U-600269, Final Potential Deficiency Rept 55-85-05 Re Inadequate Design Change Control by Zack Co.Initially Reported 850807. Field Const Procedure 3.0 Addressing Retroactive Design Changes Revised.Issue Not Acceptable Per 10CFR50.55(e)

Final Potential Deficiency Rept 55-85-05 Re Inadequate Design Change Control by Zack Co.Initially Reported 850807. Field Const Procedure 3.0 Addressing Retroactive Design Changes Revised.Issue Not Acceptable Per 10CFR50.55(e)

ML20137Y402
Person / Time
Site:	Clinton
Issue date:	09/26/1985
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-85-05, 55-85-5, U-600269, NUDOCS 8510080003
Download: ML20137Y402 (4)

Text

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U- 600269 Nd L14-85(09-26)-L j 1A.120 ILLINDIS POWER 00MPANY September 26, 1985 Docket No. 50-461 Mr. James G. Keppler NRC Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 61037

Subject:

Potential 10CFR50.55(e) Deficiency 55-85-05:

Inadequate Design Change Control by Zack Company

]

Dear Mr. Keppler:

On May 7, 1985, Illinois Power Company notified Mr. F.

Jablonski, NRC Region III (Ref: IP memorandum Y-32264, dated May 7, 1985) of a potentially reportable deficiency per 10CFR50.55(e) concerning inadequate design change control by Zack Company. This initial notification was followed by one (1) interim report (Ref: IP letter U-600150, D. P. Hall to J. G. Keppler dated June 10, 1985). Our investigation of this matter is complete. Illinois Power has reviewed and i evaluated the findings associated with this issue and has i determined that no hardware deficiencies were identified as a result of our investigation which could have adversely

! affected the safety of operations of the Clinton Power Station (CPS). On this basis the issue is considered to be not reportable under the provisions of 10CFR50.55(e).

Attachment A provides the details of our investigation.

'L l We trust that this final 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.

I Sincerely yours, D. . all Vice President RLC/ lab (LCF) ^

8510000003 850926 PDR ADOCK 05000461 Attachment S PDR cc: NRC Resident Office

. Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety I INPO Records Center QGT 1 .

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ATTACHMENT A Illinois Power Company Clinton Power Station Docket No. 50-461 Potential 10CFR50.55(e) Deficiency 55-85-05 Inadequate Design Change Control by Zack Company Final Report Statement of Potentially Reportable Deficiency / Background A condition potentially adverse to quality was identified in the area of design change control. This matter was based on concerns identified by Zack Company's Corrective Action Request (CAR) No. ZCS-003. The concerns involved design change documents for which the review and determination for retroactivity had not been performed.

Approximately 840 change documents were received by the Zack Company since the lifting of Stop Work Order (SWO) Nos. 14, 15, and 20. These change documents were generic in nature and could have potentially affected the adequacy of previously completed work, in that the change documents were neither reviewed nor implemented as retroactive by the Zack Company.

Investigation Results/ Corrective Action Illinois Power prepared and implemented an investigation plan to determine the extent of this deficiency at CPS. The investigation plan included:

1. A committee was established to review all generic change documents identified by the Zack Company since lifting of SWO Nos. 14, 15 and 20, and identified those documents which were retroactive (Ref: IP memorandum ARS-481-85, dated May 31, 1985).

2. Sargent and Lundy (S&L) performed an independent review of the documents identified in Item No. 1 to confirm the findings.

3. Following completion of Item 2, IP, Zack and S&L jointly determined the corrective action to be taken on.those generic change documents identified to be retroactive.

i Page 1 of 3 L .

ATTACHMENT A (continued)

The review committee that was established consisted of representatives from S&L HVAC, IP HVAC and the Zack Company.

The committee reviewed all change documents that were identified by the Zack Company as typical, standard, or generic that were issued between the lifting of SWO Nos. 14, 15, and 20 (December 22, 1983); and the commencement of this investigation (May 10, 1985). This review determined which documents should have been treated as retroactive. The lifting of SWO Nos. 14, 15, and 20 was chosen as the cut-off date since all Zack work performed prior to the lifting of the SW0s was verified as meeting the design specifications and regulatory requirements as indicated by the HVAC Recovery Plan (Rev.1). An independent review of the committee's results was performed by S&L and all identified discrepancies were resolved. Resolution of the identified discrepancies is documented in IP memorandum ARS-557-85, dated June 12, 1985.

Based on the results of the review committee, the Zack Company was instructed as to which change documents were to be treated as retroactive and to determine the impact on previously constructed items. The Zack Company identified those constructed items which lacked sufficient inspection documentation to determine whether the items had been constructed to the latest design criteria. The Zack Company then inspected those items not having sufficient inspection documentation. The Zack inspection effort resulted in the '

initiation of nine (9) Nonconformance Reports (NCRs). Seven (7) of the nine (9) NCRs were dispositioned "use-as-is" and two (2) were dispositioned " rework". All rework associated with these NCRs is completed.

Determination of Effects on Other Act;%1 ties The procedures of Reactor Controls Incorporatea (PCI),

Automatic Sprinkler Company of America (ASCOA) and MCC Powers were reviewed for similar concerns involving their design change review. No similar concerns were identified.

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 further investigate and evaluate this matter for possible safety-significance, and will include this inforaation in our final report on issue 55-85-09: Inadequate Implementation of the Design Document Review Process.

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1 ATTACHMENT A  :

(continued) l Corrective Action to Preclude Recurrence Sargent & Lundy issued changes to their procedures (Procedural Deviation Nos. 83, 84, 85, 86, and 87) governing documents affecting design. The procedure changes require an effective date for each typical, standard or generic Field Change Request (FCR), NCR, Engineering Change Notice (ECN), Field Engineering Change Notice (FECN) or Nonconforming Material Report (NCMR) issued or dispositioned by S&L, and applicable to the Zack Company. The approved procedural deviations were issued May 8, 1985.

On August 30, 1985, IP's Nuclear Station Engineering

, Department (NSED) issued Advanced Procedure Changes requiring an effective date for each typical, standard or generic NCR, NCMR, FECN issued or dispositioned by NSED and applicable to the Zack Company.

The Zack Company revised Field Construction Procedure

, (FCP) 3.0, which specifically addresses retroactive design changes. Procedure FCP 3.0 now conforms with S&L and NSED procedures and was approved for use (Status 1) by S&L.

Root Cause The contract Specification K-2910, between the Zack Company and Baldwin Associates, did not specifically require the Zack Company to assess the impact of design changes upon previously constructed items, therefore, this requirement was not incorporated into the Zack Company procedures.

Safety Implications / Significance Illinois Power's investigation of this matter is complete. S&L has reviewed the final report prepared by the Zack Company addressing retroactive change documents, to

. determine the safety significance had the requirements of the change documents not been implemented. Eleven (11) of the change documents identified, had potential safety significance and required reinspection by the Zack Company.

For the remaining change documents, it was determined that either the requirements were less stringent, i.e., a relaxation of criteria from previous design, or that sufficient documentation existed to document compliance with the change documents.

The eleven (11) change documents identified as having potential safety significance were reinspected and found to be in conformance with the current design or, where a discrepancy existed, NCRs were initiated. S&L has reviewed and evaluated the deficiencies associated with these NCRs and has determined that the identified deficiencies would not l have represented a condition adverse to the safety of l operations of CPS had these deficiencies gone uncorrected.

On this basis the issue is evaluated to be not reportable l

l under provisions of 10CFR50.55(e).

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