ML20072M986
| ML20072M986 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/22/1983 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 1605-L, U-10041, NUDOCS 8304010415 | |
| Download: ML20072M986 (3) | |
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1605-L ILLINO/S POWER 00MPANY U-10041 CLINTON POWER STATIGN P.O. BOX 678. CLINTON. ILLINOIS 61727 March 22, 1983 Docket No. 50-461 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Potential Deficiency 83-04, 10CFR50.55(e)
Document Control of Design Change Documents
Dear lir. Keppler:
On February 15, 1983, Illinois Power Company verbally notified Mr. F. Jablonski, U.S. NRC Region III (Ref:
IP memoran-dum Y-14166, 1605-L, dated February 15, 1983) of a potentially reportable deficiency per 10CFR50.55(e) concerning document control of Field Deviation Disposition Requests (FDDRs) and Field Disposition Instructions (FDIs) as issued by General Electric Company for field changes.
Our investigation of this matter continues, and this letter represents an interim report in accordance with 10CFR50.55(e)(3) for this potentially reportable deficiency.
l Statement of Potentially Reportable Deficiency Quality assurance surveillance activities identified that document control of design change documents was not adequate to ensure that drawings properly identified all applicable outstanding changes.
Specifically, Field Deviation Disposition Requests (FDDRs) and Field Disposition Instructions (FDIs) received at the Clinton site were not being properly " posted" or identified as outstanding against affected Sargent and Lundy (S&L) and General Electric (GE) drawings.
This problem could potentially result in inconsistencies between design drawings released to the field and the as-built equipment.
8304010415 830322 hAAR2c083 3
PDR ADOCK 05000461 S
. Mr. James G. Keppler Page 2 March 22, 1983 Background / Investigation Results An Illinois Power quality assurance surveillance was con-ducted in early February, 1983, of the IP Startup organization and its control of design documents related to the Power Generation Control Complex (PGCC).
As a result of the surveillance, two programmatic deficiencies regarding document control practices were identified as findings.
Finding C-83-016 identified a lack of implementation of a section of Baldwin Associates procedure 1.10, " Control of GE Items / Material /
Activities affected by FDDR / FDIs".
The procedure requires Baldwin Associates Document Control to post FDDRs and FDIs as
" outstanding" against the affected drawings until the General Electric drawing is revised to incorporate the FDDR/FDI.
Baldwin Associates document control personnel, however, were found to delete the FDDR/FDI as outstanding against the affected document when the work associated with the FDDR/FDI is completed.
The second finding, C-82-017, identified a deficiency concerning FDDR/FDIs that affect Sargent & Lundy (S&L) schematic and wiring diagrams (E-02 and E-03 series drawings).
The finding identified that there are no procedural requirements to post FDDR/FDIs against affected S&L schematic and wiring diagrams until a subsequent revision to the S&L drawing incorporates the FDDR/FDIs.
The findings were assessed by Illinois Power Quality Assurance as being potentially reportable under the provisions of 10CFR50.55(c) and were reported to the NRC as such on February 15, 1983.
An investigation committee formed of members from various site organizations has been organized to report on the circum-stances surrounding the potentially reportable deficiency.
A written plan which details the scope of the investigation has been prepared.
The investigation which is currently being conducted will address both the specific and generic impacts of the identified deficiencies together with remedial and generic corrective action.
Since the major concern of the quality assurance surveil-lance dealt with posting of design change documents (FDDRs and FDIs) to drawings, immediate action was taken by Baldwin Associ-ates document control personnel to ensure compliance with BAP 1.10, " Control of GE Items / Materials / Activities affected by FDDR/FDIs."
FDDR/FDIs site control logs and files were reviewed to identify those that were closed (i.e., the associated work has been completed).
As a result of the review, 467 closed FDDR/FDIs were reissued for posting in the field.
A review of drawings is being performed to check for incorporation of the closed FDDR/FDIs.
In conjunction with this, a status report is being developed that will indicate the status of incorporation of FDDR/FDIs and the affected drawings.
. !!r. Jam 3s G. Keppler Page 3 March 22, 1983 Illinois Power has evaluated the program for implementing field design changes (FDDR/FDI's) on GE equipment.
The present practice of performing construction work changes, as a result of FDDRs and FDIs, on the GE equipment is through the use of con-trolled revisions to the work travelar (package of instructions and drawings required to explain and perform the work).
The physical change work has progressed correctly in a controlled manner.
Therefore, this potential 10CFR50.55(c) deficiency deals with the posting of changes to affected file documents.
Corrective Action Remedial corrective action is being taken to ensure that GE drawings helu on site reflect applicable FDDR/FDIs that have not been incorporated through revision of the drawings.
The committee and engineering personnel are currently evaluating alternatives for handling of S&L drawings which are " overlays" of the GE drawings and subsequently are issued to the field.
Future effort will include an evaluation of generic effects and application of corrective action.
Safety Implication / Significance Illinois Power Company's investigation of this potentially reportable deficiency is continuing.
The safety implication and significance will be assessed after further background informa-tion is presented for review.
It is anticipated that approxi-mately ninety (90) days will be necessary to complete our inves-tigation and to file a final report on the matter.
We trust this interim letter provides you sufficient back-ground information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall approach at resolving this problem.
S' elv yours, P
Ha 1 Vice President AJB/RDW/ch cc:
NRC Resident Inspector Manager - Quality Assurance Director - Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center