ML20134F787

Const Appraisal Team Insp Rept 50-461/85-30 on 850520-31 & 0610-21.Deficiencies Noted:Inadequate Control of Design Documents & Programs for Verification of Electrical Separation & Ineffective Control of Work Performed

ML20134F787
Person / Time
Site:	Clinton
Issue date:	08/06/1985
From:	Chan T, Georgiev G, Heishman R, Mclellan T, Nemoto J, Peranich M, Smeenge R, Stein S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20134F777	List: ML20134F773 ML20134F787
References
50-461-85-30, NUDOCS 8508210250
Download: ML20134F787 (125)

See also: IR 05000461/1985030

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

DIVISION OF INSPECTION PROGRAffS

REACTOR CONSTRUCTION PROGRAMS BRANCH

Report No.: 50-461/85-30

Docket No.: 50-461

Licensee: Illinois Power Company

Facility Name: Clinton Power Station

Inspection At: Clinton, Illinois

Inspection Conducted: flay 20-31 and June 10-21, 1985

Inspectors: / [ //Mor/Ed

li. W. Per ~c h, Chief, Construction Programs /

/I

Date Signed

CAT S ion Team Le

$6/85

T.(L.#LhaT, Reactor ons uction Engineer Date Signed

P A ,e M' uction Engineer

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Date'51gned

G. B. g giev,L5r. Rdactor Co

VO b.J

T. K. McLellan, Reactor Construction Engineer

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Date Signed

0 (/f

I. Nemoto, Reactor Construction Engineer

8/fo/85

Da'te signed

//b Aff97fc^ R///SV

Date Signed

[R.J.5meenge,ReactorInspector(RegionIII)

[4

2 st A u n?'

5. R. Stein, Reactor Construction Engineer

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Date Signed

Consultants: A. V. DuBouchet, D. C. Ford, J. B. McCormack,

0. P. Mallon, W. S. Marini, E. Y. ifartindale,

R. E. Serb and W. J. Sperko, Jr.

Approved By: c M

Robert F. Heishman, Chief Date Signed

Reactor Construction Programs Branch

8508210250 850015 1

DR ADOCK 050

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TABLE OF CONTENTS ,

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TOPIC SECTION

INSPECTION SCOPE AND OBJECTIVES.................................. I

ELECTRICAL AND INSTRUMENTATION CONSTRUCTION...................... II

MECHANICAL CONSTRUCTION.......................................... III

WELDING AND NONDESTRUCTIVE EXAMINATION........................... IV

CIVIL AND STRUCTURAL CONSTRUCTION................................ V

MATERIAL TRACEABILITY AND CONTR0L................................ VI

DESIGN CHANGE CONTR0L............................................ VII

CORRECTIVE ACTION SYSTEMS........................................ VIII

ATTACHMENT A - PERSONS CONTACTED AND DOCUMENTS REVIEWED

ATTACHMENT B - GLOSSARY OF ABBREVIATIONS

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I. INSPECTION SCOPE AND OBJECTIVES

The objective of this inspection was to evaluate the adequacy of

construction at the Clinton Power Station site. This objective was accom-

plished through review of the construction program, evaluation of project

construction controls, and review of selected portions of the Quality

Assurance Program, with emphasis on the installed hardware in the field.

The scope and significance of identified problems were also determined. In

addition, a sample of the results of the licensee's Overinspection Program

were compared with the NRC CAT inspection findings in applicable areas

inspected.

Within the areas examined, the inspection consisted of a detailed examina-

tion of selected hardware subsequent to quality control inspections, a

selective examination of procedures and representative records, and limited

observation of in process work.

For each of the areas inspected, the following was determined:

'

Were project construction controls adequate to assure quality

construction?

Was the hardware or product fabricated or installed as designed?

Were quality verifications performed during the work process with

applicable hold points?

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Was there adequate documentation to determine the acceptability of

installed hardware or product?

Are systems turned over to the startup organization in operable

condition and are they being properly maintained?

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II. ELECTRICAL AND INSTRUMENTATION CONSTRUCTION

A. Objective

The primary objective of the appraisal of electrical and instrumentation

,

construction was to determine whether safety-related components and

systems were installed in accordance with regulatory requirements,

Safety Analysis Report commitments, and approved vendor and construction

specifications and drawings. Additional objectives were to determine

whether procedures, instructions and drawings used to accomplish

construction activities were adequate and whether quality related

records accurately reflected the completed work.

B. Discussion

Within the broad categories of electrical and instrumentation

construction, attention was given to several specific areas. These

included electrical cable, raceways and raceway supports, electrical

equipment, and instrumentation piping and components. Additionally,

a review was made of a selected number of documents associated with

design change control and nonconformance reporting.

A number of inspection samples in several areas coincided with either

Baldwin Associates' Field Verification (BAFV) Program or Illinois

Power Company's Overinspection (IPOI) Program. These are identified

in the following sections along with an assessment of the programs'

findings compared to the observations of this inspection. Refer to

Section VII, Design Change Control, of this report for further

discussion of the IPOI Program.

1. Electrical Raceway Installation

a. Inspection Scope

Seventy segments of installed Class 1E cable tray, representing a

total length of about 1,200 feet, were selected from various plant

areas for detailed examination by the NRC Construction Appraisal

Team (CAT). These segments were inspected for compliance to

requirements relative to routing, location, separation, identifica-

tion, protection, physical loading, support spacing and support

configuration. Additionally, 31 runs of installed conduit, with an

aggregate length of about 1,000 feet, were inspected for compliance

to specified requirements such as routing, location, separation,

bend radii, support spacing and associated fittings. The BAFV

records for a number of the conduit runs inspected were also

reviewed.

Thirteen raceway supports were examined in detail for such items

as location, material, anchor spacing, weld quality, bolt torque

and installed configuration.

See Table II-1 for a listing of the cable tray, conduit and raceway

support samples.

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The following documents provided the basic acceptance for the

inspection:

Sargent & Lundy Clinton Power Station Unit 1 Specification

K-2999, " Electrical Installation," Amd. 10

Baldwin Associates Project Procedure BAP 3.3.1, " Exposed

Conduit Installation and Traveler Processing," Rev. 18

BAP 3.3.6, " Electrical Raceway Support Installation,"

Rev. 9

OAP 3.3.10, " Cable Tray Installation and Traveler Pro-

c?ssing," Rev. 6

BA) 2.3.11, " Cable Tray Attachment Installation," Rev. 6

BAP 3.3.14, " Conduit Support Installation," Rev. 1 Change B

Baldwin Associates Quality Assurance Instruction BQAI-190-8,

" Electrical Raceway Hanger / Supports Field Verification,"

Rev. 4

BQAI-190-9, " Electrical Raceway Field Verification,"

Rev. 4.

b. Inspection Findings

The NRC CAT inspectors observed that, in general, Class 1E raceway

installations were in accordance with applicable design criteria.

Important quality attributes such as material type, location,

identification and installed configuration were found to be as shown

on approved construction drawings. However, several construction

deficiencies were identified and are discussed in the following

sections.

(1) Raceway Separation

The requirement to establish physically independent and

redundant cable raceway systems is specified in the Clinton

Power Station (CPS) Final Safety Analysis Report (FSAR).

Section 8.3.1.4, entitled " Independence of Redundant Systems,"

describes requirements for physical arrangement of raceways in

order to comply with the requirements of Regulatory Guide (RG)

1.75.

The CPS raceway design includes four safety-related divisions

to serve the Engineered Safety Features systems and two

nonsafety-related divisions which serve the balance of plant

systems. Minimum spatial separation between raceways

comprising each of these divisions has been established in

accordance with the guidelines specified in the Institute of

Electrical and Electronic Engineers (IEEE) Standard 384-1974.

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NRC CAT inspectors reviewed documents which explained the CPS

electrical separation design philosophy. In summary, Sargent

& Lundy Engineers (S&L) as the Architect Engineer controls

electrical separation through their design process. Location

dimensions on electrical raceway installation drawings are used

for maintaining proper separation. Consequently, specific

separation criteria is purposely not included in the specifica-

tions and instructions issued to the electrical contractor for

installation and inspection. This has resulted in an inspec-

tion program which verifies the correct location of raceway

components but does not include attributes for inspection of

electrical separation.

To verify the adequacy of controls established through the

design process, NRC CAT inspectors selected a sample of com-

pleted raceway installations for review. During the examina-

tion the inspectors identified numerous installations which did

not maintain spatial separation as described in the FSAR.

Several deficiencies existed between components of redundant

safety divisions, but deficiencies primarily occurred between

safety and nonsafety-related components. Specific cable tray

deficiencies were then compared to design drawings to determine

if required fire barriers (i.e., tray covers) had been detailed

for installations which exhibited less than the required

spatial separation. It was noted that in many cases barriers

had not been specified on the applicable drawing. Reference

Table II-2 for a listing of raceway separation deficiencies

identified by the NRC CAT inspectors.

Discussions with the licensee indicate that they had become

aware of the need to perform specific walkdowns for electrical

separation because field installation tolerances could not be

controlled by design drawings. As such, field walkdowns of

raceway for seismic interaction were incorporated into S&L's

Clinton Project Instruction PI-CP-034, Interaction Analysis

Procedure, early in 1983. However, incorporation of specific

electrical raceway separation criteria was not accomplished

until mid 1985.

In order to evaluate this program, NRC CAT inspectors reviewed

the walkdown procedure, examined the plant area previously

inspected by the separation walkdown team, and interviewed the

engineers responsible for performing the walkdown. The

following concerns were identified as a result of this

evaluation:

Separation criteria detailed in the walkdown procedure is

not complete in that spatial separation between raceway

and exposed electrical cable has not been addressed.

Personnel performing separation walkdowns have not

received training adequate to assure that they are

knowledgeable of all accept / reject criteria.

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The program represents the final inspection and acceptance

of raceway for the attribute of electrical separation. As

such, it lacks appropriate involvement from the quality

assurance (QA) organization.

In connection with this issue, review of Sargent & Lundy

Electrical Department Standard ESI-180 indicates that analysis

has been used to justify many of the installations which

exhibit less than the required spatial separation. NRC CAT

inspectors noted that this does not satisfy the requirement of

section 8.1.6.14 position C.6 of the CPS FSAR which states,

"The analysis 'out' given in paragraphs 4.5(3), 4.6.2 and

5.1.1.2 has not been used."

An S&L calculation, No. 19-BD-13, was cited as justification

for the examples of lessor separation identified by the NRC CAT

between non-Class 1E raceway run above Class 1E cable tray. A

review of the analysis indicates that it does not meet the

requirements of IEEE-384 paragraph 5.1.1.2 in that it is not

based on tests of proposed installations and does not consider

actual raceway arrangements. The analysis only addresses non-

Class 1E raceway which crosses over Class IE cable tray and

states that covers are not required for the Class 1E tray as

the heat from a fire or fault in the upper raceway will rise.

Discussions with the licensee revealed that an amendment to

the CPS FSAR has been prepared which would allow the use of

analysis to establish adequate electrical separation. As a

result, further evaluation of this issue will be required by

NRC personnel.

In summary, the review of design, construction, and inspection

activities indicates that existing design and quality verifica-

tion programs have not been adequate to assure that commitments

relative to electrical separation have been met. As a result

of this observation, the licensee has indicated that a program

evaluation will be performed. Additionally, based upon

results of the evaluation and concerns addressed in this

report, program requirements may be revised.

(2) Raceway Supporting Scaffolding

BAP 3.3.10 permits the use of installed cable tray to support

temporary scaffolding with notification of BA quality control

(QC) by the area electrical supervisor, and the procedure

provides inspection criteria following removal of the scaf-

folding. The NRC CAT inspectors questioned the procedure

controls that would alert BA QC whenever Class 1E cable trays

were used to support scaffolding and assure inspection of the

trays after removal of the scaffolding.

Since the controls were not well documented, BA's Deputy

Project Manager subsequently issued letter EPR-160-85 June 4,

1985. The letter only permits placing scaffolds on Class 1E

cable tray on an exception basis requiring Superintendent

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approval. The letter also requires documentation in a depart-

mental log and written notification to BA QC.

Section III, Mechanical Construction, of this report, also

discusses support of temporary scaffolding.

(3) Electrical Conduit

In general, the installation of conduit conforms to design

requirements. A number of separation violations were noted

between conduits, and between conduits and cable tray and are

included in the discussion in Section II.B.1.b(1), above.

In what the NRC CAT inspectors considcr an isolated case, con-

duits C9822, C9823, and C9824 are not attached to support E29-

1000-02C-122 as required by drawing E29-1000-02C-EIH. The

licensee subsequently issued Nanconformance Report (NCR) 31717

to document the condition.

(4) Raceway Supports

The examination of seismic raceway supports was accomplished

for both cable tray and conduit installations. In general,

attributes such as location, material type and size, anchor

spacing, welds (location, size and general quality) and

installed configuration were found to be in accordance with

design requirements.

c. Conclusions

The use of engineering analysis to establish adequate electrical

separation is not consistent with current FSAR commitments, and an

analysis to justify separation between Class IE and non-Class IE

raceway was found to be technically inadequate.

The licensee's existing programs of design and quality verification

activities have not been adequate to assure that raceway

installations conform to FSAR commitments for electrical separation.

With the exception of compliance with electrical separation

criteria, conduit and support installations appear to be in

conformance with requirements.

2. Electrical Cable Installation

a. Inspection Scope

The NRC CAT inspectors selected a sample of installed Class IE

cable runs that had been previously accepted by BA QC inspectors.

The sample included medium and low voltage power, control, and

instrumentation cables. For each of the cable runs, physical

inspection was made to ascertain compliance with applicable design

criteria relative to size, type, location, routing, bend radii,

protection, separation, identification and support. In addition,

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IPOI records for installation and termination of those cables marked

with an *, below, were reviewed.

The NRC CAT inspectors selected approximately 270 cable ends for

examination. These were inspected to applicable design and

installation documents for items such as lug size and type, proper

terminal point configuration, correct identification of cable and

conductors, proper crimping of lugs or connectors, and absence of

insulation or jacket damage. See Table II-3 for a listing of cable

terminations examined.

The following medium and low voltage power cables, totaling about

1,650 feet, were selected from different systems, electrical trains

and locations:

Cable Type

1HP03C-P3E 3 Conductor 750 MCM

• 1HP08A-P3E 3 Conductor 500 MCM

1RH02A-P2E 3 Conductor 1/0 AWG

• 1RH27A-P1E 3 Conductor 19/22 AWG

• 1CC08A-P2E 3 Conductor 19/22 AWG

1DC01B-P1E 3 Conductor 4/0 AWG

• 1LP01A-PIE 3 Conductor 500 MCM

ILP03A-P1E 3 Conductor 19/22 AWG

The following control cables totaling approximately 1,020 feet were

selected from different systems, electrical trains and locations:

Cable Type

1HP08E-C3E 2 Conductor 19/22 AWG

1DG01C-CIE 15 Conductor 19/25 AWG

1DC01E-C1E 4 Conductor 19/25 AWG

• 1IA028-CIE 12 Conductor 19/25 AWG

The following instrument cables totaling approximately 560 feet

were selected from different systems, electrical trains and

locations:

Cable Type

1LD41F-K2E 1 Pair 16 AWG Twisted Wire Shielded

ISC76A-K1E 1 Pair 16 AWG Twisted Wire Shielded

IDC06G-K4E 1 Pair 16 AWG Twisted Wire Shielded

• 1NR758-KIN 1 Pair 16 AWG Twisted Wire Shielded

The following documents provided the basic acceptance criteria for

the inspection:

S&L Clinton Power Station Specification K-2999, " Electrical

Installation," Amd. 10

BAP 3.3.2, " Cable Installation," Rev. 14

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BAP 3.3.3, " Cable Terminations," Rev. 6

BAP 3.3.9, " Cable Protection," Rev. 6

BQAI-190-12, " Electrical Cable Installation Field

Verification"

BQAI-190-7, " Electrical Cable Termination Field

Ve ri fication. "

b. Inspection Findings

(1) Ro ut.i_ng

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In ceneral, the routing of Class 1E cables through design

designated raceway systems was found to be in accordance with

specified criteria. Each of the Class IE cables examined by

NRC CAT inspectors had been installed in accordance with the

roul.ing detailed on the applicable computer generated Cable

Pu'l Ticket.

One instance of improper routing was identified in the Power

Generation Control Complex (PGCC). NRC CAT inspectors noted

that nonsafety-related cable C11A-XX-030 had been looped into

a Division 2 safety-related floor section near panel H13-P652.

Investigation indicated that this condition was the result of

improper distribution of excessive slack in the cable. A

review of the applicable design document, Panel Module

Wirelist 287A5660, Rev. 11 showed a correct routing of this

cable through nonsafety-related floor sections.

As a result of this observation, the licensee has issued

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Nonconforming Material Report (NCMR) 2-0304 and Construction

Work Request (CWR) 6271 to document and correct this condition.

(2) Separation

During the inspection of Class IE cables NRC CAT inspectors

identified a number of cable and wiring installations which

did not conform to specified requirements for electrical

separation. Examples identified include wiring deficiencies

which were located inside of control room operator panels. In

this area, examination revealed that vendor installed wiring

had been routed through flexible metalic conduit. In several

areas conduits which contained redundant Class 1E wiring had

been installed in physical contact with one another. Examples

of this condition were observed in the following panels:

P800-62, 63, 64, 65

P870-55, 57, 58, 59, 61

P601-19, 22

Additionally, inadequate spatial separation was observed be-

tween exposed Class IE wiring in several of the control panel

sections.

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NRC CAT inspectors examined the documents whic.h control the

design and installation of equipment in the cortrol room area.

The General Electric Company (GE) Topical Repor?. NEDO-10466-A

provides design criteria and safety evaluation 1or components

comprising the PGCC. In accordance with the definition pro-

vided by this document, the PGCC consists of 1) a set of steel

floor sections, 2) a set of termination cabinets, and 3) a set

of interpanel cables.

Other control room panels, such as operator and signal

conditioning panels, are not considered part of the PGCC

and were designed by Sargent & Lundy Engineers. However,

internal separation for all control room panels was to be

in accordance with the requirements of GE document 22A7472

" Electrical Equipment, Independence For Nuclear Safety-

Related Systems."

In reviewing these documents NRC CAT inspectors raised

questions concerning the use of flexible conduit as a fire

rated barrier within control room panels. Discussions with

licensee personnel indicate that the use of flexible conduit

in the PGCC panels and ficor sections has been justified by

test and analysis as stated in Section 8.3.1.4.5.5 of the

FSAR and that this analysis provides justification for use

of flexible conduit in other control room panels as well.

However, based upon subsequent discussions with the NRR staff,

NRC CAT inspectors concluded that analysis of components

outside the scope of the PGCC has not been provided. As such,

the wiring configurations described above do not comply with

FSAR requirements.

Additionally, the use of flexible conduit as a fire rated

barrier and the fire protection adequacy of control room panels

outside the scope of the PGCC installation are issues requiring

further evaluation by the NRC.

In connection with this issue a program weakness was identified

concerning the review of vendor issued specifications. GE

specification 22A7472 was issued in April of 1981 and, as pre-

viously indicated, provides requirements for separation within

electrical equipment. However, the S&L review of this spec-

ification did not occur until January of 1985. The S&L approval

of this specification stipulates that " contractor may proceed

in accordance with specification based on making the revisions

noted and resubmit." NRC CAT inspectors expressed concerns re-

garding the timeliness of this review in light of the fact that

S&L revisions and comments to the specification were extensive

and that much of the equipment affected by the requirements of

the specification had previously been installed and, in some

cases, turned over to operations. The licensee should deter-

mine whether S&L's specification changes are being incorporated

into the installed equipment.

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Separation deficiencies were also identified in 4160V switch-

gear E22-5004. However, this deficiency and the adequacy of

the installation are addressed in Potential Deficiency Report

81-05. Construction activity in connection with resolution of l

this report has not been completed.

Separation Leficiencies also exist between exposed electrical

cable and raceway components. As discussed in Section

II.B.1.b(1) above, these deficiencies had not been identified

by the licensee due to inadequate incorporation of accept /

reject criteria into separation walkdown procedures.

(3) Power Cable Spacing and Derating

CPS power cable installations have been designed in accordance

with Insulated Power Cable Engineers Association (IPCEA) publi-

cations P-46-426 " Power Cable Ampacities - Volume I - Copper

Conductors" and P-54-440 "Ampacities - Cables in Open Top Cable

Trays." The power cables have been derated in accordance with

the IPCEA standards such that cables sharing raceways may be in

contact. Additionally, ampacities for power cables are based

on a 2-inch average depth of fill in cable tray. As a result,

cables in solid metal trays could be installed without

maintained spacing.

The project's power cable ampacities calculation, S&L No.

19-G-1, was reviewed and compared to the FSAR commitments.

The calculation takes the appropriate values from tables in

IPCEA P-54-440, adjusts the values for actual cable

diameters and applys a five percent general derating factor

for tray covers. The ampacities are derated an additional

10 percent as required by IPCEA P-54-440 for a 50 C ambient

temperature and it is these values that are listed in the

FSAR Section 8.3.

No deficiencies were identified in this area.

(4) Cable Damage

With the exception of the Class 1E cables damaged as a result

of the watt transducer fire in 4160V switchgear 1E22-5004

discussed in Section II.B.3, below, no deficiencies were

identified in this area.

(5) Cable Identification

In general, the identification of Class 1E cable installations

was found to be in accordance with applicable design

criteria. No construction deficiencies were identified.

(6) Terminations

In general, cable termination activities performed by

construction personnel conformed to requirements. However,

two types of deficiencies were observed and are discussed

below, i

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(a) The NRC CAT examined four 5kV terminations in switchgear

and found three which were not insulated as required by

specification. These were the "from" ends of cables

1LP01A-PIE, 1HP08A-P3E and 1HP030-P3E. Section 1004.1C2

of S&L Specification K-2999 and paragraph 4.12.la of BAP

3.3.3 require all SkV terminations in switchgear to be

insulated with termination kits or insulating boots. The

BA QC Inspection Checklists for the three terminations and

IPOI's checklist for ILP01A accepted the installations

indicating that insulation was not required.

The terminations for 1HP08A and 1HP03D in switchgear

1E22-S004 were subsequently documented on NCR 32232 and

Field Change Request (FCR) 38981 and dispositioned use-

as-is. This was based on S&L's determination that the

busses for this particular switchgear were not required

to be insulated and, therefore, the cable terminations

need not be. IP startup had identified uninsulated bus

to breaker connections in the switchgear containing cable

ILP01A, but had not identified the uninsulated cable

terminations.

Although discussions with the licensee indicate there may

be technical justifications for certain uninsulated SkV

terminations, the installations identified by the NRC CAT

inspectors do not conform to current specification require-

ments.

(b) A field-installed jumper wire in the remote shutdown panel

was found by the NRC CAT to be a type which is not qualified

for Class 1E service. This jumper wire is located on ter-

minal strip GG, between terminal points 18 and 26, and is

depicted on drawing E03-1C61-P001, sheet 6, Rev. K. Further

investigation of this finding revealed the following:

Startup discovered, during system checkout, that the

required jumper between these points was missing and

initiated Maintenance Work Request (MWR) B02288 in

order to have plant operating staff personnel install

the missing jumper wire.

The MWR form was improperly reviewed, thus the K R

was processed as a nonsafety-related work order.

Due to the error in the processing of the MWR form,

non-Class 1E qualified jumper wire was obtained from

the operations warehouse and installed by plant

operating staff personnel, and QC inspection of this

installation was not performed.

Subsequently, the licensee has issued MWR-B11255 and

Condition Report 1-85-06-007 to document this NRC CAT

finding. However, the condition report inaccurately

indicates that use of unqualified wire does not involve

nonconforming material and, therefore, does not indicate

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the appropriate safety classification for the condition

being reported.

It should be noted that, due to a similar finding by the

NRC CAT at another facility, the licensee had previously

instituted a program to assure that all field-installed

wiring was accomplished using Class 1E qualified wire.

This included the removal of all unqualified wire from

the construction warehouses to preclude its inadvertent

use. However, this purge of unqualified wire did not

extend into IP's operations warehouse.

The NRC CAT inspectors then selected an additional 10

safety-related MWRs which involved termination activi-

ties requested by startup and performed by plant staff.

The MWRs selected are: 804831, B1000, B10039, A13589,

B10038, A16980, A14412, A17116, A17112, and 810159. These

were reviewed for proper processing of the form and evi-

dence of the application of adequate QA program require-

ments to the work performed. In addition, the NRC CAT

inspectors physically inspected the completed hardware

pertaining to each MWR.

The results of this review are as follows:

Two additional instances of unqualified jumper wire

were discovered. These were related to MWRs A16980

and A17116 and involved internal wiring in

safety-related motor operated valves ISX004C and

1SX006C.

The form for MWR A14412 indicated that no QC inspection

was required. The work associated with this MWR is the

splicing of internal motor leads to field cable in

safety-related motor operated valve ISX004C, Sargent

& Lundy Standard EA-209 requires these splices to be

insulated, either with Class IE qualified insulating

and jacketing tapes, or with Class IE qualified heat-

shrinkable tubing. The completed configurations of

either of these methods renders it impossible to

determine whether or not qualified materials were

used and were properly installed. Therefore, in order

to assure the adequacy of these splices, an in process

witnessing inspection by QC was necessary.

MWR 81000 involves the swapping of two motor leads at

the Residual Heat Removal pump 1C motor in order to

achieve proper phase rotation of the motor. Review of

the MWR form and associated QC inspection documentation

indicates that the work was properly accomplished and

inspected. However, no documentation was generated

which would inform the designer of the change in motor

phasing. Therefore, the currently approved design doc-

ument (wiring diagram E03-1RH00, SH.9, Rev. D) is in

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conflict with the as-installed configuration of the in-

sta11ation. The licensee stated that the disposition of

FCR 24896 allows motor terminations to be changed with-

4

out initiating a design change document and that the

designer need not be notified of such changes in motor

! phasing. A review of this FCR reveals that, although

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it does state " connections may be modified as required

to obtain proper motor rotation", it does not indicate

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that approved design drawings (wiring diagrams) do not

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have to depict the as-installed wiring configurations.

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In addition, on page 2 of 5 of the "Clinton Power

Station As-built Program" dated May 2, 1985, the

licensee has committed to maintain wiring diagrams

l in an as-built condition.

In summary, of 11 maintenance work orders reviewed, 6

instances of either unqualified material, improperly

documented or missed inspections, and conflict between

as-built configuration and approved drawing were observed.

This indicates that the Maintenance Work Request Program

is ineffective in identifying safety-related work and

prescribing the appropriate QA requirements for the work.

c. Conclusions

Wiring installations in a number of control panels are not in

I accordance with applicable electrical separation requirements.

Additionally, the use of flexible conduit as a fire rated barrier

and the fire protection adequacy of certain control room panels are

issues requiring further evaluation by the NRC. A number of Class

IE 4160V cable terminations have not been completed in accordance

with applicable design requirements.

'

"

The hardware and QA program deficiencies identified in the area of l

the Maintenance Work Request program indicate a need for additional

management attention in order to assure that safety-related wiring

remains in conformance with applicable requirements subsequent to

turnover from construction.

3. Electrical Equipment Installation

a. Inspection Scope

Over 30 pieces of installed or partially installed electrical

equipment and associated hardware items were inspected. Samples

J were based on system function and safety classification.

The following specific electrical components were inspected in

detail:

(1) Motors

The installation of four motors and associated hardware was

inspected for such items as location, anchoring, grounding, i

identification and protection. The motors inspected were: ,

.

II-12

_ _- -

._ - _- , _ . ._ . -- __ - - - -

. _ _ _ - - - - - - - - - -

_ ____

_ _ __. __ ___ -- - _ . _ - - . - _ __- _ - . _

l Residual Heat Removal Pump Motor 1AP07EG-1A

l Residual Heat Removal Pump Motor JAP 09ED-1B

Low Pressure Core Spray Pump Motor 1AP07EE

High Pressure Core Spray Pump Motor IE22-S001

(2) Electrical Penetration Assemblies

The following containment penetration assemblies were

inspected:

1EE10E-1P2E Power

IEE22E-1C3E Control

1EE33E-1K2E Neutron Monitoring

! 1EE18E-1C1E Control

The location, type, mounting and identification of these

penetrations were compared with the installation drawings

and vendor manual.

(3) Circuit Breakers

Circuit breakers for the following Class IE pump motors were

examined to determine compliance with design and installation

l documents for size, type, system interface and maintenance.

Low Pressure Core Spray

i High Pressure Core Spray

Residual Heat Removal Pump 1A

(4) Switchgear and Motor Control Centers

l The following switchgear and motor control centers were

inspected:

Motor Control Center 1AP30E-18

l

Motor Control Center 1AP60E-1A

Motor Control Center 1AP73E-1A

4160V Switchgear 1AP07E-1A1

4160V Switchgear 1AP09E-181

4160V Switchgear 1E22-5004-101

(5) Station Batteries and Racks

The 125V battery rooms including the installed batteries,

battery racks and associated equipment were inspected. The

location, mounting, maintenance and environmental control for

installation of the batteries were compared with the applicable

requirements cnd quality records.

i

, 125V DC Battery 1DC06E-1A

i 125V DC Battery 10C01E-1B

II-13

,

- . , , . . - - - ,

- r- - . . . - . - .,----------.,n - , - - ,.,_-- - - - - --~-------rm-.

._ _

(6) 125V DC System Equipment

The following equipment comprising portions of the 125V dc

systems were inspected for compliance to design documents

for such items as location, mounting (welds, concrete anchors

and bolting) and proper configuratfor

Battery Charger 10C06E-1A

Battery Charger 1DC07E-1A

125V DC Motor Control Center 1DC14E-1B

125V DC Distribution Panel 1DC14E-4A

Static Inverter 1C71-S001A

Static Inverter 1C71-S0018

(7) Conteql Panels

A number of safety-related electrical control panels were

inspected for compliance to requirements for items such as

location, mounting and type. The panels inspected were:

Remote Shutdown Panel 1C61-P001

Diesel Generator Control Panel IPL12JA

Diesel Generator Control Panel 1PL12JB

Operator Main Control Panels

(8) Motor Operated Valves

Four motor operated valves were examined in detail.

1E12-F004A

1E12-F0278

1E12-F0248

1E12-F047A

The following documents provided the basic acceptance criteria for

the inspections:

S&L Clinton Power Station Specification K-2999, " Electrical

Installation," Amd. 10

BAP 2.10, " Equipment Installation," Rev. 6

BQAI-190-6, " Electrical Equipment Field Verification," Rev. 4.

b. Inspection Findings

(1) Motors

Motors examined were found to have been installed in accordance

with applicable design criteria. Nameplate data such as operat-

ing voltage, horsepower and speed were compared with FSAR re-

quirements and found to be acceptable. Maintenance records for

the High Pressure Core Spray pump motor were reviewed and also

found to be acceptable.

II-14

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._

During the examination of the Low Pressure Core Spray pump motor

NRC CAT inspectors raised questions concerning the adequacy of

materials used to mount the motor to its pedestal. This issue

is discussed further in Section VI, Material Traceability and l

Control, of this report.

(2) Electrical Penetrations

Penetrations examined were found to be in accordance with

design documents. Installation and inspection procedures were

thorough, and associated inspection and maintenance records

were detailed and complete.

During the examination of the electrical penetration assemblies

it was noted that a pipe restraint had been welded to the

nozzle of penetration IEE27E. Discussion with the licensee

l

regarding this issue disclosed that nonconformance reports (NCR

28725 and NCMR 1-0971) had previously been issued to document

this condition and had been dispositioned use-as-is by engi-

neering. Based upon the information available, NRC CAT

inspectors could not determine whether this activity had

.

'

adversely affected the penetration gas boundary or components

within the penetration sleeve, or whether the disposition of

the nonconformance reports is adequate.

Further evaluation by the licensee is required.

(3) Circuit Breakers

The examination of the selected circuit breakers indicated

that they had been installed and maintained in accordance

with applicable design documents. Important installation

attributes such as proper alignment and main contact pene-

tration were verified by physical inspection of the equip-

ment and review of construction and startup test records.

(4) Switchgear and Motor Control Centers

Several construction deficiencies were identified in Class 1E

switchgear installations. The examination of switchgear 1AP09E

disclosed that the switchgear unit had been floor mounted using

'

American Society for Testing and Materials (ASTM) A-307 bolting

materials corresponding to Society of Automotive Engineers

(SAE) Grade 2. In reviewing the vendor (Westinghouse) manual

NRC CAT inspectors noted that SAE Grade 5 bolting material had

been specified for this installation. Additionally, the review

of the seismic qualification report for this equipment indi-

cates that Grade 5 bolting materials had been used to mount the

test unit to the shake table for qualification.

This item was discussed with licensee personnel who produced

NCR 24174 which had been issued in December of 1984 to document

this condition. Subsequently, this item was transferred to

and dispositioned on CPS NCMR 1-0413 in accordance with site

procedures for items turned over to operations. The disposi-

II-15

..

.

.

- -__-__- -- -

tion of the NCMR requires that all of the existing bolting

material be replaced with the specified SAE Grade 5 material.

NRC CAT inspectors noted that the switchgear unit is energized

and provides the Class 1E power feed for many of the plant

systems currently under test. Consequently, although this

deficiency had been properly identified by the licensee, the

delay in initiating the specified corrective action could ad-

versely affect other plant systems.

During the examination of switchgear 1E22-5004 NRC CAT inspec-

tors noted that watt transducer 1JY-AP778 located inside of

cubicle 1 of the switchgear had burned. Additionally, the trans-

ducer associated wiring and Class 1E field cables located above

the device had also been damaged as a result of the transducer

fire.

Discussions with licensee personnel revealed that MWR B08649

had been issued to document and correct this condition. A

review of this document indicates that the disposition,

" Procure, calibrate and install new transducer and associated

wiring as necessary," is inadequate in that it fails to

consider damage done to the Class 1E field cables located

in proximity to the device.

Wiring separation deficiencies were also identified inside of

various cubicles of switchgear 1E22-5004. This item is identi-

fied as part of Potential Reportable Deficiency 81-05 dated

February 5,1982 and specified rework is scheduled to be

accomplished in accordance with the resolution of this docu-

ment.

The examination of switchgear 1AP07E and the motor control

centers selected indicate that they have been installed in

accordance with applicable requirements.

(5) Station Batteries and Racks

i

!

The condition of the 125V battery rooms was found to be clean,

free of debris and in good order. Although permanent ventila-

tion systems had not been installed, temporary systems were in

place and provided adequate ventilation for the areas examined.

Access to these areas was controlled by keyed entry.

The 125V batteries were examined in detail and found to be

in good condition. Maintenance activities were reviewed and

in general had been performed in accordance with requirements.

(6) 125V DC System

Inspection of components comprising the 125V de system

disclosed a deficier.cy in the installation of battery chargers

1DC07E and 1DC06E. Design documents which specify

installation details for this equipment show mounting pad I

dimensions which differ from the actual field configuration. '

II-16

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_

. _ _ _ _ _ _ _ _ ____ _

__ .

l

IDC07E - Design Dimensions 48 inches W x 40 inches D

Actual Dimensions 47 inches W x 36 inches D

IDC06E - Design Dimensions 48 inches W x 40 inches D

Actual Dimensions 47 inches W x 38 inches D

l The review of applicable records indicates $ hat the

l appropriate design change document had been initiated for the

conditions noted on charger 1DC-06E. However, technical

justification for the discrepancies identified on charger

1DC-07E was not provided.

As a result of this observation the licensee has issued NCR

l 32598 to document and correct this condition.

l

Other 125V dc system components examined were found to have

been installed in accordance with requirements.

(7) Control Panels

In general, the installation of Class 1E control panels was

found to be in accordance with applicable requirements. Six

panels were identified which had been mounted using bolts of

indeterminate material type. The following panels exhibited

this condition:

Switchgear HVAC Control Panel 1PL65JC

Switchgear HVAC Control Panel IPL65JB

Diesel Generator HVAC Panel 1PL54JA

Shutdown Service Water Panel 1PL53JA

Shutdown Service Water Panel 1PL53JB

Shutdown Service Water Panel 1PL53JC

i

The use of indeterminate bolting materials in safety-related

applications is discussed in detail in Section VI, Material

Traceability and Control, of this report.

During the examination of the Divisions 1 and 2 Class 1E Diesel

Generator Control panels, NRC CAT inspectors noted that physical

identification of the panels was not in compliance with FSAR

requirements for identification of Class 1E equipment. Name-

plates supplied by the vendor (Stewart & Stevenson) are not of

the color coding required for safety-related Divisions 1 and 2

electrical equipment.

Discussions with the licensee indicate that the requirements of

Specification K-2861, to which these panels were purchased, may

have been implemented prior to the FSAR commitment for color

coding of equipment. Consequently, these panels had not been

properly identified. As a result of this observation the licen-

see has issued Field Engineering Change Notice (FECN) 10305 to

document and correct this condition.

II-17

.

.

l

l

In addition, the NRC CAT inspectors reviewed a licensee surveil-

lance of vendor panels. Based on an NRC inspection at another

site, the licensee's QA organization initiated a special surveil-

lance of vendor panels concentrating on those turned over to IP

startup and initially tested. The surveillance findings indica-

ted a number of problems and resulted in IP QC performing a

broader scope inspection program. However, the scope of the IP

QC inspection program does not include panels manufactured by

MCC Powers and a number of GE panels.

The NRC CAT specifically inspected a number of panels excluded

from the IP QC program and identified a number of discrepancies:

IPL54JA (MCC Powers) Separation between non-Class 1E

field installed lighting circuit

and Class 1E vendor wires; minimum

bend radius of Class 1E vendor

wires (subsequently documented on

NCMR 2-0350); mounting bolts of

indeterminate material.

IPL53JA (MCC Powers) Separation between non-Class 1E

field cable IVH79A and Class 1E

vendor wires; mounting bolts of

indeterminate material.

1PL53JB and JC (MCC Mounting bolts of indeterminate

Powers) material.

H22-P028 (GE) Misidentification of Class 1E

associated vendor wiring as non-

Class 1E; separation between

Class 1E vendor wiring and non-

Class IE lighting and utility

circuits; isolation or analysis of

the interface between Class 1E

associated vendor wiring and non-

Class 1E field wiring. Subsequently

addressed on Field Deviation

Disposition Request, LH1-3027

Rev. O.

The NRC CAT findings indicate that the scope of the IP QC

inspection program for vendor supplied control panels needs to

be enlarged. The discrepancies found in the MCC Powers equip-

ment and the GE panel indicate t, hat the 63 panels manufactured

by these two companies originally omitted from the inspection

program should be included. Inspection attributes, such as the

interface between field wiring and vendor wiring, mounting

details, and minimum bend radius should be added to the QC

inspection program.

(8) Motor Operated Valves

Motor operated valves examined were installed and maintained

in accordance with applicable design documents.

II-18

_

_

_- _- -

. ~ . . _ . . _ - - - - - - . _ _ - . . - ..

i

l

I c. Conclusions

l In general, the installation of electrical equipment has been

i accomplished in accordance with requirements. However, of concern

j were the examples of hardware deficiencies which exist in equipment

i which has been turned over for operation.

l Items such as internal panel separation and the mounting of l

1 seismically qualified equipment are concerns which will require

i additional attention by the licensee.

i

i 4. Instrumentation Installation

a. Inspection Scope

i i

The NRC CAT inspectors selected a sample of 15 completed runs of

, instrument piping, comprising about 930 feet, for a detailed

j examination in accordance with specification requirements and

j isometric drawings.

'

four instrument racks and ten piping supports were examined for

i conformance with requirements including installed configuration,

mounting details, material conformance, identification, and loca-

tion.

l

Eleven instruments were examined for conformance with requirements

'

for location, mounting details, and instrument type and range.

i

See Table II-4 for a listing of piping runs, supports, racks, and l

1

instruments included in the sample, and identification of those

j items previously inspected by BAFV or IPOI programs.

The following documents provided the acceptance criteria for the in-

spections

f

l

S&L Clinton Power Station Specification K-2883, " Erection of

l Phase I Piping Systems and Equipment," Amd. 13

BAP 2.6, " Instrumentation," Rev. 7 Change F

f Applicable design drawings and change documents.

I~ b. Inspection Findings

l In general, the installation of instruments, racks, piping runs,

j. and supports conformed to the appropriate requirements. However, a

number of deficiencies were identified and are discussed below:

'

,

l

l (1) The weld symbol for weld number 1 of support 1AB35011G on

! drawing M-1AB35011G, Rev. B does not indicate the required

j fillet weld size. The licensee subsequently issued NCR 32421

to document this condition. It should be noted that this

i support had undergone reinspection under the BAFV program, and ,

4

this drawing deficiency was not identified.

!

il

j 11-19

t

!

. - --.~,..._ _ . ,_,,-_ _ .- _ , _.. - ,_. - _ _ . - ._ - - _ ___... - - .. _ ,... ._ . _ _ _ _. - - -

s

(2) Instrument line RH-919-7C was found bent in two locations (due

to construction traffic in the area) near support 1AB01034G.

The licensee subsequently issued NCMR 2-0338 to document this

condition.

(3) The support clamp for piping run IE12-N015A "LO" on support

1AB02204G was found to be missing. Further review revealed

that this condition had been previously discovered by the BAFV

program and documented on NCR 80367 and NCMR 1-1005.

(4) Instruments 1E12-N015C, 1E12-N055C, and 1E12-N056C are mounted

on instrument rack 1E22-P005 using bolts containing no identi-

fication markings on their bolt heads. The NRC CAT inspectors

observed that all other bolts used to mount instruments to this

and other instrument racks contain markings which identify them

as ASTM A-307 (SAE Class 2) bolts. The licensee has subsequently

issued NCMR 2-0335 to document this condition. This NCMR states

that Rosemont Instruction Manual 4302, Rev. 8, Model 1153 re-

quires these bolts to be ASTM A-193, Grade B8, which would indi-

cate that all bolts used to mount instruments to racks are non-

conforming. Further review by the licensee is necessary to ac-

curately define the material requirements for these bolts.

(5) Three instances were observed of installed instrument piping

in physical contact with other items. These are:

Instrument line 1MS31AB-3/4 is in contact with 6-inch

diameter pipe 1HG05BA

Instrument line IMS31JB-3/4 is in contact with 3-inch

diameter pipe ISC02DA

Instrument line 1NB05BB-3/4 is in contact with heating,

ventilating and air conditioning duct support P-4010.

In the first two cases, the licensee's Interaction Analysis

Group had previously documented these points of contact on

Potential Interference Reports (PIRs) C-2007 and C-2008, which

have been dispositioned use-as-is by S&L. Further discussions

with the Interaction Analysis Group reveals that the analysis

supporting the use-as-is dispositions only addresses possible

seismic interaction and may not consider thermal expansion or

movement of either the instrument lines or the pipe involved.

In the third case, discussions with the Interaction Analysis

Group indicates that interactions of this type are considered

to be a generic exclusion to their criteria and, as such, they

are not required to document this on a PIR. However, following

further discussion with the licensee, NCMR 2-0334 was issued to

document this condition as a construction deficiency instead of

a seismic interaction. The NRC CAT questions the prudence of

the generic exclusion for such an item. Identified construc-

tion deficiencies in completed and QC accepted installations

need to be recorded and evaluated in accordance with existing

QA requirements.

II-20

__

.__

Refer to Section III, Mechanical Construction, of this report )

for a further discussion of the licensee's Interaction  !

Analysis Program. -j

c. Conclusions

The NRC CAT inspectors determined that, in general, instrumentation,

tubing, and support installations conform to applicable require-

ments. The activities of the Interaction Analysis Group and

subsequent dispositioning of identified PIRs by S&L require further

review by the licensee.

1

II-21

_

l

TABLE II-1

,

RACEWAY INSPECTION SAMPLE

Cable Tray:

'

189A(P2E) 188A(P2E) 187A(P2E) 186A(P2E) 185A(P2E)

184A(P2E) 183E(P2E) 182A(P2E) 181A(P2E) 18R9(P2E)

1892G(P2E) 1893G(P2E) 16297G(P2E) 1894G(P2E) 1895G(P2E)

16296G(P2E) 16295G(P2E) 16294G(P2E) 16293G(P2E) 16292G(P2E)

16291G(P2E) 16260G(P2E) 16259G(P2E) 16257G(P2E) 1071D(P2E)

i

,

1072D(P2E) 1070D(P2E) 10690(P2E) 1068D(P2E) 10670(P2E)

1063D(P2E) 1064D(P2E) 1065D(P2E) 1066D(P2E) 169D(P2E)

i

168D(P2E) 167D(P2E) 166D(P2E) 165D(P2E) 164D(P2E)

163D(P2E) 162D(P2E) 161D(P2E) 16R1(P2E) 16413K(C4E)

16412K(C4E) 16411K(C4E) 16410K(C4E) 10510K(C1E) 16R9(C1E)

1614B(C1E) 17R12(K1E) 17111C(K1E) 17112C(K1E) 17115C(K1E)

17116C(K1E) 17117C(K1E) 17R55(K1E) 17220C(K1E) 17222C(K1E)

17223C(K1E) 17224C(K1E) 17R80(K1E) 19120D(P3E) 19121D(P3E)

19122D(P3E) 19123D(P3E)

Cable Tray Supports:

Support Number Drawing Number

1000-0180H3 E26-1000-018-H3

E26-1000-018-CPH

1001-03A-H24 E26-1001-03A-H24

E26-1001-03A-CPH

l 1003-01A-H57 E26-1003-01A-H57

E26-1003-01A-CPH

'

1005-04A-H44 E30-1005-04A-H44

E30-1005-04A-CPH

1004-04A-H2 E30-1004-04A-H2

E30-1004-04A-CPH

1002-01A-H1 E27-1002-01A-H1

E27-1002-01A-CPH

1003-01C-H9 E27-1003-01C-H9

i

E27-1002-01C-CPH

-

!

i

i

!

!

II-22

4

- - - - - - --,e--.-. - - , n - - - . , ~ , - - ,, , - --- - , ,,-,-,.-w,, - - - . . ,-,,,v- ,,,-,-,- - , - , ---- -- - - - .

_ _. _ _ _

I TABLE II-1 (Continued)

RACEWAY INSPECTION SAMPLE

Conduit Supports:

E26-1003-03A-TCC-2

'

E26-1003-01A-CC-CP-2

E26-1002-04A-CC-17

E26-1002-04A-JS-1

E26-1003-01A-CC-57

E26-1003-01A-WH-3

Conduits:

Conduit No. Length (feet) Conduit No. Length (feet)

C2301 8 C61490 36

• C2305 10 *C61545 29

C2318 19 *C62867 31

• C2319 10 C71191 37

C2341 8 C71192 39

C629 48 *C72183 45

C633 48 *C71365 110

C6404 33 *C71543 46

C6438 23 C71855 50

C6141 52 C9822 43

C61039 17 C9823 43

C61066 27 C9824 43

C61069 28 *C91230 23

C61371 25 C91523 21

C61386 16 C91527 20

C61394 27

l

NOTE: The (*) indicates conduits inspected under the Baldwin Associates

Field Verification Program.

1

II-23

-_ - - _ _ _ - - ... . _ _ _ . _ _ . . _ _ . _ _ . . .__ _ _. _ - _

TABLE II-2

SEPARATION FINDINGS

,

j Raceway segments listed in the A columns do not maintain required separation from

! the corresponding raceway segments in B columns. The (*) indicates physical

separation of less than one inch between the two raceway segments.

I

!

Column A Column B Column A Column B

l C9713(K1E) IPB999(P2E) C6207(B) 167D(P2E)

*

' C92709(C18) * C92757(P1E) C659(B) 168D(P2E)

C92709(C18) C92758(C1E) C0357(B) 1065E(C2E)

C73991(C28) C71191(C2E) C02522(B) 1065E(C2E)

j C73991(C28) C71192(P2E) C8926(B) 187A(P2E)

1

'

C71365(C2E) C73639(K18) C8133(B) 187A(P2E) ,

C71365(C2E) * C7894 (C1E) C8578(B) 184A(P2E) 1

) C71365(C2E) C71991(K3N) C8579(B) 184B(C2E)

j *

C71365(C2E) C73218(C28) C8137(B) 184A(P2E)

{ C71365(C2E) * C72235(K18) C8300(B) 183A(P2E)

• *

! C71991(K3N) C72030(K28) C8538(B) C81649(2E)

j -C72717(C2E)

C72812(K1E) C8699(C3E) 1875D(P28)

i C7891 (C2E) * C73287(K1B) C81775(2E) 1833D(P3E)'

f- C62367(K4E) * C61069(C2E) C81777(2E) 1833D(P3E)

C62367(K4E) C62084(P2E) C81776(2E) 1833D(P3E)

'

C62367(K4E) * C61068(P2E) C81778(2E) 1833D(P3E)

} C62367(K4E) * C62100(K18) C81257(B) 18926(P2E)

l- C6141 (CIE) * 1PB695(P18) C0224(B) 1061D(P2E)

i 16300K(C4E) C61039(C2E) C0223(B) 1061D(P2E)

j 16300K(C4E) C61037(C2E) 1068D(P2E) C0372(B)

j 16300K(C4E) C61038(C2E) 1068C(C2E) C0372(B)

! 16300K(C4E)

C62876(C2E) C72997(1E) * C72514(4E)

, C6947 (P1B) C6949 (PIE) C72296(1E) * C72514(4E)

j C61066(P2E) * C61364(K1E) C72297(1E) * C71570(3E)

j *

C61371(C2E) C6934 (P28) C71570(3E) * C72296(1E)

! C73255(CIE) IPB7107(DIV.2) C72888(1E) * C71541(2E)

i

C71855(K3E) * 17128C(K1B) C73160(B) * C73666(1E) l

C6917(B) 16279G(P2E) 1H13-P70GA(1E) 10360A(C1B)

i; C61364(1E) C61066(2E) 1H13-P701A(1E) 10347A(C1B)

. C61374(1E) 16257B(C2E) 1H13-P731F(IE) 10344A(C1B)

! C61373(1E) 16257A(C2E) C62382(B) 16390E(C3E)

• *

i

'

C61258(P28) C61373(1E) C62381(B) 16390E(C3E)

C6249(B) 161D(P2E) 10602(C1B) 10603K(P2E)

C6303(B) 167E(C2E) 10602B(CIB) 10631A(P1E)

;

'

i

I

1

i

a II-24

_. .. _ _ _ . . _ . _ , _ . _ _ _ _ _ . . _ . _ . _ . _ _ _ _ . . , _ . _ . . . _ . . _ - , - _ . - _ . _ - . ,

TABLE II-2 (Continued)

SEPARATION FINDINGS

Column A Column B

10632B(C1E) 10603K(P2E)

10603K(P2E) 10632A(PIE)

10611D(P28) 10615K(P2E)

10611E(C28) 10615L(C2E)

10600E(C28) 10632B(C1E)

C1079(B) 10632B(C1E)

10600K-P2E 10632A(PIE)

C6901(P28) 16257G(P2E)

C6901(P28) 16258A(C2E)

C6901(P28) 16258G(P2E)

C6901(P28) 16259G(P2E)1

C0409(B) C9866(1E)1

10358B(C1B) 1H13-P706F(1E)1

C0409(B) 1992B(C1E)

C9866(B) C9831(C1E)

C0410(B) 1989B(C1E)

C9713(K1E) IPB999(P2E)

C9804(B) 1992A(PIE)

C9657(2E) C9617(B) '

C9657(2E) C9615(B)

C74311(B) C72514(4E)

NOTE: 1These separation deficiencies also involve raceway to cable.

11-25

TABLE II-3

CABLE TERMINATION INSPECTION SAMPLE

PGCC Termination Cabinet 1H13-P743

Cables: 1VD038, IVD18E, IVD11F, IVD03D, IVD06B, 1VD03C,

IVD06C, IVH09E, 1VH098, IVH09D, IVX218, IVX188,

1VX09B, IVX128, IVY 098, IVY 088, 1D003C, 1HP21P,

1HP75A, 1HP75B, 1HP75C, 1HP75D, 100798, ID079A,

1SX750, ISX75C, 1SX55A, 1SX08C, 1SX03D, ISX038.

PGCC Termination Cabinet 1H13-P742

Cables: 1VC068, IVC 088, IVD05C, IVD02D, IVD028, IVD10F,

1VD18C, IVD02C, IVF07J, IVC 40L, IVG35K, IVC 02C,

IVC 45H, IVC 148, IVC 45F, 1AP23G, 1DG31G, 1AP23B,

1DG21f, 1AP290, LAP 21G, 1AP23F, IAP21M, IDG31L,

IAP60D, IAP29C, 1AP29K, ICC08C, ICC09C.

PGCC Termination Cabinet 1H13-P741

Cables: 1AP220, IDG11G, 1AP28E, 1AP228, 1DGG1D, 1AP20G,

IAP22G, 1AP20M, ICC11F, ICC14G, IDG11L, 1AP28K,

ICC14C, ICC11C, ICC17L, ICY 05C, IRP11E, ICY 09C.

Diesel Generator IA Control Panel 1PL12JA

Cables: IDG02A, IDG020, IDG11F, IDG11S, 1DG02B, IDG11C,

1DG11T, 1DG11E, 1DG11D, 1DG01D, 1DG02F, 1DG04A,

1DG06A, IDG098, 10G09C, 1DG10C, 1DG108, IDG05A,

1DG07A, IDG02C, 1DG02E, 1DG02G, 1DG75E, 10G11R,

1DG75C, IAP20K, 1AP22J, 1DG08A, IDG01E, 10G01Q,

IAP20M, IAP22K, IDG015, IDG01Q, IDG01R.

Division 3 Optical Isolator Cabinet IPL49J

Cables: IMIO5A, 1HP110, 1HP17J, ISX03E.

Remote Shutdown Panel 1C61-P001

Cables: 1RH55F, 1RH55E, 1RH40D, 1RH40C, 1RH310, 1RH31C,

1RH27D, 1RH27C, 1RH070, IRH07C, 1RH12D, 1RH12E,

1RH12C, 1RH01G, IRH01H, 1Ril01C, 1RS02A, 1RH22E,

1RH09F, 1RH09D, 1RH09C, 1RH18D, 1RH18C, IRH16D,

1RH16C, 1RH61F, 1RH61E, 1RH380, 1RH38C, 1RH63F,

1RH63E, 1SX20C, ISX20N, 1RH220, 1RH22C, IRI13E,

IRI13C, 1RIl0D, IRIl0C, IRIO3D, IRIO3C, IRIO60,

1RIO6C, 1RI26D, 1RI26C, 1RIO5D, IRIO5C, IRIO8D,

IRIO8C, IRI25C, 1RI258, IRI248, IRI24A, IRI27F,

IRI27G, 1NB380, 1RH73L, IRI12E, IRI12C, IRIO9G,

1RIO9C, IRI24J, IRI24H, 1RI24G, IRI24K, 1RSO4A,

1RS06A, 1RS82A, IRIllD, IRI11C, IRIO7D, IRIO7C,

IRIO40, IRIO4C, 1RS05C, 1RH13D, 1RH13C, IRH13E,

IRH17F, 1RH17E, 1RS05B, 1RH10E, 1RH23D, 1RIO2F,

IRI15F, IRI27J, IRI27H, IRI15E, IRI170, IRI17C,

1RH37C, 1RH37D, INB390, IRS 05A, 1NB35A, 1NB35C,

II-26

TABLE II-3 (Continued)

CABLE TERMINATION INSPECTION SAMPLE

Remote Shutdown Panel 1C61-P001 (Continued)

Cables: 1RI760, IRI76G, IRI76E, IRI76C, IRI85C, 1RS75A,

1RS768, 1RS76D, IRI858, IRI85A, 1RS03A, ISX59D,

1SX59C, 1RH240, 1RH24C, 1RH33D, IRH33C, 1RH360,

1RH36C, 1RH500, 1RH50C, ISX14K, 1SX14L, ISX14M,

1SX30E, 1SX170, 1SX33D, 1SX37E, 1SX10F, ISX20Q,

ISX14C, 1SX14F, 1SX14J, ISX30C, ISX17C, 1SX33C,

1SX37C, 1SX10C, 1SX11C, ISX25J, ISX25Q, ISX50F,

1SX20J, 1SX50K, ISX25X, ISX25V, ISX110, 1RS80A,

1RS798, 1RS79D, INB35M, INB35B, IRIO2G, IRIO2F.

4160 V Power Cables in Switchgear

Cables: 1RH02A, 1LP01A, 1HP08A, 1RH27A, ILP03A, 1HP03D.

11-27

_

TABLE II-4

INSTRUMENTATION INSPECTION SAMPLE

Instrument Racks: 1H22-P005 BA OI

IH22-P026 BA OI

1H22-P027 BA 01

1H22-P042 BA

-

Instrument Pipe Supports: ISPS-CM096A

1AB35004G BA

1AB35003G BA

1AB35002G BA

1AB35011G BA

1RB31511R BA

1RB32518G BA

1RB22538G BA

1RB21572R BA

1RB21576X

Instrument Piping Runs: 1PT-CM034/1PT-CH256 BA

1E31-N088C "HI"

1E31-N088C "LO" BA

1E31-N0888 "HI" BA

1E31-N0888 "LO" BA

1E12-N015C "HI" BA DI

1E12-N015C "LO"

1E12-N015B "HI" OI

1E12-N015B "LO" BA

1E12-N015A "HI"

1E12-N015A "LO" BA

1821-N078A BA

1B21-N081A "HI"

1821-N0788 BA

1821-N0818 "HI"

Instruments: 1E31-N088C

1E31-N0888

1821-N081B

1E12-N015A

1E12-N0158

1E12-N015C

1PT-CM034

IPT-CM256

1821-N078A

1821-N0788

1821-N081A

NOTE: 8A indicates inclusion in Baldwin Associates Field Verification.

OI indicates inclusion in Illinois Power Company Overinspection.

II-28

III. MECHANICAL CONSTRUCTION

A. Objective

The objective of the appraisal of mechanical construction was to deter-

mine if installed and Quality Control (QC) accepted mechanical items

conformed to engineering design, regulatory requirements and licensee

commitments.

B. Discussion

The specific areas of mechanical construction evaluated were piping,

pipe supports / restraints, concrete expansion anchors, mechanical

equipment, and heating, ventilating and air conditioning (HVAC)

systems. To accomplish the above objective, a field inspection of a

sample of QC accepted hardware was performed in each area. In

addition, certain programs, procedures and documentation were reviewed

as required to support or clarify hardware inspection findings.

The inspection samples in a number of these areas included items

covered by the Illinois Power ~ Company (IP) Overinspection Program.

Section VII, Design Change Control, of this report provides further

discussion of the IP Overinspection Program.

1. Piping

a. Inspection Scope

Piping depicted on the 11 Baldwin Associates (BA) and 3 Reactor

Controls, Inc. (RCI) drawings listed in Tables III-la and b was

inspected by the NRC Construction Appraisal Team (CAT). In all

cases, piping inspected by the NRC CAT had been previously inspected

and accepted by the responsible QC organizations. The piping

samples included portions of the High Pressure Core Spray (HPCS),

Low Pressure Core Spray, Reactor Core Isolation Cooling (RCIC),

Reactor Water Clean-Up, Shutdown Service Water, Main Steam Isolation

Valve Leakage Control, Nuclear Boiler, and Control Rod Drive ('RD)

systems. In addition, some of the NRC CAT samples included piping

covered by the IP Overinspection Program. Attributes inspected

included configuration (i.e., component orientation and dimensions),

component locations and types, and valve operator orientations.

Pipe support locations and types were inspected against hanger

design drawings to the extent indicated in Table III-1. Site

construction practice as it affected installed components was

observed and component material specifications were compared to

drawing bills of material on a random basis.

The sample of BA piping selected for inspection included all American

Society of Mechanical Engineers (ASME) pipe classes and ranged in

size from 1 to 20 inches. The sample included approximately 600

feet of large bore (greater than 2-inch diameter) and approximately

275 feet of small bore (less than or equal to 2-inch diameter)

piping located in the containment, auxiliary, fuel and diesel

generator buildings. QC verified isometric drawings were used to

III-1

1

l

perform the inspection. Subsequently, field data compiled by the

NRC CAT was also compared to walkdown record copies (NRC IE Bulletin

79-14) of piping design drawings to the extent indicated in Table

III-1. Observations associated with the inspected piping are listed

in Tables III-la and b. A sample of approximately 125 feet of RCI

piping associated with the insert and withdraw of the CRD was

inspected by the NRC CAT. The inspection utilized walkdown record

copies of the RCI drawings listed in Table III-lb.

Thirteen piping samples representing approximately 200 feet of pipe

were selected to determine whether ASME requirements for pipe wall

thickness were met. The measured pipe wall thicknesses were com-

pared against the minimum wall thickness requirement specified by

ASME (12.5 percent below nominal thickness). Pipe wall thickness

was measured using ultrasonic methods, with personnel and equipment

provided by the licensee. Circumferential measurements were taken

at the ends and the center of the samples; other measurements along

the length of the pipe were also obtained for those samples in

which a potential for violating minimum wall thickness requirements

appeared likely. See Table III-2 for the inspection sample and

observations.

The following documents provided the acceptance criteria and back-

ground information:

BA Project Procedure (BAP) 2.14, " Fabrication / Installation of

Items, Systems, and Components," Rev. 10, Change F

BAP 3.2.9, " Piping 'As-Builts'," Rev. O, Change A

BAP 3.6.6, " Control of Welded Temporary Attachments," Rev. O

i

Sargent & Lundy Engineers (S&L) Project Instruction

PI-CP-028, " Field Installation Data Required to Permit

Confirmation of Piping Subsystem Analysis," Rev. 2

S&L Drawing M09-1001N, " Component Support Installation

Tolerances ... " Sheet 1, Rev. N and Sheet 12, Rev. N

S&L Specification K-2882, " Nuclear Safety Related and

Non-Nuclear Safety Related Specifications for Phase II

Piping, Miscellaneous Equipment, and Equipment Erection,"

through Amendment 11

S&L Nuclear Station Engineering Instructions (NSEI) ME-2,

" Interaction Analysis Program," Rev. 0

S&L Project Instruction PI-CP-034, " Interaction Analysis,"

Rev. 4

RCI Quality Assurance Instruction QAI-10-1, " Instruction

for Quality Control Inspection," Rev. 6

III-2

RCI QAI-8-4, " Instruction for As-Built Inspection / Verification

Walkdown," Rev. 5

RCI Document No. RCI-FPC-4, " Friction Clamp for 1" Withdraw

CRD Pipe," Rev. 6

RCI Document No. CLN-TOL-1, "Clinton Field Tolerances,"

through Rev. 3

RCI Document No. CLN-TOL-2, "Clinton Interface Tolerances,"

Rev. 1.

b. Inspection Findings

In general, the NRC CAT inspected piping conformed to installation

requirements and tolerances. However, the following observations

and discrepancies warrant additional attention.

(1) Baldwin Associates

Pipe spool 1-NB-751-4 depicted on Drawing NB-751 is routed

through and is in contact with the tube steel support for

electrical box lJB729. This configuration is in accordance

with the support design drawing, No. E27-1602-038-EIT and

the piping design drawing, No. M27-1602-03B-03BK except

that the current pipe to support steel contact is not

identified by either drawing. According to BAP 2.14 (Form

JV-734) and BA QC personnel, this contact is regarded as an

interference to be identified during the QC walkdown

inspection. Also, according to the BA Resident Engineer,

such contact must be identified during preparation of the

as-built drawings.

There was no evidence presented to the NRC CAT inspector

that this pipe to electrical support steel contact was

identified by either the QC inspection or the as-built

walkdown for evaluation by the piping design organization.

Since no similar instances of obvious interference with

piping were encountered by the NRC CAT, this finding is

considered an isolated case which requires appropriate

engineering disposition.

At pipe spool pieces 1-RI-758-3 and 1-RI-758-5A, a temporary

pipe support was not removed at the time of the NRC CAT

inspection. Procedure BAP 2.14 specifically noted that

removal of temporary supports need not be verified for QC

acceptance of the piping. BA QC personnel noted that

removal of each temporary support was controlled by the

discipline superintendent and the dismantling was performed

in accordance with BAP 3.6.6. As discussed with BA QC

however, neither that procedure nor any other presented

to the NRC CAT inspector provided assurance that all

-

temporary supports would be removed. The NRC CAT is

III-3

concerned that the QC inspection and acceptance of piping

prior to the removal of temporary supports may result in

undetected unacceptable conditions once the temporary

supports are removed, or that if the supports are not

removed, that unanalyzed constraints may be imposed on

the piping.

Various dimensional discrepancies were also noted among

the inspected piping. Two instances were observed where

the three inch tolerance for fitting to fitting dimensions,

as specified by the piping specification K-2882, had been

exceeded. As a result of the NRC CAT observations, the

licensee has prepared Nonconforming Material Reports

(NCMRs) addressing the discrepant dimensions.

In related inspection observations, three instances were

noted where dimensions between components, or components

and supports were found to differ from the as-built

dimensions by one inch or more. Procedure BAP 3.2.9

required that as-built dimensions be checked and recorded

to the closest inch.

The maximum out of tolerance conditions and maximum dif-

ference between as-built and measured dimensions were

two inches for both cases. The magnitude of these dis-

crepancies when considered with regard to the pipe sizes

involved, are not large. The NRC CAT did not identify a

large number of discrepancies of this nature, and thus,

does not consider the occurrences of the discrepant con-

ditions to be of significant concern.

(2) Reactor Controls, Inc.

With respect to RCI installed piping, no discrepant conditions

were found by the NRC CAT during the inspection. However, the

following observations are provided.

During inspection of the CR0 piping, the RCI document

which specified the design of friction clamps used for

axial restraint of withdraw piping was reviewed. Based

on this review and discussions with RCI engineering and

QC personnel, it was determined that no inspection

tolerance or minimum clearance was specified for the gap

between the clamp halves (ears). To function as designed,

the clamp must develop bearing between the clamp and pipe

by the controlled application of torque to the clamp bolts.

Contact between the clamp ears would result in reduced

clamp to pipe bearing, and therefore reduced capacity of

clamp restraint in the axial (pipe) direction. Although

not a QC inspection attribute, RCI stated that the need to

maintain a minimum gap was known and that in all cases,

such a gap was maintained by construction.

III-4

Random inspection of RCI supports by the NRC CAT included

an inspection for a minimum clearance between clamp ears on

approximately 60 axial clamps associated with the CRD

" withdraw" piping. No cases of contact between the clamp

ears were observed, but several clamp ears exhibited

clearances of only one to two mils indicating that this

attribute may warrant QC inspection.

In conjunction with the inspection of RCI installed

piping, their as-building and stress reconciliation effort

was also reviewed. As a result, it was observed that

portions of piping associated with the Hydraulic Control

Units (HCU) to which RCI piping interfaced, had not been

walked-down for as-built reconciliation of the RCI piping

since the HCUs had been installed by BA. Subsequent clari-

fication provided by RCI stated that RCI would incorporate

the piping associated with the HCUs into their walkdown.

Because the previously completed walkdowns did not include

the HCU piping, the need exists for the licensee to assure

that the additional piping is incorporated into the

as-building effort, and to recognize the potential for

deficiencies arising from construction interfaces.

(3) Piping Minimum Wall Verification

With regard to the 13 piping samples selected for minimum wall

thickness verification, none of the samples were found to be

below the specified minimum values. Only one sample was within

seven mils of the minimum wall thickness limit. The various

, sa.mples ranged in diameter from inch to 24 inches, and were

"

s'ecified to meet the ASME Boiler and Pressure Vessel Code,

p

Section III, Class 1, 2 and MC requirements (as appropriate).

(4) Interaction Analysis Program

.

In conjunction with the review of piping systems, the NRC CAT

reviewed the licensee's Interaction Analysis Program as it

related to Unresolved Safety Issue (USI) A-17, " Systems

Interaction in Nuclear Power Plants," discussed in the Clinton

Power Station (CPS) Safety Evaluation Report (NUREG-0853).

NSEI ME-2 and Project Instruction PI-CP-034 were the guidance

documents used for the interactions inspection program.

The scope of the program originally considered only the

seismic displacement of components (e.g., piping, supports,

cable trays). The allowable clearance criteria stated in the

above identified instructions included a built-in incremental

clearance for thermal displacement. Conditions which violated

the acceptable clearance criteria (under categories identified

in the procedures) were identified on Potential Interaction

Reports (PIRs). These PIRs were then evaluated for their

acceptability.

III-5

-- - - . -- - . - _ _ _ - -

During the initial implementation of the program approximately

4000 PIRs were generated of which only 2 required rework; the

remainder were dispositioned use-as-is. Based on these results

(Report No. EMD-050518, " Generic Evaluation of Interaction

-

Between Seismically Designed Components"), the licensee

'

developed exclusions for which certain categories of potential

interactions need not be considered or documented.

In future revisions to the Interaction Analysis Program, the

'

scope of the program will be expanded to address the thermal

effects of piping with respect to the overheating of electrical

l components due to proximate hot piping, interferences with

! installation of piping insulation, and interferences with

pipe expansion resulting in piping overstress or interferences

with components. (The Interaction Analysis Program as it

relates to electrical and instrumentation components, cables

and conduits is discussed in Section II, Electrical and Instru-

mentation Construction, of this report).

The NRC CAT considers the guidance procedures to be difficult

to understand due to their apparent piecemeal compilation and

fragmented incorporation of information. Further, although the

NRC CAT did not identify any deviations regarding the applica-

tion of the current procedures, observations of hardware

indicate that the program revision will need to ensure the

appropriate identification of thermal clearance violations

for the certain categories of interactions previously excluded.

c. Conclusions

,

Piping was found to generally conform to design requirements and

specifications. Site inspection and engineering personnel were

knowledgeable of requirements and responsibilities. No significant

problems regarding construction practice as it affected installed

piping hardware were observed by the NRC CAT. However, the lack of

control regarding the removal of temporary supports, and the

piecemeal formulation of the program for identification and evalua-

tion of potential interferences and interactions warrants additional l

attention.

2. Pipe Supports / Restraints

a. Inspection Scope

Twenty-six ASME Class 1, 2 and 3, and ten Class D pipe supports /

restraints which represented a variety of types, sizes, systems and

locations were selected for detailed inspection. These supports /

restraints were inspected for proper configuration, clearances,

member size, location, weld size, fasteners, and damage. All but

two supports had been QC inspected and accepted. Included in the

ASME supports sample were two supports / restraints reviewed under the

IP Independent Design Review which was performed by Bechtel Power

Corporation and six supports / restraints reviewed under the IP

III-6

_ . . _ _ _ _ _ _ . . _ _ , __..._ _ . _ __ _ _ __ __ - _ _ _ _ _

._ - - - - . _. . _ - _

Overinspection Program. See Table III-3 for a listing of the

inspection sample.

In addition, approximately 70 other supports / restraints were

observed at random in the field for obvious deficiencies such as

loose or missing fasteners, improper clearances or angularity,

improper locking devices, disassembled items, damage and improper

concrete expansion anchor spacing.

Installation traveler packages for the supports were examined and

compared with drawings and change notices to verify that the

required attributes were inspected and that inspections were per-

formed to the latest design documents. BA Field Verification and IP

Overinspection reports were also reviewed to assess the effective-

ness of the program in this area.

Acceptance criteria for these inspections were contained in the

following documents:

S&L Specification K-2882, " Phase II Piping, Miscellaneous

Equipment, and Equipment Erection," through Amendment 11

S&L Specification K-2884, " Component Supports," through

Amendment 8

S&L Specification K-2884-001, " Basic Engineers Load Capacity

Data Sheet Manual"

S&L Drawing No. M09-1001N, " Component Support Installation

Tolerances ... " Rev. N

S&L Drawing No. M09-1003N, " Component Support Installation

Tolerances ...." Rev. M

IP QAI-710.15, " Component Support Overinspection Checklist,"

Rev. 4

"IP Nuclear Power Construction QA Manual," Appendix A,

Rev. 10

BAP 3.2.5, " Piping Component Supports," Rev. 7, Change B

BA Quality Assurance Instruction BQAI-190-5, " Component

Support Field Verification," Rev. 4

Applicable design drawings and change documents.

! b. Inspection Findings

Approximately 94 percent of the nearly 11,300 component supports

(large bore and small bore safety related, and fire protection

j related) had been installed and QC accepted. Approximately 65

percent of the 545 Class D (quality inspectable) supports had been

installed and QC accepted.

III-7

I

-. --

- - _ - - . _ -. - - - -- - - - -

The inspection activities for pipe support / restraint installation

was controlled by BAP 3.2.5 which included a three phase inspection

program that required the preparation of travelers for each

inspectable support / restraint.

Phase I inspet. tion covers the installation of the support's

primary attachment to the building, and verification of its

location and orientation to the building.

Phase II inspection covers the inspection and verification of

the installed support per the design drawings.

Phase III inspection includes restroking of snubbers, load

stamping of constant spring supports, and setting of variable

spring supports.

In general, pipe supports / restraints were in conformance with the

specified requirements. The inspection checklists for attributes

used by QC personnel were found to be comprehensive and detailed.

Several discrepancies were identified and are discussed below.

These discrepancies included incorrect modelling and analysis of

certain Class I supports, pipe shear lugs not in contact with the

riser clamp as required by the design drawing, thread length

mismatch between a snubber body and its extension piece, incorrect

substitution of material, and scaffold in contact with or supported

by pipe support / restraint components. See Table III-4 for a listing

of inspection observations. Welding deficiencies are discussed in

Section IV, Welding and Nondestructive Examination, of this report.

The lower pipe shear lugs on support M-ISX010285 were not in

contact with the riser clamp as required by the design drawing.

Gaps between the clamp and lugs ranged from 1/32 inch to 3/16

inch. In addition, one shear lug was observed to be 1-1/4

inches wide when the specified width was 2-1/2 inches. Engi-

neering documentation authorizing the variation of shear lug

sizes were not provided to the NRC CAT. NCMR 2-0327 was

generated for this condition. While this support was inspected

during the IP Independent Design Review performed by Bechtel

Power Corporation, these deficiencies were not identified

during that review.

"

Two Pacific Scientific Arrestor PSA 35 snubbers, for supports

M-1MS31002S and M-1RH080925, were identified by the NRC CAT

inspector as exhibiting a 1/4 inch thread length mismatch

between the extension piece and the snubber body. The exten-

sion piece was provided by Basic Engineering (BE); the snubber

was provided by Pacific Scientific Company. This mismatch was

a result of the male threads of the extension piece being

longer than the female threads of the snubber. Upon

disassembly, it was discovered that the extension piece was

fully seated against the internal dust cover. The NRC CAT is

concerned that the extension piece could be tighten beyond the

1-1/4 inch depth of the female threads of the snubber body and

push the dust cover into the inertia mass, thus causing the

III-8

malfunction of the snubber. We are also concerned with the

potential generic implications of this condition on other

supports which use Basic Engineering supplied extension pieces.

The licensee is currently evaluating the extent and signifi-

cance of this condition.

The licensee did not have a construction or QC procedure that

included inspection attributes which would prevent the over-

tightening of these components. However, as a result of these

observations, the licens:e is in the process of incorporating

the necessary changes into their inspection program to ensure

that such conditions are identified.

Two ASME Class 1 snubber supports were found to have been

modelled and analyzed in a manner contrary to Final Safety

Analysis Report (FSAR) commitments. According to S&L, supports

M-1NB01003S and M-1NB010025 of the Nuclear Boiler System were

modelled as rigid supports. The FSAR states that the Nuclear

Steam Supply System (of which the Nuclear Boiler System is

included) shall be modelled as flexible supports. The NRC

CAT is concerned that this deviation could affect the adequacy

of the design of the supports, and considers that this devia-

tion in design warrants additional attention by the licensee.

The NRC CAT observed that the rear bracket (Part No. BE-410-5)

on support M-1SX01028S did not have an "N" suffix as part of

the part number. The "N" suffix was observed on all of the

ASME support components in our sample. The NRC CAT was con-

cerned about the material traceability aspects of the component

and the significance of the "N" suffix. According to the

licensee, traceability is determined by a Receiving Inspection

Report (RIR) number which is etched on each part or assembly.

From the RIR, the part or assembly can be traced to the

purchase order, packing slip, and Certificate of Compliance (C

of C). Part number BE-410-5 was obtained from the BE parts

catalog which did not list the "N" suffix. BE-410-5 and

BE-410N-5 were identical parts, thus no specific distinctions

were made between the two. Safety-related supports / restraints

are required to have C of Cs and RIRs. These documents are

verified by BE QC, BA vendor surveillance and receiving QC

personnel. The licensee indicated that these supports will be

reinspected for material compliance under Corrective Action

Request 222 reinspection and verification program. Based on

this program, adequate traceability appears to be provided.

Evidence of a lack of attention to detail by QC personnel

during their inspections of Class D pipe supports / restraints

was observed by the NRC CAT during the inspection of Class D

seismic supports, even though the inspection checklist for

attributes was thorough in content. The NRC CAT identified

discrepancies in four of the ten supports selected for detailed

review, such as the unauthorized substitution of shaped steel

with one of a similar shape but smaller size, binding contact

between a pipe clamp and eye nut, and various weld quality

III-9

_ . ~ . . --- - - - _ _ - _ _ - __ - - _ . _

.- -- . -_

,

irregularities. The NRC CAT reviewed the traveler packages for

these supports and in general, found them to be accurate and .

acceptable. However, the above discrepancies were not iden- '

tified in the traveler packages associated with the supports.

! '

Numerous instances of wooden scaffold in contact with or supported

by permanent support components were observed. In one case,

scaffold was supported by a spring can and its support rod. In

each case, there was no apparent damage to the support compo-

nents when the scaffolding was removed.

The licensee did not have a formalized program which controlled

the erection of temporary scaffold on permanent supports as was

l evidenced by the numerous observations. The NRC CAT is con-

l cerned about the lack of control on the erection of scaffold

and its effects on the hardware, since physical damage is not

,

restricted to that which is readily visible. Further, damage

!

to previously QC accepted supports could result in undetected

,

unacceptable conditions. As a result of the NRC CAT observa-

!

tion, the licensee has issued a project memorandum addressing

the erection of scaffolding.Section II, Electrical and

Instrumentation Construction, of this report also discusses the

support of temporary scaffolding.

l

During the review of piping (Section III.B.1, above), three box type

l

restraints were found not to exhibit the minimum gap requirement

l between the pipe and the support frame steel. The S&L M09 series

!

'

drawings specify minimum pipe to support steel clearances based on

system temperatures. For the Shutdown Service Water piping of

Drawing SX-27, a minimum clearance of 0.015 inches is required.

Furthermore, for any system regardless of temperature, an " air i

gap" must be maintained. For the three supports listed in Table

III-la against Drawing SX-27, the required clearance was found not

to exist. For two of these (supports ISX11014R and ISX11016R),

support frame steel was found to be in contact with the top and

bottom of the pipe such that the requirement to maintain an air

gap was also violated. As a result of the NRC CAT observations,

BA has reviewed the supports in question and other similar Shut-

down Service Water supports. Two Nonconformance Reports (NCRs)

addressing a total of six cases, including the three addressed

here, of less than required pipe to steel clearances were written

following this review. The NRC CAT considers these discrepancies

to be isolated occurrences.

The installation and inspection travelers of six ASME and ten Class

D supports / restraints were reviewed, and were found to exhibit

proper chronological inspection verification and acceptance of

handling, installation processes and sequences. In addition,

six BA Field Verification packages and IP Overinspection reports

i were reviewed and were found to accurately reflect the condition of

l the hardware.  ;

III-10

.- _ . - - - - _ - - - -_ _ . _ _ _ _ - - - . _ - - _ - _ . - - - _ - -

!

!

c. Conclusions

ASME Class 1, 2, and 3 pipe supports / restraints were found to be in

general conformance to design requirements. Site engineering and

inspection personnel were knowledgeable of procedures, requirements

! and responsibilities. Procedures and inspection checklists were

!

'

thorough and detailed. However, the NRC CAT is concerned with the

potential damage and generic implications regarding the thread

l

1ength mismatch between snubber assembly components, and concludes

i

that additional attention is warranted. We are also concerned that

,

certain Class 1 supports may not be properly modelled and analyzed.

l

Class D pipe supports / restraints were generally found to be in

conformance with design requirements. However, additional attention

to detail by QC personnel during their inspections is warranted.

Observations regarding scaffolding in contact with permanent

! supports indicates a deficiency in the control of the erection of

l

scaffold.

l

3. Concrete Expansion Anchors

!

a. Inspection Scope

Seventy-one concrete expansion anchors on 12 pipe supports /

restraints and 61 anchors on 8 HVAC restraints were inspected for

proper diameter, length stamp, embedment, edge distance, damage,

washers and residual torque (an indication of anchor preload). In

addition, the length of the expansion anchors were verified by

ultrasonic testing. The anchors inspected were selected at random

on a variety of systems and ranged in diameter from one-half to one

inch. Anchors were torqued to the BA or Zack Company (Zack)

specified post installation test torque. Table III-5 provides a

listing of the anchors inspected.

l

Acceptance criteria for the field inspections were contained in the

i

following documents:

BAP 2.16 " Concrete Expansion Anchors Work," (sic) Rev. 12-5

Zack Procedure FQCP-12. " Inspection of Concrete Expansion 1

Anchors," Rev. 5-3

b. Inspection Findings

Pipe support / restraint expansion anchors were installed by BA, and

HVAC restraint anchors were installed by the HVAC subcontractor,

Zack Company. Expansion anchor installations were inspected by the

respective subcontractor QC personnel. The BA and Zack procedures

were nearly identical in substance. However, two fundamental dif- l

ferences existed with respect to inspections. BA QC inspected and  !

witnessed 100 percent of the anchor bolts installed. Zack QC

inspected a minimum of one concrete expansion anchor of each

diameter on each anchor plate assembly, or a minimum of one concrete

l

III-11

l

expansion anchor in every ten of each diameter, whichever was

greater.

For the NRC CAT inspection the anchor nuts were torqued to the

specified retightening (BA) or testing (Zack) torque. Fourteen

anchors for pipe supports out of seventy-one tested exhibited

insignificant nut rotation at less than the retightening torque

with a maximum of 1/8 turn (which was within the BAP 2.16 acceptance

criteria). Seven anchors for HVAC supports out of sixty-one tested

exhibited insignificant nut rotation at less than the testing torque

with a maximum of 1/16 turn. Since Zack procedures did not specify

any allowable nut rotation, job plans to retorque each of the

affected anchor nuts were issued for the associated anchor plate

assemblies.

All other features inspected by the NRC CAT for both BA and Zack

installed anchors were in conformance with requirements.

c. Conclusions

Concrete expansion anchors inspected by the NRC CAT were installed

in accordance with design and procedural requirements. The results

of the torque tests are typical of normal wedge type expansion

anchor installations and do not indicate installation deficiencies.

4. Heating, Ventilating and Air Conditioning

a. Inspection Scope

Six HVAC seismic restraints were selected at random and inspected

for location, configuration, member size, weld size and connection

details. Approximately 150 feet of duct adjacent to the restraints

and others selected at random were examined for proper attachment to

anchors, companion angle size and joint makeup. Thirteen fire

dampers were inspected for proper installation, operability and

condition. IP Overinspection documents were also reviewed to assess

the effectiveness of the program in this area. HVAC concrete

expansion anchor installation was inspected and is discussed in

Section III.B.3, above. See Table III-6 for a listing of inspected

items.

The following documents provided the acceptance criteria for the

inspection of HVAC hardware installations:

Zack Procedure FQCP-5, " Fabrication and Installation

Inspection," Rev. 8-1

"

Zack Procedure FQCP-10.7, " System Walkdown for Turnover,"

Rev. 2-1

"

IP QAI-710.20 "HVAC Overinspection Checklist," Rev. 4

S&L Specification K-2910, " General HVAC Specification"

!!I-12

.

S&L PI-CP-024, "Non-Category I Verification Program," Rev. 2

S&L Design Criteria DC-ME-17-CP, " Design Criteria for

Interaction Analysis in Category I Buildings," Rev. 1

Applicable design drawings, duct standards and change

documents.

b. Inspection Findings

HVAC systems were designed by S&L and detailed on the Zack layout

drawings. Hardware for fabrication and installation were detai ed

l

on duct fabrication details and hanger details.

The installation and inspection of HVAC seismic supports / restraints

are controlled through the use of " job plans." A job plan is

essentially a traveler which details the activities to be performeo

and the required inspection activities. Installation and inspection

criteria are delineated on the job plans. The inspections are

documented on hanger inspection checklists, which then become part

of the job plan package.

In general, the inspected HVAC seismic restraints conformed to

design documents and specification requirements. One minor brace

angle discrepancy (four degrees out of tolerance) and one minor

dimensional discrepancy were noted. The duct assemblies exhibited

proper weld stitches to supports and companion angles, placement of

reinforcements, proper fasteners, and in general, conformed to

specified requirements. However, two documentation related

anomalies were noted for support R-7037.

NCR 911376 recorded stiffener plates missing from its vertical

channel members, and was dispositioned use-as-is. The NRC CAT

requested the calculations for the support which formed the basis

for the disposition, and upon review noticed that the configuration

used to disposition the NCR differed significantly from that

depicted on the current design drawing. Subsequent calculations

utilizing as-built information reconfirmed that the use-as-is

disposition was still acceptable. This same support also had a

Field Engineering Change Notice (FECN) posted against it (FECN

7718) when in fact a nonconformance report should have been

generated. The FECN changed a weld symbol to match a field

configuration which had been erroneously QC accepted. Support

R-7037 had undergone IP Overinspection, and the inspection results

were documented on Inspection Report No. H2030 prior to the

inspection by the NRC CAT. These two anomolies are r.ot significant

in the engineering context and are considered to be isolated

occurrences.

With respect to the licensee's inspection program of Class D

(nonsafety-related) seismic supports and duct, Zack Procedure

FQCP-5 required that the Class D seismic assemblies receive the

same level of inspection as the safety-related seismic Category I

assemblies. The job plan packages of the Class D seismic supports

III-13

-

which were reviewed by the NRC CAT contained the appropriate

inspection reports. The concerns of Position C.2 of Regulatory

Guide 1.29, " Seismic Design Classification," have been adequately

considered and implemented by the licensee through the documents

PI-CP-024 and DC-ME-17-CP.

With regard to the 13 fire dampers which were subjected to a release

test, all of the dampers released as designed and provided the

required isolation. It should be noted however, that Zack and S&L

are currently evaluating the impact of defects in certain fire

dampers described in a 10 CFR 21 notification by the manufacturer of

the fire dampers (Ruskin Manufacturing Company). This notification,

in part, stated that certain models of fire dampers were found not

to close properly under air flow conditions, and recommended that

the affected dampers be tested under the appropriate flow condi-

tions.

S&L intends to evaluate the functionality of the dampers through

the use of test models. Test criteria have been developed; modelled

configurations. included horizontal and vertical duct runs, the use

of balancing dampers, and multiple damper configurations. The

ducting ranged in size from 24x24 inches to 60x50 inches. The

tests were conducted at the vendor's facilities with the use of an

S&L approved test procedure (XHV-85-41), which was originally

developed by Ruskin Manufacturing Company (415850Y-NIBD-23).

At the time of the NRC CAT inspection, S&L was reviewing the results

of the tests.

c. Conclusions

The inspected HVAC hardware generally conforms to design require-

ments and specifications, and the 10 CFR 21 notification regarding

fire dampers is receiving adequate licensee attention and followup.

5. Mechanical Equipment

a. Inspection Scope

Twenty-four pieces of equipment for seven systems were inspected

for proper configuration, location, condition and bolt size.

Installation documentation for these components were reviewed for

content, clarity, consistency and thoroughness. IP Overinspection

and BA Field Verification documents were also reviewed in order to

assess the effectiveness of these programs in this area. Equipment

examined included the Emergency Diesel Generators, Diesel Generator

Day Tanks, and the Standby Liquid Control Pumps. The NRC CAT

inspector examined documentation for components which were considered

to be completely installed, and those which were still in process.

Equipment which had received final alignment or whose foundation

anchor bolts had been tensioned or torqued were considered to have

been completely installed. Table III-7 provides a listing of

irsper.ted items.

III-14

-_ .. -__

The following documents provided the basic acceptance criteria for

the inspections:

BAP-2.10, " Equipment Installation," Rev. 10-D

BQAI-190-3, " Mechanical Equipment Field Verification," Rev. 3 i

IP QAI-710.3, " Mechanical Equipment Overinspection Checklist,"

Rev. 1

Applicable equipment details and foundations drawings.

b. Inspection Findings

Installation inspection reports generally exhibited the desired

sequencing of installation activities and inspections. However,

BAP 2.10 which governed the preparation of equipment installation

travelers, did not require work to be performed in the sequence in

which they appear in the traveler unless specifically noted. As

such, any designated QC holdpoint did not disallow the initiation

or completion of work activities (which may fall sequentially later

in the traveler) prior to the sign-off of the QC holdpoint. Rather,

only a QC verification need be performed for that particular

operation or activity at its completion.

Of the 24 components for which installation documentation was

reviewed, all had been inspected and found acceptable by QC for

those attributes examined by the NRC CAT inspector. Of these

components, the NRC CAT identified only one discrepancy between

installation requirements and as-installed conditions. Diesel Fuel

Oil Storage Tank 0001TC was found to be missing washers at the

foundation anchor attachment. Further, this was the only discre-

pancy identified between the sampled as-installed hardware and

the associated BA Field Verification or IP Overinspection reports.

It was noted however, that five components manufactured by Goulds

Pumps Inc. (HPCS Water Leg Pump, Residual Heat Removal Water Leg

Pump, RCIC Water Leg Pump and the Control Room Chilled Water Pumps)

appeared to nave been improperly fastened to the foundation anchor

bolts in that the foundation anchor nuts were tightened to a " snug

l tight plus \ turn" condition rather than the torque value specified

by the vendor drawings. For each water leg pump, this potential

discrepancy was originally documented by licensee QC personnel

on NCR 6639. This NCR was dispositioned use-as-is by the invocation

/

'

of Field Change Request (FCR) 3477 which specified the snug tight

condition "unless otherwise specified." Due to the ambiguous and

imprecise language in both FCR 3477 and NCR 6639, the NCR appeared

to have been improperly dispositioned. A review of NCR G571, which

dispositioned a similar discrepancy (for the Spent Fuel Cooling

Pumps) in the same manner, revealed that the licensee's position was

that S&L's requirements prevailed over vendor recommendations as the

component installations were governed by S&L drawings and documents.

The NRC CAT thus considers NCR 6639 to have been appropriately dis-

III-15

- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

positioned and the equipment to have been properly installed. The

licensee has agreed to provide clarification regarding the tighten-

ing of foundation anchor bolts.

The NRC CAT inspector also reviewed the seismic analyses for the

HPCS, RCIC and Residual Heat Removal Water Leg Pumps, RCIC Pump,

Turbine and Gland Seal Compressor, and the Diesel Generator Day

Tanks for consistency between the foundation anchor bolt material

type assumed in the analyses, and the as-installed material. No

discrepancies were identified.

During the review of equipment installation travelers, the traveler

package covering the modification of the lube oil system for the

HPCS diesel generator was examined. Documentation showed a history

of queries by licensee personnel regarding the appropriateness of

the safety classification of the materials to be used during the

modification; nonsafety-related material and components were

purchased for the modification. These questions arose as a result

of a disparity between a vendor generated Field Deviation

Disposition Request (FDDR LH1-482) which categorized the lube

oil system to have been safety-related, and a General Electric

Quickletter dated March 4, 1985 which stated that the material to

be used in the modification need not be safety-related.

Ultimately, the use of nonsafety-related materials was approved

by the supplier of the HPCS diesel generator in FCR 37073. The

NRC CAT inspector reviewed documents germaine to this concern and

concludes that the specified use of nonsafety related materials

and components as described in FCR 37073 is consistent with

licensee commitments as evaluated in Section 9.5.7 of the

'

CPS Safety Evaluation Report (NUREG-0853).

c. Conclusions

Mechanical equipment installations generally conformed to design

and installation requirements. Equipment travelers adequately

documented work activities.

I

i

III-16

_ _ _ _ _ _ _

,_- _ _ _ _ _____ _ _ - _ _ _ _ _ - _

TABLE III-la

PIPING INSPECTION SAMPLE - LARGE BORE

Baldwin Associates Piping  !

No. of

Support

Drawing Pipe Diameter Locations

Number Class (inches) Inspected Notes Observations

Design As-Built

l

l

HP-2 2 20, 16 15 15 1 10'0" design dwg.

Rev. 10L dimension measures

9'7"

LP-1 1 10 5 5 2

Rev. 8G

RI-7 2 6 12 12

Rev. 10M

RI-14 1 4 - -

3

Rev. 8J

I RT-47 3 4, 3 14 14

Rev. SK

l SX-25 3 8 18 18 4 6'10" as-built

l Rev. 8J dimension from

Support 1SX13003X

to upstream elbovi

measures 6'8"

!

! SX-27 3 8 15 15 4'0" as-built

Rev. 7P dimension from

Support 1SX11016R

to Support ISX11015X

l measures 4'1"

Pipe to support steel

minimum gap does not

exist at Supports

ISX11012R, 1SX11014R

and 1SX110016R

III-17

,. ..

..

. _ _ _

- . - .. - . - . . -_ - __ - .

I

, TABLE III-lb

PIPING INSPECTION SAMPLE - SMALL BORE

Baldwin Associates Piping

i

No. of

Support

, Drawing Pipe Diameter Locations

< Number Class (inches) Inspected Notes Observations

Design As-Built

.

! HP-753 2 2, 1 10 5 5 2'6" as-built

Rev. 15 dimension measures

2'7"

'

15-754 1, 2 1,2 23 0 6 3'9" design dwg.

Rev. 12 dimension measures

3'5 "

1

'

NB-751 1, 3 2 - -

3 Interference between

4

"

Rev. 6 pipe and support for

electric box IJB729

!

not documented for

piping design

-

incorporation

RI-758 2 2 0 0 7 Temporary pipe

Rev. 17 support not

dismantled at two

locations

Reactor Controls, Inc. Piping

.

'

No. of

Support

Drawing Pipe Diameter Locations

Number Class (inches) Inspected Notes Observations

Design As-Built

SA-489 2 1 -

4 8

Rev. 3

j SA-490 2 1 -

5 8

i

Rev. 5

l SA-501 2 1k -

4 8

Rev. 3

i

III-18

{

. _ _ - . - . , _ - - . . _ _ . . _ , _ _

,

_ . . -

TABLES III-la and b (Continued)

PIPING INSPECTION SAMPLE

NOTES

1. ' Piping dimensions inside containment wall not inspected.

2. Piping dimensions outside containment wall not inspected.

3. Selected piping components inspected by NR'. CAT - Piping layout not

inspected.

4. Piping between floor at elevation 737'0" and support M-1SX13004R not

inspected by NRC CAT.

5. As-built walkdown is not required for all piping shown.

6. As-built data not inspected.

7. As-built walkdown not required for piping shown.

8. Walkdown design data recorded (March 29, 1985) on listed mathematical

model revision inspected by NRC CAT.

III-19

I

. __ _ _ _

TABLE III-2

PIPE WALL THICKNESS SAMPLE AND OBSERVATIONS

i

Specified Nominal / Minimum Wall

Manufacturer2 / Pipe Size / ASME Minimum Wall Thickness Measured

(Heat No.) Schedule Class Thickness (Inches) (Inches)

B&W (59768) 2 /xxs 2 0.552/0.483 0.501

C-W (14-390) 12/40s 1 0.375/0.328 0.434

!

C-W (13-419) 12/80s 1 0.688/0.602 0.715

!

J&L (631675) 12/40 2 0.406/0.355 0.377

J&L (364557) 4/80 2 0.337/0.295 0.316

S (466139) 1/80s 2 0.179/0.157 0.170

i S (465835) \/40s 2 0.109/0.095 0.106

S (462337) 6/40s 2 0.280/0.245 0.267

PSC (60834) 8/80 2 0.500/0.438 0.473

TCS (93563) 3/4/40s 2 0.113/0.099 0.109

1

USS (L-24722) 6/40 2 0.280/0.245 0.279

SF (1-RI-14-5) 4/120 1 0.438/0.383 0.390

(1E51-D306) 24/ MC 1.000/0.875 1.096

NOTES:

IB&W - Babcock & Wilcox Tubular Products Division

C-W - Curtiss-Wright Corporation

J&L - Jones & Laughlin Steel Corporation

S - Sandvik, Inc.

SF - Southwest Fabricating & Welding Company, Inc.

PSC - Phoenix Steel Corporation

TCS - Teledyne Columbia - Summerill

USS - U.S. Steel Corporation

,

i

e

1

III-20

- .. _ - - . - .

-_ _ _ _ _ _ - _

TABLE III-3

PIPE SUPPORT / RESTRAINT INSPECTION SAMPLE

Pipe 2 Size

S/R Number 1 Type Class (Inches) Location 3 Comments 4

M-1MS32002S Rev. C Snubber C 12 Cont.

M-1MS31002S Rev. C Snubber C 12 Cont. BA

M-1MS33009S Rev. O Snubber C 12 Cont. BA

M-1MS31009C Rev. F Spring C 12 Cont.

M-1NB01003S Rev. A Snubber A 2 Cont.

M-1NB01002S Rev. 8 Snubber A 2 Cont.

M-1NB01008S Rev. C Snubber A 2 Cont.

M-1NB01027X Rev. A Box A 2 Cont.

H-1RH-780-4 Rev. 0 U-bolt B 3/4 Aux. IP

M-1RH47013G Rev. A Box B 1-1/2 Aux. IP

M-1RH71016G Rev. C Box C 1-1/2 Cont. IP

M-1RH34010X Rev. A Strut A 18 Cont. IP

M-1RH140095 Rev. D Snubber B 8 Aux.

M-1RH14006S Rev. C Snubber B 8 Aux. TVL

M-1RI14025G Rev. B Box B 1 Aux.

M-1RI14018G Rev. D Box B 2 Aux. BA, TVL

M-1RI14002G Rev. D Box B 2 Aux. BA, TVL

M-1RI14015G Rev. E Box B 2 Aux. BA, TVL

M-1RI14001G Rev. G Box B 2 Aux. BA, TVL

M-1SX42021R Rev. F Strut C 2-1/2 Aux. IP, TVL

M-1SX42019R Rev. C Strut C 1-1/2 Aux. IP

M-1SX01048X Rev. F Strut C 30 Screen

M-1SX01017R Rev. H Riser Clamp C 30 Screen

M-ISX01050X Rev. E Strut C 30 Screen

M-1SX01028R Rev. J Riser Clamp C 30 Screen

M-1SX21002G Rev. B Box C 2 Aux.

M-1CC06042G Rev. B Box D 14 Fuel TVL*

M-1CC06016X Rev. B Strut D 14 Fuel TVL*

M-1CC12007C Rev. D Spring D 3 Cont. TVL

M-1CC07014R Rev. D Rod D 14 Fuel TVL

M-1CC06035X Rev. A Strut D 14 Fuel TVL

M-1CC07050X Rev. C Strut D 14 Fuel TVL

M-1CY23002G Rev. C Box D 3 Aux. TVL

M-1FWO30145 Rev. C Snubber D 20 Turbine TVL

M-1HP03024R Rev. C Rod D 10 Fuel TVL

M-1VQ03003R Rev. E Strut D 10 Cont. TVL

III-21

1

,

TABLE III-3 (Continued)

PIPE SUPPORT / RESTRAINT INSPECTION SAMPLE

NOTES:

1CC - Component Cooling Water

CY - Cycled Condensate

FW - Feedwater

HP - High Pressure Core Spray

MS - Main Steam

NB - Nuclear Boiler

RH - Residual Heat Removal

RI - Reactor Core Insolation Cooling

SX - Shutdown Service Water

VQ - Drywell Purge

2A - ASME Class 1

8 - ASME Class 2

C - Asme Class 3

3 Cont. - Containment Building

Aux. - Auxiliary Building

Screen - Screen House

Fuel - Fuel Building

Turbine - Turbine Building

4BA - BA Field Verification Records Reviewed by NRC CAT

IP - IP Overinspection Records Reviewed by NRC CAT

TVL - Traveler Package Reviewed by NRC CAT

- Not QC Inspected at Time of NRC CAT Inspection

4

1

III-22

. _ _ _ -

TABLE III-4

PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS

From Support Sample

Support / Restraint Observations

M-1MS310025 Rev. C Mismatch of thread engagement of BE extension

piece and PSA 35 snubber. Extension piece

male threads measured 1-1/2 inches and snubber

body threads were 1-1/4 inches. Extension

piece was in contact with internal dust cover.

1/4 inch of threading exposed on extension

piece when assembled with snubber body.

M-1MS31009C Rev. F Scaffold contacting against riser clamp.

M-1MS330095 Rev. D Exessive debris in W-beam i)1ocks drainage

of water.

M-1NB01003S Rev. A Incorrect lock wiring. Not modelled per

FSAR commitment.

M-1NB01002S Rev. B Not modelled per FSAR commitment.

M-1NB01008S Rev. C Weld of item 2 to item 3 not welded as

shown on design drawing.

M-1NB01027X Rev. A Elevation of 2-1/2 x 2-1/2-inch angle is

2-7/8 inches above drawing location.

Thickness of 2-1/2 x 2-1/2-inch angle is not

listed as 3/8 inch on FCR 33320.

M-1RH14006S Rev. C Zero inch gap on top between telescoping

cylinder and support cylinder of snubber. 1/8

inch gap on bottom between telescoping cylinder

and support cylinder of snubber.

M-1RH140095 Rev. O Cotter pin not spread. Loose locknut on

extension piece. Zero inch gap on top

between telescoping cylinder and support

cylinder of snubber. 1/8 inch gap on bottom

between telescoping cylinder and support

cylinder of snubber.

l

!

III-23

- - - _ _ _ _ _ _ _ _

TABLE III-4 (Continued)

PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS

From Support Sample

n:

Support / Restraint Observations

M-1RI14002G Rev. D Zero inch clearance between top horizontal

member and pipe. Pipe not supported by bottom

horizontal member; 0.046 inch clearance between

bottom member and pipe.

M-1SX01048X Rev. F Sheet 1, item 6 calls for rear bracket

(Ref. Dwg. No. M-1SX01017R) BE-410-5, no "N" suffix. Extra rear bracket

of a BE strut was incorrectly listed on NCR

26414.

M-1SX01017R Rev. H Support was not listed on NCR 26414 with

reference tc the extra rear bracket shown on

Drawing M-1SX01048X.

M-1SX01028R Rev. J Bottom lugs were not in contact with riser

clamp. Gaps measured 1/32 inch through 3/16

inch. Bottom lug width of 1-1/4 inch did not

meet the design requirements of 2-1/2 inches.

M-1CY23002G Rev. C 1/8 inch grind depth at weld tie-in on east

vert member.

M-1CC07014R Rev. D Pipe clamp ears binding against eye nut. Cotter

pin not spread.

M-1CC07050X Rev. C Undercut on main structural member (Item 6)

greater than 1/16 inch. Members not welded

as shown on design drawing (Item 6 to Item 7).

Hole in weld of west rear bracket.

M-1CC06042G Rev. 8 Debris between pipe and south vertical support

steel. Support was not QC inspected.

M-1CC12007C Rev. O Structural steel shape M4 x 13 was substituted

for a W4 x 13 shape. 3/16" x 3" x 6-1/4"

plate was substituted for two 3" x 3" washer

plates without proper documentation.

III-24

-. .

,

TABLE III-4 (Continued)

PIPE SUPPORT / RESTRAINT INSPECTION OBSERVATIONS

From Random Sample

i

Support / Restraint Observations

M-1FC02003R Scaffold interfering with support.

M-1FP46005 Sway strut in contact with conduit C6513.

M-1HP03024R Scaffold resting on pipe support.

M-1MS23006C Scaffold platform resting on riser clamp.

M-1RH14010S Scaffold in contact with snubber.

M-1RH13036S Cotter pin not spread on rear bracket.

M-1RH09049X Loose locknut on pipe clamp.

M-1RH16031X Nail substituted for cotter pin in rear

bracket of sway strut.

M-1RH07053X Auxiliary steel for conduit support E-26-1001-

02B-CP-13 is in contact with rear bracket pin

on sway strut.

M-1RH08092S Mismatch of thread engagement of BE extension

piece and PSA 35 snubber. Extension piece

"

male threads measures 1-1/2 inches and

snubber body threads were 1-1/4 inches.

Extension piece was in contact with internal

dust cover. 1/4 inch of threads exposed on

extension piece when assembled with snubber.

M-1SX18022V Scaffold in contact with spring can.

M-1SX17028X Rear bracket binding eye bolt of sway strut.

Pipe clamp was 2 inches lower than design

elevation.

WS00520G U-bolt damaged (nonsafety).

M-1VC02003R Scaffold interfering with support.

Valve No. 2SX017A Scaffold interfering with valve.

III-25

- - ._

a

TABLE III-5

CONCRETE EXPANSION ANCHOR SAMP3.E AND OBSERVATIONS

Number of Bolts

Turned Prior to Number of Turns

Achieving to Achieve

Pipe Support Number of Retightening or Retightening or

Drawing (BA) Bolts - Diameter Testing Torque Testing Torque

3

M-IVC 04017X 15-3/4 6 1/12, 1/12, 1/12

1/8, 1/12, 1/32

M-IVC 04001V 4-1/2 0 -

M-1CC06042G 6-1 1 1/16

M-1RI27003G 3-3/4 1 1/8

M-1RIO3017R 8-3/4 0 -

M-ISX75015G 4-1 1 1/16

M-1SX78008R 8-3/4 2 1/32, 1/16

M-1SX77020X 4-3/4 1 1/32

M-1SX21002G 4-1 0 -

M-1SX23008V 4-3/4 1 1/32

M-1RI14001G 2-3/4, 1 1/32

1-1

M-1RI14019R 8-1 0 -

Number of Bolts

Turned Prior to Nunber of Turns

Achieving to Achieve

HVAC Support Number of Retightening or Retightening or

Drawing (Zack) Bolts - Diameter Testing Torque Testing Torque

C-3163 6-3/4 3 1/16, 1/64, 1/64

C-3162 6-3/4 0 -

D-4308 15-3/4 1 1/64

C-3211 8-3/4* 1 1/16

C-3151 8-3/4 1 1/64

D-0121 6-3/4 0 -

C-1109-3 4-1 0 -

C-4103 8-3/4 1 1/64

• 0ne anchor bolt is recessed into the nut and one thread of the nut is visible.

NCR No. 912167 issued.

.

III-26

. . . --- - -

_ .

-

_. _

.

TABLE III-6

HVAC INSPECTION SAMPLE AND OBSERVATIONS

Supports / Restraints

Support I.D. Location Observations

R5008 Containment Acceptable.

R7022 Containment "E" and "X" dimensions were

15/16 inches longer than

that shown on dwg.

R7033 Containment Brace angle exceeded dwg.

requirements by 4 degrees.

NCR 911376 was dispositioned

using wrong configuration.

C3163 Control Building Acceptable.

C6335 Control Building Acceptable.

D4324 Diesel Generator Acceptable.

Building

Fire Dampers

Damper I.D. Quantity HVAC System

OVC42YF 4 Control Building

OVC103Y 1 Control Building

OVC104Y 1 Control Building

OVL68Y 1 Laboratory HVAC

OVL70Y 1 Laboratory HVAC

1VX08YC 1 Switchgear Heat Removal

IVX82Y 2 Switchgear Heat Removal

IVX86Y 2 Switchgear Heat Removal

III-27

- . - . -. - - _

TABLE III-7 ,

MECHANICAL EQUIPMENT SAMPLE

Diesel Generator Air Start Skid 1DG06SA

Diesel Generator Day Tanks 1DG01TA,B,C

Diesel Generators 1DG01KA,B

Diesel Generator Oil Transfer Pumps 10001PA,C

Diesel Generator Fuel Oil Storage Tanks 10001TA,C

HPCS Diesel Engine 1E11-S001

HPCS Water Leg Pump 1E22-C003

RHR Water Leg Pump 1E12-C003

RCIC Pump and Turbines 1E51-C001, C002

RCIC Gland Seal Compressor IE51-C002

RCIC Water Leg Pump 1E51-C003

Standby Liquid Control Pumps 1C41-C001A,B

Control Room Chilled Water Pumps OVC08PA,8

Switchgear Heat Removal Coolers IVX01SA,B

.

RHR Room Coolers IVYO65,07S

4

f

.,

I

III-28

.. . _ . . ._ _ -. _ _ _ - - - _ . - __._ -. - -

IV. WELDING AND NOND5SNUCTiVs EXAMINATION

A. Objective

The objective of the appraisal of welding and nondestructive examination

(NDE) was to determine if Quality Control accepted work related to

welding and NDE activities was controlled and performed in accordance

with design requirements, Safety Analysis Report commitments, and

applicable codes and specifications. An additional objective was to

determine if personnel involved in welding and NDE activities were

trained and qualified in accordance with established performance

standards and applicable code requirements.

B. Discussion

To accomplish the above objectives, welds and welding details for

piping, pipe supports / restraints, field and shop fabricated tanks and

heat exchangers, structural steel installations, heating, ventilating

and air conditioning (HVAC) installations, electrical supports, and

instrumentation and control tubing were inspected. The inspectedTelds

were selected to provide a representative sample of the licensee's

contractor welding activities in terms of welding processes used,

materials welded and existing weld-joint configurations. Considerations

such as physical location, difficulty of welding and limited accessi-

bility were also used in sample selection.

NDE activities were appraised through the review of radiographs for

both field and vendor fabricated welds, the review of NDE procedures

and personnel qualifications, the inspection of the calibration status

of NDE equipment, and the witnessing of in process NDE activities.

During the inspection of welds on pipe supports / restraints, the NRC

Construction Appraisal Team (CAT) identified welds which did not have

the weld size specified by the Architect Engineer, Sargent & Lundy

Engineers (S&L). Undersized welds were found in both skewed and non-

skewed connections on pipe supports. S&L has evaluated most of the

undersized welds and determined that the welds are adequate for the

intended application. Undersized weld reinforcements were also found in

nozzle to shell joints (ASME Code Category D joints) on tanks and heat

exchangers. A detailed discussion concerning these welds is included

in Sections IV.B.1 and 11, below.

The licensee has instituted an Illinois Power Company (IP) Overinspec-

tion Program. The program provides for additional inspections to be

performed by the Baldwin Associates Field Verification (BAFV) Group and

the IP Overinspection Group.Section VII, Design Change Control, of

this report provides additional discussion of the IP Overinspection

Program.

The IP Overinspection Program was set up to include inspections of

welds in all of the major areas of plant construction such as electri-

cal, piping, instrumentation, HVAC and structural steel. The NRC CAT

inspectors inspected eleven pipe supports / restraints which were

inspected under the scope of the program. In addition two supports

in the electrical, two supports in the instrumentation, two supports in

IV-1

l

l

the HVAC and two supports in the structural steel areas were inspected

to assess the adequacy of the welding overinspections.

In the area of NDE, the NRC CAT inspectors reviewed radiographs

supplied by various contractors and vendors. The NRC CAT inspectors

found radiographs which showed that some welds did not have the

required weld quality or the NDE documentation did not accurately

reflect the current status of the hardware. A detailed discussion

concerning the welds and their associated deficiencies are provided in

Sections IV.B.1., 9, 10 and 11, below.

The welding and NDE activities were examined in order to ascertain

compliance with the governing construction codes and specifications.

This effort involved the review and inspection of the following

contractors:

Field Activities

1. Sargent & Lundy Engineers: Architect Engineer.

2. Baldwin Associates: piping installation and piping supports /

restraints, instrumentation installation and instrumentation

supports, fire protection fabrication and installation, electrical

installation and supports, drywell wall field installation and

structural steel erection and modification.

3. Chicago Bridge and Iron Company (CB&I): containment liner and

containment penetration fabrication and installation, tank

fabricator.

4. Bristol Steel Company: reactor pool and spent fuel pool liner

fabrication and installation, structural steel supplier.

5. Zack Company (Zack): heating, ventilating and air conditioning.

6. General Electric Company: reactor internals field modification and

installation.

7. Reactor Controls Inc.: control drive mechanism piping

installation.

Shop Fabrication

1. Southwest Fabricating & Welding Company, Inc.: shop fabricated

piping spools.

2. Harnischfeger Corporation: crane manufacturer.

3. General Electric Company: nuclear steam supply system.

4. Anchor / Darling Valve Company: valve manufacturer.

5. Progressive Fabricating Inc.: pipe sleeve and cylinders supplier.

IV-2

_ _ _ _ _ . _ . . . -, . _

. -

6. Carrier Corporation: chillers and coolers manufacturer.

7. Pathway: expansicn bellows supplier.

8. RECO Industries Inc.: tank fabricator.

9. Posi Seal: valve bodies supplier.

10. Fisher Controls Inc.: valve manufacturer.

11. Rockwell: flow diverters supplier.

12. Lakeside Bridge and Steel: miscellaneous steel supplier.

13. La Barge: pipe supplier.

14. Hub: tube supplier,

15. Yuba Heat Transfer Corporation: high pressure heater manufacturer.

16. Southern Boiler: small tanks supplier.

17. Tube Turns: penetration manufacturer.

18. Spencer Turbine Co.: blow casing supplier.

19. Chicago Tube and Iron: tee tubes supplier.

20. Nooter: water storage tank supplier.

21. Guyon Alloys: tube and fittings supplier.

22. Gould: valve supplier.

23. Metal Bellows: bellows manufacturer.

24. Atomic International: hydrogen recombiner manufacturer.

25. Steward and Stevenson: air receiver tank supplier.

'

26. W.J. Woolley Company: containment vessel hatches fabricator

and supplier.

27. G.W. Taylor: material supplier.

28. Trent Tube: material supplier.

29. Bingham-Willamette: pump manufacturer.

The results of the inspection activities involving each of these areas

and contractors are documented in the following sections.

IV-3

.. , , . _ . . -_. - - _ _ . . , . .

1. Pipe and Pipe Support Fabrication

a. Inspection Scope

(1) Welding Activities

The NRC CAT inspectors reviewed activities relating to

fabrication contracts in the areas of piping system welds,

support / restraint welds, welding procedures, welder

qualifications, NDE procedures, personnel qualifications, and

the review of radiographic film for shop and field fabricated

welds. Field welding involving pipe fabrication was performed

by BA. Southwest Fabricating and Welding supplied the shop

fabricated piping spools.

The NRC CAT inspected 56 pipe supports / restraints involving

approximately 550 welds in order to verify conformance of

welding to drawing requirements and confirm the visual

acceptability of the welds. The inspection included 11 sup-

ports consisting of 68 welds, which had been checked under

the IP Overinspection program in order to evaluate the effec-

tiveness of that program. See Table IV-1 for a listing of

supports subjected to detailed inspection. Additionally,

another 16 supports / restraints involving 400 welds were

visually inspected to verify the quality of the completed

welds. See Table IV-2 for a listing of supports inspected.

The NRC CAT inspection of piping welds consisted of visual

inspection during walkdown of piping systems and inspection of

pipe welds located near the supports / restraints being inspec-

ted. Approximately 44 piping spools involving 1400 American

Society of Mechanical Engineers (ASME) Class 1, 2 and 3 welds

were inspected. Twenty-four of those piping spools were

subjected to detailed inspection which included the review of

pertinent QC documentation while the remaining 20 spools were

only visually inspected. Both field and shop welds were

inspected in order to assure compliance with the requirements

of the ASME Code. Some of the inspected socket welds were

fabricated by Reactor Controls, Inc. (RCI) in conjunction with

the Control Drive Mechanism piping installation contract. See

Tables IV-3 and IV-4 for listings of piping spools inspected.

In addition, 75 welding filler metal test reports, 22 welder

qualification test records and 4 welding procedures were

reviewed for compliance with applicable specifications,

procedures and the ASME Code requirements.

(2) Nondestructive Examination Activities

The NRC CAT inspection of NDE activities for the pipe

fabrication area included the review of 62 shop and 75 field

fabricated welds which involved 1815 film. The field welds

were fabricated by BA and the shop fabricated pipe spools were

supplied by Southwest Fabricating and Welding. Three welds

involving 28 film supplied by RCI were also reviewed as a part

IV-4

of this inspection. In addition, 6 NDE procedures and 11 NDE

personnel qualification records were reviewed in order to

verify compliance with the governing codes and specifications.

Six NDE technicians were observed while performing in process

inspections and were evaluated for their ability to follow the

applicable inspection procedures. Twenty pieces of NDE equip-

ment were inspected for calibration and one quality assurance

NDE procedure was reviewed for adequacy.

b. Inspection Findings

(1) Welding Activities '

In general, the inspected pipe and pipe support / restraint

welding activities were found to comply with the governing

codes and specifications. However, discrepancies were iden-

tified involving undersized welds in both skewed and nonskewed

welded connections. Forty-six of 950 structural welds inspec-

ted, involving 56 pipe supports / restraints, were found to be

deficient with respect to the specified acceptance criteria.

Forty-four of the welds were undersized, one weld had overlap

and lack of fusion, and another weld had undercut and was also

welded across the beam flange which violated the specification

requirements. Nineteen of the undersized welds were found on

hanger 1RH051R which had a total of 79 welds. As a result of

this finding the BA personnel identified and reinspected the

remaining 20 hangers of similar design. A relatively high

percentage of undersized welds were also found on those han-

gers. Investigation revealed that the hangers were predomi-

nately shop fabricated by BA and the shop fabricated portion

was not inspected as closely as those welds which were made

during installation. See Table IV-1 for details. As a result

of this finding the applicant issued Nonconformance Reports

(NCRs) and the welds were determined to be adequate for the

intended application.

Two of the 1400 pipe welds inspected were found to deviate from

the specified acceptance criteria. The two welds and their

associated deficiencies are listed as follows:

(a) An undersized reinforcing fillet weld between a small-

diameter coupling and spool piece IRH-8-7 was found. NCR

32441 was written as a result of this finding.

(b) Undersized welds were found on socket welds on the 3/4-inch

Schedule 160 piping connections on RCI work. NCR

CRD-185-48 was written as a result of this finding. In

addition, all pipe of this size and schedule was reinspec-

ted and accepted by the Architect Engineer without repair.

l Ten percent of the remaining RCI fillet welds were also

l inspected, and these were found to be of the correct size

since the connecting piping was Schedule 80 or lighter.

i

l

IV-5

._ . . _ _ _ .

(2) Nondestructive Examination Activities

In general, the inspected NDE activities were found to comply

with the applicable codes and specifications. However, during

the review of the radiographic film some irregularities were

identified which involved the following two welds:

Field Weld IVQ-B-1

The radiographs for this weld covering view 2-3 were

originally rejected for base metal gouging. The repair

film did not adequately cover the repaired area. As a

result of this finding the applicant issued NCR 31598.

Shop Weld IFC-2-13

This weld was reradiographed by BA. The weld traveler

FC-2-B misidentified weld IFC-2-13 as being weld

IFC-2-13-W-3. A visual examination of weld IFC-2-13

confirmed that the radiographed weld is IFC-2-13. As a

result of this finding the applicant issued NCR 31513.

c. Conclusions

(1) Welding Activities

In general, the inspected welding activities were found to

comply with the requirements of the applicable codes and

specifications. However, the NRC CAT found structural welds on

pipe supports / restraints which did not meet the weld specifi-

cations. The welds for these supports were evaluated by the

Architect Engineer and determined to be structurally adequate

for the intended application.

(2) Nondestructive Examination

In general, the inspected NDE activities were found to comply

with the requirements of the governing codes and specifica-

tions. However, the NRC CAT found welds which were misidenti-

fied and the repair areas did not have adequate radiographic

coverage.

2. Reactor Internals Modification and Installation

a. Inspection Scope

Apprvximately 20 feet of welded seam of the outer bank hood replace-

ment of the steam dryer and 6 new tie bar installation welds were

inspected. In addition, one welding procedure and the qualification

test records for two welders were also reviewed for adequacy. The

modification work was performed by General Electric Installation and

Services Engineering Division.

IV-6

-

b. Inspection Findings and Conclusions

No problems were identified in the area of inspected welding

activities. Activities were found to meet the specified acceptance

criteria.

3. Electrical Installation and Electrical Supports

a. Inspection Scope

The NRC CAT inspected approximately 100 field and 60 shop welds in

the area of electrical installation. Two welding procedures and

the qualification test records for six welders were reviewed. In

addition, the personnel qualification test records for four welding

inspectors were also reviewed and four inspectors were observed

and evaluated for their ability to follow the visual inspection

procedures. The welding activities in the electrical area were

performed by BA.

b. Inspection Findings and Conclusions

No problems were identified in the area of inspected welding

activities. Activities were found to comply with the applicable

construction codes and specifications.

4. Instrumentation Tubing Installation and Instrumentation Supports

a. Inspection Scope

Approximately 110 welds involving 18 instrumentation supports, 2

panels, and 80 tubing welds were visually inspected to ascertain

compliance with the specified acceptance criteria. Two welding

procedures and qualification test records for six welders were

reviewed. NDE procedures and qualification records for four NDE

inspectors were also reviewed. Two visual welding inspectors and

two liquid penetrant inspectors were observed and evaluated for

their ability to follow the applicable inspection procedures. The

welding in the instrumentation area was performed by BA.

b. Inspection Findings and Conclusions

No problems were identified in the area of inspected welding and

NDE activities. Activities were found to comply with the

applicable construction codes and specifications.

5. Heating, Ventilating and Air Conditioning

Installation and Supports

a. Inspection Scope

Approximately 140 welds involving 20 supports were inspected for

compliance with the specified acceptance criteria. Six welding

procedures and the qualification test records for six welders were

reviewed. In addition, four welding inspector personnel qualifi-

cation test records were also reviewed and two welding inspectors

IV-7

. _

were observed and evaluated for their ability to follow the visual

inspection procedures. The welds on four duct pieces, two air

blowers, one air filter and four dampers were also included in this

inspection. The welding in the HVAC area was performed by Zack

Company.

J

b. Inspection Findings

During the inspection of Hanger A-0082 a burn through the duct was

observed in the welded joint between the duct and the duct companion

flange. As a result of this finding, Zack Company issued NCR 912085

and the duct will be repaired as required.

c. Conclusions

In general, the inspected welded activities were found to comply

with the requirements specified by the Architect Engineer. With

the exception of the minor finding (burn through duct in one

isolated case) the inspected welding activities were found to comply

with the applicable codes and specifications.

6. Structural Steel Fabrication, Erection and Modification

a. Inspection Scope

Approximately 150 welds comprising 80 field and 70 shop welds

, involving 22 structural beams were visually inspected in order to

ascertain compliance with the specified acceptance criteria.

Five welding procedures and the qualification test records for six

welders were reviewed. Visual inspection procedures and the

qualification test records for five inspectors were also reviewed.

Three welding inspectors were observed and evaluated for their

ability to follow the visual inspection procedures. The structural

steel field welding was performed by BA. Rockwell Engineering and

Bristol Steel supplied structural steel to the project.

b. Inspection Findings and Conclusions

No problems were identified in the area of inspected welding

activities. Activities were found to comply with the applicable

construction codes and specifications.

7. Fuel Storage Pool and Refueling Cavity Liner Fabrication

a. Inspection Scope

The NRC CAT visually inspected approximately 120 feet of welded

seam on the Fuel Storage Pool and the Refueling Cavity Liner. The

attachment welds for two gusset hooks and two pad plates were also

inspected in order to ascertain compliance with the specified

acceptance criteria. In the area of NDE the NRC CAT reviewed the

radiographs for 100 feet of welded seam involving 234 film. The

Fuel Storage Pool and Refueling Cavity Liner fabrication was

completed by Bristol Steel.

IV-8

__.

__ - - . _ . - .-

b. Inspection Findings and Conclusions

No problems were identified in the areas of inspected welding and

NDE activities. Activities were found to comply with the

applicable construction codes and specifications.

8. Fire Protection System Fabrication and Installation

a. Inspection Scope

Approximately 80 welds involving 10 pipe supports' and 15 pipe welds

,

involving 2 pipe spools were visually inspected. One welding

procedure and the qualification test records for two welders were

also reviewed for adequacy. The fire protection installation was

completed by BA.

b. Inspection Findings and Conclusions

No problems were identified in the area of inspected welding and

NDE activities. Activities were found to comply with the governing

construction codes and specifications.

9. Containment Liner and Containment Penetration Installation

a. Inspection Scope

The NRC CAT visually inspected approximately 50 feet of liner seam,

the welds on one pad plate, the attachment weld for one personnel

hatch, and the attachment welds for two mechanical and two

electrical penetrations. In the area of NDE, the NRC CAT reviewed

the radiographs for 150 feet of liner seam which involved 450

film. One radiographic examination procedure was also reviewed as

a part of this inspection. The containment liner and penetrations

were installed by CB&I.

b. Inspection Findings

No problems were identified in the area of inspected welding

activities. However, during the review of radiographs the NRC CAT

inspectors identified 14 spot radiographs which did not meet the

required weld quality. As a result of this finding, the applicant

performed an evaluation of the affected liner welds and concluded

that the welds are acceptable "as is" because every weld was sub-

jected to and had passed magnetic particle and vacuum box inspec-

tions. In addition, in 1984, the applicant had reviewed 25 percent

of the fabrication and erection documentation for the containment

,

'

liner. The review was conducted by the Authorized Nuclear Inspector

employed by the Hartford Steam Boiler Inspection and Insurance

Company. Twenty-six minor nonconforming conditions were identified

and no major discrepancies were found. Based upon these reviews the

applicant has concluded that the overall liner weld quality is

acceptable to maintain the structural and leak tightness integrity

of the containment liner.

IV-9

. . _.

__ _ . _ _ _ _ _.

The NRC CAT identified welded seams and their associated deficien-

cies are listed as follows:

Purchase Order (P.O.) 409.27 7-8A-7C 139 porosity

7-8A 146 porosity

7-8B 144 porosity

7-88-7L 145 Incomplete Fusion

513-A-5 142 porosity

P.O. 409.29 9-10B 176 linear indication

9-108 173 alligned indication

P.O. 409.35 11-128-12L 194 crack-like indication

P.O. 409.35 170 219 porosity

16A 10A crack-like indication

16A 4-5 crack-like indication

P." 409.40 517-11-7 280 incomplete fusion

51-B-7 275 aligned indication

P.O. 409.44 C0 Vert. 4-5 I.F. porosity

! c. Conclusions

In general, the inspected welding and NDE activities were found to 4

comply with the requirements of the governing codes and

i specifications. However, the NRC CAT found spot radiographs which

did not meet the specified weld quality. The welds were evaluated

by the applicant and determined to be adequate for the intended

application because every weld had passed magnetic particle and

vacuum box testing.

10. Drywell Wall and Penetrations

a. Inspection Scope

The NRC CAT visually inspected approximately 40 feet of drywell wall

seam and the attachment welds for one penetration. In the area of

NDE, the NRC CAT reviewed the radiographs for 220 feet of welded

seam which involved 340 film. One radiographic examination proce-

dure was also reviewed as a part of the inspection. The drywell

wall was fabricated by Mississippi Valley Steel Company and the

field installation of the prefabricated assemblies was done by BA.

i The drywell locks and hatches were installed by CB&I.

.

b. Inspection Findings

,

No problems were identified in the inspected welding activities.

j However, during the review of radiographs, the NRC CAT inspectors

identified three welds which did not have the specified weld

quality. The three welds and their associated deficiencies are

identified as follows:

IV-10

-. _ _ . - - . ____ _ . -. . .

Seam weld No. 16, station 12 located at elevation 707' to 737',

column 173 contained an unacceptable linear indication. The

weld was fabricated by BA. NCR 32686 was generated as a

result of this finding.

Seam weld No. 30, film A-8, view F-G contained an unacceptable

insufficient fusion indication. The weld was fabricated by

Mississippi Valley Steel Company. NCR 32294 was generated

as a result of this finding.

One weld for P.O. 9993.1 on drywell locks and hatches assembly

1A, weld seam 1-5-4 to 1-5-1, view 0-1 R1 contained an

unacceptable crack-like indication near station mark 1. The

original film was rejected for a linear indication near station

mark 0 which indicated that the repair film was reversed from

the original film position. This reversal had prevented the

interpreter from detecting the crack-like indication because he

was looking at the wrong area. NCR 32597 was generated as a

result of this finding. The radiographs were supplied by CB&I.

c. Conclusions

In general, the inspected welding and NDE activities were found to

comply with the governing codes and specifications. However, three

welds were found to contain unacceptable indications. As a result

of this finding, the applicant has issued NCRs and the welds will

be evaluated and repaired as needed.

11. Vendors and Shop Fabricators Other Than Those Previously Addressed

a. Inspection Scope

The NRC CAT visually inspected six vendor supplied tanks and heat

exchangers. See Table IV-5 for inspected vendor supplied equipment.

In addition to the welds inspected and listed in Table IV-5, the NRC

CAT inspectors reviewed radiographs related to work performed by 28

vendors which have supplied various equipments and hardware to the

Clinton Power Station project. A total of 347 feet of welded seam

involving 472 radiographs and 91 welds involving 771 film were

reviewed. The radiographs for 19 valves involving 408 film, and

the radiographs for 15 spot welds involving 33 film were also

reviewed for compliance with the governing codes and specifications.

b. Inspection Findings

During the inspection of tanks and heat exchangers supplied by the

vendors listed in Table IV-5, the NRC CAT found that the size of

the nozzle and manway weld reinforcement did not meet the

requirements stated in the vendor drawings. In addition, the welds

on some of the inspected supports were also found to be undersized.

A total of six tanks and heat exchangers were found to deviate from

the required drawing sizes. As a result of these findings, the

applicant issued NCRs and this item will be reviewed and disposi-

tioned by S&L. See Table IV-5 for details. The NRC has issued

Information Notice No. 85-33 on the subject of undersized weld

IV-11

-

reinforcement in ASME Code nozzle to shell joints. As a result of

this notice, prior to the NRC CAT arrival, the licensee had inspec-

ted the nozzle welds on ten pressure vessels and tanks. Nine of the

items were found to have undersized weld reinforcements around the

nozzles. By the end of the NRC CAT inspection of this area, the

licensee had initiated a complete reinspection of tanks and pressure

vessels supplied by CBI and RECO industries.

In the area of NDE, the NRC CAT inspectors identified irregularities

relating to NDE documentation and radiographs supplied by two

vendors. See Table IV-6 for details.

c. Conclusions

In general, the inspected welding and NDE activities were found to

comply with the requirements of the governing codes and specifica-

tions. However, six tanks and heat exchangers were found to deviate

from the requirements stated in the applicable drawings and

specifications. In addition, the radiographs and NDE documentation

supplied by two vendors were found to be deficient with respect to

the required quality.

IV-12

. . . . - - ..

TABLE IV-1

LIST OF SUPPORTS WHICH WERE INSPECTED

AGAINST ORAWING REQUIREMENTS

IMS280095 (1) 1MS28012C 1RB21572R

IMS860015 1HP08009X (2) ISX45003X (3)

1FC03091X (4) 1FC03002R (5) 1HP04019R

1HP04005R (6) 1HP03042S 1RH20007X

1RH19002X 1RH07004X (7) 1RH07003S

1RH16036X 1RH090895 1LP03016S

1FB15018G* ILP04003R 1R114019R

1RH09011R (8) 1MS07002G (10) 1RH04051R (9)

1RH04035X 1RH04042X (11) IIA 16002G

ISC01020R 1RT03032R 1RT11047X

1RB13542G (12) 1MS27012S (Partial) 1MS63001G

1FWO1008G 1MS86001S 1MS860105

ISX30003V 1HP03042S (13) 1RH090875 (14)

IMS86007V 1MS86010X CLN-021-SP11 (17)

CLN-021-SP16 ISX-01028R ISX-01017R

ISX-01050X 1RH47013G* H-1RH-780-4* (15)

ISX42021R* (16) ISX42019R* 1RH34010X*

1RH71018G* 1RH71016G* 1SX52022X*

1SC01020R* 1RB22056G*

NOTES:

,

1. One fillet 1/32" undersized for full length due to member size. NCR 31498.

,

2. Two fillet welds undersized by 1/16". NCR 31499.

l

I

3. Two skewed fillet welds undersized by 1/16" for full length. NCR 31497.

!

! IV-13

!

i

-_ .- . _ - ---

._

.

TABLE IV-1 (Continued)

LIST OF SUPPORTS WHICH WERE INSPECTED

AGAINST DRAWING REQUIREMENTS

.

4. Two fillet welds 1/32" undersized. NCR 31493.

5. One fillet weld 3/4" undersized for full length. NCR 31496.

6. Two 1/4" fillet welds 3/32" undersized due to fit-up gap.

NCR 31495.

7. One fillet weld 1/16" undersized. NCR 31494.

,

8. Four obtuse angle skewed welds and one right fillet weld undersized for

full length 1/16". NCR 31542.

9. Nineteen of 79 fillet welds 1/32" undersized. NCR 31572.

10. One fillet weld undersized by 1/16". NCR 31541.

11. Obtuse angle fillet weld 3/32" undersized. NCR 31574.

12. Obtuse angle fillet weld 1/8" undersized due to too small attaching plate.

NCR 31573.

13. Three fillet welds 1/16" undersized.

14. Two obtuse angle fillet welds 1/8" undersized. NCR 31611.

15. Weld surface has overlap and lack of fusion. NCR 31604 and NCR 31615.

16. Undercut in excess of 1/32" in two places, unspecified welding across flange.

NCR 31599.

17. Obtuse angle fillet weld undersized. NCR CRD-186-48 (RCI work)

• These items were subjected to Overinspection by Illinois Power QA.

IV-14

- _

._ _ _ _ _. . _ . . _

_ _ ._

_ _ _ - _ _ _ _ _ _ _ _ _ - -

!

l

!

!

!

TABLE IV-2

LIST OF SUPPORTS WHICH WERE SUBJECTED TO VISUAL INSPECTION ONLY

1RB22144G 1CC50041G 1RB22111G

l

1FWO30115 1RB22106G IIA 16002G i

1RIl00095 1RB22056G 1RF07001G

ILP09005G 1RH40011X 1RH40013G

1FB15015G 1FB15006G 1FB15008G

1FB15018

1

IV-15

.

.

_ _ _ _ _ - - _

_ _ _ _ ___ _ _ _ _ __ _-_

e TABLE IV-3

LIST OF PIPING WHICH WAS SUBJECTED TO VISUAL INSPECTION ONLY

Item Description Pipe Size (in.) Material

G003-A-1 Main Steam 24 Carbon Steel i

10C-21-1 Component Cooling 10, 12 Carbon Steel

1RH-16-1 Residual Heat Removal 12 Carbon Steel

1SX-15-3 Shutdown Service Water 18 Carbon Steel

1FC-12-8 Fuel Pool Cooling 14 Stainless Steel

1FC-30-5 Fuel Pool Cooling 8 Stainless Steel

1FC-30-14 Fuel Pool Cooling 14 Stainless Steel

1RH-8-7 (1) Residual Heat Removal 24 Carbon Steel

1RH-8-8 Residual Heat Removal 24 Carbon Steel

1RH-8-9 Residual Heat Removal 24 Carbon Steel

1RH-26-8 Residual Heat Removal 4 Carbon Steel

1RH-26-5 Residual Heat Removal 18 Carbon Steel

1SX-17-11 Shutdown Service Water 18, 24 Carbon Steel

1SX-2-2 Shutdown Service Water 12 Carbon Steel

1RI-13-3ZA Reactor Isolation 4 Carbon Steel

1RI-13-3ZB Reactor Isolatinn 4 Carbon Steel

1RI-13-5B Reactor Isolation 4 Carbon Steel

1RI-13-6 Reactor Isolation t Carbon Steel

1RI-13-7 Reactor Isolation 4 Carbon Steel

1RI-13-8 Reactor Isolation 4 Carbon Steel

IV-16

. _ _ _ ___

_. . _ _ - _ _ - _ _ _ _ _ _ _ _ _ ____

TABLE IV-4

PORTIONS OF PIPING SYSTEMS VISUALLY EXAMINED AND

FOR WHICH DOCUMENTATION WAS REVIEWED

Item Description Pipe Size (in.) Material

G003-A-1 Main Steam 24 Carbon Steel

G004-A-1 Main Steam 24 Carbon Steel

G005-A-1 Main Steam 24 Carbon Steel ;

l 1RI-13-9 Reactor Isolation 4 Carbon Steel

1RI-13-7A Reactor Isolation 4 Carbon Steel

1RI-13-4ZA Reactor Isolation 4 Carbon Steel

1RI-13-4ZB Reactor Isolation 4 Carbon Steel l

1RI-13-5AA Reactor Isolation 4 Carbon Steel j

1RI-13-4A Reactor Isolation 4 Carbon Steel l

1RI-13-6B Reactor Isolation 4 Carbon Steel

1FW-1-1 Feedwater 20 Carbon Steel

1FW-1-2 Feedwater 18 Carbon Steel

1FW-1-3 Feedwater 12 Carbon Steel

i

1FW-1-4 Feedwater 12 Carbon Steel

1FW-1-5 Feedwater 12 Carbon Steel

1FW-1-6 Feedwater 12 Carbon Steel

l 1FW-1-7 Feedwater 12 Carbon Steel

1FW-1-8Z Feedwater 20 Carbon Steel

1FW-1-1A Feedwater Lugs Carbon Steel

1FW-1-1B Feedwater Lugs Carbon Steel

1FW-1-7J Feedwater Lugs Carbon Steel

1FW-1-7K Feedwater Lugs Carbon Steel

IFW-1-7L Feedwater Lugs Carbon Steel

1FW-1-7M Feedwater Lugs Carbon Steel

IV-17

. .. ..

.

_ _ _ _ _ _ _ _ _ _ _ _ . .

c

TABLE IV-5

-

VENDOR SUPPLIED TANKS AND HEAT EXCHANGERS

WHICH WERE VISUALLY INSPECTED

ITEM MANUFACTURER

Standby Liquid Control Tank 1C41-A001 (1) Boeing Corporation

Fuel Oil Storage Tank 10001TC (2) RECO Industries, Inc.

Fuel Oil Day Tank 1DG01TC (3) RECO Industries, Inc.

Accumulator Tank 1821-A003E (4) RECO Industries, Inc.

Fuel Pool Cooling Heat Exchanger 1FC01AA (5) Yuba Heat Exchanger Corp.

Fuel Oil Storage Tank 1D001TA (6) CB&I Corporation

NOTES:

(1) Five nozzle reinforcing fillet welds undersized. NCR 32365.

(2) One nozzle reinforcing fillet weld and support fillet welds undersized.

NCR 32364.

(3) Undersized fillet welds on supports. NCR 32363

(4) Two nozzle reinforcing fillet welds and support welds undersized.

NCR 32361.

(5) One nozzle reinforcing fillet weld undersized due to overgrinding, and

support fillet welds undersized. NCR 32362.

(6) Nine nozzle reinforcing fillet welds undersized, manway reinforcing fillet

welds undersized, support fillet welds undersized, head-to-shell mismatch in

excess of that permitted by the Code and weld surface quality

unacceptable. NCR 32573.

l

IV-18

TABLE IV-6

VENDOR RADIOGRAPHS REVIEWED

Valve Spot Feet of

Contractor Welds Pumps Welds Welds Film Notes

General Electric 20 450

Yuba Heat Transfer 30 60

Progressive Fabricating 40 105

RECO Industries 26 32

Pathway 36 52

Harnischfeger 16 12

Anchor / Darling 5 160 (1)

Rockwell 2 14

Lakeside Bridge 22 54 (2)

& Steel

Carrier 6 9

La Barge 45 37

Southern Boiler 15 10

Tube Turns 6 12

Fisher Controls 2 44

Spencer Turbine Co. 13 22

Chicago Tube and Iron 4 32

Nooter 15 33

Guyon Alloys 6 9

HUB 1 2

Gould 2 53

Atomic International 6 63

Metal Bellows 10 68

Steward and Stevenson 40 32

'

IV-19

!

l

ll

. _

-

TABLE IV-6 (Continued)

VENDOR RADIOGRAPHS REVIEWED

Valve Spot Feet of

Contractor Welds Pumps Welds Welds Film Notes

Posi Seal 7 106

W. J. Wooley 12 19

G. W. Taylor 52 40

Bingham-Willamette 3 45

Trent Tube 30 20

NOTES:

(1) Film stuck together indicating that film was improperly packaged.

(2) Reader sheet for piece mark 2-1-1 showed rejections for cracks and other

indications. The original film also showed rejections. The final acceptable

film was not identifiable as being of the same area. Further investigation

indicated that a slot in the area of interest was welded, ground smooth and

re-radiographed. The final radiographs were identified and determined to be

acceptable.

IV-20

.- - _ _ _ . - - - . . . . ._ . --

l

V. CIVIL AND STRUCTURAL CONSTRUCTION

A. Objective

The objective of the appraisal of civil and structural construction was

to determine by evaluation and review of Quality Control (QC) accepted

work and documentation whether civil and structural construction areas

were completed in accordance with regulatory requirements, Safety

Analysis Report commitments, and project specifications, drawings and

procedures.

B. Discussion

The specific areas of civil and structural construction evaluated were

concrete, reinforcing steel configuration, cadwelds, structural steel

installation, high strength bolting, structural fill, and diesel genera-

tor exhaust silencer supports. A major part of the installed structural

steel inspection sample was previously inspected by the Illinois Power

Overinspection (IPOI) Program.

For concrete, reinforcing steel configuration, structural steel install-

ation, high strength bolting, und diesel generator exhaust silencers,

a physical or hardware inspection and a QC documentation and field

procedures review were conducted. For cadwelds, concrete pours, and

structural fill, a review of QC documentation and field procedures was

performed.

1. Reinforced Concrete Construction

a. Inspection Scope

Reinforced concrete construction areas inspected by the NRC

Construction Appraisal Team (CAT) included reinforcing steel

configuration, activities for a concrete placement, and general

concrete surface quality. These areas were checked for conformance

with Sargent and Lundy Engineers (S&L) design drawings and specifi-

cations. General concrete quality was examined from surrounding

areas of completed concrete construction for conformance to site

specifications.

For the reinforcing steel configuration inspection, the upper layers

of exposed rebar projecting from the east face of the base mat along

plant wall lines 200 and 202 and between the D wall line and the

south exterior wall line of the Diesel Generator Building wall were

reviewed for conformance to applicable drawings and specifications.

One in process concrete placement for the personnel access hatch

door to the drywell was observed by the NRC CAT. These observations

occured from the time of mixing of the concrete at the site batch

plant to completion of the placement of the concrete in the steel

formwork. Observations were made for slump tests, length of time

required for concrete placement, and preparation of concrete

cylinder test specimens.

V-1

.

QC documentation and appropriate field procedures were reviewed for

six concrete pour travelers and three cadweld travelers.

The QC documentation reviewed for six concrete pour travelers and

associated concrete pour package numbers are given in Table V-1.

Records reviewed and associated with the concrete placements

included concrete pour pre placement checklist, concrete pour

placement and testing checklist, and report of concrete cylinders.

The reviews checked the forms for adequate completion by the QC

inspectors, the existence of senior QC inspectors' signature for

evaluation of completed forms, and acceptable coverage of attributes

by the documentation.

For the cadweld QC documentation and field procedures review, the

following cadweld travelers were covered: CCW No. 1, CCW No. 2 and

CCW No. 3. Records were reviewed to identify whether the cadweld

work was properly inspected before and after each cadweld was

performed and whether each cadwelder was adequately tested. In

addition, the qualification records for 10 cadwelders (operator ID

Nos. 6, 15, 16, 17, 19, 20, 27, 30, 46, 48) in cadweld traveler CCW

No. 1 were reviewed to determine if they were properly qualified to

perform cadwelds of each splice position, bar size and grade.

The requirements and acceptance criteria for reinforced concrete

construction were obtained from the drawings listed in Table V-2 and

the following specifications and procedures:

S&L Specification K-2938, " Concrete Mix Design," Rev. 3, dated

April 14, 1981

S&L Specification K-2944, " Concrete and Grout Work," Rev. 26,

dated July 13, 1984

Baldwin Associates Project Procedure BAP 3.1.1, " Concrete,"

Rev. 13, dated October 3, 1984

BAP 3.1.5, "Embedments/ Reinforcing Steel /Cadwelding," Rev. 10,

October 3, 1984

b. Inspection Findings

Two areas were identified by the NRC CAT where the concrete place-

ments did not meet site criteria in the AD wall line at elevation

724'. Debris and rags were found embedded in the wall. It was also

identified that the 2-inch shake space between the containment and

the adjacent structures had been violated. Two areas were identi-

fied by the NRC CAT inspectors where concrete had encroached into .

'

the 2-inch shake space between the containment and the adjacent

structures. The licensee reinspected the rest of the shake space

and identified 26 additional locations where the 2-inch shake space l

clearance requirements had not been met. Nonconformance Report

(NCR) 31579 was issued on this deficiency.

l

The six concrete pour travelers were found to meet procedure  !

requirements and demonstrate proper QC inspection.

V-2

-

In the top steel reinforcement of the concrete base mat on the 200

line and 202 line, one area was identified where the number and

spacing of the rebar were not in accordance with the design drawing,

but were in accordance with the shop drawings approved by S&L. NCR

31949 was written and the condition was evaluated and accepted by

S&L.

Visual inspection ,equirements before and after the cadwelds were

performed were met. The 10 cadwelders reviewed for qualification

requirements were found to be properly qualified for cadwelding

the appropriate bar size and grade and splice positions.

Two discrepancies were found in the cadweld traveler packages

reviewed. One discrepancy was a noncompliance with the cadweld

tensile testing requirements in the Final Safety Analysis Report

(FSAR) and specifications. Appendix B, paragraph B.2.3.4 of the

FSAR states "Sg srate sampling and testing cycles were established

for cadweld oplices in horizontal, vertical, and diagonal bars, for

each bar grade and size, and for each splicing operator." However,

the cadweld records showed that separate sampling and test cycles

were established for cadweld splices in each position, bar size and

grade for each shift (instead of for each cadweld operator).

This discrepancy was previously identified by Baldwin Associates

(BA) in NCR 31282 written on May 18, 1985. The S&L disposition for

NCR 31282 was to use-as-is because the specification requirements

had been met. However, the NRC CAT does not consider that the

requirements of Paragraph 4.4.1(a) of the mechanical splice speci-

fication were met. The same sampling plan is provided in the FSAR.

It appeared that S&L's resolution was based on a general observation

of the records and not a complete review of the records. Therefore,

the disposition of NCR 31282 is considered inadequate.

The concern of the NRC CAT with this discrepancy is that one or more

operators may have been tested at less than the required frequency.

Since the cadweld tensile test sampling schedule was based on each

shift, rather than individual cadwelders, there could be deviations

from the required testing frequency stated in the FSAR. The FSAR

requirements in Appendix B, paragraph B.2.3.4 for tensile testing

frequency for each operator states:

Separate sampling and testing cycles were established... for

each splicing operator as follows:

a. One production splice out of the first ten splices

b. one production and three sister splices for the next 90

production splices, and

c. one splice, either production or sister splices for the

next subsequent units of 33 splices. At least 1/4 of the

tested number of splices tested were production splices.

V-3

The cadweld records do not easily permit a reconstruction of the

testing information to determine if the testing requirements were

met. However, a tabulation was made of the tensile testing

frequency for production splices of the three cadweld travelers

reviewed by the NRC CAT. Results of the tabulation are shown in

Table V-3a and V-3b.

Table V-3a shows four operators (I.D. Nos. 6, 16, 20, 30) whose

sampling did not meet the requirements of one production splice out

of the first ten splices. Table V-3b shows 13 additional operators

(I.D. Nos. 28, 35, 38, 45, 48, 49, 50, 51, 61, 62, 67, 68, 72) whose

sampling did not meet the testing requirements.

The other discrepancy was found in the Cadweld Test Cycle Log. The

Cadweld Test Cycle Log was to record the sequential order in which

the cadwelds were performed. However, numerous instances were found

where cadwelds were not in sequential order. Table V-4 shows

numerous cadweld sequential discrepancies based on the dates

obtained from the cadweld inspection check-off sheets for 17 Cadweld

Test Cycle Log sheets. The remaining Cadweld Test Cycle Log sheets

contain over 20 other instances of improper ordering of cadweld

production splices.

c. Conclusion

The general concrete construction quality seems adequate. QC

documentation in the completed concrete pour travelers appeared

adequate. Procedures followed by site craft for the single

in process concrete pour work observed by the NRC CAT appeared to be

proper. The rags found in a completed concrete placement and the 28

locations with concrete in the shake space between the containment

and adjacent structures will require appropriate management atten-

tion.

Records reviewed for cadweld work performed indicated that the

frequency of tensile test sampling for many cadweld operators was

not satisfied. S&L's corrective action was not adequate.

2. Structural Steel Installation

a. Inspection Scon

Installed and QC accepted structural steel were inspected by the NRC

CAT. A major part of the NRC CAT inspection sample was covered by

the IP0I Program. Attributes inspected by the NRC CAT were member

size, configuration, and high strength bolted connection configura-

tion. High strength bolt friction and sliding connections were

tested by using a calibrated torque wrench to determine whether the

bolts were properly installed. Most of the friction bolt connec-

tions and all of the bolted sliding connections had been inspected

by the IPOI Program.

The samples used in the structural steel verification for correct

member size and configuration are described in Table V-5. A total of

59 structural steel members and 27 connections were inspected by the

V-4

- .- -. _ . . _

. _ . _- - _.

_

NRC CAT. Samples were taken from areas previously covered by IP0I

except for the framing to the Hydraulic Control Unit in Area 3 of

the Containment Building.

Section VII, Design Change Control, of this report discusses

deficiencies identified with the IPOI documentation for structural

steel beams. Four of the beams refered to in that section with

documentation deficiencies were inspected by the NRC CAT to deter-

mine if the hardware quality had been affected. This sample was

part of the inspection sample in Table V-5.

The location, size, and number of the three different kinds of high

strength bolts for friction connections that were checked for

installation torque are shown in Table V-6. A total of 287 bolts

were tested for minimum installation torque. Test torque values of

IPOI were used for the NRC CAT inspection.

The sample of sliding connections tested is described in Table V-7.

A total of 15 bolts spread over five connections were tested for

maximum installation torque.

The requirements and acceptance criteria for structural steel

installation are included in the drawings listed in Table V-8 and

in the following specifications and procedures:

S&L Specification K-2947, " Furnish Structural Steel," Rev. 3,

dated June 22, 1983

S&L Specification K-2948, " Erect Structural Steel," Rev. 9,

dated March 9, 1984

BAP 3.13, " Structural Steel Erection," Rev. 11, dated October

22, 1984.

b. Inspection Findings

Detailed findings of the erected structural steel member and con-

'

nection inspection are provided in Tables V-5, V-6 and V-7. The

comments portion of the tables contain an explanation of whether the

inspection sample had been covered by IPOI.

Of the 59 members reviewed, there was one discrepancy found during

the structural member size and configuration inspection. Modifica-

tion 1AC for Detail 27-615 on Drawing S27-1458 requires a 7/8-inch

A36 side plate, continuous between the centerlines of Beams 2D and

2E, which had not been installed. The beam had previously been

inspected and accepted by IPOI. This seemed to be an isolated case

rather than a program deficiency. The licensee indicated a complete

reinspection of the beam would be performed, followed by an NCR.

No hardware deficiencies were identified for the sample of four

beams associated with the IPOI documentation discrepancies discussed

in Section VII.B.3.

V-5

.-- _ _ . _ _ _ _ _ _

Of the 251 friction connection bolts tested by the NRC CAT and

previously by IP0I for minimum installation torque, only 2 bolts

were found to be under-torqued. Of the 36 fixed connection bolts

tested by the NRC CAT, but not within the inspection sample of IP

OI, seven bolts were found under minimum acceptable installation

torque including one just hand-tight.

Installation torque for the bolts of the sliding connections was

defined as snug-tight. Procedures provided to the craft to ensure

the bolts were installed in a manner which may prevent the sliding

connections to perform as intended were insufficient. A sample of

the bolting for two of the five sliding connections checked by the

NRC CAT were found to be over-tight. S&L was asked to evaluate this

condition. The subsequent response was considered inadequate by the

NRC CAT and requires further evaluation.

The floor grating inside the Containment Building was observed to

not be fastened to the structural steel. The NRC CAT is concerned

that the grating could become a missile under high energy pipe

break conditions. The licensee responded that the grating will be

fastened to the structural steel with clips, but that the grating

could still become a missile if subjected to the forces of high

energy break conditions. This matter was discussed with and will be

referred to the NRR Auxiliary Systems Branch for review.

Another observation by the NRC CAT was that the structural steel

within the Containment Building was coated with inorganic zine which

could generate hydrogen gas during a loss of coolant accident. The

licensee stated that the amount of zinc in the Containment Building

is being calculated and systems are being sized in consideration of

the hydrogen gas that could be generated. Therefore, the NRC review

of the calculations and system sizing criteria may be performed at

a later date.

c. Conclusion

The IPOI Program on the structural steel installation appears to be

satisfactory with two exceptions. The inadequate implementation of

the IPOI Program criteria resulted in not including the Hydraulic

Control Unit (HCU) framing in the scope of the IP0I Program.

Furthermore, the installed torque of some of the high strength bolts

of the friction connections of the HCU structural steel not included

in the IPOI Program was found inadequate. The evaluation by S&L of

the identified condition of the sliding connections did not address

the NRC CAT finding and the technical concern of additional loads

due to over-tightened bolts.

3. Structural Fill

a. Inspection Scope

The NRC CAT inspectors reviewed daily earthwork logs between June 3,

1976 and June 13, 1976 for the safety-related Class B structural

fill for the main power block structures. Also, the following NCRs

were reviewed: NCR S-S-S-0006, NCR 174, and NCR 1650.

V-6

. _ _ _ -. -_ _.

The requirements and acceptance criteria were included in the following

documents:

S&L Specification K-2942, " Earthwork," Amendment 9, dated

July 13, 1984

U.S. Testing Company Procedure QCP-10 " Testing Procedures for

Earthwork," Rev. O, dated February 9, 1977 and Rev. 9, dated

January 2, 1985

Fruin-Colnon " Compaction Test Section Report," dated April 1976.

b. Inspection Findings

The daily earthwork logs were reviewed by the NRC CAT inspectors.

A discrepancy was identified with the lift thickness requirements in

the structural fill records. Of the 15 compaction placement records

reviewed, 7 did not record the lift thickness used in placing the

fill. Section 2.5.4.5.1.5 of the FSAR states " Type B material used

as structural fill to support foundation loads was placed in near

horizontal lifts not exceeding 12 inches in loose thickness."

Further, the applicable compaction test report also recommends that

the fill be placed in 12 inch lifts. The NRC CAT review of the

structural fill records do not indicate that the FSAR commitment was

satisfied. Approximately one-half of the records reviewed did not

indicate any lift thickness measurement. In other records the lift

thickness was listed as 12 to 14 inches.

The dispositions for the three NCRs were questioned by the NRC CAT.

Nuclear density test data was used to accept fill placements where

the sand cone test data had failed. This was contrary to the

project specification. Also, structural fill was placed over areas

that had not been QC accepted. Some of these areas were not

accepted for as long as two years; thus indicating untimely correc-

tive action.

The following is a brief review of the three NCRs referenced above.

NCR S-5-5-0006 was written by BA on June 11, 1976 to cover

apparent errors in the correlation factor between sand cone

tests and nuclear density tests for covered fills placed

between May 29,1976 and June 10, 1976.

As part of S&L's resolution of this NCR, S&L found that the

perceived reduction in the correlation' factor had been cal-

culated incorrectly and that the 73 test locations in question

were in accordance with the design requirements. The S&L

disposition also indicated that all soil tests reports in

question were checked by BA QC and spot checked by S&L. This

check supposedly included all sand cone test data (approx-

imately 367) up to May 24, 1976, correlation factors and all

nuclear density test data.

V-7

l

NCR 174 was written by BA on January 21, 1977 to cover failed

sand cone tests between May 17, 1976 and August 19, 1976 and

represented 45 zones (100x100x1 feet) in the structural fill.

These areas of structural fill were accepted based on the

results of the nuclear density tests. However, three of the

failed sand cone tests were performed prior to May 24, 1976 and

should have been evaluated as part of NCR S-S-S-0006. Sand

cone test SC 320 performed on May 17,1976 was voided because

the results were " unreliable." A second sand cone test, SC 364

performed on May 24, 1976, had a relative density of 65.3

percent. This was 20 percent below the acceptance criteria.

On November 1, 1978 NCR 1650 was issued and stated that 16

zones placed between April 29, 1976 and May 17, 1976 did not

meet the specification requirements for frequency of testing

before additional fill was placed. This deficiency should have

been identified by the prior review of all soil test reports

accomplished under NCR S-5-5-0006 and NCR 174.

The 16 zones were accepted by S&L on the following basis:

Deviation in portions of the documentation does not

necessarily dictate nonconforming physical properties in the

fill.

Zones in question were constructed with procedures similar to

procedures used to construct the rest of the fill.

Average density of the fill is greater than that required by

specification.

Small isolated confined pockets low in the fill will not

influence the overall performance of the fill.

The daily earthwork logs and the basis for the disposition of the

NCRs reviewed by the NRC CAT inspectors are not considered adequate

for the following reasons:

The applicable specifications and procedures were changed four

times during the placement of the fill. These revisions may

not have been sufficiently addressed by S&L's resolution of the

NCRs.

Some of the records did not show lift thicknesses used. In some

cases incorrect lift thicknesses were used.

The evaluation performed for the NCRs did not adequately

address the discrepancies found by the NRC CAT with the

apparent omissions in data for evaluations performed of soil

test data.

V-8

_. - . -_ . . . _

t

The acceptance of failed sand cone test data based on nuclear

density test data was inconsistent with the specifications.

The intent was to have the less reliable nuclear density test

, data supported with direct, sound sand cone test data and not

vice versa.

Based on our limited review, there was no indication of the

size of unacceptable fill pockets.

c. Conclusion

The licensee's program of corrective actions did not result in a

timely, comprehensive evaluation and appropriate disposition of

known deficiencies in the testing and placement of structural fill

for the period reviewed by the NRC CAT. The deficiencies found in

the lift thickness of structural fill were also not identified or

addressed by the corrective action taken. Therefore, current

corrective action to ensure the adequacy of the structural fill

requires additional management attention.

4. Diesel Generator Exhaust Silencer Supports

a. Inspection Scope

,

Installed torque values were checked for the sliding connections

of the support pedestals of the diesel generator exhaust silencers.

'

Installation procedures required the nuts to be hand tight.

b. Inspection Findings

From the testing of the exhaust silencer support sliding connection

bolts, only one of the bolts were hand tight. Installed torque

values found by the NRC CAT are shown in Table V-9.

c. Conclusion

An evaluation should be made concerning the over-tightened condition

of the bolts. These bolts should not prevent the exhaust silencers

from sliding as designed for thermal growth.

!

V-9

_ - - - - - _ . - _ . _ _ _- - - _ _ .- _ ._. - _ - _ - . _ - _ __ -- _ _

__ ._. -- - - - _ _ _ .

- -- - _

VI. MATERIAL TRACEABILITY AND CONTROL

A. Objective

a

The objective of this portion of the inspection was to examine trace-

'

ability and control of material and equipment and to determine the

adequacy of the licensee's program relative to these activities.

B. Discussion

The approach to perform the inspection was to identify and select

samples of various types of installed material and equipment for

examination. Some samples of installed material that were not

! accessible, such as rebar, were selected from records. The samples

also included uninstalled material that had been QC inspected, such as

, protective coating materials, located in warehouses or shops. A total

of 293 samples were examined.

,

'

The following Baldwin Associates Project Procedures (BAP) provided the

acceptance criteria for this inspection:

BAP 1.5, " Material Identification," Rev. 11, dated December 18,

1984; Change D, dated May 23, 1985

BAP 2.3, " Receiving and Issuance," Rev. 12, dated July 26,

1984; Change F, dated April 25, 1985

BAP 2.3.2, " Transfer of Material IP to BA," Rev. O, dated

April 19, 1985

• BAP 2.8, " Material Upgrading," Rev. 8, dated October 26, 1984;

Change A, dated March 28, 1985

• BAP 2.19, " Welding Filler Material Procurement, Storage and

Control," Rev. 3, dated June 19, 1984; Change B, dated December

18, 1984; Change C, dated May 31, 1985.

An inspection of installed material and equipment was conducted in the

plant to select and verify markings on various samples such as equipment

'

(mechanical, electrical and instrumentation), pipe, supports / restraints

and weld joints. Other samples were inspected in warehouses or shops.

,

Table VI-1, Summary of Samples, indicates the types and quantities of

materials examined. Table VI-2, Weld Filler Material Compliance,

contains a list of the 17 weld filler material samples selected.

1. Material Traceability and Control

a. Inspection Scope

A total of 293 samples were selected and examined for traceability

to applicable drawings, specification, procurement, records,

j certified material test reports, certificates of compliance, heat

l

numbers or other required documentation.

VI-1

4

--~..-----w- - --,--- ,. . ., ,~, -,,-----,--,,---.-,----,--,-r- . - - , - - - - , , , - , .

b. Inspection Findings

In general, it was found that the traceability and control of

material at the site was satisfactory, with the exception of a lack

of traceability for certain fastener materials. The following

observations were made by the NRC Construction Appraisal Team (CAT)

inspector:

(1) Manual and computerized records were used to control the

identification and status of material and equipment at the

site.

(2) Seventeen samples of weld filler materials listed in Table

VI-2 examined for traceability and compliance with specifi-

cations and codes were found to be acceptable. Twenty-three

weld filler material holding ovens ir, two issue stations were

examined and found to meet requirements for temperature control

and the thermometer calibration records. The holding tempera-

ture of 18 loaded portable ovens in the issue stations was

measured using a pyrometer, and were found to be within the

established temperature range. Approximately 100 portable

ovens in use were examined, and only two were found to be not

operating satisfactorily. The heater indicator lights on these

two ovens were not lit, and rods were warm to the touch but

lower than 125 F, the specified temperature. The light of one

unit lit when the power plug was moved in the outlet. The

other oven was checked at the issue station and found to be

operating properly. The problem was identified as a loss

of power at the work station.

(3) Indeterminate American Society for Testing and Materials

(ASTM) A-36 steel plate material, which had been reported to

the NRC as a potential 10 CFR 50.55(e) deficiency (55-84-18),

is being stored in a segregated outside storage area. The

area is roped off and clearly marked to show that this material

is on HOLD.

(4) The inspector observed subdividing of stock materials by

warehouse personnel. Prior to making the cut in steel plate

and structural steel, the identification marking was trans-

ferred to each piece cut from the stock.

l (5) Material and equipment listed in Table VI-l were examined for

! traceability and control. Most items examined were found to

have the required material traceability; however, some

deficiencies were found regarding the traceability and control

for large motor mounting bolts and other fastener materials as

follows

Mounting bolts used in the transition piece between certain

large pump-motor units as listed below are not traceable

and do not have required washers. Documentation identifies

that American Society of Mechanical Engineers (ASME)

SA-193, Grade 87 bolts are to be used between the transi-

VI-2

-_. __- __ . _ _ _ . _ . _ _ _ _ ._

- - -

-.

tion piece and the pumps. Documentation does not identify

the grade of bolts to be used between the transition piece

and the motors. ASME SA-193, Grade B7 bolts were installed

between the transition piece and the pumps. Society of

Automotive Engineers (SAE), Grade 5 bolts were installed

between the transition piece and the motors. The supplier,

General Electric Company, stated in a telephone conversa-

tion to the licensee (to be followed up by a letter) that

SAE, Grade 5 bolts were adequate for this application.

Additional investigation is required to confirm the proper

bolts required for this application. However, no Noncon-

forming Material Report (NCMR) was issued by the licensee

during the NRC CAT inspection regarding the use and dis-

position of SAE, Grade 5 bolts. The pump motcr units

inspected and the NCMRs issued for the omission of washers

only, are as follows:

Low Pressure Core Spray Pump: lE21-C001 - NCMR 2-0330

High Pressure Core Spray Pump: lE22-C001 - NCMR 2-0331

Residual Heat Removal Pump: lE12-C002

Bolts installed to hold the Fuel Pool Cooling Pump motors

1FC02PA and 1FCO2PB to the skids are unmarked or incon-

sistently marked and of indeterminate material. ASTM A325

bolts are required. As a result of this NRC CAT finding,

the licensee issued NCMR 02-0340 to initiate corrective

action.

• Bolts installed to hold the Reactor Core Isolation Cooling

Pump 1E51-C001 to the skid are marked SAE, Grade 5 where

ASME SA-193, Grade B7 is specified. The turbine (lE51-C002)

hold down bolts are unmarked and indeterminate. The

coupling end requires American Iron and Steel Institute

(AISI) GR 4037-4140, and the governor end requires ASTM

A108-Gil70. As a result of these NRC CAT findings, the

licensee issuea .NCMR 02-0347 to initiate corrective action.

Nuts on clamp bolts at the lower end of a number of spring

can hangers in the recirculation piping are not properly

traceable. As a result of this NRC CAT finding the

licensee issued Nonconformance Report (NCR) 71314 to

initiate ccrrective action.

The load pin on hanger lLP02004V is an ASME Section III,

Class 2 pin used in a Class 1 application. As a result

of this NRC CAT finding the licensee issued NCR 32360 to

initiate corrective action.

Mounting bolts for HVAC control panel cabinets were

unmarked and of indeterminate material. Refer to Section

II.B.3.b(7), of this report, for details.

(6) ASME piping, tubing and welded joints inspected were marked

with the necessary traceability markings, except for a

VI-3

j

_

1/2 x 3/8 inch pipe-to-tube weld adapter in an instrument

tubing run. The travelers for installation of this adapter

identified an incorrect Receiving Inspection Report (RIR 886)

which should have been RIR 6886. The licensee issued NCR

32336 to correct documentation associated with this adapter.

(7) While inspecting the Control Rod Drive Mechanism, the inspector

noted that direction control valve No. 123 had an arc strike

which burned a hole through the solenoid housing. The licensee

issued NCMR 2-0246 to initiate the necessary corrective action.

(8) Unmarked bolting materials, without manufacturer's identifica-

tion, for non-ASME applications are purchased safety, commercial

grade, with certificates of conformance. This material and

documentation are receipt inspected by Illinois Power Company's

Quality Control before releasing for construction.

c. Conclusions

In general, except for certain fastener hardware, the material

traceability and control program was considered to be satisfactory.

Lack of traceability was found for fastener materials, particularly

for some vendor supplied pump-motor and pump-turbine assemblies

mounted on skids. Also, deficiencies were found in traceability for

fasteners on certain hangers and HVAC control panel cabinets.

2

VI-4

- - . - ___ . _ - _ . _ - . _

__.-. - _._ _ _ - ,--- - _ - - _ - _ . -_

TABLE VI-1

SUMMARY OF SAMPLES

Item No. of Samples *

Equipment 14

Pipe 22 (L)

Tubing (Weld Joints) 19 (L)

Steel-Structural 18 (L)

Steel-Rebar 3 (L)

Steel-Tube 19 (L)

Hangers / Supports / Restraints 4 (L)

Embedments 16

Valves 7

Mounting Bolts & Nuts 40

Weld Filler Material 17 (L)

Weld Joints 17

Electrical Cable (Reels) 24 (L)

Fasteners (Sets) 36

Coatings 9 (L)

Unistrut 5 (L)

Raceway 6 (L)

Shims 1 (L)

TOTAL 293

• (L) = Lots

VI-5

.__g _ .a ..__m _. a__ -

_a # 2:v+- - - . a m--._.-_u 1

TABLE VI-2

WELD FILLER MATERIAL COMPLIANCE

Material Heat No./ Compliance

Designation Material ID Comments

E7052 065094 Acceptable

,

E70S2 32470 Acceptable

E7052 065162/065163 Acceptable

E308-16 3/32 616385 Acceptable

E308-16 5/32 6MSB Mix 12 Acceptable

E308-16 3/32 49986 Acceptable

E308-16 1/8 0A0369 Acceptable

I E309-16 3/32 0A10742 Acceptable

E316L-16 3/32 01353 Acceptable

E316L-16 1/8 02754 Acceptable

i E502-16 1/8 432LO491 Acceptable

E502-16 3/32 421P4461 Acceptable

E7018XLM 3/32 402A9061 Acceptable

E7018XLM 1/8 22340 Acceptable

. E7018 1/8 40461 Acceptable

'

E7018 3/32 LOT 28112 Acceptable

E7018 3/32 28296 Acceptable

!

i

VI-6

i

_.

..-,- - . .- . -. -__ _ . . _ _ , - _ . _ _ . . _ . , _ - - - - _ _ _ - - _ _ . . .. -.-

VII. DESIGN CHANGE CONTROL

A. Objective

The primary objective of the appraisal of design change control was to

determine whether the design and other related documents and activities

which defined the installation and inspection of the as-built configu-

ration, were controlled in accordance with regulatory requirements,

Safety Analysis Report commitments and approved licensee, engineer, con-

structor and vendor procedures.

B. Discussion

The governing regulatory requirements for this appraisal are detailed in

10 CFR 50, Appendix B, Criterion III, " Design Control," and Criterion

VI, " Document Control." These requirements are elaborated in Regulatory

Guide (RG) 1.64, " Quality Assurance Requirements for the Design of

Nuclear Power Plants," Rev. 2, dated June 1976, and American National

Standards Institute (ANSI) Standard N45.2.11-1974, " Quality Assurance

Requirements for the Design of Nuclear Power Plants." The licensee's

commitment to comply with RG 1.64 is stated in Chapter 17 of the Clinton

Power Station (CPS) Nuclear Power Plant Final Safety Analysis Report

(FSAR).

In the area of design charge control, the NRC Construction Appraisal

Team (CAT) inspectors reviewed controlled documents which defined the

installation and inspection of completed structures and hardware, and

which defined or referenced design changes to in process or completed

structures and hardware. The NRC CAT inspection also reviewed the

Baldwin Associates (BA) installation and inspection program and the

Illinois Power (IP) Overinspection program. For each of these areas,

NRC CAT inspectors conducted interviews with responsible personnel,

reviewed drawings, procedures, specifications, change documents and

reports, and reviewed installed and inspected structures and hardware.

IP provided responses for the majority of the NRC CAT findings

documented in this section of the report. Where the IP response was not

considered sufficient to resolve the NRC CAT finding, this is speci-

fically noted.

1. Control of Design Documents

Inspection Scope

a.

The following documents provide the basic acceptance criteria for the

inspection:

Sargent & Lundy Engineers (S&L) General Quality Assurance (QA)

Procedure GQ-3.07, "Sargent & Lundy Drawings," Rev. 6, dated October

21, 1981

S&L General QA Procedure GQ-3.12, " Project Status Reports," Rev. 4,

dated August 24, 1984

VII-1

. _-__

l

!

S&L General Quality Assurance Program Topical Report SL-TR-1A,

Rev. 6, dated April 22, 1983

BA Quality Assurance Manual, Rev. 15, dated April 5, 1985

I

BA Project Procedure BAP 2.0, " Document Control," Rev. 13,

Change B, dated April 5, 1985

BAP 2.0.1, " Instructions for Maintaining Project Procedures /

Specifications / Drawings," Rev. 2, Change B, dated January 31,

1985

IP Nuclear Power Construction Quality Assurance Manual, Rev.

12, dated March 12, 1985

IP Nuclear Power ASME Quality Assurance Manual, Rev. 5, dated

March 5, 1985

IP Records Management System Standards No. 2.05, " Standard

for the Maintenance of Distributed Documents," Rev. 1, dated

March 7, 1985

IP Nuclear Planning and Support Department (NP&S) Procedure No.

2.51, " Document Control Procedure," Rev. O, dated June 11,

1985.

NRC CAT inspectors interviewed engineering and construction personnel

engaged in the distribution and control of S&L design drawings and

specifications, BA design installation drawings, BA installation

and inspection procedures, and vendor drawings.

b. Inspection Findings

The primary intent of this review was to assess the adequacy of the

design document control program implemented by the constructor,

Baldwin Associates, for ensuring that correct S&L or BA design

documents were utilized for installation. This review was conducted

at the BA Document Control Center (DCC), the BA resident engineering

(RE) offices in the civil and structural, piping and pipe support,

and electrical disciplines, and at the BA Field Document Center

(FDC).

(1) The DCC distributes procedures, specifications, design drawings

and associated change documents which are controlled in

accordance with the BA QA Manual, BAP 2.0, " Document Control,"

and BAP 2.0.1, " Instructions for Maintaining Project Proce-

dures/ Specifications / Drawings."

Section 5.3 of BAP 2.0.1 requires that recipients of amendments

and addenda to specifications check all transM tted documents

for accuracy against the DCC transmittal, update the speci-

fication in accordance with the transmittal instructions,

replace superseded pages, verify that all change documents

identified on the transmittal as outstanding are filed in front

VII-2

_ _ _ _ _ _ _ _ _ - - _ - - _ _ _ _ _

, - -- - - -- . - . . - . - - - - - - _ - _ _ .-

of the specification, and sign, date and return a copy of the I

transmittal to the DCC.

Section 5.4 of BAP 2.0.1 requires that recipients of change

documents issued against specifications check the documents

for accuracy against the DCC transmittal, revise the speci- .

, fication in accordance with transmittal instructions, remove

affected specification sheets or forms and destroy or return to

!

'

DCC as directed, file the change documents in the front of the

specification, and sign, date and return a copy of the trans-

mittal to the DCC.

Section 5.5 of BAP 2.0.1 requires that recipients of change

documents [ Field Change Requests (FCRs), Nonconformance Reports

(NCRs), Engineering Change Notices (ECNs), and Field Engi-

neering Change Notice (FECNs)] issued against a drawing, check

the documents for accuracy against the DCC transmittal, update

the change documents block to reflect the change document

-

numbers, maintain a file of open change documents, and sign,

1

date and return a copy of the transmittal to the DCC.

Section 5.7 of BAP 2.0.1 requires that recipients of revisions

to procedures check the documents for accuracy against the

DCC transmittal, remove superseded forms or procedures and

insert new or revised procedures or forms in accordance with

transmittal instructions, and sign, date and return a copy of

, the transmittal to the DCC. '

I While BAP 2.0.1 controls the transmittal, distribution and

receipt of changes to specifications, procedures and drawings,

'

'

the overall status of all change documents outstanding against

a given specification or drawing is provided by the Document

Management System (DMS), a computer data base which is updated

by DCC as required by Section 5.1.4 of BAP 2.0.

Sections 6.4.2 and 6.4.3 of the BA QA Manual mandate a computer

data base which maintains accountability and current status of

all documents received or issued at the site including design,

fabrication and installation drawings, design specifications,

change documents and work packages and travelers. There are i

i currently two computer data bases in use at the CPS which

address this requirement: DMS, which lists active change

documents issued at the site against the corresponding speci-

fications and design drawings, and Construction Management

Information (CMI), which lists all design change documents and

the affected design drawings and specifications. A Traveler

Tracking System (TTS), which is a subset of CMI, lists the

status and location of traveler documents, and can optionally

reference the associated design and change documents. IP is

'

now in the process of developing a computer data base system to

l provide for better tracking and integration of data in these

'

computer data basis systems.

4

1

] VII-3

- - - -

(2) Tables VII-1 and VII-2 list the drawings, specifications and

procedures selected for review, as well as the BA locations

where copies of these controlled documents were accessed. For

this documentation sample, the following information was

accessed: the S&L transmittal letters, the DCC transmittal

documents, the DMS computer data base lists of the active

change documents posted against each drawing and specification,

and the index to the latest revisions of the BA installation

and inspection procedures.

Controlled copies of the drawings, specifications and proce-

dures listed in Tables VII-1 and VII-2 were reviewed in the RE

offices and the FDC to check that specifications were properly

amended and that no superseded materials were present, and that

the change documents posted with the specifications were

consistent with the DMS computer data base listings of active

change documents for those specifications. Drawings were

checked to confirm that the latest revision of the drawings

were with the stick file and that the active change documents

listed in the change documents blocks by authorized BA

personnel were consistent with the change documents listed in

I

the DMS computer data base. The BA installation and inspection

procedures were checked to confirm that the latest revisions to ,

the procedures were posted, and that no superseded materials

were present.

The NRC CAT inspectors identified three categories of defi-

ciencies during the course of this review: the presence of

superseded or voided portions of specifications and procedures,

or inconsistencies between procedures; discrepancies between

the active change documents listed in the DMS computer data

base for a given specification and the change document

included with that specification; and discrepancies between the

active change documents listed in the OMS computer data base

for a given drawing and the change documents included on the

change documents block.

(3) The NRC CAT inspectors documented the following discrepancies

relative to superseded or voided portions of specifications and

procedures, inconsistencies between procedures, and of one

instance of drawing illegibility:

A superseded copy (dated March 4, 1985) of the S&L Document

Index System Foreign Document Report was on file at BA

civil / structural (C/S) RE. This document is distributed by

BA DCC as received on site from S&L. Distribution of this

!

document is not controlled in accordance with BAP 2.0 and

its presence without stamping as an uncontrolled item could

result in the RE's inappropriate use in preparation of work

packages.

The BA C/S RE-12 controlled copy of the BA Project Proce-

j dures Manual contained superseded copies of BAP 1.1 and BAP

t 2. 0.1. BAP 2.11 contained an Attachment A that was not

l

VII-4

.

formally listed as an attachment in the procedure. BAP

2.41 was incorrectly filed under tab number 2.40, but BAP

2.40 was not on the distribution list for that controlled

copy. A superseded copy of BAP 3.1.8 was incorrectly

! filed under tab number 3.1.4; however, the current revision

of BAP 3.1.8 was correctly filed.

FDC files CL-series drawings on aperture cards. The five

CL-series drawings listed in Table VII-2 were requested for

review. The aperture caros identified the correct revision

numbers for the drawings, but were stamped "0RIGINAL DRWG.

NOT LEGIBLE FOR MICROFILM." Blowbacks of the cards con-

firmed drawing illegibility. An examination of the

full-size sepias at DCC indicated that one of the five

sepias could not be legibly reproduced. Whether the

illegible sepia was used in producing drawings included

with a traveler needs to be verified and the affect of its

use on construction determined.

Amendment 5 to the FDC copy of S&L specification K-2947

and Amendment 11 to the FDC copy of S&L specification

K-2948 had not been incorporated into the specifications.

Voided pages were not removed.

The BA Traveler Preparation Review Group (TPRG) copy V-530

of S&L specification K-2882 contained a superseded copy of

seven page Attachment 322.

BAP 2.1.6 was filed with the TPRG copy of the BA Procedures

Manual, although shown deleted in the table of contents.

BA QA Manual, subsection 6.5.3.1, requires that design

change documents be " posted and distributed by the Document

Control Center to the affected drawings or work controlling

documents as noted on the design change document." BAP

2.0.1, subsection 5.5, requires the recipient of a change

document to maintain a file of open change documents.

However, BAP 2.0, subsection 5.1.3 was revised on April 5,

1985 to note that stamp affixed change documents will no

longer be distributed directly to the holders of the

affected documents. This revision of BAP 2.0 is incon-

sistant with the current requirement of the BA QA Manual.

The interim IP response provided during the NRC CAT inspec-

tion does not adequately address this finding. ,

(4) The following discrepancies were documented between the active

change documents posted in the DMS data base for a given

specification and the change documents posted with that

specification.

I FCR 35687 was not filed with the FDC copy of S&L speci-

l fication K-2947, but was listed in DMS. IP indicated

'

that FCR 35687 is stamp affixed. IP will correct DMS to

list this change document as stamp-affixed.

VII-5

"

The following change documents were listed in DMS but were

not filed with the TPRG, V-530 copy of S&L specification

K-2882: ECNs 4511, 4822, 4832, 4853 and 5234; FCRs 1847,

26283, 26754, 28060, 30783 and 37478, and NCR 29249.

IP indicated that the DMS listing of the ECNs is correct,

and that copies will be posted with the specification; FCR

1847 is a stamp-affixed change document. IP will correct

DMS to list FCR 1847 as stamp-affixed. DMS correctly lists

the remaining FCRs and the NCR as outstanding against the

specification, and copies of these change documents will be

posted in the specification.

The following change documents were filed with the TPRG,

V-530 copy of S&L specification K-2882, but were not listed

in DMS: ECHs 3634, 3929, 3954, 3960, 3996, 4017, 4061,

4265, 4281 and 4291; FCRs 17682, 19020, 20351, 20605,

20667, 20687, 20742, 21243, 21404, 21770, 21899, 22227,

22578, 22607, 22666, 22677, 22678, 22867, 23129, 23193,

23360, 23640, 24317, 24407, 24559, 24654, 24682, 24655,

24940, 25431, 28071, 30185, 30328, 31502 and 36345; FCR

24416 was filed with the specification, and is not

stanp-3ffixed, but is listed in DMS as a stamp-affixed

change document. IP indicated that the ECNs and FCRs

listed above had all been superseded or incorporated, and

have been removed from the specification. IP will

correct DMS to list FCR 24416 as not stamp-affixed.

The following change documents were listed in DMS but were

not filed with the TfRG, V-460, (P/DRFT) copy of S&L

specification K-2882: ECNs 4832, 4853, 4858, and 4943;

FCRs 1847 and 34643, and NCR 29249. IP indicated that DMS

correctly lists the ECNs as active against the specifica-

tion, and copies of these change documents will be included

with the specification. IP will correct DMS to list FCR

1847 as a stamp-affixed change document. IP indicated

that DMS correctly lists FCR 34643 and NCR 29249 as active

against the specification, and copies of these change

documents will be posted with the specification.

The following change documents were filed with the TPRG,

V-460 (P/DRFT) copy of S&L specification K-2882, but were

not listed in DMS: ECNs 4380, 4469 and 4895; FCRs 22867,

24317, 28071, 30328 and 36345; FECNs 6639, 7529 # (stamp-

affixed) and 9478. FCR 24416 which was filed with the

specification and was not stamp-affixed, was listed as

stamp-affixed in DMS. IP indicated that the ECNs, FCRs

and FECNs listed above were all superseded change docu-

ments, and will be removed from the specification. IP will

correct DMS to list FCR 24416 as not stamp-affixed.

The following change documents were listed in DMS, but

were not filed with the FDC, V-300 (FDC/R) copy of S&L

specification K-2882: FCRs 1847, 6480 and 22962, and FECN

8778. FECN 6639 and FCR 1874 were filed with the speci-

VII-6

. _ _ _ _ _ _ _ _ _ _ - - _ _ -

fication but were not listed in DMS. IP will correct DMS

to list FCR 1847 as a stamp-affixed change document. IP

indicated that DMS correctly lists FCRs 6480 and 22962, and

FECN 8778 as outstanding against the specification, and

copies of these change documents will be posted with the

specification; FECN 6639 is a superseded change document;

and FCR 1874 is incorrectly posted with the specification.

Due to the results of the review of TPGR, V-460 and TPGR,

V-530 copies of specification K-2882, a followup review of

a third copy of the five controlled copies of this specifi-

cation was performed.

A new DMS printout was accessed and the 104 active design

change documents listed (all nonstamp-affixed) were

checked against the change documents filed with the TPRG,

V-460, (D-6) copy of specification K-2882. All change docu-

ments were on file, with one exception: NCR-0114 (one of

seven active NCRs). Approximately 200 pages associated with

Amendment 11 to the specification were also audited, using

the S&L transmittal listing the pages to be voided or

inserted. There were no deficiencies identified.

IP's response to NRC CAT findings for the initial two

copies (V-460 and V-530) of specification K-2882 reviewed

noted that these copies have been permanently returned to

Document Control and the third copy (06/V-460) will now be

used as the sole reference of the Piping Department.

Further, the licensee indicated that a full time Document

Control clerk has been assigned the responsibility for

maintaining the controlled documents of the Piping Depart-

ment.

The following change documents were listed in DMS but were

not filed with the TPRG, V-460, (D-6) copy of S&L speci-

fication K-2884: ECNs 4683; FCRs 29144 and 32822, and NCR

70021. FCR 24317 was filed with the specification, but was

not listed in DMS. IP indicated that DMS correctly lists

the ECNs, FCRs and the NCR as outstanding against the

specification, and copies of these change documents will be

posted with the specification; FCR 24317 is a superseded

change document and will be removed from the specification.

FCRs 27508 and 27545 were listed in DMS but were not filed

with the FDC copy of S&L specification K-2999. NCR 51358

was listed in DMS but was not filed with the specification.

FCR 7113 had been removed from the file of change documents

posted with the specification. IP did not provide an

interim response during the NRC CAT inspection.

FECN 5081 was filed with the V-465, E/McGUIRE copy of S&L

specification K-2999, but was not listed in DMS. IP did

not provide an interim response during the NRC CAT

inspection.

VII-7

_ -_-____ - ___ - __-___-__-_ . .-

(5) The following discrepancies were documented between the active

change documents posted in the DMS data base for a given

drawing, the change documents posted with the drawing, and the

change documents listed on the change documents block:

FCR 32933 is listed on the change documents blocks of the

C/S RE copies of BA drawing CL1-27-S-136 and S&L drawing

S27-1001-03B, but is not listed in DMS. IP indicated that

FCR 32933 was superseded by FCR 37573 and removed from DMS

on May 22, 1985. The transmittal receipt returned to

DCC is dated May 24, 1985. The change documents blocks

were therefore not updated in a timely manner.

FCR 35968 is listed on the change documents block of the

C/S RE copy of S&L drawing S27-1003-03A, but is not listed

in DMS. IP indicated that FCR 35968 was superseded by FCR

37971 and was removed from DMS on May 25, 1985. The

transmittal receipt returned to BA DCC is dated May 28,

1985. The change documents block was therefore not updated

in a timely manner.

NCR 29699 is listed on the change documents block of the

C/S RE copy of S&L drawing S28-1002-02A. DMS lists NCR

29699 as stamp-affixed. IP indicated that DMS correctly

lists NCR 29699 as stamp-affixed. The change document

should not be posted on the change documents block.

FCR 25139 is not filed with the FDC copy of S&L drawing

S29-1422, but is listed in DMS. IP indicated that: DMS

correctly lists FCR 25139 as outstanding against the

drawing, and that a copy of the change document will be

posted with the drawing, the FCR is incorporated in both

travelers (53369 and S3370), and there is no impact on

hardware.

FCR 32686 is not filed with the FDC copy of S&L drawing

M09-1001N, but is listed in DMS. IP did not provide an

interim response for FCR 32686 during the NRC CAT inspec-

tion.

ECN 3332 and NCR 5351 R/3 were listed in DMS but were not

t

listed on the change documents block of the BA Start-Up

Field (SU-F) office copies of S&L drawings M-1SX01017R,

sheets 1 and 2. It appears that ECN 3332 has already been

incorporated into the drawings. IP indicated that ECN 3332

should not be outstanding against the drawing, and DMS will

be corrected. IP did not provide an interm response on NCR

5351 R/3.

FCR 27389 is listed in DMS but was not listed on the

change documents block of the BA SU-F copy of S&L drawing

M-1SX01048X. IP indicated that DMS correctly lists FCR

27389 as outstanding against the drawing. The transmittal

receipt returned to BA DCC is dated August 29, 1984. The

change documents block was therefore not properly updated.

VII-8

____________

-

ECN 3332 is listed in DMS but was not listed on the change

documents block of the SU-F copy of S&L drawings M-2SX01028R,

sheets 1 and 2. It appears that ECN 3332 has already been

incorporated into the drawings. IP indicated that ECN 332

should not be outstanding against the drawing, and DMS will

be corrected.

(6) NRC CAT inspectors reviewed the IP audit program to determine

whether the discrepancies identified in the construction design

change control area had previously been addressed by IP audit

personnel.

Sections 18 of the IP Nuclear Power American Society of

Mechanical Engineers (ASME) QA manual and the IP Nuclear Power

Construction QA manual define the requirements for a planned

system of periodic audits to verify compliance with the quality

assurance program at CPS.

The IP audit program is also discussed on page IV-30 of IP

report, Results of Quality Programs for Construction of Clinton

Power Station, with Appendices, NRC Docket No. 50-461, dated

February 1985. Appendix B of that report summarizes each of

the IP QA audits of the BA and IP organizations that were

scheduled and performed for the period 1982-1984.

Table VII-3 lists the sample of IP audits of activities

reviewed by the NRC CAT inspectors. The activities reviewed by

IP, as well as audit findings, indicate that a number of the

NRC CAT inspection design document control findings in this

report were similar to those previously identified by IP. For j

example, IP audit report Q31-83-8, dated July 28, 1983, audit

finding PD-1, noted that BA procedures did not describe the

activities associated with the use and updating of the DMS,

CMI or Aquarius (a historical file) computer programs. IP

audit personnel also documented discrepancies between these

computer programs, and documented additional discrepancies when

these computer programs were compared to the specific design

documents and the Document Review and Record cards. This audit

finding was closed by IP on May 23, 1985. In another example,

IP audit report Q31-85-02, dated April 4, 1985, audit finding

10-1 noted seven procedure updating discrepancies in nine

,

copies of BAP QC piping and mechanical field office manuals.

Therefore, IP has implemented an audit program to verify

compliance with the design document control provisions of the

quality assurance program at CPS. However, based on NRC CAT

findings, IP audit program corrective actions were not

effective since the acti^n -taken did not provide for the

prevention of the excest.ve deficiencies identified by the NRC

CAT.

VII-9

-- _ _ _ _

_ _ - _ ..

c. Conclusions

Design document control is generally acceptable for the overall

scope of items sampled with the exception of the high rate of

discrepancies identified in certain areas. These included the

updating of procedures for the one sampled copy of a project pro-

cedures manual, and the discrepancies between the active change

documents listed in the DMS computer data bases against two con-

trolled copies of piping design specification K-2882 and the change

documents physically posted with each copy of the specification. In

addition, examples of other discrepancies were identified such as:

the timeliness of updating change document blocks or design change

documents to be listed in DMS, the presence of an illegible sepia

drawing at DCC, and the inconsistency of the revision of BAP 2.0

with the BA QA Manual.

The examples of discrepancies identified by the NRC CAT - as cur-

rently present in the controlled project procedures and in the

listing of design change documents for controlled specifications,

drawings and their DMS computer data bases - are similar to the

deficiencies previously identified in those areas by IP QA audits

and, in part, by NRC Region III and Resident inspectors. Therefore,

the effectiveness of IP corrective action was apparently inadequate

.

IP interim responses to NRC CAT findings in this area generally

indicated that the causes of the individual discrepancies in design

change or procedure document control will be determined and that

corrective action would be taken. IP needs to address the generic

implications of NRC CAT findings for the types of discrepancies

identified in the the project procedures manual and specification

K-2882.

2. Control of Design Change Documents

a. Inspection Scope

The following documents provide the basic acceptance criteria for

the inspection:

,

IP Corporate Nuclear Procedure (CNP) 3.03, " Nonconforming

l Material Report," Rev. 4, dated July 18, 1984

l IP Nuclear Station Engineering Department (NSED) Procedure

D.8, " Handling Clinton Power Station Field Change Requests,"

Rev. 4, dated September 27, 1984

IP NSED Procedure D.9, " Handling Clinton Power Station

Field Problem Reports," Rev. 3, dated July 17, 1984

IP NSED Procedure D.12, " Preparation and Control of Field

Engineering Change Notices," Rev. 1, dated November 19,

1984

VII-10

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _

IP CPS Procedure D.7, " Handling Clinton Power Station

Nonconformance Reports," Rev. 6, dated February 28, 1985

IP Nuclear Power Construction Quality Assurance Manual,

Rev. 12, dated March 12, 1985

IP Nuclear Power ASME Quality Assurance Manual, Rev. 5,

dated March 5, 1985

IP Records Management System Standards No. 2.05, " Standard

for the Maintenance of Distributed Documents," Rev. 1,

dated March 7, 1985

IP NP&S Procedure No. 2.51, " Document Control Procedure," Rev.

O, dated June 11, 1985

S&L General QA Procedure GQ-3.07, "Sargent & Lundy Drawings,"

Rev. 6, dated October 21, 1981

S&L General QA Procedure GQ-3.13, " Engineering Change

Notices," Rev. 6, dated October 21, 1981

S&L General QA Procedure GQ-3.15, " Approved Procedural

Deviations," Rev. 1, dated January 26, 1981

S&L General QA Procedure GQ-4.01, " Procurement Specifica-

tions," Rev. 10, dated August 15, 1983

S&L Project Instruction PI-CP-003, " Processing a Baldwin

Associates Field Change Request or Nonconformance Report,"

Rev. 13, dated May 31, 1984

l

S&L PI-CP-004, " Control of Clinton Engineering Change

Notice (ECN)," Rev. 10, dated November 7, 1984

"

j S&L PI-CP-021, " Processing an Illinois Power Company Field

Problem Report," Rev. 5, dated November 7, 1984

S&L PI-CP-022, " Control of Clinton Field Engineering

Change Notices (FECN)," Rev. 5, dated October 5, 1984 l

!

S&L PI-CP-046, " Processing an Illinois Power Company l

Nonconforming Material Report (NCMR)," Rev. 2, dated l

October 10, 1984 '

BA QA Manual, Rev. 15, dated April 5, 1985

BAP 1.0, "Nonconformances," Rev. 16, dated March 28, 1985

BAP 1.2, " Field Change Requests," Rev. 12, Change C, dated

November 19, 1984

BAP 2.0, " Document Control," Rev. 13, Change B, dated April

5, 1985

VII-11

_ _ _ _ _ _ _ _

-

BAP 2.0.1, " Instructions for Maintaining Project Proce-

dures/ Specifications / Drawings," Rev. 2, Change B, dated

January 31, 1985.

NRC CAT inspectors interviewed engineering and construction person-

nel engaged in the distribution and control of design change

documents.

b. Inspection Findings

Site issued design change documents are processed through the DCC

and distributed, with the recent exception of stamp-affixed change

documents, to all locations which maintain controlled copies of the

affected drawings and specifications, and to all affected travelers.

DCC updates the DMS computer data base to indicate that a given change

document has become active against a drawing or specification, and

copies of all active change documents are maintained with drawings

and specifications. New travelers are issued, or supplements to

existing travelers are issued, to incorporate newly-issued change

documents which impact in progress or completed structures and hard-

ware. Change documents must be referenced on, and physically

attached to, these work packages. As previously noted, TTS, the

computer data base which lists the status and location of traveler

documents, does not currently mandate that active change documents

be listed in TTS. As a consequence, travelers affected by a given

design change document could not always be readily identified. This

is not consistent with the requirements of Section 17.4 of the BA QA

manual, which commits BA to an index system for records to be

maintained in the Documents Record Center which will ensure the

rapid and orderly identification and retrieval of records.

NRC CAT inspectors selected the 24 design change documents listed

in Table VII-4. In majority, the sample was selected from the change

document discrepancies the NRC CAT inspection had documented in Sec-

tion VII.B.1.b.(4) above, for a number of the controlled specifica-

tions available to REs for use in the preparation of work packages.

The review was primarily performed to assess the extent design change

documents not properly included with the specification may not have

been implemented in work packages prepared by REs utilizing those

specifications. IP was requested to provide the NRC CAT with an

example of documentation which substantiated the intended disposition

of each of the 24 selected change notices. The NRC CAT review of

the documentation provided by IP assessed the actual disposition of

each design change document for its incorporation in a work package,

i.e., either an amendment to a specification, procedure or a purchase

order, or supplement to a traveler. The NRC CAT review identified

the following discrepancies:

BA equipment installation traveler RH-024 does not appear to

have been revised to incorporate FCR 27508. The change docu-

ment is dated August 25, 1984, and waives the provisions of

American Welding Society (AWS) D1.1, paragraph 8.2.3 for

qualification for weldability of American Iron and Steel

Institute sAISI) C1010 to C1025 sheet steel. The change

VII-12

79-- -

.

document requires that specification K-2999 be amended to

incorporate this waiver. DMS still lists FCR 27508 as out-

standing against the specification.

ECN 5282, dated June 3, 1985, allows the use of ASME Code

Case N-413, Minimum Size of Fillet Welds for Linear Type

Supports,Section III, Division 1, Subsection NF. Box 7 of the

change document was marked in error as it indicates

that an FSAR revision is not required. However, the IP letter

S-5454 dated May 22, 1985, which is referenced in the ECN,

indicates that IP will draft an amendment to the CPS FSAR for

the use of this code case. NRC's letter of April 30, 1985 to

IP indicates that the referenced code case may be used at the

CPS.

FCR 27545 documents HVAC and electrical attachments welded

to structural steel that were fireproofed without prior appli-

cation of a galvanox coat. The FCR requires that specifica-

tions K-2910 and K-2999 be revised to permit a direct appli-

cation of CAFCOTE H fireproofing directly over welds which are

"

clean and free from slag and debris. The original nonconform-

ing welds should have been documented on an NCR for an evalua-

tion as to their acceptability.

This review resulted in identifying only one instance where the

change document (FCR 27508) was not referenced on the appropriate

traveler revision, and two other apparent discrepancies in docu-

mentation. However, the sample of change documents listed in Table

VII-4 is not considered sufficiently large to confirm the actual

implementation of all design change control discrepancies identified

by the NRC CAT. The NRC CAT also could not confirm that the sample

of work packages provided for review were prepared through the RE

use of the TPRG V-530 and V-460 copies of the K-2882 controlled

specification found to contain an excessive number of deficiencies

in omitted design change documents. Further, the NRC CAT followup

review of a third copy of the five controlled copies of Specifica-

tion K-2882, found only one such deficiency. This indicates that

travelers prepared by use of this third specification most likely

would implement the design change documents not included with the

V-530 and V-460 copies of the K-2882 specification. Therefore, the

results of the verifications of the sample of work packages provided

for NRC CAT review may not be representative of the disposition of

the excessive change notice discrepancies identified in two of the

five K-2882 specifications initially examined by the NRC CAT inspec-

tor.

c. Conclusions

The program for control of design change documents was generally

determined to be in accordance with site procedures, with one

exception. The exception pertains to an inconsistency between the

program instructions for TTS and the Index System of records. TTS

instructions allow that active design change documents need not be

VII-13

listed in TTS for a given traveler. This option for TTS does not allow

for the ready identification of travelers affected by a given change

notice. On the otherhand, the Index System for Records is required

to be maintained in a manner which will ensure the rapid and orderly

identification and retrieval of records. It is noted that IP's

current effort to integrate data in DMS and CMI into one data

system should resolve this inconsistency in procedural requirements.

For the sample of 24 change documents and related implementing

documents examined by the NRC CAT inspectors, all but one of the

change documents was verified to be implemented as intended in a

work package, i.e., either an amendment to a specification, proce-

dure, or purchase order or supplement to a traveler. However,

the NRC CAT findings also indicated that IP corrective action, as

discussed in Section VII.B.1.c above, is warranted.

3. Illinois Power Company Overinspection Program

A consideration of the NRC CAT's selective examinaticns discussed in

most sections of this report was to include examination of a sample

of installed hardware that had been subject to the IP Overinspection

Program.

The IP Overinspection Program was implemented in response to a

series of stop work actions imposed in 1981 and 1982 due to iden-

tified deficiencies in the implementation of the BA QA Program for

construction of various areas of CPS. The IP Overinspection Program

provides two levels of additional inspection in the functional work

areas subject to the prior stop work actions. The two adcitional

levels of inspection of work previously inspected by BA QC include a

sample inspection conducted by the BA Field Verification (BAFV)

Group and a subsequent sample inspection by the IP Overinspection

(OI) Group. The intent and scope of the IP Overinspection Program

is summarized on pages V-1 and V-2 of 1P Report "Results of Quality

Programs for Construction of Clinton Power Station", with Appen-

dices, NRC Docket No. 50-461, dated February 1985. As noted

therein:

The purposes of the Overinspection Program are to verify

that the structures, systems, and components within the

scope of the program are properly installed and to provide

IP with assurance that BA is performing installation and

inspection work that satisfies the applicable req,sirements

of codes, standards, drawings, and specifications. These

objectives are accomplished by performing additional inspec-

tions of completed and inspected work, whether performed

before issuance of stop work actions in 1982 (old work)

or after the stop work actions were lifted (new work). The

inspections conducted under the Overinspection Program are

in addition to those normally performed as part of the QA

Program for CPS. Therefore, the Overinspection Program is

a supplement to the QA Program and not a substitute for it.

VII-14

._

. .

,

Inspections in the IP Overinspection Program focus on installation

of safety-related, augmented class D (radioactive waste), and fire

protection items in the following areas: large and small bore

piping, mechanical equipment, structural steel, heating, ventilating

and air conditioning, electrical hangers, electrical conduit and

raceways, electrical terminations, electrical equipment, and

electrical and mechanical instrumentation.

Since the IP Overinspection Program supplements the BA QC program

and is not a substitute for that program, the NRC CAT inspectors

in the area of design change control reviewed the BA installation and

QC inspection work packages in addition to the IP Overinspection

Reports for the hardware sample listed in Tables VII-5 through

VII-7. Other NRC CAT examinations of hardware previously inspected

by the IP Overinspection Program are discussed in the other sections

of this report.

a. Inspection Scope

The following documents provide the basic acceptance for the

inspection:

BA Quality Assurance Manual, Rev. 15, dated April 5, 1985

BA Quality and Technical Services Organization Chart,

dated March 8, 1985

BA Quality Control Training and Qualification Manual,

Rev. 9, dated September 26, 1984

BAP 3.1.3, " Structural Steel Erection," Rev. 11, Change B,

dated May 17, 1985

BAP 3.2.5, " Piping Component Supports," Rev. 7, Change D,

dated May 13, 1985

BAP 3.3.6, " Electrical Raceway Support Installation," Rev. 10,

dated May 17, 1985

BAP 3.3.10, " Cable Tray Installation and Traveler Processing,"

Rev. 6, Change E, dated May 21, 1985

BAP 3.6.3, " Repair of Welds, Material and Items," Rev. O,

Change C, dated April 17, 1985

BAP 3.6.5, " Visual Inspections of Weldments," Rev. O,

Change B, dated March 26, 1985

IP Nuclear Power Construction Quality Assurance Manual,

Rev. 12, dated March 12, 1985

IP Nuclear ASME Quality Assurance Manual, Rev. 5, dated

March 5, 1985

VII-15 l

J

.

IP Nuclear Power Program Organizational Chart, dated

January 15, 1985

IP Quality Assurance Instructions QAI-710.01,

"Overinspection Program," Rev. 5, dated March 20, 1985

<

IP (AI-710-08, "0verinspection Sample Plar..," Rev. 3, dated

April 26, 1985

IP QAI-710.12, " Structural / Auxiliary Steel Oserinspection

Checklist," Rev. 7, dated February 22, 1985

IP QAI-710.13, " Mechanical Equipment Overinspection

Checklist," Rev.1, dated January 13, 1984

IP QAI-710.14, " Piping / Valves / Instrumentation

Overinspection Checklist," Rev. 4, dated November 15, 1984

IP QAI-710.15, " Component Support Overinspection

Checklist," Rev. 4, dated August 27, 1984

IP QAI-710.18, " Electrical Raceway Support Overinspection

Checklist," Rev. 2, dated February 21, 1985

IP QAI-710.19, " Electrical Raceway Support Overinspection

Checklist," Rev. 2, dated February 21, 1985

NRC CAT inspectors interviewed engineering and construction person-

nel engaged in the preparation and contro? of BA installation and

inspection work packages and IPOI reports.

b. Inspection Findings

Inspection findings for this review are categorized as discrepancies

in computer data bases, BA installation and inspection work pack-

ages, or in IPOI reports.

(1) As described in Section VII B.1.(b).(1) above, there are

currently two basic computer data 'asesu in use at CPS: DMS,

which lists active change documents issued at the site against

the correspcnding design drawings, and CMI, which lists all

design change documents and the affected design drawings and

specifications. TTS, which is a subset of CMI, lists the

status and location of traveler documents, and can optionally

reference the associated design and change documents.

The NRC CAT inspectors documented several discrepancies in

these computer data bases during the course of this review

of the use and relationship of the computer data with the

work packages prepared for BA installation and inspection

and IP Overinspection activities. These include:

VII-16

TTS lists the incorrect design drawing revision numbers for

the design drawing referenced in IPOI reports M-3330 and

M-3338.

A systematic weakness in DMS is it does not reference

the work packages and travelers associated with the S&L

structural steel design drawings.

A systematic weakness in TTS is it does not reference

th? design drawings associated with electrical cable tray

support travelers.

(2) There is no uniform relationship between the hardware detailed

on a design drawing and the number of BA work packages and

travelers prepared by each construction discipline to document

the installation and inspection of that hardware. As an

example, there is generally one-to-one correspondence between

the design drawing and the traveler for pipe and cable tray

supports, while for structural steel there are numerous work

packages and travelers associated with each structural steel

design drawing. Structural steel inspections were documented

on either inspection forms, vendor drawings or welding

travelers depending on whether the steel was vendor fabri-

cated, field fabricated, bolted or welded.

The NRC CAT inspectors note that the current computer data

bases program does not readily relate the associated design,

fabrication, installation and inspection documents. Since

there is no current correlation in DMS between the structural

steel design drawings and the associated work packages and

travelers, some documentation proved difficult to access and

audit. For example, BA required approximately one week to

access the welding travelers associated with the steel beams

listed in Table VII-5. Other NRC CAT inspectors indicated that

documentation proved difficult to access in their areas as

well. However, the requested work packages and travelers were

eventually accessed and, in general, were properly documented.

The NRC CAT inspectors noted a number of documentation discre-

pancies in the BA installation and inspection work packages.

These included an incorrect Receiving Inspection Report number

for a steel beam listed in a support traveler

(E26-1003-01A-H48, Rev. 11), an incorrect inspection attribute

indicated on two of three pre-inspection checklists filed with

a hanger traveler (E27-10002-018-H33), BA QC inspection forms

, for several steel beams do not reference the correct revisions

of the S&L design drawings, a steel plate listed on the bill of

materials but not used on the hanger drawing, and inconsist-

ancy in documentation relative to the use of the surveyors'

reports for verification of pipe support locations and Form

JV-718 for verification of electrical hanger locations in

containment.

VII-17

. - . .- -

(3) Illinois Power performed overinspection activities in accoi'd-

ance with a series of overinspection checklists which defined

the attributes to be inspected for a specific piece of hard-

ware. This list of attributes was generally a subset of the

attributes that had been BA QC inspected for that piece of

hardware.

The NRC CAT noted a number of generally minor documentation

discrepancies in the IP0I reports reviewed. These included

reports (S-0399, S-1490, M-3351, M-3329, E-3920) which

referenced an incorrect drawing number, or drawing or revision

number, an incorrect building elevation, or an incorrect FECN;

two reports (M-3349, E-3762) which did not document an inspec-

tion attribute or included the wrong form; and one report

(E-3623) which documents an incorrect drawing revision as being

used for the inspection.

In addition an inconsistency similar to that discussed in

Section VII.B.3.b.(2), above, relative to surveyors' reports

was found. QAI-710.18 requires location of electrical hangers

be verified to design drawings and Form JV-718 is used as the

documentation of the verification, while QAI-710.15 does not

require independent verification of pipe support locations in

containment, but does require that the surveyors' report to be

attached to the verification checklist.

As noted in Section III, Mechanical Construction, and Section V,

Civil and Structural Construction, of this report, the NRC CAT

physically inspected a sample of hardware associated with the IPOI

report work packages reviewed. This included four of the steel

beams listed in Table V-5 and six of the pipe restraints listed in

Table III-3. The purpose of the field inspection was to substan-

tiate the technical content of the IPOI reports, including the

affect of a number of the apparent documentation discrepancies on

the installation. No deficiencies in the installed hardware were

identified.

c. Conclusions

For the overall scope of documentation items sampled during tnis

NRC CAT review, the documentation of BA installation and inspec-

tion work packages and of IPOI reports, except for discrepancies

noted, is generally adequate.

The majority of the discrepancies documented for this review are

considered minor in nature. The two systematic weaknesses in the

computer basis (DMS and TTS) are considered to contribute to the

difficulty IP was having with the timely access of documentation.

The NRC CAT review of the approximately 400 documentation attributes

for the 25 IPOI reports examined found that the reports were

generally well documented relative to the overinspection conducted,

with some exceptions. In majority, the exceptions related to

documentation discrepancies which apparently had a minor effect on

VII-18

- - . - - - . .. . .. . . . . _ _ - . - . . _ - - - . .-

-

!

the overinspection conducted. However, these errors in documenta-

tion indicate that a more critical management review of the infor-

mation recorded on the IPOI reports should be performed.

I

a

)-

i

i

I

,

,

4

f

F

,

4

i

r

l

i VII-19

t

, . - . - . - - , - - . , - - , - , _ , - _ . , - - . , - - - ,a. , . , - - , - , - , _ , _ - - . . - - - - - - , - - - , - - - - - - - - , ~ , , . , - - -

. .- . - _. ._ . - ._ . - - . - - . - _

.

P

k

TABLE VII-1

SPECIFICATIONS AND PROCEDURES REVIEWED

i

Document ID Location (s)

.

S&L Spec. K-2882, Rev. 11 BA Traveler Preparation Review Group (TPRG) (3 copies)

!

BA Field Document Center (FDC)

! S&L Field Design Office

(to confirm filing of ECN 4832)

S&L Spec. K-2884, Rev. 8 BA TPRG

l. BA FDC

.

S&L Spec. K-2944, Rev. 27 BA Civil /Struc. (C/S) Res. Eng. (RE)

1 BA FDC

a

!

S&L Spec. K-2947, Rev. 5 BA C/S RE

BA FDC

i S&L Spec. K-2948, Rev. 11 BA C/S RE

BA FDC

S&L Spec. K-2999 Rev. 11 BA Electrical RE (2 copies)

BA FDC ,

t

Baldwin Project Procedures BA C/S RE

(various revisions.) BA TPRG

i

,

1

5

i

VII-20

4

v e e,- ..,.-----.n - . - , .

,.e... - ._-, ,. - -- ,- -, . _ - - - -.-, -_.,.-.---c

TABLE VII-2

DRAWINGS REVIEWED

Document ID Location (s)

S&L Dwg. S26-1705, Rev. E BA C/S RE & BA FDC

S&L Dwg. S26-1710, Rev. N BA C/S RE & BA FDC

S&L Dwg. S26-1407, Rev. Y BA C/S RE & BA FDC

S&L Dwg. S27-1001-03B, Rev. AH BA C/S RE & BA FDC

S&L Dwg. S27-1002-01A, Rev. AY BA C/S RE & BA FDC

S&L Dwg. S27-1003-03A, Rev. AM BA C/S RE & BA FDC

S&L Dwg. S27-1004-04A, Rev. AB BA C/S RE & BA FDC

S&L Dwg. S27-1005-04A, Rev. AD BA C/S RE & BA FDC

S&L Dwg. S28-1002-02A, Rev. S BA C/S RE & BA FDC

S&L Dwg. S28-1003-05A, Rev. T BA C/S RE & BA FDC

S&L Dwg. S28-1100-07C, Rev. K BA C/S RE & BA FDC

BA Dwg. CL1-27-5-132, Rev. 4 BA C/S RE &

BA Dwg. CL1-27-5-136, Sheet 12, Rev. 2 BA FDC (aperture cards) &

BA Dwg. CL1-27-S-136, Sheet 25, Rev. 2 BA DCC

BA DWG. CL1-27-S-136, Sheet 37, Rev. 1

BA Dwg. CL1-27-5-141, Sheet 18, Rev. 1

S&L Dwg. M09-1001N, Sheet 1, Rev. N BA TPRG &

S&L Dwg. M09-1003N, Sheet 1, Rev. M BA FDC

S&L Dwg. M09-1004N, Sheet 1, Rev. L

S&L Dwg. M-1SX01048X, Rev. F

S&L Dwg. M-1SX01017R, Rev. H, Sheets 1&2

S&L Dwg. M-INB010035, Rev. A

S&L Dwg. M-1NB01027X, Rev. A

S&L Dwg. M-1CC06042G, Rev. B

S&L Dwg. M-1RB24010G, Rev. C

S&L Dwg. M-1SX01050X, Rev. E

S&L Dwg. M-1SX01028R, Rev. J. Sheets 1&2

!

!

VII-21

- - _ _ -_

1

TABLE VII-3

IP AUDIT SAMPLE

IP Audit

Report No. Organization Audited

Q31-83-8 Baldwin Associates (BA) Quality Assurance

Q31-84-01 BA Quality & Technical Services

Q31-84-02 BA Procurement

Q31-84-03 BA Piping / Mechanical

Q31-84-04 BA Document Review Group

Q31-84-05 BA Electrical Department

Q31-84-07 BA Field Verification

Q31-84-09 BA Document Control Center (DCC) and

Nonconformance Review Group

Q31-84-10 ' BA Systems Release and Completion

Q31-85-01 BA Electrical Reinspection Program

Q31-85-02 BA Quality Control & Technical Services

Q31-85-04 BA Quality Engineering Systems, Quality

Engineering Procedures and DCC

Q31-85-05 BA Procurement, Receiving and Audits Sections

,

VII-22

TABLE VII-4

CHANGE DOCUMENT SAMPLE

Change Required Implementing

Document Description Disposition Document

ECN 3332 Add Note to two support Revise support drawings Traveler Nos. H-SX-2-C,

drawings to incorporate note H-SX-3-D

ECN 4291 Modification to ECN 4061 Revise Paragraphs 326.7c, Generic

d of Specification K-2882,

Revise Dwg. M06-1000,

Sheet 12

ECN 4683 Correct typographical Revise Paragraph 302.4a Generic

error in ECN 524 of Specification K-2884

ECN 4822 Clarifications to Spec. Revise Attachment 311.3 Clow Painting

BA-K-2882-29 of Specification K-2882 Procedure

EPS 30-69-721

ECN 4832 Response Spectra Data for Revise Article 305.4 in Generic

valves and actuators Attachment 311.3 of

Specification K-2882.

ECN 4853 Clarification of shop Revise Attachment 311.3 Clow Painting

painting requirements for of Specification K-2882 Procedure

valves installed in EPS 30-69-721

containment b1dg.

ECN 4943 Purchase and installation of Revise Attachment 311.2, IP P0 X-19490, dated

nuclear safety-related add Sections 327 and dated April 3, 1985

heat tracing fo- CM and PR Attachment 327 to

systems Specification K-2882

ECN 5263 Update list of Class D Revise Attachment 302.50 Traveler No. 1WOLC6303

support listed in Attach- of Specification K-2882

ment 302.50

ECN 5282 Allow use of Code Case N-413 Revise Attachment 110.1 of Generic

for component supports Specification K-2884

NCR 29249 Use as-is dispositio,of S&L Concurrence Traveler No. DG-2

pipe minimum Supp. 15

NCR 51358 Use as-is disposition of Revise Specification Traveler No. IVH25B

control cable mechanical K-2999

connection

l

VII-23

l

I

l

TABLE VII-4 (Continued)

CHANGE DOCUMENT SAMPLE

Change Required Implementing

Document Description Disposition Document

NCR 7002 Superseded by DR 5935; S&L Concurrence N/A

DR 5935 superseded by

10283; NCR 10283

documents use as-is

disposition for anchor

bolt which does not

project beyond nut

FCR 21404 Incorporate '81 Addenda to Revise Paragraph 118 of Traveler No. RR-759-A

ASME Code for Minor Attach- Specification K-2882

FCR 21899 Revision of purchase Revise Article 319.2 of BA P0 C49800

requirements for copper Specification K-2882

refrigeration tubing

FCR 27389 Snubber substitution for Incorporate design change Traveler No. H-SX-2-C

two supports drawings

FCR 27508 Material clarification and Revise Specification Traveler No. RH-024

weld qualification infor- K-2999 has not reference to

mation FCR 27389.

FCR 27545 Use as-is disposition of Revise Specification Generic

fire proofed HVAC and K-2910 and K-2999

electrical attachment weld

to structural steel without

galvanex

FCR 28060 Material substitution for Revise Paragraph 118 of Baldwin Purchase

SA 307 GR A bolts and nuts Specification K-2882 Order No. C48811

FCR 29144 Clarification of safety- Revise Specification Generic

related requirements for K-2884

exempt items per NF-2121(b)

from basic engineers

FCR 30783 Material substitution for Revise Specification Midway Industrial

primer and finish for K-2882 Contractors Form

interior of diesel oil

storage tanks

FCR 32822 Clarification of hanger Revise Specification Generic

support ID K-2884

VII-24

1

TABLE VII-4 (Continued) l

CHANGE DOCUMENT SAMPLE

Change Required Implementing

Document Description Disposition Document

FCR 38578 Installation modifications S&L Concurrence Traveler No. CS1655

to beam connections due to

field interference

FCR 36538 Clarification of installa- Revise Paragraph 313.5 Traveler No. VG-3-8

tion and inspection require- of Specification K-2882

ments for Class O penetra-

tion assemblies

FCR 36245 Hanger stiffener cannot be Revise Hanger Drawing Traveler No. H-RR-995-F

installed due to inter- 1RB13521G

ference

VII-25

_ _ _ _ _ _ _

TABLE VII-5

STRUCTURAL STEEL IPOI SAMPLE

DI Report Elev. Bristol

No. Bldg. (Ft.) S&L Drawing Bristol Drawing Piece Mark

S-0826 Aux. 800 S26-1004-01A, Rev. F F-02710, Sheet 5-8, Rev. 0 5-8B6

S-0399 Fuel 800 526-1004-02A, Rev. F Baldwin Detai1* S2520A

S-0825 Aux. 800 S26-1004-01A, Rev. F F-0271D, Sheet 5-6, Rev. 0 5-683

S-0862 Aux. 800 S26-1004-02A, Rev. H F-0271D, Sheet 5-9, Rev. 1 5-9B5

S-1460 Contain. 778 527-1003-03A, Rev. AH F-0271A, Sheet 3-14, Rev. 1 3-1483

S-1462 Contain. 778 S27-1003-03A, Rev. AH F-0271A, Sheet F3-11, Rev. 2 F3-11B1

S-1464 Contain. 778 S27-1003-03A, Rev. AH F-0271A, Sheet F3-5, Rev. 2 F3-5B8

S-1472 Contain. 778 S27-1003-03A, Rev. AH Fab. Detail Per FCR 11690* --

S-1486 Contain. 778 S27-1004-01A, Rev. AA F-0271A, Sheet F5-16, Rev. 1 F5-16BA

S-1490 Contain. 803 S27-1004-01A, Rev. AB F-0271A, Sheet F5-13, Rev. 1 F5-13B1

,

OSite Fabricated

VII-26 l

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. - . _ - - -. - . - - _ _ _ _ _ - - . - -

TABLE VII-6

PIPE SUPPORT IPOI SAMPLE

DI Report Elev. S&L Drawing

No. Bldg. (Ft.) C1 (Support No.) Traveler No.

M-2590 Contain. 737 A M-1RH34010X, Rev. A H-RH-20I, Rev. 3*

M-3155 Control 737 C M-1SX52022X, Rev. A H-SX-22K, Rev. 1FR*

M-3328 Contain. 755 B M-1RH71016G, Rev. C H-RH-767-U, Rev. 1*

M-3329 Aux. 737 B BA Dwg. H-1-RH-780-4, Rev. 0 H-RH-780-D, Rev. IFR

M-3330 Contain. 755/762 B M-1RH710185, Rev. E H-RH-767-CC, Rev. 4

M-3338 Contain. 755 C M-1RB22056G, Rev. B H-RH-947H, Rev. 1

M-3349 Contain. 828 8 M-1RH22035X, Rev. F H-RH-29F, Rev. 2

M-3351 Fuel 712 C M-1SX42019R, Rev. C H-SX-138, Rev. 15

M-3354 Aux. 708 B M-1RH47013G, Rev. A H-RH-764-L, Rev. 1*

M-3421 Fuel 712 C M1SX42021R, Rev. F H-SX-13P, Rev. 7*

RTraveler Not Reviewed

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L VII-27

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TABLE VII-7

ELECTRICAL CABLE TRAY HANGER IPOI SAMPLE

01 Report Elev. BA Drawing

No. Bldg. (Ft.) (Hanger No.) Traveler No.

E-3762 Contain. 755 1002-018-H24, Rev. 04 E27-1002-018-H24, Rev. 5

E-3920 Aux. 781 1003-01A-H47, Rev. 04 E26-1003-01A-H47, Rev. 8

E-3921 Aux. 781 1003-01A-H48, Rev. 02 E26-1003-01A-H48, Rev. 12

E-4010 Contain. 768 1002-01B-H33, Rev. 04 E27-1002-01B-H33, Rev. 5

E-4541 Control 800 1004-04A-H10, E30-1004-04A-H10, Rev. 23

Sheet 1, Rev. 03 &

Sheet 2, Rev. 01

01 Report Elev.

No. Bldg. (Ft.) S&L Drawing Traveler No.

E-3623 Control 800 1004-00A-CPR, Rev. E RT425, Rev. 6

1942, Rev. Y

(Items 10510K, M, N)

• SCI - Seismic Category I

VII-28

.

VIII. CORRECTIVE ACTION SYSTEMS

A. Objective

The corrective action systems and related activities were examined to

determine whether measures were established and implemented to assure

that nonconformances and other conditions adverse to quality were promptly

identified and corrected.

B. Discussion

An examination was made of the licensca's program for identification and

control of corrective actions, including review of sample documents and

inspection of some material and equipment for verification of actual

corrective actions in the plant.

The following procedures by Baldwin Associates (BA) and Illinois Power

Company (IP) protided the acceptance criteria for this inspection:

• BA Project Procedure (BAP) 1.0, "Nonconformance Report (NCR),"

Rev. 17, dated May 24, 1985

IP Nuclear Station Engineering Instructions (NSEI) ME-2,

" Interaction Analysis Program," Rev. O, dated March 4, 1985

IP Quality Assurance Procedure QAP-115.02, " Nonconforming

Material Report (NCMR)," Rev. 4, dated February 8, 1985

• QAP-116.04, " Reporting of Deficiencies per 10 CFR 50.55(e),"

Rev. 4, dated February 14, 1985

QAP-116.05, " Evaluation and Reporting of Defects and Noncon-

formances per 10 CFR 21," Rev. 2, dated June 20, 1983

• QAP-116.06, " Project Trend Analysis Program," Rev. 7, dated

May 15, 1985

QAP-116.07, " Management Corrective Action Requests (MCAR),"

Rev. 7, dated February 14, 1985

QAP-116.08, " CPS Condition Report (CR)," Rev. 5, dated July 27,

1984

IP Startup Administrative Instruction SAI-7, " Control of Condi-

tions Adverse to Quality," Rev. 5, dated February 25, 1985

• IP Startup Administrative Procedure SAP-1, " System Subsystem

Turnover," Rev. 12, dated July 18, 1984

• SAP-2, " Construction Work Requests," Rev. 13, dated December 20,

1984

SAP-6, " System Release and Return," Rev. 5, dated December 7,

1984

VIII-1

_ - _ _

SAP-9, " Maintenance Work Requests-Startup Group," Rev. 5 dated

August 24, 1984

SAP-20, " Preventative Maintenance," Rev. O, dated March 30, 1984.

1. Corrective Action Measures Inspection

a. Inspection Scope

A review was performed of applicable portions of the Quality

Assurance (QA) program and procedures. A total of 231 samples

of corrective action documents including Nonconformance Reports

(NCRs), Nonconforming Material Reports (NCMRs) and Condition Reports

(CRs) were reviewed. Five material and equipment samples were

inspected for verification of corrective actions in the plant. Three

samples of risk releases were selected for field verification of

control and status of work on material and equipment to correct

the deficient condition involved. Also, 26 samples of corrective

action documents which identified documentation revisions to show

as-built conditions for their disposition, were reviewed to verify

that the required documentation revision had been completed.

Samples were selected to cover various disciplines and activities.

The activities included the normal program activities of BA, Zack

Company, IP and the additional activities of BA Field Verification

and IP Overinspection.

Open items requiring corrective action after turnover from BA to IP

were also reviewed.

Corrective actions dispositioned use-as-is were evaluated to

determine if sound engineering was used for the disposition.

b. Inspection Findings

In general, it was found that satisfactory procedures were in place

for corrective action systems to identify and correct conditions

adverse to quality at the site. Except for a high rate of errors

found in a limited sample of open items identified in the IP Startup

Punch List, the corrective action measures were found to be accept-

able. The following details the NRC CAT inspector's findings:

(1) With approximately 80 percent of the systems turned over to IP,

more than 6000 open items are identified on the IP Startup

Punch List Tracking System. The document packages for four

open items were selected for a detailed review by the NRC CAT.

The criteria used for the sample selection was that the item

was identified as an open item and corrective action was required.

Discrepancies were found in the posting of documents against

two of the open items which prevented the open items from being

closed although the work had been accomplished. Because of the

high percentage of problems identified in this small sample, two

additional sample packages were selected for review. Problems

were identified in both of these additional packages. The high

VIII-2 l

-_ --_

.- - - ..

percentage of open item packages with problems identified by

the NRC CAT inspector indicates that additional management atten-

tion to this matter is required.

>

The packages examined are as follows:

ISA0069 Install Permanent Cable Between E21-N049 and JB

BA #61 -- Satisfactory

ISA0009 Change Wiring of NSIV-LC Valves -- Satisfactory

, DGA0349 Division II Overhaul, Rust on Cylinder Liner, NCR

17583 -- Unsatisfactory, See Table VIII-1

LPA0109 Water Leg Pump Seal Piping Discrepancies

ILP-1P2 -- Unsatisfactory, See Table VIII-2

DGA0153 Lube Oil Strainer Element Opening --

Unsatisfactory, See Table VIII-3

ISA0074 1E32-F008 Torque Switch Not Working in the Closed

Position -- Unsatisfactory, See Table VIII-4

(2) Manual and computerized records were used to track the status

and to trend nonconformances.

(3) Work had been completed and inspected for five samples

selected which required rework to correct a nonconformance.

(4) Three samples of the nonconformance documents reviewed

permited work to continue on a conditional release before a

final disposition could be made. The corrective action docu-

ments were still open and were controlled through the project's

nonconformance program.

(5) The appropriate revisicns to design documents for a sample of

26 corrective action reports which identified document revi-

sions to show as-built conditions for their disposition, were

found to be posted or incorporated into the design documents.

The only exception was three documents identified on an NCR

which had not been completed at the time of the NRC CAT

inspection.

(6) Sections II.B.3.b(2), V.B.1.b and V.B.3.b of this report iden-

tify NCRs dispositioned use-as-is without providing sufficient

documentation to substantiate compliance with requirements.

Section III.B.4.b of this report identifies the use of an FECN

when an NCR was required by project procedures.

(7)Section VII.B.1.b(7) of this report identifies ineffective

corrective actions for IP QA audit program findings for the

area of design document control. The NRC CAT inspectors found

similar deficiencies in the same area previously identified by

IP QA audits.

VIII-3

. -_ _ - - -

-. . _ _ _ .- - . _ . . - . .

t

(8) Documentation reviewed for NCRs written due to BA Field Veri-

fication and IP Overinspection findings, was found to be satis-

factory.

c. Conclusion

The corrective action system was found to be generally acceptable

except for the following:

"

Lack of control of entries into the IP Startup Punch List after

turnover of systems for startup testing. The number of problems

found with the limited NRC CAT sample of open items reviewed

indicates that this matter requires additional management

attention.

Failure to apply effective corrective actions in the area of

document control for IP QA audit findings.

Disposition of nonconformances use-as-is without providing

a basis to substantiate this disposition.

VIII-4

TABLE VIII-1

REVIEW 0F OPEN PUNCH LIST ITEM DGA0349

DIVISION II OVERHAUL, RUST ON CYLINDER LINER, NCR 17583

Documents

Issued /Date Comments

NCR 17583 Identified light rust bloom on number 6 cylinder liner

(5/2/84) of 16 cylinder diesel, 1DG01KB. This NCR was superseded

by NCMR 1-0809 (4/15/85) which is not identified on the

punchlist. IP NSED investigated rust problem on all DGs

(memo Y-72291) under NCR 17583, recommendation was to

" rework" and the position taken, "the rust will be

removed, after turnover, during disassembly of the

engine to replace power assembly lower seal by

mechanical maintenance."

MWR B02134 Work request to inspect engine turbocharger via the

(4/1/85)* inspection ports, for 16 cylinder engine. General

maintenance and inspection, visual inspection performed.

MWR B02133 Work request to remove power assembly and perform work

(4/1/85)* as per instruction provided, for 16 cylinder engine.

General maintenance and inspection activities.

MWR 802135 Work request to replace viscous damper as per

(4/1/85)* instructions provided, for 16 cylinder engine.

Maintenance work.

MWR B02138 Same as MWR 802133, except for 12 cylinder engine.

(4/1/85)*

MWR B02139 Same as MWR B02134, except for 12 cylinder engine.

(4/1/85)*

MWR 802140 Same as MWR B02135, except for 12 cylinder engine.

(4/1/85)*

NCMR Q-01-08290 Written as the result of Condition Report, CR 1-85-04-054

(4/19/85) which identified what the inspector believed to be a

flaw in the weld area of the upper water jacket for

cylinders 8 and 9 of the 12 cylinder engine. Engineering

investigation and evaluation found this condition to be

normal.

NCMR Q-02-018900 Written to identify scoring of connecting rod bearing

(4/26/85) surface, cylinders 1-9 of 16 cylinder engine, found

while performing MWR 802135.

MWR B17342 Work request for pressure test of 12 cylinder engine

(5/2/85) cooling water system per instructions provided.

• Written 10/29/84, and, while not applicable to this subject item, were entered

4/1/85.

VIII-5

_ - - -

_

. _ _ _ _ _ _ _ . _ - _ - . ._- _ . -_

TABLE VIII-l (Continued)

REVIEW OF OPEN PUNCH LIST ITEM DGA0349

DIVISION II OVERHAUL, RUST ON CYLINDER LINER, NCR 17583

Documents

Issued /Date Comments

MWR B17351 Same as MWR B17342, except for 16 cylinder engine.

(5/22/85)

MWR B17364 Work request to replace 12 cylinder, engine AMOT valve

(5/28/85) element housing bolts per disposition of NCMR 2-0216.

Problem: Of the twelve corrective action documents identified for

punch list item DGA0349, only NCR 17583 appears to be

related to the item description. NCMR 1-0809 which

should have been identified, is missing. The initially

identified open item has not been closed out.

VIII-6

i

TABLE VIII-2

REVIEW 0F OPEN PUNCH LIST ITEM LPA0109

WATER LEG PUMP SEAL PIPING DISCREPANCIES ILP-1P2

Documents

Issued /Date Comments

NCMR Q-00-02400 Unrelated NCMR entered in error and not removed from

(12/16/83) punch list. Related NCMR is Q-01-02400.

FPR 3288 Identified that pump IE21-C002 was different from the

(8/27/84) other pumps in that seal injection piping was missing.

CR 1-84-09-00400 Identified seal bypass piping on LPCS pump 1E21-C0002

(9/6/84) was missing.

NCR 021710 Identified the nonconformance.

(9/6/84)

NCMR Q-01-02400 Replaced NCR 021710 for corrective action control

(10/2/84) after turnover.

CWR 11334 Work request to install seal by pass piping. NCR

(11/3/84) 021710, not NCMR Q-01-02400, identified the nonconfor-

mance. This work request was closed out 1/14/85.

Problem: Work has been completed, NCR 021710 has been closed

out. NCMR Q-01-02400 has not been closed out and is

preventing this open item from being closed out.

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VIII-7

_ . _ - _ __ _

_ . _ . . . -__ _-_ _

TABLE VIII-3

REVIEW OF OPEN PUNCH LIST ITEM DGA0153

LUBE OIL STAINER ELEMENT OPENING

Documents

Issued /Date Comments

MWR B00183 Identified provisions for the diesel generator lube

(9/18/84) oil flush.

CR 1-84-10-540 Identified lube oil strainer had manufacturer's defect.

(10/19/84)

NCMR Q-01-052100 Identified the nonconformance with disposition to scrap

(1/9/85) defective strainer and replace with a new strainer.

FDDR LH1-5151 Provided GE's disposition for NCMR Q-01-052100.

(1/15/85)

MWR B03584 Prepared to replace strainer. Note: This work had been

(3/5/85)- performed under MWR B00183 which was never closed out.

MWR 803584 was closed out because the work had been

previously completed.

-Problem: MWR B00183 is still identified as an open item of the

punch list, preventing this item from being closed out.

VIII-8

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TABLE VIII-4

REVIEW 0F OPEN PUNCH LIST ITEM ISA0074

1E32-F008 TORQUE SWITCH NOT WORKING IN THE CLOSED POSITION

Documents

Issued /Date Comments

MWR 807829 Repair of identified problem with new Torque switch.

Switch was replaced 4/17/85 and documentation closed

out 4/19/85.

NCR 07082900 Nonconformance, spectacle flange, 1E32-D307, paper work

(3/2/85) indicated that an ASME Class NF flange was being used

where a Class NC flange is required.

CWR C013430 Was prepared to replace the flange with an ASME NC l

(3/28/85) flange as required.

Problem: Tne NCR and CWR were initially entered into the punch

l list tracking system under ISA0074. The operator deleted

l the problem descripticn but did not delete the NCR and

CWR. ISA0074 was then reused for MWR B07829 with the NCR

and CWR identified as documentation related to the open

item. All the work for the MWR has been completed. The

licensee had made the necessary corrections and removed

this item from the open punch list prior to the NRC CAT

inspection exit meeting.

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VIII-9

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

ATTACHMENT A

A. Persons Contacted

The following list identifies licensee representatives and NRC personnel

present at the exit meeting, and licensee discipline coordinators and key

individuals contacted during the inspection for each area.

1. Exit Meeting

a. Licensee and Contractors

G. Bell D. Hall M. Pacy

W. Connell R. Heider D. Selva

H. Daniels S. Johnson D. Shelton

G. Gandsey W. Kelley H. Victor

W. Gerstner A. King J. Wilson l

J. Green L. Osborne S. Zabel

b. State of Illinois

R. Hubbard A. Samelson S. Swartz

c. NRC and Consultants

T. Chan J. McCormack R. Serb

A. DuBouchet T. McLellan B. Siegel

G. Georgiev 0. Mallon R. Smeenge

T. Gwynn W. Marini W. Sperko

J. Harrison E. Martindale S. Stein

R. Heishman J. Nemoto J. Taylor

D. Johnson * M. Peranich R. Warnick

H. Livermore

! 2. Licensee Coordinators and Contacts

Area Name

Team Leader G. Bell D. Shelton

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D. Hall

Electrical and E. Bailey R. Kennedy

Instrumentation D. Gilbert L. Ratliff

B. Johnson

Mechanical D. Adams K. Danner

B. Buffie R. Kennedy

1

L. Clark A. Sherwood

L. Combs B. Taylor

• Institute of Nuclear Power Operations observer

AA-1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______

Welding and NDE J. Carson T. Wilmoth

Civil and Structural T. Parrent K. Smith

Material Traceability J. Gruber

Design Change Control G. Buffington J. Greene

R. Collins S. Lyons

W. Connell

Corrective Action Systems T. Warnick

l

In addition to the above personnel, numerous other inspectors, engineers I

and supervisors were also contacted.

B. Documents Reviewed

The types of documents listed below were reviewed by the NRC CAT members

to the extent necessary to satisfy the inspection objectives stated in

Section I of tnis report. References to specific procedures, specifica-

tions, and drawings are contained within the body of the report.

1. Final Safety Analysis Report

2. Quality assurance manual

3. Quality assurance procedures and instructions

4. Quality control procedures

5. Administrative procedures

6. General electrical installation procedures and specifications

7. General instrumentation installation procedures

8. General piping and pipe support installation procedures and

specifications

9. General mechanical equipment installation procedures and

specifications

10. General concrete specifications

11. As-built drawings

12. Welding and NDE procedures

13. Personnel qualification records

14. Material traceability procedures

15. Procedures for processing design changes

AA-2

16. Procedures for document control

17. Procedures for controlling as-built drawings

18. Procedures for processing nonconformances

.

I

AA-3

\.

ATTACHMENT B

GLOSSARY OF ABBREVIATIONS

AISC - American Institute of Steel Construction

AISI - American Iron and Steel Institute

ANSI - American National Standards Institute

ASME - American Society of Mechanical engineers

ASTM - American Society for Testing and Materials

AWG - American Wire Gauge

AWS - American Welding Society

BA - Baldwin Associates

BAFV - Baldwin Associates Field Verification

BAP - Baldwin Associates Project Procedure

BE - Basic Engineering

80M - Bill of Materials

BQAI - Baldwin Associates Quality Assurance Instruction

• C - Degree Celsius

CAT - Construction Appraisal Team (NRC)

CB&I - Chicago Bridge and Iron Company

CEA - Concrete Expansion Anchor

CHI - Construction Management Information

CPS - Clinton Power Station

CR - Condition Report

C/S - Civil / Structural

CRD - Control Rod Drive

CWR - Construction Work Request

dc - Direct Current

DCC - Document Control Center

DMS - Document Management Systen

ECN - Engineering Change Notice

F - Degree Fahrenheit

FCR - Field Change Request

FDC - Field Document Center

FECN - Field Engineering Change Notice

FSAR - Final Safety Analysis Report

GE - General Electric Company

HCU - Hydraulic Control Unit

HPCS - High Pressure Core Spray

HVAC - Heating, Ventilating and Air Conditioning

IE - Office of Inspection and Enforcement (NRC)

IEEE - Institute of Electrical and Electronic Engineers

IP - Illinois Power Ccmaany

IPCEA - Insulated Power Ca)le Engineers Association

IP0I - Illinois Power Company Overinspection

k - One Thousand

LPCS - Low Pressure Core Spray

MCM - One Thousand Circular Mils

MWR - Maintenance Work Request

NCMR - Nonconforming Material Report

NCR - Nonconformance Report

NDE - Nondestructive Examination

NP&S - Nuclear Planning and Support

NRC - United States Nuclear Regulatory Commission

NSED - Nuclear Station Engineering Department

AB-1

NSEI - Nuclear Station Engineering Instructions

PGCC - Power Generation Control Complex

PI - Project Instruction

PIR - Potential Interaction Report

PSA - Pacific Scientific Arrestor

PSAR - Preliminary Safety Evaluation Report

QA - Quality Assurance

QAI - Quality Assurance Instructions

QAP - Quality Assurance Procedure

QC - Quality Control

RCI - Reactor Controls, Inc.

RCIC - Reactor Core Isolation Cooling

RE - Resident Engineer

RHR - Residual Heat Removal

RG - Regulatory Guide (NRC)

RIR - Receiving Inspection Report

SAE - Society of Automotive Engineers

S&L - Sargent & Lundy Engineers

SSW - Shutdown Service Water

SU-F - Startup Field Office

TPRG - Traveler Preparation Review Group

TS - Technical Services -

TTS - Traveler Tracking System

USI - Unresolved Safety Issue (NRC)

V - Volt (s)

AB-2

- . _

_ _ . _ . _ __ _ _

___ __ _ . _ _ _ _ , _ _ . __.

r- _ic

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!

NRC Form 8-C

(4-79)

NRCM O240

COVER SHEET FOR CORRESPONDENCE

Use this Cover Sheet to Protect Originals of Multi-Page Correspondence.

1

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