ML20080P855

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Final Deficiency Rept 83-04 Re Control of Design Change Documents.Initially Reported on 830215.Procedures Revised Re Methods of Posting & Handling Design Change Documents
ML20080P855
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/30/1983
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, 83-04, 83-4, U-10100, NUDOCS 8310120077
Download: ML20080P855 (4)


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g ILLIN018 POWER COMPANY ggy 199 CLINTON POWER STATION. P.O. BOX E78, CLINTON ILLINOIS 61727 September 30 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:

Deficiency 83-04 10CFR50.55(e)

Document Control of Design Change Documents

Dear Mr. Keppler:

On February 15, 1983, Illinois Power Company verbally notified Mr. F. Jablonski, U.S. Nuclear Regulatory Commission, Region III (ref: IP memorandum Y-14166, 1605-L, dated February 15, 1983) of a potentially reportable deficiency per 10CFR50.55(e) concerning document control of General Electric Company (CPS NSSS Supplier) Field Deviation Disposition Requests (FDDRs) and Field Disposition Instructions (FDIs).

This initial notific'ation was followed by two (2) interim reports (Ref: IP letter U-10041, 1605-L, D. P. Hall to J. G. Keppler, dated March 22, 1983 and IP letter U-10067, D. P. Hall to J. G. Keppler dated July 6, 1983).

Our investigation has determined that this concern is a reportable deficiency per 10CFR50.55(e).

This letter represents a final report in accordance with 10CFR50.55(e)(3).

Statement of Reportable Deficiency Document ecntrol of some design change documents did not ensure that drawings properly identified all outstanding changes.

General Electric FDDRs and FDIs received at the Clinton site were not always properly " posted" or identified as outstanding against affected General Electric (G.E.) drawings.

Background

An Illinois Power quality assurance surveillance of the IP Startup organization was conducted in February, 1983, and

- resulted in two (2) findings regarding document control practices.

One finding identified a lack of implementation of a section of Baldwin Associates' (BA) (CPS Constructor) procedure 1.10, " Control of G.E. Items / Material / Activities affected by FDDRs/FDIs".

The procedure requires Baldwin Associates Document Control Center to post FDDRs and FDIs as " outstanding" against k

8310120077 830930 PDR ADOCK 05000461

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James G. Kcppler 2-September 30, 1983 the affected drawings until the G.E. drawing is revised to incorporate the FDDR/FDI.

Contrary to this, the FDDR/FDI was sometimes deleted as outstanding again3c the affected document when the physical work associated with the FDDR/FDI was completed.

The second finding identified a deficiency concerning FDDRs/FDIs that affect Sargent & Lundy (S&L) (CPS Architect / Engineer) schematic and wiring diagrams (E-02 and E-03 series drawings).

It was identified that procedures did not require postings of FDDRs/FDIs against affected S&L schematic and wiring diagrams.

Therefore, changes to design drawings were not being distributed and used at the locations where the prescribed activities are performed.

Investigation Results An investigation of this issue was performed and is summarized below:

1.

The present practice cf performing construction work changes as a result of FDDRs and FDIs is through the use of controlled revisions to the work traveler (package of instructions and drawings required to explain and perform the work).

The construction work resulting from the FDDR/FDIs has progressed correctly and in a controlled manner under the direction of a G.E. site representative.

Therefore, this 10CFR50.55(e) deficiency concerns the documentation changes to affected file documents and the potential use of these documents for startup testing.

2.

BA's practices for posting FDDRs and FDIs against G.E.

drawings were evaluated.

It was determined that the posting was deleted on completion of the field work specified by the FDDR/FDI.

This resulted in a situation where some drawings erroneously reflected the pre-modified design conditions and work control travelers reflected the hardware in the post-modified configuration.

3.

A review of IP Startup document control nrocedures revealed that the mechanics of posting design change documents to G.E. drawings were unclear and did not assure that all unincorporated design change documents were known and evaluated at the time of testing.

However, there is no impact on testing at this time since pre-operational tests have not yet been performed.

4.

The posting of FDDRs and FDIs against S&L design drawings was evaluated.

It was confirmed that FDDRs and FDIs were not being posted to these drawings.

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Jam c G. Keppler September 30, 1983 5.

The investigation determined the main causes contributing to the occurrence were:

document control instructions for handling FDDRs/

FDIs were not, in all cases, sufficiently

detailed, training of personnel in the use and inter-relationship of various G.E. documents was not
adequate, administrative support staffing of the document control center was not adequate to support planning and development work.

This problem was found to be unique to the handling of G.E.

design changes.

BA's design change methods for other drawings used at CPS were reviewed and found to be adequately controlled by procedures.

Corrective Action The following actions have been or are being taken to correct this deficiency and to prevent recurrence:

1.

Baldwin Associates has revised their procedures and instructions to incorporate revised methods of posting design changes.

BA then performed a complete review of G.E. drawings and ensured that the current design change status was indicated.

2.

Illinois Power Startup has revised their procedures and instructions to clarify how design change documents shall be received, reviewed, and issued in a controlled manner.

3.

Training has been performed for affected Illinois Power and Baldwin Associates personnel on processing of FDDRs/FDIs and in the use/ interrelationship of the various G.E. documents.

4.

The FDDRs and FDIs that have not yet been incorporated into S&L design drawings have been identified.

S&L is issuing Field Engineering Change Notices (FECNs) for posting against their design drawings, until the changes are incorporated.

5.

Illinois Power has established improved methods to identify the incorporation of G.E. design changes into affected drawings and provide status information regarding superseded drawings.

6.

The Baldwin Associates Document Control Center was reorganized under a new manager and additional

.....s Jemas G.-Keppler september 30, 1983 supervision is being recruited.

A management audit of the Document Control Center is also being performed to review present methods and procedures and to plan for future development.

Safety Implications / Significance The investigation of the FDDR/FDI posting problem found that the inadequate document control practices did not have an adverse impact on construction work'or testing activities at this time.

However, certain drawings did not reflect the approved design changes and the potential existed that future tests and test evaluations may not have accounted for the effects of the design changes.

Had this occurred, it could be postulated that design change errors would not have been identified during testing, which may have affected the safety of operations of Clinton Power Station.

Although this assumes several unlikely events, this deficiency is considered significant, and reportable under 10CFR50.55(e).

We trust that this final report provides sufficient background information to perform a general assessment of this reportable deficiency, and adequately describes our investigation and resolutions.

Sincerely yours,

/

. Hall Vice President REC /ldf cc:

NRC Resident Office Director-Office of I&E, USNRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center

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