ML20064K859

Interim Deficiency Rept Re Inconsistencies in Certifications for HVAC Matls Installed by Zack Co.Initially Reported on 811002.Vendor QA Manual Revised,Centralized Documentation Ctr Established & Procurement Documentation Reviewed

ML20064K859
Person / Time
Site:	Clinton
Issue date:	02/03/1983
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, U-10026, NUDOCS 8302150032
Download: ML20064K859 (4)

Text

. -

U-10026

/LLINDIS POWER COMPANY 1605-L CLINTON POWER STATION, P.O. BOX 678, CLINTON, ILLINOt$ 61727 February 3, 1983 l 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 81-04 4 -

10 CFR50. 55 (e)

Certification of HVAC Materials

Dear Mr. Keppler:

On October 2,1981, Illinois Power verbally notified Mr. H.

M. Wescott, NRC Region III, of a potential reportable deficiency per 10CFR50.55(e) concerning inconsistencies in the certifica-tions for Clinton Project HVAC materials installed by the Zack Company. This initial notification was followed by five (5)

Interim Reports: 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; and D. P. Hall letter U-10007 to J.

G. Keppler dated November 3, 1982.

Illinois Power's investigation has determined that this matter represents a reportabic deficiency per 10CFR50.55(e).

This letter presents an interim report in accordance with 10CFR50.55(e) (3).

STATEMENT OF REPORTABLE DEFICIENCY Investigation has determined that a breakdown in the Zack l Company (HVAC Contractor) Quality Assurance program had occurred l 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 numerous errors of omission, inaccuracies and in some instances, alterations or modifications. These errors and bg()

l 8302150032 830203

/y PDR ADOCK 05000461 S PDR FEB 7 E83

l Mr. James G. Keppler Page 2 NRC inconsistencies resulted in the material certifications being suspect and, therefore, the material suspect. These inconsis-

, tencies in documentation have, and will require extensive re-l sources to evaluate, correct, and prove adequacy of material, and is considered 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 four areas

l 1) Incomplete material. test reports, 4 ') Incorrect material test reports,

3) Improperly modified test reports, and 41 Possibility of indivliual(s) within the Zack Company improperly changing test reports.

As a result, the Zack Company issued Corrective Action Request (CAR) f014-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 #or 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 o#

noncon#orming purchase order / CMTR documentation packages.

Fi#ty-three (53) nonconformance reports have been submitted to Baldwin Associates for evaluation and disposition. The status of the #ifty three (53) nonconformance reports is as follows:

j a. reviewed by Tilinois Power Company Quality Assurance and Baldwin Associates, and considered closed....... 17

b. submitted to Sargent and Lundy for review........... 29 recommended disposition to "use-as-is" evaluated as acceptable.................. . 15 requires additional research and/or physical sampling and test of material............... 14

c. additional research required by Zack Company prior to closure by Zack...................................... 4

d. pending Baldwin Associates review and evaluation..... 3 Corrective Action Request 1014-b has not been closed to date pending completion of corrective action measures addressed in-this letter.

Mr. Jane. . Keppler Page 3 iTRC in addition to the actions being taken to resolve the identified documentation discrepancies, Illinois Power Quality Assurance has conducted three (3) evaluation / verifications of Zack Company's corrective action on this matter.

CORRECTIVE ACTInti The #ollowing f measures have been or are being taken to correct this de iciency and to prevent further recurrences:

1) Zack Company is revising their Quality Assurance Manual 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. Approval of the revised manual is scheduled to be accomplished by February 27, 1983.

1) The Zack Company's Corporate Training Practices, for Cicero, Illinois employees in quality assurance program requirements has been reviewed by Illinois Power Quality Assurance and was evaluated as being effectively implemented.

3) A centralized documentation center has been established within the Zack Company's Cicero, Illinois office.

Speci#ic guidelines have been established in Zack Company Quality Assurance Instruction (QAI No. 4) titled, " Control and Maintenance of QA Purchase Order /

Certified Material Test Report Files".

4) The Zack Ouality Assurance Department reviews all procurement documentation and receiving inspection reports for compliance. Procedures titled,

" Procurement" (PQCP-15) and " Receiving Inspection" (PqCP-1), incorporates the requirement for quality assurance review.

5) Unauthorized personnel are not allow'ed access to quality records at the Cicero, Illinois office, o) 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.

7) The Zack Company has added additional Quality Assurance personnel to support the upgraded procurement program.

t

8) Illinois Power and Baldwin Associates Quality Assurance Departments have increased surveillances and audits of Zack Company (Cicero, Illinois ) activities.

i .

Mr. James G. Keppler Page 4 MRC

9) Procurement documentation has been revalidated by the Zack Company Quality Assurance and Document Control Departments and results have indicated a - possible fifty-three (53) questionable procurement document packages. These are identified by a nonconformance report for each package. Resolution of these noncon-formance reports will assure that HVAC materials are adequate in meeting the design intent.

SAFETY IMPLICATIOMS/ SIGNIFICANCE At this time, the impact of this deficiency on the safety of operations o' Clinton Power Station is unknown, and cannot be ascertained until the nonconformance reports have been disposi-tioned, dispositioning action taken, and 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 disposition the nonconformance reports, evaluate for safety impact, and provide a final report on this matter.

This letter is hereby submitted as an interim report in accordance with 10CFR50.55 (e)(3) . I trust that is sufficient for analysis and evaluation of the deficiency and corrective action.

t Ve truly yours,

. . Tall Vice President cc: H. H. Livermore, NRC Resident Inspector Director, Office of I&E, Washington, DC 20555 Illinois Department of Huclear Safety Manager-Quality Assurance l

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