ML20066E139

Fifth Interim Rept of Deficiency 81-04 Re Inconsistencies in Certifications of HVAC Matls Installed by Zack Co.Initially Reported on 811002.Zack QA Manual Revised & Procurement Documentation Revalidated.Final Rept Expected in 90 Days

ML20066E139
Person / Time
Site:	Clinton
Issue date:	11/03/1982
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, 81-04, 81-4, U-10007, NUDOCS 8211120446
Download: ML20066E139 (4)

Text

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i 1605-L ILLINDIS POWER 00MPANY U-10007 CLINTON POWER STATION, P.O. BOX 678. CLINTON. ILLINOIS 61727 November 3, 1982 Mr. James G. Keppler Regional Administrator Region III U S. Nuclear Regulatory Commission 799 Roosevelt Raad Glen Ellyn, Illinois 60137 Docket No. 50-461

Dear Mr. Keppler:

Deficiency 81-04 10CFR50.55(e)

Certifications of HVAC Materials On October 2, 1981, Illinois Power verbally notified Mr. H.M.

Wescott, NRC Region III, of a potential reportable deficiency per 10CFR50.55(e) concerning inconsistencies in the certifications for Clinton Project HVAC materials installed by the Zack Company. This initial notification was followed by four (4) Interim Reports: L.J.

Koch letter U-0325 to J.G. Keppler dated November 4, 1981; L.J. Koch letter U-0413 to J.G. Keppler dated February 3,1982; W.C. Gerstner letter U-0474 to J.G. Keppler dated May 3, 1982; and W.C. Gerstner letter U-0524 to J.G. Keppler dated August 3, 1982.

Illinois Power's investigation has determined that this matter represents a reportable deficiency per 10CFR50.55(e). This letter presents an interim report in accordance with 10CFR50.55 (e)(3) .

STATEMENT OF REPORTABLE DEFICIENCY Investigation has determined that a breakdown in the Zack Company (HVAC Contractor) Quality Assurance program had occurred in the area of 10CFR50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services. A quality review of HVAC material certifications revealed that the certifications contained numerous errors of omission, insecuracies and in some instances alterations or modifications. These errors and inconsistencies resulted in the material certifications being suspect and, therefore, the material suspect. These inconsistencies in documentation have, and will require extensive resources to evaluate, correct, and prove adequacy of material, and is considered a reportable deficiency per 10CFR50.55(e).

r211120446 821103 N0y g 1982 DR ADOCK 05000 g7

' J.G. Kcppler November 3, 1982 NRC Page 2 of 4 INVESTIGATION RESULTS/ BACKGROUND During a Zack Company Quality Assurance review of the certifica-tions for the Clinton Power Station HVAC materials, a number of inconsistencies were identified. These inconsistencies were cate-gorized into the following four areas:

1.) Incomplete material test reports, 2.) Incorrect material test reports, 3.) Improperly modified test reports, and 4.) Possibility of individual (s) within the Zack Company improrarly changing test reports.

As a result, the Zack Company issued Corrective Action Request (CAR) #014-b on September 25, 1981, which identified the problem, contained a plan of action to determine the extent of the problem, and the time frame for completion. Corrective Action Request #014-b has not been closed to date pending completion of corrective action measures addressed in this letter.

Zack Company is presently generating for Baldwin Associates (Illinois Power Contractor), a final list of nonconforming purchase order /CMTR documentation packages that were identified during Zack Company's investigation into this matter. Fifty-three (53)

Nonconformance Reports are being generated by Zack Company for submission to Baldwin Associates for evaluation and disposition.

In addition to the actions being taken to resolve the identified documentation discrepancies, Illinois Power Quality Assurance has conducted two (2) evaluation / verifications of Zack Company's correct-ive action on this matter. These evaluation / verifications revealed problems in the Zack Campany's closure of a number of discrepant documentation packages, and with other Zack Company's corrective action measures being taken to correct deficiencies and to prevent further recurrence. These problems are documented on Illinois Power Quality Assurance surveillance findings, and are being resolved by the Zack Company through Baldwin Associates.

CORRECTIVE ACTION The following measures have been or are being taken to correct this deficiency and to prevent further recurrences:

1. Zack Company has revised their Quality Assurance Manual to enhance controls and describe in detail the programs for assuring that the requirements of 10CFR50, Appendix B, and the HVAC Instellation Specification K-2910 are met. This revised manual has been reviewed and has been conditionally approved by Baldwin Associates Quality Assurance. The Zack Company has added additional Quality Assurance personnel to support the upgraded program, including the area of procure-ment and certification documentation review.

J.G. Keppler November 3, 1982 NRC Page 3 of 4

2. Procurement documentation has been revalidated by the Zack Company Quality Assurance and Document Control Departments and results have indicated a possible fifty-three (53) questionable procurement document packages. These are identified by a nonconformance report for each package.

Resolution of these nonconformance reports will assure that HVAC materials are adequate in meeting the design intent.

It is expected that nonconformance reports will be submitted to Baldwin Associates and Sargent & Lundy (as applicable) for disposition by November 19, 1982.

3. A centralized documentation center has been established within the Zack Company's Cicero, Illinois, office.

Specific guidelines have been established in Zack Company Quality Assurance Instruction (QAI No. 4) titled, " Control and Maintenance of QA Purchase Order / Certified Material Test Report Files".

4. The Zack Quality Assurance Department reviews all procure-ment documentation and receiving inspection reports for compliance. Procedures titled, " Procurement" (PQCP-15) and

" Receiving Inspection" (PQCP-1), incorporates the require-ment for quality assurance review.

5. Unauthorized personnel are not allowed access to quality records at the Cicero, Illinois, office.

6. Zack Company management has established, in written direct-ives, a company policy addressing disciplinary action to be taken as a result of instances of failure to follow proced-ures by employees.

7. Monthly training schedules have been developed and imple-mented for on-going training of personnel at Zack Company's Cicero, Illinois, office as to the requirements of Zack's Quality Assurance program.

8. Illinois Power and Baldwin Associates Quality Assurance Departments will increase surveillance and audits of Zack Company (Cicero, Illinois) activities, specifically in the documentation and records management areas.

SAFETY IMPLICATIONS / SIGNIFICANCE At this time, the impact of this deficiency on the safety of operations of Clinton Power Station is unknown, and cannot be ascer-tained until the nonconformance reports have been dispositioned, l dispositioning action taken, and reports closed. The corrective actions identified above will identify and assure resolution of all potential documentation and material discrepancies and will prevent further discrepancies; consequently, the safety of operations of Clinton Power Station will not be impacted by this deficiency. It is anticipated that ninety'(90) days will be necessary to evaluate and disposition the nonconformance reports, evaluate for safety impact, and provide a Final Report on this matter.

J.G. Keppler November 3, 1982 NRC Page 4 of 4 This letter is hereby submitted as an interim report in accordance with 10CFR50.55(e)(3). I trust that it is sufficient for analysis and evaluation of the deficiency and corrective action.

Ve v truly yours, l Jf

/Hal

,l Vice President l

cc: H.H. Livermore, NRC Resident Inspector Director, Office of I&E, Washington, DC 20555 Illinois Department of Nuclear Safety Director-Quality Assurance l

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