ML20082D575

Responds to NRC Re Violations Noted in IE Insp Rept 50-461/83-15.Corrective Actions:Baldwin Assoc Originated safety-related Procurements Now Stamped to Indicate Applicability of 10CFR21

ML20082D575
Person / Time
Site:	Clinton
Issue date:	10/27/1983
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20082D551	List: ML20082D575
References
0981-L, 981-L, U-10104, NUDOCS 8311220471
Download: ML20082D575 (3)

Text

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0981-L ILLINOIS POWER OOMPANY y_195gg CLINTON POWER STATION, P.O. BOX 678. CLINTON. ILLINOIS 61727 Ocbdwr 27, 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:

Response to Notice of Violation dated Sep tember 29, 1983, NRC IE Inspection Report Number 50-461/83-15

Dear Mr. Keppler:

This letter is in response to your Notice of Violation dated September 29, 1983, Inspection Report Number 50-461/83-15.

Illinois Power Company's response to the two items of noncompli-ance is as follows:

A.

The Notice of Violation states in part:

...five procurement documents for ASME Boiler and Pressure Vessel Code Section III welding filler metal identified as C-35773, C-35884, C-39946, and C-40763, did not specify that the provisions of 10 CFR Part 21 applied.

I.

Corrective Action Taken and the Results Achieved The five procurements identified (C-32587, C-35773, C-35884, C-39946, and C-40763) were for material purchased by Baldwin Associates from a single supplier of welding filler metal.

Other procurements from that supplier were reviewed, resulting in six additional instanccs where the provisions of 10 CFR Part 21 were not applied.

Procurement change documents, which will identify the 10 CFR Part 21 requirements, have been requested for these eleven procurements.

These changes are expected to be issued by November 21, 1983.

The applicability of 10 CFR Part 21 is identified in one of two ways for Baldwin Associates procurements.

For procurements written to safety-related design specifications, the requirements of 10CFR Part 21 are pre-established as part of the specification.

In contrast, safety-related procurements that do not invoke design specifications must specifically add 10 CFR Part 21 requirements to the procurement documentation.

A review of safety-related procurements, dated after January 6, 1978, i

8311220471 831117 g

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lMr.fJcmes G.;Keppler -

Page 2S,

October 27, 1983

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~~.which do not reference a design specification, is being accomplished.

Coupletion of the' review is expected by Novem3er~21, 1983.. Procurement change documents will be issued as required to adequately = identify.the requirements

'of;10 CFR-Part 21.

II.

Corrective Action to be Taken to Avoid Further Noncompliance L Baldwin ' Assoc'iates. originated : safety-related ' procurements

.are'now stamped tof indicate <the applicability of 10 CFR Part

-21.

'The stamping was instituted September 26, 1983 an' Lapplies_to all~ safety-related procurements.

III. Date' When Full Compliance Will' Be Achievea Illinois Power _ Company was in compliance on September 26, 1983.

.* *;* *-* *o* ***********-***************

5B.

The Notice of Violation states in part:

... instructions, procedtzes, or-drawings-did not rec uire that measurements be performed.for all 2" and uncer pipe' bends'to: assure that the bends were in compliance'with:thee8% ovality tolerance.

Consequently,; sufficient records were not available to furnish evidence of acceptable bent pipe.

~

I.

Corrective Action Taken and the Results Achieved Baldwin Associates _ Quality: Control-(BAQC) inspection of ASME pipe bends is included in thel provisions'of procedure QCI-302.- Although the_pr'ocedure requires inspection for ovality, the BAQC practice was:not to. record measuring equipment data when ' inspection verified conformance to requirements._ Ovality within_the; tolerances of the ASME

. Code,Section III, was documented by BAQC inspector acceptance on the' inspection checklist'or: fabrication

~

traveler.

The~ single-checklist entry denotes the acceptance 1 of'all: attributes?for the pipe _ bend.

Implementation;of. procedural requirements is. dependent upon P

clear. understanding of the written' procedure. "The wording

^

of procedure QCI-302 wasf sufficiently broad to allow misin-

' terpretation of the ' intended requirements.

Procedure-L>

QCI-302 wasurevised to' clearly state the requirement to h

document.the inspection for ovality of=ASME two inch and Lunder; pipe bends, i-

?

EBAQC performed-a reinspection on-a representative sample of

. completed. bends to identify possible nonconformances resulting from the unclear provisions of procedure!QCI-302.

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. Thirty = (30) travelers were selected.for ~ reinspection, F;

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. Mr. : Jamno G. --K ppler --

.Page 3 october 27, 1983 representing. sixty-four (64)Lpipe bends..All sixty-four (64) pipe bends.were within the ovality tolerances set by

the ASME Code,Section III.

'II.

Corrective Action to be Taken to Avoid Further Noncompliance Procedure QCI-302 was revised October 4, 1983 to. clarify the inspection frequency and to provide adequate: documentation of the inspection activity.

Every two inch and under ASME

_. pipe bend is inspected. for ovality. - A calibrated. measuring

'devicesisiused, and the documentation includes the identi--

fication., number and the' calibration due date for the device.

Concurrent with processing the revised QCI-302 for approval, BAQC: conducted a training session for piping / mechanical inspectors. - The ASME Code,Section III, ovality tolerances for pipe bends were reiterated and the proposed changes, later approved,_to QCI-302 were presented.

Training was-completed September 2, 1983.

2 III'. Date When Full Compliance Will Be Achieved Illinois Power Company was.in compliance on October 4,1983.

i

['

I-trust that'our; response is satisfactory.to allow closure

- of the items of noncompliance' identified in the - Notice of Viola-tion.

Sincerely yours,

.P Vice President LJRS/j f

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cc:

W. S. Little (Chief Engineering Branch 2, Region III)

Director, Office of I&E, Washington, D.C.

20555

'NRC Resident Office-

-Illinois Department of Nuclear Safety

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