IR 05000313/1986014
| ML20212E014 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/19/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8701050222 | |
| Download: ML20212E014 (2) | |
Text
September 30, 1986
SUBJECT:
Arkansas Nuclear One - Units 1 & 2
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Decket Nos. 50-313 and 50-368
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License Nos. DPR-51 and NPF-6 Response to Inspection Report 50-313/86-14 and 50-368/86-14 f.
Dear Mr. Gagliardo:
N The subject report has been reviewed.
Responses to the Notice of Violation and Notice of Deviation are attached.
Very truly you s,
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. Ted E s, Manager i
Nuc a ngineering and Licensing
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NOTICE OF VIOLATION During an NRC inspection conducted on April 14-18 and May 19-23, 1986, a violation of NRC requirements was identified.
The violation involved improper drawing control.
The violation and response are listed below.
Improper Drawing Control Criterion V of Appendix B to 10CFR50 and Section 5 of the approved Arkansas Power and Light Company Quality Assurance Manual - Operations requires.that
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activities affecting quality shall be prescribed by appropriate documented instructions, procedures, or drawings appropriate to the circumstances.
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Contrary to the above, review of pipe supports and hanger locations did not
assure that activities affecting quality were appropriately documented as evidenced by:
1.
Hanger GCB-1-H4 was misrepresented on hanger location drawing 7-DH-6 as DH-15 indicating a lack of information transfer.
2.
The file copy of hanger GCB-1-DH18 was not updated as required to-reflect the changes instituted in DCP-80-D-1007DD.
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This is a Severity Level IV violation.
(Supplement II.D) (50-313/8614-02)
Response The p'urpose of this inspection was to review AP&L's actions taken in res;cn'se ta IE Bulletin 79-02, Concrete Expansion Anchor Bolts in Masonry Walls, and 79-14, Seismic Stress Analysis for As-Built Safety Related Piping
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Systems.
The drawing revision efforts associated with these bulletins were
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extensive, involving several hundred drawings.
Design change modifications were required for supports as a result of deficiencies identified during piping system walkdowns.
In reviewing the drawing discrepancies identified in the violation, it appears that drawing revisions were performed out-of sequence of the actual design modifications resulting in out-of-date information transfers to a final as-built drawing.
This type of event should be pre'cluded following completion of the project underway which will
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eliminate det<ign change backlogs.
This project was described in AP&L's letter to Mr. Richard Denise, March 29, 1985 (0CANO38510), Item D.
Following identification of these discrepancies, actions were taken to correctly represent hangers GCB-1-H4 and GCB-1-DH18 on the design drawings.
As a result of the violation, a quality assurance review was performed to
' evaluate the present drawing control process.
The results of the review are presently being evaluated.
Additionally, a portion of the 1986 design
control audit will include a review of drawing procedural requirements and compliance.
Recommendations included in the audit report will be evaluated.
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Arkansas Power & Light Company (AP&L) has, subsequent to IE Bulletins 79-02 and 79-14, implemented more detailed verification requirements in the specifications for' installation, modification, inspection and documentation
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of piping systems.
Design change packages include documentation of two
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inoependent inspections of a pipe support installation and the disposition
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of any discrepancies identi fied.
This should ensure that current and future m
installations are in accordance with the applicable codes and standards as designed and documented.
i The two drawing discrepancies were documentation problems only and of minor safety significance.
This violation, therefore, constitutes a Severity Level V category as delineated in 10CFR20, Appendix C, and not a Severity Level IV.
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NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on April 14-18 and May 19-23, 1986, a deviation from written commitments was identified.
The deviation consisted of several examples of failure to provide supplemental information to the NRC as denoted in written correspondence.
The deviation with several examples and a response are listed below.
A.
Arkansas Power & Light Company (AP&L) letter (1-010-4) dated January 7, 1980, committed to send the results of additional analyses of nonconformances of inaccessible systems found to be out of established tolerances no later than April 10, 1980.
In deviation from the above, this letter was never received by Region IV.
(Unit 1 only)
B.
AP&L letter (1-020-11) dated February 12, 1980, committed to send the results of analyses of support loads for accessible piping by April 10, 1980.
In deviation from the above, this letter was never received by Region IV.
(Unit 1 only)
C.
AP&L letters (1-129-6 and 2-129-6, item 5(d)) dated December 12, 1979, committed to send the results of field verification of anchor bolts installed prior to mid-1977 by March 24, 1980.
In deviation from the above, this letter was never received by Region IV.
(Units 1 and 2)
D.
AP&L letters (1-129-79 and 2-129-79, item 5(a)) dated December 12, 1979, committed to provide the results of a field survey to identify concrete block walls utilizing concrete expansion anchors to support Seismic Category 1 systems by February 10, 1980.
In deviation from the above, this letter was never received by Region IV.
(Units 1 and 2)
Response The items identified in Inspection 50-313/86-14 and 50-368/86-14 as required to close out IE Bulletins 79-02 and 79-14 had been completed by AP&L but had not been submitted to the NRC.
At the time IE Bulletins 79-02 and 79-14
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were issued, AP&L did not have a formal method of identifying and tracking NRC commitments.
Thus, the commitments to submit additional information were not properly followed up on.
Since that time, a formal AP&L commitment tracking system has been developed and in place for several years.
This system provides for the identification and tracking of commitments made to the NRC.
This system will preclude similar events from occurring in the
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future.
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In a letter dated September 22, 1986 (0CAN098604), AP&L provided the NRC with the information required to close IE Bulletins 79-02 and 79-14.
With the submittal of this information, full compliance is achieved.