U-600260, Interim Potentially Reportable Deficiency Rept 55-85-09 Re Inadequate Implementation of Design Document Review Process. Initially Reported on 850816.Investigation Plan to Determine as-built Condition of Hardware Implemented

Interim Potentially Reportable Deficiency Rept 55-85-09 Re Inadequate Implementation of Design Document Review Process. Initially Reported on 850816.Investigation Plan to Determine as-built Condition of Hardware Implemented

ML20133E275
Person / Time
Site:	Clinton
Issue date:	09/30/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-85-09, 55-85-9, U-600260, NUDOCS 8510090331
Download: ML20133E275 (4)

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U-600260 1A.120 Ll4-85(09-30)-L ILLIN0/S POWER COMPANY CLINTON POWER STATION. P 0. Box 678. CLINTON. ILLINOIS 61727 September 30, 1985 Docket No. 50-461 Mr. James G. Keppler Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellen, Illinois 60137 t

Subject:

Potentially Reportable 10CFR50.55(e) Deficiency 55-85-09: Inadequate Implementation of the Design Document Review Process

Dear Mr. Keppler:

On August 16, 1985, Illinois Power Company notified Mr.

J. McCormick-Barrer, NRC Region III (Ref: IP Record of Coordination Y-3d439 dated August 16, 1985) of a potentially reportable deficiency under the provisions of 10CFR50.55(e) concerning Baldwin Associates' Resident Engineering (BARE)

Civil / Structural Department's inadequate review of design change documents to identify changes, and to assure that travelers and procedures were revised as required by Baldwin Associates' (BA) Procedure BAP 2.41, Design Document Review.

Our investigation of this issue is continuing and this letter represents an interin report in accordance with the requirements of 10CFR50.55(e) (3). 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 this issue.

Sin erel yours, 0510090331 050930 gDR ADOCK0500g1 'D . . Hall Vice President RLC/kaf Attachment cc: B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Director, Office of I&E USNRC, Washington, DC 20555 1 Illinois Department of Nuclear Safety # t INPO Records Center i OCff 2t985 MA3 _.

j . .

ATTACEMENT A i Illinois Power Company ,

i Clinton Power Station i i Docket No. 50-461

)' Potential 10CFR50.55(e) Deficiency 55-85-09:

Inadequate Implementation of the Design Document

Review Process

Interim Report i

j Statement of Potentially Reportable Deficiency / Background A condition potentially adverse to quality was I

identified concerning BARE Civil / Structural Department's i inadequate review of design change documents to identify

changes, and to assure that travelers and procedures were j revised as required by BA Procedure BAP 2.41, Design J Document Review. As a result, the accomplishment of I

required design changes / modifications, by BA 1 Civil / Structural Department, is indeterminate.

1 Illinois Power s Overinspection (IPOI) identified and

documented on Nonconformance Reports (NCRs) specific

instances of unincorporated design changes / modifications 1 into structural steel installations. The identified deficiencies are documented on the following NCRs

3 52505* 52348 52181 52092 52227* 52616 ,

52428 52315 52159 52019 52418 52618

, 52405 52199 52135 52246 52473 52824 ,

j 52369 52198 52096 52283 52529 52860 i

-52406

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• NCRs 52505 and 52227 have been superseded by NCRs 52616 j and 52406, respectively.

Investigation Results/ Corrective Action i

! Illinois Power (IP) has prepared and is im)lementing an [

investigation plan to determine the extent of t' tis defici- ,

l, ency at the Clinton Power Station (CPS). The investigation plan includes:

I. Determination of As-Built Condition of Hardware I The 25 NCRs identified above document the as-i built condition of the structural beams turned '

over to IPOI for inspection.

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

l l II. Determination of Effects on Other Activities A review and evaluation was performed to determine the effect of the inadequate implementa-  !

tion of the design document review process j on other activities. All BA Resident Engineering

disciplines, except the Civil / Structural

Department, were found to be conducting their document review process properly. As a result, only civil / structural work is affected by this deficiency.

1 i Another condition has been identified concerning

} design changes to non-safety and non-seismic HVAC

systems. These changes were accomplished by the Zack Company based on Zack Procedure FCP-23, Field Installation Problems. Initial investigation into this matter has identified major modifications that were performed utilizing the Field Interference Notice which is designated for minor modifications only. Illinois Power will j further investigate and evaluate this matter for possible safety-significance.

III. Define Scope of Condition Identified by NCRs In order to define the scope of the condition identified by the NCRs, Baldwin Associates l Resident Engineering (BARE) will perform the i following review:

4 A. For beams already inspected by IPOI, BARE will determine the drawing revision in effect

! at the time of IP inspection and will review all Engineering Change Notices (ECNs) and

). Field Engineering Change Notices (FECNs) issued against the identified revision, in addition to all subsequent revisions, to ensure that no further design changes were made to the beams since their inspection.

! NOTE: NCRs and Field Change Requests (FCRs) will be excluded from this i review since it has been confirmed j that these documents are properly a tracked for completion in a i separate system.

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B. Baldwin Associates' Civil / Structural Department has now fully implemented the requirements of procedure BAP 2.41, Design Document Review. Design changes will be reviewed in accordance with the above procedure for structural installations remaining to be inspected by IPOI.

C. For beams not identified for IPOI inspection, BARE will physically review each beam against the current design to ensure all changes have been implemented.

D. Additionally, BA will review the remaining scope of Civil / Structural work controlled by their design document review process to assure all design changes have been incorporated for implementation into plant construction.

Root Cause Illinois Power has reviewed and evaluated the findings associated with this issue and has determined that the root cause of the identified deficiency was improper implementa-tion, by BA's Resident Engineering Civil / Structural Department, of the procedural requirements which establishes a documented program for design document review to identify changes, and to assure that travelers and procedures are revised where required.

Safety Implications / Significance Illinois Power's investigation of this potentially reportable deficiency is continuing. The safety implica-tions and significance will be assessed by S&L after further background information has been evaluated. It is antici-pated that approximately sixty (60) days will be required to complete our investigation, determine reportability and to

file a final report on the issue.

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