Part 21 Report - 1998-222

ACCESSION #: 9803180409 Illinois Power Company Clinton Power Station P.O. Box 678 ILLINOIS Clinton, IL 61727 POWER Tel 217 935-5623 An Illinova Company Fax 217 935-4632 Walter G. MacFarland IV Chief Nuclear Officer U-602960 4F.140 March 12, 1998 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 reportability 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 February 17, 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 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 accident hydrogen and oxygen concentrations in the Drywell and Containment. 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 reportable under the provisions of 10CFR21 on December 23, 1997. 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 of changes in the 10CFR, Part 21, rule concerning commercial grade dedication requirements. Sentry has been 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 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, Appendix B. Affected equipment includes the following items: Part Name Sentry Part Number GC Oven Kit 4-02962B and 4-029620 Filter Element 4-00361D Gas Columns 4-03181A Pressure Switch 2-01429A Heater Element 4-02844A Gas Tank Adapter 2-01709B Relay 4-01967A 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 qualification specimen eventually degraded to an inoperable status and can no longer be used to verify acceptability of spare parts. 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 relating to dedication of commercial grade items for use as basic components. 10CFR21 requires that basic 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 the items will perform their intended safety functions. U-602960 Page 3 IP concludes that if this issue had gone uncorrected it could have caused a loss of the Drywell and Containment Hydrogen and Oxygen Analyzer safety function. The 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 provide the primary indication used by the operator during a design basis loss-of-coolant 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 affect the equipment safety function, the Drywell and Containment Hydrogen and Oxygen Analyzers should be considered to be inoperable. The Operations Shift Supervisor has been 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 issue should also be reported under the provisions of 10CFR50.73. 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. Weber, Supervisor-Procurement Engineering, at (217) 935-8881, extension 3785. Sincerely yours, 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 Illinois Department of Nuclear Safety INPO Records Center Sentry Equipment Corporation POWER REACTOR EVENT NUMBER: 33896 FACILITY: CLINTON REGION: 3 NOTIFICATION DATE: 03/13/98 UNIT: [1] [ ] [ ] STATE: IL NOTIFICATION TIME: 14:11 [ET] RX TYPE: [1] GE-6 EVENT DATE: 03/12/98 EVENT TIME: 15:00 [CST] LAST UPDATE DATE: 03/13/98 NRC NOTIFIED BY: R. S. FRANTZ HQ OPS OFFICER: FANGIE JONES NOTIFICATIONS EMERGENCY CLASS: NOT APPLICABLE 10 CFR SECTION: GARY SHEAR RDO CCCC 21.21 UNSPECIFIED PARAGRAPH VERN HODGE NRR UNIT SCRAM CODE RX CRIT CURR PWR CURR RX MODE 1 N N 0 COLD SHUTDOWN INIT PWR INIT RX MODE 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 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 THIS ISSUE, IDENTIFIED THAT SENTRY WAS NOT AWARE OF CHANGES IN THE 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 RELATING TO DEDICATION OF COMMERCIAL GRADE ITEMS FOR USE AS BASIC COMPONENTS. *** END OF DOCUMENT ***

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