ML20042B022
| ML20042B022 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/17/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| References | |
| NUDOCS 8203240404 | |
| Download: ML20042B022 (1) | |
Text
-
js' d
/
Docket No. 50-461
/,,
Illinois Power ra-pany
.*y ~
ye ATTN Mr. W. C. Cerstner 2]z
'Q n,
A.,
a d :a L'
Executive Vice President 0
^^'
l 500 South 27th Street
\\(3 i
Decatur, Illinois 62525 E '
f9 Ny
,^. y q~, 7 7 - -
Centlemen:
j
'3nank you for your letter dated February 23, 1982, informing us of the actions you have taken, or plan to take, to strengthen the overall I111acis Pouer Company QA Program for the Clinton Nuclear Power Station.
We appreciate you and Mr. Kelley meeting with me and members of my staff l
in the Region III Office on February 23,.1982 to discuss your QA Program.
In preparing your response to our Confirmation of Action Letter, dated January 27, 1982, please ensure that you provide a complete detailed desc2iption of the actions *=han to determine the quality of installed, completed, and in process, electrical items as well as the programmatic changes in effect which will assure the quality of new work. Also, please consider the informal comuments provided to members of your staff on March 11, 1982 by Mr. H. Livermore, NRC Senior Resident Inspector, regarding enclosures B and C-to your February 23, 1982 letter.
l We will be in contact with you in the near future to arrange a meeting in the Region III Office to discuss your progress in upgrading your QA Progrant and the verification of installed electrical items.
Your cooperation with us is appreciated.
i
. Sincerely, Original signed by James G. Keppler James G. Keppler Regional Mainistrator ec w/1tr dtd 2/23/82:
IEB/ Document Control Desk (RIDS)
Resident Inspector, RIII Mary Jo Hurray, Office of Assistant Attorney General-Gary N. Wright, Manager Nuclear Facility Safety Randall L. Plant, Prairie
/[fj/ g Alliance
, R III
,R III R II R III R III,
, ;Nork.
R I gg R III OF F ICI Wescott/N Knop /
~4yf[f;;)'
.. 1.. 7.. g g fl ijgy Lit $le
~
Ke cr/
s a % Love /c Williams 8203240404 829317
~~gpfg'fyg
,,,) fy,,.'7; ' ' '
';itT T ' % '
..i.
1
- PDR ADOCK 05000461
[gg gfg[ppggfj\\[( [g[ggg{g[g) g{dypp
]
NR
a 0982-L U
//LINDIS POWER COMPANY
' K f q3 _
z9,_g3y_L W' j 500 SOUTH 27TH STREET, DECATUR, llONOIS 67525 February 23, 1982 1
.1*
Mr. James G. Keppler Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 61037
Dear Mr. Keppler:
l Many significant actions have been taken by Illinois Power Company since January 15th which we believe places added emphasis on quality for the Clinton Power Station Project.
These actions will not only increase Illinois Power QA and construction management involvement in the contractor's construction j
management and quality programs, but also strengthen the overall l
IP QA program.
I i
The details of those actions taken and those that are planned are further described in the enclosures to this letter.
While some actions are not yet complete, I believe that it is essential-to recognize that the upper management of IP is firmly committed towards building and operating a plant which is safe and wh.ich on a day-to-day basis emphasizes quality.
It is our intent to keep you advised as to the further progress we make in accomplishing the direction outlined 19 this letter.
(
Sincerely,
/
~
spy anu s W.C.
Gerstner l
Executive Vice President 1
Enclosures:
A.
CHRONOLOGY OF EVENTS
, ILLINOIS POWER COMPANY B.
NEW QUALITY ACTIONS C.
STOP WORK RECOVERY PLAN - ELECTRICAL i
cc:
H.H. Livermore, NRC Resident Inspector i
Wendell J. Kelley, President and Chairman Director, Quality Assurance
<^ 1 exQQ%@Wk b~'
CK
Enclosure A C11RONOLOGY OF EVENTS - ILLINOIS POWER COMPANY JAN. 15 STOP WORK ON CABLE TRAY ISSUED.
JAN. 28 IP ISSUED STOP WORK CLARIFICATION.
JAN. 29 NRC-IP MANAGEMENT MEETING.
FEB. 1 IP MANAGEMENT ASSESSMENT OF NRC~ MEETING.
- s.
FEB. 1 EXECUTIVE V.P. RESPONSIBILITIES REALIGNED TO EMPHASIZE QUALITY.
FEB. 2 IP DIRECTOR QA REPORTING TO EXECUTIVE VICE PRESIDENT.
FEB. 3 EXECUTIVE-V.P. MEETINGS WITH BA & IP CONSTRUCTION PERSONNEL AND BA TECHNICAL SERVICES PERSONNEL.
FEB. 3 FORMATION OF AD HOC TASK FORCE BY EXECUTIVE C.P.
TO ASSESS ELECTRICAL CONSTRUCTION ACTIVITIES.
FEB. 3 COMMITMENT TO NRR TO RESTRUCTURE OPERATIONAL QA/QC ORGANIZATION.
FEB. 3 HIRED ASME AND QA CONSULTANTS.
FEB. 4 EXECUTIVE V.P. MEETINGS WITH REMAINING BA CONSTRUCTION PERSONNEL, IP QA SITE PERSONNEL, AND BA QAjQC PERSONNEL.
FEB. 6 AD HOC TASK FORCE PRELIMINARY REPORT SUBMITTED TO EXECUTIVE V.P.
~
l
[
FEB. 8 NEW BA MANAGER Q&TS CONCURRED WITH,BY EXECUTIVE V.P.
FEB. 8 EXECUTIVE V.P. MEETING WITH QC INSPECTORS.
FEB. 8 QA LETTER OF RECOMMENDATION SUBMITTED TO EXECUTIJE V.P.
(
FEB. 15 AD HOC TASK FORCE FINAL REPORT SUBMITTED TO EXECUTIVE V.P.
l i
FEB. 17 EXECUTIVE V.P. MEETING WITH BALDWIN ASSOCIATES BOARD OF DIRECTORS.
e T
Enclosure B Page 1 of 3 NEW QUALITY ACTIONS 1.
IP Executive Vice President responsibilities have been realigned to give daded emphasis to Quality.
2.
Organization changes have been made to enhance the effectiveness of quality assurance activities, The IP Director-QA reports directly to the Executive a.
Vice President.
b.
The IP Executive Vice President provides project direction to the BA Manager of Quality and Technical Services...
IP Quality Assurance Department will assume operational c.
Quality Control responsibilities.
d.
A person very familiar with the present program has been appointed BA Manager of Q&TS.
3.
The IP Executive Vice President is ascembling a team to perform an overall assessment of the Quality Assurance program and implementation as applied to electrical, mechanical, and piping construction activities ~. -
The IP President-and Chairman will participate in the team selection, scoping of the. assessment, and -.
review' of results'. -;
4.
A consultant will be hired to perform an evaluation of project training and to assist with implementing an necessary changes to enhance our training progrcms.y 5.
A " Quality Report" program, using a suggestion form, will be administered by the IP Executive Vice President and the Director-Quality Assurance to provide a mechanism for all personnel to report concerns and identify problems related to quality.
6.
The staffs of the IP and BA Quality organization, BA Project Engineering, and IP Clinton Project Management Compliance are being increased.
The larger staffs will allow IP and BA to:
give more attention to identifying the root a.
causes of discrepant conditions and track l
O
Enclosure B Page 2 of 3 corrective action to insure it is completed in a timely fashion, b.
review open NCR/DR/FCRs with added emphasis on expeditious closure.
c.
increase surveillance of construction activities.
7.
The IP Executive Vice President has received recommendations for quality assurance program improvements from the Ad Hoc Task Force and from the IP Director-Quality Assurance.
A number of these recommendations are currently being implemented. The remaining recommendations are being evaluated; those considered necessary.willlbe: implemented by means such as management directive and procedure changes.
8.
Additional emphasis on quality is being provided by the following:
Progressive elimination of change-implemented Field a.
Change Requests (FCR).
b.
IP QA will appro.ve Baldwin Associates Procedures and Job Instructions prior to issue.
c.
IP QA~will perform an in-line review of BA-Quality ~ Ass ~urance Pr6~cedurbs, Tedhnical '
Servicds-Procedures, Quality Assurance- -
Instructions, Quality Control Instruction, and.
Technical Service Instructions.
Commen'ts resulting from the reviews will be resolved prior to issuance of the procedures / instructions.
d.
IP QA will increase emphasis on periodic (at least annually) evaluation of the effectiveness of the QA Program implementation of specific departments using audit and surveillance reports, trending data, etc.
9.
Action is being taken to provide more attention to ensuring that prompt and adequate corrective action is taken in response to discrepant conditions.
a.
IP QA in-line approval of NCRs I O e
oe-
Enclosure B Page 3 of 3 b.
BA QA approval of DRs with additional emphasis on review for adequate corrective action.
IP QA monthly surveillance of DRs to assess adequacy of c.
content, dispogition, and corrective action.
d.
IP QA has started trending IP audit and surveillance
- findings, Additional emphasis on BA trending of NCRs, DRs, e.
electrical hanger checklists, pipe hanger checklists, piping system walkdown checklists and associated corrective actions.
f.
Established a Management. Corrective Action Request (MCAR) System to provide management visibility and assure immediate corrective action-is taken to resolve important conditions adverse to quality.
g.
STOP WORK action will be taken when prompt and adequate corrective action is not completed in a responsive manner.
h.
BA QA will perform in-line review of NSSS Mechanical Equipment installation travelers.
e e
I e
Wh
Enclosure C Page 1 of 2 STOP WORK RECOVERY PLAN - ELECTRICAL
- s GENERAL PLAN 1.
Prepare various electrical procedures / instructions.
Revised BAP 3.3.1 - Raceway.
Revised BAP 3.3.6 - Raceway Supports.
Created BAP 3.3.9 - Cable Protection.
Revised Job Instruction E-008.
Revised QCI.405 - Exposed Conduit.
Revised QCI 403 - Cable Tray.
Revised QCI 401 - Raceway Hanger.
Revised QCI 102 - Conduct of Inspections.
(These procedures / instructions have been written.)
2.
Procedure / instruction review and approval by IP QA and Ad Hoc Task Force.
(The above procedures / instructions are currently in the review-approval cycle.)
3.
Issue procedures / instructions---These procedures /instruc-tions include the practice that Category I cable tray and attachments will be completed by-construction and accepted by QC prior to pulling any cable.
Further, these procedures / instructions have been revised to require the use of travelers for cabic tray attachments.
4.
Conduct trai6ing for IP and BA Construction, Engineering, and Quality Personnel on procedures / instructions.
5.
Prepare new Travelers based upon the revised procedures.
6.
Select a sample of approximately 100 Travelers for controlled release of work.
7.
Perform work, s
e ed
Enclosure C Page 2 of 2 8
Construction walk-down per instructions---Construction personnel familiar with the cable tray installation process will walk down completed tray using a construction checklist.
Incomplete work will be completed by construction.
q..
9.
QC Inspection---QC will inspect completed tray after the construction walkdown and will use a checklist to perform the inspection.
Incomplete work will be returned once to construction for completion.
Upon resubmittal of work for reinspection against the original checklist, if the work is nonconforming then the adverse conditions will be documented on NCR/DR. In addition, incomplete work identified on checklists will be trended by EA QA.
The General Inspectica Report (GIR) will no longer be used to document discrepancies in electrical work.
10.
Perform IP QA r.urveillance of cable tray construction and inspection activities using QA ' checklist.
11.1 Evaluate results ofJIP QA'survei11ance, QC inspection, and construction walkdown.
12.
Release a second sampte increment of work based upon assessment of first sample.
l CONCURRENT ACTIVITIES-1.
BA QA is reviewing,all open;slectrical General Inspection Reports (GIR) 2aul is documenting nonconformances on either. a nonconformance report (BAP 1.0) ot; a deviati'on report (BAP 1.0.1).
2.
BA QA is reviewing open noncenformance reports (NCRs) and open deviation reports (DRs) to identify conditions which should be tagged ind which may not initially have been tagged.
NCR/DR tags will be placed on equipment determined 1
to require tagging.
BA QA is conducting a surveillance to verify that tags previously applied to equipment as a result of open NCRs and 'DRs are still in place.
3.
IP QA ic performing a review of open IP Construction QA surveillance findings and is initiating a NCR/DR for any nonconfo'rming condition notL previously identified on a NCR/DR.
T
- 4. T BA QA is phrforming a review of_ open Corrective Action Requests (CARS) and is 'initiatihg a NCR/DR for any nonconforming conditicd not previously identified on a NCR/DR.
e-
~
s e
i j
i
.