ML20024D251
| ML20024D251 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/22/1983 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 1605-L, 55-81-04, 55-81-4, U-10075, NUDOCS 8308030388 | |
| Download: ML20024D251 (4) | |
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ILLIN01S POWER COMPANY 1605-L l3CE U-10075 CLINTON POWER STATION, P.O. BOX 678, CLINTON ILLINOIS 61727 July 22, 1983 Docket Number 50-461 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Deficiency 55-81-04 10CFR50.55(e)
Certification of HVAC Materials
Dear Mr. Keppler,
On October 2, 1981, Illinois Power verbally notified Mr. H.
Wescott, NRC Region III, of a potentially reportable deficiency per 10CFR50.55(e) concerning inconsistencies in the certifica-tions for-Clinton Project HVAC materials installed by the Zack 4
Company.
This initial notification was followed by seven (7)
' interim reports (ref:
L. J. Koch letter U-0325 to J. G. Keppler dated November 4, 1981; L. J. Koch letter U-0413 to J. G. Keppler dated February 3, 1982; W. C. Gerstner letter U-0474 to J. G.
Keppler dated May 3, 1982; W. C. Gerstner letter U-0524 to J. G.
Keppler dated August 3, 1982; D. P. Hall letter U-10007 to J. G.
Keppler dated November 3, 1982; D. P. Hall letter U-10026 to J.
G. Keppler dated February 3, 1983 and D. P. Hall letter U-10054 to J. G. Keppler dated May 23, 1983).
Illinois Power's investigation has determined that this matter represents a reportable deficiency per 10CFR50.55(e).
This letter presents an interim' report in accordance with 10CFR50.55(e)(3).
Statement of Potentially Reportable Deficiency Investigation has determined that a breakdown in the Zack Company (HVAC Contractor) Quality Assurance program had occurred in the area of 10CFR50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services.
A quality review of HVAC material certifications revealed that the certifications contained errors of omission, inaccuracies and in some instances, alterations or modifications.
These errors and inconsistencies resulted in the material certifications being suspect and, therefore, the material suspect.
These inconsistencies in documentation will require extensive resources to evaluate, correct, and prove adequacy of material.
On this 8308030388 e30722
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J. G. Keppler-Page 2 July 22, 1983 NRC 4
basis, this matter is considered to be a reportable deficiency per 10CFR50.55(e).
Investigation Results/ Background During a Zack Company Quality Assurance review of the certifications for the Clinton Power Station HVAC materials, a number of inconsistencies were identified.
These inconsistencies were categorized into the following areas:
1)
Incomplete or' missing material test reports, 2)
Incorrect material reports, and 3)
Improperly modified or altered test reports.
As a result, the Zack Company issued Corrective Action Request (CAR) 1014-b on September 25, 1981, which identified the problem, contained a plan of action to determine the extent of the problem, including a review of all material test reports for accuracy and completeness, and a time frame for completion.
As a result of this review, Zack Company has generated for Baldwin Associates (Illinois Power Contractor),.a final list of noncon-forming purchase order / certified material test report documen-tation packages.
Fifty-three (53) nonconformance reports have been submitted to Baldwin Associates for evaluation and disposi-tion.
The status of the fifty-three (53) nonconformance reports is as follows:
a.
Closed by Zack; reviewed by Illinois Power Company Quality Assurance (IPQA) and Baldwin Associates, and considered closed................................
24 b.
Closed by Zack; not yet verified by IPQA..........
0 c.
Submitted to Sargent & Lundy (Illinois Power Architect
-Engineer) for review with recommendation to use-as-is.........................................
3 d.
Additional research/ testing required by Zack......
6 e.
Pending Baldwin Associates review and submittal to Sargent & Lundy...................................
1 f.
Dispositioned use-as-is by Sargent & Lundy and con-curred by Illinois Power Company Quality Assur-ance.............................................
19 Corrective Action Request #014-b has not been closed pending completion of corrective action measures addressed in this letter.
In addition to the actions being taken to resolve documentation discrepancies, Illinois Power Quality
J. G. Keppler Page 3 July 22, 1983
.;NRC
-Assurance has conducted three (3) evaluations / verifications of Zack Company's corrective action on this matter.
Corrective Action-The following measures have been or'are being taken to correct this deficiency and to prevent further recurrences:
1)
Zack Company has revised its Corporate and Clinton Site Quality-Assurance Manuals to enhance controls and describe, in detail, the programs-for assuring that.the requirements of 10CFR50, Appendix B, and the HVAC Installation Specification K-2910 are met.
The revised site manual was reviewed and given. conditional approval-September 30, 1982, and full approval June 30, 1983.
The revised corporate manual was reviewed and given conditional approval April ll, 1983.
Full approval for i
the corporate manual is scheduled to be accomplished September 15, 1983.
2)
The Zack Company's Corporate Training Practices for Cicero, Illinois employees in quality assurance program requirements were reviewed by Illinois Power Quality Assurance and evaluated as being effectively implemented.
3)
A centralized documentation center has been established within the Zack Company's Cicero, Illinois' office.
Specific guidelines _have been established in Zack
~
Company Quality Assurance Instruction (QAI No. 4) titled, " Control, Content, and Maintenance of QA Purchase Order / Certified Material Test. Report Files".
4)
The Zack Quality Assurance Department reviews all procurement documentation and receiving inspection reports for compliance.
Procedures titled, " Procure-ment" (PQCP-15) and " Receiving Inspection" (PQCP-1),
incorporate the requirement for quality assurance review.
5)
Unauthorized personnel are not allowed access to quality re ords at the Cicero, Illinois office.
6)
Zack Company management has established, in written directives, a company policy addressing disciplinary action to be taken as a result of instances of failure to follow procedures by employees.
i 7)
The Zack Company hac added additional Quality Assurance personnel to support the upgraded procurement program.
8)
Illinois Power and Baldwin Associates Quality Assurance 4
Departments have increased surveillances and audits of Zack Company (Cicero, Illinois) activities.
4
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'J. G. Keppler Page 4 July 22, _1983 4~,. ; NRC 9)
Procurement documentation has been revalidated by the 4
Zack Company Quality Assurance and Document Control Departments and results have indicated-fifty-three (53) questionable procurement document packages.
These are identified by a nonconformance report for each package.
Resolution of'these nonconformance reports will assure that HVAC. materials are adequate in meeting the design
. intent.
J 10)
Sargent & Lundy has developed a Technical Evaluation
' Program of Zack' installed HVAC systems that includes an evaluation of certifications for-Zack furnished mater-ials.
The program was initiated on June 13, 1983.
Documentation is being provided by Zack and Baldwin Associates for Sargent & Lundy review.
Sargent & Lundy is presently writing procedures and finalizing sched-ules for this program.
Safety Implications / Significance At this time, the impact of this deficiency on the safety of operations of Clinton Power Station is unknown, and cannot be ascertained until the nonconformance reports have been disposi-tioned, dispositioning action taken, and the reports closed.
The corrective actions identified above will identify and assure resolution of all potential documentation and material discrep-ancies -and will prevent further discrepancies.
It is anticipated that ninety (90) days will be necessary to evaluate and disposi-tion the nonconformance reports, evaluate for safety impact, and provide a final report on this matter.
4 This letter is submitted as an interim report in accordance
~ with 10CFR50.55(e)(3).
I trust that the information provided is sufficient for you to evaluate both the deficiency and our proposed corrective action.
Sincerely yours, D. P. Hall y
Vice President RAW /j f cc:
H. H. Livermore, NRC Resident Inspector Director, Office of I&E, USNRC, Washington, D.C.
20555 Illinois Office of Nuclear Safety Manager-Quality Assurance l
INPO Records Center i
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