View source for U-600779, Forwards Summary of Results Re Allegations RIII-86-A-0166-a, B & C in Response to 861027 Request for Review & Followup. Hygrometer Not Installed Per Mfg Specs But Present Configuration Conforms to Plant Mod CM-20

{{Adams
| number = ML20211Q147
| issue date = 12/11/1986
| title = Forwards Summary of Results Re Allegations RIII-86-A-0166-a, B & C in Response to 861027 Request for Review & Followup. Hygrometer Not Installed Per Mfg Specs But Present Configuration Conforms to Plant Mod CM-20
| author name = Hall D
| author affiliation = ILLINOIS POWER CO.
| addressee name = Keppler J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION III)
| docket = 05000461
| license number = 
| contact person = 
| document report number = U-600779, NUDOCS 8612190209
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

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                                                '                                    U-600779              h Al d L30-86(12.11).L 1A.120
-Q ILLIN0/8 l'0WER COMPANY CLINTON POnta STAtlON. P.O. BOX 678. CLINTON. ILLINOIS 61727 DEC 111986 Fh1C2111 ROUII*4 IN y3                _
Docket No. 50-461                                          p w Q3 4 -;y             /   -
Mr. James G. Keppler                                                     $;dC k Regional Administrator, Region III U. S. Nuclear Regulatory Commission i__.* -g[F 799 Roosevelt Road Glen Ellyn, Illinois 60137

==Subject:==
Licensee Investigation of Employee Concerns

==Dear Mr. Keppler:==

This letter is in response to E. G. Greenman's letter to W. C.
Gerstner dated October 27, 1986, which forwarded three (3) allega-                                          1 tions for Illinois Power (IP) review and follow-up.
IP has completed a review of the allegations and has enclosed a summary of our results. Sup aorting documentation that provides further detail in support of the information provided in the enclosure has been compiled and is being maintained by IP for inspection by Region III personnel.
Illinois Power welcomes the opportunity to assist in investi-gations and resolving employee concerns. We trust that the en-closed information is adequate to provide you with a general assessment of IP's results.
Sincerely yours,
                                              .   . Hall Vice President CEC /jsp Enclosure cc:    Director, Office of the I&E, USNRC, Washington, DC 20555 B. L. Siegel, NRC Clinton Licensing Project Manager Illinois Department of Nuclear Safety NRC Resident Office t
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ENCLOSURE

==REFERENCE:==
NRC  letter dated October 27,      1986, (Mr. G. E.
Greenman, NRC to Mr. W. C. Gerstner, Illinois Power Company)
ALLEGATION (RIII-86-A-0166-a)
(As stated in reference letter)
: a. Cable installed on the Containment hygrometer was not in-stalled in accordance with manufacturer's specifications.

==SUMMARY==
OF INVESTIGATION It was substantiated that the hygrometer was not installed in accordance with the manufacturer's specifications. However, the present configuration of the hygrometer is in accordance with Clinton Power Station specific design in accordance with Plant Modification CM-20 and Engineering Change Notice (ECN) 7726. ECN 7726 identifies that these cables require separate termination of the shielding. This change was made in accordance with the design control program at CPS. Further, the device is classified as non safety-related. No action is required on this matter.
ALLEGATION (RITI-86-A-0166-b)
(As stated in reference letter)
: b. Similar hygrometer [ sic) installed at other plants were replaced due to unspecified problems, but were not replaced at Clinton.

==SUMMARY==
OF INVESTIGATIO!!
This matter was discussed with cognizant engineering personnel at CPS. Further, a review was conducted of the Operating Plant Experience and Operations & Maintenance Information Exchange data bases of the Institute of Nuclear Power Operations (INPO) Nuclear Network. These reviews did not disclose information relative to a generic problem with Panametrics Model 4000 hygrometers. This concern could not be substantiated.
ALLEGATION (RIII-86-A-0166-c)
(As stated in reference letter)
: c. The hygrometer installed at Clinton was never calibrated.
1

==SUMMARY==
OF INVESTIGATION Calibration of this instrument was completed during June 1986 in accordance with Preoperational Test Procedure CM-01 and Special Test Procedure CM-03. This concern could not be substantiated.
ALLEGATION (RIII-86-A-0156-a)
(As stated in reference letter)
: a. Procedure No. 8106.03, Revision 2 for Crane inspection, maintenance and testing, was inadequate and was prepared by unqualified persons.

==SUMMARY==
OF INVESTIGATION Procedure No. 8106.03 was prepared, reviewed and approved by personnel who have the responsibility for assuring that the procedure contained adequate direction, was technically correct and was in conformance with Quality Assurance program require-ments.      The review and approval process for this procedure included the following personnel:
Supervisor - Mechanical Maintenance Director - Maintenance Nuclear Station Engineering Department personnel Quality Assurance Department personnel Facility Review Group In addition, a subsequent review of CPS Procedure No. 8106.03, Revision 2,      by Quality Assurance personnel determined that the procedure is adequately prepared to fulfill its intended use.
This review was conducted as a result of a similar employee concern on this procedure and a Quality Assurance Audit                                 Finding
  ,      (Q38-86-54-PD1) documenting deficiencies in Revision 1                                  of this procedure.       Minor discrepancies were noted by the                                  review.
However, these discrepancies are not significant and                                   will be incorporated in the next revision.
Although no specific qualification rec uirement exists for person-nel assigned responsibility for procec.ure preparation, the person who prepared the procedure was selected and assigned in accor-dance with applicable requirements,                                 and his qualification is supported by the adequacy of the procedure.                                This condition could not be substantiated.
ALLEGATION (RIII-86-A-0156-b)
(As stated in reference letter)
: b. Maintenance personnel are being asked to use inadequate maintenance work request (MWR) job stops [ sic] or maintenance 2

standing orders in lieu of approved maintenance procedures.
The individual stated that recent problems with doors (water-tight, fire, secondary containment, and security doors) were a typical example. In addition, maintenance technicians with no experience were sent out with only a MWR to perform work on these devices.

==SUMMARY==
OF INVESTIGATION This concern is partially substantiated.      Recent QA trending data and NRC inspections have resulted in          the identification of problems in the area of maintenance and work controls, some of which relate to MWR job stepping. To respond to these concerns, the Maintenance Department has implemented action to improve and consolidate maintenance functions at Clinton Power Station.
These actions include the issuance of a " Maintenance Improvement Program" and a " Maintenance Action Plan."     CPS management is also evaluating other initiatives to improve overall effectiveness of maintenance at CPS.
l        A surveillance was conducted by Quality Assurance to review the use of Maintenance Standing Orders (MS0s) to ensure compliance with CPS Procedure 1005.05, Standing Orders.        During this sur-veillance,    CPS   Condition Report 1--86-09-224 was written to document the use of Maintenance Standing Orders (MS0) that provide instructions on quality-related activities which are not adequately addressed in CPS procedures. This Condition Report is closed and has resulted in the withdrawal of one (1) MSO.         This surveillance also referenced Condition Report #1-86-09-146 that identifies similar problems in this area.        Commitment Control Tracking Item C43179 was submitted to track corrective action implementation on this matter and includes revision of applicable procedures to incorporate items currently in standing orders.
This is scheduled for completion by initial criticality.
Illinois Power (IP) and Stone & Webster maintenance technicians currently performing maintenance on doors are trained in accor-dance with CPS 1502.03, Training and Qualification of Maintenance Department Personnel. In addition, IP maintenance personnel were provided training on fire doors by a vendor representative. The personnel performing this maintenance, while not specifically experienced in door maintenance, are experienced and trained technicians or union craftsmen whose work is subjected to routine maintenance supervision review. Most maintenance work on doors is classified as non-safety related, is simple in nature and is therefore performed in accordance with approved MWR job steps.
These MWRs undergo various reviews prior to issuance for work.
Safety-related MWRs also undergo an additional review by Quality Assurance. Further, safety-related MWR work is subjected to Quality Control inspection requirements when appropriate to verify adequate maintenance.
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ALLEGATION (RIII-86-A-0156-c)
(As stated in reference letter)
: c. The individual also stated that there were not adequate instructions provided for the replacement of the main lifting cable on the containment polar crane.

==SUMMARY==
OF INVESTIGATION The replacement of the polar crane cable was conducted in accor-dance with Maintenance Work Request (MWR) B31446.           This MWR specified replacement to be accomplished in accordance with specification 2832-B-003. This specification provides step-by-step instruction for the replacement of the polar crane cable.
Although several condition reports related to polar crane main-tenance were generated, they relate to causes other than inade-quate instruction provided for cable replacements and have been corrected in accordance with the Corrective Action Program and reviewed by the Quality Assurance Department. The cable has been successfully replaced and operationally tested.         This concern could not be substantiated.
ALLEGATION (RIII-86-0161-a)
(As stated in reference letter)
: a. Transco did not have the insulation top to place over valves, so they continued to work without the valve tops.           As a result, dirt from the insulation process was trapped between the pipes and the insulation.       The individual thought the feedwater piping was the system involved.

==SUMMARY==
OF INVESTIGATION An effort was made to substantiate the statement that the insula-tion tops were unavailable during installation; however, due to demobilization of knowledgeable        subcontractor personnel,     no specific information could be obtained.      Therefore,  this concern was provided to the CPS Architect Engineer, Sargent & Lundy, under the assumption that the alleged conditions exist.          Their evaluation states in part, "If foreign material were to collect between the pipe and the insulation after the insulation was installed, it would not increase the heat transfer across the insulation. Additionally, the feedwater pipe is carbon steel and would not be affected by dire generated in the insulation pro-cess. Delaying the closure of the insulation on valves would not affect the function of the feedwater pipe or insulation."
Therefore, although this condition could not be confirmed to exist, it would not have significance as stated above.
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a ALLEGATION (RIII-86-0161-b)
(As stated in reference letter)
: b. He heard that several voids existed in the concrete wall between the Diesel Generator and Fuel Building. He thought the approximate locations of the voids were between Column Lines AD and AC on either the 762' or 770' elevations. He also heard the voids were probably repaired.

==SUMMARY==
OF INVESTIGATION The concrete pour travelers associated with the construction of the referenced wall were reviewed.      The pour traveler for the specific area cited in the concern did not identify any voids in the concrete, and a walkdown by Quality Assurance did not iden-tify any voids at this time.      This review identified traveler F-W-8-4, which was used to document the concrete construction of the 124 line wall, 771' to 782', AC line to 8' north of AL line, immediately above the area identified in the concern. This wall separates the Fuel and Diesel Generator Buildings and includes the general area _of the alleged voids. This traveler identified that voids did exist in the original concrete pour and were documented on Nonconformance Report 3451. The NCR was disposi-tioned " Repair". The voids were repaired and accepted in accor-dance with the Baldwin Associates       Quality Assurance Program.
Therefore, this concern was substantiated, but the voids were previously repaired, and no action is required on this matter at this time.
ALLEGATION (RIII-86-A-0161-c)
(As stated in reference letter)
: c. The individual also stated that the inner bioshield wall was covered with "20 gauge reflective insulation" and the insula-tion was improperly installed. According to the individual, gaas and dents existed in the insulation and dirt was trapped behind the insulation. Also, sheet metal screws were missing and holes existed in the insulation.

==SUMMARY==
OF INVESTIGATION This employee concern did not identify a timeframe (month / year) that the alleged conditions were observed, and due to poor accessibility of this area and proximity to the reactor vessel, a physical inspection of this work is impractical and hazardous.
Therefore, review of this concern focused on completion and acceptance of this commodity from the insulation subcontractor.
On April 4, 1986, the bioshield wall insulation was submitted to Illinois Power by the insulation subcontractor for acceptance. A walkdown was conducted which identified thirty-three (33) items 5

requiring additional work. Many of the items, similar to the types of problems identified above, were documented on an Insu-lation Completion / Acceptance punchlist. The insulation was subsequently rejected by Illinois Power on May 5, 1986.      Work-associated with the punchlisted items was completed by the subcontractor, and another walkdown was conducted. The insula-tion was subsec.uently accepted by Illinois Power on July 3,1986.
Therefore, altaough the concerns above were confirmed to have existed in May 1986, these conditions were reworked to Illinois Power's satisfaction. Due to the present inaccessibility of this area, it is unlikely that degradation of the insulation occurred subsecuent to its acceptance in July 1986, and it can be con-cludec. with confidence that the insulation presently is in an acceptable condition.
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