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.
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