ML20070C146

Interim Deficiency Rept Re Instrument Data Sheets.Initially Reported on 820902.Instrument Data Sheet Books Collected & Reissued as Controlled Copies.Investigation Continuing. Final Rept Will Be Filed in 90 Days

ML20070C146
Person / Time
Site:	Clinton
Issue date:	12/04/1982
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
10CFR-050.55E, 10CFR-50.55E, U-10012, NUDOCS 8212140057
Download: ML20070C146 (4)

Text

_ -

M" '

8 /Hl3 1605-L ILLINDIS POWER 00MPANY U-10012 CLINTON POWER STATION, P.O. BOX 678. CLINTON. ILLINOl$ 61727 December 4, 1982 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roocevelt Road Glen Ellyn, Illinois 60137 Docket No. 50-461 Dnar Mr. Keppler:

Potential Deficiency 82-08 10CFR50.55(e)

Distribution Control for Instrument Data Sheets on September 2, 1982, Illinois Power notified Mr. R. Knoa, NRC Region III, (Ref: IP Memorandum Y-13906, 1605-L, dated September 2, 1982) of a potentially reportable deficiency concerning the lack of distribution control for instrument data sheets. This initial notifi-cation was followed by one (1) interim report (Ref: IP letter U-0560, D.P. Hall to J.G. Keppler, 1605-L, dated October 1, 1982). Our investigation into this matter continues, and this letter represents an interim report per 10CFR50.55(e).

STATEMENT OF POTEt4TIALLY REPORTABLE DEFICIENCY As a result of an Illinois Power Quality Assurance Special Surveillance (Y-13104, 4138-L, dated September 3,1982) , it was deter-mined that the methods of controlling the distribution of instrument data sheets was inadequate. This condition potentially allows for incorrect revisions of data sheets to be used during instrument procurement, receipt, installation, inspection, and calibration activities, which could result in errors in documentation and instru-ment requirements.

INVESTIGATION RESULTS (INTERIM)

Investigation has found that revisions to instrument data sheets are issued by Sargent & Lundy (CPS Architect / Engineer) to Baldwin Associates (IP contractor) Document Control Center for insertion into Instrument Data Sheet Books. Baldwin Associates then distributes these sheets to individual bookholders utilizing a transmittal letter, however, the books were not treated as controlled copies.

8212140057 B21204 DEC 9 sat 4c2 'y PDR ADOCK 05000461 ~

S PDR ,/g f

J.G. Kepplcr NRC Page 2 of 4

)

Additionally, investigation found that the latest revisions of instrument data sheets were not always incorporated into the purchase specifications. Only those revisions which impacted the instrument vendor's scope were transmitted by Sargent & Lundy to the vendor. If no such impact existed, the data sheets were sent to individual book holders via the Baldwin Associates Document Control Center. The above conditions resulted in discrepancies between the data sheet revisions found in the purchase specification, the Master Instrument Data Sheet Book found in the Baldwin Associates Document Control Center, and the data sheets held by individual book holders.

Investigation of the effects of utilizing improperly controlled instrument data sheets is in progress, and includes the effects on procurement, receipt, installation and inspection of instruments under safety related procurement specifications and bills of material. The status of the investigation is as follows:

1. The investigation of instruments purchased and installed under contract K-2911 (HVAC controls) is in process. An Engineering Change Notice (ECN-3243), superseding ECN 3204, was issued by Sargent & Lundy on October 25, 1982, which incorporates into K-2911 the latest revisions of applicable instrument data sheets, and includes approximately 736 individual sheets. MCC Powers (HVAC instrumentation contractor) is in the process of reviewing each sheet, summarizing materials procured against the latest data sheet revision. It is anticipated that this review will be complete and ready for IP evaluation by December 20, 1982.

2. The investigation of instruments purchased and installed under specification K-2882 (Phase II Piping, Miscellaneous Equipment, and Equipment Erection) and associated bills of material is being performed by Baldwin Associates Quality Control to determine if the correct instruments were purchased and installed in accordance with the latest revision of instrument data sheets. It is anticipated that this investigation will be complete and ready for IP evaluation by December 20, 1982.

3. An initial review of instrument data sheets transmitted by Sargent & Lundy to General Electric for procurement under K-2801 is in progress. The investigation of these data sheets for impact on procurenent, receipt, and installation is being performed by Baldwin Associates Quality Control.

It is anticipated that this review will be complete by January 14, 1983.

4 Investigation into instruments procured under specification K-2928 (Radiation Monitoring Equipment) found that the associated instrument data sheets had not been revised since issuing for procurement. The data sheets in the

J.G. Keppler

, NRC " age 3 of 4 s

specification for procurement are the same.as in the f

Instrument Data Sheet Books, and therefore, no adverse

! impact on procurement, receipt, and/or installation was experienced.

5. Investigation completed to date has determined that this potential' deficiency has-not adversely impacted the calibra-tion of safety related instruments.

, 15 . An investigation to determine if other instrument-related i

' documents exist which lack distribution control has also been made. The investigation revealed that Instrument Setpoint Logs are distributed in the same manner as instru-ment data sheets. ~

These documents have not yet been used for instrument calibration-activities at CPS, therefore ru) adverse impact on plant documentation or hardware has occurred as a result of this problem.

, CORRECTIVE ACTION (INTERIM)

I

! Although investigation of this potential reportable deficiency is i

still in progress, actions have been taken or are being taken to

. correct the problem and prevent recurrence. The status of corrective action taken or planned, to date, is as follows:-

1. Instrument Data Sheet Books issued to individual bookholders have been collected and re-issued as " Controlled Copies."

2. Discrepancies between the Master Instrument Data Sheet Book and the Master Instrument Data Sheet Index provided by l Sargent & Lundy have been identified and will be corrected by December 30, 1982. Discrepancies in individual' I

instrument data sheet books vill be corrected within two (2)

! weeks of correction of the masters.

3. A computer tracking system for the instrument data sheets for latest revision has been established by the Baldwin Associates Document Control Center.

j-

! 4. The Instrument Setpoint Log sheets have been recalled and are in the process of being reissued as " Controlled Copies."

It~is anticipated that these documents will be issued by December 8, 1982.

l S. Sargent & Lundy has revised their methods of issuing revised 1 instrument data sheets. These methods include:

A. The issuance of revised data sheets by formal amendments or engineering change documents to the 4

purchase specifications / bills of material, when the

_ purchase specifications / bills of material are active (i.e. affected instrument not yet received at CPS).

-- -- . _ _ _ - _ _ _ _ _ _ . - - , _ _ . _ _ - _ _ _ _ _ _ _ , _ _ _ - - . , _ _ , _ ~ _

• NRC. Paga-4 of 4 3

[' B. .After receipt inspection of the affected instrument-(i.e. procurement specification no longer active) revised data sheets'will be transmitted to the Baldwin Associates Document Control Center for controlled distribution to bookholders.

C. For instruments provided and installed under contract K-2911, the above is followed excepe the date of: system-turnover for the affected instrument will be considered the date when the purchase specification is no longer active for that item.

6. An Engineering Change Notice (ECN 3243) superseding ECN 4

3204, has been issued to incorporate into contract K-2911, the. latest revisions-of instrument data sheets as of October 25, 1982.

SAFETY IMPLICATIONS / SIGNIFICANCE

' Investigation is continuing into this potentially reportable deficiency to determine the effects of inadequate distribution control of instrument data sheets on plant documentation'and hardware.

The investigation will include the effects on instrument purchasing,

. receipt, installation, and inspection at Clinton Power Stations determine the need for additional corrective actions and will determine significance on plant safety. It is anticipated that approximately ninety (90) additional days will be necessary to complete the investigation, determine reportability, and to file our

, final report.

I We trust that this interim letter provides you sufficient information to perform a general assessment of this potential reportable deficiency and overall approach to resolution of the problem.

~

Very truly yours, I

. . Hall Vice President i

4 cc: H.H. Livermore, NRC Resident Inspector Director, Office of I&E, Washington, D.C. 20555

-Illinois Department of Nuclear Safety l Director-Quality Assurance i

. . . - - - - , ,.--_-e-