ML20079J784

Responds to NRC 821006 Confirmatory Action Ltr Re Util Overinsp Program.Util Terminated All New Overinsp Work on 821005.No Further Insps Will Be Performed Until Proper Overinsp Program Developed

ML20079J784
Person / Time
Site:	Clinton
Issue date:	11/08/1982
From:	Hall D ILLINOIS POWER CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-10005, NUDOCS 8212280360
Download: ML20079J784 (3)

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o 0981-L ILLINDIS POWER COMPANY U-10005 CUNTON POWER STATION P.O. 80X 678. CLINTON. ILLINots 61727 November 8, 1982 Mr. R.L. Spessard, Director Division of Project and Resident Program U.S. Nuclear Regulatory Comuission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Docket No. 50-461

Dear Mr. Spessard:

The purpose of this letter is to acknowledge receipt of and provide initial response to your October 6,1982 Confirmatory Action 4i Letter (CAL) concerning Illinois Power Company's Overinspection ,

Program. Illinois Power Company has reviewed and evaluated the i conditions addressed in the CAL, and submits the following response:

1. In regards to the CAL statement which reads in part,

"...U.S. Testing Quality Control personnel, who are perfcraing the overinspections, have not had site specific training in accordance with approved Illinois Power Company procedures...", Illinois Power Company's interpretation of this condition is as follows: ,

U.S. Testing Quality Control personnel, who were performing the overinspections, were not trained in accordance with Illinois Power Company procedures.

However, U.S. Testing Quality Control personnel, who were performing the overinspections, were given site specific training in accordance with the U.S. Testing Clinton Power Station Program Plan, dated August 1982.

This Program Plan was approved by Illinois Power Company on August 11, 1982. The Program Plan required ,

that training be presented to U.S. Testing Personnel, ,

prior to their commencing inspeccion activities, on the following subjects:

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16 RiLa-Spsdsar'd  : November 8,1982: d 7 ;NRC; - '

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. Baldwin Associates Project Procedures Manual-Baldwin Associates QA Procedures.

Baldwin. Associates Technical ServicesLManual Baldwin Associates QC Instructions Baldwin Associates QC' Training Manual f --

Baldwin Associates Technical Services Instructions Baldwin Associates Procurement Manual

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U.S. Testing Company QA Manual i

Verification Team Audit Report _

U.S.' Testing' Company Procedure UST(CL)-QAP-1.

Individual discipline training by QC Supervisor Safety training conducted by Baldwin Associates

! Safety Dept.

Applicable Sargent & Lundy Specifications

!, .During the NRC inspection of September 27 through October

' 8,~1982, this information may not have been thoroughly

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relayed by Illinois. Power to the inspectors for their evaluation. Additionally, Illinois Power believes that the Illinois Power procedure for overinspection may have been misleading as to' training requirements:for U.S. Testing

' Quality Control personnel. It was not intended that U.S.

l Testing Quality Control personnel be trained in accordance with Illinois Power training procedures, but to applicable U.S. Tescing requirements described in the Program Plan.

To clarify this matter, U.S. Testing Company is developing a procedure to define site specific training requirements.

This procedure will be reviewed and approved by Illinois Power Company. Illinois Power Quality Assurance Instruction QAI-710.01 will.be revised to clearly specify that U.S. Testing Company Quality Control personnel shall be trained in accordance with the Illinois Power approved U.S. Testing Company procedures.

2. In regards to CAL paragraph 1.a which states, " Root cause(s) established by evaluating the -above problems / deficiencies aave been determined and corrective action, both ad hoc and generic, described.", Illinois Power Company's response is as follows:

L The Illinois Power Company Improvement Program, which includes the Overinspection Program, will address the

" lessons learned" software and hardware deficiencies for root causes and corrective action.

3. In regards to CAL paragraphs 1.b through 8, Illinois Power Company's response is as follows:

Illinois Power Company is revising our Overinspection Program to address the items discussed in your CAL paragraphs 1.b through 8.

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-* R.L. Spessard November 8, 1982-NRC Page 3 of 3 Illinois Power ' Company terminated all new overinspection work on October 5,1982 (Ref: A.J. Budnick letter Y-13974, 4250-L, dated 10/5/82). No further inspections will be performed until an Overin-spection Program Plan, which addresses the items discussed in your CA'L,- has been . fully developed, reviewed, and . approved by Illinois -

Power Quality Assurance, and concurrence is obtained from the U.S.

NRC.

I trust this initial response satisfactorily addresses your concerns with the Illinois Power Overinspection Program. We will

continue to keep you advised as to our progress in achieving our obj ective .

SEYEe el -

L. ,

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Vice President cc: USNRC Sr. Resident Inspector Director-Quality Assurance Director-Office of I&E, Washington, D.C. 20555 Illinois Department of Nuclear Safety I

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