ML19332E306

Responds to Violations Noted in Insp Rept 50-382/89-30. Corrective Action:Corresponding Controlled Matl Tag & Controlled Filter Matl Index Card for Lot Number 10219-1 Corrected to Reflect Correct Lot Number 10217-1

ML19332E306
Person / Time
Site:	Waterford
Issue date:	11/29/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-2150, NUDOCS 8912070053
Download: ML19332E306 (6)

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. Louinione Power O Light Company ij c ;: hp ,

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,; Tel. 504 595 2805

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LNdvember'29, 19891 -

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'U.Sh Nuclea'r; Regulatory Commission i  ; ATTN:'jDocument: Control Desk

Washington, D;C. -20555; y .i; .

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Subject:

Waterford .3 SES :

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LDocket No. 50-382' >

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. License No.'NPF-38 4

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1NRC Inspection Report 89 ]

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Gentlement.

'U-  : In accordance with 10' CFR Part' 2.201, Louisiana Power & Light .hereby:

, , ' submits in Attachment ~ 1 the response to the Violation identified in-T  ? 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..

N L.Very:truly!yours, ,

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<cct.fMessrs.'R.D. Martin, NRC Region IV F.J. Hebdon,.NRC-NRR D.L. Wigginton, NRC-NRR l E.L. Blake' j W.M. Stevenson .

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W3P89-2150

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e ATTACHMENT 1 U LP&L RES'PONSE T0'THE VIOLATION IDENTIFIED IN APPENDIX A i 0F INSPECTION REPORT 89-30 VIOLATION 8930-01 Criterion V of Appendix B t.o 10.CFR Part 50 requires activities affecting quality to be' prescribed by documented procsit vs'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 i

.be responsible for all welding activities and for conducting a weekly audit on Control-of Filler Materials in the Filler Material Issue Facility...."

"The Welding Coordinator or HMS (Mechanical Maintenance Supervisor)- shall verify the transfer of heat number and/or lot number from the filler material centainer 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:

1. There was no documented evidence available to substantiate.that the required weekly audits had.been performed.

2. . 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 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 s

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 i misinterpretation. The following information explains this lack of

. documentation.

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b' i= Page 2 of 5 Die' purpose of Procedure HH-001-053 is to provide a method in '

b controlling the storage andiissuance of welding and brazing filler-materials. One of the intents of the procedure was to proceduralize

.the Weld, Coordinators' responsibilities with regard to the control of

~ filler materials in the Filler Material Issue Facility.- These

, responsibilities' include:.

4 (f 'L Verification of heat and lot number transfers from the filler material containers to Control Material Tags-and Control Material Index Cards; Monitoring'the Filler Material Issue Facility on a weekly basis to ensure-procedural compliance; and'

Resolving any filler material-control concerns, n Paragraph 4.2' states, "The Weld Coordinator shall be responsible for all-welding activities 1and for conducting a weekly audit on Control of ,

Filler Materials in the Filler Material Issue Facility." When this provision for audits was added to Revision 4 of the procedure, it was not in' tended that the weid coordinator perform. weekly " formalized"

. audits with' documented auditable: findings on the control of weld filler materials.. =With this intention, no procedura11 zed audit or

. log forms-were' included and required to be completed as attachments to MM-001-053.- Consequently, no forms have been completed and kept on

~ file. The specific intent was for regular surveillances on a weekly

= basis to be performed by the Weld Coordinator. Therefore. the wording of Paragraph-4.2 was poor cnd 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 l 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 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 MMS

-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 veld 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 perforned by the Weld Coordinator.

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f For Example 3, the tool room attendant inadvertently transposed the E . incorrect lot number for 1/8 inch Type E-7018 electrodes. The correct- '

q lot number (30920AG02) was transposed as 2C920AG02.

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(2)' CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED.

j Example 1 h s The individua1Linvolved has been counselled on'the importance of ~!

E procedure compliance and the significance of. assuming they were meeting the_ intent of the procedure. The individual should have f initiated a procedure change.to clarify the intent or complied with I

the common interpretation of an audit.

-Example 2 The original transfer requisition, TR-5026 for the 1/8 dnch Type  ;

E309-16 electrodes was reviewed. Review of the TR-50t; indicated that 2 21 cans-(210 lbs) of 1/8 inch E309-16 electrodes were transferred from EBASCO to LP6L. 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' l Card for the single can of electrodes with lot number 10219-2 was l 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 material represented by lot number 10219-1.

The corresponding Controlled Material Tag and Controlled Filler Material Index Card for lot number 10219-1 has been corrected to a reflect 1the 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 el'ectrodes 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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(3) ' CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Example:1 1

, LP&L realizes'that the intentiof Paragraph 4.2 of procedure MM-001-053

-can be misleading. . Based on this, paragraph 4.2 will be revised to

, clarify.its meaning. This procedure will be revised.by' January 31, y . 1990.

4 Example.2-m The following weld' packages affected by the inadvertently transposed

-lot number (10219-1) associated with Example 2 are listed below by

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Condition Identification (CI) number and corresponding Work 3 Authorization l(WA):.

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1. . 263447 01039963

.2.. .263474 01039810'

3. 266033 99000319

-4, 266312 99000319.

The above listed weld packages will be corrected with the correct lot

, number (10217-1) by December 30, 1989.

Example 3 ,

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-The!following' weld packages.affected by the inadvertently transposed j lot; number'(2C920AG02) associated with-Example 3 are listed below by CI number and corresponding WA..

CI WA

1. 264820 99000273 i

2. -:256061 99000190 3.. 263925. 99000278=

4. 260845 99000242 ,

5. 263474 01039810 The above listed weld packages will be corrected with the correct lot  ;

number (3C920AG02) 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, 1990. 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 compliance.

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P,  % -LP&L.: feels-that the specific errors made in the weld rod issuance'were

. isolated cases. However, in addition to the training, a follow-up. '

a 2.s "Di audit [w111-.be performed by-the-' Site Quality organization by.

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