ML20125C342

Forwards Insp Rept 50-331/92-201 on 920511-15.Violations Noted

ML20125C342
Person / Time
Site:	Duane Arnold
Issue date:	12/08/1992
From:	Roe J Office of Nuclear Reactor Regulation
To:	Leslie Liu IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
Shared Package
ML20125C345	List: IR 05000331/1992201 ML20125C342
References
NUDOCS 9212110153
Download: ML20125C342 (6)

See also: IR 05000331/1992201

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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December 8, 1992

Docket No. 50-331

lowa Electric Light

and Power Company

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ATTN:

Mr. Lee Liu

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Chairman of the Board

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and Chief Executive Officer

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P.O. Box 35)

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Dear Mr. Liu:

SUBJECT:

INSPECTION OF THE PROCUREMENT AND COMMERCIAL GRADE DEDICATION

PROGRAMS AT THE DUANE ARN0LD ENERGY CENTER (REPORT NO.

50-331/92-201)

This letter transmits the report of the inspection conducted May 11

through 15, 1992, at Iowa Electric Light and Power (IELP) Company's Duane

Arnold Energy Center (DAEC) by R. Pettis, S. Alexander, L. Camobell, and

S. Magruder of the Nuclear Regulatory Commission's (NRC's) Vendor Inspection

Branch (VIB) and R. Langstaff of NRC Region III.

The inspection was related

to activities at the plant site authorized by NRC license DPR-49. At the

conclusion of the inspection, we discussed our findings with Mr. J. Franz,

Vice President, and the other members of your staff identified in Section 5

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of the enclosed inspection report.

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The inspection was conducted to review the implementation of IELP's program -

for the procure,ent and dedication o.f commercial grade items (CGIs) used in

safety-related

alications at DAEC. The inspection team identified a major

program strer,

in that IELP's policy was to purchase safety-related spare

and replacement items from original equipment manufacturers with approved

10 CFR Part 50, Appendix B, quality assurance programs when available, thus

reducing the number of items that need to be purchased commercial grade and

detlicated fcr use in safety-related applications. Another strength identified

was IELP's receipt inspection and testing capabilities for performing material

verification which are perform (d by independent quality control inspectors

qualified to ANS! N45.2.6.

The results of the inspection also indicate that some weaknesses existed

within IELP's program for the dedication of CGIs procured for use in safety-

related applications.

These weaknesses contributed to the specific findings

that were identified during the review of dedication files for CGIs installed

or available for installation in safety-related plant systems.

Examples of

these findings are that IELP did not fully verify the material of certain

CGIs, did not have provisions to fully assure material traceability and lot

homogeneity when using statistical sampling plans, did not properly classify

9212110153 921208

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Mr. Lee Liu

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certain valve and pump parts when using a generic classification approach, and

did not assure the calibration and control-of certain test equipment used in

the dedication process.

It should be noted that the inspection team selected

for review equipment from DAEC's safety-related component list and made no

further attempts to assess individual component contribution to the system's

safety-related function,

lhis was the fourth of a series of five pilot inspections being ccoducted to

evaluate the implementation of licensee- CGI procurement and dedication

programs and to finalize an inspection procedure for future inspections of

this type.

The other four inspections also identified certain weaknesses in

licensee CGI deaication programs and their implementation.

The first three

inspections classified these weaknesses as deficiencies with the potential for

subsequent enforcement actions by the appropriate NRC regional of fice. - During

this period, the NRC also received significant feedback from several utilities

and from the Nuclear Management and Resources Council questioning the

regulatory basis for the CGI dedication guidance contained in NRC Generic Letter 91-05 as well as specific interpretations of that guidance by the NRC

inspection teams.

In order for the NRC to properly respond to these concerns and to resolve

major points of contention cencerning the CGI dedication process we will be

holding public meetings with individual utilities and conducting a public

workshop which will address issues concerning-the existing dedication guidance

and specific interpretations of that guidance.

Prior to the public workshop,

the proposed ir.spection procedure for future inspections will be issued for

public comment and discussion at the workshop.

In view of these pending actions, the specific observations concerning your

CGI dedication programs and implementation are classified as " findings."

Because of the need for additional discussion of the appropriate guidance for

dedication of CGis, no enforcement action will be taken based on any of the

five pilot inspections.

It should be recognized, however, that some of these

findings may require corrective action-based on: (1) their potential impact on

the performance of specific equipment. -or (2) because of noncompliance with

your commitments to specific industry standards or regulatory guides endorsing

such standards.

We expect that-you will evaluate the inspection findings in

view of these considerations and take appropriate corrective action as

necessary.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and the enclosure will be placed in the NRC's Public Document

Room.

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December 8, 1992

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Mr. Lee Liu

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Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Thank you for your cooperation in this inspection.

Sincerely,

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Jack W. Roe, Director

Division of Reactor Projects 111, IV, V

Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 50-331/92-201

cc w/ enclosure:

see next page

DISTRIBUTION

Docket files 50-331/ Central Files / RIDS IE:09

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December 8, 1992

Mr. Lee Liu

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Should you have any questions concerning this inspection, we will be pleased

to discuss them with you. Thank you for your cooperation in this inspection.

Sincerely,

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Jack W. Roe, Director

Division of Reactor Projects III, IV, V

Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 50-331/92-201

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cc w/ enclosure:

see next page

D_lSTRIBUTICI!

Docket Files 50-331/ Central Files / RIDS IE:09

CHehl, RI

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WHodges, RI

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EMerschoff, Rll

VIB R/F

AGibson, RII

DRIS R/F

GWright, RIII

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BBurgess, Rill

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HMiller, RllI

FMiraglia

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RLangstaff, RIII

LNorrholm

LCallan, RIV

UPotapovs

SCollins, RIV

RPettis

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SAlexander GGrant, OEDO

LCampbell

JZwolinski

SMagruder

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Should you have any questions concerning this inspection, we will be pleased-

to discuss them with you. Thank you for your cooperation in this inspection.

Sincerely,

M

Jack W. Roe, Director

D$ vision of Reactor Projects III, IV, V

Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 50-331/92-201

cc w/ enclosure:

see next page

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Mr. Lee Liu

lowa Electric Light and Power Company

Duane Arnold Energy Center

Jack Newman, Esquire

Kathleen H. Shea, Esquire

Newman and Holtzinger

1615 L Street, N.W.

Washington, D.C.

20036

Chairman, Linn County

Board of Supervisors

Cedar Rapids, Iowa 52406

lowa Electric Light and Power Company

ATTN:

David L. Wilson

Plant Superintendent, Nuclear

3277 DAEC Road

Palo, Iowa 52324

Mr. John F. Franz, Jr.

Vice President, Nuclear

Duane Arnold Energy Center

3277 DAEC Road

Palo, Iowa 52324

Mr Keith Young

Manager, Nuclear Licensing

Duane Arnold Energy Center

3277 DAEC Road

Palo, Iowa 52324

U.S. Nuclear Regulatory Commission

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Resident inspector's Office

Rural Route #1

Palo, Iowa 52324

Regional Administrator, Region Ill

U.S. Nuclear Regulatory Commission

799 Roosevelt Road

Glen Ellyn, Illinois 60137

Mr. Stephen N. Brown

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Utilities Division

Iowa Department of Cammerce

Lucas Office Building, 5th Floor

Des Moines, Iowa 50319

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