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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-05
	ML20149K845
Person / Time
Site:	Waterford
Issue date:	07/25/1997
From:	Howell A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C; ENTERGY OPERATIONS, INC.
References
	50-382-97-05, 50-382-97-5, NUDOCS 9707300189
	Download: ML20149K845 (4)
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- "'Cvt UNITED SrATES

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NUCLEAR REGULATORY COMMISSION

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REGION IV

S b'8- [ 611 RYAN PLAZA DRIVE, SUITE 400

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8 AR LINGTON, TE X AS 760118064

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July 25, 1997

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Charles M. Dugger, Vice President

Operations - Waterford 3

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

SUBJECT: NRC INSPECTION REPORT 50-382/97-05

Dear Mr. Dugger:

l Thank you for your letter of July 8,1997, in response to our letter and Notice of Violation

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dated May 23,1997. We have reviewed your reply and find it responsive to the concerns

raised in our Notice of Violation regarding Examples 1,2, and 3 of the' violation. -We will i

review the implementation of your corrective actions during a future inspection to

determine that full compliance has been achieved and will be maintained regarding

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4 Examples 1, 2, and 3.

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- As a result of our review of Example 4 (involving welding on a containment spray line as 1

opposed to a safety injection line), we have.found that additional information is needed. j

This need was discussed with Mr. T. Gaudet during a telephone call on July 22,1997. l

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Specifically, the proposed corrective action for Example 4 was only to counsel the team !

leader. However, we identified in our inspection report that Example 4 revealed many

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breached barriers. The additional information that we are requesting should address your

proposed corrective actions to remedy the ca ases that led to all of the barrier failures.

. As agreed during our telephone call, please provide the additional infermation by

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August 22,1997. This time extension will enable your completion of the root cause

analysis and the finalization of corrective actions.

Sincerely, 1

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Arthur T. Howell 111, Director

Division of Reactor Safety

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Docket No.: 50-382

License No.: NPF-38 ,.

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9707300189 970725

, PDR ADOCK 05000382

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Entergy Operations, Inc. -2-

cc:

Executive Vice President and

Chief Operating Officer I

Entergy Operations, Inc. i

P.O. Box 31995 l

Jackson, Mississippi 39286-1995

Vice President, Operations Support

Entergy Operations, Inc. l

P.O. Box 31995 ,

Jackson, Mississippi 39286-1995 l

Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, Mississippi 39205

General Manager, Plant Operations

Waterford 3 SES

Entergy Operations, Inc.

~ P.O. Box B

Killona, Louisiana 70066

Manager - Licensing

Waterford 3 SES

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

Chairman -

Louisiana Public Service Commission

One American Place, Suite 1630

Baton Rouge, Louisiana 70825-1697

Director, Nuclear Safety &

Regulatory Affairs

Waterford 3 SES

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

William H. Spell, Administrator

Louisiana Radiation Protection Division

P.O. Box 82135

Baton Rouge, Louisiana 70884-2135

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Entergy Operations, Inc. -3-

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Parish President l

St. Charles Parish

P.O. Box 302

Hahnville, Louisiana 70057 ,

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Mr. William A. Cross

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Bethesda Licensing Office

3 Metro Center

Suite 610

Bethesda, Maryland 20814

Winston & Strawn

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1400 L Street, N.W.

Washington, D.C. 20005-3502

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Regional Administrator Resident inspector

DRP Director DRS-PSB

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Project Engineer (DRP/D) RIV File

Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10) l

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Ente perations Inc.

KWona LA 70CE6 i

, Tel 504 739 6242 I

Early C. Ewing,111

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W3F1-97-0182 i

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July 8,1997

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U.S. Nuclear Regulatory Commission e I

ATTN: Document Control Desk J ag -

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Washington, D.C. 20555

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Subject: Waterford 3 SES

Docket No. 50-382

License No. NPF-38 l

NRC Inspection Report 97-05

Reply to Notice of Violation

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Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in

Attachment i the response to the violation identified in Enclosure 1 of the subject

Inspection Report.

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if you have any questions concerning this response, please contact

me at (504) 739-6242 or Tim Gaudet at (504) 739-6666

Very truly yours,

C

$1./

E.C. Ewing

Director,

Nuclear Safety & Regulatory Affairs

ECE/GCS/tjs

Attachment

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, NRC Inspection Report 97-05

Reply to Notice of Violation

W3F1-97-0182

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Page 2

July 8,1997 l

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cc: E.W.'Merschoff (NRC Region IV) .

C.P. Patel (NRC-NRR)

J. Smith

N.S. Reynolds l

NRC Resident inspectors Office

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W3F1-97-0182

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ATTACHMENT 1

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l ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN

. ENCLOSURE 1 OF INSPECTION REPORT 97-05

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VIOLATION NO. 9705-03

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i Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be

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established to assure that special processes, including welding.. .. are controlled

i. and accomplished..... in accordance with applicable codes, standards,

i specifications, criteria, and other special requirements."

Contrary to the above, measures did not assure that welding was controlled in -

i accordance with requirements in the following examples that were identified by the

l, licensee's correction program:

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l 1. Weld rod was not discarded in accordance with the requirements in

Procedure MM-001-053, in that, on five occasions from April 16-23,1997,

unattended and unaccounted for weld rods were found.

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4' 2. Stainless steel welds were contaminated contrary to the requirements in

Procedure MM-001-050 on two occasions, March 6 and April 15,1997, when

! carbon steel wire brushes, chains and work tables came into contact with

l weld surfaces. .

3. Final quality control inspections of stud welds were not performed as required ~

by Procedure NOECS-100 on April 16,1997.

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p 4. A coupling was not welded on a safety injection line, as required by Work

Order 001153561. The coupling was erroneously welded on April 20,1997,

- to a containment spray line.

} . These examples constitute a Severity Level IV violation (Supplement 1) (50-

!' --382/9705-03).

, RESPONSE

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(1)- Reason for the Violation

k- All four examples of failure to control the welding program were identified by

Waterford 3 and entered into the corrective action program. Each example

i was evaluated in concert with other program deficiencies to draw conclusions

regarding process control. Evaluation results indicate the process, in general,

i is well defined and controlled. Moreover, the corrective action program

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continues to provide feedback and corrective actions that promote process

. improvement.

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Analysis of each example indicated a need for both specific and broad

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- corrective actions. Specific root causes and corrective actions for each

violation were formulated to preclude the recurrence of similar examples. The

j root causes and corrective actions for each example are identified below.

j included within those actions, where appropriate, are plans to conduct

additional training. We believG additional training is warranted to address the

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, brcader implications of this violation; namely, to ensure that welding activities

]- - are accomplished in accordance with program controls.

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!- Example 1

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l The root cause of this example is inadequate training. Personnel using

welding material were not properly trained on plant requirements related to

l disposal and control of filler material. During the outage, many of the

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individuals using welding material were contractors who were temporarily 1

_ assigned to Waterford 3. These individuals were provided reading material

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! on the proper control of filler material but were never given formal classroom '

[ training.

I Contributing to this example is inadequate administrative controls. There

j' were no administrative controls to ensure that welders did not check out

!- excessive quantities of welding filler material. According to site Administrative

l Procedure MM-001-053, " Control of Welding Consumables (Filler Material),"

j' welders could request any quantity of welding filler material as long as they

were qualified to use that filler material. As a result, excessive quantities of

j welding filler material were sometimes requested for minor welding activities,

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and the unused filler material was not always returned.

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f' Also contributing to this example is poor work practice. The use of rod stub

i- disposal barrels as a means of disposing welding filler material proved to be

. inadequate. The rod stub disposal barrels were not properly maintained and

j' were not emptied when they became full. As a result, rod stubs were

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sometimes falling out of the barrels.

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l Example 2

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[ The root cause for this example is an inadequate procedure. Site

l Administrative procedure MM-001-050, " General Welding Requirements,"

does not specifically state that carbon steel wire brushes should not be used

on stainless steel material. The procedure states that tools used on one type

[ . of base material such as carbon steel are not to be used on another type of

i material such as stainless steel. This statement does not preclude using

carbon steel brushes on stainless steel material, but prohibits using the same

l tool on both carbon and stainless steel materials.

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Contributing to this example is inadequate administrative controls. Stainless

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steel wire brushes are required to be color coded red to distinguish them from

carbon steel brushes. . It was discovered in some instances that carbon steel

brushes were incorrectly color coded red.

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Regarding stainless steel welds contacting carbon steel surfaces, it was

determined, as documented in engineering input to condition report CR-97-

0527, that casual contact between the stainless steel and the carbon steel

surface of the work table and the chainfall will not contaminate the stainless i

steel welds.

Example 3 I

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The root cause of this example is inadequate procedure. The Weld j

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Specification Documentation Sheet (WSDS) in procedure MM-001-054,

" Control and Documentation of Welding," which specifies when QA visual j

examination of welds is required did not clearly indicate that all the stud welds j

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associated with the work should be examined. Initially only two of the

preproduction testing welds were inspected by QA. !

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Contributing to this example is poor communication. The Quality Assurance l

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Inspectors were aware that stud welds were being placed on the gantry crane

rail holddown bolts and that they were required to inspect the welds after

installation. However, the lead engineer on this task was not on site when

this activity was completed and notification that the welds had been :

completed and ready for inspection was not communicated to QA. As a

result, the work was completed and nuts and plates were placed over the stud

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welds before QA could inspect them.

Example 4 .

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The root cause for this example is inattention to detail. The individuals tasked

to weld a coupling on a safety injection line were provided with isometric

drawings showing the location of the line to be welded on. They incorrectly

welded on the containment spray line which was in the vicinity of the safety

injection line. Had these individuals paid closer attention to detail and

matched the penetration number on the isometric to the penetration number

on the containment wall, they would not have made this error.

(2) Corrective Steps That Have Been Taken and the Results Achieved

The corrective steps that have been taken for each example of failure to

control the welding process at Waterford 3 are provided below:

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Example 1

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Filler material training was conducted on April 25 and April 28,1997.

, Welding foreman and tool room attendants were required to attend the l

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training. Those welders who did not attend the training were not allowed to l

check out welding material. j

A satellite filler material issue facility was established to be used during heavy I

welding periods for issuing filler material outside the protected area to ,

enhance the filler material issue process. )

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Tighter controls have been placed on the issuance of filler material. j

Individuals requesting filler material are required to jus (n'y reason for usage. 1

l The quantity of filler material requested and used is tracked. Unused material

and rod stubs are returned to storage. l

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All covered electrodes or welding rods are issued in either a rod caddie, a ;

leather pouch or equivalent container. i

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Rod stub cans are issued to welders when they request filler material.

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Rod stub disposal barrels will no longer be used for general disposal of

welding filler material.

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Example 2

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Quality Assurance issued a Stop Work Order to place a hold on activities

where there was a potential for carbon steel brushes to be used on stainless i

steel material.

The Filler Material Data Base was reviewed to identify stainless we: ding l

activities in order to determine the work packages involved.

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Engineering evaluated the effect of using carbon steel brushes on various

stainless steel components and determined that they were not adversely j

affected.

Wire brushes were verified to be properly color coded.

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Carbon steel brushes were removed from job locations, tool rooms, and the l

plant warehouses.

Tighter controls have been placed on the issuance of wire brushes.

Individuals requesting wire brushes are required to justify reason for usage.

Welders were instructed on the proper use of wire brushes. This included the j

use of wire brushes on joints constructed of dissimilar material.

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) Appropriate Management personnel discussed his issue with their

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supervisors who held discussions with their employ 6es.

L Example 3

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l The nuts and plates were removed from the gantry crane rail holddown bolts

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' A discussion of this event was held with appropriate' personnel to ,

reemphasize the requirement for QA inspections of welds. I

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i Example 4

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[ The individual leading the team responsible for welding on the incorrect line

was counseled.

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I (3) Corrective Steos Which Will Be Taken to Avoid Further Violations - .

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l- The corrective steps which will be taken to avoid further violations for each

!. example of failure to control the welding process at Waterford 3 are provided

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Example 1

Administrative procedure MM-001-053, " Control of Welding Consumables,"

.will be revised to specify training requirements for the tool room lead, tool

i room filler material issue personnel, and welders. This revision will be

completed by 10/31/97.

! - Example 2

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_ Mechanical Maintenance procedure MM-001-050, " General Welding

l Requirements" and MD-001-012, " Tool Control,"_will be revised to include a

i- statement that only stainless steel brushes should be used on stainless steel

components. This revision will be completed by 10/31/97.

f- Formal training will be developed for workers and contractors that normally

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use or issue wire brushes and grinding wheels. Training will be developed by

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12/31/97. New workers and contractors will receive training before attempting

[ any welding activities.

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j Example 3

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t - Mechanical Maintenance procedure MM-001-054, " Control and

[ Documentation of Welding," will be revised to enhance administrative controls

i regarding Weld Specification Documentation Sheet preparation. This revision

. will be completed by 12/1/97.

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Example 4

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l- Waterford 3 believes that the corrective action taken for example 4 is

j adequate to prec;ude this type of occurrence.

(4) Date When Full Comoliance Will Be Achieved

' Full compliance will be achieved by December 31,1997,

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ML20149K845

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