ML20138K973

Forwards Comments Re 851115 Proposed Changes to Record Verification Program.Author Cannot Concur at Present. Violation & Two Unresolved Items Re Adequacy of Records & Record Verification Program Exist.Insp of Records Required

ML20138K973
Person / Time
Site:	Clinton
Issue date:	12/16/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Gerstner W ILLINOIS POWER CO.
References
NUDOCS 8512190128
Download: ML20138K973 (4)

Text

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DEC 1 6 1985 .

Docket No. 50-461 Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th Street -

Decatur, IL 62525

Reference:

Letter, D. P. Hall to J. G. Keppler, U-600318 dated November 15, 1985 Gentlemen:

This letter is in reply to your letter of November 15, 1985, in which you proposed changes to your Record Verification Program. Your letter stated that you believe there is adequate basis to terminate the Record Verification Program for all categories of records covered by the program with two_ exceptions: Electrical Equipment (old work) and Miscellaneous Non-Travelers (old work). Your letter specifically requested that we perform a prompt review of your proposal and provide comments prior to your tennination of the program.

We have completed our review of your proposal and our comments are enclosed.

We noted that attachment 2 to your letter specifically requested that Region III concur in the termination of the Record Verification Program.

We cannot concur in your proposed actions at this time. Our inspection activities related to your QA Record Program have assumed up to now that IP would complete the Record Verification Program based on your commitment to review "All (100%) safety-related, fire protection, and augmented class D system QA records for acceptability" (reference Records Verification Program, Section 2.1 Scope). For that reason, our inspection in this area has been limited to review of the Records Verification Program, review of personnel qualifications, review of Records Verification Program implementation, and a limited review of early program results (document exception lists and generic resolutions). Our inspections were documented in inspection reports 50-461/83008, 83016, 84002, 84015, 84017, 84040, 85003, 85018.-

85041, 85059, and various other inspection reports which address allegations related to your records and your Record Verificatior. Program. At this time, there are two unresolved items and one violation concerning the adequacy of Clinton Power Station records and the record verification program.

Additional inspection of the Record Verification Program results and the implementation of your nonnal Clinton Power Station QA Records Program will be required.

0512190128 851216 PDH ADOCK 05000461 A PDR

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Illinois Power Company. -

DEC 1 6 1985

, We will be prepared to perform the necessary inspections during January 1986.

i L~ Thank you for cooperating with us in this matter. If you have any questions l please contact R. F. Warnick at (312-790-5575).

t Sincerely, Original stead by

Mrs G. Koppfor -

James G. Keppler Regional Administrator

Enclosure:

Comments Concerning t

Proposal to Terminate the'IP Records Verification Program cc w/ enclosure:

DCS/RSB(RIDS)

Licensing Fee Management Branch Resident Inspector, Rill Richard Hubbard Gary N. Wright, Manager Nuclear Facility Safety Jean Foy, Prairie Alliance 1

Mark' Jason, Assistant Attorney General.

Environmental Control Division H. S., Taylor Quality Assurance Division e -m b M l

l \ Y'd y'd RI I1 R) R! RI g Rill RIII Warnick/r1 Mwkins Norelius yes Pape ello da s Ke 1er 12//A/85 2 12/pB5 12/(V/85 //E8512/1/85 12//> /85 12/ /4/85 l

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j ENCLOSURE COMMENTS C0f.tERNING^

PROPOSAL T0. TERM'NATE THE IP RECORDS

,, VERIFICATION PROGRAM ,

1. As you know, quality assurance records furnish' documentary evidence of

.. the quality of items and of activities affecting quality. Those QA

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records you have designated lifetime records are/ categorized by ANSI N45.2.9 as being records which,would be of significant value in demonstrating; capability for-safe operation; would be of significant

.' value in maintaining, reworking, repairing, replacing, or modifying an item; would be of significant value in determinin ' the cause of an

~'- accident or malfunction of an item; and those~ whi h provide baseline data for inGrvice fiTpectionf Thocy QA records'you hive designated Q' ' non perpanent aie categorized by ANSI N45.2.9 as reccrds of no significant value except as evidence that the activity was properly performed. We'found no indication in your submittal or.its referenced Results Reports that your evaluation of the Record Verification Program results considered the significyce of the record or the ' potential impact of record deficiencies (document exceptions) on your ability to safely

, operate, maintain, and modify the Clinton Power Station.

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2. The termination i.riteria used to support this proposal were very similar to thercriteria proposed for termination of the.0verinspection Program.

,, _. HowevLiB we believe there is a fundamental diffeiance between the purpose of the Record Verification Program and the purpose of the Overinspection

'Propanwhichcausesustoquestiontheapplicabilityofthecriteria used. In particular, criteria B and C of attachment 2 to your letter may not provide a sufficient basis to judge the adequacy of program results ,

'.g ot support,the proposed, termination.

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s With regard to criterion B, the criterion relates t'u the number of f ' s deficient attributes identified for a record commodity. However, the

..~ number of deficient attributes cannot be directly related to the number

,, of_ deficient records; not all commodity attributes are of equal importance when judging the acceptability of the records (acceptability as define with resp'd in your program);-ond ccttoplantoperationa], safety. not all. we,believe Thys records arethat of a equal importance f: ,quantitatio inalysis, by*ltself, is an inappropriate basis to judge m , record adequacy ,

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With regard to criterion C, the criterion relates to safety-significant

< nonconformances with generip implications. This criterien excludes the

,? majorityf of recorit! deficiencies identified under the Record Verification

Program (i.e., [liLs) whicih Jeems to presuppose their insignificance to l plant, safety; no justification is provided for this. -

3. Da iddGstand that the records categorized as "NEW ;;0RK" in Tables 2.1 and 2.2 6f attachment 2 to your letter had been subjected to all portions of your normal QA Progenm except IP receipt inspection prior to f 4

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performance of Record Verification reviews; nevertheless, significant  ;

numbers of deficient records attributes and some nonconforming hardware

! were identified during verification of those records. IP has not reported the significance of the record deficiencies identified or the number of

, affected records. We believe that IP should certify that the normal QA >

l Program can and will identify significant record deficiencies prior to l termination of the Record Verification Program. <

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