ML20011D506
| ML20011D506 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/15/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8912270337 | |
| Download: ML20011D506 (2) | |
See also: IR 05000313/1989042
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DEC 151195
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- 50-313/89-42
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<ATTH: Gene. Campbell, Vice President
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Nuclear Operations
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lThank you:for your letter of December 4,1980, in "#onse to our letter .
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and Notice of Violation-dated November 3,1989.. We have reviewed your reply
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. and find it respnsive to the~ concerns raised in our Notice of Violation. ,We
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will revie*# the implementation of'your corrective. actions during a future
inspection to determine that fu11Ecompliance has been achieved and will be
maintained,
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Sincerely,
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Original Signed By:
~ Ssnoel J. coWns
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Samuel s1.: Collins, Director
Division of Reactor Projects
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-Arkansas Nuclear One
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ATTH:. Early Ewing, General Manager
Technical Support and Assessment
P.O. Box 608
- Russellville, Arkansas .72801
Arkansas. Nuclear One
ATTN: Neil Carns, Director
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Nuclear Operations
'P.O.- Box 608
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- Russellville, Arkansas 72801
Combustion Engineering, Inc;
ATTH:
Charles B. Brinkman, Manager
Washington Nuclear Operations
12300 Twinbrook Parkway, Suite 330
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Honorable Joe W. Phill'.ps
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County Judge of Pope County
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.Russellville; Arkansas 472801
Bishop, Cook, Purcell & Reynolds
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ATTN: Nicholas S. Reynolds Esq.
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1400-L Street, N.W
Washington, D.C.
20005-3502.:
-ATTN: Ms. Greta Dieus, Director .
Division of Environmental' Health
Protection
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4815 West Markam Street-
Littic Rock, Arkansas 72201
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Babcock A Wilcox.
Nuclear Power Generation' Division
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ATTN: Mr. Robert B. Borsum
1700 Rockville Pike, Suite 525
' Rockville, Maryland 20852
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U.S. Nuclear Regulatory Comission
. ATTN: Senior Resident inspector
- l Nuclear Plant Road
Pussellville, Arkansas 72801
U.S. ~ Nuclear Regulatory Comission
ATTN: Regional Administrator, Region IV
611 PJan Plaza Drive, Suite 1000
Arlington, Texas 76011
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bec distrib. by RIV:
-R. D. Martin
Resident Inspector
DRSS-FRPS
SectionChief(DRP/A)
Lisa_Shea,P.M/ALF
RIV File
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MIS System
RSTS Operator
ProjectEngineer(DRP/A)
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C. Harbuck, NRR Project Manager (MS:
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C. Posiusny, NRR Project Manager (MS:
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December 4, 1989
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U. S. Nuclear Regulatory Commission
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Document Control Desk
Mail Station P1-137
Washington, D. C.
20555
SUBJECT:
Arkansas Nuclear One - Units I and 2
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Docket Nos. 50-313/50-368
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Response to Inspection Report
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50-313/89-42; 50-368/89-42
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Gentlemen:
Pursuant to the provisions of 10CFR2.201, attached is the response to the
violations identified in the subject inspection report.
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Very truly yours,
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/ E. C. Ewing
General Manager,
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Technical Support
and Assessment
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Region Administrator
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
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Page 1
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December 4,1989
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A.
Control of Welding Activities
Criterion IX of Appendix B to 10 CFR 50 and the licensee's approved
quality assurance plan require that special processes, such as
welding, be controlled and accomplished by qualified personnel using
qualified procedures.
In the following examples, this did not occur.
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1.
The travel speed specified on Drawing 2CCB-14-2 for Weld FW18C1
is 3-10 inches per minute.
Contrary to the above, the welding speeds in use were 2 and 11/2
inches per minute.
2.
The Welding procedure Specification (WPS) for Weld FW1C1 did not
address the use of domineralized water to quench the weld.
Contrary to the above, domineralized water was sprayed on the weld
to expedite cooling below 350' F, the maximum interpass temperature
in the WPS.
3.
Flare-bevel Welds FW9, FW10, FW15, and FW16 identified on Drawing
2CCC-6-H-2 were specified to be 2 inches of weld 4-inch centers.
Contrary to the above, these welds were accepted although they were
made continuously (for 6 inches without break).
This is a Severity Level IV violation.
(Supplement II)(313/8942-01;
368/8942-01)
Response to the Violation
1.
The reason for the violation:
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With regard to examples 1 and 2, the cause of the violation was the
failure of management to clearly communicate expectations regarding
adherence to the quality requirements built into the program to the
weld craftsmen and weld craftsmen supervision.
In example 1, the welder was not aware that the travel speed specification
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was in the WPS.
(As stated in paragraph 3.b of the Inspection Report,
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the WPS, not the drawing, is the document containing the travel speed
specifications.)
Concerning example 2, the use of demineralized water as a que.1ching
spray on austenitic stainless steel was an historical construction
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practice not covered by procedure.
The welder was following what he
considered to be an accepted practice instead of strictly adhering to
the WPS.
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Page 2
December 4, 1989
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With regard to example 3, the cause of the violation was inattention
to detail by the welder.
After completing the welding on a nearly
identical hanger 2CCC-12-H1 which specified a continuous weld, he
failed to note the difference in the drawings and welded hanger 2CCC-6-H2
similarly.
2.
The corrective steps that have been taken:
To ensure that weld craftsmen and weld craftsmen supervision were aware
of management's expectations for the conduct of welding activities,
training was conducted on October 20, 21, and 22, 1989, which emphasized
that the requirements of the WPS must be followed and that circumstances
prohibiting WPS compliance require that work is stopped and the supervisor
is notified for resolution.
Also, supervisors began reviewing each
weld package and the WPS with the craftsman before the job is started.
These actions were previously addressed in our letter of October 26,
1989 (SCAN 198917).
Additional training which discussed weld procedure specifications and
compliance with these requirements was conducted during the week of
November 27, 1989, for plant modifications wela craftsmen and maintenance
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weld craftsmen.
The " Control of Plant Modification Welding" and " Conduct of Maintenance
Welding" procedures have been changed to state that a copy of the WPS
shall be in the work package at the work location and that the supervisor
will review the weld packages and the WPS with the craftsmen at the
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start of each shift. The procedures now clearly state that welding
specifications will be followed, activities not addressed in procedures
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or specifications will not be done, and circumstances prohibiting
compliance with the specifications require stopping work and notifying
the Lognizant supervisor for resolution.
Also, to address the additional weakness identified in the inspection
report regarding Quality Control (QC) surveillance of welding activities,
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QC has implemented a special welding surveillance checklist which has
been incorporated into QCO-6, " Welding Inspection", along with monitoring
frequency guidance.
Routine, random surveillance of in process welding
activities is being performed and documented.
Concerning the adequacy of the weld noted in example 1, the supporting
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procedure qualification records for the WPS were reviewed by Engineering.
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As a result, the WPS travel speed was determined to be overly restrictive,
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and the WPS was revised accordingly to require 1-10 inches per minute.
As this change to the WPS was non-essential pursuant to the applicable
ASME code, the quality of the weld was not affected by the use of a
slower travel speed and the weld was determined to be acceptable.
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December 4 -1989
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To establish the adequacy of the weld noted in example 2. Engineering
determined that the use of demineralized water to control interpass
temperature on P8 austenitic stainless steel is an appropriate use of
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a quenching spray.
A memorandum was issued by Engineering which
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established interim requirements for use of domineralized water as a
quenching spray until the weld specifications are revised.
(The weld
specifications will be revised by February 28, 1990.) However, prior
to this determination occurring, the weld was cut out and rewelded
without the use of quenching spray and the new weld was determined to
be acceptable.
The continuous flare-bevel welds in example 3 were determined to be
acceptable in accordance with AP&L specification APL-M-2410. Section
4.11. " Support Assemblies of Greater Strength than Required". The
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hanger as-built drawing was revised to indicate the continuous weld.
In each of the examples given, the quality of the welds was not affected.
AP&L has no indication that procedural non-compliance has resulted in
unsafe welding practices.
3.
The corrective steps that will be taken to avoid recurrence:
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Training on compliance with procedures and specifications will be
conducted for new welders coming on site in the future.
This on-going
training, the training and the procedure changes which have already
been completed, and the implementation of the QC welding surveillance
checklist will prevent a recurrence of this violation.
A review of AP&L/ANO ASME and AWS Welding Procedure Specifications for
accuracy and adequacy was initiated.
The 52 AWS D1.1 qualified joint
and pre qualified joint WPSs have been reviewed and no changes were
required.
Of the 57 ASME Section IX qualified WPSs, 14 of the most
commonly used WPSs have been reviewed and revised as necessary. The
remaining ASME Section IX qualified Welding Procedure Specifications
will be reviewed and revised as necessary by February 28, 1990. Any
inadequacies in the remaining WPSs will not affect welding activities
as the weld craftsmen and supervisors review the WPS prior to starting
work and they are aware that any difficulties must be resolved before
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the work can be done.
The AP&L/AND Specification M-2415. " Nuclear
Welding Standards", will be revised to address the use of demineralized
water for controlling interpass temperature on austenitic stainless
steels by February 28, 1990.
A review of the welding program at ANO has been initiated for possible
enhancements, such as consolidation of the separate controls for the
maintenance and modifications groups into uniform, comprehensive
procedures and policies.
Such procedurer, and policies would encompass
training and qualification requirements ter all welders on site. This
review is expected te be completed by May 1, 1990.
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December 4, 1989
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4.
The date of full compliance:
Compliance was achieved by October 22, 1989, with the completion
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of the training of the weld craftsmen on compliance with procedures and
specifications.
As discussed above, the following procedures changes will be completed
by February 28, 1990:
The remaining 43 ASME Section IX qualified WPSs, to be revised as
necessary based on reviews.
AP&L/ANO Specification M-2415 to address the use of quenching spray.
Identified enhancements to the welding program as discussed above are
expected to be completed by May 1, 1990.
B.
Document Control
Criterion VI of Appendix 8 to 10 CFR 50 and the licensee's approved
quality assurance plan require that measures shall assure that document
changes are distributed to and used at the location where the prescribed
activity is performed.
Contrary to the above, out-of-date revisions of Procedures 1092.011
" Implementing and Control Welding," and 1033.003, "Weiding Filler
Material Control" were in use at the storeroom during the issue of
welding materials.
This resulted in procedurally required records not
being maintained.
This is a Severity level IV violation.
(Supplement II) (313/8942-02;
368/8942-02)
Response to the Violation
1.
The reason for the violation:
The correct revision of Procedure 1092.011 was not in the storeroom
because Materials Management was not included on the Master Procedure
Distribution List (MPDL) for 1092.011.
The MPDL is used by Document
Control to distribute new procedure revisions.
The need for this
procedure in the storeroom was apparently overlooked when distribution
of the procedure was determined.
The correct revision of procedure 1033.003 was not in the rod storeroom
because the Stores Supervisor failed to forward a copy to the rod
storeroom.
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December 4, 1989
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2.
The corrective steps that have been taken:
Copies of the latest revisions of procedures 1092.011 and 1033.003 were
placed in the rod storeroom on October 20, 1989.
Materials Management and the rod storeroom have been added to the MPDL
for procedure 1092.011, and the rod storeroom was added to the MPDL for
procedure 1033.003.
Revisions to these procedures will now be issued
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directly to the rod storeroom by Document Control, and written confirmation
of receipt of each revision is required by Document Control procedures.
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The Stores Supervisor has a controlled set of procedures required by
Materials Management.
There are no other work locations in Materials
Management (except the rod storeroom) which require distribution of
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document changes.
The approval form for procedure revisions has recently been revised to
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ensure that if a procedure revision affects departments other than
the department responsible for the procedure, the revision is also
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approved by a section leader in the other affected departments.
This
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will help ensure that procedures are distributed to the appropriate
departments.
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3.
Corrective steps that will be taken to prevent recurrence:
Actions taken to place the procedures on the MPDL for the rod storeroom
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will prevent recurrence of this event.
A review will be conducted of the 1033 procedure series (Materials
Management procedures) to identify referenced procedures which are the
responsibility of other departments.
These identified procedures will
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be reviewed to determine if Materials Management should be on the
distribution list for each procedure.
This review will be completed
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by January 15, 1990.
4.
The date of full compliance:
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Full compliance was achieved October 20, 1989, when the current revisions
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were placed in the storeroom.
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