ML20100F918
| ML20100F918 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/21/1985 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-N 55-84-01, 55-84-1, U-10257, NUDOCS 8504050330 | |
| Download: ML20100F918 (4) | |
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/LLIN018 POWER COMPANY j)CE U 10257 CLINTON POWER STATION. P.O. BOX 678. CLINTON ILLINOIS 61727 March 21, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III
.U..S. Nuclear Regulatory Commission i
799 Roosevelt Road i
Glen Ellyn, Illinois 60137 i
Subject:
Potential 10CFR50.55(e) Deficiency 55-84-01 Design Change Control (NCRs/FCRs)
Dear Mr. Keppler:
1 On January 11, 1984, Illinois Power Company notified 3
Mr. R. C. Knop, NRC Region III, (ref: IP memorandum Y-18979 dated January 11, 1984) aof 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 four-(4) interim reports (ref: IP letter U-10126, D.
j P. Hall to J. G..Keppler dated February-21, 1984;' IP letter L-10160, D.
P.. Hall to J. G. Keppler dated June 13,-1984; IP i
letter U-10202, D. P. Hall to J. G. Keppler dated September'24, 1984; and IP letter U-10230, D.
P.. Hall to J. G. Keppler dated December 18, 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 l
potentially: reportable deficiency and adequately describes our overall approach to resolve the issue.
Sincerely yours,
^
8504050330 850321
. Hall i'
DR ADDCM 05000461 Vice President g
PDR RLC/lr*(NRC2)-
Attachment.
cc: 'NRC Resident Office:
Director
_ Office.of!I&E,:US NRC,' Washington, DC 20555 L I\\
Illinois' Department of Nuclear Safety
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MAR 261985M1 "INPO Records Center 6
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J ss ATTACHMENT A 1
Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-84-01 g
Design Change Control (NCRs/FCRs)
Interim Report
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Statement of Potentially Reportable Deficiency i
-Potential problems have been identified with the coordination and control'of field-initiated design changes between Sargent & Lundy (CPS Architect / Engineer) and Baldwin Associates-(CPS Constructor).
The problems pertain to the 4
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, effect on installed hardware, and significance to the safety of operation of CPS.
Background
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-As a result of Illinois Power'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 arocedural requirements defining the design change interface 3etween'the CPS Architect / Engineer and CPS Constructor.
The specific nature:of the concerns includes the following:
'1.-
FCRs issued. prior to December 1, 1983,.were identified as
-not being posted against or incorporated-into all affected i
design drawings.
This inhibits verification of-document 4
status-within the Constructor's document control system.
I 2i.
FCRs were revised and incorporated into design drawings l
.without noting the FCR revision number on the. design drawings. 1This inhibits-verification that the FCR revision 4
was incorporated into.the design drawing.
3.
The Constructor's procedures.for processing-revisions to change documents did not. allow revision after the specific-i 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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ATTACHMENT A
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(continued)
L Investigation Results/ Corrective Action Illinois' Power (IP) prepared and. implemented an investigation plan to determine.the extent of this problem at
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CPS.
The. investigation plan included:
1.
A' review was performed of FCRs/NCRs issued prior to,
' December 1, 1983, to assure that all directly affected documents associated with the field change have been properly identified, 2.
A review was performed of reques'ts for revisions to FCRs/NCRsito ensure that hardware installations were performed, where required, and that they agreed with the i
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-latest plant design, i
-3.
Procedures used by affected organizations for the control of field design changes were reviewed for consistency and interfacing adequacy, and
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4.
The methods for controlling revisions to other types of j'
design: change-documents, such as Field Engineering Change 1
Notices (FECNs), were also reviewed for adequacy.
To date, approximately 30,000 FCRs/NCRs,- issued prior to l
December:1, 1983, have been reviewed to. identify directly affected design documents.
Trac'eability was established for.
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additional affected design documents that were not listed on the F
FCR/NCR in;approximately 45% of the FCRs/NCRs 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.
The newly identified.affected design' documents'may not be aosted or-incorporated into the design-document, but will-3e entered into the CPS Construction Management Information (CMI) and Data
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Management System (DMS). computer data bases for document 4
i tracking.
As of Novembert1983,. procedures required affected 4
documents to'be identified and-listed on the FCR/NCR, indicating incorporation or.non-incorporation. - The CPS (CMI) computer data
. base isLheing utilized to--maintain up-to-date information on the latest' revision:and incorporation-status of.each FCR/NCR for
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- document control interfacing between S&L, BA, and'IPC. : A similar-
- (DMS)~ data base, which is used by_the Constructor to-verify installation conformance t:o the. latest revision of ' documents
-affecting-design,-is.in the process.of being updated with-the-latest information.
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ATTACHMENT A i
(continued)
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A review has also been performed of all S&L letters issued from July,-1981 to September, 1983, pertaining to S&L requests for revisions to FCRs or NCRs.
This review identified 1,560 change documents..which required additional Baldwin Associates
' action.
Of these, 260 required documentation changes or field
' checks to verify the installations conform to the latest plant
- des ip.
Forty-one.new FCRs or NCRs were. generated to ensure
. completion of action by this verification process.
The practice of 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 /
constru'ction interface documents, such as ECNs, FECNs, and Engineering Change Packages (ECPs), were evaluated to verify that these. documents are satisfactorily controlled and do not have similar problems with revisions.
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Progress Summary Since our last report, Illinois Power has reviewed the S&L committed action and is satisfied that all change documents (NCRs/FCRs) issued prior to 12/1/83, have affected design drawings' identified.
The directly affected documents-and status of incorp' oration have been entered into the CPS (CMI) computer data base 1 tracking system.
The parallel.DMS computer data base is currently'being updated and will be verified for accuracy and completeness.
Completion of the DMS tracking system will provide 4
ready. availability of.this information to all site. drawing i-stations >for use by construction' personnel.
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- During the course of resolution of.the problem sith process-ing revisions-to change documents, 41 new change documents (NCRs/
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FCRs) were generated.
S~&,L has provided notification that.the.
' review and/or analysis of these' change documents is complete'and
'that no significant safety concerns were1 identified.
Safety' Implications / Significance LIllinois Power Company's investigation of this potentially reportable deficiency is : continuing.:.The safetyJimplications and significance ~will be~ assessed after S&L has completed.their.
review of~the directly.affected design documents ~against the c
= change' document data l base and_the_ data. base is verified.
It is-anticipated thattapproximately 45 days will he1 required-to
- complete the above. action and.to file a final report on this C
issue.
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