IR 05000461/1986003

Insp Rept 50-461/86-03 on 860127-30,0203-07,10-13 & 24-27. No Violation or Deviation Noted. Major Areas Inspected: Previous Insp Findings & Const Records Verification Program

ML20140A631
Person / Time
Site:	Clinton
Issue date:	03/17/1986
From:	Hawkins F, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140A628	List: IR 05000461/1986003 ML20140A624
References
50-461-86-03, 50-461-86-3, NUDOCS 8603210054
Download: ML20140A631 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86003(DRS)

Docket No. 50-461 License No. CPPR-137 i Licensee: Illinois Power Company i 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection p nducted: January 27-30, February 3-7, 10-13, 24-27, 1986 i

Inspector: R. N. Sutphin 3/17/BG

, Dite Approved By: . C. Hawkins, Chief 3/(l/S Quality Assurance Programs Section Date

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Inspection Summary Inspection on January 27-30, February 3-7, 10-13, 24-27, 1986 (Report No. 50-461/86003(DRS))

Areas Inspected: Special announced inspection by one regional inspector of

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licensee action on previous inspection findings and the construction records verification progra Results: The inspector identified no violations or deviations.

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DETAILS ,

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1. Persons Contacted Illinois Power Company

• C. Gerstner, Executive Vice P'esident

• D. P. Hall, Vice President

• J. E. Loomis, Construction Manager

• H. E. Daniels Jr. , Project Manager

• J. W. Wilson, Plant Manager

• J. S. Perry, Manager, Nuclear Program Coordination

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• J. H. Greene, Manager of Startup

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• D. C. Shelton, Manager, Nuclear Safety and Engineering Analysis

• F. A. Spangenberg, Manager, Licensing and Safety

• W. Connell, Manager, Quality Assurance

• N. C. Williams, Director, Support Services

• R. Cowley, Assistant Director, Support Services

• V. F. Palchak, Supervisor, Plant Support Services

• J. C. Wemlinger, Supervisor, Instruction

• K. A. Baker, Supervisor, I&E Interface G. L. Baker, IPQA Records Coordinator Soyland/Wipco

• J. Greenwood, Manager, Power Supply U.S. NRC

• T. P. Gwynn, Chief, Reactor Projects Section IB 1 Baldwin Associates

• J. Schlatka, Project Manager

• J. V. Hawkins, Manager of Quality Assurance

• J. L. Thumpsca, Mana;er of Q1ality Engineering

• Denotes those in attendance at the exit interview on February 27, 198 Other personnel were contacted as a matter of routine during the inspectio . Action on Previous Inspection Findings (Closed) Unresolved Item (461/84002-04): Acceptability and justification of record review generic resolutions. The licensee had conducted the necessary reviews and had established a final position on all of the recommendations made by Dennis Millican and Associates Incorporated. The inspector was satisfied that the licensee had satisfactorily addressed this issu .

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' (Closed) Open Item (461/85016-06): Records Classification Code List

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(RCCL) not complete, and up-to-date. The licensee had added to the 3 RCCL those items referenced in the FSAR as records commitments and

released an up-to-date revision. The inspector was satisfied that the licensee was appropriately addressing this issu . Inspection of Records Verification Program

The inspector examined the results of the licensee's special Records i Verification (RV) Program (RVP) to verify that the program had

! accomplished the intended objectives and was essentially completed in accordance with commitments to the NRC. The RVP was intended to augment the normal Clinton Power Station (CPS) Quality Assurance (QA) records program and provide additional assurance on the acceptability of the CPS Construction QA record The licensee had advised Region III in their letter of November 15, 1985, i that the results of the RVP indicated thatLthere were no safety significant

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nonconformances (NCR's) identified as a result of the RVP reviews, no -

difficulties that had adverse implications on hardware quality, and that

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there was an adequate level of confidence in the acceptability of the CPS Construction QA records. The licensee arrived at these conclusions after l completing more than 80% of the planned RV reviews. As a result of these conclusions, the licensee proposed to discontinue further RV reviews at an appropriate point of completion in the various record categories and terminate the program subject to NRC comment !

The objective of this inspection was to provide the basis for the NRC position in this matter and include NRC comments and recommendations regarding the termination of the special construction-RVP at this tim Procedures and Documents Reviewed (1) CNP 1.14, Revision 0, " Records Management"

(2) RMS STND No. 1.01, Revision 1, " Preparation and Control of RMS l Standards"

4 (3) RMS STND No. 1.02, Revision 1, " Development of the Required Records List" I

(4) RMS STND No. 2.01, Revision 0, " Standard for the Collection and

Review of Records"

(5) RMS STND No. 2.02, Revision 2, " Standard for Record Quality"

(6) RMS STND No. 2.03, Revision 0, " Disposition of Record Deficiencies" I (7) RMS STND No. 2.04, Revision 1, " Records Turnover / Transfer"

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(8) RMS STND No. 3.01, Revision 1, " Maintenance of CPS Records Classification Code List (RCCL)"

l (9) RMS STND No. 3.02, Revision 1, " Records Storage, Preservation and Maintenance" 4 (10) CPS U-600214, Revision 3, " Record Verification Program Plan" j (11) Baldwin Associates (BA) QA Training Manual - Appendix 3, Revision 1, " Document Review Personnel"

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) (12) BAP 2.1.1, Revision 6, " Verification of BA Records" l (13) BAP 2.1.2, Revision 2, " Verification of BA Procurement and j Subcontractor Documentation" (14) BAP 2.1.3, Revision 1, "QA Final Review Checklists" (15) BAP 2.1.4, Revision 2, " Final Document Review Status, Tracking i and Trending" (16) BAP 2.1.5, Revision 0, " Generic Resolution Management"

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(17) NP&S 1.01, Revision 0, " Preparation and Control of Nuclear Planning and Support Department Procedures" (18) NP&S 2.50, Revision 0, " Records Processing and Maintenance" (19) NP&S 2.51, Revision 0, " Document Control Procedure" (20) NP&S 5.04, Revision 0, " Records Control" I (21) NS 1.01, Revision 1, " Preparation and Control of Nuclear

Support Department Procedures"

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l (22) NTD Procedure 1.9, Revision 1, " Nuclear Training Department Records Control" i (23) CPS No. 1017.01, Revision 6, " Plant Records Preparation, Transmittal and Retention" (24) PMP 7.1, Revision D, " Records Control"

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(25) NSED Procedure A0, Revision 8, " Nuclear Station Engineering Department Procedures / Instructions"

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(26) NSED Procedure A1, Revision 4, " Document / Correspondence Administration" (27) NSEI R-1, Revision 6, " Transmittal of Records to Nuclear i Support Records Management Group (RMG)" ,

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(28) QAP 117.01, Revision 4, " Records Control" (29) SAI-4, Revision 10 " Document and Records Control" (30) Emergency Planning (Draft Procedure) 1.02, " Control of Nuclear Program Coordination Records" (31) Corrective Action Requests (CARS) numbered 138, 145, 150, 162, 173, 207, 227, 230, 240, 259, 256, and 258 b. P_r_ogram Areas Inspected and Results (1) RV Program Definition and Controls The inspector reviewed the procedures and instructions relating to the definition and control of the RVP for construction QA records and found them to be acceptable. The licensee had developed a comprehensive program plan with effective control The plan included not only those measures necessary to provide for the review process, but also included appropriate audits, surveillances, and a 20% sampling plan to verify that the reviews were completed in an acceptable manner and in accordance with program objective (2) Implementation Status The inspector reviewed the pertinent program implementation information and found that the program had been initiated and conducted in accordance with the RVP plan. Information generated by the licensee using computer data processing methods in September 1985, provided an appropriate basis for an assessment of the status and success of the progra This data indicated that the RV program was over 80% complete and that no significant safety-related record deficiencies had been identified. The many minor deficiencies that were identified were assigned to appropriate problem resolvers for investigation, correction, and resolution. The impact on hardware was minimel. Engineering personnel and consultants had evaluated all problems documented by nonconformance reports (NCRs) that may have had a potential adverse impact on hardware

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or safet As an update to the September 1985, data, the inspector also reviewed the data generated as of February 1986. This final data was an indication of the status of the RVP at its conclusio (3) Generic Resolution Activity The inspector reviewed the Generic Resolution (GR) process employed by the licensee's Document Review Group (DRG). A l

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Generic Resolution was defined as a documented resolution approved by management for a generic proble A generic problem was defined as repetitive document exceptions whose causes, effects, and resolutions were closely relate DRG personnel listed all document exceptions and the GRs if used on a Document Exception List (DEL) form, and the DEL became a permanent part of the record package. A consultant had been employed to evaluate and comment on the individual generic resolutions early in the program. The inspector made a detailed review of the consultants recommendations and the licensee's responses. Of 127 GRs proposed, only 30 were accepted for regular continued use in the RV '

(4) Document Review Checklists The inspector examined the instructions and procedures associated with the development, approval and use of checklists. He found that appropriate checklists were developed and used. There were six functional areas of construction disciplines. A random sampling process was used to select and review the actual completion and use of the checklists in all of the functional area Each item on the checklists was considered to be an attribute and was used to generate the statistical data on the progress and success of the RVP. Checklists were included in handbooks and issued to document reviewers as required for their assigned wor (5) Document Exception Lists (DEls) and Record Packages The inspector reviewed approximately 100 record packages and the associated DELs. The packages were selected by a random selection process covering the six functional areas and 17 major types of records. The inspector found that the licensee had a DEL attached to 100% of the records reviewe Each DEL was attached and properly signed off by Level II reviewers, even when there were no exceptions found in a record package. The licensee was able to retrieve all referenced information and supporting data for resolution of all the inspector's questions. Each record package was indexed and the accountability for all required items was 100%.

(6) Qualifications of Document Review Personnel The inspector reviewed tia list of all individuals certified as either Level II or Level III Quality Assurance Engineers (QAE) (Cocument Reviewers). He selected a sample of 50% for a detailed qualifications chec Those selected included reviewers in the functional areas of electrical, civil /

structural, piping / mechanical, and procurement / subcontract .

The qualification records reviewed included all the necessary )

information to establish the basis for their certification l The records included results of exains, education information

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and experience, military experience, previous nuclear plant experience, training, on the job training, and practical demonstrations, all in accordance with the RVP plans and

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procedure (7) Nonconformance Repor_ts_(N_C_Rs) and Disp _osi_tions The inspector selected a 10% random sample of the NCRs that required an engineering evaluation for disposition and closecut. There were 333 NCRs in this group. The group was

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divided into nine different categories. The 10% random sample process was applied to each of the nine categories.

d The inspector checked the overall adequacy and final dispositions of the sampled NCRs and reviewed in detail the basis for any

"USE-AS-IS" dispositions. In each sample the basis and supporting information for the USE-AS-IS dispositions were found to be acceptable and in accordance with the applicable NCR procedure (8) Audits and Surveillances The inspector reviewed the results of 100% of the licensee's QA

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audits performed in the records activities areas during 1983, t 1984, and 1985. A 25% sample of surveillances was also reviewe The inspector found that the surveillances were particularly effective in the identification of detail problems with the records anc the audits were effective in the assessment of the overall program performance to procedures ard QA program commitments. All findings were addressed in an acceptable manner, and the process seemed to have a favorable impact on the performance of the records review program (9) Corrective Actions and Generi_c Reso_lution_s

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Corrective Action Request (CAR) record files that were associated with generic resolutions and other RV

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program activities. The inspector found that the CARS were processed in accordance with requirements and had a generally favorable impact on the resolution of problems. The problems were identified both in the administration and management of the RV programs and in the handling of detailed records problems; some of which were associated with the development, approval, training implementation, and retirement of generic resolution i (10) Implementation of Normal Records Programs

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The inspector reviewed a sample of 60 records packages, ten i each from the six functional areas, to verify the overall

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adequacy of records preparation, processing and reviews. Six NCRs were included in this group to verify the normal processing and dispositions of NCR's other than those generated as a result of the RV . ,

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The inspector reviewed the internal Records Management procedures of the following departments:

(a) Plant Staff (b) Training (c) Project Management l (d) Nuclear Station Engineering (NSED) i (e) Nuclear Planning & Support (NP&S) '

(f) Quality Assurance (g) Emergency Planning l (h) Startup I They were found to be generally in accordance with the corporate policy and commitments for records managemen Each department was required to have a records coordinator and alternates. The inspector interviewed 12 individuals assigned to these functions. Those who were the regular records coordinators were found to be knowledgeable and experienced I in performing the records responsibilities assigned. Those assigned as alternates were found to be in need of more regular participation to either maintain or develop their proficienc The NRC inspector did not consider this to be a significant j item of concern at this tim Conclusions and Comments on DVP The licensee's Records Verification Program activity was implemented in accordance with their commitments to the NRC and their program plans. The conclusions reached by the licensee in November 1935 were essentially correct. The inspector found no safety significant nonconformances identified as a result of the RVP reviews, no document exceptions that had an adverse impact on hardware quality or acceptability, and that there was an adequate level of confidence in the acceptability of the construction QA records. The inspection also determined that the normal records management personnel, procedures, and programs were established in an acceptab;e manner to haaintain this conditio The decision by the licensee to terminate the special records verification program because of its good results and completion status was well supported. Based on this inspection, the NRC concurs with the licensee's termination of the RV . Exit Meeting The inspector met with licensee representatives (denoted in the Persons Contacted paragraph) at Clinton on February 27, 1986, at the conclusion of the inspection. The inspector summarized the scope and findings of the inspection. The probable contents of the report were discussed with licensee personnel and no proprietary information was identifie ,

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