ML20071B447

Interim Deficiency Rept 83-01 Re Qualification of Calibr Svcs Suppliers.Initially Reported on 830113.Investigation Plan Determined Need to Include QA Requirements in Procedure Documents for Calibr Tasks by Svcs Suppliers

ML20071B447
Person / Time
Site:	Clinton
Issue date:	02/18/1983
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, 83-01, 83-1, U-10031, NUDOCS 8302280309
Download: ML20071B447 (4)

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1605-L llLINO/8 POWER COMPANY IP U-10031 CLINTON POWER STATION, P.O. 80X 678, CLINTON, ILLINOIS 61727 February 18, 1983 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 Deficiency 83-01 10CTR50.55(e)

Qualification of Calibration Services Suppliers

Dear Mr. Keppler:

On January 13, 1983, Illinoic Power verbally notified Mr.

Frank Jablonski, NRC Region III, (Ref: IP memorandum "-14069 dated January 13, 1983, 1605-L) of a potentially reportable deficiency under 10CFR50.55(e) concerning the qualification of calibration services suppliers. Our investigation of this matter continues, and this letter represents an interim report in ~

accordance with 10CFR50.55 (e)(3) on this potentially reportable deficiency.

Statement of Potentially Reportable Deficiency Measuring and test equipment (M&TE) used at Clinton Power Station was calibrated, in some cases, by external sources that were not QA approved by pre-award evaluations or post-award audits. As a result, the validity of the calibrations performed by.these sources is indeterminate. An investigation is being performed to determine the scope of this problem, the validity of calibration performed by unqualified sources and the potential for impact on the quality of structures, systems, and components inspected and accepted using the affected measuring and test equipment.

1 I'J02280309 830218 PDR ADOCK 05000461

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Mr. J. C. Keppler Pags 2 F:bruary 18, 1983

Background

As a result of an Institute of Nuclear Power Operations (IUPO) evaluation of Clinton Power Station, it was revealed that Baldwin Associates (IP Contractor) and Illinois Power Company were procuring calibration services from unapproved sources (i.e. suppliers that have not been QA-qualified by pre-award evaluations or post award audits). A subsequent Illinois Power Quality Assurance (IPQA) surveillance (Y-14316) revealed that the INPO evaluation findings also applied to activities being per-formed by U.S. Testing Company (CPS Testing Agency), in as much as procurement of materials and services in support of U.S.

Testing Company is accomplished by Illinois Power Company. The results of the INPO evaluation and the IPQA surveillance culminated in the initiation of this investigation under 10 CFR50. 55 (e) .

Investigation Results (Interim)

In order to determine the scope of this problem and the adequacy of calibration services provided in the past, an inveatigation plan has been established and is being implemented.

This plan includes the following activities:

1. Review purchase orders and/or calibration certificates to identify calibration services suppliers used by Clinton Power Station: This activity has been com-pleted for M&TE used by U.S. Testing Company and Illinois Power, and is in process for quality acceptance tools used by Baldwin Associates (BA). This activity thus far has identified 126 suppliers of calibration services.

2. Develop a matrix of M&TE versus calibration organiza-tions and dates of calibration: This activity has been completed for the 126 suppliers identified in 1. above, and will be updated as additional suppliers are identi-fled. The purpose of this matrix is to catalogue the suppliers of calibration services and associated M&TE, and to track the status of actions being taken to validate previously performed calibrations.

3. Obtain QA qualified sources of calibration services:

In order to establish the qualifications of calibration sources, other utilities / organizations are being contacted to obtain results of the audits, evaluations, and/or surveillances of suppliers used by Clinton Power Station. Calibration services suppliers are being contacted to obtain copies of their quality assurance

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'Mr. J.fG. Kippl'or

'Pags~3- 1 February _18,71983

. programs for review by Illinois Power 1QualityL Assurance. Additionally, Illinois Power-and Baldwin-Associates arecscheduling and conducting pre - award surveys in an effort to obtain qualified: sources of calibration services.

4. Evaluate the adequacy of pasticalibration services performed: As QA-qualified suppliers become available, y arimary reference-standards not previously calibrated

)y a QA-qualified source willsbe sent out for re-calibration, requesting "as-found" and "as-left".

-data. Use-history analysis will be performed on those pieces of M&TE with unacceptable "as-found" data. .-This analysis will be used to. determine additional action necessary on a case-by-case basis.

Although progress is being made in these activities, it is.

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anticipated that the itctions deceribed above will not be complete until_ June 1, 1983. The need to cease the performance of acceptance testing and inspection using the affected M&TE vas evaluated and-deteruined not to be necessary during the evaluation / investigation period. During-this period, M&TE used for acceptance-testing at CPS will be identified and traceable to the work through inepection reports and test data sheets.

Unacceptable h&TE ideatified and used during the evaluation period will be analyzed as described in item 4, above.

An evaluation / determination.of IP/BA quality program require-ments that apaly to this issue was performed to determine the adequacy of the programs in meeting regulatory requirements and the requirements of the Clinton Power Station PSAR/FSAR. This review found that the procurement procedures utilized by Baldwin Associates and Illinois Power did not adequately. address calibra-tion services by external suppliers. More specifically,-proce-dures did not require the imposition of quality assurance program requirements in procurement documents for the controlHof.

calibration of M&TE, nor'did they require source evaluations of suppliers' performing the calibration services. This problem was caused by a misinterpretation of regulatory requirements with regard to " commercial grade" procurement, in that procurement of calibrationiservices was believed to be commercial grade.

In order to prevent recurrence of this problem, Illinois Power has begun to include applicable quality assurance program requirements in procurement documents for the calibration of measuring and test equipment by calibration services suppliers.

This action also includes procurement in support of U.S. Testing Company activities. Training has been provided to Illinois Power Quality Assurance personnel on February 10, 1982 on this subj ect.

Additionally' QAI-404.01 Procurement Document Review",, Illinois Power Quality is presently Assurance Instruc being

Mr. J.'G. Kappler. I Paga 4 February 18,-1983 revised to address-the requirements for imposing applicable Lquality assurance program _ requirements in: procurement documents for. calibration of M&TE. Baldwin Associates has also instructed:

their Quality Assurance personnel to include applicable quality assurance program requirements in procurement-documents for~

calibration of M&TE.. Further, Baldwin Associates has discon- ~

tinued the processing of procurement documents for calibration

-services until QA-qualified-sources have been obtained.

Procurement procedures are being reviewed and will be revised as-necessary.to assure compliance with regulatory and SAR. require-ments.

Safety Implicationc/ Significance We are currently investigating the effects of this potential .

deficiency on the validity of. calibration perforced by unqualified cources, and evaluating the.pctential impact on the .

quality of structures, systems, and components inspected and accepted ruing the affected measuring and test enttipment. .Until 5

these aspects of the investigation are completed, a detailed analysis of the safety implications of this potential deficiency ,

cannot be performed. .

It is anticipated that our-investigation'and analysis of , '

'this potentially reportable deficiency will be completed.by June 1, 1983, at which time a final report on this matter can be provided. We trust that this interim letter provides sufficient information to perform a general assessment of this potential ,

deficiency, and adequately describes our overall approach to resolve the problem.

ere yours,

. . Hal:.

Vice President cc: NRC Resident Inspector Manager-Quality Assurance 1: Director, Office of I&E, USNRC, Washington DC 20555 l Illinois Department of Nuclear Safety l

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