ML20209C736
| ML20209C736 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 09/04/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| References | |
| NUDOCS 8609090109 | |
| Download: ML20209C736 (9) | |
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Docket No. 50-461 Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th Street Decatur, IL 62525
Reference:
Letter, D. P. Hall to J. G. Keppler, U-600514, dated April 3, 1986 Gentlemen:
This letter is in reply to your letter of April 3,1986, notifying Region III that Illinois Power Company had completed the Overinspection Program at Clinton Power Station.
Enclosed with this letter is a synopsis of the Overinspection Program, a tabulation of correspondence and documents pertaining to the Illinois Power Company Overinspection Program, and a tabulation of NRC inspection reports documenting overinspection activities.
The overinspection of completed construction work was necessary at the Clinton Power Station because the Illinois Power Company could not assure Region III in 1982 that the installed structures and components were free of critical defe' cts which could adversely affect the operation of safety related systems.
Based on Region III's review of Illinois Power Company's overinspection data and engineering evaluations-and Region III's independent inspection, review, and evaluation, it is concluded that the Overinspection Program was conducted in accordance with approved plans and procedures, and that none of the discrepant attributes identified during the overinspection had significant safety implications. Region III's review of the Overinspection Program is completed and the results are acceptable to us.
Sincerely, 8'OrI0 NI U'M i
Charles E. Norelius, Director Division of Reactor Projects
Enclosure:
Overinspection Program Synopsis with Tables See Attached Distribution RIIIS RIII RIII S RIII RIII g ot Ja 1 ski /jp Kn p Wd
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Distribution cc: DCS/RSB(RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard Gary N. Wright, Manater Nuclear Facility Safety Mark Jason, Assistant Attorney General, Environmental Control Division H. S. Taylor, Quality Assurance Division David Rosenblatt, Office of Consumer Services i
OVERINSPECTION PROGRAM SYNOPSIS Significant deficiencies in the applicant's QA program and site construction practices were found by Region III staff in February 1981; an Immediate Action Letter was issued in March 1981. Cited problems included seismic Category I large bore pipe supports and restraints design, fabrication, installaticr., and inspection.
More serious QA problems at the Clinton station surfaced in December 1981.
The resident inspector received a number of allegations frcm electrical inspectors employed by the prime contractor, Baldwin Associates. Significant deficiencies and nonconformances were identified by contractor ir.spectors but were not formally documented and resolved through established reporting procedures. As a result of the findings, in January 1982 all safety related electrical work was ordered stopped by the applicant.
Region III and Office of Nuclear Reactor Regulation representatives met with the applicant in January 1982 to discuss the stop work order. The applicant committed to inspect a portion of work completed prior to July 1982, before issuance of the stop work order, to verify adequacy of the plant's ongoing construction. The applicant originally committed to inspect approximately 20 percent of structural steel; mechanical equipment; electrical raceways and supports; heating, ventilating, and air conditioning (HVAC); and large and small bore piping and supports. Overinspections began in August 1982 but were stopped by the applicant in October because Region III determined that the applicant had not properly planned the activities nor trained the inspectors.
The applicant submitted an Overinspection Program Plan to Region III in November 1982 and resumed inspection activities according to the plan in September 1983. The Overinspection Plan approved by the NRC called for samplingbybothBaldwinAssociates(BA)andIllinoisPower(10).
Each overinspection group (BA & IP) selected a sample from a lot based on MIL Standard 105 D and inspected independently of each other. Many components received three 100% inspections (initial QC inspection, BA verification, and IP overinspection) because the method of selecting lot sizes resulted in lot sizes too small for sampling techniques. A detailed description of the Overinspection Program is included in Inspection Report 50-461/83016.
Region III's overview of the applicant's Overinspection Program was accomplished by onsite inspections and meetings with the licensee management and staff. Results of the NRC overview are documented in correspondence with Illinois Power. Table 1 lists the management meetings and various pertient correspondence; Table 2 lists the inspection reports that document Region III inspections of Overinspection Program implementation and hardware.
The applicant provided Region III with criteria for termination of the Overinspection Program for large and small bore piping and supports in October 1984. A review by Region III indicated that the applicant had not supplied sufficient data and analysis to support its conclusion.
The request for terminating overinspection of the commodities was initially denied.
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The applicant submitted results of its Overinspection Program to Region III in two volumes titled "Results of Quality Programs for Construction of Clinton Power Station" in February 1985, and updated it in April 1985 and April 1986.
Region III conducted onsite inspection of as-built conditions.
In addition, Region III reviewed the engineering evaluations made by the architect engineer of problems identified during overinspection. Based on the review, Region III permitted the applicant to suspend overinspection activities for large and small bore piping and supports in July 1985.
The applicant provided Region III with criteria for termination of the Overinspection Program for electrical raceways and supports, HVAC duct and supports, cable, and cable terminations in August 1985. A review by Region III irdicated that the applicant had not supplied sufficient data and analysis to support its conclusion. The request for terminating overinspection of the components was initially denied. Subsequent to the applicant's request, Region III conducted onsite inspection of as-built conditions.
In addition, Region III reviewed the engineering evaluations made by the architect engineer of problems identified during overinspection. Based on this review, Region III permitted the applicant to suspend overinspection activities of electrical raceways and supports, HVAC duct and supports, cable and cable terminations in November 1985.
In general, the applicant's overinspection data indicated an improved quality of work. The average number of discrepant attributes found after the stop work orders were lifted was less then the average number found before issuing the stop work orders.
As documented in its "Results of Quality Programs for Construction of Clinton Power Station", the applicant determined that none of the several thousand discrepant attributes identified during overinspection had significant safety implications. Reviews by Region III of overinspection data and engineering evaluations for the hardware involved substantiated the applicant's conclusion.
Early in the construction phase, petitions to intervene were filed by the Prairie Alliance and the State of Illinois Attorney General. A meeting was held in December 1984 at Region III's office between NRC and representatives of the State of Illinois Attorney General. The purpose of the meeting was to discuss NRC inspection activities and the methods used or contemolated to verify the applicant's overinspection plans. Subsequent to the meeting a joint stipulation was signed in January 1985 between the applicant, the State of Illinois Attorney General, and the NRC. The joint stipulation allowed the Illinois Attorney General to represent the Prairie Alliance and participate in matters pertaining to those quality related issues previously discussed.
Members of the Illinois Attorney General's office have attended meetings and actively participated in matters pertaining to the applicant's Overinspection Program.
Attachments:
1.
Table I - Documents pertaining to the Illinois Power Company Overinspection Program 2.
Table 2 - Inspection Reports Documenting Overinspection Activities 2
TABLE 1 DOCUMENTS PERTAINING TO THE ILLIN0IS POWER COMPANY OVERINSPECTION PROGRAM
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1.
Letter, Knop to Gerstner, dated 10/12/83, transmitting Inspection Report 50-461/83-16 pertaining to the Overinspectior. Program.
2.
Report, dated 8/84, titled Summary of Quality Improvements and Confirmatory Actions (QICA).
3.
Letter, Norelius to Gerstner, dated 11/21/84, transmitting Inspection Report 50-461/84-37 documenting meeting on 10/25/84 to discuss proposed changes to the Overinspection Program.
4.
Memo, Siegel to Schwencer, dated 12/26/84, documenting meeting between RIII, IE, and IAG to discuss the Overinspection Program and quality issues.
5.
Letter, Zabel to Clark, et. al., dated 1/28/85, transmitting copy of Joint Stipulation.
6.
Reports, 2 volumes dated 2/85, and titled Results of Quality Programs for Construction of Clinton Power Station.
7.
Letter, Hall to Keppler, dated 3/29/85, U-0827, regarding changes to the Overinspection Program.
8.
Letter, Hall to Keppler, dated 3/29/85, U-0828, describing proposed changes in the IP Overinspection Program.
9.
Letter, Hall to Denton/Keppler, dated 4/11/85, U-0834, transmitting an updated attached n lume titled Results of Quality Programs for Construction of Clinton Power Station.
- 10. Letter, Keppler to Gerstner, dated 4/11/85, transmitting questions and comments regarding proposed changes to the Overinspection Program procedures.
11.
Letter, Samelson to Keppler, dated 4/12/85, transmitting IAG comments and questions regarding IP's Results of Quality Programs for Construction of CPS.
- 12. Letter, Hubbard to Warnick, dated 4/18/85, transmitting IAG comments and questions regarding IP letters U-0827 and U-0828.
- 13. Letter, Hall to Keppler, dated 4/19/85, U-600007, responding to NRC questions concerning CPS Overinspection Program implementing procedures.
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- 14. Letter, Hall to Keppler, dated 4/19/85, U-600008, responding to questions concerning IPs request for concurrence to remove safety related piping and mechanical supports from the Overinspection Program.
- 15. Letter, Keppler to Gerstner, dated 5/8/85, transmitting Inspection Report 50-461/85024 documenting a meeting to discuss proposed changes to the Overinspection Program.
- 16. Letter, Keppler to Samelson, dated 6/14/85, responding to IAG questions and comments relative to IP's proposed changes to the Overinspection Program.
- 17. Letter, Hall to Keppler, dated 6/14/85, U-600163, transmitting supplemental IP Overinspection Program results data.
- 18. Letter, Norelius to Samelson, dated 6/17/85, documenting a meeting between RIII and the IAG to discuss matters relating to IP's Overinspection Program.
- 19. Letter, Keppler to Gerstner, dated 7/2/85, concurring in IP's request to terminate overinspection of safety related large and small bore piping and piping supports.
- 20. Letter, Hall to Keppler, dated 7/26/85, U-600197, requesting NRC concurrence to terminate the Overinspection Program for electrical hangers.
- 21. Letter, Hall to Keppler, dated 8/6/85, U-600211, requesting NRC concurrence to terminate the Overinspection Program for HVAC duct and duct supports.
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- 22. Letter, Hall to Keppler, dated 8/8/85, U-600179, regarding additional work performed to support proposed changes to IP's Overinspection Program.
- 23. Letter, Hall to Keppler, dated 8/12/85, U-600215, requesting NRC l
concurrence to terminate the Overinspection itogram for cable tray, conduit, cable and cable terminations.
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- 24. Letter, Samelson to Keppler, dated 8/27/85, providing the IAG's position l
regarding IP's requests to terminate part of the Overinspection Program.
- 25. Letter, Keppler to Gerstner, dated 8/30/85, responding to IP's request to terminate the Overinspection Program for reinspection of electrical hangers and HVAC ducts and supports.
- 26. Letter, Hall to Keppler, dated 6/6/85, U-600244, pertaining to IP's request to terminate part of the Overinspection Program.
- 27. Letter, Samelson to Keppler, dated 9/12/85, providing the IAG's position regarding IP's proposal to terminate part of the Overinspection Program.
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- 28. Letter, Keppler to Gerstner, dated 9/13/85, responding to IP's proposal to terminate part of the Overinspection Program.
- 29. Letter, Keppler to Samelson, dated 9/26/85, responding to IAG letters of 8/27/85 and 9/12/85.
- 30. Letter, Hall to Keppler, dated 10/11/85, U-600295, providing additional information to support IP's proposal to terminate part of the Overinspection Program.
- 31. Letter, Keppler to Gerstner, dated 11/21/85, responding to IP's request to terminate the Overinspection Program for electrical hangers, HVAC duct and duct supports; and cable tray, conduit, cable and cable terminations.
- 32. Letter, Hall to Keppler, dated 3/4/86, U-600474, Overinspection Program -
Lessons Learned.
- 33. Letter, Hall to Keppler, dated 4/3/86, U-600514, Conclusion of Overinspection Program.
- 34. Letter, Hall to Keppler, dated 4/21/86, U-600521, Overinspection Program Results Data Errata.
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TABLE 2 INSPECTION REPORTS DOCUMENTING OVERINSPECTION ACTIVITIES 1.
50-461/83016 - Overinspection Program 2.
50-461/84016 - Management Meeting 3.
50-461/84024 - Welding 4.
50-461/84028 - Welding 5.
50-461/84029 - Cable Tray 6.
50-461/84037 - Management Meeting 7.
50-461/84041 - Program Implementation 8.
50-461/84043 - Cable Tray 9.
50-461/85001 - Systematic Analysis of Licensee Performance 10.
50-461/85005 - Program Implementation 11.
50-461/85012 - Program Implementation 12.
50-461/85013 - Electrical Commodities 13, 50-461/85015 - Program Implementation
- 14. 50-461/85024 - Management Meeting
- 15. 50-461/85027 - Termination of Piping & Supports 16.
50-461/85029 - Structural Steel As-built
- 17. 461/85030 - Construction Appraisal Team 18.
50-461/85032 - Program Implementation 19.
50-461/85037 - Criteria for Termination
- 20. 50-461/85044 - Termination of Electrical & HVAC
- 21. 50-461/85049 - Electrical & HVAC Hangers & Ducts As-built
- 22. 50-461/85053 - Request to Terminate Overinspection 23.
50-461/85063 - Structural Steel
.