ML20101Q227
| ML20101Q227 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/18/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-5000461 55-84-01, 55-84-1, U-10230, NUDOCS 8501070476 | |
| Download: ML20101Q227 (4) | |
Text
N /71 O lA.120 ILLINOl8 POWER COMPAlvY U-10230 CLINTON POWER STATION P.O. box 678 CLINTON, ILLINOIS 61727 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:
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 three (3) interim reports-(ref: IP letter U-10126, D.
P. Hall to J. G. Keppler dated February 21, 1984, IP letter U-10160, D. P. Hallito J. G. Keppler dated June 13, 1984 and IP letter U-10202, D. P. Hall to J. G. Keppler dated September 24, 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.
Sincerely yours,
. Hall Vice President RLC/gs (NRC2) 8501070476 841218 PDR ADOCK 05000461 Attachment g
PDR cc:
NRC Resident Office
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Director - Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety k ".,N INPO Records Center L
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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-initiated 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. lui 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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a ATTACHMENT A
-(continued)
. Investigation Results/ Corrective Action Illinois Power-(IP) prepared and implemented an investigation plan to determine lthe extent of this problem at
. CPS.
The investigation plan included:
1.-
A review was-performed of FCRs/NCRs issued prior to December.1, 1983, co assure that all directly affected documents associated with the field change have been properly identified, 2.
A review we.s performed of requests for revisions to FCRs/NCRs'to ensure that hardware installations were r
performed, where required, and that they agree with the latest plant decign, 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 an Field Engineering Change i
Notices (FECNs), were also reviewed for adequacy.
[
-To date, approximately 30,000 FCRs/NCRs have been reviewed.
to identify directly affected design documents.
Additional-l 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 l
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, affected design'poration/non-incorporation.
indicating incor i~
~
The newly identified
[
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 L
utilized to maintain up-to-date information on'the latest revision and incorporation status of each FCR/NCR for documant control' interfacing between S&L,,BA, and IPC.
The data base will Lbe 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 l
JJuly, 1981 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.
L of action, where required, by the documents. reviewed.
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a' ATTACHMENT A (continued)
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 /
construction interface documents, such as ECNs, FECNs, and ECPs, were evaluated to verify that these documents are satisfactorily controlled.
All FCRs/NCRs issued in the future will have the directly affected documents listed in the IP computer data base, along with the status of incorporation.
Progress Summary Since our last report, Illinois Power has reviewed the S&L committed ar. tion under audit report findings Q35-83-5, AF-PD-1 and AF-PD-2.
The committed S&L action was reported, complete on July 15, 1984.
However, several concerns have been raised through an IP0A audit regarding the completeness / adequacy of the S&L committed actions.
It is anticipated'that further review will be required to resolve these concerns.
During the course of resolution of Audit Report Finding 031-82-3-2, 41 new change documents (NCRs/FCRs) were generated.
S & L has provided verbal notification that the review and/or analysis of 40 change documents is complete and that no significant safety concerns were identified.
The review and analysis of the final change document is still pending.
Safety Implications / Significance Illinois Power Company's investigation of this potentially reportable deficiency is continuing.
The safety implications'and significance will be assessed after S&L has completed their-review of the 41 new change documents and addresses the IPQA concerns-regarding the completeness / adequacy of the committed review of the 30,000 change documents.
It is anticipated that approximately two (2) months will be required'to complete the above action and to file a' final report on this issue.
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