ML20113D330
| ML20113D330 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/29/1985 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-0827, U-827, NUDOCS 8504150238 | |
| Download: ML20113D330 (3) | |
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U-0827 L37-85 ( 0 3-2 9)-L I A'IE O ILLINDIS POWER 00MPANY IP CLINTON POWEH STATION. P.O. BOX 678. CLINTON, ILLINOIS 61727 March 29, 1985 Docket No. 50-461
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'7 f Mr. James G. Keppler W
Regional Administrator Q
4*A Region III 1"s s U.S. Nuclear Regulatory Commission A ::$j -
799 Roosevelt Road i
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Glen Ellyn, IL 60137 Subj ect:
Implementation of Illinois Power Company Overinspection Program
Dear Mr. Keppler:
This letter provides information regarding a change which Illinois Power (IP) is making in the practices used to implement the Overinspection Program.
As described in the Overinspection Program Plan, the IP Overinspection Program consists of two sample reinspections of plant hardware, one by the Baldwin Associates Field Verification (BAFV) group and a second by the Illinois Power Overinspection (IPOI) group.
Samples from lots are randomly selected using criteria for sample size derived from MIL-STD-105D.
Reinspec-tions are then conducted and results are documented.
Based on the reinspection results, lots are classified as acceptable or rejectable, again using criteria derived from MIL-STD-105D.
According to the Overinspection Program Plan, if a lot is determined to be rejectable, the lot is subjected to evaluation and possible reinspection by BAFV.
Any reinspections may be limited depending upon the results of the evaluation.
- However, in practice, although not required by the Overinspection Program, an evaluation of rejectable lots has not been conducted.
Instead an overly conservative approach has been taken by reinspecting 100% of the remainder of the lot.
For many lots, this practice has resulted in a 100% reinspection by BAFV and a 100%
reinspection by IPOI of the same lot.
This practice is resulting in the reinspection of types of items which have no identified nonconforming conditions but which may be in a lot that is rejected because of nonconforming condi-tions in another type of item.
It is also causing reinspection based on sample reinspections that identify nonconforming conditions which are superficial and insignificant to plant s a fe ty'.
gugg gi8S$h APR 1 1985 L
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Therefore, Illinois Power is revising the implementing procedures for the Overinspection Program to conform more closely with theLpractice which.was originally intended by the Overinspection Program Plan. In the future, an evaluation will be performed on.the results of BAFV and IPOI sample reinspections of a lot.
.Specifically, the following evaluations will be conducted:
Acceptable Lots Results of lots which are sample inspected and are statis-tically acceptable will be evaluated by IPOI or BAFV, as appropriate, and Nuclear Station Engineering Department (NSED) (in conjunction with Sargent & Lundy (S&L)).
This evaluation is intended to' determine whether a single nonconforming condition may be significant enough to warrant further action even though the lot is statistically acceptable.
Rejectable Lots Results of lots which are rejected will be subject to two types of' evaluations:
~1)
Results of rejectable lots will be evaluated by IPOI or BAFV, as appropriate, to identify which specific types of items or inspection attributes are-responsible-for the rejection of the lot.
IPOI or BAFV will then evaluate the nonconformances in these types of items and inspection attributes to determine whether further reinspections of these types of items or inspection attributes should be conducted regardless of the results of the evaluations conducted below in (2).
2)
Nonconformances identified. in rejectable lots will be evaluated by IP NSED (in conjunction.with' S&L) to determine the safety significance of the l-nonconformances.
Based upon this evaluation, IPOI or i
BAFV, as appropriate, and NSED will determine what, if any, further reinspection should be performed or corrective actions should be taken based upon the significance and/or frequency of the nonconformances.
i i.
Procedure revisions to accomplish the evaluation described'
- above are being prepared at this. time and will be implemented during Aprilfof 1985.
t-IP has concluded that the above actions will have several beneficial effects for Clinton Power Station.
First, those
- nonconforming conditions which are identified will be evaluated j
and treated according to their significance to plant safety.
Second,' inspection effort and resultant reporting will more closely reflect plant quality.
Third, inspection resources will be allocated to areas with identified deficiencies.
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If further.information-is required regarding this matter, please contact us at your convenience.
Sincerely yours,
D.
. Hall Vice President-JEK/skt Director, Office of I&E, US NRC, Washington, DC 20555 cc:
NRC Resident ~0ffice Illinois Departmer.t of Nuclear Safety