United States Nuclear Regulatory Commission - Protecting People and the Environment


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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