and the current walkdown program has not been

effective. The FSAR does not currently allow the use of analysis which is

now being used to justify reduced separation requirements.

3. Examples were noted where design requirements were not implemented by

construction and verified by quality control activities. This is indi-

cated by examples of hardware deficiencies identified in several areas.

For example, power cable terminations were not insulated as required,

tanks and heat exchangers were supplied with deficient welds, certain

snubber supports were not modelled as committed, and a number of pieces of

equipment were found to be mounted with bolts of a material grade other

than that specified.

4. A number of document control discrepancies were found between the design

change data listed for a specification or drawing in the Document Manage-

ment System (DMS) and the design change documents actually posted with the

controlled construction specification or drawing. This is of particular

concern since control of construction specifications and drawings, and

their computer data bases, is key in the management system established for

ensuring that current design documents are used in developing work pack-

ages for installation and inspection. However, no resulting hardware

deficiencies were noted in a sample of related work checked by the team.

5. Corrective action was not considered timely or sufficiently compreher.,ive

for deficiencies identified by the licensee in the testing of structural

fill. Deficiencies were identified in the structural fill records related

to the lift thickness requirement of structural fill.

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An effort was made by the NRC CAT to assess the IP Overinspection (IPOI)

Program. The NRC CAT noted fewer program or hardware deficiencies in areas

covered by the IPOI Program than in areas not covered by the IPOI Program.

These identified weaknesses require additional management attention to assure

that completed installations meet design requirements.

AREAS INSPECTED AND RESULTS

Electrical and Instrumentation Construction

The electrical and instrumentation samples inspected generally met the appli-

cable design requirements and installation specifications. However, several

discrepancies were identified including some which will require additional

management attention.

Electrical separation critt ia detailed in the CPS FSAR had not been met in

some raceway installations. The review of related activities indicates that

existing design, quality verification and walkdown programs have not been

completely adequate to ass,re compliance with specified commitments, and that

personnel performing walkdown activities have not received adequate training

and acceptance criteria to assure that existing deficiencies will be identi-

fied. Analysis to justify lessor spatial separation is also being used which

is inconsistent with current FSAR commitments.

Separation deficiencies also exist in vendor wiring installed in several

sections of the operator main control panels. In this area, the use of flexi-

ble metallic conduit as a fire rated barrier, and the fire protection adequacy

of certain control room panels are items requiring further NRC evaluation. A

number of deficiencies were also identified in vendor panels that have been

excluded from the special QC inspection program.

Work performed on Class 1E equipment by plant staff under the Maintenance Work

Request Program is not effectively controlled. Examples of unperformed inspec-

tions and the use of unqualified wire in safety-related components were identi-

fied. l

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Design specification requirements were not, in some cases, implemented by the  :

construction and QC activities. This was evidenced by several uninsulated l

medium voltage terminations which were QC, and in one case IPOI, accepted

although design, installation and inspection documents required them to be  ;

insulated.

Mechanical Construction

Piping, concrete expansion anchor installations, heating, ventilating and air

conditioning (HVAC) ducts and supports, and mechanical equipment were found to

be in general conformance to design and procedural requirements.

A-2

Discrepancies were identified in ASME and Class D pipe support / restraint

installations. Greater attention to detail during inspections of Class D .

supports appears necessary. Potential damage and generic implications with  !

respect to PSA 35 snubber component congruity needs to be addressed. A need l

for additional reanalysis of two supports is evidenced by their incorrect  !

modelling. Controls for ensuring the timely removal of temporary supports are l

inadequate.

Welding and Nondestructive Examination

Welding and nondestructive examination activities were generally found to be

conducted in accordance with the governing codes and specifications. However,

a number of examples were identified where completed structural welds in pipe

supports / restraints did not have the weld sizes specified by the Architect

Engineer. Two of these examples were previously covered by IP Overinspection.

The licensee has performed an engineering evaluation concerning this problem

and concluded that the welds are structurally adequate for the intended appli-

cation.

In the area of vendor supplied tanks and heat exchangers a number of tanks were

found to have undersized weld reinforcements in nozzle to shell and manway to

shell welded joints.

The NRC CAT inspectors also found radiographs for welds in areas of the

containment liner and drywell wall which did not meet the specified acceptance

criteria. The containment liner condition had been previously identified by

the licensee who, based upon a sample review, had conculded that no remedial

work was required. Based on this and the fact that MT and vacuum box inspec-

tion had been applied, the CAT concurred with the licensee conclusion.

Civil and Structural Construction

The civil and structural construction areas were found to be adequate. How-

ever, several deficiencies were identified.

The requirements in the FSAR and specifications for cadweld operator testing

frequency were not met. Certain structural fill records were found to be

inadequate relative to backfill lift thickness requirements in the FSAR. In

addition, corrective actions taken by S&L for previously identified deficien-

cies in testing of cadweld operators and structural fill records were con-

sidered inadequate.

Two deficiencies were identified with the implementation of the IPOI Program in

that not all primary steel beams were properly identified per applicable

criteria for inspection and the torquing of bolts for slide connections was not

adequately inspected.

Material Traceability and Control

The licensee's materie traceability and control program was found to be  !

acceptable, except foi certain fastener hardware. Lack of traceability was

found for some vendor supplied fastener materials, including bolts for large

pump-motor and skid-mounted pump-turbine assemblies, and mounting bolts for

HVAC control panel cabinets.

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Design Change Control

The design change control program was determined to be generally in accordance

with site procedures with several exceptions. A number of discrepancies were

identified in the updating of a Civil and Structural Resident Engineer's

Project Procedures Manual. A high rate of discrepancies was also found in the

active change documents listed in the Document Management System related to a

piping design specification and the change documents physically posted with

controlled copies of the specification.

A systematic weakness was identified in the current computer data base system.

The NRC CAT requests for and examinations of work packages associated with the

installation of structural steel and electrical cable tray support design

drawing requirements noted that the computer data base does not currently

satisfy the Baldwin Associates QA Manual objective for an index system which

will ensure the rapid and orderly identification and retrieval of records.

Corrective Action Systems

In general, corrective action measures were found to be acceptable. However, a

high rate of errors was found with entries into the Startup Punch List. These

included the listing of, unrelated corrective action documents against punch list

items, resulting in not identifying the closure against punch list items when

the related corrective action documents were completed. In addition, correc-

tive actions implemented to correct deficiencies identified by IP QA audits in

the area of design document control had not been effective.

A number of nonconformances were found dispositioned use-as-is without evidence

to substantiate this disposition.

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APPENDIX B

POTENTIAL ENFORCEMENT ACTIONS

As a result of the NRC CAT inspection of May 20-31 and June 10-21, 1985, at

the Clinton Power Station site, the following items are being referred to

Region III as Potential Enforcement Actions. Section references are to the

detailed portion of the inspection report.

1. 10 CFR 50, Appendix B, Criterion III, as implemented by Illinois Power

Nuclear Power Construction (IPNPC) Quality Assurance Manual (QAM) Chapter

3, requires that measures shall be established to assure that applicable

regulatory requirements and design basis are correctly translated into

specifications, drawings, procedures, and instructions.

Contrary to the above, at the time of this inspection, the licensee's

program was not adequately implemented in that two ASME Class 1 Nuclear

Steam Supply System snubber supports were found to have been modelled and

analyzed as rigid supports contrary to FSAR commitments to model them as

flexible supports. (Section III.B.2)

2. 10 CFR 50, Appendix B, Criterion VI, as implemented by IPNPC QAM Chapter

6, requires that measures be established to assure that documents such as

instructions, procedures, and drawings, including changes thereto, are

distributed to and used at the location were the prescribed activity is

performed.

Contrary to the above, at the time of this inspection, BA document control

procedures were not properly implemented in that numerous discrepancies

were identified in the filing and updating of procedures in the Civil and

Structural Resident Engineer's copy of the BA Project Procedures Manual,

and in the posting of design change documents in specifications. (Section

VII.B.1)

3. 10 CFR 50, Appendix B, Criterion VII, as implemented by IPNPC QAM Chapter

7, requires measures be established to assure that purchased equipment

and services conform to the procurement documents.

Contrary to the above, at the time of this inspection, the NRC CAT inspec-

tors identified vendor procured tanks and heat exchangers that had been

accepted and installed with deficient welds. They also identified various

vendor and contractor supplied radiographs which did not have the required

weld and film quality. (Sections IV.B.9, 10, and 11)

4. 10 CFR 50, Appendix B, Criterion VIII, as implemented by IPNPC QAM

Chapter 8, requires that measures be established for control of

materials, parts and components to prevent the use of incorrect or

defective items.

Contrary to the above, at the time of this inspection, bolts for mounting

large pump-motors, pump turbine assemblies mounted on skids, and HVAC

control panel cabinets were not as required by the applicable drawings and

specifications. (Section VI.B.1)

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5. 10 CFR 50, Appendix B, Criterion X, as implemented by IPNPC QAM Chapter

10, requires that a program for inspection of activities be established and

executed to verify conformance with documented instructions, procedures

and drawings for accomplishing the activities.

Contrary to the above, at the time of this inspection, the licensee's

inspection programs were not effectively implemented in that they:

a. Have not assured that safety-related electrical raceways have been

installed in accordance with FSAR commitments for electrical

separation. (Section II.B.1)

b. Have failed to assure that appropriate quality verifications are

conducted and that only qualified materials are used for work performed

under the Maintenance Work Request Program. (Section II.B.2)

c. Had not assured that safety-related SkV power cable terminations were

accomplished in accordance with design documents in that required

insulating materials had not been installed. (Section II.B.2)

6. 10 CFR 50, Appendix B, Criterion XVI, as implemented by IPNPC QAM Chapter

16, requires that conditions determined to be adverse to quality are

promptly identified and corrected.

Contrary to the above, at the time of this inspection:

a. NCR 31282 was incorrectly dispositioned by S&L as use-as-is based on

specification requirements having been met, when the specification

and FSAR requirements had not been met for cadweld operator testing

frequency. (Section V.B.1)

b. The resolution of NCR S-S-S-0006 and NCR 174 had not provided a

timely and comprehensive review of applicable soil test data to

ensure the FSAR commitments were met. Corrective action taken for

NCR 174 had accepted structural fill placements using nuclear density

test data where the sand cone test data had failed which was contrary

to the project specifications. Further the evaluation performed of

soils records did not identify or address that the inspection program

during that period had not provided for adequate records or assurance

that the structural fill was placed in 12 inch lifts as stated in the

FSAR. (Section V.B.3)

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