U-600179, Forwards List of Lessons Learned from Reviews of Evaluations of Overinsp Program Nonconformances & Corrective Actions,Per NRC 850611 Request During Meeting Re Discontinuance of Util Overinsp Program
| ML20137E110 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/08/1985 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-600179, NUDOCS 8508230139 | |
| Download: ML20137E110 (5) | |
Text
.
.;4-U-600179 L37-85 ( 08-08)-L 1A.120 ILLIND/S POWER 00MPANY CLINTON POWER STATION. P.O. BOX 678. CLINTON. ILLINOIS 61727 August 8, 1985 NICRITY RC'JIIyG yt wik Docket No. 50-461 7
ac
,# ya e s 31 Mr. James G. Keppler 4%
'An Regional Administrator
]
jL Region III m
U. S. Nuclear Regulatory Commission flLE g 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Illinois Power (IP) Company Overinspection Program
Reference:
Letter D. P. Hall to J. G. Keppler of March 29, 1985 about Proposed Changes in the IP Overinspection Program
Dear Mr. Keppler:
In the referenced letter, IP requested concurrence from the US Nuclear Regulatory Commission (NRC) to terminate the IP Overinspection Program for safety related piping and mechanical supports.
In making this request, IP included the results of evaluations by Sargent & Lundy (S&L) of the safety significance of the nonconforming conditions identified by the Overinspection Program for piping and mechanical supports through December 31, 1984. The S&L cvaluations concluded that no safety significant nonconforming conditions were identified. This supported IP's position that overinspection of these items should be discontinued.
The NRC conducted a review of the adequacy of the S&L cvaluation during the week of April 29, 1985 and held an exit meeting on May 3, 1985 in the Chicago offices of S&L. During the exit meeting, Messrs R.
F. Warnick and J. W. Muffet of the NRC noted that the NRC could not, at that time, reach a conclusion on the adequacy of the S&L evaluation.
The NRC identified four actions that were necessary in order for the NRC to complete their review of the S&L cvaluations and to determine whether the IP request to terminate the Overinspection Program for safety related piping and mechanical supports was adequately supported by the SEL evaluation. The four actions were:
Perform an improved technical review of the evaluations of a.
discrepancies which resulted in more than a 10% reduction in
- strength, b.
Perform an improved technien1 review of the evaluations which were evaluated based solely on engineering judgement.
Perform an analynis to address the problem of gaps in " box c.
type" supports.
0500230139 050000 (DH ADOCK 0500o461 PDR
\\
.p AUG 1319857g
U-600179 L37-85 (08-08)-L 1A.120 d.
Review the discrepancy data base to determine if any other cases of missing vents or drains were discovered.
In response to items a and b above, IP directed Sargent & Lundy to review approximately twecty-five hundred nonconformance reports for piping and mechanical supports taking the NRC comments into considera-tion. Over fourteen thousand manhours were expended by S&L to address the technical adequacy.and completeness of the evaluations. To accomplish this review, S&L developed procedures, detailed checklists, and evaluation criteria based on comments at the exit meeting and an internal S&L Quality Assurance audit.
The checklista and procedures required an independent detailed review of all "B2" calculations (load capacity reduction of 10 percent or more). The effort also included an arithmetic check to assure that all attributes were addressed, verification that all quantities recorded in the data base were correct, and a check to ensure that documentation in the calculacion was such that an individual not familiar with the subject could easily follow the logic of the solution.
Engineering judgement was used as a basis in over forty percent of the evaluations when it was evident that the hardware met all approp-rinte design criteria and for repetitive calculations for similarly designed items.
In the review for technical adequacy each NCR utilizing engineering judgement was inspected to confirm the acceptability of the engineering judgement in the resolution and to ensure that adequate information was present to allow reconstruction of the evaluation.
About twenty five percent of the evaluation packages required more detail in order to address completely the references utilized.
In addition to the S&L review, Impe11 Corporation examined approximately fifty percent of the S&L evaluations to verify their technical adequacy. The results of these additional reviews verified that the original evaluations were technically correct and the conclusions drawn remain unchanged.
In response to item c, above, the effects of out of tolerance gaps on box type pipe supports were analyzed generically to demonstrate that gaps on supports not subject to overinspection would be acceptable. As of December 31, 1984, there were 1,684 safety related box type pipe supporta used in the design of Clinton Power Station.
1,073 of these supports were overinspected with 87 nonconformance reports written for out of tolerance gaps. Each of these 87 NCRs were evaluated to deter-mine the effects on piping stresses and support loads.
In all cases, stresses were within code allowables and the revised loads were accep-table without any support modifications. Based on this review, the probability of an installation tolerance nonconformance existing on a support not overinspected that could result in pipe stresacu exceeding cog)allowableswasdeterminedtobeexceedinglysmall(ontheorderof 10
U-600179 L37-85 ( 08-08)-L 1A.120 In response to item d, above, the impact of missing high point vents and drains on testing / operations was investigated. All of the piping overinspection NCRs were reviewed for occurrences of missing vents and drains and only one was identified. This particular NCR was l
resolved as incorrect. The inspector had reviewed a fabrication traveler for a spool piece and overlooked the associated installation traveler which was still in process. The installation traveler j
identified the high point vent as remaining to be installed. Based on this review, missing high point vents and drains have not been identified by the Overinspection Program and are not an issue.
Upon completion of the S&L and Impell work, the NRC again reviewed the S&L cvaluations and an exit meeting was held for this second review by the NRC on June 11, 1985, in the Chicago offices of S&L. At the meeting, IP provided the NRC with copies of an S&L report titled out of Tolerance Gaps at Box-Type Supports, a copy of S&L internal QA Audit Report No. 127, and a report by Impell confirming the technical adequacy of the evaluations. During the NRC review, Mr. Muffett indicated that the evaluations were now acceptabic and requested information about the lessono learned from these reviews and how these lessons will be applied to future evaluations of Overinspection Program nonconformances.
Attachment A provides a list of the lessons learned and the measures taken as a result. We believe that these actions will address the NRC's concerns about implementation of the lessons learned and preclude similar concerns with future nonconformance evaluations by S&L.
Sincerely yours,
. I. Itall Vice President COB / lab Attachment cc Director, Office of I&E, USNRC, Washington, DC 20555 B. L. Siegel, NRC Clinton Lic2nsing Project Manager NRC Recident Office Illinois Department of Nucicar Safety Allen Samelson, Assistant Attorney General, State of Illinois i
ATTACHMENT A Lesson Learned Resultant Action 1.
There were no generic implications of None Required deficiencies en box type pipe supports.
2.
There was no impact on testing /cperations None Required missing high point vents or drains 30 Technical verification procedures should Issued technical verification procedures for piping, be previded.
mechanirri pipe supports, structural supports, structural steei, HVAC ducts and supports, electrical cable, terminations, conduit and tray.
4.
S&L engineering standard should be utilized S&L standard verification procedures were incorporated to obtain improved technical review, into the S&L overinspection program nonconformance i
evaluation process.
MAS-22, Preparation, Review, and Approval of Mechanical Department Design Calculations.
MAS-17. Technical Evaluation of Quality-Related Design Activities.
l l
EDSI-71, Seismic Category I Conduit Support Drawings l
and Design Calculations.
EAP-36 Technical Evaluation of Selected Quality Related Design Activities on Nuclear Projects.
ESI-253, Electrical Department Instructions for preparation.
l reviews and approval of Electrical Design Calculation.
l DC-SD-01-CP, Structural Design Criteria SAS-26. Technical Evaluation of Quality Related Design Activities.
5.
References cust be stated in the evaluations.
The evaluation checklist now requires a review to assure that input documents and reference design data which form the basis for the evaluations are clearly stated.
9
--rre
ATTACHMEhT A Lesson Learned Resultant Action 6.
Engineering judge =ent should be adequately The evaluation checklist now requires a review to assure explained.
that engineering judgement is cler.rly documented and quanti-fied in the evaluation. Engineering judgement evaluation content must permit a reviewer of the evaluation to verify the logic and adequacy of the judgement.
7.
Guidelines for evaluation of technical Guidelines for technical criteria were issued to assure criteria should be provided, a consistent and technically adequate basis for resolution of the more common nonconforming attributes. Guide-lines cover electrical equipment, HVAC ductwork and supports, structural steel and structural supports, piping and mechanical pipe supports.
8.
Training of evaluators was needed.
Training of the engineers in use of the evaluation procedures and resolution guidelines was provided for future work.
9.
Quality Assurance auditing was required.
S&L Quality Assurance has continued to audit the over-inspection evaluations program to verify that the evaluations are complete and have an adequate technical basis.
-