IR 05000382/1988011

Insp Rept 50-382/88-11 on 880418-22.Violations Noted.Major Areas Inspected:Licensee Action on Previously Identified Insp Findings,Inservice Insp & 10CFR21

ML20154J826
Person / Time
Site:	Waterford
Issue date:	05/16/1988
From:	Barnes I, Gilbert L, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154J819	List: IR 05000382/1988011 ML20154J814 ML20154J821
References
50-382-88-11, NUDOCS 8805270148
Download: ML20154J826 (8)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/88-11 Operating License: HPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

N-80 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford 3 Steam Electric Station (WAT)

Inspection At: WAT, Taft, Louisiana Inspection Conducted: April 18-22,1988 Inspectors: //7a- 5" / 6 - Pd'

Date gfer L. D. Gilbert, Reactor Inspector, Materials and Quality Programs Section, Division of Reactor Safety

$ 8a.n wn r- n, -17 Date p'R.C. Stewart,ReactorInspector,Materialsand Quality Programs Section, Division of Reactor Safety

/ 75,m r - n, - 29 1. Barnes, Chief, Materials and Quality Programs Date Section, Division of Reactor Safety Other Accompanying Personnel: J. Guillen, Generic Communications Branch, Office of Nuclear Reactor Regulation Approved: I W w -/ 5 -/ 6 - P!P I. Barnes, Chief, Materials and Quality Programs Date Section, Division of Reactor Safety 8805270148 880523 PDR ADOCK 05000382 o DCD

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_2 Inspection Summary Inspection Conducted April 18-22, 1988 (Report-50-382/88-11)

Areas Inspected: Routine, unannounced inspection of licensee action on

.previously identified inspection findings, inservice inspection, and 10 CFR

. Part 2 Results: Within the three' areas inspected, one' violation was identified (failure to follow procedures with respect to evaluation of Quality Notices for 10 CFR Part 21 reportability, paragraph 4).

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DETAILS Persons Contacted LP&L

• N. S. Carns, Plant Manager

'*T. F. Gerrets, Nuclear Services Manager

• S. A. Alleman, Quality Assurance Manager

• D. Vinci, Maintenance Manager

• G. E. Wuller, Operational Licensing Supervisor

• G. W. Robin, Nuclear Operations Engineering-Inservice Inspection

• D. Gallodoro, Nuclear Operations Engineering-Procurement

• C. Gaines, Event Analysis Review & Reporting

• L. Bass, Nuclear 0perations Engineering-

• M. Meyer, Nuclear Operations Engineering

• R. G. Azzarello, Nuclear Operations Engineering J. G. Dickinson, Operations Quality Assurance NRC

• F. Smith, Senior Resident Inspector

• D. D. Chamberlain, Chief, Project Section A

• T. R. Staker, Resident inspector

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The NRC inspectors also interviewed other licensee and contractor employees during the inspectio * Denotes those present at exit intervie . Licensee Act'on on Previously Identified Inspection Findings (92701 and 92702) (Closed) Unresolved Item 382/8631-03: Technical Discrepancies in Westinghouse Procedure for Qualification and Certification of Visual Examination Personnel - The technical discrepancies in Westinghouse Procedure QA 2.4, Revision 0, have been resolved in Revision 1 and Addendum LP&L-1, Revision 0, to the procedure. Procedure QA 2.4 is now consistent with the provisions of Regulatory Guide 1.58 and ANSI N45.2.b for qualification of visual exan11 nation personnel. The NRC inspector reviewee the licensee's evaluation of the Westinghouse personnel used for performing visual examinations and discussed the evaluation reports with the licensee's Level III for nondestructive examinations. The NRC inspector determined that the Westinghouse visual examination personnel qualifications were consistent with the revised procedure. This item is considered risolve '

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-4- (Closed) Violation (382/8721-01): Failure to Evaluate Out-of-Calibration Test Equipment in a Timely Manner - The licensee's Station Information Management System (SIMS) is now being utilized in tracking of M&TE nonconformances. Each user department is now responsible for planning the work authorization within that department. In addition, Procedure UNT-5-009, "Disposition of M&TE Nonconformances," has been revised (Revision 1 dated January 11,1988) to include provisions for the nonconformance evaluator to request an extension in time for performance of the evaluation. During this inspection, the NRC inspector reviewed Revision 1 of Procedure UNT-5-009 and witnessed a demonstration of the SIMS computer tracking program for M&TE nonconformances. The NRC inspector had no further questions regarding this matte This item is considered close . Inservice Inspection (73051, 73052, 73753 and 73755) Review of Program and Procedures The NRC inspectors reviewed the changes to the inservice inspection program and the NRC interim approval letter dated March 25, 1988, for Revisions 2 and 3 to the 10 year progra The NRC inspectors determined that Westinghouse has not revised the inservice inspection procedures since the last outage. However, LP&L has issued several new procedures. The following new LP&L procedures were reviewed:

Administrative Procedure MD-1-022, Revision 0, "Section XI Repairs and Replacements";

Procedure N0EP-251, Revision 0, "Control of Inservice Inspection"; and

Quality Assurance Procedure QAP-353, Revision 1 "Visual Examination."

In the areas reviewed, the inservice inspection program and procedures were consistent with the requirements of ASME Section XI, 1980 Edition through Winter 1981 Addenda, Observation of Work The NRC inspectors observed the manual ultrasonic examination of two welds, weld Nos.41-001 and 41-022, on main steam header A of steam generator No. 1. The examinations were consistent with the program plan and examination Procedure WTR-ISI-206, Revision 0, Field Change 1. The personnel performing the examinations were certified to the level required in Procedure WTR-ISI-206. The ultrasonic equipment, search units, and couplant used in performing the examination were certified as required by Procedure WTR-ISI-20 . - - - . . . -

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-5- Record Review The NRC inspectors reviewed the First Outage Inservice Inspection Summary Report, Revision 0 and selected two repairs and two replacements for a review of the documentation records. The repair and replacement record packages reviewed are ldentified below:

Repair of leaking pipe flange on Line 2804-2 which was documented in Condition Identification Work Authorization (CIWA)

No. 02597 *

Replacement of valve IA-910 which was documented in CIWA No. 02797 Repair of cracked weld in line 2 CHI-28 which was documented in CIWA No. 03119 Replacement of valve CVC-103 which was documented in CIWA Nos. 020552 and 02055 The NRC inspectors also reviewed the nondestructive examination records of the most recent inservice examinations listed below:

Surface and volumetric examination data sheets for eight reactor coolant system welds, six safety injection system welds, and one feedwater system pressure retaining wel Pressure test with visual examination data reports for the fuel pool cooling system and the low pressure safety injection syste Visual examination data sheets for ten piping support In the areas inspected, the records were complete, the data was being compared to the preservice inspection data, and the licensee was utilizing the services of a third party inspection agency in the inservice inspection progra No violations or deviations were identified in this area of inspectio . 10 CFR Part 21 Inspection (36100)

The purpose of this inspection was to determine whether the licensee had established and implemented procedures and controls which provide for

evaluating of deviations, assuring that defects or failures to comply are I reported to the NRC and that records applicable to these activities are established and maintained.

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-6-a. Posting

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The NRC inspector examined notice boards in the Administration and Site Support Buildings and verified that a notice which complied with the posting requirements of 10 CFR Part 21 was presen No violations or deviations were identified in this area of the inspection, b. Review of Procedures In order to assess 10 CFR Part 21 procedural controls with respect to evaluation and tracking of potentially reportable conditions, the NRC inspector reviewed the following documents: 4 Nuclear Services Procedure NSP-105, "Compliance with 10 CFR 21 Reporting of Defects and Noncompliances," Revision 0, effective date January 16, 1985, and Revision 1, effective date February 24, 1987;

Nuclear Operations Procedure N0P-005, "Corrective Action," Revision 1, effective date October 26, 1987; Nuclear Services Procedure NSP-106, "Coninitments Management System," Revision 3, effective date November 11, 1986; and QA Procedure QAP-007, "Reportability Screening of Documents Identifying Conditions Adverse to Quality," Revision 1, effective date February 26, 198 From this review, it was ascertained that the lead responsibility for review and coordination of pottntially reportable 10 CFR Part 21 items is currently assigned to the onsite licensing function. The NRC inspector was informed by LP&L personnel that this review l

activity was planned to be transferred to the Event Analysis l Reporting and Response grou The NRC inspector reviewed the l tracking of potential 10 CFR Part 21 items which had been received from external sources and examined the review logs maintained by the site licensing supervisor for Quality Notices (QNs) and Deficiency Notices (DNs).

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As a result of review of the QN log, the NRC inspector noted that l there was no entry to indicate that a review had been performed of 31 QNs which had been generated during 1986 and 1987.

l Paragraph 5.1.5 of Procedure N0P-005, Revision 1, requires that a

! copy of each QN be sent to licensing for 10 CFR Part 21 review. The NRC inspector obtained a printout of valid QNs from QA and l

' ascertained that 14 of the 31 QNs had been invalidated subsequent to issue. From review of records, QA personnel established that receipt had been acknowledged by licensing for 10 of the 17 unreviewed valid l

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. -7-QNs; i.e., QA 86-124, QA 86-134, QA 86-054, QA 86-027, QA 86-005,

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QA 86-009, QA 87-116, QA 87-077, QA 87-066, and QA 87-007. Receipt

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had not been acknowledged by licensing for the remaining seven valid QNs; i .e. , QA 86-137, QA 86-090, QA'87-123, QA 87-113, QA 87-069, QA 87-028, and QA 87-001. Paragraph 5.1.3 of Procedure NSP-105, Revisions 0 and 1, requires licensing to review QNs for 10 CFR Part 21 reportability and document the reviews on a review shee The failure to implement procedural commitmen'.s with respect to transmittal and review of QNs for 10 CFR Part 21 reportability is an apparent violation (382/8811-01).

c. Spec _tfication of Applicability of 10 CFR Part 21 in Procurement Focaments The NRC inspector selected seven purchase orders (P0s) (i.e.,

WP 015245, WP 017960, WP 017941, WP 017330, WP 017178, WP 016713, and WP 016707) for safety-related materials and components in order to determine whether the requirements of 10 CFR Part 21 were being appropriately imposed on LP&L vendor Each P0 was found to impose 10 CFR Part 21 on the vendo No violations or deviations were identified in this area of the inspectio d. Review of 10 CFR Part 21 Evaluations (1) Heinemann Circuit Breakers: During an audit performed in March 1988 at Systems Control, Iron Mountain, Michigan, the LP&L auditors identified that commercial grade Heinemann 30 amp circuit breakers had been utilized by Systems Control for two LP&L P0s for safety-related equipment. P0 L-105967-P was issued by LP&L for one Heinemann 30 amp circuit breaker and P0 L-85177-K was issued for one 120 VAC isolation pane The isolation panel contained two 30 amp circuit breaker Both P0s imposed 10 CFR Part 21 on the vendor and contained equipment qualification requirements that had been applied to original equipmen The NRC resident inspector was informed of these i

findings by LP&L.

l The NRC inspector ascertained that a final determination of l reportability had not been completed as of this inspection. The circuit breaker received on P0 L-105967-P was established by l

l LP&L to be in a warehouse and had been downgraded by DN to nonsafety-related applications. The NRC inspector was infonned l

l by LP&L personnel that the circuit breakers in the isolation i panel had been damaged during installation of the panel and had been replaced with qualified circuit breakers. This replacement activity is censidered an open item pending NRC review of the l applicable documentation (382/8811-02). Examinations were in l

progress of installed safety-related circuit breakers which had i

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-8-been received from Systems Control subsequent to the last date that LP&L had data to substantiate that safety-related Heinemann circuit breakers had been procured by Systems Control (i.e.,

November 1983). As of this inspection, 6 of 11 installed circuit breakers in this category had been inspected, with manufacturing date codes from 1978 to 1983 being found. The NRC inspector will perform a review of the completed evaluation during followup of the above open ite (2) Other Evaluations: Insufficient time was available during this inspection to review completed 10 CFR Part 21 evaluation Inspection of this activity will be performed during followup of the above open ite No violations or deviations were identified in this area of the inspectio . Exit Interview The NRC inspectors summarized the inspection scope and findings on April 22,1988, with those persons identified in paragraph 1.

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