ML20141K053

Insp Rept 50-382/97-05 on 970421-25 w/in-ofc Insp & Followup Continuing Through 970501.Violations Noted.Major Areas Inspected:Review of Licensee ISI Activities & Followup on Previously Identified Insp Findings

ML20141K053
Person / Time
Site:	Waterford
Issue date:	05/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141K015	List: ML20141K012 ML20141K033 ML20141K053
References
50-382-97-05, 50-382-97-5, NUDOCS 9705280297
Download: ML20141K053 (9)

See also: IR 05000382/1997005

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ENCLOSURE 2

i U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Docket No.: 50-382

5 License No.: NPF-38

Report No.: 50-382/97-05

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 >

Location: Hwy.18

Killona, Louisiana

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Dates: April 21-25,1997, with in-office inspection and followup continuing

through May 1,1997

Inspector: William M. McNeill, Reactor inspector, Maintenance Branch

Approved By: Dr. Date A. Powers, Chief, Maintenance Branch

Division of Reactor Safety ,

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ATTACHMENT: Supplemental Information

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9705200297 970523 ,

ADOCK 05000382

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EXECUTIVE SUMMARY

Waterford Steam Electric Station, Unit 3

NRC Inspection Report 50-382/97-05

This inspection consisted of a review of the licensee's inservice inspection activities and

followup on a previously identified inspection finding. The inspection report covers a

1-week period onsite with continuing in-office inspection.

Maintenance

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• The inservice inspection program and the eddy current testing program of steam

generator tubing were wellimplemented (Section M1.b).

• There were rec.ent problems with the implementation of the licensee's welding

program. These problems included lack of control of weld rod, carbon

! contamination of stainless steel welds, missed final quality control inspection of

t stud welds, and welding on the wrong system. These problems indicate that less

than adequate oversight of welding activities occurred during outage.

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Report Details  !

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Summarv of Plant Status ]

The plant was in the eighth refueling outage during the inspection period.

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II. Maintenance

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M1 Conduct of Maintenance i

a. 1rtsoection Scope (73753)

The inspector observed the following inservice inspection activities on safety-related ;

welds that were identified in the licensee's program. l

• Ultrasonic Examination - Pipe Weld 17-033,12-inch pipe to 12-inch x 8-inch j

reducer

• Magnetic Particle Examination - Pipe Weld 15-010, surge line to reactor

coolant loop

The inspector observed the collection of steam generator eddy current testing data.

The inspector also observed the resolution of differences between the primary and I

secondary data analysts calls by the third-party resolution analysts. {

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The inspector reviewed a sample of 20 records of examinations, which were l

performed in previous outages. By performing this review, the inspector verified the l

adequacy of the licensee's actions to complete the required examinations for the I

10-year period, which ended with this outage. In addition, the inspector reviewed a

sample of welds associated with seven valves that were previously found to be

missing from the inservice testing program (See NRC Inspection

Report 50-382/96-20).

The inspector reviewed ASME Section XI repair / replacement activities, in particular, ;

the inspector reviewed the following associated condition reports.

Conditions Reports issue Dates

97-0813 April 16,1997

97-0886 April 16,1997

97-0907 April 18,1997

97-0983 April 23,1997

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Conditions Reports issue Dates

97-0984 April 23,1997

97-0527 March 6,1997

97-0879 April 15,1997 .

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97-0883 April 16,1997

97-0952 April 21,1997 with the associated Work

Order 001153561, "LPSI Header to Reactor

Coolant Loop 1 A Penetration 36, RB-4 Col

SA and El + 15"

97-0990 April 23,1997

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b. Observations and Findingg

The inspector found the ultrasonic and magnetic particle examinations were

performed in accordance with the program, procedures, and ASME code

requirements. A geometric indication found in Pipe Weld 17-033 was dispositioned

in accordance with procedures. The inspector determined the licensee identified

and dispositioned the geometric indication in an excellent manner.

Eddy current testing was performed in accordance with the procedures. Data

acquisition and resolution were performed on site. Primary and secondary data calls

were made off site based on data transmitted via telephone lines. With about one

half of the steam generator tube examinations completed, the licensee had identified

25 tubes that required plugging.

l The inspector found no problems with the sampled records. The welds associated

with the sampled valves were noted to be exempted, in accordance with IWC-1220

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of the ASME code, or in the inservice inspection plan (but not sampled for the

10-year cycle).

The inspector did not observe welding during the inspection. However, during the j

review of condition reports, the inspector became aware of many problems with the

( implementation of the welding program. For example, the licensee had identified

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problems with the control of weld rods. These problems were identified in

! Condition Reports 97-0813, 97-0886, 97-0907, 97-0983, and 97-0984. The

licensee dispositioned Condition Report 97-0907 as significant and identified a

degraded trend requiring a root cause analysis, in general, the condition reports

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noted the loss of control in the fabrication shop (outside the protected area), and

j documented the f ailures to follow Procedure MM-001-053 on how to properly

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discard rods. Condition Report 97-0983 identified that the NRC resident inspector l

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found uncontrolled weld rod in the containment building. The inspector agreed with

the licensee's conclusion that the loss of rod control was attributable to poor work

practices.

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Additional condition reports identified other problems with the implementation of the I

welding program. Condition Reports 97-0527 and 97-0879, both identified carbon i

contamination of stainless steel welds. Condition Report 97-0527 identified that l

stainless steel pipe was in direct contact with carbon steel chain-falls and work l

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tables. Condition Report 97-0879 identified that carbon steel wire brushes were

used to clean stainless steel welds. The contamination in this case was because

Procedure MM-001-050 did not assure that welding was controlled and

accomplished in accordance with requirements. The licensee identified Condition

Report 97-0879 as significant and indicative of a degraded trend.

A stop work order was issued by the licensee on April 16,1997. The stop work

order was in effect until April 22,1997. The licensee reviewed 353 work orders.

An engineering analysis of the carbon steel contamination concluded there was not

a technical problem. The inspector agreed with the engineering analysis that the

carbon contamination was attributable to poor work practices.

The inspector noted Condition Report 97-0883 identified that final 100 percent

visual inspection of stud welding was not performed prior to the installation of

plates and nuts on the turbine building gantry crane. Procedure NOECS-100

required 100 percent final visual inspection to be performed prior to the installation

of plates and nuts. >

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in reviewing Condition Report 97-0952, the inspector found a potentially significant l

event. The inspector reviewed the associated Work Order 001153561 and j

interviewed the license's staff. The purpose of the work order was to weld a vent i

valve on Safety injection Line 2Sl8-113RL1-A, which went through Containment j

Penetration 36. However, on April 20,1997, the coupling for the vent valve was l

welded to Containment Spray Line 2CS10-7A, which went through Containment I

Penetration 34. Following the completion of the coupling weld, the next procedural  ;

step was to drill out the pipe through the coupling. This work was stopped, ,

however, prior to breaching the containment spray system due to the ending of a I

work shift. When a different work crew returned to complete the job, the problem

of welding on the wrong system was identified because the relief crew had walked

down the job on the correct line 2 days before. l

A number of barriers to f ailure were identified as breached by the inspector in

reviewing this particular event. For example, there was an experienced licensee

welder leading the work crew; there was a proper system clearance order tag-out

process accomplished; there were correct labels on the penetrations and references I

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to the penetrations in the work order; there was a quality control fit-up inspection

prior to the final welding, and the line number identified in the work order properly

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included the pipe size as 10 inches (not the 8-inch pipe that was welded on by the

crew). All of these barriers failed to identify that the work preparations had been

performed on the wrong system. There were some similarities, however, that lead

to personnel confusion. For example, both penetrations were at the same

containment azimuth, the elevation difference between the Penetrations 34 and 36

was only 6 feet, there was a platform at each penetration, and there was no

insulation on either of the pipes at the positions of interest.

The licensee, after review of these condition reports and the identification by the

licensee's quality assurance process survey of additional concerns, issued Condition

Report 97-0990 of a degraded and potentially adverse trend on April 23,1997.

This condition report required a root cause analysis. The condition report alerted

management to the problem, increased monitoring by quality assurance, instituted

more positive controls of weld rod, developed a training program for the welders,

and caused a review of the welding program by the River Bend Station welding

engineer. The initial review by the River Bend Station welding engineer was,

however, limited in scope to only weld rod control problems.

Taken in the aggregate, the above issues identified a welding program

implementation problem. This failure was the result of inadequate measures

to assure that welding activities were properly controlled and accomplished

in accordance with requirements. The failure to establish adequate measures

to assure that welding activities were properly controlled and accomplished

was a violation of Criterion IX of Appendix B to 10 CFR 50

(50-382/9705-02).

c. Conclusions

The inservice inspection program and the eddy current testing of steam generator

tubing was wellimplemented. There were recent problems with the implementation

of the welding program. These problems included lack of control of weld rod,

carbon contamination of stainless steel welds, missed final quality control

inspections of stud welds, and welding on the wrong system. The implementation

of the welding program warranted additional management attention.

M3 Maintenance Procedures and Documentation

The records were in accordance with the program, procedures, and ASME code

requirements.

M4 Maintenance Staff Knowledge and Performance

The inspector found the knowledge and performance of the inservice inspection

contractor and licensee staff were good.

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l M7 Quality Assurance in Maintenance Activities

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a. Inspection Scope 173753) '

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The inspector reviewed the licensee's planned quality assurance audit / surveillance

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- of eddy current testing activities.

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b. Observations and Findinas

The inspector noted that the licensee's response to a violation on eddy j

l current testing on steam generator tubing was to implement a change to

l Procedure NOECP 252. The procedure required an audit / surveillance of steam i

j generator eddy current testing records to ensure that (1) the approved procedure  ;

l for fixture location was used, and (2) steam generator tubing position verification

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during data acquisition. The licensee was in the process of performing this

! audit / surveillance and the fixture installation was accomplished.

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c. ' Conclusion

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l The licensee's planned quality assurance audit / surveillance of eddy current testing

l activities appeared appropriate and was stillin process.

M8 Miscellaneous Maintenance issues (92902)

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(Closed) Violation 50-382/9406-01: Installation and operation of robotic fixtures

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were not prescribed by procedures, and the positive visual tube identification was

not consistently performed, as required by procedure.

During this inspection, the inspector verified the corrective actions, described in the

licensee's response letter, dated June 3,1994, were implemented. No problems

were identified.  !

V. Manaaement Meetinas

X1 Exit Meeting Summary

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The inspector presented the inspection results to members of licensee management

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telephonic exit on May 1,1997. The licensee acknowledged the findings

presented.

The inspector asked the licensee whether any materials examined during the j

inspection should be considered proprietary. No proprietary information was j

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

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Licensee

R. Azzarello, Maintenance Manager

M. Bratton, Nondestructive Examination Level til

R. Burski, Plant Modifications and Construction Director

F. Drummond, Site Support Director

C. Dugger, Nuclear Operations Vice President

T. Gaudet, Licensing Manager i

B. Fitzsimmons, Steam Generator Project Manager

K. Hall, inservice Inspection Engineer

J. Howard, Procurement / Programs Engineering Manager

R. Ki! Son, Technical Support Quality Specialist

J. Ridgel, Mechanical Maintenance Superintendent

G. Robin, Programs Engineering Supervisor l

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J. Siller, Nondestructive Examination Supervisor

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G. Scott, Licensing Engineer

L. Thomas, Licensing Supervisor i

i G. Wilson, Acting Quality Assurance Manager

Factorv Mutual Enaineerina

J. Smoot, Authorized Nuclear Inservice Inspector

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NRC

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T. Dexter, Security inspector, Plant Support Branch

P. Harrell, Chief, Project Branch D

T. Pruett, Resident inspector, Project Branch D

INSPECTION PROCEDURES USED

IP 73753 Inservice inspection

IP 92902 Followup-Maintenance

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ITEMS OPENED, CLOSED, AND DISCUSSED  ;

Opened

50-382/9705-02 NOV . Welding Problems (Section M1.b) l

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50-382/9406-01 NOV installation Procedure and Tube l

identification (Section M8)  !

LIST OF DOCUMENTS REVIEWED ,

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Ten Year Inservice Inspection Program First Interval, Revision 6 )

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Procedure NDE 9.23, " Ultrasonic Examination of Austenitic Pipe Welds (ASME Section

XI) " Revision O j

Procedure OAP-380, " Magnetic Particle Examination," Revision 2.0

Procedure NOECP-252, " Steam Generator Eddy Current inservice Testing," Revision 3

Procedure 1253366A, "Eddynet 95 Acquisition Operating Instruction," Revision 11

Procedure 54-ISI-400-04, " Multi-Frequency Eddy Current Examination of Tubing,"

l Revision 7.11

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Design Engineering Guide 1S1-1-001, " Steam Generator Eddy Current Data Analysis

j Guidelines," Revision 4

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