IR 05000382/1986028

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/86-28.Ack That Rev 3 to Procedure UNT-5-004 May Be Limited in Scope to Installed Equipment & Not Specifically Violated

ML20234E507
Person / Time
Site:	Waterford
Issue date:	07/02/1987
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8707070593
Download: ML20234E507 (2)

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. 9 3 In Reply Refer To:

Docket: 50-382/86-28 M gg Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations N-80 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

Thank you for your letter of April 16, 1987, in response to our letter I and Notice of Violation dated March 17, 198 We have reviewed your reply and !

find it responsive to the concerns raised in our Notice of Violation. We acknowledge that your Procedure UNT-5-004, Revision 3, may be limited in scope

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to installed equipment and therefore was not specifically violated; however, 1

the failure of your Procedure ME-7-002, Revision 5 to assure proper restoration of equipment following a bench test is still in violation of the requirements of 10 CFR 50, Appendix B, Criterion V to provide documented procedures of a type appropriate to the circumstance We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

.Dricinal Signed by:

R.E.HALU J. E. Gagliardo, Chief Reactor Projects Branch cc:

Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P. O. Box B Killona, Louisiana 70066 RIV:RSB/0S y)Y OS gg RSB

/N RPB JRBoardman:gt DMHunnicutt TFWesterman gJEGagliardo 7 / 1 /87 ]/)/87 1/t/87 7/(/87

?Dk 3 670702 F l0$[K 05000382PDR I

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. 1 -4 Louisiana Power & Light Company 2

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Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P. O. Box B 1 Killona, Louisiana 70066 1

. Middle South Services ATTN: Mr. R. T. Lally l P. O. Box 61000  ! '

New Orleans, Louisiana 70161 Louisiana Power & Light Company ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340  ;

New Orleans, Louisiana 70160 i

Louisiana Radiation Control Program Director I i

bec to DMB (IE01)

bcc distrib. by RIV: .

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• RPB *D. Weiss, RM/ALF i

• RRI R. D. Martin, RA i

• SectionChief(RPB/A) DRSP RPSB *RSB

• MIS System * Project Inspector, RPB

• RSTS Operator *R. Hall

• RIV File NRR Project Manager

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LO UlSI POWE R & AN L1GHTA / 317 NEWBARONNE

STREET ORLEANS, LOUISlANA P. O BOX 60340 70160 * (504) 595 3100 U1'sl$ES SE April 16, 1987  ?

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W3P87-1010 A4.05 QA

' % Fu; . l U.S. Nuclear Regulatory Commission L M \~- :p!":I }li ATTN: Document Control Desk ;j

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ll Washington, D.C. 20555 ~

g 2 l jgp i r i L i Subject: Waterford 3 SES I Docket No. 50-382

, License No. NPF-38 NRC Inspection Report 86-28

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Attached is the Louisiana Power and Light Company (LP&L) y,esponse to Violation No. 8628-01 identified in Inspection Report No. 86-2 If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-349 l l

l Very truly yours, C

oY l A h K.W. Cook Nuclear Safety and Regulatory Affairs Manager T( y s

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KWC:KLB:ssf .

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\ cu cc: R.D. Martin, NRC Region IV s G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR V'

g NRC Resident Inspectors Office ,

E.L. Blake

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W.M. Stevenson s'

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,_ g "AN EOUAL OPPORTUNITY EMPLOYER"

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Attcch2:nt to W3P87-1010

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Sheet 1 of 2

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LP&L Response To Violation No. 8628-01 1 VIOLATION No. 8628-01 Failure to Follow Procedures for Control of Temporary Modifications 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be accomplished in accordance with approved procedures. ANSI N18.7-1976, to which the licensee is committed, Section 5.2.2, requires that procedures shall be followed. Licensee Procedure UNT-5-004, Revision 3, " Administrative Procedure Temporary Alteration Control, identifies specific requirements for the control and restoration of tcmporary modifications. This procedure specifies that procedures requiring temporary modifications shall either appropriately reference UNT-5-004, or contain the specified controls for temporary modification Contrary to the above, the NRC inspector on November 19, 1986, identified that licensee Procedure ME-7-002, Revision 5 " Maintenance Procedure Molded-Case Circuit Breakers and Thermal Relays," did not contain required

,. controls for temporary removal and replacement of current limiting fuses during performance testing of the circuit breakers, nor reference UNT-5-00 .

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This is a Severity Level IV violatio RESPONSE (1) Reason for the Violation This violation cites procedure ME-7-002, Molded Case Circuit Breakers and Thermal Relays, "for not containing required controls for temporary alterations as specified by UNT-5-004, Temporary Alteration control". Although ME-7-002. inadvertently omitted steps that would ensure proper restoration of equipment to its design operating condition, we do not feel that it viol'ated UNT-5-004. UNT-5-004 is a procedure written to control temporary alterations to existing, installed, operational plant equipment. ME-7-002 is a procedure which removes a piece of equipment and bench tests it. Temporary changes,

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modifications, disassembly or reassembly of the equipment once removed from the plant is not considered a temporary alteration and should not fall under the requirements of UNT-5-004. Nonetheless, procedures controlling maintenance in these situations must be adequate to ensure complete and proper restoration of equipment; this is the area in which ME-7-002 was deficien (2) Corrective Action That Has Been Taken ME-7-002 has been revised to require removal of any shorting alocks that could have been previously installed, re-installation of fuses and independent verification of the came. The possibility that shorting devices could have been left in breakers previously tested by this procedure has also been considered. We are confident that this is not the case based on the following:

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. W3P87-1010

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Sheet 2 of 2  !

. Section 8.6 (Thermal Element Time Delay Test) of ME-7-002 did ,

contain a note requiring removal of shorting devices and j re-installation of fuses. Section.8.6 is required each'tima the breaker is teste (Section 8.5, Instantaneous Trip-Test, had no such provisions, but is only required on newly installed breakers.)

. To date there have been no instances of shorting devices found in breakers removed from service for maintenanc All of the Electrical Maintenance procedures which cover circuit breaker testing (ME-3-315, ME-3-325, ME-3-327, ME-3-330,

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ME-4-111 ME-4-131, ME-4-143, ME-4-145, ME-4-146, ME-4-155, ME-7-100) have been reviewed and no similar deficiencies were foun ,

(3) Corrective Action To Be Taken j No further action deemed necessary w-(4) Date When Full Compliance Will Be Achieved -

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Full compliance was achieved on April 8, 198 l

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