ML20100G119
| ML20100G119 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/22/1985 |
| From: | Hall D, Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 55-84-14, U-10260, NUDOCS 8504080081 | |
| Download: ML20100G119 (4) | |
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ILLIN0/S POWER 00MPANY 1A.120 M
U-10260 CLINTON POWEH STATION, P.O. BOX 678, CLINTON. ILLINOIS 61727 March 22, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Potential 10CFR50.55(e) Deficiency 55-84-14:
BAQA Vendor Surveillance
Dear Mr. Keppler:
On June 21, 1984, Illinois Power Company notified Mr. F.
Jablonski, NRC Region III, (Ref:
IP memorandum Y-20648 dated June 21, 1984) of a Baldwin Associates' potentially reportable deficiency concerning Quality Assurance (BAQA) Vendor Surveillance Program.
This initial notification was followed by two (2) interim reports (ref: IP letter U-10181, D. P. Hall to J. G.
Keppler dated July 20, 1984 and IP letter U-10231, D. P. Hall to J. G. Keppler dated December 18, 1984).
Illinois Power's investigation of this issue is continuing and this letter is submitted as an interim report in accordance with the requirements of 10CFR50.55(e).
Attachment A provides details of our investigation to date.
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 TW/1r (NRC2)
Attachment cc:
NRC Resident Office, V-690 Director, Office of I&E, US NRC, Washington, DC 20555
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ATTACHMENT A.
ILLINOIS POWER COMPANY CLINTON POWER STATION Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-14:
EBAQA Vendor Surveillance INTERIM REPORT Statement'~of Potentially' Reportable Deficiency During routine surveillance activities, a significant number of discrepancies were identified'with contracts which were assigned'to a specific BAQA Vendor Surveillance Engineer during
.his-employment with Baldwin Associates-(BA).
The specific contracts involved'and a description of1 discrepancies found are documented on Baldwin Associates' Corrective Action Request (CAR)
No. 173.
Background' Prior to-the issuance of CAR Na. 173 a number of program discrepancies were identified, such as:
Vendors performing fabrication special processes o
without purchaser s approval of procedures as required by Purchase Order.
o Vendors failed to notify aurchaser of, inspection point and released shipment without. purchaser release authorization.,
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Vendor permitted fabrication.of Class IE Battery racks at an unapproved facility..
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, Vendor. Surveillance Engineer failed to' establish'an Inspection Hold Point' program at Vendors facility as
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F 1 required by Purchase Order.-
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Vendor failed to submit copies of-documentation
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required by Purchase Order.
As a result.of these program discrepancies identified fagainst purchase orders that were the: responsibility of a 1 specific BAQA1 Vendor Surveillance Enginee.r, CAR 173 was issued.
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. Illinois. Power Company developed anc implemented a correc-tive actioniplan to evaluate and provide-resolution'to' CAR'No.
173 and investigate 1the potentially/ investigation ~ plan required reportable deficiencies
~ identified.
The corrective action
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the. followings.
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d ATTACHMENT A (continued) j;
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CAR-173 Corrective Action-Plan
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5 A 100% review ofrall procurement documentation
_ supplied for each. procurement contract. assigned to
.the specific BA Vendor Surveillance Engineer.
10CFR50.~55(e), Investigation Plan
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-1.;
Identify all Purchase Orders:(P.iO.) assigned to the f
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specific Vendor / Surveillance Engineer.
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Review' procurement specification to establish technical requirements.
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. Develop documentation checklists for established l requirements'.
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Identify all Receiving Inspection Reports-(RIR) for each P.O.
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Identify all equipment / material received on each RIR.
6.
Review procurement documentation for each contract to the checklist.
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-Document all nonconformances identified during review.
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Process Nonconformance Reports per established procedures. Nonconforming Material: Report (NCMR) by IP l
for'all turned over items: Nonconformance Report (NCR) i by BA for. items still in their-control.
I' 9.
Determine:reportability based on safety significance of the noncon!ormances-identified.
t Investigation Results/ Corrective ~ Action l;
F Items 1-.thru 8 of the Corrective Action / Investigation ~ Plan j'
have been: completed.
The review addressed fourteenf(14) purchase y
orders involving 311: Receiving? Inspection ~ Report packages. 'This review'resulted in'the' issuance of four-(4) nonconformance reports..
Two (2);NCMRs, Nos. 2-0142 'and 2-0143 were issued _ by IP i
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against items. supplied iniaccordance with Sargent & Lundy
-(S&L)~ specifications?K-2928'(Eberline)oand K-2930 (Victoreen) respectively.
Two i(2)fNCRs,E Nos. 27376 and ~ 27377 were ' issued by BA against
- K-2976 (pplied=per: S&L specifications K-2982 (Okonite)Jand '
items su Gould);respectively.
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ATTACHMENT A~
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' Additionally,-ten (10)-BA "Open Item Reports" (numbers
- 269-277, mand 279) were generated to document minor
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discrepancies that require resolution.-
These types of
- discrepanciesiare missing certificates of compliance, of l incorrect. entries on documents or missing' test reports.
The'nonconformancetreports have been reviewed and Edispositioned as.follows:
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ot NCR 27376 "Use-as-is" based on S&L :telecon with cable manufacturer in which cable manufacturer stated that
. subject cables' meet the requirements of IPCEA S-19-81, Section14.13.11 based on testa performed on similar cables with"similar types of construction requirements.
co NCR-27377
-HCC 1DC15E, Section 4 "Use-as-is".
The testscperformed on the power circuits is'aufficient for this.section.
For;the remaining 5 MCC units the disposition'is to perform megger testing of the central wiring to meet the intent of the specification
' requirements.
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NCMR 0-142 and 0-143 - Contact Vendor of systems and request themLto identify the documentation furnished to support the test requirements of the' specification.
The'nonconformance reports were reviewed by the appropriate organizations within IP and BA and were judged not -potentially reportable under the_ provisions of.10CFR50.55(e) or 10CFR Part 21.
!Sargent & Lundy will review all of'the identified i
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discrepancies and provide a statement'of safety significance for
.each' condition-documented.
Root'Cause
.The-conditions described in CAR-173 were attributed to the lacklof. understanding, on1the part.of1the Vendor ^ Surveillance Engineer,Jin performing surveillance-functions.which verify conformance.to; procurement contract requirements.-
Safety-Implications / Significance
-Illinois Power' Company's< investigation of this potentially re ortable~ deficiency is: continuing.
The safety; implications and si ificance will.be established after.the completion of' activity No.u9-in.the; revised-10CFR50.55(e)fInvestigation' Plan.
It isfanticipated that:approximately one month is require'd
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^to completeethel Investigation: Plan and issue;a finalJreport.
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