IR 05000382/1989018

Insp Rept 50-382/89-18 on 890626-30.Noncited Violation Noted.Major Areas Inspected:Corrective Action Program & Licensee Actions on Previously Identified Findings

ML20247K665
Person / Time
Site:	Waterford
Issue date:	07/13/1989
From:	Barnes I, Ellershaw L, Gilbert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247K654	List: IR 05000382/1989018 ML20247K649
References
50-382-89-18, IEIN-89-022, IEIN-89-22, NUDOCS 8908010023
Download: ML20247K665 (9)

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APPENDIX f U.S. NUCLEAR REGULATORY-COMMISSION l REGION IV F

L NRC Inspection Report: 50-?B2/89-18 Operating License: NPF-38

' Docket: 50-382 q Licensee:- Louisiana Power & Light Company (LP&L)

Facility Name: Waterford Steam Electric Station Unit 3-(WAT-3)

Inspection At: WAT-3. Taft Louisiana

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Inspection Conducted: June 26-30, 1989 j Inspectors.: I8es 7- # 3 - B'1

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

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f t. E. Ellershaw, Reactor Inspector, Materials- Fate-and Quality. Programs Section. Division of

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Reactnr Safetv 1 l

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Approved: 8w 7 - 83 -8'?

l I. Barnes, Chief Materials and Quality Date-Programs Section Division of Reactor Safety l

Inspection Sumc.ary Inspection Conducted June 26-30, 1989 (Report 50-382/89-18)

Areas Inspected: Routine, unannounced inspection of the corrective action !

program and licensee actions on previously identified finding Results: In general, the corrective action program has been defined in plant procedures and connitted corrective action program enhancements have been l implemented. A noncited violation (NCV) was identified (paragraph 3)

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s90so10023 890717 PDR ADOCK 05000382 o FDC

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'l , , g JJ 2 fsr failure to accomplish activities affecting. quality in accordance with~ a l pre,scribedprocedure;i.e;,~failuretoprovideobjective"evidencerequiredto ,

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substantiate verification and closure of supplier corrective' action.+ In j

, ._. addition,,anunresolvedLitemwasidentified(paragraph ~3)'.in"regardto' j

'n . performance and documentation of corrective actions for radiological

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DETAILS

. I' . . Persons Contacted-L LPa*.' r

• D.F. Packer,AssistantPlantMabager-OperationsandMaintenance

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• P. V. Prasankumar, Assistant Plant Manager - Technical Services >

• J. J.;Zabritski, Quality Assurance Manager

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• D.'E. Baker, Nuclear Operations Support and Assessment Manager

. *R. L., Azzarello,. Nuclear Operations Engine <ering and Construction Manager i

• L. W. Laughlin, Site Licensing Supervisor  ;

• L.: L. ' Bass, Nuclear Operations Engineering and Construction Engineer .  :

• J. A. Ridgel; Lead Health ~ Physics Supervisor .

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• P. N. Backes,' Programs Engineering Supervisor

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J. R. McGaha, Plant Manager-  ;

G. M. Davis, Event Analysis Manager-  ;

W. E. Day,. Events Analysis Supervisor

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NRC

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• T. R; Staker,: Resident Inspector The3RC inspebtor'also interviewed other licensee employees during the *

inspectio * Denotes attendance at exit interview conducted on June 30, 198 j

! Licensee Actions on Previously Identified Inspection Findings (92701)

(Closed) Unresolved. item (382/8902-05): This unresolved item pertained to i the adequacy of documentation for fastener material which was supplied to LP&L i from Hardware Specialty Company (HSC) Inc., with respect to complying with- j ASME Code requirements.- -

The unresolved item was a precursor to an NRC inspection performed at HSC' l during February 7-10, 1989. This inspection resulted in the issuance of  ;

NRC Information Notice 89-22 " Questionable Certification of Fasteners."  !

LP&L, as a result of the unresolved item and the Information Notice, l conducted an investigation into the adequacy of documentation end f astener l material upplied by HSC. This included'a review of documentation and j

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testing d'c sample of fasteners. The conclusion was that the documentat * m exhibited deficiencies; however, except for minor l deviation).. t he fastener material met the requirements of the material specifications. A review was made of those fasteners for which questions regarding heat treatment and physical testing (charpy impact tests) still .

remaineo in order to determine the installed location. It was determined i

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that the fasteners were used in either non ASME applications or in

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installations for which the failure to have charpy impact tests was of no concern. In one case, it could not be determined if the fasteners had been properly heat treated. These particuler studs were installed in the fuel transfer tube saddle support and are being replace It would appear that LP&L has acted appropriately in response to the unresolved item and the Information Notice; therefore, this item is close . Corrective Action (92720)

The objective of this inspection was to determine whether LP&L has developed a compnhensive corrective action program to identify, follow, and correct safet -; elated problem %e NRC inspectors reviewed the licensee policy statements and commitments expressed in Section 17.2 of the LP&L Final Safety Analysis Report (FSAR)

and Section 6 of the Technical Specifications regarding the corrective action program, and enhancements delineated in LP&L Letter W3P89-0145

' dated January 31, 1989. The corrective action progra.n has been promulgated into the Nuclear Operations Management Manual and further defined in the following implementing procedures:

' Nuclear Operations Procedure N0P-005, Revision 2.0, " Corrective Action"

• Quality Assurance Procedure QAP-012 Revision 8.0, " Quality Notice"

' * Administrative Procedure UNT-5-002, Revision 8 Change 2, " Condition Identification" i

Administrative Procedure UitT-6-014, Revision 1 Change 2, " Root Cause Determination and Trend Analysis"

• Quality Assurance Procedure QAP-207. Revision 3.0, " Supplier Quality Assurance Corrective Action Reports" Quality Assurance Procedure QAP-250, Revision 8.0, " Material Receipt Inspection" Administrative Procedure HP-1-112, Revision 5, Change 1,

" Radiological Deficiency Reporting"

• Administrative Procedure UNT-6-010. Revision 5, Change 1. " Event Notification and Peporting"

• Nuclear Operations Procedure NOP-Oll, Revision 0.0, " Commitments Management Systim" i

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These procedures establish management controls.for the trocking and

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resolution of problems identified by. operational events, c,uality assurance ,

audits, NRC findings, employees, or any other person or organizatio The NRC inspectors verified that the licensee.has approved and implemente the Corrective Action Review Subcommittee to the Safety Review Committe Charter, which was a commitment to NRC in the area of-corrective actio program enhancements. The subcommittee meetings and. timeliness of m .. corrective actions were discussed with the Chairman.' The subcommittee has- ,

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been tracking the timeliness of corrective actions and reporting to:

management those corrective actions that N ye been open for more than~ ,

120 days. The timeliness for completing corrective actions has shown  !

1mprovement based on the trend analysis over the past 12 month !

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The trend analysis. reports for the fourth quarter of 1988 and the first

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quarter of 1989 were reviewed, which included ~ root cause and trending -

information for problems identified during each 3-month perio The NRC. inspectors selected problems which had been recently identified

.and reviewed t h tracking and resolution of each issue. For this review, j the selection was made from problems documented on Quality Notice i Nonconforming Condition Identifications, Corrective' Action Reports, Deficiency Notices, Radiological Deficiency Reports, and Potential Reportable Events. The problem reports selected for review are listed in  ;

the Attachment to this repor j During review of Radiological Deficiency Reports (RDRs), it was noted that RDR 89-4 dated February 1, 1989, stated in part, "There has been a recurring problem with nonhealth physics personne; mosing radiological 3 i

postings.-. The most frequent violation is outside the North Letdown Valve Galley door. This posting is moved almost daily, causing an unbolted radiation area to exist." The corrective action section of the RDR was signed and dated February 8, 1989, and stated, "This issue was discussed at the mornirg Plan-of-Day meetings, and plant supervisors were directed to inform their personnel to contact HP (Health Physics) before I moving any postings." . RDR 89-5 dated February 2,1989, identified that the radiation posting rope hao been untied thus creating an unposted radiation area. This was in the same location as stated-in RDR 89-4. The corrective action section stated. "See RDR 89-4." Because of the seriousness of the subject matter and the fact that it appears to have been a fairly common occurrence. the NRC inspectors requested the licensee :l C to provide documentation which would substantiate that the corrective i actions had been performed and documented as required by Administrative

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Procedure HP-1-112. The NRC inspectors did not identify this condition until just before the exit interview, thus the licensee did not have adequate time to assemble and present any substantiating documentation which review might exist. Therefore, of the documentation this item required shall remain by Procedure unresolved HP-1-11 pending )

(382/8918-01

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During review of Corrective Action Reports (CARS) and associated; documentation pertaining to Telemecanique, Inc. (TE), there appeared to be conflicting and/or missing information which did not tend to support closure of two of the seven CARS. The licensee performed a Quality .

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Assurance Audit (A35.39.262-88.1)'at TE during April 11-12, 1988. During

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that audit, conditions were identified which resulted in the issuance of

.- seven CARS. The audit report,, including.the. CARS .were transmitted to

/ TE by letter dated May 17, 1988.. CAR 2 identified that TE had been

" unable to provide objective evidence that the design characteristics of all their products has not changed since the original date of their product qualification as Class IE equipment." Under separate enve letter, LP&L provided to TE a list of the equipment causing concern. 'This consisted of 17. different types of equipment in varying quantities which had been purchased after December 31, 1985. TE responded to the audi report and provided corrective action to the CARS by letter dated June 9 .

1988. The corrective action' for CAR 2 addressed just one type of equipment and the fact that they had not received the necessary design control information from their. supplier. TE stated that when the information was received, it would be provided to LP&L. Subsequently, LP&L performed a -

surveillance at TE during March 13-17, 1989, in which one of the activities performed was a verification of TE's corrective actions with respect to the seven CARS. LP&L transmitted letter W3K89-0270 dated April 3, 1989, to TE, which stated that the corrective actions had been verified and found to be acceptable. The CAR had also been signed and dated to show acceptance, verification, and closure. In addition, a statement had been typed on the form which stated that the design information for the one type of equipment had been reviewed and accepted. However, the original audit findings addressed 17 types of equipment, not just one. In addition,.

an internal LP&L letter to file (L3K89-0282) dated April 17, 1989, also stated that the corrective actior:was verified to be in compliance; thus the CAR was close Subsequent to the identification of this condition by the NRC inspector, the LP&L auditor provided a letter (which he had in his personal files)

from TE dated May 24, 1988, which addressed all 17 types of equipment and the fact that objective evidence was on file to support equipment qualification. The LP&L auditor stated that even though the closure statement on the CAR addresses just one type of equipment, he actual reviewed the qualifications of all 17. The LP&L auditor proceeded te have CAR 2 amended to reflect that information, which he signed and date CAR 5 addressed TE's failure to perform certain quality control inspections with report to painting and coatings as required by procedure. TE.provided corrective actions which were reviewed and accepted by LP&L as stated in theirletter(W3K89-0270 dated April 3, 1989) to TE. A typed statement on the CAR stated, "This audit finding is considered closed due to discontinuance of the Telemecanique 10 CFR 50 QA program after July 31, 1989." This was initialed and dated by the LP&L auditor. However, the LP&L auditor's letter to file (W3K89-0282 dated April 17,1989) stated that CAR 5 was not

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closed because of the discontinuance of the TE 10'CFR 50 Appendix B.QA' ~

program after July 31,1988. The NRC. inspector questioned the validity of the date with; respect to TEs discontinuance of their 10 CFR Part 50 Appendi:: B program in view of the fact that TE was listed on the.currentJ

.QualifiedSuppliers2 List (QSL)asbeinganacceptablesupplierbasedon-o their.having a'10 CFR Part 50 Appendix B program. The LP8L auditor then proceeded to amend the letter to file by correc. ting.the date of TEs discontinuance of an Appendix'B-QA program to July 31, 1989. He also amended the statement on the CAR to show that procurement of painted products is prohibited and that this restriction is now incorporated into the QS As a result of the' identification of the above conditions Quality .

Notice (QN) No. QA-89-148 was written on June 30, 1989, to document-the failure to comply with paragraph 5.4.4'of Procedure QAP-207. Revision LP&L committed to perfonn a review of;all closed CARS in order to evaluate and correct'any. CARS found-to be in noncompliance with Procedure QAP-207, G - with respect to having the objective evidence necessary for verificatio "and close-out. This is an apparent violation for failure.to accomplish

> activities affecting quality in accordance with a, prescribed procedure; however, the violation is not being cited because-it is of minor safety ,

significance and meets the criteria specified in Sect',on V.A. of the Enforcement Polic (NCY382/8918-02)

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' . Exit Interview q An exit interview was conducted on June 30, 1989, wit'h those personnel denoted in paragraph 1. At the exit interview, the NRC inspectors-summarized the inspection findings. No information was presented to the NRC inspectors' that was identified by the licensee as proprietar +

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ATTACHMENT

Quality Notices (ONs)

QN-QA-89-004 QN-QA-89-018 QN-QA-89-027 QN-QA-89-031 QN-QA-89-054'

QN-QA-89-057 QN-QA-89-061 QN-QA-89-074 QN-QA-89-102 QN-QA-89-117 QN-QA-89-135

• Corrective Action Reports (CARS)

CAR 1 for Audit S39.069-88.1 of Mechanical Testing Laboratory '

CAR 1 thtu 7 for Audit A35.39.262-88.1 of Telemecaniqu CAR 1 for Audit Q-3-A35.39.402-89.1 of BIW Connector Systems, In CAR 1 thru 3 for Audit A39.267-88.1 of US Testing Company, In CAR 1 for Audit A39.411-88.1 of CYGNA Energy Services ,

Discrepancy Hotices (DNs)

DN No. 04685-89 for Arreron Protective Coatings DN No. 04648-89 for Teledyne Analytical instrument ,

I DN No. 04644-89 for Henze-Movats DN No. 04643-89 for Paul Munroe Enertech DN No. 04641-89 for Nova Machine Products Cor DN No. 04638-89 for Conax Buffalo Cor DN No. 04691-89 for Ott Process Equipment DN No. 04574-89 for Sorrento Electronics, In !

DN No. 04678-89 for Hilti Industries, In DN No. 04679-89 for Hilti Industries, In DN No. 04675-89 for Anchor Darling Valve Company DN No. 04653-89 for United Technologies Carrier Cor :

• Potential Reportable Events (PRES)

PRE 89-014 PRE 89-019

• Radiological Deficiency Reports (RDRs)

RDR 89-1 RDR 89-2 ,

RDR 89-3 RDR 89-4 RDR 89-5 RDR 89-6 i

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• Nonconforming Condition ?dratliitations '(CIs)

'CI 263232 WA 01038858 CI 262392 WA 01035812 C1 262871 WA 01037132 CI 260306 WA 01033334 CI'261819 WA 01933419 CI 259817 WA 01028884 CI 258613 WA 01025759 C1 258200 WA 01024550 CI 260438 WA 01029647

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