IR 05000382/1989012

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-12.Excluding Incident 1,Violation 382/8912-02 Should Stand as Cited. Response W/Corrective Actions Requested within 30 Days

ML20245J516
Person / Time
Site:	Waterford
Issue date:	08/11/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8908180056
Download: ML20245J516 (3)

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, AUG i i 1989

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In Reply Refer To:

Docket: 50-382/89-12 Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 <

Gentlemen:

Thank you for your letter of July 10, 1989, in response to our letter and Notice of Violation, dated June 9, 1989. We have considered your request to reevaluate Violation 382/8912-02. In Incident No.1, you explained that the torque switch terminal washer stackup was determined to be acceptable whether or not it matched the vendor technical manual assembly drawing, based on subsequent discussion with the vendor. While the vendor may not have considered the stackup important, the assembly drawing illustrated what appeared to be a proper washer stackup, contrary to the way it was installed. In view of the vendor's position, we hereby withdraw that portion of the violation you have designated as Incident No. In Incident No. 2, your response contended that the splices in MS-416 were

" acceptable." If they had not been acceptable for that particular application, the. inspectors would have questioned.the operability of the valve. The issue was procedure inadequacy and the continuing discrepancies over the past year between the splice procedure and the applicable drawing. We emphasized this issue in the inspection report summary. Because the procedure was not kept current with the associated drawing changes, the subject splices did not receive insulating tape in the " crotch" of the splices as required by Step 3. of the current drawing change notice. Your response failed to address these facts even though we discussed them with your staff as well as the actions you will take to end these continuing splice procedure / drawing conflicts. We also noted that, although the above deficiencies were identified by the inspector on May 12, 1989, the procedure was still not corrected as of July 21, 1989. Your responsiveness in correcting the specific problem did not appear to be timel We have discussed these issues again with your staff on July 24, 1989, and concluded that excluding Incident No.1, the violation should stand as cite Please provide a supplemental response, within 30 days of the date of this letter, which includes the corrective steps which will be taken to avoid further violations of this kind and the date when full compliance will be achieved.

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Louisiana Power & Light Company -2-We have reviewed your reply to Violation 382/8912-03 and find it 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 maintaine

Sincerely, odginalsigned By:

Thomas P.Gwynn James L. Milboan, Director Division of Reactor Projects cc:

Louisiana Power & Light Company ATTN: J. R. McGaha, Vice President Nuclear Operations P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: R. F. Bur.ki, Manager Nuclear Safety & Regulatory Affairs 317 Baronne Street New Orleans, Louisiana 70160 Louisiana Power & Light Company ATTN: L. W. Laughlin, Site Licensing Support Supervisor P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATIN: G. M. Davis, Manager Everts Analysis Reporting and Response P.O. Box B Killona, Louisiana 70066 f Middle South Services ATTN: Mr. R. T. Lally P.O. Box E1000 New Orleans, Louisiana 70161 Louisiana Radiation' Control Program Director

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LOUISIANA POWER & LIGHT / INTER-OFFICE COAMESPONOENCE NUSNIYS W3P89-3073 A4.05 QA July 10, 1989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 SES Docket No. 50-382

) License No. NPF-38 NRC Inspection Report 89-12 Gentlemen:

In accordance with 10 CFR Part 2.201, Louisiana Power 6 Light hereby submits in Attachment 1 the responses to the Violations identified in Appendix A of the subject Inspection Repor If you have any questions concerning these responses, please contact L.W. Laughlin at (504) 464-349 Very t uly yours,

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R(/f. Burski Manager f

Nuclear Safety & Regulatory Affairs RFB/DMU/ssf Attachment cc: Messrs.JR.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR 7 -]

D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office i

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Attachment to W3P89-3073 Page 1 of 5 ATTACHMENT 1 LP&L Responses to the Violations Identified in Appendix A of Incpection Report 89-12

, VIOLATION NO. 8912-02 Inadequate Maintenance Procedure Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A to Regulatory Guide 1.33 recommends maintenance on safety-related equipment to be performed in accordance with written procedures appropriate to the circumstance Contrary to the above, on May 11 and 12, 1989, the instructions in Work Authorization 01037167 were not appropriate and resulted in incorrect washer stacking on the torque switch terminals and improper power supply cable splices during motor actuator reassembly for Valve MS-41 This is a Severity Level IV violatio NOTE: Two separate incidents are identified in this violatio For clarity each will be addressed separatel RESPONSE TO INCIDENT NO. 1 LP&L does not believe that incident No. 1 in Violation 8912-02 constitutes inappropriate work instructions or that incorrect washer stacking occurre In accordance with the work instructions of WA 01037167 the torque switch for the motor operator of Valve MS-416 was replaced. The motor operator for this valve is a Limitorque type SMB-000. Because the Limitorque vendor manual (457000468) does not provide specific written instructions for stacking washers on a torque switch terminal, it has been LP&L's practice to reinstall the washers as originally found during determinatio The NRC Inspector has taken exception to this practice s.nd contends that washer stacking on torque switch terminals should be in accordance with page 9 of section A in the Limitorque vendor manual. This page of the vendor manual consists of four diagrams and a parts list for the torque switch used in the SMB-000 motor operator. This page does not contain any written instructions for washer stacking on torque switch terminal i However, by comparing four part numbers from two separate diagrams against the parts list, the Inspector felt a pictoral washer stacking arrangement l could be derived from this pag )

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Attachment to W3P89-3073 Page 2 of 5 Maintenance personnel have contacted Limitorque for information regarding L

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washer stacking on torque switch terminals. Limitorque's response was that there is no specific washer stacking arrangement required on the SMB-000 torque switch terminals. Page 9 of the vendor manual is for parts listing and is not intended to be an assembly drawing. As long as all components are used, the stacking order does not affect the termination. Limitorque further stated that no particular sequence is used during initial assembl Identical mocel torque switches could have different w& sher stacking arrangements when purchased and this is acceptabl A new SMB-000 torque switch was subsequently drawn from warehouse stock for examination. The washer stacking arrangement of this torque switch, received under MRIR 1689-85, did not match the pictoral representation on page 9 of the vendor manual. It was however the same arrangement technicians originally used on the torque switch for MS-41 Based on the manufacturers' statements, there is no perticular washer stacking arrangement required on torque switch terminals. As long as all components are used the termination is acceptable. LP&L's practice of reinstalling the washers as originally found is therefore appropriat . _ _______ _________________________

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Attachment to W3PS9-3073 Page 3 of 5 RESPONSE TO INCIDENT NO. 2 LP&L denies incident No. 2 in Violation 8912-02 as written. The violation states that instructions in WA 01037167 were not appropriate and resulted in improper power supply cable splices. It is LP&L's contention that the splices made.per the above WA are acceptabl According to the instructions in the above work package, technicians were directed to splice the power leads for the motor operator on valve MS-416 in accordance with ME-4-809, section 8.5.2. This section requires the splice be insulated per LOU-1564-B-288 sheet 40 step 6. The subject splices were made in accordance with the WA instructions and this drawin Contrary to what is stated in the violation, a splice made in accordance

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with parts A through F ef step 6 on drawing LOU-1564-B-288 sheet 40 is a proper power supply cable splic LP&L does acknowledge that at the time the splices were performed, a procedure / drawing discrepancy did exist. Drawing B-288 sheet 40 was revised by drawing revision notice (DRN) No. E-8900125. The general notes on this page were revised to be consistent with the splice details and General Notes on Drawing B-288 sheet 3 The general notes on B-288 sheet 40 were revised and renumbered. What had been note 6 became note Although the note numbering changed, the insulating instructions remained essentially the sam Maintenance personnel working under WA 01037167 had both versions of B-288 sheet 40 in their work packag In accordance with the instructions of the work package, the technicians performed the motor lead splices in accordance with note 6 of the superceded drawing as directed by ME-4-809 step 8.5.2.3. The technicians were aware of the discrepancy caused by the DRN and should have suspended work until the matter was clarifie However, the existence of a note numbering inconsistency in no way detracts from the acceptability of the splices. The splices had been performed in accordance with a valid method and are therefore acceptabl In recognition of what occurred, Quality Notice QN No. QA-89-124 was immediately written on the above procedure deficiency. As part of the response to the QN, ME-4-809 revision 4 will be revised to eliminate the note conflict with drawing B-288 sheet 4 Furthermore, Maintenance personnel will be instructed as to the proper course of action should procedural discrepancies of this nature be encountered in the futur Based on the information provided above, LP&L requests that incident Nos. I and 2 of Violation 8912-02 be re-evaluated.

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Page 4 of 5 VIOLATION NO. 8912-03

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Failure to Fo.llow' Radiological Protection Control Procedures Technical Specification 6.11.1 requires, in part, that approved procedures for personnel radiation protection shall be adhered to for all operations involving personnel radiation exposure. Paragraph 4.8.6 of approved radiation protection Procedure HP-1-110, Revision 8. " Radiation Work-Permits," requires observing and abiding by radiation work permits and posted radiological signs. Standing Rediation Work Permit (RWP) 89000002 requires Health Physics permission prior to entering radiologically restricted or high radiation areas. In addition, RWP 89000002 requires full anti-contamination protective clcthing when climbing into contaminated area Contrary to the above, on May 26, 1989, an auxiliary operator entered the Low Pressure. Safety Injection Pump area, which had radiological postings stating " Radiological Restricted Are," "High Radiation Area," and "No Entry Without Health Physics Permission," without obtaining Health Physics permission. In addition, several operations personnel were observed climbing in areas posted as contaminated without wearing required full protective clothin )

This is a Severity Level IV violatio RESPONSE-(1) Reason For The Violation The root cause of this violation was failure by Operations personnel to comply with Paragraph 4.8.6 of Radiation Protection Procedure HP-1-110, Revision 9 which states that individuals working under a radiation work permit are responsible for observing and abiding by the radiation work permit and the radiological signs posted within the RCA. Radiation Work Permit (RWP) 89000002, Task Number 1, addresses nuclear auxiliary operations watchstanding duties (RAB & RCA) and valve line-ups, including entry into high radiation area Items 1 and 9 of the special instructions in this RWP state the following:  ; Minimum protective clothing requirements for contaminated areas are partial protective clothing (cotton liners, rubber gloves, plastic booties, and rubber overshoes) unless otherwise specified i by Health Physics. Kneeling / sitting / climbing in contaminated areas requires full protective clothin . Contact Health Physics prior to entering radiologically l restricted areas, high radiation areas, or zone 3 hot particle )

area l Contrary to special instruction #1, several Operations personnel were ,

observed by the NRC Resident Inspector climbing in areas posted as  !

contaminated without wearing full protective clothing (P.C.'s).

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Attachment to W3P89-3073-Page_5 of 5

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-Also~, on May 26, 1969 at approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />, the NRC Resident

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inspector observed an infraction of special instruction #9. An

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auxiliary operator, already dressed in' full ~ protective clothing and inside the contaminated area of the B safeguards pump room, reached across-6 radiologically restricted area boundary to operate valve S1-1142B vithout first obtainit.g Health Physics permissio ,(2) Corrective Steps That Have Been Taken And The Results Achieved Radiological Defici6ncy Report 89-12 was written against the auxiliar operator for reaching across a radiologically restricted area boundary. The operator's TLD was pulled and he was counselled on'the requirements for entering radiologically regtricted areas.. The operator vas then required to attend General Employee Training (GET)

2,~ Radiation Worker Training requalification, prior to having his TLD reissued,and assuming his normal duties. An Operations. department-daily instruction' entry.was made to emphasize the requirements of-notifying Health. Physics department prior.to entering' radiologically restricted area ' In addition, letter number W3089-0058 dated June 22, 1989 from the-Operations Superintendent was is. sued to the.0perations departmen to stress their responsibility for observing and abiding by radiological signs posted within the RCA and RWP instructions, in-particular climbing without full protective clothin .(3) Corrective Steps Which Will Be Taken To Avoid Further Violations The actions taken in (2) should prevent a recurrence of this type of violation in the futur (4). Date When Full Compliance Will Be Achieved Based on the above information, LP&L is currently in full complianc I

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