IR 05000313/1990027

Insp Repts 50-313/90-27 & 50-368/90-27 on 900813-17.No Violations Noted.Major Areas Inspected:Review of Records Program,Document Control Program & Design Changes & Mods Program

ML20059E870
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/30/1990
From:	Barnes I, Gilbert L, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059E866	List: IR 05000313/1990027 ML20059E862
References
50-313-90-27, 50-368-90-27, NUDOCS 9009100372
Download: ML20059E870 (9)

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i . ~ APPENDIX .

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i:, U.S. NUCLEAR REGULATORY COMMISSION'  !

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REGION IV

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NRC Inspection Report: 50-313 Operating Licenses: DPR-51 ,

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' Dockets: 50-313 E 50-368-

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i ' Licensee: Entergy Operations, In q'

P.O. Box 55 ~

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4 Little Rock, Arkansas 72203

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% , ' Facility ~Name: ArkansasNuclearOne(ANO), Units 1and2

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P Inspection At: .ANO, Russellville, Arkansas l

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i ' Inspection Conducted: August 13-17, 1990

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Inspectors: da p-3h Date

<to' i A W. M. McNeill, Reactor Inspector, Materials and Quality Programs Section, Division of s

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Reactor Safety .;

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/! * L. D. Gilbert, Reactor Inspector, Materials Date ,

and Quality Programs Section . Division of ';

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Reactor Safety  !

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Approved: dem I. Barnes, Chief, Materials and Quality t-so-7o Date q

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Programs Section, Division of Reactor Safety

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r Inspection Summary  ;

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Inspection Conducted August 13-17. 1990 (Report 50-313/90-27i50-368/90-27)

f ' Areas Inspected: Routine, unannounced inspection of action on previously

' identified inspection findings and review of the records program, document

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control'~ program, and design changes and modifications progra !

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90o9100372 900831

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adequately and implemented effectively.The records and document con design changes and modifications were found to have been

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=was identified regarding the handling of minor chan

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DETAILS I

' PERSONS CONTACTED l

' Entergy

• B. C. Austin, Office Services Supervisor >

K. Barrett, Engineering Records Assistant Supervisor *

.u D. N. Bauman, Configuration Management Superintendent h *J. Davis, Office Services Manager  ;

• D. A. Graham, Quality Engineering Supervisor  :

G. A. Higgs, Modifications. Engineering Supervisor i

, *R. W. Howerton, Engineering Support Manager  !

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D. C. Irving. Operations Manager Assistant i

• J. D. Jacks, Nuclear Safety & Licensing Specialist r

'G. T. Jones, Engineering General Manager P. A. Kearney, Modifications Engineering Supervisor  ;

• R. J. King, Licensing Supervisor M. Little, Control Room Supervisor D. B. Lomax, Engineering Services Superintendent R. D. McCormick, Quality _ Assurance Auditor B. J. Miller, Document Analyst D. Mims, Plant Engineering Superintendent .

B. K.' Thibodeaux, System Engineer

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R. L. Turner; Special Proje:ts Coordinator

• J.'D Vandergrift,' Unit 1 Plant Manager ,

B. E. Williams, System Engineer C. P. Zimmerman, Operations Manager '

1.2 ~ g C. C. Warren, Senior Resident inspector

• Denotes those persons that attended the exit meeting on August 17, 1990. LICENSEE ACTION ON PREVIOUSLY IDENTIFIED FINDINGS (92702)

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- (0 pen) Violation ~(363/893904): Failure to establish effective drawing controls. The inspectors reviewed the response to the violation and verified those actions completed to date which included: (a)DrawingControlpersonnel -;

have been issuing Modification Impact Reports as instructed by Changes 2 and 3 '

to Procedure 1032.11 and (b) Revision 8 to Drawing No. 200B-61-1 was issued to-identify each weld on the drawing and incorporate the as-built information from Design Chan;e Package (DCP) 89-2026. Since adequate time was not available to review the Isometric Upgrade Project, this item will. remain ope *

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o RECORDS PROGRAM (39701) l The objective of this inspection was to ascertain whether the licensee is e

! implementing a records program that is in conformance with regulatory I g requirements. Safety Analysis Report commitments, and industry guides and je

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standard ;

R h The inspectors were informed that the ANO records management program was the W responsibility of the Office Services organization as documented in Procedure 1000.017. The inspectors reviewed the records management procedure J and the implementing procedures referenced therein which are listed in the .

Attachment.to this-report. The procedures adequately defined the records r management program and responsibilities for implementing the requirements of 1 X, the program. The inspectors selected various records, which are listed in the 1 Attachment to this report, and verified that the documents were retrievable and ,

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r, met the retention requirements of Procedure 1013.009. The retention

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requirements of the procedure were consistent with the requirements specified in Amendment 7 of the ANO Units 1 and 2 Safety Analysis Reports, Amendment 130 of the ANO Unit 1 Technical Specifications (TS), Amendment 105 of the Unit 2 TS, and Revision 12 of the Quality Assurance Manual Operations. The documents retrieved had been micrnfilmed and designated for lifetime retention. The .

master microfilm for each of the documents reviewed was stored in the ANO :

archives. vault. The inspectors verified that: (a) the ANO records and archives vault were being controlled with regard to access of storage areas as ,

described in Procedure 1013.005; (b) the smoke detection and halon fire f suppression systets were activated and tested in accordance with i Procedure 1307.36 for the records computer room and Procedure 1307.39 for the ,

records and archives vault; (c) the ANO archives vault was being controlled

. with regard to temperature and humidity as specified in Procedure 1000.017; and (d) the records condition, location, availability, storage temperature and humidity were being monitored by the office services superv'sor as required in Procedure 1000.017. On the basis of the above evaluhtion, the licensee was ,

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determined to be effectively implementing the records management progra .

No violations or deviations were identified during this portion of the ->

inspectio . DOCUMENT CONTROL PROGRAM (39702) {

The objective of this part of the inspection was to ascertain whether the licensee is implementing a quality assurance program that is in conformance ;

with the TS, regulatory requirements, Safety Analysis Report commitments, and applicable industry guides and standard ,

The ANO document control program has been divided into three areas: (a) design ;

documents, (b) procedures, and (c) documents other than procedures or design document The requirements for design document control have been specified in  ;

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l Procedure 1032.011. The inspectors selected various piping and instrumentation ,

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, -S-drawings from those indicated on the M' ster Drawing Distribution List (MDDL)

for the Unit 1 control room, the Unit 2 contro1+ room, and the system .

engineering office. The inspectors verified that the aperture card or hard t-copy of the drawing selected was at the location designated on the MDDL for ;

each of the three locations. .I, list of the drawings selected is provided in .

the Attachment to this report. -Since Procedure 1032.011 specifies that the '

r Design Document Information System (DDIS) will be used for verifying the latest L revision of the drawing, the inspectors compared the drawing revision of ,

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drawings selected at each of the three locations to the latest revision ;

specified in the DDIS for that drawing. Of'the 21 drawings checked, only one

, discrepancy was noted, in that,- the revision of Drawing M-2202-01 in the Unit 2 control room and the systems engineering office drawing files was Revision 38T03; ,

, however, the DDIS designated Revision 39T01 as the latest revision for this *

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drawing. In discussing this discrepancy with drawing control personnel, it was l determined that the revision in the DDIS database was incorrectly entered as

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39T01 in June of this year. The revision was corrected to 38T03 but the 39T01

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L was not deleted from the DDIS database. A Condition Report (CR-2-90-0364) was initiated to document the discrepancy and ensure that better controls are in !

place to keep the database accurat '

The requirements for procedure control have been specified in Procedure 1000.00 i The inspectors checked the revision of 20 safety-related procedures against the :

Master Promdure Index maintained by Offices Services. The 20 procedures were ;

randomly selected and were representative of procedures from the following:

(a)controlledcopiesintheUnit1ControlRoom,(b)controlledco i-Unit 2 Control Room, (c) copies being used to perform work, or (d) pies used copies in the !

by document control. No discrepancies were identified betwetn the revision of

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t b procedure in use and that listed in the Master Procedure Index. The inspectors' verified that Revision 33 of Procedure 1000.006 was being implemented by document control personnel on August 17, 1990, which coincided with the >

effective date of the procedure. Since-the new revision requires that controlled copies of procedures issued for work shall be valid for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the user ,

shall verify that the procedure is current every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, document control

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personnel were: implementing means for documenting when a controlled procedure was issued and recording tne verification every 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ,

The requirements for control of documents other than procedures and design documents have been included in Procedure 1000.016. Since the document control responsibilities were assigned to Office Services, the inspectors verified that Office Services personnel were controlling other documents, such as, the ANO Units 1 and 2 TS, the ANO Units 1 and 2 Safety Analysis Reports, and the Quality Assurance Manual Operations. The inspection included review of Controlled Document Distribution Lists and Controlled Document Transmittals for selected documents and document revisions or amendments, i Ho violations or deviations were identified during this portion of the inspection.

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' DESIGN CHANGES AND MODIFICATIONS PROGRAM (37702)

The objective of this-inspection was to ascertain whether the licensee is implementing a quality assurance program relating to the control of design O changes and modifications that is in conformance with regulatory requirements,

, Safety Analysis Report comitments, and industry guides and standard The inspectors reviewed the procedures written to establish the design changes and modifications program at ANO. The procedures reviewed are identified in the Attachment to this report. The inspectors found that the design changes and modifications program,'as described, provided for the initiation of a modification and the review of such in regard to 10 CFR 50.59 to assure that a modification does not constitute an unreviewed safety question. The inspectors found that controls were established which identified the organization responsible for a modification and-the interfaces required to accomplish a modificatio It was found that the need for a modification began with a Plant Engineering Action Request from plant personnel or an Engineering' Action Request from design engineering. Design engineering then developed a Project Scoping Report. The scoping report and other planning documents became the oasis for developmentofaDesignChangePackage(DCP). Less complex change efforts were calledLimitedChangePackages(LCPs)orChangePackageswhenthedesignbases and Technical Specifications were not affected by the chang The inspectors verified implementation of the design changes and modifications program by review of a sample of 14 dedgn packages, which are listed in the Attachment to this report. The samp %d design packages were planned for installation in the next refueling outage of Unit I and were on file-in the central file system. Theinspe'.torsfoundadesignpackagetoinclude(as applicable): an approval pagr.; indext overall description; 10 CFR 50.59, ALARA, and fire protection reviews; QA category evaluation; design change sumaries by applicable disciplines; component data sheet; bill of materials; drawings needed for installation; independent design evaluation; design document checklist; and applicable appendices of calculations, information requests, specifications, and input The inspectors found that design packages were subject to the review and approval of such persons as a lead engineer, an engineering supervisor, a quality engineer, an independent reviewer, and applicable engineering discipline ,

The inspectors also reviewed the QA auditing of the design changes and modifications program that was in progress during this inspection and the previous year's audi The inspectors noted some very minor discrepancies in regard to the elevation of supports in DCPs 89-1039 and -1040. The licensee will correct these

. discrepancies. It was also observed by the inspectors that some changes were made'after the various sectinns of design packages were prepared and reviewe i

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Certain of these changes were made without initials, dates, and concurrence of the applicable preparer and reviewer. These changes were not " typo" type corrections but were minor changes in the rationale of an evaluation. Examples

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of this problem found by thl inspectors were changes on: page 23, an independent design evaluation, in LCP 90-5021; page 37, also an-independent design ;

evaluation in LCP 90-5004; evaluation, in *

andpage28,aQAcategory(CR-1-90-0325)

DCP 89-1026. The licensee issued a Condition Report on this problem. The licensee plans to review other design packages in order to ,

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establish the extent of the problem. A memorandum was issued to all engineering personnel which emphasized the requirement to initial and date all changes to documents. In addition, the licensee has agreed to change it ,

, . Procedure 6010.001 to require the initials, date, and concurrence of the :

r applicable preparer and reviewer if changes are made after a design package section has been prepared. A Notice of Violation is not being issued because t the criteria of Section V.A. of the NRC's Enforcement Policy have been me '

Temporary mo' d ifications. installed in 1990 were also reviewed to verify compliance with and effectiveness of Procedure 1000.028. Temporary modifications were.found to be. properly controlle ;

16. EXIT INTERVIEW  :

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An exit meeting was held on August 17, 1990, with those individuals denoted in

, Section:1 of this report. At this meeting, the scope of the inspection and the findings were summarized. The licensee did not identify as proprietary any of the information provided to, or reviewed by the inspector *

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ATTACHMENT *

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LISTING OF DOCUMENTS REVIEWED Records Management Procedures:

1000.01'7, " Records Management," Revision 19 f- 4000.001, " Control of Plant Modifications Welding," Revision i

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1013.005, " Indexing and Storage of Records," Revision 16 .'

1013.006,1 *Hicrographics," Revision 16 1013.009, " Documentation ~ Retention & Disposition," Revision 12 1307.36 ." Testing 5th Floor Computer Room Halon System," Revision 8

, 1307.39, " Testing 5th Floor Records / Archives Vault Halon System," Revision 7-

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L Document Control Procedures:

1000.003, " Station Commitment Tracking," Revision 12 1000.006, " Procedure Review, Approval, and Revision Control," Revision 32 1000.006, " Procedure Control " Revision 33

! 1000.016 " Document Control Requirements," Revision 9

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1013.001, " Control Documents and Distribution," Revision 11, Change No I 1013.002, " Control of. Procedures," Revision 33, Change No. TC-1 1013.003, " Correspondence Control," Revision 15 1013.007, " Action Tracking," Revision 12 1013.008, "AND Library," Revision 8 1032.011,." Design Document Control," Revision 10, Change No. 3 Records:

Document Description Microfilm Location Number ,

Unit 1 Licensee Event Report No.86-007 030471119 through 1122 Unit 2' Licensee Event Report No.89-012 044682586 through 2593 Audit Report QAP-20-89 - 047150556 through 0695 SRC Heeting Minutes for July 8,1985 023900130 through 0110 l PRC Meeting Minutes for February 12, 1980 008012946 through 2349 .

Surveillance Procedure 2104.39 Supp 4 045330082 through 0084 l Surveillance Procedure 1106.06=Supp 3 046421837 through 1845 ,

Inservice Inspection IR6 SG Tubes 031771538 through 1548 .

Inservice Inspection Data Package 039511140 ANO-410-002-4 Weld No.01-017 Welder Qualification for May 15,'1985 026363103 through 3107

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Drawings:  :

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M-0200, Sheet 1,Revisibn9-M-0200, Sheet 2, Revision 0 M-0200, Sheet 3. Revision 0 M-0204-05, Revision 10

~M-0210,. Revision 77T01

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, i'M-0211, Revision 49

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'f M-0231-02, Revision 15 M-2200, Sheet l', Revision 12

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M-2202-01, Revision 38T03

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M-2202-02, Revision-52 ,

NM-2202-03, Revision 8

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YiW aM: N-2204-04,~ Revision 38 M-2230 's1, Revision 52

jhi% !M-2236, Sheet 1,-Revision 59 1 G+ ' J N-2236, Sheet 2, Revision 7 M-2240, Revision'34 ' ~

M-2250 . Revision 4 I

Design Changes and Modifications Procedures:

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i NP-20. "ANO Plant Modifications Manual," Revision 3 1000.103, " Plant Modification Process," Revision 5 1000.028, ." Temporary Modification Control," Revision-15 6000.010. " Design Control Process," Revision 4

,, 6000.020, " Design Document' Control," Revision 6

!6000.060, " Project Closecut,". Revision 5 *

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r 6010.001, "DCP Cevelopment," Revision 4 ..

6020.002, " Control of Design. Change Documents," Revision 3 '

000-2, "QE Document Review," Revision 6 ..

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QCO-03,'"QCHoldpoint/InspectorGuidelin#e" Revision 3

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QCO-8, "QC Operating procedure Maintenance and Modification QC Inspections,"

Revision 4

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, - Design Packages-

' U (LCP.90-5021,'QuenchtankdrainlinepipeNeplacement LCP:90-5019, Pressurizer safety relief discharge piping support modification

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LCP 90-5007, Redesign of reactor coolant system drainline .

'i ;LCP 90-5004, liigh pressure injection valveJ(MU-45 A thru D) replacements-

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=LCP 90-5002, Main,feedwater pump minimum speed 6 ' DCP 90-1032, Cable replacement of valve operators

', LCP 89-5005, Modification of an emergency diesel generator support

. DCP 89-1042, Refueling. comunication system DCP'89-1040, Support modification toz chilled water pipin '

' DCP 89-1039, Support modification to intermediate cooling' water piping 1 DCP 89-1029,' Decay heat support raodification .

'DCP 89-1026, Decay heat support anchor bolt replacement

, .DCP_89-1018, Piping thermal stratification monitoring system

. DCP 89-1006A, low pressure injection modification

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