ML20081H692

Interim Deficiency Rept 55-81-04 Re Certification of HVAC Matls Installed by Zack Co.Initially Reported on 811002.Zack Co Revising Corporate & Site QA Manuals to Enhance Controls & Describe Programs for Complying w/10CFR50,App B

ML20081H692
Person / Time
Site:	Clinton
Issue date:	10/24/1983
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-10101, NUDOCS 8311070557
Download: ML20081H692 (4)

Text

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bM?8 ILLINO/S POWER OOMPANY 1005'L j][F U-10101 CLINTON POWER STATION. P.O. BOX 679. CLINTON. ILLINOIS 61727 October 24, 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:

Reportable Deficiency per 10CFR50.55 (e) 55-81-04 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 Company. This initial notification was followed by eight (8) 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; D. P. Hall letter U-10054 to J. G. Keppler dated May 23, 1983; and D. P. Hall letter U-10075 to J. G. Keppler dated July 22, 1983).

Illinois Power's investigation has determined that this matter represents a reportable deficiency in accordance with 10 CFR50. 55 (e) . This letter is submitted as an interim report in accordance with 10CFR50.55(e)(3).

Statement of Reportable Deficiency Investigation has determined that a breakdown in the Zack Campany (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 have required extensive resources to evaluate, h

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J. G. Keppler Page 2 October 24, 1983 NRC correct, and prove adequacy of material. On this 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 certi' ications for the Clinton Power Station HVAC materials , a numbwr 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) #014-b on September 25, 1981, which identified the prnblem, 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 (BA) (Illinois Power Contractor) , a final list of nonconforming material documentation packages. Fifty-three (53) nonconformance reports were submitted to Baldwin Associates and/or Sargent & Lundy (CPS Architect / Engineer) for evaluation and disposition. Forty-six (46) of the nonconformance reports have dispositioned the material acceptable-as-is, and one(1) nonconformance requires rework of the material to conform with the specification requirements. The remaining six (6) nonconformance reports are presently being evaluated to determine the adequacy of affected materials. Corrective Action Request

1. 0]4-b has not been closed pending completion of corrective action measures addressed in this letter.

Corrective Action The following measures have been or are being taken to correct this deficiency and to prevent further recurrences:

1) Zack Company is revising 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 fully approved June 30, 1983. The revised corporate manual was reviewed by BA and IP and comments were provided to Zack for incorpor-ation. Full approval for the corporate manual is scheduled to be accomplished by November 4, 1983.

2) A new Zack Company Corporate Indoctrination and Train-ing Procedure, CB-PQCP-2.1, has been prepared for

J. G. Keppler Page 3 October 24, 1983 NRC corporate office (Cicero, Illinois) employees which includes training in quality assurance program re quirements . This procedure is presently being reviewed by BA for adequacy and is scheduled for approval by November 18, 1983.

3) A centralized documentation center has been established within the Zack Company's corporate office. Specific guidelines for controlling and maintaining quality records have been established in Zack Company Corporate Procedure CB-PQCP-17.0. This procedure is presently being reviewed by BA for adequacy and is scheduled for approval by November 29, 1983.

4) The Zack Quality Assurance Department reviews all procurement documentation and receiving inspection reports for compliance. New Corporate Procedures CB-PQCP-4.1, -7.0, and -7.1 have been prepared to describe procurement document review, receipt, and source inspection. These procedures are expected to be approved by November 4,1983.

5) Unauthorized personnel are not allowed access to quality records at the corporate 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 enployees.

7) The Zack Company has added additional Quality Assurance personnel to supt.,rt the upgraded program.

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

l 9) Sargent & Lundy has developed a Technical Evaluation

Program of Zack installed HVAC systems that includes an I evaluation of certifications for Zack furnished mater-

! ials. The program was initiated on June 13, 1983 and is scheduled for completion in February, 1984.

10) The Zack Company Site Quality Assurance organization will review all material documentation prior to transfer of documentation to BA.

11) Baldwin Associates , Quality Assurance Vendor Surveil-lance group will perform a 100% review of Zack supplied documentation either prior to or concurrent with l transfer of completed HVAC systems to BA. In addition, j the BA and IP Document Review groups will perform i reviews of Zack Co. documentation on systems turned over to BA in accordance with the CPS Records Verifica-tion Program Plan.

F J. G. Keppler Page 4 october 24, 1983 NRC Safety Evaluation / Significance l An evaluation of forty-six (46) of the fifty-three (53) l nonconformance reports has shown that the actual materials used at CPS were adequate-as-is and therefore would not have resulted in an adverse impact on the safety of operation of CPS. In the one case requiring material rework, an analysis by Sargent &

Lundy has shown that the safety of operations would not have been affected had the problem gone uncorrected. The remaining six (6) nonconformances require an engineering evaluation to determine the adequacy of the installed materials. It is expected that an additional ninety (90) days will be required to complete our investigation and to file a final report on this issue.

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 solutions.

Sincerely yours,

. P'.' Hall Vice President RDW/j f cc: NRC Resident Office Director, Office of I&E, USNRC, Washington, D.C. 20555 Illinois Office of Nuclear Safety INPO Records Center

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