Text

IR 07200049-04-001, on 08/31/2004 - 09/02/2004, Entergy Operations, Inc., River Bend Station; ISFSI Report; No Violations
	ML042780632
Person / Time
Site:	River Bend
Issue date:	10/01/2004
From:	Spitzberg D; NRC/RGN-IV/DNMS/FCDB
To:	Hinnenkamp P; Entergy Operations
References
	-RFPFR
	Download: ML042780632 (36)
	v • d • e

ber 1, 2004

SUBJECT:

INSPECTION REPORT 072-00049/04-001

Dear Mr. Hinnenkamp:

An NRC inspection was conducted on August 31 through September 2, 2004, at your River Bend Station. This inspection consisted of observing the welding demonstration segment of your Independent Spent Fuel Storage Facility (ISFSI) pre-operational testing program. The inspection included direct observation of the welding and weld testing, review of selected records and procedures, and interviews with personnel. The enclosed inspection report documents the results of that inspection.

The inspection determined that you are conducting pre-operational testing activities in compliance with the Commissions rules and regulations and with the conditions of your license as they relate to welding and weld testing of spent fuel canisters. No violations were identified.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publically Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this inspection, please contact the undersigned at (817) 860-8191 or Mr. Scott Atwater at (817) 860-8286.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Docket No.: 72-049 License No.: NPF-47

Entergy Operations, Inc. -2-

Enclosure:

NRC Inspection Report 072-00049/04-001

REGION IV==

Docket No.: 072-00049 License No.: NPF-47 Report No: 072-00049/04-001 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: August 31 through September 2, 2004 Inspectors: S.P. Atwater, Inspector R.L. Kellar, Inspector W.E. Bezanson, Contractor - ATL Approved By: D.B. Spitzberg, Ph.D., Chief Fuel Cycle and Decommissioning Branch Attachments: 1. Supplemental Information 2. Inspector Notes ADAMS Entry: IR 07200049-04-01 on 09/30/2004; Entergy Operations, Inc., River Bend Station; ISFSI Report; No violations.

-2-EXECUTIVE SUMMARY River Bend Nuclear Generating Station NRC Inspection Report No. 072-00049/04-001 Condition 10.f of Certificate of Compliance (CoC) 72-1014 for the Holtec HI-STORM 100 cask system requires the licensee to perform multi-purpose canister (MPC) welding, non-destructive examination (NDE) inspections, hydrostatic testing, draining, moisture removal, helium backfilling, and helium leakage testing prior to spent fuel loading. The MPC welding and NDE inspection portions of Condition 10.f were demonstrated at the River Bend Station from August 31 through September 2, 2004 and were observed by the NRC. The demonstration included welding and NDE inspections of the MPC lid-to-shell, vent and drain port cover plates (including set screws), and closure ring segments.

The purpose of this inspection was to determine if the licensees personnel, processes, equipment, and materials were adequate to perform the closure welds specified for the Holtec 100 Spent Fuel Storage Cask System.

Personnel:

Welding Services, Inc. (WSI) provided the welders and welding equipment for making the closure welds on the Holtec spent fuel canisters at the River Bend Independent Spent Fuel Storage Installation (ISFSI). The WSI welders assigned to the River Bend project were qualified to perform manual and machine Gas Tungsten Arc Welding in accordance with ASME Code Section IX. The River Bend senior welding engineer reviewed the welder qualification records supplied by WSI and approved the welder qualifications. The records indicated all welders had satisfactorily completed the required qualification tests and the qualification tests themselves met the rigor of ASME Code Section IX. The Welder Maintenance Log indicated all welders had performed manual and machine Gas Tungsten Arc Welding within the past 6 months.

The licensee NDE inspectors were trained, qualified, and certified to perform non-destructive testing on the Holtec canister closure welds in accordance with American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section III and with American Society of Non-Destructive Testing Technical Council (SNT-TC-1A).

The Entergy written practice for control and administration of NDE personnel training, examination, and certification included written and proficiency examinations for both the liquid penetrant and visual testing methods of NDE. Recertification intervals were specified and all NDE personnel were current.

Processes:

The licensee welding process specified compliance with ASME Boiler and Pressure Vessel Code 1995 Edition with Addenda through 1997. This was documented in the contract between Entergy and WSI and on the weld data sheets. The licensee had compared the WSI welding procedures and their associated procedure qualification records to the ASME Section IX welding code and found them to be acceptable for use under the contract.

-3-A work plan and weld traveler package were implemented for controlling this demonstration. Both documents were approved by the River Bend Dry Fuel Storage (DFS) project manager.

The liquid penetrant procedure specified the method, acceptance standards, and records for recording liquid penetrant test results. The visual testing procedure established the requirements and acceptance standards for performing visual examination of welds.

Both procedures contained the minimum elements required.

The work plan contained specific instructions for evacuating the space under the lid with an explosive proof vacuum system. Combustible gasses were continuously monitored during the root pass of the MPC lid-to-shell weld. An alert level of 10 percent of the lower explosive limit for hydrogen was set, at which point all welding and grinding operations would cease.

The radiological control practices simulated during this demonstration were adequate for cask welding operations. Area postings, exposure limits, expected dose rates (based on Arkansas Nuclear One history), alarming dosimeter setpoints, low dose rate areas, and adherence to the radiation work permit were demonstrated to the maximum extent practical. The concept of ALARA was emphasized throughout the demonstration.

The foreign material exclusion (FME) controls simulated during this demonstration were adequate for cask welding operations. The FME zone established for the demonstration was a roped off area around the MPC mock-up in the pipe fabrication shop. Signs were posted to designate the area as an FME zone. The FME contact was assigned and posted adjacent to the zone entrance. A Tool and Material Control Log was maintained.

Personnel, tools and materials were logged in and out. Cleanliness and good housekeeping practices were maintained during the demonstration.

Equipment:

The weld traveler required that all welding equipment be calibrated. The welding machines and control console were calibrated, but the hot wire machines were not.

The licensee generated a Condition Report to document Entergy's position that the hot wire machines would not be used on MPC closure welds unless they were calibrated.

Materials:

The chemicals used for liquid penetrant testing of the closure welds met the requirements of ASME Code Section V. The chemical certification records for the Sherwin DUBL-CHEK products in use indicated that all of the products met the requirements for standard and high temperature liquid penetrant testing.

The weld wire in use for the demonstration was purchased in 1984 under the 1974-1980 editions of the ASME code. At the time of the inspection, a code reconciliation had not been performed to verify the weld wire met the requirements of the 1995 edition of the code. The weld wire was subsequently determined to be acceptable, however a programmatic requirement to perform the code reconciliation prior to use was not

-4-identified. The licensee generated a Condition Report to correct this condition and the disposition will be tracked as an Inspector Follow-up Item.

Summary:

No findings of significance were identified. Licensee personnel, processes, equipment, and materials were adequate to perform the closure welds specified for the Holtec 100 Cask System. The welding and NDE personnel were well qualified, the work plans and procedures were approved, comprehensive, and functional, the equipment was reliable and accurate, and the materials were consistent with the design documents.

The scope of this inspection was MPC welding and NDE inspections only. Condition 10.f of Certificate of Compliance (CoC) 72-1014 also requires the licensee to perform MPC hydrostatic testing, draining, moisture removal, helium backfilling and helium leakage testing. With the exception of helium leakage testing, these operations will be performed during the fluid operations phase of the pre-operational testing program. The helium leakage testing requirement will be met prior to fuel loading, if still in force at that time.

Condition 10.j of CoC 72-1014 requires the licensee to perform cask system unloading, cooling fuel assemblies, flooding the canister cavity and removing canister lid welds.

Removal of the canister lid welds was demonstrated in July of 2004 and a videotape was made. The videotape confirmed the demonstration was conducted in accordance with the procedure and the inspectors concurred that the lid weld removal requirement in Condition 10.j was met. MPC gas sampling, venting, flooding, cooldown, and unloading will be demonstrated during the fluid operations phase of the pre-operational testing program.

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel R. Albert, Jr, Radiation Protection Supervisor G. Avellone, Welding Engineer R. Biggs, Licensing Coordinator J. Campbell, DFS Project Manager E. Clevenger, DFS Design Lead T. Hoffman, Manager Strategic Capital Project B. Kienlen, NDE Certifying Agent J. Magee, NDE Examiner G. Mahan, Senior Welding Engineer W. Selby, NDE Examiner B. Williams, NDE Examiner Welding Services, Inc.

D. Antoine, Welding Supervisor W. Osborne, Welder and Welding Operator W. South, Welder and Welding Operator J. Terry, Welder and Welding Operator INSPECTION PROCEDURES USED IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Installations at Operating Plants LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened IFI 72-049/0401, Program Requirement for Conducting ASME Code Reconciliations Closed None.

Discussed None.

LIST OF ACRONYMS ALARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers CFR Code of Federal Regulations CoC Certificate of Compliance GMAW Gas Metal Arc Welding GTAW Gas Tungsten Arc Welding HEPA High Efficiency Particulate Airborne FME Foreign Material Exclusion FSAR Final Safety Analysis Report ISFSI Independent Spent Fuel Storage Facility MPC Multi-Purpose Canister NDE Non-Destructive Examination NRC U.S. Nuclear Regulatory Commission PT Liquid Penetrant Testing VT Visual Testing LIST OF DOCUMENTS REVIEWED ADM-0092, "Foreign Material Exclusion - FME", Rev. 2 Condition Report CR-RBS-2004-02458 Condition Report CR-RBS-2004-02602 Condition Report CR-RBS-2004-02760 CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 DFS-0135, "Work Plan, MPC Welding Operations Mock Up", Rev. B DFS-MPC Vent and Drain Port Cutting and MPC Lid Cutting, Rev. 0 Entergy General Welding Standard, E-GWS-1, Rev. 3 Holtec Design Document PS 1502, Rev. 4, Sheet 3 Holtec Design Drawing 2524, "MPC-68/68F/68FF Weld Mock Up Ancillary #502", Rev. 5 Letters dated 08/30/04 issued by the River Bend Senior Welding Engineer, approving WSI welder qualifications.

Multi-Gas Monitor ITX Instruction Manual, Rev. 3

-2-NDE Personnel Certification Records Purchase Order #28446 dated 06/18/84 and its associated material certification record Purchase Order #28625 dated 07/12/84 and its associated material certification record River Bend Weld Material Requisitions #16012 and #16013 Sherwin, Inc. Chemical Certification Records Welding Engineering Review of WSI Welder and Welding Operator Qualifications For Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004 Welding Engineering Review of WSI Weld Procedures for Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004 Welding Services Inc. Procedure Qualification Records; PQR 08-08-TS-001, Rev. 0; PQR 8.8.6-OKG; PQR-08-08-TS-002, Rev. 0; PQR-08-08-T-901, Rev. 0 Weld Procedure Specification WPS-08-08-T-901, "GTAW - Hot Wire", Rev. 0 Weld Procedure Specification WPS-08-08-TS-001, "GTAW/SMAW", Rev. 2 Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S System, dated August 30, 2004 Videotape of MPC Lid Cutting Demonstration, dated July 22, 2004

RIVERBEND WELDING DEMONSTRATION Inspector Notes Category: Welding Topic: Applicable Codes Reference: FSAR 1014, Sections 7.1 and 7.1.1 Requirement The HI-STORM 100 confinement vessel is the MPC. The confinement boundary of the MPC consists of the MPC shell, bottom baseplate, lid (including the vent and drain port cover plates), closure ring, and associated welds. The MPC is designed, fabricated, and tested in accordance with ASME Section III, subsection NB [7.1.1] to the maximum extent practical. Reference [7.1.1] is the ASME Boiler and Pressure Vessel Code,Section III, Division 1, Subsection NB, Class I Components, 1995 Edition.

Finding: This requirement was implemented. The 1995 Edition of ASME Boiler and Pressure Vessel Code was in use for the MPC boundary welds. The licensee had reviewed the welding procedures to the ASME Section IX Welding Code and found them to be acceptable for use under the contract. Upon questioning by inspectors, the licensee stated that the contract contained the references to the Holtec FSAR welding requirements, including a reference to the ASME Welding Code, 1995 Edition.

The inspectors also reviewed the licensee Weld Data Sheets utilized to control the welding process. The specification referenced in the Weld Data Sheets was "Holtec Docket 72-1014." Use of this reference included all docketed material for the Holtec licensee 72-1014. The licensee explained that the intent of the reference to the Holtec Docket was to encompass the ASME Welding Code requirements, including which edition was to be utilized.

The licensee also stated that the welding typically performed at the plant site was performed to the 1995 Edition of the ASME Welding Code. Thus, the information provided by the licensee indicated that the welding processes for the Holtec canister were performed in accordance with the ASME Welding Code, 1995 Edition.

Documents Welding Engineering Review of WSI Weld Procedures For Entergy Dry Cask Storage, Reviewed: River Bend Station, dated August 30, 2004 Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S System, dated August 30, 2004 Category: Welding Topic: Combustible Gas Monitoring Reference: FSAR 1014, Table 8.0.1 Requirement Monitor the area around the MPC lid for combustible gases prior to and during welding or cutting activities. For defense in depth, the space below the MPC lid should be evacuated or purged prior to and during these activities.

Finding: This requirement was implemented. The licensee had provided a work plan that included precautions and specific instructions for combustible gas monitoring during the welding demonstration. Instructions were provided to sample for combustible gases during the welding operation until the root pass weld, including NDE, had been completed. The work plan also specified that the action level occurred when the Page 1 of 25

combustible gas concentration exceeded 10% of the lower explosive limit.

The licensee process for sampling combustible gases consisted of an explosive proof vacuum system that pulled suction from underneath the MPC lid. Fresh air entered the canister through the gaps around the lid to shell weld area and was evacuated through the MPC vent port opening to the explosive proof vacuum system. The discharge of the explosive proof vacuum was routed through a HEPA filter. A multi-gas monitor capable of monitoring combustible gas concentrations was inserted into the discharge tube and read by an individual stationed to continuously monitor for combustible gases during welding operations until the root pass weld had been completed.

The inspectors questioned the accuracy of the multi-gas monitor for detecting the level of hydrogen that could be present during welding operations. The licensee produced a vendor chart that showed the lower explosive limit correlation factors between the monitor calibration gas and the gas being sampled. The calibration gas reported to be utilized by the licensee for calibration purposes was pentane. For hydrogen monitoring, the licensee calibration method would show that the 10% of the lower explosive limit had been reached by the monitor, when the actual value for hydrogen was 5% of the lower explosive limit providing a conservative reading by a factor of two.

Documents DFS-0135, "Work Plan, MPC Welding Operations Mock Up", Rev. B Reviewed: Multi-Gas Monitor ITX Instruction Manual, Rev. 3 Category: Welding Topic: Materials; Minimum Delta Ferrite Content Reference: ASME Section III, Article NB-2433; Reg Guide 1.31 Requirement A delta ferrite determination must be made for A-No.8 consumable inserts, bare electrode, rod, or wire filler metal. Exceptions: 1) A-No.8 metal used for weld metal cladding; 2) SFA-5.4 and SFA-5.9 metal; 3) Type 16-8-2 metal. The minimum acceptable delta ferrite content is 5 FN and it must be stated in the certification records.

Finding: This requirement was implemented. The certification record for the weld wire purchased under PO #28446 dated 06/18/84 indicated a delta ferrite number of 10 FN.

The certification record for the weld wire purchased under PO #28625 dated 07/12/84 indicated a delta ferrite number of 8.6 FN.

Documents Purchase Order #28446 dated 06/18/84 and its associated material certification record Reviewed: Purchase Order #28625 dated 07/12/84 and its associated material certification record Category: Welding Topic: Materials; Specifications Reference: 10 CFR 72.154 Requirement The licensee shall establish measures to ensure that purchased material, equipment, and services conform to procurement documents. These measures must include provisions for source evaluation and selection, objective evidence of quality furnished by the contractor/subcontractor, inspection at the contractor/subcontractor source and examination of product on delivery. Records shall be available for the life of the ISFSI.

The effectiveness of the control of quality by contractors/subcontractors shall be assessed at intervals consistent with the importance, complexity and quantity of the Page 2 of 25

product or service.

Finding: This requirement was not fully implemented at the time of this pre-operational inspection.

The materials used in the MPC mock-up, mock-up ancillaries, and welding process were consistent with procurement documents. Holtec Design Drawing 2524, "MPC-68/68F/68FF Weld Mock Up Ancillary #502", Rev. 5, Sheet 2 and Holtec design document PS 1502, Rev. 4, Sheet 3 specified that the MPC mock-up components (lid, shell, vent and drain port cover plates and set screws, closure ring, and closure ring plugs) were fabricated from SA 240-304 stainless steel. The Holtec FSAR 1014 also required the actual MPC components to be fabricated from SA 240-304 stainless steel.

The WSI weld procedures WPS 08-08-TS-001 and WPS-08-08-T-901 also specified SA 240-304 stainless steel, and identified the compatible weld wire (spool and bare rod) as ER 308L. The manufacturer's identification on the weld wire and the River Bend Weld Material Requisitions #16012 dated 08/30/04 (035" spools) and #16013 dated 08/31/04 (1/8" bare rod) identified the weld wire as ER 308L. The Holtec FSAR 1014 also requires the ER 308L weld wire to be used on actual MPC closure welds.

A programmatic deficiency concerning weld wire suitability was identified. The ER 308L weld wire used for the demonstration was purchased in 1984 under purchase orders

28446 dated 06/18/84 and #28625 dated 07/12/84. Both purchase orders specified that the weld wire met the requirements of the 1974-1980 editions of the ASME Code. The inspectors asked whether or not the weld wire met the requirements of the 1995 edition of the ASME code, which is specified in Holtec FSAR 1014. The licensee had not performed a code reconciliation for this weld wire and could not find a programmatic requirement to do so. The licensee generated Condition Report CR-RBS-2004-02551 to evaluate this condition.

A subsequent review of the material certification records indicated the weld wire did meet the requirements of the 1995 ASME code.

Documents Holtec Design Drawing 2524, "MPC-68/68F/68FF Weld Mock Up Ancillary #502",

Reviewed: Rev. 5 Holtec design document PS 1502, Rev. 4, Sheet 3 WPS 08-08-TS-001, "GTAW/SMAW", Rev. 2 WPS-08-08-T-901, "GTAW - Hot Wire", Rev. 0 River Bend Weld Material Requisitions #16012 and #16013 Purchase Orders #28446 and #28625 Category: Welding Topic: Personnel and Procedure Qualification Reference: 10 CFR 72.158 Requirement Special processes, including welding, heat treating, and non destructive testing are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

Finding: This requirement was implemented. The welding demonstration was controlled using Page 3 of 25

procedures qualified for welding and weld testing of actual spent fuel canisters. The Weld Traveler Package for the Holtec Dry Cask Closure Welds of the HI-Storm 100S System, dated 08/30/04, Attachment A specified that all WSI welding procedures and welder qualifications used for production welding on the MPC be submitted and approved by the Entergy Senior Welding Engineer. The Welding Services, Inc. (WSI)

welding procedures used during this demonstration, WPS 08-08-TS-001, Rev. 2 and WPS-08-08-T-901, Rev. 0 were approved. The WSI welders and welding operator qualifications were approved and documented in two letters dated 08/30/04 issued by the River Bend Senior Welding Engineer. Those letters stated that the WSI weld procedures and welder and welding operator qualifications were approved and met the ASME Section IX welding code requirements.

Documents Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S Reviewed: System, dated August 30, 2004 WPS 08-08-TS-001, "GTAW/SMAW", Rev. 2 WPS-08-08-T-901, "GTAW - Hot Wire", Rev. 0 two letters dated 08/30/04 issued by the River Bend Senior Welding Engineer.

Category: Welding Topic: Personnel Quals; Expiration Reference: ASME Section IX, Part QW-322.1 Requirement The performance qualification of a welder or welding operator, for any process, shall expire when he has not welded with that process for six months or more.

Finding: This requirement was implemented. The welding vendor had established a Welder Maintenance Log (WML) that had been provided to Entergy for review. The WML listed the expiration date of each welder by welding process (i.e. GMAW, GTAW, etc.).

Entergy had reviewed and approved the vendor WML that ensured each welder had maintained their performance qualifications current for the GTAW welding process being performed, including both machine and manual process applications. The performance qualifications for each of the 4 vendor welders present indicated their qualifications were current for the welding processes demonstrated during the welding demonstration.

Documents Welding Engineering Review of WSI Welder and Welding Operator Qualifications For Reviewed: Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004 Category: Welding Topic: Personnel Quals; Performance Records Reference: ASME Section IX, Part QW-301.4 Requirement The record of welder and welding operator performance qualification (WPQ) tests shall include the essential variables (QW-350 or QW-360), the type of test and test results, and the ranges qualified in accordance with QW-452 for each welder and welding operator.

Finding: This requirement was implemented. The vendor had provided Welder Performance Qualification (WPQ) records for each of the 4 welders utilized during the welding demonstration. The WPQ records provided detailed information of the GTAW essential variables utilized for each welder's WPQ. For GTAW, this includes the joint type, base metal utilized, filler metal utilized, welding position, backing gas and electrical current Page 4 of 25

or polarity as specified in QW-356. The Entergy Senior Welding Engineer had reviewed and approved the WPQ records for each of the welders. A review of selected WPQ records indicated they contained the essential variables, type of test, and qualified ranges, as required by ASME Section IX, Part QW-301.4 Documents Welding Engineering Review of WSI Welder and Welding Operator Qualifications For Reviewed: Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004 Category: Welding Topic: Personnel Quals; Performance Test - General Reference: ASME Section IX, Part QW-301.2 Requirement The performance qualification test shall be welded in accordance with qualified welding procedure specifications (WPS), unless preheat or post weld heat treatment is specified.

Finding: This requirement was implemented. The vendor had provided Welder Performance Qualification (WPQ) records for each of the 4 welders utilized during the welding demonstration. The WPQ records provided detailed information of the welding processes and ranges that each welder was qualified to perform. The WPQ records included qualification ranges for the welders utilizing both a manual and machine Gas Tungsten Arc Weld (GTAW) process. The Entergy Senior Welding Engineer had reviewed and approved the WPQ records for each of the welders. A review of the WPQ records for the welding personnel indicated that as a team, the welders were qualified to perform the specified welds on the Holtec canister.

Documents Welding Engineering Review of WSI Welder and Welding Operator Qualifications For Reviewed: Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004 Category: Welding Topic: Proc-Quals; Tests - General Reference: ASME Section III, Article NB-4331 Requirement All welding procedure qualification tests shall be in accordance with the requirements of Section IX as supplemented or modified by the requirements of this article.

Finding: This requirement was implemented. The Entergy Senior Welding Engineer had reviewed the vendor welding procedure qualification tests to the requirements of ASME Section IX requirements and found them to be acceptable. The inspectors independently reviewed the vendor welding procedure qualification test records (PQRs) and found that each qualification test had been certified by a vendor representative as being prepared, welded, and tested in accordance with the requirements of Section IX of the ASME Code.

Documents Welding Services Inc. Procedure Qualification Records; PQR 08-08-TS-001, Rev. 0; Reviewed: PQR 8.8.6-OKG; PQR-08-08-TS-002, Rev. 0; PQR-08-08-T-901, Rev. 0 Welding Engineering Review of WSI Weld Procedures for Entergy Dry Cask Storage, River Bend Station, Dated August 30, 2004.

Category: Welding Topic: Proc-Specs; GTAW Essential Variables 1-8 Reference: ASME Section IX, Part QW-256 Requirement The welding procedure specification for Gas Tungsten Arc Welding (GTAW) shall describe the following essential variables: (1) Maximum weld thickness qualified for Page 5 of 25

test coupons greater than 8"; (2) Change in the base metal thickness beyond the range qualified in QW-451; (3) Change in base metal P-number; (4) Change in F-number of the filler metal; (5) Change in chemical composition of the weld deposit from one A-number to another A-number; (6) Addition or deletion of filler metal; (7) Change in filler metal between flux core, solid core, and powder; (8) Change in weld deposit thickness beyond the range specified in QW-451.

Finding: This requirement was implemented. The welding vendor supplied the Welding Procedure Specifications (WPS) that were to be utilized for the welding demonstration and production welding at the River Bend Station. The Entergy Senior Welding Engineer had reviewed the vendor supplied WPS documents to verify compliance to the ASME Section IX Welding Code and found them to be acceptable. The inspectors independently reviewed the vendor supplied WPS documents and found that the essential variables as specified above (numbers 1-8) were identified on the WPS.

Documents Welding Engineering Review of WSI Weld Procedures for Entergy Dry Cask Storage, Reviewed: River Bend Station, Dated August 30, 2004 WPS-08-08-TS-001, "GTAW/SMAW", Rev. 2 WPS-08-08-T-901, "GTAW - Hot Wire", Rev. 0 Category: Welding Topic: Proc-Specs; GTAW Essential Variables 9-14 Reference: ASME Section IX, Part QW-256 Requirement The welding procedure specification for Gas Tungsten Arc Welding (GTAW) must also describe the following essential variables: (9) Decrease of more than 100 degrees F in the preheat temperature qualified. (10) Change in post weld heat treatment conditions; (11) Change in post weld heat treatment conditions above the upper transformation temperature; (12) Addition or omission of a shielding gas, or changing the gas mixture; (13) Deleting the inert backing gas, or changing its mixture; (14) Deleting the trailing shielding gas, changing its mixture, or decreasing its flow rate by more than 10%.

Finding: This requirement was implemented. The welding vendor supplied the Welding Procedure Specifications (WPS) that were to be utilized for the welding demonstration and production welding at the River Bend Station. The Entergy Senior Welding Engineer had reviewed the vendor supplied WPS documents to verify compliance to the ASME Section IX Welding Code and found them to be acceptable. The inspectors independently reviewed the vendor supplied WPS documents and found that the essential variables as specified above (numbers 9 - 14) were identified on the WPS.

Documents Welding Engineering Review of WSI Weld Procedures for Entergy Dry Cask Storage, Reviewed: River Bend Station, Dated August 30, 2004 WPS-08-08-TS-001, "GTAW/SMAW", Rev. 2 WPS-08-08-T-901, "GTAW - Hot Wire", Rev. 0 Category: Welding Topic: Weld Repairs; Surface Defects Reference: ASME Section III, Article NB-4452 Requirement Surface defects may be removed by grinding or machining without weldout provided the minimum section thickness is maintained, the depression is blended and liquid penetrant testing is performed to ensure the defect is removed.

Page 6 of 25

Finding: This requirement was implemented. The Entergy welding program provided instructions for the repair of weld metal defects. Entergy General Welding Standard E-GWS-1, Rev.

3, section 4.9 provided instructions to the welding engineer for implementation of repairs to weld metal defects. These instructions were in compliance with the requirements of ASME Section III, Article NB-4452.

Documents Entergy General Welding Standard, E-GWS-1, Rev. 3 Reviewed:

Category: Welding Topic: Welding Machine Calibration Reference: 10 CFR 72.144(b)

Requirement The licensee shall provide control over activities affecting the quality of the Systems, Structures, and Components (SSCs) covered by the Quality Assurance program to an extent commensurate with the approved design of each ISFSI, MRS, or spent fuel storage cask. The licensee shall ensure that activities affecting quality are accomplished under suitably controlled conditions, such as the use of appropriate equipment.

Finding: This requirement was not fully implemented at the time of this pre-operational inspection. The Weld Traveler Package, Attachment A prerequisites required that all WSI welding equipment be calibrated. The welding machines and control console were calibated, but the hot wire machines were not. The licensee generated Condition Report CR-RBS-2004-02602 to document Entergy's position that the hot wire machines would not be used on MPC closure welds unless they were calibrated.

Documents Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S Reviewed: System, dated August 30, 2004 Condition Report CR-RBS-2004-02602 Category: Welding Topic: Welding Procedures; General Reference: 10 CFR 72.158 Requirement Measures shall be established to assure that special processes, including welding, heat treating, and non destructive testing, are controlled and accomplished by qualified personnnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

Finding: This requirement was implemented. Entergy procedure DFS-0135, "Work Plan, MPC Welding Operations Mock-Up" Rev. B and the "Weld Traveler Package for Holtec Dry Cask Closure Welds", dated 8/30/04 were implemented for controlling this demonstration. Both documents were approved by the River Bend Dry Fuel Storage (DFS) Project Manager.

The Weld Traveler for FW-1 (lid-to-shell) specified the following: Step 5 - Verify the lid surface is equal or below top of shell; Step 6 - Measure and record the as fit total weld joint depth; and Step 11 - Weld the root pass using procedure WPS 08-08-TS-001.

Steps 17 and 23 specified that "the remaining intermediate fill weld deposits shall not exceed 3/8".

Prior to the start of the traveler, an area about 5" long had been identified where the top shell edge was below the lid surface. The condition was evaluated by the Senior Page 7 of 25

Welding Engineer, considered to be acceptable for this demonstration, and documented in step 5 of the Weld Traveler Package. The average weld joint depth specified in Step 6 was measured and recorded as 23.7/32". The FW-1 root weld, step 11 and intermediate filler weld deposits, steps 17 and 23 (weld deposits shall not to exceed 3/8") were accomplished in accordance with the weld procedure and Weld Traveler requirements.

The final average acceptable weld deposit measurement required by Step 27 was recorded as 23/32".

The fit up and welding requirements for field welds FW-2 (Drain Port Cover Plate), FW-3 (Vent Port Cover Plate), FW-4 (Drain Port Cover Set Screws), FW-5 (Vent Port Cover Set Screws), FW-6 (Inside Closure Ring Weld), FW-7 (Outside Closure Ring Weld),

FW-8 (Closure Ring Segment Welds), and FW-9 (Closure Ring Plug Welds) were observed and the results were satisfactory, with the exception of the FW-6 fit up. This was due to a machining problem causing the lid to vary in height by 1/8". This created a problem in achieving the partial penetration groove weld joint required by Holtec Drawing 1402, Rev. 23, Sheet 3. Condition Report CR-RBS-2004-02458 was generated to document and evaluate the condition.

Preheat and interpass temperature, amperage, voltage, and shielding (Argon) rate were observed during the welding process, with no discrepancies identified.

Documents DFS-0135, "Work Plan, MPC Welding Operations Mock Up", Rev. B Reviewed: Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S System, dated August 30, 2004 Condition Report CR-RBS-2004-02458 Category: Weld Testing Topic: Liquid Penetrant Testing; Records Reference: CoC 1014, App B, Table 3-1 Requirement The inspection process for the MPC lid, including findings (indications), shall be made a permanent part of the user's records by video, photographic, or other means which provide an equivalent retrievable record of weld integrity. The video or photographic records should be taken during the final interpretation period described in ASME Section V, Article 6, T-676.

Finding: This requirement was implemented. The Weld Traveler Package, Attachment A required a videotape to be made of the final liquid penetrant examination of the MPC lid-to-shell weld and photographs to be taken of the final liquid penetrant examinations on the vent and drain port cover plates and set screws. These records of weld integrity were created during the final interpretation period using the welding console camera and hand held cameras.

Documents Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S Reviewed: System, dated August 30, 2004

.

Page 8 of 25

Category: Weld Testing Topic: Personnel Certs; Exam Question Approval Reference: SNT-TC-1A, Section 8 Requirement All questions used in Level I, II, and III written examinations must be approved by a Level III examiner.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 required that

"All parts of the examination must be administered by the NDE Level III Examiner or an outside NDE agency approved by the company". Although this is generic, it would include approval of examination questions on Level I, II, and III written examinations.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level I PRACTICAL Exam Reference: SNT-TC-1A, Section 8 Requirement Proficiency should be demonstrated in performing the method and interpreting the results on one or more samples. At least 10 test checkpoints should be used to test understanding of the variables.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [2](f)

required at least 10 test checkpoints for Level I and II PRACTICAL examinations.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level I&II Exam Grading Reference: SNT-TC-1A, Section 8 Requirement Level I and II examiners take 3 examinations; GENERAL, SPECIFIC, and PRACTICAL. A composite grade should be determined by simple averaging of the results of the 3 examinations. A passing composite grade should be 80% with no one examination below 70%.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [2](g)

required simple averaging of the results of the 3 examinations and a passing composite grade of 80% with no one examination below 70%.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level I&II GENERAL Exam Reference: SNT-TC-1A, Section 8 Requirement The GENERAL examination is written. The GENERAL examination for VT and PT should contain a minimum of 30 questions related to the basic principles of the method.

Finding: This requirement was not fully implemented at the time of this pre-operational inspection. CEP-NDE-0110, Rev. 0, section 5.11 [2](c) directed the reader to Attachment 9.10 for the number of questions for GENERAL and SPECIFIC examinations for each method. Attachment 9.10 required 30 questions on the PT GENERAL examination but was silent on the VT GENERAL examination. Condition Report CR-RBS-2004-02760 was generated to correct this oversight.

Page 9 of 25

Section 5.11 [2](d) required that all questions relate to principles, application, and interpretation of the method.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level I&II SPECIFIC Exam Reference: SNT-TC-1A, Section 8 Requirement The SPECIFIC examination is written. It should address the equipment, operating procedures, NDT techniques, codes and acceptance criteria for the method. The SPECIFIC examination for VT and PT should contain a minimum of 20 questions for VT, 20 questions for PT Level I, and 15 questions for PT Level II.

Finding: This requirement was not fully implemented at the time of this pre-operational inspection. CEP-NDE-0110, Rev. 0, section 5.11 [2](c) directed the reader to Attachment 9.10 for the number of questions for GENERAL and SPECIFIC examinations for each method. Attachment 9.10 required 20 questions on the PT SPECIFIC examination for Level I and 15 questions on the PT SPECIFIC examination for Level II, but was silent on the VT SPECIFIC examination. Condition Report CR-RBS-2004-02760 was generated to correct this oversight.

Section 5.11 [2](e) required that the questions relate to equipment, procedures, techniques, codes/specifications, and acceptance criteria used by the company.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level II PRACTICAL Exam Reference: SNT-TC-1A, Section 8 Requirement Proficiency should be demonstrated in selecting and performing the applicable techniques within the method and interpreting the results on one or more samples. At least 10 test checkpoints should be used to test understanding of the variables.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [2](f)

required at least 10 test checkpoints for Level I and II PRACTICAL examinations.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level III BASIC Exam Reference: SNT-TC-1A, Section 8 Requirement The BASIC examination should contain 15 questions relating to understanding the SNT-TC-1A document, 20 questions relating to applicable materials, fabrication, and product technology, and 20 questions similar to published Level II questions for other appropriate NDE methods Finding: This requirement was not fully implemented at the time of this pre-operational inspection. CEP-NDE-0110, Rev. 0, section 5.11 [3](d) contained the specifications for Level III BASIC examinations. The River Bend Level III BASIC examination required a minimum of 20 questions relating to understanding the SNT-TC-1A document, 15 questions relating to applicable materials, fabrication, and product technology, and 15 Page 10 of 25

questions similar to published Level II questions for other appropriate NDE methods.

This number of questions differed from the requirement because CEP-NDE-0110, Rev. 0 was based on the 1984 edition of SNT-TC-1A rather than the 1992 edition. Condition Report CR-RBS-2004-02760 was generated to revise CEP-NDE-0110, or develop a new procedure, for use in dry fuel storage activities. The new or revised procedure will be based on the 1992 edition of SNT-TC-1A .

The current Level III BASIC examination contained 75 questions, rather than the 50 questions required by the 1992 edition of SNT-TC-1A. Although the procedure was based on the 1984 edition, the actual examination contained a greater number and type of questions than required by the 1992 edition of SNT-TC-1A.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed: Condition Report CR-RBS-2004-02760 Category: Weld Testing Topic: Personnel Certs; Level III Exam Grading Reference: SNT-TC-1A, Section 8 Requirement Level III examiners take 3 examinations; BASIC, METHOD AND SPECIFIC. A composite grade should be determined by simple averaging of the results of the 3 examinations. A passing composite grade should be 80% with no one examination below 70%.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [3](h)

required simple averaging of the results of the 3 examinations and a passing composite grade of 80% with no one examination below 70%.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level III METHOD Exam Reference: SNT-TC-1A, Section 8 Requirement The METHOD examination should contain 30 questions relating to fundamentals and principles, 15 questions relating to application and establishment of techniques and procedures, and 20 questions relating to interpreting codes, standards and specifications.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [3](e)

required the number and type of questions specified in SNT-TC-1A, Section 8.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Level III SPECIFIC Exam Reference: SNT-TC-1A, Section 8 Requirement The SPECIFIC examination should contain 20 questions relating to specifications, equipment, techniques, and procedures applicable to the employer's product.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.11 [3](f)

required 20 questions relating to procedures, test techniques and applicable equipment.

It also included other ASME, ANSI, and AWS codes and specifications, and Entergy NDE procedures.

Page 11 of 25

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Recertification Reference: SNT-TC-1A, Section 9 Requirement Maximum recertification intervals are 3 years for Levels I and II, and 5 years for Level III. Recertification may be granted without testing provided there is documented continuing satisfactory performance. "Continuing" must be defined in the written practice. Without documented continuing satisfactory performance, reexamination is required for those sections deemed necessary by the Level III examiner.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.12 contained the 3 year and five year recertification requirements. "Interrupted service" was defined as a period in excess of twelve months during which personnel have not performed in the NDE method certified. Personnel may be re-examined at any time at the discretion of the certifying agent (Level III Examiner).

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Certs; Records Reference: SNT-TC-1A, Section 9 Requirement Certification records should contain: (1) name of certified individual; (2) certification level and method; (3) educational background and NDE experience; (4) statement of satisfactory completion of training per the employers written practice; (5) visual examination results; (6) evidence of successful completion of examinations, including grades; (7) date of certification; (8) signature of employer.

Finding: This requirement was implemented. The licensee has 4 certified NDE examiners. The lead examiner was the certifying agent for the River Bend Station and was certified as a Level III in PT and VT. The second examiner was certified as a Level III in PT and Level II in VT. The third examiner was certified as a Level III in VT and Level II in PT. The fourth examiner was certified as a Level II in both PT and VT. The certification records for these examiners were complete and contained all the elements required by SNT-TC-1A, Section 9.

Documents NDE Personnel Certification Records Reviewed:

Category: Weld Testing Topic: Personnel Certs; Written Practice Reference: SNT-TC-1A, Section 5 Requirement The employer shall establish a written practice for control and administration of NDT personnel training, examination and certification. The written practice (1) should describe the responsibility of each level of certification for determining the acceptability of material or components and (2) shall describe the training experience and examination requirements for each level of certification.

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, section 5.6 contained the responsibilities for each level of certification in determining the acceptability of material or components. Sections 5.8, 5.9, and 5.11 contained the training, experience and Page 12 of 25

examination requirements for each level of certification.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Quals; General Reference: FSAR 1014, Sect 7.1.3 Requirement Confinement boundary welds are inspected and tested in accordance with ASME Section III, Subsection NB. ASME Section III, Article NB-5521 requires all NDE examiners to be qualified in accordance with SNT-TC-1A.

Finding: This requirement was implemented. The PURPOSE section of CEP-NDE-0110, Rev. 0 stated; "This procedure establishes the requirements for training, qualification, examination and certification of Nondestructive Examination (NDE) personnel in accordance with SNT-TC-1A, 1984 Edition, or for Dry Fuel Storage Activities the 1992 Edition." Both editions of SNT-TC-1A were listed in the procedure references.

Procedure DFS-0135, Rev. B, Paragraph 4.4 specified that all QC/NDE personnel shall be qualified and certified to perform liquid penetrant (PT) and visual testing (VT)

examinations in accordance with the approved procedures.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed: DFS-0135, "Work Plan, MPC Welding Operations Mock Up", Rev. B Category: Weld Testing Topic: Personnel Quals; Level III Reference: SNT-TC-1A, Section 6 Requirement A candidate who has completed less than 2 years of engineering or science study, must have 4 years of experience comparable to a Level II.

A candidate who has completed 2 years of engineering or science study, must have 2 years of experience comparable to a Level II.

A candidate who has completed 4 years of engineering or science study, must have 1 year of experience comparable to a Level II.

Finding: This requirement was implemented. For all certification levels in all NDE methods, CEP-NDE-0110, Rev. 0, Section 5.7 provided the education requirements; Section 5.8 and Attachments 9.1 through 9.4 provided the training requirements; and Section 5.9 and Attachments 9.1 through 9.4 provided the experience requirements. All of the education and experience requirements were consistent with SNT-TC-1A, Section 6 specifications.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Quals; PT Levels I & II Reference: SNT-TC-1A, Section 6 Requirement A Level I candidate who is a high school graduate or equivalent, or who is has completed 2 years of engineering or science study, must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 1 year of experience.

A Level II candidate who is a high school graduate or equivalent, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of Page 13 of 25

training and 2 years of experience.

A Level II candidate who has completed 2 years of engineering or science study must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 2 years of experience.

Finding: This requirement was implemented. For all certification levels in all NDE methods, CEP-NDE-0110, Rev. 0, Section 5.7 provided the education requirements; Section 5.8 and Attachments 9.1 through 9.4 provided the training requirements; and Section 5.9 and Attachments 9.1 through 9.4 provided the experience requirements. All of the education and experience requirements were consistent with SNT-TC-1A, Section 6 specifications.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Category: Weld Testing Topic: Personnel Quals; Vision Reference: SNT-TC-1A, Section 8.2; NB-5521(4) exception Requirement The examiner should have natural or corrected near-distance acuity in at least one eye capable of reading Jaeger Number 1 at a distance of not less than 12 inches on a standard Jaeger test chart, or capable of perceiving a minimum of 8 on an Ortho-Rater test pattern. This should be verified annually. The examiner should demonstrate the capability of distinguishing and differentiating contrast among colors used in the applicable method. This should be verified every 3 years. (This also satisfies ASME Section V, Article 9, T-952)

Finding: This requirement was implemented. CEP-NDE-0110, Rev. 0, Section 5.5 and Attachment 9.7 contained the near distance and color differentiation requirements for all NDE examiners. A review of the certification records for the NDE examiners indicated all personnel were current in their visual acuity and color differentiation examinations.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed: NDE Personnel Certification Records Category: Weld Testing Topic: Personnel Quals; VT Levels I & II Reference: SNT-TC-1A, Section 6 Requirement Level I: A candidate who is a high school graduate or equivalent, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of training and 1 year of experience. A candidate who has completed 2 years of engineering or science study, must have 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of training and 1 year of experience.

Level II: A candidate who is a high school graduate or equivalent, must have 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of training and 2 years of experience. A candidate who has completed 2 years of engineering or science study, must have 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of training and 2 years of experience.

Finding: This requirement was implemented. For all certification levels in all NDE methods, CEP-NDE-0110, Rev. 0, Section 5.7 provided the education requirements; Section 5.8 and Attachments 9.1 through 9.4 provided the training requirements; and Section 5.9 and Attachments 9.1 through 9.4 provided the experience requirements. All of the education and experience requirements were consistent with SNT-TC-1A, Section 6 specifications.

Documents CEP-NDE-0110, "Certification of NDE Personnel", Rev. 0 Reviewed:

Page 14 of 25

.

Category: Weld Testing Topic: Proc-Quals: General Reference: FSAR 1014, Sect 7.1.3 Requirement Confinement boundary welds are inspected and tested in accordance with ASME Section III, Subsection NB. Article NB-5512 requires all NDE examinations to be performed using written procedures meeting the requirements of Section V for the particular examination method.

Finding: This requirement was implemented. Observation of the welding and weld testing demonstration, and reviews of documentation indicated the welding and NDE program requirements specified in ASME Section V were satisfactorily implemented.

Procedure CEP-NDE-0640 (PT), Rev. 0 specified the method, acceptance standards, and records for recording liquid penetrant test results. Procedure CEP-NDE-0965, Rev. 0 established the requirements and acceptance standards for performing visual examination of welds. Procedure DFS-0135, Rev. B, "Work Plan, MPC Welding Operations Mock-Up", provided additional details and instructions for the completion of the welding and NDE inspections. The requirements specified in those procedures and applicable Holtec drawings included joint fit up configuration, weld size, weld surface conditions, correct penetrant materials (manufacturer and family), calibrated M&TE (light meter, temperature indicator), adequate illumination, examination coverage, examination sequence, final examination, and records.

The Weld Traveler Package, dated 08/30/04 specified the required hold points, including the QC NDE hold points. The first section of the Weld Traveler Package contained nine Weld Data Sheets, one for each of the nine field welds. Those sheets duplicated the QC/Welding hold points identified in Attachment A of the traveler and required the same sign-offs. The Senior Welding Engineer reviewed the duplication problem and determined the Weld Data Sheet hold point sign-offs were not required and the hold points identified on Attachment A would be used as the official sign-off document. A noted was added to the nine Weld Data Sheets to reflect this change, and they were initialed and dated by the Senior Welding Engineer. He also stated the Weld Traveler Package would be revised to reflect those changes.

The NDE hold points identified on the Weld Traveler were performed in accordance with the procedures and Weld Traveler and in the order specified. Inspection results were documented and the hold points were initialed and dated by the responsible QC Inspector.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed: CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 DFS-0135, "Work Plan, MPC Welding Operations Mock Up", Rev. B Weld Traveler Package for Holtec Dry Cask Closure Welds of the HI-STORM 100S System, dated August 30, 2004 Page 15 of 25

.

Category: Weld Testing Topic: Proc-Quals; PT Acceptance Criteria Reference: ASME Section III, Article NB-5352 Requirement The following indications are unacceptable: (1) any cracks or linear indications. (Linear indications have a length at least 3 times greater than the width); (2) rounded indications with dimensions greater than 3/16" (4.8 mm); (3) four or more rounded indications in a line, separated by 1/16" (1.6 mm) or less edge to edge; (4) ten or more rounded indications in any 6 square inch area in the most unfavorable location relative to the indications being evaluated.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0, Attachment 9.1 contained the liquid penetrant examination acceptance criteria for linear and rounded indications specified in this article.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Contaminants Reference: ASME Section V, Article 6, T-641(b)

Requirement The user shall obtain certification that the total chlorine plus fluorine content of each agent (penetrant, cleaner and developer), does not exceed 1% by weight.

Finding: This requirement was implemented. A review of the Sherwin, Inc. chemical certification records indicated the following:

Sherwin DR-60 DUBL-CHEK CLEANER/REMOVER - Fluoride and Chloride 0.0001

%BW.

Sherwin DP-51 DUBL-CHEK PENETRANT - Fluoride and Chloride < 0.0001 %BW.

Sherwin D-100 DUBL-CHEK DEVELOPER - Chloride 0.0011 %BW.

Sherwin KO-19 DUBL-CHEK HI-TEMP REMOVER - Fluoride < 0.0002 %BW, Chloride < 0.0001 %BW.

Sherwin KO-17 DUBL-CHEK PENETRANT - Chloride < 0.0001 %BW.

Sherwin D-350 DUBL-CHEK DEVELOPER - Fluoride and Chloride < 0.0001 %BW.

Documents Sherwin, Inc. Chemical Certification Records Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Final Interpretation Reference: ASME Section V, Article 6, T-676.1 Requirement Final interpretation shall be made within 7-60 minutes after the minimum developing time. This applies to steel alloys between 50 and 125 degrees F. The 7-60 minute clock starts immediately after application of a dry developer. For wet developer, the clock starts when the coating is dry.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0, step 5.10.3 specified 7 to 30 minutes after the minimum developing time. This was within the 7 to 60 minute range specified in this article.

Page 16 of 25

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Minimum Elements 1-4 Reference: ASME Section V, Article 6, T-621 Requirement Each procedure shall include: (1) materials, shapes or sizes to be examined; (2) type of each penetrant, remover, emulsifier, and developer, (3) pre-examination cleaning and drying, including the cleaning materials used and minimum time allowed for drying; (4)

applying the penetrant, the length of time the penetrant will remain on the surface (dwell time), and the temperature of the surface during examination outside the 50-125 F (10-52 C) range; Finding: This requirement was implemented. Procedure CEP-NDE-0640, Rev. 0 specified the requirements for performing both the standard (60 -150 degree F) liquid penetrant test and the high temperature (120-275 degree F) liquid penetrant test. Both tests were satisfactory demonstrated during this inspection. The NDE material used for both the standard and high temperature liquid penetrant testing was from Sherwin manufacturing. Cleaner DR-60, Penetrant DP-51, and Developer D-100 were used for standard testing. Cleaner KO-19, Penetrant KO-17, and Developer D-350 were used for high temperature testing. The weld joint fit ups (FW- 2 through 9) and weld joint deposits complied with the applicable drawings and welding procedure requirements.

Welded surfaces were ground as required. A calibrated light meter (KTC-131, due 08/06/05) and temperature instrument (QCTE-157, due 12/03/04) was used to determine if the surface conditions were adequate before the required NDE was performed. The pre- cleaning, drying, cleaning method, penetrant application, dwell time, penetrant removal, developer application, and final interpretations were performed satisfactorily.

Indications identified during the NDE process were removed and retested. Test results were documented on a Liquid Penetrant Examination Report. Those reports were reviewed and approved by a Level III examiner.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Minimum Elements 5-7 Reference: ASME Section V, Article 6, T-621 Requirement Each procedure shall also include: (5) removing excess penetrant and drying the surface before applying the developer; (6) length of developing time before interpretation; (7)

post-examination cleaning.

Finding: This requirement was implemented. Procedure CEP-NDE-0640, Rev. 0 specified the requirements for performing both the standard (60 -150 degree F) liquid penetrant test and the high temperature (120-275 degree F) liquid penetrant test. Both tests were satisfactory demonstrated during this inspection. The NDE material used for both the standard and high temperature liquid penetrant testing was from Sherwin manufacturing. Cleaner DR-60, Penetrant DP-51, and Developer D-100 were used for standard testing. Cleaner KO-19, Penetrant KO-17, and Developer D-350 were used for high temperature testing. The weld joint fit ups (FW- 2 through 9) and weld joint deposits complied with the applicable drawings and welding procedure requirements.

Welded surfaces were ground as required. A calibrated light meter (KTC-131, due Page 17 of 25

08/06/05) and temperature instrument (QCTE-157, due 12/03/04) was used to determine if the surface conditions were adequate before the required NDE was performed. The pre- cleaning, drying, cleaning method, penetrant application, dwell time, penetrant removal, developer application, and final interpretations were performed satisfactorily.

Indications identified during the NDE process were removed and retested. Test results were documented on a Liquid Penetrant Examination Report. Those reports were reviewed and approved by a Level III examiner.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Non Standard Temperature Reference: ASME Section V, Article 6, T-653 Requirement When it is not practical to conduct a liquid penetrant examination within the range of 50 to 125 degrees F, the examination procedure at the proposed higher or lower temperature range requires qualification. This shall require the use of a quench cracked aluminum block which in this article is designated as a liquid penetrant comparator block.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0 step 5.1 required a low temperature procedure for temperatures between 40 and 60 degrees F, a standard procedure for temperatures between 60 and 150 degrees F, and a high tempererature procedure for temperatures between 120 and 275 degrees F. The high temperature procedure was contained in Attachment 9.3 and its procedure qualification record (PQR)

was attached to the back of Attachment 9.3. The PQR contained a photo of the quench cracked aluminum (comparitor) block that was used.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Relevant Indications Reference: ASME Section III, Article NB-5352 Requirement Indications with major dimensions greater than 1/16" shall be considered relevant.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0, Attachment 9.1 defined relevant indications as those with major dimensions greater than 1/16".

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; PT Solvents Reference: ASME Section V, Article 6, T-673.3 Requirement Flushing the surface with solvent, following application of the penetrant and prior to developing is prohibited.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0, step 5.9, first NOTE prohibited flushing the surface with solvents.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Page 18 of 25

.

Category: Weld Testing Topic: Proc-Quals; PT Surface Preparation Reference: ASME Section V, Article 6, T-642 (b)

Requirement Prior to each PT exam, the surface to be examined and all adjacent areas within an inch must be dry and clean.

Finding: This requirement was implemented. CEP-NDE-0640, Rev. 0, Section 5.5 required that the surface to be examined, and all adjacent areas within one inch, be dry and clean prior to liquid penetrant testing.

Documents CEP-NDE-0640, "Liquid Penetrant Examination (PT), Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; Tack Welds Reference: ASME Section III, Article NB-4231.1 Requirement Tack welds used to secure alignment shall either be removed completely when they have served their purpose, or their stopping and starting ends shall be properly prepared by grinding or other suitable means so that they may be satisfactorily incorporated into the final weld. When tack welds are to become part of the finished weld, they shall be visually examined and defective tack welds shall be removed.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, steps 6.4.1 and 6.4.2 required that tack welds be removed or properly prepared for integration into the final weld. The lid-to-shell fit-up and tack welding operations were performed and initially accepted by Holtec before the MPC mock-up was shipped to the site. Visual examinations of the lid-to-shell tack welds were performed by the licensee prior to starting the lid-to-shell weld, with no discrepancies noted.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Arc strikes Reference: ASME Section III, Article NF-5360 Requirement Arc strikes and blemishes in the weld or base material are acceptable, provided no cracking is visually detected.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, Step 6.11.4 stated that arc strikes and weld splatter were unacceptable. The last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 stated that arc strikes and blemishes were acceptable provided no cracking was visually detected.

Although the two procedure sections differed, they both met the requirements of this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

.

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Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Cracks Reference: ASME Section III, Article NF-5360 Requirement Cracks are unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 specified that cracks were unacceptable.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Craters Reference: ASME Section III, Article NF-5360 Requirement Craters outside the weld area are irrelevant, provided there are no cracks.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined irrelevant craters as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Fusion Reference: ASME Section III, Article NF-5360 Requirement For fillet welds, incomplete fusion of more than 3/8" (10 mm) in any 4" (102 mm)

segment is unacceptable. For fillet welds, incomplete fusion of more than 1/4" (6 mm)

in welds less than 4" (102 mm) is unacceptable. For groove welds, any incomplete fusion is unacceptable. Rounded end conditions (starts and stops) shall not be considered indications of incomplete fusion.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined the unacceptable degrees of incomplete fusion as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Lengths Reference: ASME Section III, Article NF-5360 Requirement For welds 3" and longer, weld lengths shorter than specified by more than 1/4" (6 mm)

are unacceptable. For welds less than 3" long, weld lengths shorter than specified by more than 1/8" (3.2 mm) are unacceptable. Intermittent welds not spaced within 1" (25 mm) of the specified location are unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable weld lengths as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

.

Page 20 of 25

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Overlap Reference: ASME Section III, Article NF-5360 Requirement When fusion in the overlap cannot be verified, an overlap length of less than 3/8" (10 mm) in any 4" (102 mm) weld segment is unacceptable. When fusion in the overlap cannot be verified, an overlap length of less than 1/4" (6 mm) in any weld segment less than 4" (102 mm) is unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable overlap lengths as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Porosity Reference: ASME Section III, Article NF-5360 Requirement The following degrees of random porosity are unacceptable: (1) The sum of the diameters of random porosity exceeding 3/8" (10 mm) in any one linear inch of weld; (2) The sum of the diameters of random porosity exceeding 3/4" (19 mm) in any 12 linear inches (305 mm) of weld; (3) Four or more pores aligned, AND the pores separated by 1/16" (1.6 mm) or less edge to edge.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable random porosity as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Slag Reference: ASME Section III, Article NF-5360 Requirement Slag 1/8" (3.2 mm) or less in size is irrelevant. Slag greater than 1/4" (6 mm) in size after cleaning is unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable slag size as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Thickness Reference: ASME Section III, Article NF-5360 Requirement Welds thinner than specified by greater than 1/16" (1.6 mm) for more than on-fourth the weld length are unacceptable. Welds thicker than specified are unacceptable if they interfere with mating parts.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable weld thickness as specified in this article.

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Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria - Undercut Reference: ASME Section III, Article NF-5360 Requirement Undercuts deeper than 1/32" (.8 mm) on one side for the full length of the weld are unacceptable. Undercuts deeper than 1/32" (.8 mm) on one side for one-half the length of the weld AND deeper than 1/16" (1.6 mm) on the same side for one-fourth the length of the weld, are unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 defined acceptable undercut depth as specified in this article.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Acceptance Criteria-Melt through Reference: ASME Section III, Article NF-5360 Requirement Any melt-through that results in a hole is unacceptable.

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, last attachment, "Visual Acceptance Standards for Dry Cask Storage On Site Welding Activities", Rev. 00 specified that melt-through was unacceptable.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Eye Position and Lighting Reference: ASME Section V, Article 9, T-952 Requirement The eye must be within 24" (610 mm) of the surface, at an angle not less than 30 degrees.

The light intensity must be at least 100 footcandles (2001 code edition).

The light intensity must be at least 15 footcandles for general examination and 50 footcandles for the detection and study of small anomalies (1995 code edition).

Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0, Steps 5.3 and 5.4 contained the eye position and light intensity requirements specified in the 1995 edition of ASME Section V.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Minimum Elements Reference: ASME Section V, Article 9, T-921.1 Requirement Each procedure shall include: (1) technique used; (2) surface conditions; (3) surface preparation and cleaning; (4) method or tool(s) required for surface preparation; (5)

direct or indirect viewing method; (6) special illumination; (7) equipment to be used; (8) sequence of performing examination; (9) data to be documented; (10) report forms to be completed; (11) personnel qualifications; (12) procedure qualification reference Finding: This requirement was implemented. CEP-NDE-0695, Rev. 0 contained all 12 of the Page 22 of 25

elements required by this article for Visual Testing procedures.

Documents CEP-NDE-0695, "Visual Welding Inspection ASME, ANSI B31.1", Rev. 0 Reviewed:

Category: Weld Testing Topic: Proc-Quals; VT Requalification Reference: ASME Section V, Article 9, T-921.2 Requirement Whenever a change is made to the following essential variables in a VT Examination procedure, the procedure must be requalified: (1) technique used; (2) surface conditions; (3) direct or indirect viewing method; (4) special illumination; (5)

personnel qualifications; (6) procedure qualification reference.

Finding: This requirement was implemented. The licensee qualified all revisions to their visual testing procedures, whether or not an essential variable had changed.

Documents None Reviewed:

Category: Training Topic: Dry Run Exercise; Loading Reference: CoC 1014 Condition 10.f / FSAR 1014 Section 12.2.2 Requirement A dry run training exercise of the loading, closure, handling, unloading and transfer of the HI-STORM 100 cask system shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The dry run shall include MPC welding, NDE inspections, hydrostatic testing, draining, and moisture removal (by vacuum drying or forced helium dehydration, as applicable), helium backfilling, and leakage testing.

Finding: This requirement was implemented for the MPC welding and NDE inspection portions of the dry run training exercise. Welding of the MPC lid-to-shell, vent and drain port cover plates (including set screws), and closure ring segments was demonstrated and all welds were tested by visual examinations and liquid penetrant examinations. All welding and weld testing was performed in accordance with the Weld Traveler Package and all data was collected on the Weld Data Sheets. The process was controlled and the procedural requirements were adhered to. Although procedure placekeeping was inconsistent at times, no performance discrepancies were identified.

The welding operators demonstrated the hot wire technique during the final weld pass for the MPC lid-to-shell weld using weld procedure WPS 08-08-T-901, Rev. 0. The welding requirements for the hot wire technique differed from normal GTAW welding only in voltage and amperage ranges and in travel speed.

Documents WPS 08-08-T-901, "GTAW-Hot Wire", Rev. 0 Reviewed:

Category: Training Topic: Dry Run Exercise; Unloading Reference: CoC 1014 Condition 10.j / FSAR 1014 Section 12.2.2 Requirement A dry run training exercise of the loading, closure, handling, unloading and transfer of the HI-STORM 100 cask system shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The dry run shall include MPC unloading, cooling fuel assemblies, flooding the MPC cavity, and removing MPC welds.

Finding: This requirement was implemented for the MPC weld removal portion of the dry run Page 23 of 25

training exercise. The MPC lid removal demonstration was conducted on July 22, 2004 under procedure DFS-MPC Vent and Drain Port Cutting and MPC Lid Cutting, Rev. 0.

The procedure overall sequence was as follows: 1) drill through the closure ring over the vent and drain ports with a 4" hole saw; 2) drill through the vent and drain port cover plates with a 3.5" hole saw, exposing the vent and drain port caps; 3) Install both Removable Valve Operating Assemblies (RVOAs) and sample for combustible gasses; 4) Remove the lid-to-shell weld with a lathe cutter.

The demonstration included radiological safety, foreign material exclusion, and calculating the maximum time to recirculation. However, it did not include gas sampling for determining fuel integrity, venting, reflooding, or cooldown. The procedure specified that those operations would be demonstrated at a later date.

The videotape indicated the demonstration was conducted in accordance with the procedure.

Documents DFS-MPC Vent and Drain Port Cutting and MPC Lid Cutting, Rev. 0 Reviewed: MPC Lid Removal Videotape dated July 22, 2004 Category: Radiological Topic: ALARA Pre-Job Briefings Reference: FSAR 1014, Sect 10.1.1 Requirement Pre-job ALARA briefings should be held with workers and radiological protection personnel prior to work on or around the system.

Finding: This requirement was implemented. A pre-job briefing was conducted on August 31, 2004 at 9:00 am. The DFS Project Manager presented the overall scope of the demonstration, including schedule and roles and responsibilities. He emphasized that there would be no time pressure during the demonstration.

The Radiation Protection Supervisor presented the ALARA portion of the pre-job briefing. He covered area postings, exposure limits, expected dose rates (based on ANO history), alarming dosimeter setpoints, low dose rate areas, adherence to the Radiation Work Permit, and how neutron dose would be accounted for.

The Radiation Protection Supervisor also presented the industrial safety briefing. He discussed hard hats, footwear, eye and face protection, tripping hazards, self checking, error likely situations, communications, questioning attitude, lessons learned from other sites, and stop work criteria. Finally he covered the Foreign Material Exclusion (FME)

controls that would be used during the demonstration.

Documents None Reviewed:

Category: Procedures & Tech Specs Topic: Foreign Material Exclusion Reference: CoC 1014, License Condition 2 Requirement Written operating procedures shall be prepared for cask handling, loading, movement, surveillance and maintenance. The user's site-specific written procedures shall be consistent with the technical basis.

Page 24 of 25

Finding: This requirement was implemented. Entergy procedure ADM-0092, Rev. 2 specified the following FME requirements: 1) FME Zones are established and properly posted; 2)

workers are briefed on the FME requirements; 3) a contact person is designated; 4) the Tool and Material Control Log is maintained; 5) workers check with the contact person before entering the zone; 6) materials and tools are logged in and out, and; 7)

cleanliness and good housekeeping practices are maintained.

The procedural requirements for establishing the FME Zone for the MPC Mock Up demonstration were implemented satisfactorily. An FME Zone was established around the MPC mock-up in the pipe fabrication shop. The pre-job meeting specified that FME requirements would be practiced for the demonstration. Signs were posted to designate the area as an FME Zone. The FME contact was assigned and posted adjacent to the zone entrance. A Tool and Material Control Log was maintained. Personnel, tools and materials were logged in and out. Cleanliness and good housekeeping practices were maintained during the demonstration.

Documents ADM-0092, "Foreign Material Exclusion - FME", Rev. 2 Reviewed:

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IR 07200049/2004001

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2004 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 19(0) 7(0) 8(0) 10(0) 11(0) 12(0) Security Operator Exams 301(0) Emergency Planning Other

IR 07200049/2004001

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SUBJECT:

Dear Mr. Hinnenkamp:

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