ML20093E641

Interim Deficiency Rept 55-84-01 Re field-initiated Design Change Control.Initially Reported on 840111.Procedural Changes Developed to Provide Adequate Guidance for Correcting Change Disposition

ML20093E641
Person / Time
Site:	Clinton
Issue date:	09/24/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-01, 55-84-1, U-10202, NUDOCS 8410120196
Download: ML20093E641 (4)

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'ILLIN0/8 POWER OOMPANY ggy y.10202 CLINTON POWER STATION. P.O. 80X 678. CLINTON. ILLINOIS 61727 September- 24, 1984 Docket-No; 50-461 Mr. James G. Keppler Regional Administrator Region III-U.,S. Nuclear Regulatory Commission

'799 Roosevelt Road Glen Ellyn, Illinois 60137

. Subj ect : Potential 10CFR50.55 (e) Deficiency 55-84-01 Design Change Control (NCRs/FCRs)

Dear'Mr. Keppler:

On January 11, 1984, Illinois Power Company notified Mr. R. C. Knop, NRC Region III, (ref: IP memorandum Y-18979 dated January 11, 1984) of a potentially reportable deficiency per 10CFR50.-55 (e) concerning the control of field design changes at Clinton Power Station (CPS). This initial notification was

.followed by two (2) interim reports:(ref: IP letter U-10126, D.

P. Hall to J. G. 'Keppler dated February 21, 1984, and IP letter U-10160, D. P. Hall to J. G. Keppler dated June 13,.1984) . -Our investigation of this issue is_ continuing, and this letter represents an interim. report in accordance with the requirements of 10CFR50.55 (e) . Attachment A provides the details of our -

investigation to date.

We trust that this interim. report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes our overall_ approach- to resolve the issue.

Sin cerely . yours ,

@ D. P. Hall Vice President RLC/cah;(NRC2) cc: NRC: Resident Office Director - Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records- Center 8410120196 840924 PDR ADOCK 05000461 S PDR gy Eq _

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ATTACHMENT A ,

Illinois Power Company.

Clinton Power Station

, Docket No. 50-461 Potential 10CFR50.55 (e) Deficiency 55-84-01 Design Change Control (NCRs/FCRs)

. Interim Report Statement of -Potentially Reportable Deficiency

-Potential problems have'been identified with the coordination and control of field-initd ated design changes between Sargent & Lundy (CPS Architect / Engineer) and Baldwin.

Associates (CPS Constructor).. The problems pertain to the revision of Field Change Requests (FCRs) and Nonconformance Reports (NCRs), their incorporation into affected design documents, and the identification of:all directly affected documents on the FCRs/NCRs. An investigation and evaluation of

'this issue is being performed to determine the extent of this problem, affect on installed hardware, and significance to the safety of operation of CPS.

Background

As a result of Illinois Power Company's Quality Assurance audits, findings were written to document problems identified in the area of control of field design changes for CPS. The findings concerned procedural requirements defining the design change interface between the CPS Architect / Engineer and CPS Constructor. The specific nature of the concerns includes the following:

1. FCRs were identified that were not posted against-or incorporated into all affected design drawings. This inhibits verification of document status within the Constructor's document control system.

2. FCRs were revised and incorporated into design drawings without noting the FCR revision number on the design drawings. This inhibits verification-that the FCR revision was incorporated into the design drawing.

3. The Constructor's procedures for processing revisions to change documents did not allow revision after the specific work completion and work document closure. As a result, revised FCRs and NCRs must be reviewed to ensure that the documentation and/or hardware changes were accomplished. '

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-Investigation Results/ Corrective Action-

. l Illinois Power _(IP). prepared and implemented ae investigation. plan to determine _the' extent of this problem at

- CPS .- The-investigation plan included:

1. A~ review'was: performed of FCRs/NCRs issued. prior to December 1, l1983, to assure that all directly affected documents associated with the field change have been properly identified,.

2. A. review was performed of' requests for revisions to

.FCRs/NCRs to ensure that hardware installations were.

performed, 'where required, and that they agree with the latest-plant design, 3.- Procedures.used by affected organizations for the control of

. field design changes _were reviewed for consistency and interfacing adequacy, and

4. The methods for controlling revisions to other types of ,

design change documents, such as Field Engineering Change Notices (FECNs), were also reviewed for adequacy.

lo date, approximately 30,000 FCRs/NCRs have been reviewed to identify directly affected design documents. Additional affected design documents were identified for approximately 45%

of the 30,000 FCRs/NCRs that were reviewed. The newly identified affected documents are primarily.due to the past practice of listing,.on the FCR/NCR, only those affected documents that would be posted and incorporated. Current procedures require all affected. documents to be identified and listed on the FCR/NCR, indicating incorporation /non-incorporation.

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The newly identified affected design documents may not be posted or incorporated into the design document, but will be entered into - the IPC computer data base for traceability. The IPC computer data base will be utilized to maintain up-to-date information on the latest. ..

revision and incorporation status of each FCR/NCR for document control interfacing between S&L, BA, and IPC. The data base will be _ utilized by the Constructor to verify installation conformance to the latest revision of documents affecting design.

A review'has been performed of all S&L letters issued from July,21981~to September, 1983, pertaining to request for revision to FCRs/NCRs. Of the 1,560 change documents identified by this review, approximately 260 required' documentation / field

' verification that affected installations conform to the latest plant. design. New-FCRs/NCRs were generated to ensure completion of action, where required by the documents reviewed.

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J ATTACHMENT A

'(continued)'

The practice ofL revising FCRs/NCRs ' was discontinued by-Baldwin Associates. Procedural changes were developed to provide

- adequate guidance for correcting the disposition of a FCR/NCR which is determined to be incorrect, inadequate or incomplete.

The methods -for controlling changes to other engineering /

' construction interface documents, such as ECNs, FECNs, and ECPs,-

were evaluated to verify-that these documents are satisfcetorily controlled.

All FCRs/NCRs issued in the future will have the directly affected documents listed in the IP computer data base, along with the1 status of incorporation.

Since our last reports (1) 5,000 additional NCRs/FCRs have been reviewed for a total of approximately 30,000 documents, and all newly identified design documents have been entered into the

IP computer data base (Engineering Change Tracking System) for tracking. (2) Sargent & Lundy (S&L) has completed logging into the IP computer data base the latest revision of each FCR/NCR.

Baldwin Associates can now utilize this program to verify installation conformance with the design. (3) Applicable S&L and BA procedures have been revised and issued. (4) Approximately 260 change documents requiring documentation review or field verification were reviewed. Of the 260 documents reviewed, 39 have been identified as requiring evaluation for safety.

significance.

Safety Implications / Significance Illinois Power Company has requested Sargent & Lundy to-evaluate the 39 FCRs/NCRs identified as a result of this investigation for significance to the safety of operation of CPS.

It is anticipated that approximately sixty (60) days will be necessary.to complete this evaluation and to file a final report on this issue.

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