IR 05000461/1986034

Insp Rept 50-461/86-34 on 860513-16,27-30 & 0603-05.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Part 21 Repts & 10CFR50.55(e) Items

ML20199F119
Person / Time
Site:	Clinton
Issue date:	06/18/1986
From:	Danielson D, Kaufman P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199F092	List: IR 05000461/1986034 ML20199F086
References
50-461-86-34, NUDOCS 8606240195
Download: ML20199F119 (8)

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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-461/86034(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee:

Illinois Power Company

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500 South 27th Street Decatur, IL 62525 Facility Name:

Clinton Power Station, Unit 1 Inspection At:

Clinton Site, Clinton, IL Inspection Conducted:

May 13-16, 27-30, and June 3-5, 1986 ka+bw/~

ge/ac Inspector:

P. D. Kaufman

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/db Approved By:

D. H. Danielson, Chief Materials and Processes Section Date

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Inspection Summary i

Inspection on May 13-16, 27-30, and June 3-5, 1986 (Report No 50-461/86034(DRS))

Areas Inspected:

Routine, unannounced inspection of licensee action on previous inspection findings, Part 21 Reports, and 50.55(e) items.

Results: Of the areas inspected, no violations or deviations were identified.

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8606240195 860618 PDR ADOCK 05000461 G

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DETAILS 1.

Persons Contacted Illinois Power Company (IP)

R. Lebkuecher, Specialist, Licensing

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• J. Brownell, Specialist, Licensing

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K. A. Baker, Supervisor, I&E Interface Sargent & Lundy Engineers (S&L)

J. Blattner, Mechanical Engineering Supervisor I. A. Garza, Mechanical Project Engineer The inspector also contacted and interviewed other licensee and contractor employees.

• Denotes those attending the final exit interview on June 5, 1986.

2.

Licensee Action on Previous Inspection Findings a.

(Closed) Violation (461/85026-01):

The Baldwin Associates (BA)

Resident Engineering Traveler Preparation and Review Group (TPRG)

was bypassing the BA Nonconformance Report program during final traveler review, by identifying and documenting nonconforming conditions on Interoffice Memorandum (IOMs) in lieu of Nonconformance Reports.

To resolve this issue, BA Quality Engineering reviewed and evaluated 1677 10Ms issued to correct problems in the field or for return of travelers to TPRG. The IOMs were segregated into six (6) categories with corrective actions-taken as follows:

(1) 113 IOMs were issued for hardware related issues.

Evaluation of these memos showed that 21 10Ms identified hardware related nonconforming conditions; NCR No. 35862 was issued to resolve these problems.

The remaining 92 10Ms were written to initiate actions which were not related to nonconforming conditions; therefore, issuance of an NCR or correction of travelers was not required.

(2) 113 10Ms were issued to correct non-hardware related nonconforming conditions.

NCR No. 33663 was issued to resolve these problems.

(3) 50 10Ms identified that travelers had missing Tech Service (TS)

signatures, missing NDE reports, or were requests from engineering for inspections to clarify concerns.

These types of deficiencies do not require the initiation of a nonconformance

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report.

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BA Procedure 2.14, " Fabrication / Installation of Items, Systems, and Components," requires travelers to be final reviewed by TPRG, TS, and Quality Control (QC).

Final review of travelers would identify and correct these types of deficiencies.

In addition, EA Document Review Group (DRG) perfoms a review of travelers prior to vaulting which would also identify and correct these types of deficiencies.

(4) 23310Ms identified that travelers had missing QC signatures, inspections, forms,'etc. These problems would be identified and corrected by the mechanisms discussed in Item 3.

(5) 32 IOMs requested that travelers be returned to Field Engineering. The memos do not indicate why the travelers were to be returned to Field Engineering. Based on the review of these memos, there is no indication that a problem exists which would require issuance of an NCR or correction of the traveler.

(6) The remaining 1136 IOMs consisted of statements that do not identify a concern / deficiency. These 10Ms only reference a traveler number or a generic statement that says, "Sent back at Field Request." Based on the review of these memos, there is no indication that a problem exists which would require issuance of an NCR or correction of the travelers.

The inspector reviewed NCR No. 35862, NCR No. 33663, the JV-808 Form, and the training records of TPRG personnel in the proper use of the JV-808 Form. Based on these reviews the measures taken by the licensee to identify and correct the problem of circumventing the BA Nonconformance Report program appears to be adequate and effective.

b.

(Closed) Violation (461/85051-01): Baldwin Associates Resident Engineering was not adhering to their established and documented job descriptions, as evidenced by the Lead Instrt.. ant Verification Engineer not meeting the required educational requirement.

The licensee's review of work performed by the Lead Instrument Verification Engineer has shown that even though the individual was not qualified as indicated by the lack of an engineering degree, all the safety-related work done by this individual was reviewed and approved by either Quality Control or Sargent & Lundy, as appropriate.

Thus, all the work performed by or under the direction of this individual has had no impact on safety-related components or systems.

Baldwin Associates has revised the position description for the Lead Instrument Verification Engineer. The position description now requires an engineering degree plus 3 years experience or a high school diploma and 8 years experience.

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i In addition, Baldwin Associates Personnel conducted a complete review

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of Illinois Power personnel assigned to Baldwin Associates. This

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review compared the education and experience for each person to the job description for the position held.

The BA Personnel review has shown that all of the Illinois Power personnel met or exceed the job description's education and experience requirements. Thus, it can be concluded that the NRC identified deviation was an isolated occurrence.

The NRC inspector concurs with the above actions taken by the licensee.

c.

(Closed) Violation (461/85056-01): Mechanical snubber rear bracket of Sargent & Lundy (5&L) designed pipe support 1RH-160355 was welded to the yoke of Anchor Darling Limitorque valve IE12-F064A, without

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either the A&E or valve manufacturer conducting an engineering reevaluation of the valve assembly seismic qualification report.

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Sargent & Lundy has performed the necessary calculations to verify the seismic qualification and operability of the valve. Sargent &

Lundy calculation CQD-022163, Revision 00, dated July 16, 1985 was reviewed by the NRC inspector. The calculation demonstrated the operability and structural integrity of valve 1E12-F064A to be acceptable, with the added pipe support IRH-160355 attached. Sargent

& Lundy seismic qualification package (SQ-CL100) has also been updated to reflect these calculations.

In addition, S&L has identified all other safety-related valves which are restrained by component supports

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and is performing or has performed calculations as necessary to verify the Dynamic Qualifications of the subject valves. Also, the seismic qualification packages are being updated to reflect these calculations.

3.

Licensee Action on 10 CFR 21 Reports a.

(Closed) Part 21 Report'(461/85006-PP/IP No. 21-85-03): General Electric Company notified Illinois Power Company (IP) on February 1, 1985 of a potential 10 CFR 21 defect found during testing at Wyle

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Laboratory of a Hammel-Dahl No. 2500, 2" valve. During testing the valve experienced a failure in the coupling connecting the actuator stem and the valve stem, thus preventing the valve from opening or fully closing. This particular type of air operated valve is used

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only in the Control Rod Drive (CRD) Scram Discharge Volume (SDV)

system at the Clinton Power Station.

GE's investigation found that the valve coupling failure was the direct result of an improper test setup. The valve handwheel had been inadvertently engaged during the setup. Later the manufacturer

found that with the handwheel engaged during the air operation mode, the forces would be sufficient to deform the actuator coupling and subsequently jam the actuator. GE recommended that the valve

handwheel be locked in the neutral position whenever operating in the air actuation mode. With the handwheel in " neutral" the valve will operate satisfactorily.

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The licensee's Plant Operations section initiated changes to chain lock valves 1C11-F180 and 1C11-F181 in the " neutral" position. The Instruction and Maintenance Manual K-2801-0180 has been revised to reflect GE's recmommendation.

A review of the CRD scram discharge volume design indicates that had this problem gone undetected and the valve subsequently failed during plant operation, then other measures are available to isolate the scram discharge volume (i.e., resetting the scram signal jn the Control Room when the trip signals have cleared or manual closure of -

isolation 102 or 112 on each HCU). Also, the Hammel-Dahl valve is backed up by a redundant in-series Fischer air operated valve.

This matter is considered closed.

b.

(Closed) Part 21 Report (461/85005-PP/IP No. 21-85-06): Basic Engineers Division of National Valve and Manufacturing Company notified Clinton Power Station's general contractor, Baldwin Associates, of a potential 10 CFR 21 Defect in its sway strut and snubber pipe clamps in sizes 3/4" and 1", which may slip circumfer-entially around the pipe when a compressive load less than faulted rate load (Service Level D) is applied at an angle of 5 to the centerline of the clamp.

The licensee notified Region III of this problem by letter U-600208, dated August 12, 1985.

The licensee's actions and evaluations, which are documented in letter U-600465, dated March 31, 1986, concluded that had this defect gone undetected it would have resulted in

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inadequate support of various safety-related piping systems in the faulted condition. This could have affected the integrity of those systems and is judged to be reportable by the licensee.

A review of the documentation for corrective action taken to correct the identified deficiency and to preclude recurrence was performed by the NRC inspector.

In addition, the inspector verified that Basic Engineers had revised their load capacity data (LCD) sheets and

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issued the requirement for use of higher strength bolts, SA-307 Gr.B

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bolts changed to SA-193 Gr.B7 bolts or studs of the same size with SA-194 Gr.2H Hex Nuts, hardened steel washers for BE-412, 413, 418, 419, and 421 N-1 (both 3/4" and 1" pipe size) clamps to prevent stretching of the bolts. These LCD sheets also were revised to provide new torque values and installation instructions.

A total of 129 supports were reworked in accordance with Sargent &

Lundy issued Field Engineering Change Notices (FECNs) and the following Construction Work Requests (CWRs)

CWR No.

Date Closed CWR No.

Date Closed 16206 12-15-85 19735 12-05-85 17054 09-17-85 19991 03-16-86 17131 09-27-85 19992 01-25-86

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17190 10-22-85 19993 03-19-86 19683 03-17-86 19994 02-11-86 19684 02-26-86 21049 02-11-86 The required corrective actions have been implemented and completed.

This matter is considered closed.

4.

Licensee Action on 10 CFR 50.55(e) Items a.

(Closed) 50.55(e) Item (461/85015-EE):

The licensee notified Region III on December 27, 1985 of a potentially reportable deficiency under the provisions of 10 CFR 50.55(e) concerning the instrument lines connected to the reactor coolant pressure boundary that are ASME Class 3 instead of ASME Class 2 as required by the Final Safety Analysis Report (FSAR).

A review was performed by Illinois Power Company Nuclear Station Engineering Department (NSED) and Illinois Power Quality Assurance (IPQA) to determine the differences in requirements regarding the two ASME Classes.

The results of this review determined that additional nondestructive examinations (NDE) would have to be performed on the instrument line welds in order to upgrade these lines to ASME Class 2.

Reviews were performed of the isometric drawings and design documents, including line lists and P& ids, to identify the instrument lines which had not been classified in accordance with the FSAR.

As a result of this review 2,716 instrument line welds were identified which required additional nondestructive examination for upgrading to ASME Class 2.

Of this total, 132 welds required radiographic (RT)

examination.

The remainder required liquid penetrant (LP)

examination.

The NDE examinations were completed on March 1, 1986.

These examinations revealed that forty-nine (49) of the welds radiographed and four (4) of the welds examined by liquid penetrant did not meet acceptance criteria.

Nonconformance Reports (NCRs) were initiated to document and disposition these welds.

The 49 welds were replaced by socket welds.

Engineering Change Notices (ECNs) 6926, 6927, and 6976 were issued to upgrade the design.

In addition, Sargent & Lundy (S&L) issued an internal memorandum to appropriate engineering personnel reiterating the design requirements.

A safety significance evaluation was performed by S&L which concluded that the identified weld deficiencies would not have resulted in a condition adverse to the safety of operations if the weld deficiencies had gone uncorrected.

In addition, a significant portion of the RT examination failures were destructively tested to aid in these evaluations. On this basis, the issue was evaluated to be not reportable under the provisions of 10 CFR 50.55(e).

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The NRC inspector reviewed the licensee's Final Response, dated March 12, 1986, and the documentation for corrective actions taken to correct this identified deficiency and to prevent recurrence.

The following documentation was verified by the inspector:

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Radiographs and reports of 62 welds that were recorded as being

acceptable by Baldwin Associates, the ANI, and U.S. Testing -

Level IIs.

Liquid Penetrant reports.

• Weld repair reports.

• Nonconformance reports.

• Sargent & Lundy safety evaluation calculations 01 ME-92,

01 ME-93, and 01 ME-94.

Field Engineering Change Notice (FECN) 13591.

• Baldwin Associates piping drawings15-900 through 15-911.

• All required corrective actions have been implemented and the repair /

rework is complete.

The actions taken by the licensee are acceptable and this item is closed.

b.

(Closed) 50.55(e) Item (461/85011-EE):

The licensee notified Region III on September 6, 1985 of a potentially reportable deficiency per 10 CFR 50.55(e) concerning the use of shims under J. C. White clamps on gang hangers for instrumentation lines.

Baldwin Associates field construction shimmed J. C. White clamps on gang hangers and failed to assure that the following design J

requirements were met:

That 3 directional J. C. White clamps were not shimmed;

That no more than (1) 3/4" pipe was shimmed on gang hangers;

That no more than (2) 1/2" pipes were shimmed on gang

hangers; and That no more than the allowed combination of (1) 1/2" pipe

and (1) 3/4" pipe were shimmed on a gang hanger.

Also, Baldwin Associates Quality Control (BAQC) only assured that shim thickness did not exceed 1/2" without regard to the criteria stated above.

The finding was documented on Baldwin Associates Corrective Action Request (CAR) No. 260.

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Sargent & Lundy performed an evaluation of 1500 hangers that assumed

a 1/2" shim plate under each clamp supporting the instrumentation lines. The results, which are documented in S&L's Calculation

.No. SDQ10940G05 show that the addition of 1/2" shim plates under the clamps have no effect'on the hangers to meet the design requirements and therefore is not safety significant.

The calculations show that the actual stresses of members, welds, and bolts are less than the design allowable.

Sargent & Lundy revised M09-1003N and M09-1004N drawings to incorporate the requirements of FCR 41124, which allow the addition of a maximum 1/2" shim plate under all J. C. White clamps supporting instrumentation lines.

Following the results of S&L's evaluations, on September 26, 1985, the licensee notified the NRC Resident Inspector that this issue was'not reportable per 10 CFR 50.55(e).

The NRC Resident Inspector concurs

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with the corrective actions taken to correct the potential deficiency.

5.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

on June 5,1986, and summarized the scope and findings of this inspection.

The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.

The licensee did not identify any such documents or processes as proprietary.

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