IR 05000382/1987011
| ML20236K957 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/04/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8708100070 | |
| Download: ML20236K957 (2) | |
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AUG4 1987
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In Reply Refer To:
Docket:
50-382/87-11
Louisiana Power & Light Company ATTN:
J. G. Dewease, Senior Vice President Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:
l Thank you for your letter of July 24, 1987, in response to our letter and Notice of Violation dated June 24, 1987.
We have reviewed your reply and find it l
responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, l
O#nni Shor! D'/
J. E. Gaglimdo l
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 Louisiana Power & Light Company
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ATTN:
N. S. Carns, Plant Manager l
P. O. Box 8 Killona, Louisiana 70066 Middle South Services ATTN: Mr. R. T. Lally Newbr n
ouisiana 70161
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JPJahdonj C/RPB Ag\\
RPB 9 cnm JEGagJiardo 8/gf87 8/3 /87 8700100070 870804 DR ADOCK 05000382 (
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Louisiana Power & Light Co.
-2-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
Louisiana Radiation Control Program Director bec to DMB (IE01)
bec distrib. by RIV:
RPB D. Weiss, RM/ALF RRI R. D. Martin, RA Section Chief (RPB/A)
DRSP RPSB RSB MIS System Project Inspector, RPB RSTS Operator R. Hall RIV File J. Wilson, NRR Project Manager l
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LOUISlANA POWER & LIGHT COMPANY * Post Office Box 6008 New Orleans. Louisiana 70174
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i NEW ORLEAfJE PUCLIC SERVICE INC. e Post Offee Box 60340 New Orleans. Louisiana 70160
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July 24, 198/
W3P87-1729 A4.05 l
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l U.S. Nuclear Regulatory Commission j
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ATTN: Document Control Desk
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Washington, D.C. 20555 1 :
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Jul. P. 7198't
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Subject: Waterford 3 SES l
Docket No. 50-382 J Ui License No. NPF-38 NRC Inspection Report 87-11 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8711-01 identified in Inspection Report No. 87-11.
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If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.
l Very truly yours, i
K.W. Cook
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Nuclear Safety and i
Regulatory Affairs Manager KWC:PTM:ssf Attachment R.D. Martin, NRC Region IV.
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J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson
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NS20659 137@7s9b 3 n
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"AN EQUAL OPPORTUNITY EMPLOYER" 9., \\.\\
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Attachment to
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W3P87-1729 Sheet 1 of 2
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LP&L Response to Violation No. 8711-01 VIOLATION NO. 8711-01 Technical Specification (TS) 6.8.1.a requires, in part, that written procedures be established and implemented for the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Februa ry 1978.
Paragraph 9.e of Appendix A of Regulatory Guide 1.33, Revision 2, requires, in part, " General procedures for control of maintenance, repair, replacement, and modification..." Two examples of failure to follow such
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procedures are listed below.
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Procedure PE-2-006, Revision 8, " Plant Engineering Station
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Modification," is an approved procedure which iraplements a portion of
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the licensee's program to control modification work. Paragraph 5.8.4
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of Procedure PE-2-006, Revision 8, requires that modification packages l
include or reference written testing requirements.
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Contrary to the above, on May 20, 1987, the NRC inspector observed i
licensee personnel performing testing on the "A" essential chiller under Station Modification 615 without an approved written test procedure.
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Procedure UNT-4-002, Revision 1, " Field Control of Technical Documents," is an approved procedure detailing the control of documents used in quality related activities.
Paragraph 1.0 of Procedure UNT-4-002, Revision 1, requires the use of field controlled copies of technical documents "for any quality related activity that can affect the plant" including station modification packages.
Contrary to the above, on May 20, 1987, licensee personnel performing testing on the "A" essential chiller under Station Modification 615 were using uncontrolled wiring drawings of the essential chiller control circuitry.
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This is a Severity Level IV violation.
RESPONSE
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l (1) Reason For The Violation l
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Procedure PE-2-006, Revision 8, Section 5.8.4.1 requires that modification packages include or reference written testing requirements.
Depending on the complexity of the work, testing may be performed per a general test procedure or per detailed
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test instructions developed as part of the Station Modification Package.
In this instance, the Station Modification (SM-615) in Section VI, TESTING, recommended testing per general plant procedure ME-7-003, Control Circuit Testing & Maintenance after implementation of the changes in the Station Modification.
Testing on the
"A" er,sential chiller was initiated in accordance with plant procedure ME-7-003.
The violation stems from the fact
that the test procedure was not 'in-hand' at the time of test initiation. Maintenance Procedure MD-1-014, Section 5.2.13 and
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Attachment to
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Sheet 2 of 2 i
Administrative Procedure UNT-4-009 Section 5.6.3 identify requirements for test procedures to be in the possession of test personnel at the time of testing.
This is considered a personnel error in not following plant procedures.
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In the course of testing the identified components, the test personnel had need to make reference to wiring diagrams in the Station Modification Package. This package was not immediately l
available at the test location during the test.
The Action
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Engineer on location provided a working copy of the detailed drawing for reference to the testing personnel.
This drawing was not controlled as required by plant procedures, however, it was the copy used to develop the controlled drawings. The information on the drawings were similar, however, procedurally the working copy was uncontrolled and thus in violation of plant procedures.
This is considered a personnel error in not following procedures for use of controlled drawings.
For both items identified in the violation, Waterford 3 personnel failed to strictly follow procedures for maintenance and modification activities.
(2) Corrective Action That lias Been Taken A more detailed test procedure was developed to retest SM-615 and to minimize the need for drawings.
Only controlled drawings were allowed during test performance. Work has been completed on all three chillers with satisfactory test results. QA surveillance were performed during the conduct of these tests.
The electricians working on this job were counselled on their responsibilities with regard to not performing work or testing without required procedures as well as their responsibility for using field controlled copies of technical documents in the field.
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Additionally, a shop meeting was held the day after the event and I
these problems were discussed with all electricians present with emphasis on the mistakes made, how to prevent similar mistakes in the future, and the need for procedural compliance. The engineer involved and other engineers in the Engineering I&C department were counseled the day of the event on the need to adhere to procedures for proper control of drawings in the field.
(3) Corrective Action To Be Taken The details of this event and the corresponding corrective action will be discussed with personnel in the other Maintenance and Engineering departments.
(4) Date When Full Compliance Will Be Achieved Testing on SM-615 was completed on June 15, 1987 and appropriate personnel counselling was performed the day after the event.
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Counselling of other maintenance and engineering personnel will be achieved by September 1, 1987.
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