ML20114B647

Interim Potential Deficiency Rept 55-84-02 Re Problems Concerning Identification & Traceability of Installed Electrical Hanger Matls.Initially Reported on 840111.Next Rept to Be Submitted within 45 Days

ML20114B647
Person / Time
Site:	Clinton
Issue date:	01/18/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-02, 55-84-2, U-10-240, U-10240, NUDOCS 8501290395
Download: ML20114B647 (6)

Text

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

[f a .

/LLINDIS POWER COMPANY 1A.120 j)CE U-10240 CLINTON POWER STATION P.O. BOX 678. CLINTON. ILLINOIS 61727 January 18, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Potential 10CFR50.55(e) Deficiency 55-84-02 Material Traceability

Dear Mr. Keppler:

On January 11, 1984, Illinois Power Company notified Mr. R.

C. Knop,-NRC Region III (ref: IP memorandum Y-18980, dated January 11, 1984) of a potentially reportable deficiency per 10CFR50.55(e) concerning material traceability at the Clin:on Power Statien (CPS). This initial notification was followed by three (3) interim reports (ref: IP letter U-10124, D. P. Itall to J. G. Keppler dated February 14, 1984; IP letter U-10157, L. P.

Hall to J. G. Keppler dated July 12, 1984; and IP letter U-10207, D. P. Hall to J. G. Keppler dated October 18, 1984.) Our investigation of this issue is continuing, and this letter represents an interim report in accordance with the requirenents of 10CFR50.55(e). Attachment A provides the details of our investigation to date.

We trust that this interim report provides you sufficiN?ttt background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve this issue.

Sincerely yours,

. . Hall Vice President

~

RLC/lr (SW) sggigg@[{5!004!1 0

Attachment { PDR cc: -NRC Resident Office Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety -

INPO Records Center JAN 231989 N7

., J ..

ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-02 Material Traceability Interim-Report Statement of Pctentially Reportable Deficiency

-A' condition;potentially. adverse to quality was identified in the area'of. material traceability. This concern is based on a numb ~er of Deviation Reports (DRs), Nonconformance Reports (NCRs),

.and' Quality Assurance aucit findings,- documenting problems related to identification and traceability of, primarily

. electrical' hanger materials installed at CPS.. An. investigation;

and, evaluation of this issue is being performed to1 determine the extent of this: problem, root causes, effect on installed 1 hardware, and significance on.the safety of operation of CPS.

Investigatton Results/ Background On' December 20, 1983, Illinois Power Quality Assurance issued Management Corrective Action Request (MCAR) Number 07 to

- . identify an adverse condition existing in the area of material

' traceability'. The basis-for issuance of MCAR 07-included:

1. The: untimely resolution of Corrective' Action Request (CAR)

Number 073, which 'ident:ified a material. traceability

problem. This problem was evidenced by a significant number of NCRs

and DRs writtet to. document electrical hanger-support members installed with incorrect or' missing material identification numbers. These incorrect or missing

. identification numbers resulted in the inability to verify

-that the installed materials were correct.

2. LAn Illinois Power-Quality Assurance audit disclosed problems

, 'regarding. adherence-to procedures related.to material

identification and traceability.

m

~

. . An. Investigation. Plan was prepared and implemented by 1 Illinois Power-Company-to. investigate'and address'the concerns identified in the: area of material identification and l traceability'. The plan included'the"following actions: ,

1. . A review.of historical data leading up'to issuance.of MCAR 07:was performed to:identf.fy the scope of past material traceability problems.

^

Page 1"of 5 b 1: ___

( -:

3, .

ATTACHMENT A (continued)

2. A review of design requirements, specifications, procurement procedures, and construction procedures was performed to evaluate-adequacy of the CPS material identification /

traceability requirements and their implementation.

3._ A list.of specific hardware installations affected by the material traceability problem was compiled and categorized.

4.

~

Data collected'in steps 1,2, and 3 above is being' analyzed to_ determine the scope, root causes, and the significance of the issue.

5.- Corrective, action for identified hardware / software deficiencies and their root causes is being determined and

' implemented.

.The' investigation has identified several areas where the

implementation of material traceability requirements is unclear or is in question. These areas include:

1. - Structural ~ plates and shapes used in electrical supports 2' . -

. Electrical strut and strut fittings

3. Concrete expansion anchor bolts

'4. ' ASTM A-307 bolts 5.. ' Washer and shim stock ~ material

.fN ; 6 '. ASME Section'III, Subsection NF, Class 2 and 3, support ,

materials

17. Cable finger assemblies Corrective Action Baldwin Associates ' . Procedure BAP 1.5 and appropriate-subtier documents'have been revised to provide clarification of theztraceability requirements and preclude recurrence of the material ~ traceability problems. Changes in the procedures

• ' include the requirement that permanent plant materials, upon

, Jreceipt, will be identified by hard marking or tagging.

Discipline 1 Superintendents are required to notify QC prior to subdividing materials in order to verify that traceability-is imaintained through installation.

t p-Page'2 of 5

!m m- u

.m 4,..

ATTACHMENT A (continued)

Training on the enchanced. procedural controls was given to all appropriate personnel, concurrent with the revision of applicable BAP procedures.

Additional corrective actions taken,to date include the following:

1;. The'l majority of new materials (structural shapes, plates, struts, strut fittings, bolts, etc.) will be purchased as safety related only.

2. -Laydown yards are being reorganized to clearly segregate

materials.

3. Sampling and testing programs were' developed and implemented to provide assurance that the installations made prior to che implementation of the revised BA procedures have-

_ utilized materials capable of meeting design requirements.

4. A site purge of all non-traceable structural shapes, plates, and-unmarked bolting material'has been performed.

Certain structural shapes and plate materials utilized in the fabrication of electrical supports were iden~tified as having

incorrect or' missing heat or Receipt Inspection Report (RIR) numbers which are necessary for QC verification. This item was

partially resolved by the revision of appropriate procedures to require material ~ verification in future, installations. The remaining. concern is to provide assurance that-the installations-made prior to the' implementation'of-the-revised procedures have utilized ~ materials-capable of

meeting design requirements. .A Esampling program has been developed and implemented. utilizing MIL-STD-414 (Level V) . Testing was performed on a representative

. population 1of. electrical hangers-with-traceability problems Lidentified on Deviation Reports (DRs) and Nonconformance Reports (NCRs). This program established.that the materials met the

. requirements of Sargent &'Lundy-(S&L) Specification, K-2999 (Ref.

NCRi23422). This testing also closed BA Corrective Action Request.(CAR)_ Number 073.

NCRs 10214,.10210, and 10217. indicated that Certificates of Compliance had not been validated for the B-line, Superstrut, and-Unistrut materials used in the fabrication of electrical and

' instrumentation supports.

The concerns related to B-Line and Unistrut-were resolved

-through.BAQA Survey Audits. However, those related to Superstrut remained, and sampling programs conducted by the electrical

discipline demonstrated.that Superstrut materials met the

. requirements of S&L Specification K-2999 (Ref. NCR 12597 &

.12598). . Prior to these sampling programs, any Superstrut Page 3 of 5

p V 4(.

ATTACHMENT A (continued) material used'in the fabrication of an instrumentation support was replaced with.Unistrut. Currently, all procurements of strut s materials are made safety-related. This, in conjunction with the

' sampling programs, allows all strut materials on site to be considered safety-related; and as such, are exempt from heat and

/or RIR number. traceability.

. The; remaining item under investigation was a field fabricated. bracket (similar to Powerstrut Part #AB-213/214-W) in which the identity of the triangular-shaped gusset plate was questioned. Of the 150 brackets fabricated under traveler fell 88, 22 have been located. On all of these,_the material was identified correctly (RIR No.). This quantity / acceptance satisfies MIL-STD-105D (Level II).

Baldwin_ Associates Quality Engineering has qualified Hilti asLa safety-related. supplier utilizing documentation obtained through the Coordinating Agency for. Supplier Evaluation (CASE) and other sources. Past purchase orders for Hilti bolts are currently being evaluated for upgrading in accordance with

. approved site procedures.

A sampling-program was developed and implemented in .

.; accordance:with MIL-STD-414'(Level V)-for testing of electrical' and:HVAC unmarked (lacking manufacturers-identification) A-307

- bolts.. The program established that the unmarked bolts met the

' strength' requirements of A-307 (Ref. NCR 19789). The piping /

instrumentation discipline'has been reviewed for the use of unmarked bolts (Ref. Letter JWH-65-84, . dated .12/14/84) . Although a shipment of unmarked. bolts was issued to the field, testing has shown-that'.these bolts met the strength requirements of A-307

'(Ref. NCR'21931). The Civil / Structural discipline is currently.

being reviewed for the use of unmarked bolts. _Similar-testing by

_this, discipline may also be required.

S&L.has: clarified the requirements-for washer and shim stock with respect to_ documentation, identification, and traceability.

--via-their dispositions to FCRs 10556, 20742, 20988, 21476, and

~

24423. BA procedures will.be revised to. address these require-ments?as applicable. Shims utilized in bolted applications are 7 acceptable, (material type is not a-concern in compressive 1

loading).however those used in-welded electrical hanger-installations were_ investigated'in~ order to determine material

.weldability'. Chemical analysia, as a minimum, was performed on

those shims found in the electrical hanger installations removed-for testing'per the electrical hanger test program. This analysis demonstrated the. material-weldability (Ref. NCR 24659).

y ~

~

i - ~.

~

Pagekof5 f 's 1

e, -

- , h1 . '

• • 3 ATTACHMENT A (continued) >

.'Although no objective evidence has been found concerning

~

improper materials _ identified with pink paint, the practice of

~ marking ASME Section III, Subsection NF, Class 2 and 3 safety related. items,with pink paint was discontinued. In' lieu of this,

items are being identified with heat numbers and RIR numbers. An evaluation of the Code requirements for material identification is'being' performed in order to address concerns on past installations.

Finger assemblies for which the material traceability has been identified as indeterminate and documented'via an NCR were

. tested.in conjunction with the electrical support materials. This

' testing has demonstrated the materials met the requirements of S&L specifications K2949/2999.(Ref. Letter Y-26007, dated 12-18-84).

In summary, the problems associated with traceability were, Lin part,.due to the lack of clarity and consistency in procedural requirements resulting in a lack of adherence to those procedures ~. .-Therefore, several Baldwin Associates' Procedures.

(BAPs) (most notably BAP-1.5), associated Job Instructions (JIs),

and: Quality Control Instructions (QCIs)-have been revised to-

. prevent recurrence. The changes included marking or tagging

-permanent plant materials, upon receipt and requiring the crafts ico notify QC prior to subdividing materials in order to maintain traceability through installation.. In addition,.most materials (structural shapes, plates, strut, strut-fittings, bolts, etc.).

, (are~ purchased only safety-related. This deletes the need for traceability after-receipt inspection of particular items. ' Steps 9 ,

--have.been taken to reorganize the laydown yards to clearly

segregate' materials and.a purging of the: site has been performed-to: remove any non-traceable structural shapes, plates, and

~ unmarl.ed bolting material.

Safety Implications / Significance-

~

'IllinoisLPower Company's investigation of this potentially reportable deficiency is continuing. The safety implications and

. fsignificance will be~ assessed after further background

.information is evaluated. 'It is anticipated that;approximately 45 days will:be necessary to complete our investigation,

• determine reportability.and file a final report on the issue.

RLC/gs (SW) 4 -

e ~-

m ,

q Page 5:of 5 y ,

w