ML20106A590

Forwards Suggested Review Items Re General Design Control Submitted w/840531 Ltr Proposing Independent Design Review. Description of Origin of Document Provided

ML20106A590
Person / Time
Site:	Clinton
Issue date:	09/28/1984
From:	Hall D ILLINOIS POWER CO.
To:	Milhoan J NRC
References
U-0741, U-741, NUDOCS 8410050227
Download: ML20106A590 (7)

Text

N,t,; '~ U-0741 L40-E4(09-28)-L 8G.150a

-lLLIN0lO POWER COMPANY CLINTON POWER STATICN, P.O. BOX 678. CLINTON. ILLINotS Ell" w

September 28, 1984 Docket No. 50-461 Mr. James L. Milhoan U.'S. Nuclear Regulatory Commission East West / South Towers Building Room 303-Mail Stop EW/S 305B 4340 East West Highway Bethesda, Maryland 20014

Dear Mr. Milhoan:

By our letter of May 31, 1984 to the NRC proposing an Independent Design Review (IDR), a document identified on page 7 under Item D., (General Design Control), was labeled the Stone and Webster study. Per your recent telephone conversation with J. D. Geier, you requested a copy of this document and any related fi ndings . For your review, a copy of the document is included as attachment 1. The purpose of this letter is to describe the origin of this document by providing the following information:

1. In response to a request from Illinois Power Company (IPC) in late 1983, a Stone and Webster manager, in conjunction with IP, developed a list identifying twenty (20) generic industry problems related to design control.

This list became locally known, inaccurately, as the

" Stone and Webster study". This term was used in the IDR letter to describe the list.

2. In a memorandum dated December 6, 1983, D. P. Hall (directed the Nuclear Station Engineering Department (NSED) to prepare a point paper on each of the twenty (20) topics. A copy of this memorandum is included as attachment 2. The intent of this effort was to have cognizant working level engineers conduct " desk top" engineering reviews to assess the applicability of these twenty (20) items to Clinton. The information obtained was intended for use locally to achieve a meaningful appraisal of some of the problems facing the NSED engineers.

, b r m

~ 1$($ 54bW 3> \

J

k.' ,.

.~

Mr. J. Milhoan . September 28, 1984 t

3._ This_ effort of preparing point papers will be complete in November, 1984. Each of the twenty (20) topics will be reviewed by IP management and will be made available J to Bechtel as part of the IDR should.Bechtel so desire.

They can also be made available to the NRC.

Sincerely yours, D. . Hall Vice President DPH/HRV/j sm Attachments cc: See Attached Distribution List i

I

2 ,,, ,_

• \

I 'I ' .

{

• g Attachment 1 E4-942 e

, l I

) . . 1 1

EL1,1H015 POM, CLINTON STATION. SUCCESTED REVIEW ITEMS

} -1. System to Control Design Information There must be some form of document control syntaa to ensure that information providad by Engineering to Construction le current and has . bean approved to the degree required, and is supported by current analysis, etc.

There should also be documented evidence that the design end .all changes have been reviewed for compliance with all licensing commitmaats.

l

2. Synten to ensure that all design changes are_,accymplished and documented.

There is & need to meure that any changes' made by construction forces in advance of ' engineering spproval era . entered t into

• the engineerint syste;a.

,L Similarly, changes made to ansionerina documents durias the construction phase smet be varified as having baan accomplished.

i 3. Effect of Construction Changes on hurchased Equipment . . . . .

There shonid be a system in effect to evaluate the effect of Construction changes in relation ta the following itema for purchased equipments i a.- Coda Couplianca ..

n. gatenic Qualification -

t. Environaantal Qualification * *

4. Imad Tracking *

(t.

I Each discipline must be able to demonstrate that design criteria has haan l maintained up-to-date and that changes made by other disciplines or in construction are included in the final analysis. .

Examples of areas where* 'this is needed are .

) ,

• Changes to power distribution system when motors are,Addad or~ motor

.. sites

., -are . substantially increased (This also affects s~ontrol siting).

• inada o'n'atructuras *

• dua,to concentration

• of equipment or pipe supports.

2 Tank storaga capseity due to system parameter changes.

5. Thtre abould be a written Environnant*1- Qualificatise program to ensure 1

coop 11ance with IEEE 323/36..

I It shonid demonstrata how the status of myatems/ equipment is to be described

• i l

1 and made known during purchase, installation, and testing. That is, l complete er partial qualification to harsh or mild environnantal i requivelmente should be apparent free the documentation, and tasks remaining I l to e,omplete the qualification should be identified work items.

k1here is a definite need in this area to identify additional work that  !

results when it is learned that the manufacturer failed to qualify the exact assembly that was delivered.) .

(' 6. There should beIsyeram to evaluate problems or concerne identified by NRC 15 Bulletina and Information Mettees and 50ER'a or SER's from IMPO.

l l

.~,e .%..,-.,...,.-,.-w.-. ,,,<-ee,.,,-,--.,,m.,,vy.--,w,---,,,-,wy,,---,mv.., -,,-,,m-,.,my-,mw, m-w .- w .--_ ,c.-,-.

_,,,;_,-.- - ~

.) .s 6

_ ( .. , ,

f

) *

' EA-942 Faga 2 of 3 3 7.

There a~nould be a systsu to eva'luate the engineering or licensing (55(e), L

(} part 21) costseguences of identified problems.

. . .. u

3. The documentation of the procureaant system should include

a. Provison for,ansuring tha,t, venders are qualified.

h. Trainsmission of needed re.,..quirements to vendors and sub-vanders.

Provision for procurement od~ catalog iteam.

.. c.

8' e .. . . IF*VA'.i'".for progreaant of apare parts and,,raplace,mant, pahr,s u ,, ,

T.

There shbuld:b6 a system 'to 'e'nsure 't'h'at electrical seharati5n crit' aria are consistaat and ' acceptable from plant licensing (SAR) throuah design and installation..

. .. . . . . . . .. .i.,,.. - .-

10.

There should versus be a system to obtain and evaluate as-installed cable lansth design length.

. . . . . . . .s . ..

i 11.

Commitment to include TNI changes. -

i , . .

,=

Required changes to structures, control systems, security systems, computer read-outs, shovid be factored into axistion designs as anoothly as possibia.

12.

There should be a written program doecribing the reconciliation of as-installed piping systems with the design and analysis. This prograa

( abould verify the correctness of the system parameters used in the piping analysis, the lead tambinationa used in the piping analysis, the agreement i of the work sketch "in the piping analysts with the as-constructed condition, verification that materiale used comply with the design, the correctness of

_masumed loads such as valve weights er other in-line connonene_ weichts, sunabIIity auf tability of of pips supparssfremtrhinta, nocrie loads pipe rUptura or pipa, whip effects,

analysist.and"tertification-to code fequirements. ' ~~. ,"to ..

vendor c.r .

2

13. . .

.r .

There should be a program which will demonstrata suitable documentation and qualification of all computar software used ge . safety related analysis.

l This shouldin developed include house./ purchased or astvics bureau p' rograms' as well se those This proaram should be capable of demonstrating qualification of evety veraien/ level of each progcas that has been used, and of identifying computer input and output to the qualified version and level.

16. .

i The Radiationfactorst the following Protection calculations should hava a system to account for

a. .

The soorce tore data fram the NSSS.is usually preliminary. The

• I system should ensure that this data is used as conservatively as l prictical, as possible.

and that the verified data is obtained and used as soon D.

f . There should be centro 11ed access drautogs prepared and maintained

( *, to show radiation levels axpected in leanned spaces and in access .

paths to and from spaces that may be occupied.

l 1

(' SEP Ei M

(

.. u ..... .. -

( ~

4a-942 P:ss } cf 3

15. There should be e elaar definition of responsibility for as-built condition of rH8SS systema er portions of system. This 'should specifically identify flow diagram /BAR figure informatian as well as fabrication 150's and control draviass. -

16. There should ha a system to resolve differences ,bstween vendor wiring disgrams and conditicas noted during io,ssallation or teating. , . .

17. There should be a system to ensure that supplier operating and maintenance

- sanuala..are provided as . required, and ,that they are available at the installation, maintenance, testing, and operational phases.

14. There should be in-plant reviews er system walk-downs to. verify, .that adequate clearanca exists to prevent interference betweap piping (especially hot pipiss) and other composeats or structurgs. This should,also verify the adequacy of the desias and other measuras taken to ensure that the failure af nos-safety related systema or equipment will not endangar dataty-related systems er equiposat. , ,

. 19. There should be a system to ensure that all needed documentation for ASHE III systems is available and in a satisf acto,ry condition. This should .

include a review of Design specs for completanass and code compliance, a review of Stress Reporte, and a system to.obtain and review information for data reports. . .

20. General Industry issues: .

i

a. Waterhammer C. ) b. 8eismic Design. criteria - -

.t- -

_ , _ cs Station blackout . '

d. Control systers safety issplications (automatic and manual j .. .

shutdown initi,ation wili occur as designed).

j .

• g 0 . . . gg j -

f ,

i

.* " - r y : t .:-- - . -- . . . , . , . . . . , . , , . ,

,p j -

3 . * *

- . . . - *- . e . ... .

l , . . .

I,

. .....e e e, e . p I -

I

- 1 i

4 i

l .. . . . . . . . . . . . . . . . .

s

, ,e . .. ..

l

.i i a .

I i

i SEP 21 Mg4 .

. . . .. ;. . . . . . tj f

'e ." 8 N'

(

'/ f Attachment 2 ,

~

- { -

17 . December 6, 1983

%.)

J. D. Geier, F-33' Potenti*al Engineering Actlpn Items on several occasions we have discussed some of the long range engineering efforts which remain to be completed. Much .

good work has been done to schedule the remaining effort in a 6

timely manner. The attachment contains several (20) engineer-ing tasks which have been noted at other nuclear construction

, sites as troublesome.

I request the following action:

! , a. Assign.each item.to the cognizant work,ing -

level engineer with the task of preparing -

a point paper describing where the issue

. stands.

b. The responsibility should be in NSP.D*because one of the design control system guiding

}

1

" * (r - ). '

parameters le to set up a formal acceptance

.of items from other design / engineering agents.

. Bring the papers to a meeting; suggested c.

aE~tandants would be J. spencer, B. Xant, J. Geier #nd myself. .

,/ -

- It is important to gath'ertre. Working level opinion without adjustment to echieve a meaningful appraisal'of the ,

Problems some of our engineers may be facing. '

7- .

) Hal DPH/ psf f attachmen t

! . l cc J. Spencer, V-920

, E. Mant, F-33

• i .

R. Wyatt, V-275 R. Wight, T-31 -

l T. Plunkett. T-31

• R. Schaller. f-31 '

'( 17 ,

l SEP 2% IW

.i j ..._. .. . .

i' )

\

I,

.j Clinton Pcwer Station Independent Design Review .

Standard Distribution List ,:

1 1

Director of Nuclear Reactor Regulation Atta: Mr. A. Schwencer, Chief Richard J. Goddard, Esq.

Office of the Legal Director j;;.

Licensing Branch No. 2 U. S. Nuclear Regulatory Comission  :

Division of Licensing Washington, D.C. 20555 fl U. S. Nuclear Regulatory Commission 4; Washington, D.C. 20555 Don Ecchison Director, Illinois Department of James G. Keppler Nuclear Safety Regional Administrator 1035 Outer Park Drive  !

Region III Springfield, Illinois 62704 [

U. S. Nuclear Regulatory Commission 799 Roosevelt Road , Allen Samelson, Esq.

Clan Ellyn Illinois 60137 Assistant Attorney General <

l Environmental Control Division Byron'Siegel? .

Southern Region ,

Clinton Licensing Project Manager 500 South Second Screet -

Mail Code 416 Springfield, Illinois 62706 U. S. Nuclear Regulatory Co= mission Washington, D.C. 20555 Jean Foy Spokesperson, Prairie Alliance Fred Christianson 511 W. Nevada r

Mail Code V-690 Urbana, Illinois 61801 NRC Resident Office Clinton Power Station Richard Hubbard R.R. f3, Box 228 MHB Technical Associates Clinten, Illinois 61727 1723 Hamilton Avenue Suite K James L. Milhoan San Jose, California 95125 Section Chief, Licensing Sectica Quality Assurance Branch Gordon L. Parkinson Office of Inspection and Enforcement Bechtel Power Corporation

, Hail Stop EWS - 305A Fifty Beal Street U. S. Nuclear Regulatory Cornission 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 Straat Chicago, Illinois 60603 3

U. S. Nuclear Regulatory Commission 799 Roosevelt Road j Clen C lyn, Illinois 60137 i

DES.CNATED OR.CINAL Certified By [ O

/

fd'

• 1 e .

9

- _. .e ,, _.4 ~ . -_ m - .. ,__m - . - . ._