ML20086P168
| ML20086P168 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/14/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1605-L, 55-84-02, 55-84-2, U-10124, NUDOCS 8402270025 | |
| Download: ML20086P168 (3) | |
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,s g}h 1605-L ILLIN0/8 POWER COMPANY U-10124 CLINTON POWER STATION, P.O. BOX 678, CLINTON ILLINOIS 61727 February 14, 1984 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 10CFR50.55(e) Deficiency 55-84-02 Material Traceability
Dear Mr. Keppler:
On January 11, 1984, Illinois Power Company notified Mr. R. C._ Knop, NRC Region III,-(ref:
IP memorandum Y-18980, dated January 11, 1984) of a potentially reportable deficiency
-per 10CFR50.55(e) concerning material traceability at Clinton Power Station (CPS).
Our investigation of this issue continues, and this letter represents an interim report in accordance with 10CFR50.55(e).
Statement of Potentially Reportable Deficiency A condition potentially adverse to quality has been identified in the area of material traceability.
This concern'is based upon a number of Deviation Reports (DRs), Nonconformance Reports (NCRs), and Quality As'urance findings. documenting problems related to the identirication of electrical hanger materials installed at CPS by Baldwin Associates (CPS Constructor).
An evaluation of this issue is being performed to
-determine the extent of this problem, root causes, effect on installed hardware, and significance on the safety of operations of CPS.
Investigation Results/ Background On December 20, 1983, Illinois Power Quality Assurance issued Management Corrective Action Request (MCAR) Number 07 to identify.an adverse condition existing in the area of material traceability.
The basis for issuance of MCAR 07 included:
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lir. James G. Keppler February 14, 1984 1.
Untimely resolution of Baldwin Associates (BA) Corrective Action Request (CAR) Number 073, which identified a material f
traceability problem.
This problem was evidenced by a significant number of NCRs and DRs written to document electrical hanger support members installed without material identification numbers.
The lack of these numbers results in difficulty verifying that the installed materials are correct.
2.
A recent Illinois Power Quality Assurance Audit of BA disclosed problems regarding adherence to procedures related to material identification and traceability.
An Investigation Plan has been prepared and implemented by Illinois Power Company to investigate and address the concerns identified in this area.
The plan includes the following actions:
1.
A review of historical data leading up to issuance of MCAR 07 is being performed to identify the scope of past material traceability prchlems.
2.
A review of design requirements, specifications, procurement procedures, and construction procedures is being performed to evaluate adequacy of CPS material traceability program requirements and their implementation.
3.
A list of specific hardware installations affected by the naterial traceability problem will be compiled and cate-gorized.
4.
Data co!1ected in Steps 1, 2, and 3 above will be analyzed to determine the scope, root causes, and the significance of the issue.
5.
Corrective action to correct identified hardware / software deficiencies and their root causes will be determined and taken.
Corrective Action (Interim)
Investigation of this issue has determined that loss of identification of some materials was, in part, the result of lack of consistency in, and adherence to, procedural requirements.
To correct this situation, several Baldwin Associates Procedures, Job Instructions, and Quality Control Instructions have been revised to enhance controls for the identification of materials at receipt and when subdividing bulk materials into smaller units.
Training on the enhanced controls is being given to affected personnel concurrent with the procedural revisions.
Additional steps include a reorganization of laydown yards to clearly segregate materials, and a purging of the site of unidentified structural shapes and plate material.
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Mr. Jam;c G. Kappler February 14, 1984 Safety Implications / Significance Illinois Power Company's investigation of this potentially reportable deficiency is continuing.
The safety implications and significance of the issue will be assessed after further back-ground information is collected and evaluated.
It is anticipated that approximately six (6) months will be necessary to complete the investigation and to provide a final report on the issue.
Illinois Power intends to provide you an update on the investigation in approximately ninety (90) days.
We trust that this interim report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach to resolve this issue.
Sincerely yours,
/
. Hall Vice President RDU/ lag cc:
NRC Resident Office Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety INP0 Records Center i