IR 05000382/1989030
| ML19332E719 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/06/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8912120023 | |
| Download: ML19332E719 (3) | |
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DEC - 6 lgg
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'In Reply Refer To:
Docket:
50-382/89-30
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Louisiana Power & Light Company ATTN:
J. G. Dewease, Senior Vice Presiaent Nuclear Operations t
317 Baronne Street New Orleans, Louisiana 70160
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Gentlemeni Thank you for your letter of November 29, 1989, in response to our letter and Notice of Violation dated October 30, 1989. We~ have reviewed your reply and find it' responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to' determine that full compliance has been achieved and will be
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maintained.
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Sincerely,
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original seed By:
Samuel J. Collins Samuel J. Collins, Director Division of Reactor Projects i.
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CC:
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Louisiana Power & Light Company ATTN:
R. P. Barkhurst, Vice President e
Nuclear Operations P.O. Box B Killona Louisiana.70066 e
r Louisiana Power & Light Company
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ATTN:
J. R. McGaha, Jr., Plant Manager P.O. Box B Killona, Lou'isiana 70066 Louisiana Power & Light Company-l
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ATTN:
L. W. Laughlin, Site Licensing Support Supervisor P.O. Box B Killona, Louisiana,70066 RIV:RI: MOP C: MOPS g
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Louisiana Power & Light Company.
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i Louisiana Power & Light Company
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ATTN:
G. M. Davis, Manager Events Analysis Reporting & Response j
P.O. Box B K111ona, Louisiana 70066 r
Monroe & Leman
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ATTN:
W. Malcolm Stevenson, Esq.
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201 St. Charles Avenue, Suite 3300
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New Orleans Louisiana 70170-3300
Shdw Pittman, Potts & Trowbridge.
- ATTH: Mr. E. Blake 2300 N Street, NW Washington, D.C; 20037
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Middle' South Services. Inc.
' ATTN:. Ralph T. Lally, Manager of Ouality Assurance P.O. Box 61000
New Orleans, Louisiana 70161 Chairman
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Louisiana Public Service Commission
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One American Place, Suite 1630
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Baton Rouge, Louisiana 70825-1697 l
Louisiana. Power & Light Company ATTN:
R. F. Burski, Manager, Nuclear Safety and Regulatory Affairs 317 Baronne Street
New Orleans, Louisiana 70112
Department of Environmental Ouality ATTN: William H. Spell, Administrator
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Nuclear Energy Division
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P.O. Box 14690 Baton Rouge, Louisiana 70898 President, Police Jury-
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St.: Charles Parish Hahnv111e, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office
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.Bethesda, Maryland 20814 E
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U.S. Nuclear Regulatory Commission
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ATTN: Resident Inspector.
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P.O. Box 822 K111ona Louisiana 70066
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d U.S. Nuclear Regulatory Connission
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ATTN: Regional Administrator Region IV 76hl ington exa
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bec to DMB (IE01)
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R. D. Martin Resident Inspector SectionChief(DRP/A)
DRP DRSS-FRPS.
MIS System ProjectEngineer(DRP/A)
RSTS Operator 4RIV File DRS D. Wigginton. NRR Project Manager (MS:
13-D-18)
Lisa Shea, RM/ALF L. Ellershaw
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P. O. Bok topo New Ortsans. L.A 70100 0M0 Tel. Dos 605 2006 n. r.
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Manager W3P89-2150 A4.05
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1.1i DEC - I S89 I
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November 29, 1989 i
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U.S. Nuclear Regulatory Commission
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ATTN Document Control Desk Washington, D.C.
20555 Subject: Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 89-30 Gentlemen In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment l_the response to the Violation identified in Appendix A of the subject Inspection Report.
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If you have any questions concerning this response, please contact L.W. Laughlin at (504) 464-3499.
Very truly yours, f.(
i RFB/DDG/pi Attachment Messrs. R.D. Martin,NRC Region IV $
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e F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-NRR E.L. Blake W.H. Stevenson L.
NRC Resident Inspectors Office
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Att chment t2
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Page 1 of 5 ATTACHMENT 1 LP&L RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 89-30 VIOLATION 8930-01
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Criterion V of Appendix B to 10 CFR Part 50 requires activities affecting quality to be prescribed by documented procedures and accomplished in accordance with these procedures.
Paragraphs 4.2 and 5.2 in Revision 5 to Procedure MM-001-053, " Weld Filler Material Control." respectively state, in part "The Weld Coordinator shall
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be responsible for all welding activities and for conducting a weekly audit on Control of Filler Materials in the Filler Material Issue Facility...."
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"The Welding Coordinator or MHS (Mechanical Maintenance Supervisor) shall verify the transfer of heat number and/or lot number from the filler material container to the Controlled Material Tag...(and) to the Controlled Material Index Card.
In addition, the Purchase Order (PO) or Transfer Requisition (TR), and Material Requisition Inspection Report (MRIR) shall be verified." Paragraph 5.3 and Attachment 6.5 require the tool room attendant to enter the correct lot number of the weld filler material on the Filler Material Control Form.
Contrary to the above, the following conditions were identified:
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There was no documented evidence available to substantiate that the ree.uired veckly audits had been performed.
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Traceability of certain E309-16 electrodes, some of which had been issued and consumed, was lost in that a nonexistent lot number was erroneously assigned to the controlling documentation associated with this material.
3.
Certain Filler Material Control Forms (used to document the issuance, consumption, and return, if applicable, of filler
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material) associated with a certain heat of E-7018 electrodes, had incorrect lot numbers entered.
This is a Severity Level IV violation.
RESPONSE (1) REASON FOR THE VIOLATION Example 1 LP&L agrees that documented evidence to show audits per paragraph 4.2 of Procedure MM-001-053, " Weld Filler Material Control," is not available. The root cause for this was personnel procedural misinterpretation. The following information explains this lack of documentation.
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Attcchment to
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Page 2 of 5 l
i The purpose of Procedure HM-001-053 is to provide a method in controlling the storage and issuance of welding and brasing filler materials. One of the intents of the procedure was to proceduralize j
the Weld Coordinators responsibilities with regard to the control of j
filler materials in the Filler Material Issue Facility. These
responsibilities includet l
Verification of heat and lot number transfers from the
filler material containers to Control Material Tags and Control Material Index Cardst Monitoring the Filler Material Issue Facility on a weekly
basis to ensure procedural compliance; and
a Resolving any filler material control concerns.
- Paragraph 4.2 states, "The Veld Coordinator shall be responsible for all welding activities and for conducting a weekly audit on Control of
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Filler Materials in the Filler Material Issue Facility." When this t
provision for audits was added to Revision 4 of the procedure, it was not intended that the weld coordinator perform weekly " formalized" audits with documented auditable findings on the control of weld filler materials.
With this intention, no proceduralized audit or log forms were included and required to be completed as attachments to MM-001-053. Consequently, no f orms have been completed and kept on
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file. The specific intent was for regular surveillances on a weekly basis to be performed by the Weld Coordinator. Therefore, the wording
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of Paragraph 4.2 was poor and not complied with in the common interpretation of an audit.
Examples 2 and 3 The root cause of Examples 2 and 3 of the violation was personnel error.
In both cases welding personnel inadvertently transferred an incorrect lot number from the filler material container to the Controlled Material Index Card on July 14, 1989 and July 13, 1989 for i
Examples 2 and 3. respectively.
Paragraph 5.2.3.1 in Revision 5 to Procedure MM-001-053, " Weld Filler Material Control" states, in part, "The Welding Coordinator or HMS shall' verify the transfer of heat numbers and/or lot numbers from the filler material container to the Controlled Material Index Card.
Also, Attachment 6.5 to the procedure requires the tool room attendant to enter the correct lot number of the weld filler material on the Filler Material Control Form.
Regarding Example 2, while recording the lot numbers provided on filler material containers onto Controlled Material Index Cards, lot numbers 10217-1 and 10219-2 appeared frequently. In the process, the number 10219-1 was incorrectly entered on a Controlled Material Index Card. This error was not detected in the subsequent verification performed by the Weld Coordinator.
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Attcchment to
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Page 3 of 5 For Example 3 the tool room attendant inadvertently transposed the incorrect lot number for 1/8 inch Type E-7018 electrodes. The correct
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lot number (30920AG02) was transposed as 2C920AG02.
(2) CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
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Example 1 The individual involved has been counselled on the importance of procedure compliance and the significance of assuming they were meeting the intent of the procedure. The individual should have initiated a procedure change to clarify the intent or complied with
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the common interpretation of an audit.
Example 2
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The original transfer requisition, TR-5026 for the 1/8 inch Type E309-16 electrodes was reviewed. Review of the TR-5026 indicated that
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21 cans (210 lbs) of 1/8 inch E309-16 electrodes were transferred from EBASCO to LP&L. Of the 21 cans, 20 cans (200 lbs) were lot number 10217-1 and one can (10 lbs) was lot number 10219-2. After accounting for the 21 cans and reviewing the Controlled Material Tags and Controlled Material Index Cards, the Controlled Material Tag and Index Card for the single can of niectrodes with lot number 10219-2 was i
located. Based on this review, it was concluded that the lot number 10219-1 was actually lot number 10217-1.
Furthermore, no purchase order or CMTR exists for mat.erial represented by lot number 10219-1.
The corresponding Controlled Material Tag and Controlled Filler Material Index Card for lot number 10219-1 has been cotrected to reflect the correct lot number (10217-1). Lot number 10219-1 was issued for use four times (July 14, 1989, October 12, 1989, November 5, 1989 and November 6, 1989). By making the above correction, material traceability has been restored.
In addition, the welding personnel involved with Example 2 have been counseled on procedural compliance and the significance of correctly transferring the lot and heat numbers to the index cards.
Example 3 The Controlled Filler Material Index Card for the 1/8 inch Type E-7018 electrodes has been revised to indicate the correct lot number (3C920AG02).
In addition, the welding personnel involved with Example 3 have been counseled on procedural compliance and the significance of correctly transferring the lot and heat numbers to the index cards.
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W3P89-2150 Page 4 of 5 (3) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Example 1 LP&L realizes that the intent of Paragraph 4.2 of procedure MM-001-053 can be misleading. Eased on this, paragraph 4.2 will be revised to clarify its meaning. This procedure will be revised by January 31, 1990.
Example 2 The following weld packages affected by the inadvertently transposed lot number (10219-1) associated with Example 2 are listed below by Condition Identification (CI) number and corresponding Work j
Authorization (WA):
CI WA h
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263447 01039963 2.
263474 01039810 3.
266033 99000319
266312 99000319 The above listed veld packages will be corrected with the correct lot
number (10217-1) by December 30, 1989.
Example 3 The following veld packages affected by the inadvertently transposed lot number (2C920AG02) associated with Example 3 are listed below by
CI number and corresponding WA.
CI WA
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264820 99000273 2.
256061 99000190
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263925 99000278 4.
260845 99000242 5.
263474 01039810 i
l The above listed weld packages will be corrected with the correct lot number (30920AG02) by December 30, 1989.
In addition, the tool room attendants will receive formal training in filler material control procedures and other areas such as M&TE control. This training will be completed by January 31, 1990.
(4) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With regard to actions in (3) above, LP&L will be in full compliance by January 31, 1970.
In the area of procedural compliance, Maintenance has begun direct debriefing between Management and individual personnel to ensure understanding and emphasize the importance of procedural complianc t.
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Page 5 of 5 LP&L feels that the specific errors made in the weld rod issuance were
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isolated cases. However, in addition to the training, a follow-up audit will be performed by the Site Quality organization by
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June, 1990, i
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