ML20099L497
| ML20099L497 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/27/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| U-0764, U-764, NUDOCS 8412010147 | |
| Download: ML20099L497 (11) | |
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=L40-84(ll-27)-L 8G.150b I ILLIN018 POWER COMPANY!
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' 500 SOUTH '27Th STREET, DECATUR. ILLINOIS 62525-1805 4 ;
November-27, 1984 1 Docket:50-461 J. -Nelson. Grace, Director Division of.Qcality Assurance, Safeguards and Inspection Programs Office of Inspection and Enforcement U. S. Nuclear' Regulatory Commission Washington, D. C.
20555
Subject:
Clinton Independent Design Review Implementation Inspection Report t
50-461/84-39
Dear Mr. Grace:
Your letter to Illinois Power Company (IP) of November 6, 1984, transmitted the subject report (50-461-84-39) which documents the results and conclusions of the implementation inspection of the Bechtel Power Corporation's (Bechtel) independent design review of the Clinton Power.
17 Station (IDR) by the Nuclear Regulatory Commission's (NRC) Office of Inspection and Enforcement.
4 Your letter stated that the NRC inspection team concluded /that, while
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-the IDR program plan was being adequately implemented,'some items had been identified as areas for IDR improvement. These items were-classified-as either programmatic or_ technical. The comments classified as programmatic were to be addressed as.soon as possible, while comments classified as technical did not need to be separately addressed as long as they are-discussed in the final IDR report.
Your letter also requested that plans fo_r resolution of the items in the NRC-inspection report be presented at the Clinton IDR progress report meeting on November 13, 1984, and that a follow-up written response be-submitted by November 27.
In accordance with your request, at the November 13_ meeting Bechtel described preliminarily-the improvements being made in the IDR in response to the NRC's programmatic. comments. The NRC representatives at the meeting i
indicated that the-described actions were responsive to the NRC inspection-
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report.. -(Tr.'261).Bechtel has summarized the actions ~being.taken in the enclosed letter-to'IP dated November 27, 1984. We have reviewed..Bechtel's 4
response-and believe that_it satisfactorily' responds to the NRC's
-programmatic comments. 'Accordingly, the improvements described by Bechtel are'being-implemented-in the conduct of-the-1DR.
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-As we have discussed with your staff, in view of the substantive matters involved in the NRC's technical comuments we have requested Bechtel
- to: communicate directly with the NRC on those items.. Accordingly, we understand that by separate letter Bechtel.is either responding to the
--technical comments or informing the NRC that the items will be discussed in the final IDR report.
Sincerely yours, LA.
D. P. Hall Vice President'-
cc: See attached distribution list f
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L40-84(11-27)-L.
8G.150b Clinton Power Station Independent Design Review Standard Distribution List Director of Nuclear Reactor Regulation
. Richard J. Goddard, Esq.
Attn:
Mr. A. Schwencer, Chief Office of the Legal Director Licensing Branch No. 2 U.S. Nuclear Regulatory Commission Division of Licensing Washington, D. C.
20555 U.S. Nuclear Regulatory Commission Washington, D. C.
20555-Don Etchison Director, Illinois Department of James G. Keppier Nuclear Safety Regional Administrator 1035 Outer Park Drive Region III Springfield,. Illinois 62704 U.S. Nuclear Regulatory Commission 799 Roosevelt Road Allen Samelson, Esq.
Glen Ellyn, Illinois 60137 Assistant Attorney General Environmental Control Division Byron Siegel Southern Region Clinton Licensing Project Manager 500 South Second Street Mail Code 416 Springfield, Illinois 62706 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Jean Foy Spokesperson, Prairie Alliance Fred Christianson 511 W. Nevada Mail Code V-690 Urbana, Illinois 61801 NRC Resident Office Clinton Power Station Richard Hubbard R.R. f3, Box 228 MHB-Technical Associates Clinton, Illinois 61727 1723 Hamilton Avenue Suite K James L. Milhoan San Jose, California 95125 Section Chief, Licensing Section Quality Assurance Branch Gordon L. Parkinson Office of Inspection and Enforcement Bechtel Power Corporation Mail Stop EWS - 305A Fifty Beale Street U.S. Nuclear Regulatory Commission P. O. Box 3965 Washington, D. C.
20555 San Francisco, California 94119 Richard C. Knop Roger Heider Section Chief Sargent & Lundy Engineers Projects Section 1-C 55 East Monroe Street U.S. Nuclear Regulatory Commission Chicago, Illinois 60603
~799 Roosevelt Road Glen Ellyn, Illinois 60137 5
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Bechtel Power Corporation Engineers-Constructors Fifty Beale Street San Francisco, Cahforno Mast Address: P O. Box 3965, San Francisco, CA 94119 November 27, 1984 BLI-42 Mr. J. D. - Gef er Illinois Power Company Mail Code A-17 500-South 27th Strcot Decatur, Illinois 62525
Subject:
Clinton Power. Station, Independent Design Review -
Illinois Power Company Job No.15478-003 Responses to NRC Inspection Report 50-461/84-39, dated November 6,1984
Dear Mr. Geier:
Enclosed is our response to the subject inspection report, except with' respect to the NRC's technical cornents.
In accordance with your request, we are providing our responses to the technical comments directly to the NRC.
Please advise, as soon as possible, regarding acceptance of this response by the NRC.
Very truly yours,
/
Av
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L'. Parkinson Project Manager GLP:scr Enclosure cc: 11. Axelrad D. Wilson i
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-w November -27,1984 BECHTEL POWER CORPORATION RESPONSES TO NRC INSPECTION OF CLINTON IDR OF OCTOBER 17-19, 1984 General This is the response to the NRC report of Noyegber 6,1981 covering the NRC inspection of the IDR on October 16-19,198411 J, except with respect to the NRC's technical comments.. In this response, the IDR sets forth its positions regarding programatic comments of the NRC, and describes specific actions as a result of the report and related discussions.
The programmatic coments in the NRC report are interpreted as recommended
. improvements to facilitate acceptance of the results of the IDR including the Final Report.
It is understood, however, that the NRC comments indicated that the IDR-was being satisfactorily implemented. To effect these improvements, efforts have been made in several areas: 1) documenting the IDR work in greater detail and assuring greater consistency of it segments, 2) formalizing some of its existing practices through guidelines and procedures, 3) clarifying definitions and responsibilities, and 4) performing internal reviews of the IDR work to assure ebjectives of the IDR are met.
The IDR proposes to be responsive to all of the NRC programmatic recommendations.
In doing so, the IDR Team is interpreting the NRC recommendations in' the context of the situation known to the IDR and attempting to assure that the NRC concerns are most effectively met.
In some areas, this requires striking a balance between considerations, such as, balancing the level of detail in procedures against providing the reviewers with sufficient latitude to assure their effectiveness.
In evaluating results, it is concluded that the work performed prior to the NRC inspection of October 17-19 is valid.
That is, the IDR Team concludes there are no reasons to believe areas exist where its basic work is not acceptable or needs to be reperformed. This is supported by the NRC Inspection Report which concludes, "the IDR progran plan was being adequately implemented", including its quality assurance program. To the extent that recommended actions produce any further review or other results, these may be regarded as being necessary to augment the IDR rather than reperforming parts of it. The IDR Team is confident of the validity of its work, to date, with respect to both its programmatic and technical work.
(l)Clinton Independent Design Review (IDR) Implementation Inspection Report 50-461/84-39 0655C j
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- s Programmatic Comments Specific actions to be taken by the IDR Team related to programmatic matters are listed in Table 1, attached. The procedure revisions referred to clarify existing topics, and make additions to them. However, they do not change existing procedures. They essentially describe, more explicitly, how the IDR is already being performed.
Schedule for Action Action has been completed on programmatic matters, subject to possible further comments by the NRC or Illinois Power.
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November 27, 1984 Table 1 PROGRAMATIC COMMENTS NRC Comment:
IDR procedures should permit obtaining factual information from reviewee personnel. At the same time, these procedures should clearly identify protocol requirements relative to discussions of substantive technical matters with reviewee organizations. Substantive discussions of technical matters with reviewee personnel should be prohibited until after a potential observation report has been prepared and the reviewee organization has been given an opportunity to respond to the potential observation in writing. This procedure may yield an increased number of invalid potential findings but is necessary to guard against the possibility of premature disposition of a valid observation. The re-examination of review sheets in light of threshold guidelines discussed above should identify any potential observations which may have been prematurely dispositioned prior to revision of these procedures.
Response
As we explained at the meeting on November 13,1984 (Pages 216-18), we believe that the protocol (including the amendment approved by the NCR on November 6) contains suitable provisions which permit the IDR to obtain necessary facts, that we are using experienced reviewers who have the maturity to avoid undue influence and to operate within the constraints of the protocol, that the review by our System Leaders assures tnat items which should be pursued are not passed over, and that additional assurance will be provided by the fact that our review work is well documented and available for audit.
The process for contact with reviewees was addressed in the original Procedures Manual and has been adhered to throughout the IDR process.
In addition, IDR Procedure #2 and IDR Procedure #3 were revised to further emphasize that substantive discussions with the reviewee relative to the design information or review conclusions were not to take place.
Sections 4.1.2 (Review Sheets) and 4.1 (Design Review) of Procedures #2 and 3 respectively, have been changed as follows:
"In making such contacts, the Reviewer shall take particular care to avoid conveying, to the Reviewee, any potential or preliminary conclusions of the review."
(Section 4.1.2, Procedure #2)
"In making such contacts, the Reviewer will take particular care to avoid conveying, to the Reviewee, any potential or preliminary conclusions of the review." (Section 4.1, Procedure #3.)
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Review t:aa engineers were counseled to emphasize that such substantive discussions with reviewee contacts were to be avoided, and a memorandum was issued to review team members to this effect. This memorandum was signed by the Project Manager on October 23, 1984 and distributed to each IDR team member.
Pertinent portions of this memorandum are as follows:
"All review team members are cautioned to take particular care to avoid conveying to S&L or other design reviewees any potential or preliminary _
conclusions during review activity."
NRC Comment:
IDR project procedures should provide clear guidelines for determining the threshold between inconsequential discrepancies, such as minor calculation math errors, and observations or potential observations. The review sheets should be re-examined considering these threshold guidelines.
Prior to the final report, the completed review sheets should be examined as a package for implications related to design process trends indicated by those deficiencies not classified as observations or potential observations.
Response
As me also explained at the meeting on November 13 (Pages 213-5), we believe that the specific definition of an observation is a key threshold of the IDR, that judgement and experience are necessary.to distinguish a potentiel observation from less important items, that it is difficult to establish absolute consistency in evaluating minor matters, and that the most important requirement is to assure that none of the potential observations is not fully reviewed.
Any threshold question has generally been handled during the course of the review by close coordination between review team engineers and their system leaders.
If there was any doubt in a reviewing engineer's mind as to the significance of a deviation or deficiency, he was directed to consult with his system leader on the matter. Nevertheless, as we discussed on November 13 (Pages 215-16), we have taken some additional actions.
o A memorandum on this subject has been issued to the review team to provide clear, consistent guidelines for determining the threshold betw?en inconsequential discrepancies and potential observations. This memorandum was signed by the Project Manager on November 12, 1984 and distributed to each IDR team member.
Pertinent portions of the memorandum are as follows:
"To provide as much uniformity to our review process as is possible (recognizing varying degrees of complexity in the areas being reviewed and the varying sensitivities of the individual design processes 'to potential deficiencies), the following potential observation threshold guidelines are provided:
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-l Typical conditions which might warrant a POR'includa:
Is there a failure to meet a commitment?
-o Does a design process fail to provide for consideration of all design o
requirements?
o Is there a design error which could result in degradation to system / component performance?
o Is there a design error which, in the reviewed area, does not result in degradation but could adversely affect other commitments?"
o Section 4.1.2 (Review Sheets) of Procedure #2 was clarified to assure that all potential deficiencies are documented on the review sheet, and that the Reviewer includes his justification if he determines that the deficiency does not warrant issuing a POR. The procedure now states:
"If the potential deficiency does not, in the Reviewer's opinion, warrant the initiation of a Potential Observation Report (POR), the review sheet shall contain the Reviewer's justification for that position."
o Section 4.1.4 (Review Concurrence) of Procedure #2 has also been revised to make explicit that if the System Leader does not concur with the Reviewer's justification, it will be supplemented or a POR will be issued. The procedure now states:
"The System Leader shall review noted potential deficiencies and the Reviewer's recommended disposition.
If the System Leader does not concur with the Reviewer's justification for not issuing a POR, the justification shall be supplemented or alternatively, a POR will be issued."
o We are also counseling our reviewers to assure that items are properly evaluated so they are not inadvertently misclassified as insignificant.
In addition, System Leaders were directed via the above memorandum to e
res few a representative sample of completed review sheets and take corrective action, if required. Further, Quality Engineering will, during their reviews far deficiencies noted on review sheets, bring indications of insufficient detail to the attention of the System Leader. The appropriate excerpt of this memorandum is as follows:
"To provide as much consistency in review detail as is possible, considering the points made above regarding potential observation threshold guidelines, System Leaders should consider this requirement regarding review detail in their acceptance of Review Sheets. Review Sheets with insufficient detail should be returned for augmentation prior to approval, t
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y Since thes2 guidelines are being issued late in the IDR process, System Leaders should review a representative sample of review sheets already accepted and take corrective action if required.
In addition, Quality Engineering will, during their reviews for deficiencies noted on review sheets, bring indications of insufficient detail to the attention of the System Leader."
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o Finally, the trending program being implemented by Quality Engineering has been expanded to include the minor discrepancies for which PORs were not issued in order to detennine whether they collectively indicate other areas that may be worthy of investigation. Section 4.3 (Trend Analysis) has been revised; the Procedure now states:
" Quality Engineering shall review completed and approved Review Sheets to note the documentation of potential deficiencies not reported as Potential Observations.
These deficiencies shall be reviewed for evidence of comon or repetitive trends.
If trends are detected, they shall be evaluated and processed in accordance with IDR #3."
NRC Coment:
Project procedures should be made clear as to the management level making decisions relative to scope questions, as well as basic guidelines or policy regarding prosecution of problem areas which exceed scope restrictions.
Response
As we discussed on November 13 (Pages 218-31), we believe that in view of the broad scope of the IDR there are inherent safeguards against missing items because they are considered out of scope, and our program plan and impicmenting procedures cover this area rather well.
Nevertheless, we have revised Section 4.1.3 of Procedure #2 to clarify how scope ocisions are made at the management level of the IDR. Specifically, even for a problem which may be outside of the IDR scope, a POR will be issued thus requiring review by the System Leader and the Level-1 Review Committee.
Procedure #2 now states:
"If the Reviewer identifies a condition which has a potential adverse impact on a design area or activity outside of the scope of the Clinton IDR, a POR shall be initiated which will contain a recommendation for Sal or others_to investigate."
NRC Comment:
Project review sheets are an important source of information in evaluating the depth of the IDR. As such, they should be consistent in the level of detail provided in them, particularly with regard to providing reference information or cross-referencing to related observations. The IDR procedures should address how consistency between review sheets will be assured.
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Response
As we explained on November 13 (Pages 231-36), we believe that it is essential to assure that the review sheets are consistent in containing the key elements of each topic reviewed and that achieving consistency in details is more difficult and less important. Moreover, the IDR final report will normalize the discussions of matters covered in the review sheets.
Nevertheless, review sheets are now being prepared in greater and more consistent detail.
In addition, Section 4.1.2 of IDR Procedure #2 was revised to address the required level of detail. Review team engineers were counseled as to the level of detail and clarity desired. Finally, reviews for level of detail are being perfomed by management and Quality Engineering This procedure has been revised to include this requirement as follows:
" Review sheets shall contain sufficient detail of the identification of documents reviewed and review characteristics to permit the System Leader to assess the depth of review achieved by the Reviewer."
HRC Comment:
Further communication between discipline review groups should be encouraged.
Response
As we discussed on November 13 (Pages 240-42), encouragement and maximization of inter-and intra-disciplinary communication is standard policy on all Bechtel projects. The Clinton IDR team engineers in the various disciplines are physically located in the same area. Whenever a portion of an item being reviewed is outside the reviewer's area of expertise, the reviewer, as a matter of course, consults with appropriate team engineers either within or outside his discipline.
In addition, Section 4.1.2 of IDR Procedure #2 was revised to make more visible this normal Bechtel mode of operation, and review team engineers were instructed that such communication is required in the event of any doubt.
Also, the multidiscipline Level I review of Potential Observation reports constitutes an additional level of review beyond the normal interdiscipline exchange at the working level.
The procedure now includes the following instruction:
"If the Reviewer is unable to conclude acceptability of a particular condition *because the subject is outside of the Reviewer's area of expertise, the condition shall be referred to an appropriate member of the IDR team. The Reviewer shall note such referral on the review sheet."
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