ML20100F918

Interim Deficiency Rept 55-84-01 Re Control of Field Design Changes.Initially Reported on 840111.Field Change Repts Issued Before 831201 Reviewed to Identify Affected Design Documents.Next Rept Will Be Submitted within 45 Days

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 AA*I20 j)CE U 10257 CLINTON POWER STATION. P.O. BOX 678. CLINTON ILLINOIS 61727 March 21, 1985 Docket No. 50-461 l 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:

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On January 11, 1984, Illinois Power Company notified

, 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 i L-10160, D. P.. Hall to J. G. Keppler dated June 13,-1984; IP 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,

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DC 20555 L I\

Illinois' Department of Nuclear Safety ' g'P "INPO Records Center MAR 261985M1

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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

{ 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 4

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, 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 4

design drawings. This inhibits verification of-document status-within the Constructor's document control system.

I 2i. FCRs were revised and incorporated into design drawings

.without noting the FCR revision number on the. design l

drawings. 1This inhibits-verification that the FCR revision 4

was incorporated into.the design drawing.

3. The Constructor's procedures.for processing-revisions to i 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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+ ATTACHMENT A (continued)

L Investigation Results/ Corrective Action Illinois' Power (IP) prepared and. implemented an 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, 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 i

performed, where required, and that they agreed with the t

-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

}- 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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4 Management System (DMS). computer data bases for document i

4 tracking. - As of Novembert1983,. procedures required affected 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

? - 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)

I c 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 4 completeness. Completion of the DMS tracking system will provide

! ready. availability of.this information to all site. drawing i- stations >for use by construction' personnel.

During i the course of resolution of.the problem sith process-1 ing revisions-to change documents, 41 new change documents (NCRs/

[' 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 c of~the directly.affected design documents ~against the

. = 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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