ML20116D099

Forwards Responses to Region III 850411 Comments & Questions Re Revs to Overinsp Program Implementing Procedure Concerning Evaluation of Sample Lots.Util Prepared to Discuss Responses at 850422 Meeting

ML20116D099
Person / Time
Site:	Clinton
Issue date:	04/19/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-60007, NUDOCS 8504290284
Download: ML20116D099 (9)

Text

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• s U-600007 L37 }) /U*A lA.120 ILLINDIS POWER COMPANY. . ,

CLINTON POWER STATION. P.O. BOX 678. CLINTON ILLINOIS 61727 April 19, 1985 " " I 72

'kls /j0 Docket No. 50-461 E- -

SV, Mr. James G. Keppler kIl" U$ $

Regional Administrator $;}Hg Region III 7 siwic-U.S. Nuclear Regulatory Commission /FILLMcgb 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect: Response to NRC Questions Concerning Clinton Power Station Unit 1 Overinspection Program Implementing Procedure Revisions.

Reference:

Letter, D. P. Hall to J. G. Keppler, U-0827, dated March 29, 1985, " Implementation of Illinois Power Company Overinspection Program."

Dear Mr. Keppler:

Reference 1 forwarded for information a description of the Overinspection Program implementing procedure revisions concern-ing the evaluation of sample lots prior to further reinspection or corrective action. Enclosure 1 to NRC's letter dated April 11, 1985 (J. G. Keppler to IP (Attn: W. C. Gerstner)) forwarded NRC Region III comments and questions concerning these revisions.

Enclosed at'a IP's responses to the NRC Re and questions contained in Enclosure 1 to NRC'gion s April III comments 11, 1985 letter. IP will be prepared to discuss these responses at the April 22, 1985 meeting to be held at the Region III offices.

IP believes that the information submitted in IP's March 29, 1985 letter U-0827 and the enclosed responses provide a complete base of information for the April 22, 1985 meeting and for completion of the NRC Region III review at the earliest possible time.

e, yours, 8504290284 850419 PDR G ADOCK 05000461 PDR D. . Hall Vice President JEK/skt Attachments cc: Director, Office of I&E, USNRC, Washington, D.C. 20555 B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Illinois Department of Nuclear Safety Allen Samelson, Assistant Attorney General, State of ApR 2 2 06b Illinois

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ENCLOSURE 1 ILLINOIS POWER RESPONSE TO NRC QUESTIONS AND COMMENTS REGARDING OVERINSPECTION PROGRAM IMPLEMENTING PROCEDURE REVISIONS This enclosure responds to the NRC questions and comments regarding Illinois Power (IP) letter U-0827, D. P. Hall to J. G. Keppler dated March 29, 1985, which were forwarded to IP as Enclosure 1 to the April 11, 1985 NRC letter from J.

G. Keppler to IP, attention W. C. Gerstner. The following NRC comments and questions are quoted directly from'Enclo-sure 1 of the NRC and are followed by the IP responses.

NRC COMMENT A:

Under the heading " Rejectable Lots", IP states:

1. The results of rejectable lots will be evaluated by IPOI or BAFV, as appropriate, to identify which spe-cific types of items or inspection attributes are responsible for the rejection of the lots. 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 nonconfor-mances. Based upon this evaluation, IPOI or 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 of and/or frequency of the nonconformances.

NRC QUESTION a: Where in the Overinspection Program Plan, which was previously reviewed and concurred in by Region III, does the plan delegate the authority and responsibility to IPOI to evaluate the results of rejectable lots?

IP RESPONSE TO NRC QUESTION a: The Overinspection Program Plan states in Paragraph 2.2 that "IP is responsible for program direction and execution. Other organizations provide engineering, quality and inspec-l tion services to support the overall program."

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In paragraph 4.4 of the Overinspection Program Plan a portion of IP responsibility for program execution, that of evaluation of rej ectable lots, is delegated to Baldwin Associates. Paragraph 4.4 also states that,

" Lots which provide samples which do not meet the

[ Acceptance Quality Level (from MIL-STD-105)] AQL will be returned to BA and subjected to reevaluation and possible reinspection.... The reevaluation will be written by BA and approved by IPQA."

IP has always had overall responsibility for the Overinspection Program and for review and approval of the evaluations of rejectable lots and the decisions made regarding subsequent actions.

In view of IP's overall responsibility for the Over-inspection Program and the stated responsibility of IP to approve reevaluation results (and to approve deci-sions made regarding subsequent actions), IP's revision of the subject implementing practice within the Over-inspection Program is consistent with the Overinspec-tion Program Plan.

NRC QUESTION b: What level of authority and technical qualifications must be held by individuals performing evaluations discussed in 1) and 2) above?

IP RESPONSE TO NRC QUESTION b: The process for eval-untion of rejectable lots and determinations as to further reinspections and/or corrective actions con-sists of two parallel paths:

1. IPQA (for OI lots) or BA Q&TS (for FV lots) will evaluate the rejectable lots as described in item 1, page 1 above and provide the evaluation to the IP Manager QA or BA Manager Q&TS, respectively, for a determination as to whether further reinspection or corrective action should be undertaken for all or a portion of the lot prior to completion of the engineering evaluation and determinations as described in item 2, page 1 above. This 7rovides a mechanism for prompt decisions to undertate re-inspection or corrective actions where those decisions can be made irrespective of the outcome of the pending parallel engineering evaluation and determinations. This might occur in cases where the work to reinspect the balance of the lot is small, all defects can be isolated to a common cause, or where large numbers of nonconforming attributes are identified. These evaluations and r

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determinations are intended to facilitate the prompt, effective and efficient execution of the reinspection process, and do not supplant the engineering evaluations and determinations in item-2, page 1 above.

2. Irrespective of the evaluations and determinations described in item 1, page 1 above, in all cases the engineering evaluations described in item 2, page 1 above will be performed by S&L and the results furnished to IP(NSED). The final determination as to further reinspection and/or corrective action will. be made by the IP Manager of NSED and the IP Manager of QA (OI lots) or the BA Manager-Q&TS (FV lots) with the approval of the IP Manager of QA and the concurrence of IP Manager of NSED.

The evaluations described in item 1 on page 1 will be i performed by the IP Supervisor of Welding, NDE and Testing for IPOI lots and the BA Manager of QA for BAFV lots. These individuals are appropriately qualified and are responsible for evaluating results and provid- 1 ing recommendations regarding further reinspection or l corrective action- to the .IP Manager of QA or BA Assis-tant Manager of Q&TS for approval.

The evaluations described in item 2.on page 1 will be 4 performed by qualified S&L engineers within the group responsible for the affected portion of the design.

The results of the evaluation will be provided to

- responsible S&L management for review, approval and submission to IP (NSED).

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NRC QUESTION c: What level of authority and tech-nlcal qualifications must be held by individuals  ;

determining what, if any, further reinspections should be performed or corrective actions taken as discussed j in 1) and 2) above? 1 NRC QUESTION d: What level of management review will

. be afforded to these activities?

l IP RESPONSE TO NRC QUESTIONS c and d: For evaluations described in item 1, page 1 above, determinations as to p what, if any, further reinspection or corrective

actions will be made as follows

1 i For OI lots determinations will be made by the IP Manager of QA.

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For FV lots, determinations will be made by the BA Manager Q&TS, with the concurrence of the IP Manager of QA.

For evaluations described in item 2, page 1 above, determinations as to what, if any, further reinspection or corrective actions will be made as follous:

For 01 lots determinations will be made by the IP Manager QA with the concurrence of the IP Manager of NSED.

For FV lots the determinations will be made by the BA Manager of Q&TS, with the concurrence of the IP Manager QA and the IP Manager NSED.

The above-mentioned Managers are appropriately qualified and during the review and approval process, Mr. D. P. Hall, Vice President of IP will be kept informed of these determinations.

IP RESPONSE TO NRC QUESTION d: In addition to the

, information provided above in response to question c above the IP audit and surveillance programs will serve to verify proper execution. IP and BA management will i be provided the results of the audits and surveillances in accordance with the IP corrective action program.

NRC QUESTION e: What, if any, quality assurance actions will be employed by IP to assure the proper implementation of this program change?

IP RESPONSE TO NRC QUESTION e:

NOTE:

The audit and surveillance functions of IP and BA were combined in and are now conducted by the IP audit and surveillance groups respectively.

Under the IP (and BA) Quality Assurance Program, all modifications in implementation practices are made through revision to procedures followed by training of personnel, implementation of the revised procedure and verification of satisfactory implementation. This i process is procedurally described and is controlled and verified by IP QA through procedure reviews and audits of the process. Specifically, the following steps are and will be followed by IP and BA for the subject procedure revisions:

1. Preparation of revised procedures.

2. -Review of revised procedures by the preparing organization (BAFV or IPOI) and by BAQA and IPQA (Quality Engineering Group) to assure that the requirements and commitments of the QA Program are met.

3. Review and approval of the revised procedures by IP Management and by BA Management for BA Procedures.

4. Training of IP and BA personnel in the revised procedures.

5. IP QA audit and surveillance of activities after procedure implementation to verify satisfactory performance.

NRC QUESTION f: What specific criteria will be used by BAFV, IPOL, and NSED (in conjunction with S&L) in performing the evaluations in 1) and 2) above?

IP RESPONSE TO NRC QUESTION f: The type of determin-ation described in item 1, page 1 is not amenable to the definition of specific criteria. However, the following factors will be considered in making this determination. If a lot is rej ected, it may be desir-able to complete the reinspection of the remainder of the lot or portions of the lot without waiting for the results of the evaluation described in item 2, page 1 above, based on the following factors:

The work required to reinspect the remainder of the lot is small (e.g. sample size already approaches lot size), or All defects cat be isolated to a common cause, or A large number of nonconforming attributes are identified.

The engineering evaluation in item 2, page 1 will be performed by S&L in the same manner as described in the report "Results of Quality Programs for Construction of Clinton Power Station, Chapter V. , Section C.2, Engi-neering Evaluation". Determination of what further reinspection or corrective action is appropriate will consider the results of this evaluation, and the

following specific factors

! If a safety significant nonconformance is ident-ified, the lot will be inspected for the remaining l _

attributes of the type for which the safety signif-icant nonconformance was identified.

Regarding the frequency of occurrence of nonconfor-mances. If 5% of the number of attributes inspect-ed in a lot are nonconforming and result in a category B classification (as defined in IP's separate Response to Question A.3 of Enclosure 2 to NRC's April 11, 1985 letter), the remainder of the lot will be reinspected for those attributes for which the evaluation of nonconformances resulted in a Category B classification.

NRC COMMENT g: Recent correspondence (IP Letter U-10233, D. P. Hall to J. G. Keppler dated January 5, 1985) from IP indicated that all NCRs generated by the IPOI program will be dispositioned and evaluated by the architect engineer (S&L). Reference 1 seems to contra-dict letter U-10233. In addition, IPQA recently

, identified in Audit Report Q38-85-02 that NSED did not 4

have an ANSI N45.2.11 design / design review program.

NRC QUESTION g: Considering the comments above, should NSED be delegated the authority and responsibility for engineering disposition and evaluation of 01 NCRs?

IP RESPONSE TO NRC QUESTION g: NSED has the authority and responsibility to disposition those BA FV NCRs which do not impact the CPS design basis, and therefore do not require review by the architect engineer (S&L).

Prior to January of 1985, the NCR review and disposi-tioning process for all NCRs at CPS contained the following steps:

BA Resident Engineering reviewed the NCRs and for certain types of nonconforming conditions could assign rework dispositions without further review and approval. All other NCRs were forwarded to NSED.

NSED reviewed the NCRs and could assign rework disposition to the NCRs or could make the deter-mination that the NCR did not constitute a valid nonconforming condition. These NCRs do not require further review and approval. All other NCRs were forwarded to S&L.

S&L provided dispositions for all NCRs not dispo-sitioned as described above.

S&L also performed the engineering evaluations for l safety significance of all NCRs generated by the l

Overinspection Program regardless of the source of.

the ' disposition 'as described above.

-In January of 1985, IP (in IP letter U-10233) notified

.the NRC that in order to reduce duplication of efforts all-NCRs generated by the IP Overinspection effort would be forwarded directly to S&L for simultaneous review, dispositioning and evaluations. This meant that the review-and dispositioning by BA Resident Engineering and NSED described above would not be performed for IPOI:NCRs.

The NRC comment states that letter U-10233 from IP indicated that all NCRs generated by the IPOI procram (emphasis added) will be dispositioned and evaluated by the architect engineer (S&L). IP Letter U-10233 stated that NCRs " generated by the IP Overinspection effort (Emphasis.added) will be processed directly to S&L for

... dispositioning ... ". Letter U-10233 intended .to refer only to IP Overinspection and not to all NCRs initiated by BA FV, as further indicated by the final sentence of that letter: "BA will continue to review and forward to S&L those Nonconformances, generated by Field Verification, which require engineering determin-ation."

The IP NSED role'is limited to dispositioning those'BA FV initiated NCRs for which the disposition is rework or those BA FV initiated NCRs~which,.upon review, do not constitute valid nonconformances. The basis for this is that neither of these~ cases would result in a potential change to the design and S&L review and engineering disposition for these cases is'not nec-essary. As contemplated by letter U-10233, BAFV initiated NCR's dispositioned use-as-is or repair do require S&L review and engineering disposition. NSED's activities in NCR dispositioning are procedurally described and controlled and subject to audit and surveillance by-IPQA. NSED is not dispositioning NCRs initiated by IPOI: this is done by S&L only.

In regard to engineering evaluations of Overinspection Program NCRs to determine' safety significance, S&L will perform those evaluations for all NCRs identified by the Program, whether or not the NCR is dispositioned by IP NSED or S&L.

To clarify the phrase in the IP letter, U-0827 (Refer-ence 1 in NRC Comment G) ... " rejectable lots will be evaluated by NSED (in conjunction with S&L)

, NSED is responsible for the IP interface with S&L concerning evaluations for safety significance and is responsible with IPQA for concurrence with IP m

determinations as to reinspections or corrective actions. See IP response to NRC Questions B and C above.

NRC COMMENT B:

Provide copies of the procedure changes and details of programmatic actions to Region III prior to their implemen-tation.

IP RESPONSE TO NRC COMMENT B: At the April 22, 1985 meeting, IP will provide information copies of the proce-dure revisions that include details of the programmatic actions to Region III prior to implementation.

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