U-600202, Final Potentially Reportable Deficiency Rept 55-84-01 Re Control of Field Design Changes.Initially Reported on 840111.Investigation Identified No Hardware Deficiencies. Issues Not Reportable Per 10CFR50.55(e)

Final Potentially Reportable Deficiency Rept 55-84-01 Re Control of Field Design Changes.Initially Reported on 840111.Investigation Identified No Hardware Deficiencies. Issues Not Reportable Per 10CFR50.55(e)

ML20133D720
Person / Time
Site:	Clinton
Issue date:	07/23/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-84-01, 55-84-1, U-600202, NUDOCS 8508070429
Download: ML20133D720 (6)

Text

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. U-600202 L14-85(07-23)-L 1A.120

/LLIN0/8 POWER COMPANY CLINTON POWER STATION, P.O. BOX 678. CLINTON, ILLINOIS 61727 Docket No. 50-461 July 23, 1985 Mr. James-G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Potentially Reportable 10CFR50.55(e) Deficiency 55-84-01: Design Change Control

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 five (5) interim reports (ref: IP letter U-10126, D.

P. Hall to J. G. Keppler dated February 21, 1984; IP Letter U-10160, D. P. Hall to'J. G. Keppler dated June 13, 1984; IP letter U-10202, D. P. Hall to J. G. Keppler dated December 24, 1984; IP letter U-10230, D. P. Hall to J. G. Keppler dated

. December 18, 1984; and IP letter U-10257, D. P. Hall to J. G.

Keppler, dated March 21, 1985). .

Illinois Power's investigation of this matter is complete and has determined that the issue does not represent a reportable deficiency under the provision of 10CFR50.55(e). There were no hardware deficiencies identified as a result of our investigation which could have adversely affected the safety of operations at CPS. Attachment A provides the details of our ,

investigation.

, We trust that this final report provides you sufficient background information to perform a general assessment of this potentially reportable deficiency and adequately describes cur overall approach to resolve the issue.

Sincerely yours,

. . Hall Vice President RLC/lr (NRC2)

. Attachment cc: NRC Resident Office Director - Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center 8508070429 850723 JUL 25 265 PDR ADOCK 05000461 S PDR _ _________

e ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 Potentially Reportable 10CFR50.55(e) Deficiency 55-84-01: Design Change Control Final Report Statement of Potentially Reportable Deficiency Potential problems were identified with Illinois Power Company, Sargent & Lundy (CPS Architect / Engineer), and Baldwin Associates (CPS Constructor) in the coordination and control of documents affecting design. 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.

Background / Investigation Results A. Illinola Power issued two audit findings to Sargent & Lundy:

I. AUDIT FINDING NUMBER: Q35-83-5, AF-PD-1, dated September 9, 1983, pertains to the incorporation of FCRs into design documents and complete tracking of the information to preclude the possibility of use of outdated or inappropriate documents. s (S&L) QA Program requires that design changes Sargent be & Lundy'd controlle under a program equivalent to that controlling the original design and that participating organizations be made aware of the changes and have procedures for control of these documents. FCRs were identified which were not incorporated into or posted against all referenced drawings to allow verification of status within the Contractor's document control system. As a result, S&L was directed to reevaluate all FCRs and NCRs to determine if the directly affected documents were correctly identified. No hardware deficiencies or safety concerns were identified as a result of this review. The corrective action for this audit finding has been satisfactorily completed and the finding closed May 24, 1985.

Sargent & Lundy issued Project Instruction, PI-CP-059, FCR/NCR Validation Program, to determine the accuracy r.nd completeness of specific information, such as system designation, equipment number (i.e. valve, line, instrument and hanger number), and directly af fected documents. .S&L evaluated approximately 30,000 FCRs/NCRs issued prior to December 1, 1983, to validate and assure that dire,ctly affected design documents associated with each FCR/NCR were Page 1 of 5 e

ATTACHMENT A (continusd) properly identified where required. [FCRs which were voided, superseded, or rejected and NCRs classified as either rejected, superseded, rework or not applicable to S&L design activities were part of this total, although not validated.]

Subsequent to December 1, 1983, the procedures in effect required that the directly affected documents be listed on the FCR/NCR, indicating incorporation or nonincorporation status.

The validation program resulted in approximately 45% of the total NCRs/FCRs reviewed having newly identified affected design documents. This 45% was categorized in the following three areas:

1. Directly affected documents requiring incorporation of a change into the design documents,

2. directly affected documents not requiring incorporations however, requiring entry into the data base for traceability: and

3. dire, affected documents which were not identified on the. AR/FCRs however, where the change was actually incorporated into the affected design document.

The affected design documents requiring incorporation of a change would have been identified in the S&L design review process. The change requests and the newly identified design documents have now been entered into the IPC computer data systems, i.e., the CPS Construction Management Information (CMI) and Data Management System (DMS) computer data bases for document tracking and incorporation status.

The CMI data base is being utilized to maintain up-to-date information on the latest revision and incorporation status of each FCR/NCR for document control interfacing between Sargent & Lundy, Baldwin Associates (BA) and IPC. A similar CPS computer data base (DMS), which is maintained by Baldwin Associates to verify installation conformance to the latest revision of documents affecting design, has also been updated with the latest information. This DMS data base is now available to all site controlled drawing stations for use by construction, engineering, operations, and quality personnel.

II. AUDIT FINDING NUMBER Q35-83-5, AF-PD-2, dated September 20, 1983, pertains to site revisions to FCRs and tracking the incorporation of revisions into the affected documents.

Sargent & Lundy's QA program requires that approved changes be incorporated into affected documents through controls consistent with the original issue. Approved design changes are required to be traceable as well as implemented by all organizations involved. A number of FCRs were revised and S&L incorporated the revision into drawings without noting the FCR revision number. As a result, BA could not clearly determine from the design document if the revision to the Page 2 of 5 .

ATTACHMENT A (continued) design change was incorporated in the design document.

Review of the incorporation status of change documents was covered by the above validation program. This information has been entered in the IPC computer data bases and is available for verification of change document incorporation.

Baldwin Associates' procedures BAP 1.0, Nonconformances and BAP 1.2, Field Change Requests were changed in August 1983 to delete provisions to revise field change documents.

There were no hardware deficiencies or safety concerns identified as a result of this review. The corrective action for this audit finding has been satisfactorily con'pleted and the finding closed May 24, 1985.

Revision numbers of FCRs were not consistently indicated in the drawing change block. The issue of not identifying revision numbers of FCRs on affected design drawings could lead to errors in the processing of FCRs. An FCR could be closed inadvertently, if thought to be incorporated into the drawing. The drawing review process by BA Resident Engineering was incomplete, in that the S&L drawing change block indicated incorporation although the revised FCR was not incorporated. The details of the revision to the drawing may not be reviewed by BA for FCR design changes and the drawing released for construction without including the required FCR revision. If the drawing was not reissued at a later date to include the FCR revision, there could be a difference between the hardware and required design.

B. Illinois Power issued an audit finding to Baldwin Associates:

AUDIT FINDING NUMBER Q31-82-3-2, dated June 3, 1982, identified S&L issued revisions to approximately 200 FCRs for which the revised disposition had not been implemented.

This finding was later supplemented with the need to address approximately 220 S&L issued revisions to NCRs. BA has reviewed all S&L letters covering approximately 1,560 documents, issued from July 1982 to September 1983, pertaining to requests for revisions to FCRs/NCRs.

Aaproximately 260 of these documents required verification ttat the documentation or field installation conforms to the latest plant design. Forty-one hardware related items were reviewed, however there were no hardware deficiencies of safety significance identified. IPC QA review and closure of Audit Finding Q31-82-3-2 was completed on September 24, 1984.

As a result of the Audit Finding Q31-82-3-2, it was agreed that FCRs/NCRs would not be revised in the future and BAP 1.0 and 1.2 were changed in August 1983 to reflect this.

Subsequently, on October 18, 1983, S&L revised their Project Instruction, P1-CP-003, Processing A Baldwin Associates FCR/NCR, to specify that a Field Engineering Change Notice (FECN) be issued to make cha.ges to an FCR/NCR. Requests to supersede FCR/NOR documents were reviewed for necessary action in accordance with this procedure.

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ATTACHMENT A (continued)

As part of the subject investigation, IPQA evaluated the processing of other site documents which interface with the S&L Site Liaison Engineer. Of the documents reviewed, only the procedural controls for Illinois Power Nonconforming Material Report (NCMRs) could result in a situation similar to FCRs and NCRs. No requests to revise an NCMR were identified. In order to prevent revisions to NCMRs from becoming a future problem, NSED procedure D. O., Processing Nonconforming Material Reports for CPS has been revised and S&L Proj ect Instruction PI-CP-046, Processing an IP Nonconforming Material Report was revised and issued October 10, 1984.

C. Illinois Power issued two surveillance findings to Sargent &

Lundy and IP-NSED:

Subsequent to closing Audit Finding Q31-82-3 above, two additional IPQA Surveillance Findings C-85-121 and C-85-122 identified several FCRs, which showed technical changes by S&L and NSED after the initial approval and issue. The same numbered FCRs were reissued with a revised approval date.

Revising change documents was disallowed by BA procedures BAP 1.0 and 1.2 as of August 1983 and by S&L PI-CP-003 as of October 1983.

More than twenty thousand FCRs, starting with FCR 18000 issued May 23, 1983, were reviewed for clerical and technical changes. FCR-18000 was verified as a starting point in that the first group of technical changes were noted with the 19000 series of FCRs issued as of August 31, 1983. Approximately six hundred FCRs had changes made with revised approval dates, two hundred of which were potentially technical changes. Baldwin Associates investigated the hardware affected by these FCRs and found all installations in agreement with the reissued FCRs.

Furthermore, field quality inspections were performed to the reissued FCRs. S&L did not receive for final review and approval fifty-seven of the two hundred FCRs. However, uaon receipt, S&L's evaluation of these 57 changes concluded that there were no conditions of safety significance if the changes were not implemented.

To prevent this situation from S&L issued Procedural Deviation PD-77 dated recurring,which 5/30/85, changed PI-CP-003 to prohibit S&L from making any change to an FCR once it has been approved by NSED. NSED revised Procedure D.8 - Handling CPS FCRs to assure that no technical changes are made to an FCR after NSED approval. Training of personnel was conducted to explain the procedures.

IPC QA review and closure of Surveillance Finding C-85-122 was completed July 3, 1985. Surveillance Finding C-85-121 was completed July 15, 1985.

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- ATTACHMENT A

! . (continued)

_C_crrective Action / Root Cause The scope and root cause for both audit findings against S&L have been determined to be procedural and corrected by validating applicable FCR/NCR documents issued before December 1, 1983.

FCRs/NCRs will have the affected documents listed in the IPC computer data bases, including the incorporation status of the document. Procedures have been revised to require that directly affected documents be listed on the FCR/NCR.

The root cause associated with the audit finding against BA was determined to be a difference in provisions between procedures issued by BA and S&L. The procedures have been corrected and revisions to FCR/NCR documents are no loncer allowed. New FCR/NCR documents were issued to ensure completion of any required outstanding actions.

The root cause for the surveillance findings against S&L and IP-NSED was determined to be a lack of specific detail within the site procedures for review of FCRs. Procedures have been corrected to assure no technical changes are made to an FCR after NSED approval.

Safety Implications / Significance Our investigation of this issue is complete. Illinois Power has reviewed and evaluated the findings associated with this investigation and has determined that the procedural problems l identified with design change control at CPS did not result in a deficiency to a structure, system or component which were it to have remained uncorrected could have affected adversely the j safety of operations of CPS. On this basis the issue is considered not reportable under the provisions of 10CFR50.55(e).

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