U-602960, Part 21 & Deficiency Rept Re Commerical Grade Dedication Program of Sentry Equipment Corp.Initially Reported on 980217.IP Performed an Addl Assessment at Sentry Facility on 980226.Next Rept Will Be Submitted by 980411

Part 21 & Deficiency Rept Re Commerical Grade Dedication Program of Sentry Equipment Corp.Initially Reported on 980217.IP Performed an Addl Assessment at Sentry Facility on 980226.Next Rept Will Be Submitted by 980411

ML20248L127
Person / Time
Site:	Clinton
Issue date:	03/12/1998
From:	Walter MacFarland ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-98 U-602960, NUDOCS 9803180409
Download: ML20248L127 (4)

Text

f: ~g flhnois Power Company

, Chnton Power Station

, P.O. Box 678 Chnton. IL 61727

, Tel 217 935-5623

.. Fax 217 935-4632 Walter G. MacFarland IV g g Chief Nuclear Officer P(MNER -vamo An lHmova Company 4F.140 l

March 12,1998 i

l Docket No. 50-461 10CFR21.21 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

10CFR21 Initial Report 21-97-060:

Sentry Equipment Corporation Commercial Grade ,

Dedication Program Failure to Comply with 10CFR. Part 21

Dear Madam or Sir:

On February 17,1998, Illinois Power (IP) issued 10CFR21 Interim Report 21-97-060 in letter U-602939 to notify the NRC that an evaluation for deportability under  ;

the provisions of 10CFR, Part 21, was not complete for deficiencies discovered in the commercial grade dedication program of Sentry Equipment Corporation (Sentry).

Sentry supplies IP with replacement parts for the two safety-related Drywell and Containment Hydrogen and Oxygen Analyzers in use at Clinton Power Station (CPS).  ;

> The following information updates the data provided in the letter dated Febmary 17, i 1998.

On December 17,1997, during the triennial supplier audit to verify the adequacy  ;

and implementation of the Sentry quality assurance program, IP identified that Sentry j did not have documented procedures for controlling their commercial grade dedication .

process. As a result, Sentry is unable to furnish sufficient objective evidence providing reasonable assurance that items Sentry supplied to IP have been procured or tested to requirements needed to demonstrate that the parts are capable of performing their intended safety functions. The Drywell and Containment Hydrogen and Oxygen Analyzers provide the capability of monitoring and indicating normal operating and post

, acciJent hydrogen and oxygen concentrations in the Drywell and Contairunent.

f On December 18,1997, Condition Report 1-97-12-289 was initiated to track an investigation and resolution of this issue. IP determined this issue was potentially 1q ' 0 reportable under the provisions of 10CFR21 on December 23,1997.

J 9003180409 980312 PDR ADOCK 05000461 S PDR {jglll.llll.lhllh

~

U-602960 Page 2 Condition Report 1-97-12-289 initially identified three purchase orders and four

, stock codes of equipment affected by this issue. However, IP performed an additional assessment at the Sentry facility on February 26,1998, to determine the extent of this )

issue. The assessment identified that Sentry was not aware ofchanges in the 10CFR, Part l 21, rule concerning commercial grade dedication requirements. Sentry has been l purchasing commercial grade items from their approved sub-suppliers and supplying them to CPS as safety-related parts on the basis of a receipt inspection, verifying part number l

and item marking. No evidence was available to demonstrate that item critical characteristics had been established or that verification of critical characteristics was performed. The parts supplied to Sentry were purchased from sub-suppliers that have not been audited to the provisions of 10CFR50, Agipendix B.

Affected equipment includes the following items

Part Name Sentry Part Number i

GC Oven Kit 4-02962B and 4-029620 Filter Element 4-00361D Gas Columns 4-03181 A Pressure Switch 2-01429A l Heater Element 4-02844A Gas Tank Adapter 2-01709B Relay 4-01967A

l. Flow Switch ' 4-01890A Electronic Amplifier Bridge 4-03382A O-Rings 4-02962F The IP's June 1992 audit of Sentry reported that Sentry was installing commercial grade parts in the actual qualification specimen to verify operability of the parts prior to supplying the parts to the purchaser. However, based on the limited number of spare parts orders, Sentry could not justify maintaining the actual qualification specimen. The i> ' qualification specimen eventually degraded to an inoperable status and can no longer be used to verify acceptability of spare parts.

l IP has completed the evaluation of this issue and concludes that this issue should be reported under the provisions of 10CFR21. The basis for the reportable conclusion is that Sentry failed to comply with the provisions of 10CFR21 rel_ating to dedication of commercial grade items for use as basic components. 10CFR21 requires that basic L components are items designed and manufactured under a quality assurance program complying with 10CFR50, Appendix B, or commercial grade items which have -

successfully completed the dedication process. Sentry has failed to provide documented evidence that demonstrates critical characteristics have been established and verified for commercial grade parts supplied as basic components to provide reasonable assurance that l the items will perform their intended safety functions.

l

- J

6

=

U-602960 - i

, Page 3 e .

• IP concludes that if this issue had gone uncorrected it could have caused a loss of 4 -

the Drywell and Containment Hydrogen and Oxygen Analyzer safety function. The l Drywell and Containment Hydrogen and Oxygen Analyzers detect high hydrogen and oxygen concentration conditions that represent a potential for containment breach. This variable is also important in verifying the adequacy of mitigating actions; the analyzers l provide the primary indication used by the operator during a design basis loss-of-coolant l

accident.

Further, on March 12,1998, an evaluation of these issues concluded that some of

[ the parts supplied by Sentry since the June 1992 IP audit are currently installed in the plant, and therefore, since the quality of these parts are indeterminate and could adversely l affect the equipment safety function, the Drywell and Containment Hydrogen and Oxygen l Analyzers should be considered to be inoperable. The Operations Shift Supervisor has peen notified of this issue and a restraint against changing plant modes is in place pending resolution of the Drywell and Containment Hydrogen and Oxygen Analyzer issues. <

Therefore, IP has determined that this issut, should also be reported imder the p_rovisions j of 10CFR50.73. I IP will issue a report describing these issues in accordance with the provisions of 10CFR21 and 10CFR50.73 by April 11,1998.

Additional information about this issue may be obtained by contacting R. D. i Weber, Supervisor-Procurement Engineering, at (217) 935-8881, extension 3785.

Sinyerely yours, I # l t

4s, _

Walter G. MacFarland, IV Senior Vice President RSF/krk cc: NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC l Illinois Department of Nuclear Safety j INPO Records Center I Sentry Equipment Co*.poration l

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v. -- 1 POWER REACTOR EVENT NUMBER: 33896

'FACILI.TY: CLINTON REGION: 3 NOTIFICATION DATE: 03/13/98 0 UNIT: [1] [] [] STATE: IL NOTIFICATION TIME: 14:11 [ET]

FA TYPE: [1] GE-6 EVENT DATE: 03/12/98 EVENT TIME: 15 : 00 [ CST)

NRC NOT!FIED BY: R. S. FRANTZ LAST UPDATE DATE: 03/13/98 HQ OPS OFFICER: FANGIE JONES NOTIFICATIONS .

EMERGENCY CLASS: NOT APPLICABLE 10 CFR SECTION: GARY SHEAR RDO i CCCC 21.21 UNSPECIFIED PARAGRAPH VERN HODGE NRR I

UNIT SCRAM CODE RX CRIT INIT PWR INIT RX MODE CURR PWR CURR RX MODE 1 N N O COLD SHUTDOWN 0 COLD SHUTDOWN EVENT TEXT 10-CFR-PART-21 NOTIFICATION ON MARCH 12, 1998, ILLINOIS POWER (IP) CONCLUDED THAT THE DRYWELL AND CONTAINMENT HYDROGEN AND OXYGEN ANALYZERS SHOULD BE CONSIDERED INOPERABLE.

THIS IS BASED ON EVALUATION OF ISSUES OF COMMERCIAL GRADE PARTS VERSUS SAFETY GRADE PARTS INSTALLED IN THE DRYWELL AND CONTAINMENT HYDROGEN AND OXYGEN ANALYZERS BY SENTRY EQUIPMENT.

CONDITION REPORT 1-97-12-289 (12/18/97) WAS INITIALLY ISSUED TO TRACK THE ADEQUACY AND IMPLEMENTATION OF THE SENTRY QUALITY ASSURANCE PROGRAM. IP l IDENTIFIED THAT SENTRY DID NOT HAVE DOCUMENTED PROCEDURES FOR CONTROLLING THEIR COMMERCIAL GRADE DEDICATION PROCESS. AS A RESULT, SENTRY IS UNABLE TO FURNISH SUFFICIENT OBJECTIVE EVIDENCE THAT ITEMS SUPPLIED TO IP HAVE BEEN PROCURED OR TESTED TO INTENDED SAFETY FUNCTIONS. AN ADDITIONAL '

ASSESSMENT AT THE SENTRY FACILITY ON 02/26/98 TO DETERMINE THE EXTENT OF l THIS ISSUE, IDENTIFIED THAT SENTRY WAS NOT AWARE OF CHANGES IN THE l 10-CFR-PART-21 RULE CONCERNING COMMERCIAL GRADE DEDICATION REQUIREMENTS.

IP CONCLUDED THAT THIS IS REPORTABLE UNDER THE PROVISIONS OF 10 CFR PART 21 IN THAT SENTRY FAILED TO COMPLY WITH THE PROVISIONS OF 10 CFR PART 21 l RELATING TO DEDICATION OF COMMERCIAL GRADE ITEMS FOR USE AS BASIC l COMPONENTS.

I I

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