ML20093M412

Forwards Rev 2 to Record Verification Program Plan, Updating Implementing Procedure Revs Which Incorporate Changes to Increase Clarity & Provide Streamlining of Overall Program.List of Changes Encl

ML20093M412
Person / Time
Site:	Clinton
Issue date:	09/26/1984
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093M413	List: ML20093M412 ML20093M442
References
U-10189, NUDOCS 8410220114
Download: ML20093M412 (5)

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ILLINDIS POWER COMPANY U-10189 CLINTON POf!R STATION. P.O. BOX 678. CLINTON, ILLINOIS 61727 September 26, 1984 paltiCIPAL DO .oh

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Docket No. 50-461 h fjy .

j Mr. James G. Keppler Regional Administrator kggg RL I ' 'd/

Region III U. S. Nuclear Regulatory Commission QC 3pA kFI 799 Roosevelt Road Glen,Ellyn,.IL 60137 Subj ect: Illinois Power Company Clinton Pover Station Record Verification Program Plan, Rev. 1

Dear Mr. Keppler:

%. Illinois Power (IP) has performed an evaluation of Revision 1 of the Records Verification Program Plan. As a result, changes have been made to provide a general update of implementing procedure revisions which incorporates changes that increase clarity and provide streamlining of the overall program.

The major areas of change are as follows:

1. Section 2.1 of the subject plan identified the scope of the program as .... "All (100 percent) safety-related, fire protection, ano aupented Class D system QA records...". Revision 2 defines the scope as the following record types for safety-related, fire protection and augmented Class D systens or structures:

Baldwin Associates' (BA) construction / fabrication /

installation work documentation packages.

Site generated or maintained purchase order documentation packages, including associated receiving inspection and vendor data packages.

2. Revision 1 of the plan, paragraph 2.4.2, required completion of all reviews and resolution of all record deficiencies prior to hardware turnover. Revision 2 allows the management option of completing reviews and recolution of deficiencies subsequent to hardware turnover. These reviews and resolutions will be adequately tracked through completion.

8410220114 840926 PDR ADOCK 05000461 A PDR 00T 11994 f,eol i(

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• ? 23. :According-'to Revision _.1,' paragraph 2.'4.14, records

,- - reviewed by BA' &..IP .are _ returned to the BA vault. -As a practical matter,'it~is more efficient-to transmit f frecords directly from BA' Document Review Group (DRG) to h -IP. . Therefore, this option is allowed by Revision 2.

Section 4'.0'of the subject plan described the basic-

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content of a series of BA Quality Assurance procedures

,and instructions,1 (BQAs and BQAls),:which.were needed-

. inforder to-implement the plan. These have since been incorporated-into Baldwin' Associates' Procedures

' ( BAPs ) . - ' Revision was accomplished to show the current

. status.of implementing procedures and instructions.

5. ~Section 6;0 discussed resourceJrequirements-wh ch are

. considerably out of date. This section was revised to reflect? current status.

In ' addition to these five major categories, a number .of.

min'r-revisions o were made~for. clarity _and accuracy.

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i The revisions discussed above are-listed on Exhibit A and correlated to the numbered' paragraphs of Revision 1 of the plan.

..In addition, a- copy of' Revision .2 of the Records Verification Plan has been attached.

. -; . Illinois- Power -feels 'that the' revised plan adequate 1y -

clarifies and. describes the program as presently implemented.

. Should.you have.any comments, please contact me.

Sincerely yours, y

D. P. Hall Vice President GLB/cah (NRC2)

. Attachments ces' ' NRC Resident Inspector-

- Director, Office of I&E, US1;RC, Washington, DC 20555 i - Illinois Department of Nuclear Safety' p

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/ . Exhibit A

, . 5- >- Page 1 of 3' LIST OF' CHANGES'

'E RECORD VERIFICATION PROGRAM PLAN Revision 2-L-

1The following is.a sunmary of' changes incorporated in Revision 2

of=the: Record Verification Program-Plan.

Revision-l' Revision 2 Page~ Paragraph Change-1 2: .1 Revised scope statement.

1. 2.2 Deleted' references to phases (paragraph deleted).

Made appropriate paragraph number 1-4 2.3:- 2.5.5 changes resulting from the deletion of

. paragraphs 2.2 and 2.4.1.

'l 2.4.1 Deleted reference to phases (paragraph deleted)..

ol- 2.4.2 Revised to allow completion of reviews and-resolutions subsequent to hardware turnover.if necessary.

2- 2. 4. 3' Deleted unnecessary detail.

~2 .2.4.4 Clarified trending program.

i; .2 2.4.7-  : Revised wording for accuracy.

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2 2.4.9 Clarified that field traceability checks may be done under a separate plan..

2 2.4.10 Inserted the word " personnel" for "QAEs", since field checks may be done by other than QAEs.

3 2.4.11 Replaced the words " final acceptance" with "re-review" . This more accurately describes the DRG function in the

- context of the paragraph.

-3 2.4.14 Added the option of transferring records directly from the DRG to IP.

4 3 2.5.3 Added a sentence to clarify the scope of the IP records surveillance.

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'i Exhibit- A 3 '

Page 2 of 3

-.- LIST OF CHANGES Revision 1- ' Revision 2

.Page- Paragraph Change-3 2.5.4. Deleted unnecessary detail.

4- ;3.4 Modified procedure reference to read

" applicable procedures" .

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3.6 Added " procedures" to the list of requirements documents from which checklists are derived.

5 3.8 Deleted unnecessary detail.

.5 4.0.&-4.1 Revised to show that former BA QA procedures and instructions used to implement the program have been.

incorporated in BA Project Procedures (BAPs).

4.1.1-L5 - 12 Deleted descriptions of former implementing procedures / instructions.

Retained the description of the QA/DRG training program.

Noted that the former training procedure ~BQA-184 had been incorporated into the BA QA Training Manual. Made changes in written training requirements commensurate with present BA QA Training Manual.

12 4.1.2 Removed unnecessary detail.

'15 4.1.4 - a,b,c Changed training reference.from BQA-184 to the BAQA Training Manual.

'17 4.1.5 Minor wording change for clarity.

Corrected section referenced from "7.0" to "6.0".

17 4.1.6 Reworded for clarity and to remove unnecessary detail.

17 4.2.1.1 Reworded for clarity and accuracy.

Deleted the necessity to implement surveillance prior to transfer to IP.

17 .4.2.1.2 Reworded for clarity and accuracy.

Deleted unnecessary detail.

17 14.2.1.4, Corrected paragraph number to 4.2.1.3 4.2.1.5 and 4.2.1.4.

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Exhibit A

Page 3 of 3' 2.- ..

.a - - LIST OF CHANGES

Revisionc1' Revision 2

~ !Page Paragraph Change 18 14.2.1.6, . Corrected paragraph number to 4.2.1.5, 4.2.1;7, .4.2.1.6 and 4.2.1.7 respectively.-

4.2.1.8 LAlso revised wording which indicated that the IP record curveillance group will be performing trend analysis.

This is being done by another IP QA group.

18 14'.2.1.9 . Corrected . paragraph number to 4. 2.1.8.

Also revised wording for clarity.of intent with regard to stamping records reviewed. ,

18' 4.2.1.10 Deleted this paragraph as unnecessary detail. Details of the review com)1etion and turnover'will be ela') orated on in implementing procedures.

18 '4.2.2 . Deleted reference to typec of

<. . checklists since 'it is redundant with

- previous statements that IP review would use the same criteria as-BA.

19 4.2.3.2, Wording.was brought into line with 4.2.3.3  : actual words in IPQA Training, Qualification and' Certification Manual.

20' 4.2.) a Deleted trend ant. lysis program from Records Coordinator Responsibility.

This is the responsibility of another IP QA. group.-

21- :4.2.5 - b Minor wording change for accuracy.

- 21 ' 4.2.5 - d Clarified duties of Records Engineer.

22 6.0 Revised the discussion of resource requirements to reflect current reality.

'22 4 23 6.1 Deleted

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l 23 6.2 utteted 23 .7. 0 Deleted Attachments 4 and 5.

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