ML20011F661

Responds to Violations Noted in Insp Repts 50-313/89-39 & 50-368/89-39.Corrective Actions:Procedural Controls for NDE Will Be Upgraded to Incorporate Requirements of ASME Section XI,IWA-2641, Layout of Component Ref Points.

ML20011F661
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/02/1990
From:	Ewing E ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN039010, CAN39010, NUDOCS 9003070096
Download: ML20011F661 (10)

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U.S. Nuclear Regulatory Commission Document Control Desk t Mail Station PI-137 p Washington, D. C. 20555

SUBJECT:

Arkansas Nuclear One - Units 1 and 2 1 Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Report 50-313/89-39; 50-368/89-39 e

, Gentlemen: ,

Pursuant to the provisions of 10CFR2.201, attached is the response to the violations identified in the subject inspection report. An extension for ,

the date of this response was granted in a telephone conversation between Messrs. Dwight Chamberlain of the NRC Region IV Staff and Rick King of my '

staff. i Very truly yours, l

E. C. Ewing General Manager, Technical Support

• and Assessment ECE/JDJ/abw Attachment cc: Regional Administrator Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 >

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< March 2, 1990 Notice of Violation A. Title 10 Paragraph 50.55a of the Code of Federal Regulations requires that a plant Inservice Inspection Program be established and performed in accordance with applicable editions of the ASME code. Accordingly, the Arkansas FSAR and Inservice Inspection Program invoke the requirements of the 1980 edition of Section XI of the ASME code with addenda through the winter of 1981 for the second 10 year inspection interval. ASME Section XI, IWA-2600 and Appendix III, Supplement 2 of that code require establishment of a reference system that identifies each weld (including vendor welds), location of each weld center line, and designation of regular intervals along the length of the weld.

f Contrary to the above, an NRC inspection identified that the Arkansas Unit 1 Inservice Inspection (ISI) Program had no reference marking system and that the welds within the ISI Program were not marked with unique identifiers.

This is a Severity Level IV violation. (Supplement I) (50-313/8939-03)

Response to the Violation

1. The reason for the violation:

The cause of the violation was determined to be less than optimum guidance or control by ANO of the ISI contractor's activities in the area of documenting weld reference markings. Based on conversations with the vendor, Babcock and Wilcox, weld reference markings were apparently being performed; however, compliance with the ASME requirements could not be verified because the markings were not recorded on the ISI

, examination report forms used to document NDE activities.

2. The corrective steps that have been taken and the results achieved:

When the subject condition was identified, Condition Report CR-1-89-0524 was initiated to address a weld reference stamping system for both Units One and Two. An evaluation of the existing conditions determined that there would be no impact on plant safety if the welds currently in the field did not contain reference markings. These markings are required for welds subject to ISI surface or volumetric examinations and are used to relocate indications found during ISI excminations for tracking purposes in future examinations. The existing welds are satisfactory and examination records are maintained to provide a basis for evaluation and to facilitate comparison with the results of subsequent examinations.

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3. The corrective steps which will be taken to prevent recurrence:

L LANO will upgrade procedural controls for nondestructive examinations to incorporate the requirements of ASME Section XI, IWA-2641, " Layout p of Component Reference Points." Weld reference markings will be proceduralized by March 26, 1990, and future inspections will require

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s< marking of subject welds in accordance with the code. ISI weld examinations subject to this code reference have not been performed since this condition was identified and will not be performed before the procedure is implemented.

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4. The date of full compliance:

Proceduralcompliancewiththecode.requirementswIllbe'achievedby-

! March 26, 1990, with the implementation of the weld reference marking L procedure.

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. U. S. NRC Page 3 March 2, 1990 Notice of Violation B. 10 CFR 50, Appendix B, Criterion XVII-Quality Assurance Records, requires that quality assurance records shall be identifiable and retrievable consistent with applicable regulatory requirements. Site Quality Manual Section 17.0, Quality Asturance Records, invokes ANSI N45.2 that requires quality records be indexed, filed and maintained l' in facilities that provide a suitable environment to minimize deterioration or damage and to prevent loss. Site Design Document

Control Procedure 6000.20 reinforces these requirements.

Contrary to the above, an NRC inspection during October 16-26, 1989

l. disclosed that over seventeen 5 drawer file cabinets containing quality assurance records such as vendor as-built drawings, NDE-

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inspection reports and other historical quality records, were stored i

improperly in the hall of the Drawing Control Center. These records were not indexed, filed, and maintained in facilities that provide a suitable environment to minimize deterioration or damage and to prevent loss.

This is a Severity Level V violation. (Supplement I) (50-368/8939-05)

Response to the Violation

1. The reason for the violation:

The violation occurred due to inadequate procedural controls over the storage of these records when the records were received from the architect / engineer. From 1981 until mid-1989, these records were stored in fireproof cabinets located in the Drawing Control vault. The cabinets were inappropriately moved out of the vault into a clerical work area to relieve congestion in the vault caused by engineering staff accessing these files.

2. The corrective steps that have been taken and the results achieved:

Immediately following the subject inspection in October 1989, the fireproof cabinets containing the vendor documentation were returned to the Drawing Control vault. As a Vault Access Authorization List is used to limit and control access into the vault, this corrective action immediately restored a measure of control to the documents until further corrective measures could be taken.

A plan has been developed to correct the subject condition:

a. inventory the entire subject vendor documentation files;

b. generate an index of the subject vendor documentation; E

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c. transmit copies of subject vendor documentation to Office Services

for microfilming; and L d. microfilm the subject vendor documentation and distribute microfilm ,

reels / aperture cards of the documentation.

L The first three items will be completed by September 1990. The last ,

item will be completed by March 1991. Completion of these activities '

will ensure that the vendor documents meet requirements for indexing and storing QA records. Also, the distribution of the vendor documen-i tation on microfilm will provide wider access to the documentation without compromising the security of the documentation.

3. The corrective steps which will be taken to prevent recurrence:

. A QA surveillance will be performed by April 30, 1990, to verify that other quality assurance records are being stored in accordance with  !

the QA Manual Operations, j Procedural mechanisms currently exist to ensure that new incoming i documents are received at ANO in a manner that is consistent with the requirements of 10CFR50, Appendix B, Criterion XVII. The problem records were part of an initial records turnover from the architect / engineer and .

were not received in accordance with procedures currently'in place. '

Procedures 1032.010 and 1032.011 provide guidance for the receipt of new drawings at ANO ensuring that the drawings are indexed, filed and maintained in an appropriate manner.

4. The date of full compliance:

The records are stored in fireproof cabinets in the Drawing Control vault to assure their protection and control until such time as the records are microfilmed and distributed to dual storage locations, ,

expected to be completed in March 1991. t t

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Notice of Violation ,

C. 10 CFR 50, Appendix B, Criterion VI-Document Control, requires that a *

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system be in place that establishes the control of drawings including

_ changes. These controls should preclude the possibility of use of outdated or inappropriate drawings. Site QA manual Section 6.0 for Document Control reinforces these requirements.

Contrary to the above, an NRC inspection during October 16-26, 1989, identified the following examples of failure to effectively control <

drawings. i L

(1) The latest revisions to many plant isometric drawings do not reflect changes as required by design packages (DCPs). The drawing changes required by the DCPs have not been made nor are the OCPs affecting the drawings listed or issued with the appropriate drawing.

A specific example is isometric drawing 2CCB-61-1, Rev. 6 which does not incorporate the drawing revisions required by DCP-890-20060 and does not list DCP-890-20260 as affecting the drawing. ,

(ii) Information on drawings is inadequate in that it does not include-information such as unique weld identities for field welds and vendor welds. This information is necessary to positively identify the weld  ;

.in order to readily retrieve historical records, such as vendor as-built drawings and inspection records. A specific example is ISO 200B-70-4, Rev. 6, which did not uniquely identify welds in spool piece S1-200B-70-4-2.

(iii) Piping hanger and support drawings do not include changes resulting from previous design change packages. A specific example is drawing 2HCC-290-H32 revision N-2, which does not accurately reflect the actual "as-built" configuration of the supports.  ;

This is a Severity Level V violation. (Supplement I) (50-368/8939-04)

Response to the Violation The effective control of drawings has previously been recognized by ANO l as an area requiring attention. Lack of effective control in the past has led to inaccuracies in drawings, which is being addressed in part by the Isometric Update Project. This project is designed to identify and resolve significant as-built discrepancies in the piping isometric #

drawings. As discrepancies are identified, the Condition Reporting System is used to address evaluation of the safety significance of the discrepancy and the impact of the discrepancy on system operability.

In order to adequately address the specific issues identified in each of the examples given, each example will be considered separately.

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. U. S. NRC Page 6 March 2, 1990 Example (i)

1. The reason for the violation:

The cause of the violation was the fact that no consistently controlled system was in place to readily and accurately identify to drawing users the modifications affecting a given drawing. Although procedure 6000.060, " Project Closeout," includes steps to ensure that Operations

• Essential drawings (P& ids and electrical single line diagrams) are as-built prior to completion of the modification installation process, othet ANO drawings are as-built between the installation of a modification and closure of the modification package by Engineering. Efforts have been and will continue to be made to keep this period of time to a minimum. When drawing 20C8-61-1, Rev. 6, was reviewed by the inspector, >

DCP-890-2026 was still open and the drawing had not yet been revised. ,

A DCP is not closed until the associated drawings are updated. Drawing ,

20C0-61-1, Rev. S, will be revised before DCP-89D-2026 is closed. '

2. The corrective steps which have been taken and the results achieved:

In December 1989, Drawing Control clerks were directed to issue a Modification Impact Report to engineers when drawings were requested for inclusion in a new modification package. The Modification Impact Report lists active modification package numbers that affect the requested drawings (e.g., outstanding DCPs, etc.). By identifying modifications affecting drawings in the new modification, the engineer is able to evaluate the impact of the existing active modifications on  ;

his/her design, i The inspection report also discussed drawing 2GCB-5-1 and a problem with weld FW55C1. The current revision of 2GCB-5-1, Revision 15, does not indicate FW55C1; however, this drawing was affected by a recent plant change, and the updated drawing produced as part of the '

modification closeout will show FW55C1. The drawing referenced by 2GCB-5-1, which is 2HCB-179-1, shows FW1, a weld at the opposite end of valve 251-35 from FW55-C1. Drawing 2HCB-179-1 is correct. '

3. The corrective steps which will be taken to prevent recurrence:

Drawing control procedure 1032.011, " Design Document Control," will be revised to incorporate steps for the issuance of the Modification Impact Reports to engineers preparing new modification packages.

Furthermore, the revision to procedure 1032.011 will direct Drawing Control to provide a Modification Impact Report with any print request if it is needed. The revision to procedure 1032.011 includes a revised print request form (form 1032.011F) that will prompt the requestor to indicate whether or not a Modification Impact Report is needed.

As a result of the use of Modification Impact Reports, print users will be aware of modifications impacting new designs, the plant configuration and as-built drawings. Copies of the active modification packages are stationed in various locations at ANO for reference.

Copies of specific modification package drawings may be obtained from Drawing Control (Plant Changes) or the Modification Central Files group (DCPs and LCPs).

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. U. S. NRC l' Page 7 l March 2, 1990 Another activity that is expected to enhance the timely update of r

drawings is the recent implementation of computer-aided draf ting (CAD) at ANO. As drawings are converted to the CAD format, the time necessary j.

to as-build the drawings following the implementation of a modification is expected to decrease.

4. The date of full compliance:

Compliance with the specifics of the violation was achieved by implementing.

the use of the Modification Impact Reports in December 1989. This process will be proceduralized by April 15, 1990.

Example (ii)

1. The reason for the violation:

ANO has determined that the omission of unique field identifiers for field welds and vendor welds resulted from a lack of detailed direction by ANO during drawing development. Welding information turned over to AND by the architect / engineer (A/E) was fragmented. The master copy of the piping isometric drawings did not include any weld identifiers.

Sepia copies (field revisions) of many of the piping isometric drawings were turned over to ANO showing field weld locations and identifiers.

The vendor documentation stored in file cabinets included spool piece drawings showing vendor weld identifiers.

2. The corrective steps which have been taken and the results achieved:

Field weld identifiers are currently being added to piping isometric drawings as part of the Isometric Upgrade Project. Corrective action to add the field weld identifiers began in the early 1980s; when piping isometric drawings were redrawn, often the field weld identifiers were transferred from the field revision sepia drawings to the original drawings. This process is now formalized in the Isometric Update Project.

The inspection report discussed a concern with a particular vendor spool drawing (SI-2CCB-70-4-2) which had not been updated. This type of drawing is archive information and is not updated. The Isometric Update Project is now including the addition of vendor weld indentifiers and marking of spool piece boundaries on the piping isometric drawings. This will enhance traceability back to the vendor spool drawing when needed for historical purposes.

3. The corrective steps which will be taken to prevent recurrence:

The Isometric Upgrade Project has been enhanced to include the addition of vendor weld identifiers to the piping isometric drawings already redrawn and to add them to drawings as they are redrawn in the future.

A unique symbol is used for the vendor weld identifiers along with a symbol that marks spool piece boundaries on the piping isometric drawings. The vendor weld identifier and spool piece identifier also shown on the drawing will provide information necessary to locate other related records such as radiographs.

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4. The date of full compliance: '

Full compliance is expected at the conclusion of the Isometric Upgrade -

Project in December 1995.

Example (iii)

1. The reason for the violation:

This example occurred because a configuration change identified in the field by a maintenance group was not communicated to Engineering, and the master drawing was not updated to include this information.

Previous as-built information is retained when drawings are updated as a result of a DCP. As-built information not associated with the DCP is not deleted from the updated drawing.

The example provided was pipe support drawing 2HCC-290-H32, revision N-2. The drawing copy reviewed by the inspector had been retrieved from a job order file which contained drawings associated with certain closed job orders. In 1982, a job order had been assigned to the contractor maintenance group for resolution of discrepancies on Unit Two service water system large pipe hangers. In addressing the job order, a revised copy of this pipe support drawing was included in the job order at the time of closure. This was the drawing copy reviewed by the inspector. However, a notification to revise the master drawing

, had not been issued to Plant Engineering from the maintenance group  :

involved with the job order. Therefore, the master drawing was never as-built to reflect necessary changes. Consequently, when the inspector reviewed the drawing in the DCP against the copy which had been retrieved from the job order files, certain as-built information was missing from the drawing copy in the DCP.  ;

The cause of this example was inadequate communication from maintenance personnel to engineering concerning configuration control. This illustration of a failure of field workers to communicate configuration changes to engineering is representative of the reason for such discre-pancies in general.

l 2. The corrective actions which have been taken and the results achieved:

To correct the specific problem identified during the inspection, the Project Engineer responsible for as-building 2HCC-290-H32 ensured that the as-built revision included the missing information. The current drawing accurately reflects the as-built configuration of the support.

3. The corrective steps which will be taken to prevent recurrence:

Procedure 1025.003, " Conduct of Maintenance," was revised to direct the performers of maintenance activities to stop work and contact Mainten-l ance Engineering when a change to the plant configuration is believed to exist. Specific examples are listed of potential design configura-L tion changes.

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! A Maintenance Engineering administrative procedure has been implemented which directs Planning and Scheduling planners to secure a Maintenance Engineering review of job orders when technical assistance is required and to incorporate Maintenance Engineering's comments into the job order. From this review, the appropriate requests are generated when as-built drawing revisions are needed.

Also, the Isometric Upgrade Project is progressively correcting drawing deficiencies on piping isometric drawings and pipe support drawings

, such as the one identified by the inspector.

During the recent organizational realignment at ANO, a separate Configuration Management work group was created. The purpose of this group is to review the current configuration management practices at ANO and to suggest procedural and training improvements to better control the configuration of the plant. As the group is staffed and work begins, improvements in overall plant configuration control will result.

4. The date of full compliance:

ANO is currently in compliance with the specifics of the violation.

The Isometric Upgrade Project is scheduled for completion during December 1995.

To summarire, ANO is addressing the control of dr9 wings from several perspectives. In particular, the configuration management work group is addressing the overall issue of. configuration control and methods of improvement, which will include.the control of drawings. Configuration control 'during maintenance activities has been enhanced by the role of the Maintenance Engineer. Also, steps have been taken to ensure that work packages reference the appropriate drawims, and craf t personnel are required to use drawings that are controlled and issued by Drawing Control.

To ensure u3ers of drawings have accurate information, Modification Impact Reports provide a list of modifications affecting drawings to drawing users who require such information, and.the Operations Essential drawings are updated prior to completion of modification installations which affect them.

Lastly, the Isometric Upgrade Project is addressing the addition of weld identifiers to piping isometric drawings and verifying these drawings against as-built configurations.

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