ML20101B656

Final Deficiency Rept 55-84-07 Re Use of GE nonsite-specific Design Specs in Developing Preoperational Test Procedures. Initially Reported on 840328.Training on Proper Use of 6E Documentation Completed.Procedures Revised

ML20101B656
Person / Time
Site:	Clinton
Issue date:	12/06/1984
From:	Hall D IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-07, 55-84-7, U-10225, NUDOCS 8412200435
Download: ML20101B656 (5)

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Le IA.120 ILLIN0lB POWER COMPANY U 10225 CLINTON POWEll STAflON. P.O. BOX 670. CLINTON, ILLINOls 61727 December 6, 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

Subject:

10CFR50.55(e) Deficiency 55-84-07

Use of GE Non-Site Specific Design i Specifications for CPS Application l

Dear Mr. Keppler:

1 l On March 28, 1984, Illinois Power notified Mr. F. Jablonski, US NRC, Region III (Ref: IP memorandum Y-20510, dated March 28, 1984) of a potentially reportable deficiency under the provisions of 10CFR50.55(e) pertaining to the possible use of General Electric non-site specific design specifications in developing preoperational test procedures in use at Clinton Power Station (CPS). This initial notification was followed by two (2) interim reports (Ref: IP Letter U-10149, D. P. Itall to J. G. Keppler, -

dated April 27, 1984: and IP letter U-10195, D. P. Hall to J. G.

Keppler, dated August 17, 1984). Illinois Power's investigation of the above issue is complete and has determined that the issue represents a reportable deficiency under the provisions of 10CFR50.55(e). This letter is submitted as a final report regarding this potentially reportable deficiency. Attachment A provides the details of our investigation.

i We trust that this final report provides sufficient background information to perform a general assensment of this I reportable deficiency, and adequately describes our overall approach to resolve the issue.

Sincerely yours, t /

. . Itall Vice President <

f RLC/cbs (NRC) l Attachment I cci NRC Resident Office, V-690 1

Director - Office of I&E, USNRC, Washington, DC 20555 Illinois Department of Nuclear Safety '

INPO Records Center 8412%[oh dam t

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,- s ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 10CFP50.55(e) Deficiency 55-84-07 l Use of GE Non-Site Specific Design ,

Specifications for CPS Application '

Final Report Statement of Reportable Deficiency Illinois Power Plant Operations identified a problem in determining specific General Electric design specifications applicable to CPS. Illinois Power Startup staff use GE design l specifications as a basis in writing CPS preoperational test

procedures. Use of GE documents not directly applicable for CPS l may have resulted in incomplete preoperational test procedures.

We have reviewed this concern for possibic adverse impact on the safety of operation of CPS.

Background

, Illinois Power Plant Operations issued a Condition Report (1-83-03-067) on March 23, 1984, indicating that a roblem may exist with the use of GE generic document 22A3899, p' Control Rod Drive System Fast Scram," as a basis for writing a preoperational test procedure (PTP-RD-01), whereas document 22A5395, specific to l CPS, should have been used. A GE reference listing of documents, I

Customer Document Control System (CDCS), was used by the preparer of the test procedure to determine applicable design saccifications as a basis for the test procedures. A review of t:1e test procedure by Illinois Power Nuclear Station Engineering Department (NSED) identified an error in that the reference document, was not noted in the GE Haster Parts List (HPL). The condition report pertains to the selection of the proper source of information as used by CPS startup in selecting applicabic documents for writing tent procedures.

Investigation Results Illinois Power prepared and impicmented an investigation plan to determine the extent of this problem at CPS. The investigation included:

1. A report was issued by General Electric outlining the I

specific linting and means to deternine the correct documents and instruction manuals applicabic to CPS.

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ATTACHMENT A (continued)

2. Procedures used by CPS staff to identify the correct controlled GE documents and instruction manuals, applicabic to CPS, were reviewed. Ambiguities in the selection of controlled documents for use in writing testing and other procedures were identified.

3. Documentation control used for other than GE equipment was reviewed for similar problems in selecting controlled information.

Our investigation has determined that the primary root cause of the problem stems fron some CPS personnel not being fully cognizant of the use of the MPL as the correct method for determining GE documents that are specific to CPS. -

The GE Manual - Engineering Documentntion Systems, provides direction on how to use the GE documentation system. The manual states that following issuance, the Master Parts List (MPL) becomes the principal working document for the CPS project, with respect to hardware and software to be provided by GE. The MPL is the top tier controlled document that references lower tier documents. The MPL must he used to determine which documents are applicabic to CPS. The GE Engineering Infornation System (EIS) lists the latest revision of all documents directly applicabic to CPS and those identified as references on these documents.

The CDCS, by contrast, is a listing of the latest revision of each document transmitted to CPS from GE, regardicas of the specific applicability to CPS. The CDCS functions to provide an ongoing transmittal log of GE transnitted documents. no CDCS listing has been compared against the EIS listing and GE advised IP on January 16, 1984 (IP-2185), of those documents not applicabic to CPS. Sargent & Lundy Engineers have revised their Foreign Document Report to note this status. GE will periodically perform this comparison at IP's request.

Test procedures are initiated by the IP Startup group.

Preoperational Phase Test Procedures to verify operational performance of equipment are submitted to NSED for review in accordance with FSED Procedure D.10-Test Procedure Review and Approval. NSED reviews for adequacy and completeness of the referencen used to preparc the test 3rocedure and considers critoria such as system design, purciase specification, applicabic prints, drawings, data sheets etc. The test procedure is approved by the Startup Group after resolution of review comments, this approval does not constitute approval to perform the test. " Test Release" assurcs that before approval in ziven to commence testing, the previously issued test procedure las been ovaluated again by Startup for system scoping or design change revisions to references, etc.

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ATTACHMENT A (continued)

Illinois Power's Startup Group has reviewed 536 test procedures for possible use of improper references. This review identified 93 procedures with GE document references which were questionable. Of thesc 93 procedures, 25 have been released for test. Startup has reviewed all 25 procedures, only two of which pertain to safety related systems. One (1) of these documents references a possible incorrect design specification, however, subsequent review and evaluation hac determined that no impact en safety exists. The second procedure was corrected to delete information not applicable to the equipment and to update with latest drawing revisions, neither of which have an impact on safety. The remaining 68 test procedures (including PTP-RD-01) will be niven a final review and revised if necessary prior to

" Test ReIcase". This approach is appropriate since the referenced GE documents may change prior to " Test Release".

A review was conducted by NSED to ensure that a similar concern does not exist for documentation provided by other vendors, and used in writing Startup preoperational test procedures. The conclusion of this review indicated that the existing S&L and BA document status reporting systems, available on site, are sufficient to ensure that the appropriate revisions of site specific documents are used at CPS.

Corrective Action To preclude the possibility of incorrect documents being used for writing of preoperational procedures, the following corrective actions have 3cen taken:

1. Training NSED, Startup, and Plant Staff have provided training on the proper use of GE documentation. Emphasis has been placed on assuring that all personnel are aware that the MPL is the naster document to be used in deternining applicable GE documents, and the CDCS in merely a transmittal log of the latest revision of each document sent to CPS by CE. The CDCS cannot be used to determine if a document is applicable to Clinton, NSED - All training complete.

Startup - All training complete.

Plant Staff - All training complete except as follows:

Operations - duc 12/21/84.

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• ,,* O e ATTACHMENT A (continued)

2. Departmental Procedures To ensure proper consideration is given to using the MPL when preparing procedures, the following p"rocedures have been revised to specifically state that, the MPL should be used to determine appropriate GE documents".

a. NSED Procedure D.10, " Test Procedure Review and Approval", Revision 2, Attachment D.10-3.

b. NSED Procedure D.25, " Test Procedure and Aparoval for Plant Modifications", Revision 1, Attachment D.25-1.

c. Startup Procedures SAP-14, " Test Procedure Development", Revision 2, Section 6.1.5.6 (TR-7).

d. Startup Procedure SAP-15, " Test Release",

Revision 0, Section 6.3.2.3 (TR-3).

l c. Operations Procedure OAP 1005.01, " Preparation,

. Review, and Approval of Station Procedures and l Documents", Rev. 12, Paragraph 8.1.2.9.12.

l 3. A review of all test procedures was performed to assure l that the correct references were used. The test I

procedures will be revised where appropriate to correct identified discrepancies prior to fuel load.

4. An EIS terminal has been provided for use by the Startup and Plant Operations Groups in addition to the existing terminal in the GE Construction Office. The EIS terminal arovides on-line computer capability for determining the latest revision to GE documents.

5. The Startup and Operations Libraries have been provided with a controlled copy of the MPL for use in determining applicable GE documento.

Snfety Implications / Significance Investigation of this issue is complete. Illinois Power Company has reviewed and evaluated the findings of this investigation and determined that there was a breakdown in the program for identifying the correct documents to use as a basis in writing preoperational test procedures. A number of test procedures were approved for testing using incorrect design information. Had this condition remained uncorrected it could have adversely affected the safety of operation of CPS in that the design performance specifications would not have been properly verified. Therefore this issue is considered to be reportable under the provisions of 10CFR50.55(e).

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