U-600080, Revised Response to NRC Re Violations Noted in Insp Rept 50-461/85-13.Corrective Actions:Processing of Nonconformance Repts 65790,65850,65905 & 65994 More Accurately Described.W Connell 850403 Response Encl

Revised Response to NRC Re Violations Noted in Insp Rept 50-461/85-13.Corrective Actions:Processing of Nonconformance Repts 65790,65850,65905 & 65994 More Accurately Described.W Connell 850403 Response Encl

ML20128P027
Person / Time
Site:	Clinton
Issue date:	07/16/1985
From:	Spangenberg F ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20128P031	List: ML20128P097 U-600080, Revised Response to NRC Re Violations Noted in Insp Rept 50-461/85-13.Corrective Actions:Processing of Nonconformance Repts 65790,65850,65905 & 65994 More Accurately Described.W Connell 850403 Response Encl
References
U-600080, NUDOCS 8507260321
Download: ML20128P027 (4)

Text

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' U- 600080 L42-85(07-16)-L 1A.120 ILLINO/S POWER COMPANY CLINTON PCMER STATION, P.o. BOX 678. CLINTON. ILLINOIS 61727 July 16, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Revised Response to Notice of Violation Dated March 20, 1985, NRC I&E Inspection Report Number 50-461/85-13

Dear Mr. Keppler:

This letter provides a revised response to the March 20, 1985, Notice of Violation concerning the inadequate disposition of construction nonconforming conditions. The revised response concernsSection I.1 of Attachment A to our letter, W. Connell to J. G. Keppler, U-10264, dated April 3, 1985. Specifically, this revised response is related to dispositioning Nonconformance Reports numbered 65850 and 65905. Please refer to Attachment A of this letter for details of the revised response.

I trust that our revised response is satisfactory.to insure compliance with regulatory requirements.

Sincerel ours, F. A. S Enge . erg Directo - Nuclear Licensing and Configuration Nuclear Station Engineering REC / lab Attachment cc: B. L. Siegel, NRC Clinton Licensing Project Manager Director, Office of I&E, USNRC, Washington, DC 20555 NRC Resident Office Illinois Department of Nuclear Safety 8507260321 PDR 850716 ADOCK 05000461 G PDR JUL 2 7 585 TF oi 'I t

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

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SUBJECT:

Inadequate Dispositioning of Nonconforming Conditions, l Revised Response

REFERENCE:

Illinois Power Company (IP) Letter, W. Connell to J. G.

Keppler, U-10264, Dated April 3, 1985 The Notice of Violation states in part:

...the NSED disposition in response to BA Field Verification Nonconformance Report No. 65790 was found to be inadequate in that the disposition states, "Usc-as-is, Type B" (written in error),

when in fact it was a valid nonconforming condition. This disposition did not identify the cause, resolution, or the corrective action to prevent recurrence of the identified deficiency.

I. Corrective Actions Taken and Results Achieved NRC IE Inspection Report 50-461/85-13 lists four examples of this item of noncompliance: Nonconformance Reports (NCRs) 65790, 65850, 65905, and 65994. In each instance the responsible engineer failed to provide sufficient justification for the disposition assigned.

The engineer did not review the condition as it. existed in the field, but rather, the engineer relied upon a memorandum from Baldwin Associates Field Verification Supervisor. The memorandum stated that the NCRs were written in error. No justification was included with the memorandum. Illinois Power Company reviewed the NCRs with the following results:

1. The original response in the referenced letter did not provide an accurate description of the processing of these nonconfor-mance reports. The following is a revised response to that portion of the notice of violation related to NCRs 65850 and 65905:

NCR " A 5 -

he original traveler package, EC-C2789, had been conjl. a 1 .. vaulted on June 8, 1984. On August 8, 1984, a supp ementui traveler was issued to hanger traveler E22-1012-DET.30-11 to remove the conduit support. This work required the removal of the conduit strap. The Baldwin Associates Field Verification (BAFV) inspector was performing inspection activities to the original traveler, EC-C2789, unaware that a supplement had been issued. The inspector identified two (2) deficiencies on NCR 65850. Item 1 documented the improper identification marking on the conduit.

Item 2 noted the conduit strap was not installed.

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ATTACHMENT A CONT'D The NCR was dispositioned "Use-as-is, Type B" for both items, but no' justification was documented to support the concurrence of the disposition as required by NSED Procedure D.7,

" Handling Clinton Power Station Nonconformance Reports".

Item 1 was documented as a result of a misunderstanding of the specification requirements by the inspector. Item 2 was a result of work being performed to the supplemental traveler which required the removal and re-installation of the conduit strap. Although the "Use-as-is, Type B" disposition is

!~ = correct for the condition documented, the NCR was not l processed in accordance with project procedures.

- NCR 65905 - The original traveler package, EC-C2626, had been p3 completed and vaulted on April 18, 1984. This NCR was written l October 10, 1984, to document the improper identification marking on the conduit. This was a result of a l

misunderstanding of the specification requirements by the BAFV inspector. The NCR was dispositioned "Use-as-is, Type B", but 4 no justification was documented to support the concurrence of I the disposition as required by NSED Procedure D.7. Although-the "Use-as-is, Type B" disposition is correct for the condition documented, the NCR was not processed in accordance with project procedures.

.2. NCR 65790 was closed without adequete resolution of the non-conforming condition. NCR 28094 supersedes NCR 65790, and it was dispositioned in accordance with established procedural controls.

NCR 65790 was incorrectly dispositioned by the responsible engineer. A review of this individual's work, beginning in November 1984, was performed. The review encompassed 126 NCRs of which 27 represent conditions similar to that described by NCR 65790. No additional examples of inadequate disposition were identified.

3. NCR 65994 was written with reference to the wrong drawing detail. Although the NCR was written against a drawing detail that is predominately applicable to the installation being inspected, there is another approved-drawing detail which includes design characteristics fo'r this particular installation. This drawing detail was identified by the responsible engineer while dispositioning the NCR. The installation.was compared to this drawing detail and found to conform to the design requirements. A disposition of "nonhardware" is appropriate for the condition described because the deficiency does not affect permanent plant hard-ware. Further corrective action for nonhardware conditions is prescribed by Baldwin Associates procedures.

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ATTACHMENT A CONT'D II. Corrective Action to be Taken to Prevent Recurrence Training was conducted on March 5, 1985 to stress that proper justification must be available as part of the record for each NCR disposition. An additional supervisory review of the NCR disposi-tion review form further assures that sufficient justification exists for each NCR.

1. Concurrent with the NRC inspection, Illinois Power Company was processing a revision to Nuclear Station Engineering procedure D.7, Handling Clinton Power Station Nonconformance Reports.

Revision 6 was issued February 28, 1985. Training to the revised procedure, presented March 5, 1985, was expanded to address the related NRC concerns and to emphasize the adequate assignment of NCR dispositions. The conditions cited by the NRC were used as examples.

2. The incorrect disposition of NCR 65790 was discussed with the responsible engineer, and a letter was issued to reinforce the counseling provided. Investigation has determined that the example of inadequate disposition is an isolated instance.

Additional corrective action is not considered necessary.

3. NCR 65994 was correctly dispositioned as nonhardware. Est-ablished procedural requirements will achieve adequate corrective action for the nonhardware condition.

The NRC inspector recommended that corrective action include a review of the procedural controls for clarity and for consistency between organizations. Nuclear Station Engineering procedure D.7, Baldwin Associates procedure BAP 1.0, Nonconformances, and Sargent

& Lundy procedure PI-CP-003, Processing a Baldwin Associates Field Change Request or Nonconformance Report, were reviewed and found to be adequate and consistent. No further corrective action is necessary.

III. Date When Full Compliance Will be Achieved Illinois Power Company was in full compliance by February 28, 1985.

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